Compare countries

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

Countries

PolandChecked 18 August 2026

Yes, with paperworkWork: HighEnforcement: Active

In one paragraph: Poland is a European Union country, so data may leave as long as you use one of the approved European transfer routes. We found no general Polish rule forcing data to stay in the country. The privacy regulator is fully staffed and busy, and it fines government bodies as well as companies. Finance is the sector to watch: the financial supervisor wants cloud data kept in Europe.
The catch: True in general, much weaker in finance. Banks, insurers, brokers and payment firms follow a supervisory notice telling them to keep cloud data in European data centres, to put critical firms' data inside Poland first where they can, and to warn the financial supervisor 14 days before any cloud project starts. That notice is a strong recommendation, not a ban — but the supervisor checks it. Classified government information sits outside all of this and is effectively locked inside Poland.
Does this apply to me?: Yes, it reaches you with no office in Poland. European privacy law applies to any organisation anywhere that offers goods or services to people in Poland, or that monitors their behaviour. There is no size or revenue threshold. An organisation based outside Europe normally has to name a representative inside Europe. Poland then adds one local step that foreign groups routinely miss: if you must appoint a data protection officer, you have to tell the Polish regulator that person's name and contact details within 14 days of appointing them.High confidence
Can the data leave the country?: Yes, with paperwork. Poland has not added a general rule of its own that keeps data inside the country, and European law actually forbids member states from imposing storage-location rules on data that is not about people, except on public-security grounds. We searched for industry walls in banking, payments, insurance, securities, health, telecoms, government cloud, mapping and gambling. The only one we could confirm from an official Polish source is in finance, and it is a firm supervisory recommendation rather than an outright ban.Medium confidence
What do I have to do to send it abroad?: Think of it as an approved-routes list. Personal data may go outside Europe if the destination country has been officially approved, or if you sign the standard European contract with the recipient, or if your corporate group has rules approved by a regulator. The approved-country list is real and populated — roughly sixteen countries plus one international organisation. For the United States it only covers companies that have signed up to a specific certification scheme, so you have to check the recipient, not the country.High confidence
Who enforces this — and are they actually working?: The Personal Data Protection Office, and it is genuinely working. It is led by Mirosław Wróblewski, it publishes news several times a week, and its public decisions database held 581 decisions when we checked on 18 August 2026, with new ones published through June and July 2026. It fines public bodies too: it penalised the Minister of Justice in June 2026 and a local social welfare centre later the same month. Three other regulators matter — the financial supervisor for banks and insurers, the electronic communications office for telecoms and post, and the Ministry of Digital Affairs for cyber security.High confidence
How long must I keep it, and when must I delete it?: There is a ceiling and a floor. The ceiling is European: you may not keep personal data in a form that identifies someone for longer than you need it, and you have to be able to state that period. The floor is Polish: tax, accounting, employment and medical rules force you to keep certain records for years. When the two collide, the specific keeping duty wins for those records and everything else must still be deleted on time. We could not open the official Polish texts for the exact periods on the day we checked, so treat any specific number you read elsewhere as unverified until you see the statute.Medium confidence
What happens when something goes wrong?: Count at least two clocks, often three. For a personal data breach you have 72 hours to tell the Polish privacy regulator, and you must warn the people affected without undue delay if the risk to them is high. Separately, Poland rewrote its cyber security law and the new version started on 3 April 2026; if you are on the new register of key or important organisations you also report to the national cyber teams, on a much shorter first clock. Financial firms add a third set of reporting duties to the financial supervisor. The overlap is what breaks people, because the same incident triggers all three with different content and different deadlines.Medium confidence
What's the trap?: Five things that are not in the summary. First, appointing a data protection officer is not the end of it — you have 14 days to file that person's name and contact details with the Polish regulator, and foreign groups miss this constantly. Second, the list of Polish organisations that must appoint one is wider than expected and includes the central bank and state research institutes. Third, a brand-new Polish law on data management started in July 2026 and can fine you about two million złoty, roughly $550,000, for sending protected public-sector data to the wrong country. Fourth, the financial supervisor expects to be told 14 days before a cloud project starts and wants critical firms' data inside Poland where possible. Fifth, being a public body is no shield — the regulator fined the Minister of Justice in June 2026.High confidence
What's about to change?: Three dated things and one live risk. Poland's new cyber security register is being phased in through 2026: self-registration opened on 7 May 2026, and organisations the ministry enters itself get six months from being served notice to complete their details. On 12 January 2027 European rules ban cloud providers from charging you anything to move your data out. On 2 April 2027 a new European regulation on how privacy regulators run cross-border cases starts to apply, which will change how Polish complaints against foreign companies are handled. The live risk is the European Union–United States data transfer arrangement, which is valid today but being challenged.High confidence
Hardest industry wall: None found.

FranceChecked 18 August 2026

Depends on your industryWork: HighEnforcement: Aggressive

In one paragraph: France follows the European rule: data may leave, but only once the right paperwork is in place. France then adds hard walls of its own. Health records must be stored inside Europe. Online gambling records must sit on a machine in mainland France. From 1 September 2026 the invoicing platