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Two or three countries, side by side, one row per question. Pick up to 3.

Countries

NetherlandsChecked 18 August 2026

Depends on your industryWork: HighEnforcement: Aggressive

In one paragraph: For most businesses the Netherlands follows the ordinary European rules: data may leave the country once you have the right paperwork in place. Two areas are much harder. Online gambling firms must keep their regulator-facing database physically in the Netherlands, and central government now has to keep all its information inside Europe. The Dutch privacy regulator hands out some of the largest transfer fines in Europe.
The catch: The relaxed headline stops being true the moment you touch online gambling, central government work, health records or a regulated financial firm. An online gambling licence forces one database onto Dutch soil. Central government contracts now bar storage outside Europe. And a brand-new cybersecurity law switched on three days ago, on 15 August 2026, with a 24-hour incident alarm most companies have not built yet.
Does this apply to me?: Yes, it reaches you with no Dutch office. Europe's privacy law applies to any organisation anywhere that offers goods or services to people in the Netherlands or watches what they do online, and there is no size or revenue floor. Separately, the new Dutch cybersecurity law says that if you are a cloud provider, data centre, managed service provider, online marketplace, search engine or social network based outside Europe but selling into the Netherlands, you must appoint a representative inside the European Union.High confidence
Can the data leave the country?: In general yes, with paperwork, because the Netherlands is an EU country and European rules govern transfers. But three Dutch walls override that. An online gambling licence holder must physically place its regulator-facing control database in the Netherlands. Central government must keep all its information inside the European Economic Area plus Switzerland. And a healthcare provider, bank or insurer can put data abroad only if the supervisor can still see and audit it.High confidence
What do I have to do to send it abroad?: The model is an allowlist run at European level, not a Dutch one. You may send personal data outside Europe only if the destination has been officially approved, or you sign the standard European contract, or you use approved group-wide rules. The approved list is full and active. The Netherlands adds no national approval step and keeps no blocklist of its own.High confidence
Who enforces this — and are they actually working?: The Dutch Data Protection Authority, and it is very much operational and very much willing to fine. It has a full three-person board, and a new chair, Geert Potjewijd, took office on 1 August 2026. It has issued two of the largest cross-border transfer fines in Europe: 290 million euros against Uber in 2024 and 100 million euros against a taxi app in May 2026. Cybersecurity is enforced separately, by sector ministries and inspectorates, and that machinery is only now being assembled.High confidence
How long must I keep it, and when must I delete it?: There is a firm floor and a soft ceiling. You must keep your books and tax records for seven years, and money-laundering records for five years after the relationship or transaction ends. Against that, privacy law says you must delete personal data once you no longer need it, and there is no fixed number. When the two collide, the legal duty to keep wins for as long as it lasts, and deletion follows immediately after.High confidence
What happens when something goes wrong?: Count three clocks, not one. For a personal data breach you have 72 hours to tell the Dutch Data Protection Authority. If you are covered by the new cybersecurity law that started on 15 August 2026, you must raise an early warning within 24 hours, file a full report within 72 hours, and deliver a final report within one month. Telecom operators have a fourth clock and must tell the privacy regulator without delay.High confidence
What's the trap?: Five things that are not in the summary. Your works council can block an HR or monitoring system. Breaking a professional secrecy duty is a crime, not a fine. The telecom retention duty printed in the law cannot be enforced. Children need a parent's permission until they turn sixteen. And the new cybersecurity law started on 15 August 2026 with a phased exception for universities that most checklists miss.High confidence
What's about to change?: Three dated changes. On 1 September 2026 an amendment act tidies up the Dutch privacy law and adds new rules for handing over health files, but one part of it has deliberately been left switched off. Registration and incident duties under the cybersecurity law that started on 15 August 2026 are being phased in now. And by 12 January 2027 every cloud provider must drop switching and data export charges to zero across Europe.High confidence
Hardest industry wall: Online gaming — Besluit kansspelen op afstand, artikel 4.42, tweede lid
Government — Herziening rijksbreed cloudbeleid 2026

UkraineChecked 18 August 2026

Depends on your industryWork: MediumEnforcement: Active

In one paragraph: Ukraine still runs its 2010 privacy law, not a European-style one. Personal data may leave the country only to a country the law treats as safe — that means Europe and the 50-odd countries that signed a Council of Europe data treaty. The United States is not on that list. Fines are tiny, but the human rights Commissioner really does inspect, and misusing data can be a crime.
The catch: The general picture changes completely once government is involved. If a Ukrainian state body is the organisation deciding how personal data is used, only a Ukrainian state-owned or municipal company may process that data for it — a private or foreign supplier cannot. State systems, defence data and critical infrastructure also carry hard location rules, and several of the current permissions exist only because the country is under martial law.
Does this apply to me?: Probably not, if you have nothing in Ukraine. The 2010 law simply says it covers the processing of personal data by automated means or in structured paper files. It contains no clause reaching foreign companies that only sell into Ukraine from abroad, and it does not make you appoint a local representative. There is no size or revenue threshold either — a corner shop and a bank are treated the same.Medium confidence
Can the data leave the country?: Yes, but only to countries Ukraine already treats as safe. Those are the European Economic Area countries plus every country that has signed the Council of Europe's data protection treaty — roughly 55 states. The United States has signed neither, so routine transfers to American servers do not fit the safe-country route and need one of the narrow exceptions instead. Whole sectors then override this: government, defence and critical infrastructure are far tighter, and securities firms are unusually looser.High confidence
What do I have to do to send it abroad?: There is no form to file and no government permission to obtain. You either send the data to a country the law already treats as safe, or you rely on one of five narrow exceptions. Those are: the person's clear consent, necessity for a contract made for that person's benefit, protecting someone's life, an important public interest or a legal claim, and the sender giving guarantees that private and family life will not be interfered with. That last one is a catch-all that a lot of Ukrainian practice leans on.High confidence
Who enforces this — and are they actually working?: The Ukrainian Parliament Commissioner for Human Rights — the national ombudsman — is the data protection regulator, and it is genuinely working. It publishes a fresh inspection programme every three months; the one for July to September 2026 went up on 2 July 2026. It also publishes what it found, including a run of checks on the national electronic health system. The catch is the money: the regulator cannot fine anyone itself, it writes up a case and sends it to a court, and the maximum penalty is about $800.High confidence
How long must I keep it, and when must I delete it?: The floor comes from tax law. Companies must keep primary accounting documents and financial statements for 1,825 days — five years. Papers needed for transfer pricing checks run to 2,555 days, which is seven years. Everything else the tax authority may ask for runs 1,095 days, three years. The ceiling comes from the privacy law: you must delete personal data when the agreed storage period runs out, or when your relationship with the person ends, unless another law tells you to keep it.High confidence
What happens when something goes wrong?: This is the biggest surprise in Ukrainian law: if you lose personal data, there is no duty to tell the regulator and no duty to tell the people affected. The 2010 privacy law simply has no breach reporting clause. The only mandatory clocks sit in the cyber security regime, and they only bite if you run a state system or a piece of critical information infrastructure. Even there the law does not set the hours — it leaves the deadline to an order of the cyber agency.Medium confidence
What's the trap?: Five. (1) If a Ukrainian government body is the one deciding how personal data is used, only a Ukrainian state-owned or municipal company may handle that data for it — a private or foreign supplier is not allowed at all. (2) Misusing personal data is a crime, not just a fine, and repeat offences carry up to five years in prison. (3) The fines are aimed at named individuals and sole traders, not at companies. (4) Posting anything that shows where Ukrainian troops are carries five to eight years in prison. (5) Martial law lets the government limit the constitutional right to privacy that the whole system rests on.High confidence
What's about to change?: The date to watch is not a new law — it is the end of the war. Martial law was extended again on 13 July 2026 and now runs from 2 August 2026 for 90 days, so to about 31 October 2026. Several of today's permissions exist only while it lasts, and they die six months after it ends. A European-style replacement privacy law has been discussed for years and has still not been passed, so nothing about the current regime should be planned around its arrival.High confidence
Hardest industry wall: Government — Закон України "Про захист персональних даних", частина третя статті 4
Government — Закон України "Про захист інформації в інформаційно-комунікаційних системах"
Defence — Закон України "Про хмарні послуги"
Mapping and location — Кримінальний кодекс України, стаття 114-2

The eight framework questions answered for each selected country
Question	NetherlandsChecked 18 August 2026	UkraineChecked 18 August 2026
The three ratings	Depends on your industry Work: High Enforcement: Aggressive	Depends on your industry Work: Medium Enforcement: Active
In one paragraph	For most businesses the Netherlands follows the ordinary European rules: data may leave the country once you have the right paperwork in place. Two areas are much harder. Online gambling firms must keep their regulator-facing database physically in the Netherlands, and central government now has to keep all its information inside Europe. The Dutch privacy regulator hands out some of the largest transfer fines in Europe.	Ukraine still runs its 2010 privacy law, not a European-style one. Personal data may leave the country only to a country the law treats as safe — that means Europe and the 50-odd countries that signed a Council of Europe data treaty. The United States is not on that list. Fines are tiny, but the human rights Commissioner really does inspect, and misusing data can be a crime.
The catch	The relaxed headline stops being true the moment you touch online gambling, central government work, health records or a regulated financial firm. An online gambling licence forces one database onto Dutch soil. Central government contracts now bar storage outside Europe. And a brand-new cybersecurity law switched on three days ago, on 15 August 2026, with a 24-hour incident alarm most companies have not built yet.	The general picture changes completely once government is involved. If a Ukrainian state body is the organisation deciding how personal data is used, only a Ukrainian state-owned or municipal company may process that data for it — a private or foreign supplier cannot. State systems, defence data and critical infrastructure also carry hard location rules, and several of the current permissions exist only because the country is under martial law.
Does this apply to me?	Yes, it reaches you with no Dutch office. Europe's privacy law applies to any organisation anywhere that offers goods or services to people in the Netherlands or watches what they do online, and there is no size or revenue floor. Separately, the new Dutch cybersecurity law says that if you are a cloud provider, data centre, managed service provider, online marketplace, search engine or social network based outside Europe but selling into the Netherlands, you must appoint a representative inside the European Union.High confidence	Probably not, if you have nothing in Ukraine. The 2010 law simply says it covers the processing of personal data by automated means or in structured paper files. It contains no clause reaching foreign companies that only sell into Ukraine from abroad, and it does not make you appoint a local representative. There is no size or revenue threshold either — a corner shop and a bank are treated the same.Medium confidence
Can the data leave the country?	In general yes, with paperwork, because the Netherlands is an EU country and European rules govern transfers. But three Dutch walls override that. An online gambling licence holder must physically place its regulator-facing control database in the Netherlands. Central government must keep all its information inside the European Economic Area plus Switzerland. And a healthcare provider, bank or insurer can put data abroad only if the supervisor can still see and audit it.High confidence	Yes, but only to countries Ukraine already treats as safe. Those are the European Economic Area countries plus every country that has signed the Council of Europe's data protection treaty — roughly 55 states. The United States has signed neither, so routine transfers to American servers do not fit the safe-country route and need one of the narrow exceptions instead. Whole sectors then override this: government, defence and critical infrastructure are far tighter, and securities firms are unusually looser.High confidence
What do I have to do to send it abroad?	The model is an allowlist run at European level, not a Dutch one. You may send personal data outside Europe only if the destination has been officially approved, or you sign the standard European contract, or you use approved group-wide rules. The approved list is full and active. The Netherlands adds no national approval step and keeps no blocklist of its own.High confidence	There is no form to file and no government permission to obtain. You either send the data to a country the law already treats as safe, or you rely on one of five narrow exceptions. Those are: the person's clear consent, necessity for a contract made for that person's benefit, protecting someone's life, an important public interest or a legal claim, and the sender giving guarantees that private and family life will not be interfered with. That last one is a catch-all that a lot of Ukrainian practice leans on.High confidence
Who enforces this — and are they actually working?	The Dutch Data Protection Authority, and it is very much operational and very much willing to fine. It has a full three-person board, and a new chair, Geert Potjewijd, took office on 1 August 2026. It has issued two of the largest cross-border transfer fines in Europe: 290 million euros against Uber in 2024 and 100 million euros against a taxi app in May 2026. Cybersecurity is enforced separately, by sector ministries and inspectorates, and that machinery is only now being assembled.High confidence	The Ukrainian Parliament Commissioner for Human Rights — the national ombudsman — is the data protection regulator, and it is genuinely working. It publishes a fresh inspection programme every three months; the one for July to September 2026 went up on 2 July 2026. It also publishes what it found, including a run of checks on the national electronic health system. The catch is the money: the regulator cannot fine anyone itself, it writes up a case and sends it to a court, and the maximum penalty is about $800.High confidence
How long must I keep it, and when must I delete it?	There is a firm floor and a soft ceiling. You must keep your books and tax records for seven years, and money-laundering records for five years after the relationship or transaction ends. Against that, privacy law says you must delete personal data once you no longer need it, and there is no fixed number. When the two collide, the legal duty to keep wins for as long as it lasts, and deletion follows immediately after.High confidence	The floor comes from tax law. Companies must keep primary accounting documents and financial statements for 1,825 days — five years. Papers needed for transfer pricing checks run to 2,555 days, which is seven years. Everything else the tax authority may ask for runs 1,095 days, three years. The ceiling comes from the privacy law: you must delete personal data when the agreed storage period runs out, or when your relationship with the person ends, unless another law tells you to keep it.High confidence
What happens when something goes wrong?	Count three clocks, not one. For a personal data breach you have 72 hours to tell the Dutch Data Protection Authority. If you are covered by the new cybersecurity law that started on 15 August 2026, you must raise an early warning within 24 hours, file a full report within 72 hours, and deliver a final report within one month. Telecom operators have a fourth clock and must tell the privacy regulator without delay.High confidence	This is the biggest surprise in Ukrainian law: if you lose personal data, there is no duty to tell the regulator and no duty to tell the people affected. The 2010 privacy law simply has no breach reporting clause. The only mandatory clocks sit in the cyber security regime, and they only bite if you run a state system or a piece of critical information infrastructure. Even there the law does not set the hours — it leaves the deadline to an order of the cyber agency.Medium confidence
What's the trap?	Five things that are not in the summary. Your works council can block an HR or monitoring system. Breaking a professional secrecy duty is a crime, not a fine. The telecom retention duty printed in the law cannot be enforced. Children need a parent's permission until they turn sixteen. And the new cybersecurity law started on 15 August 2026 with a phased exception for universities that most checklists miss.High confidence	Five. (1) If a Ukrainian government body is the one deciding how personal data is used, only a Ukrainian state-owned or municipal company may handle that data for it — a private or foreign supplier is not allowed at all. (2) Misusing personal data is a crime, not just a fine, and repeat offences carry up to five years in prison. (3) The fines are aimed at named individuals and sole traders, not at companies. (4) Posting anything that shows where Ukrainian troops are carries five to eight years in prison. (5) Martial law lets the government limit the constitutional right to privacy that the whole system rests on.High confidence
What's about to change?	Three dated changes. On 1 September 2026 an amendment act tidies up the Dutch privacy law and adds new rules for handing over health files, but one part of it has deliberately been left switched off. Registration and incident duties under the cybersecurity law that started on 15 August 2026 are being phased in now. And by 12 January 2027 every cloud provider must drop switching and data export charges to zero across Europe.High confidence	The date to watch is not a new law — it is the end of the war. Martial law was extended again on 13 July 2026 and now runs from 2 August 2026 for 90 days, so to about 31 October 2026. Several of today's permissions exist only while it lasts, and they die six months after it ends. A European-style replacement privacy law has been discussed for years and has still not been passed, so nothing about the current regime should be planned around its arrival.High confidence
Hardest industry wall	Online gaming — Besluit kansspelen op afstand, artikel 4.42, tweede lid Government — Herziening rijksbreed cloudbeleid 2026	Government — Закон України "Про захист персональних даних", частина третя статті 4 Government — Закон України "Про захист інформації в інформаційно-комунікаційних системах" Defence — Закон України "Про хмарні послуги" Mapping and location — Кримінальний кодекс України, стаття 114-2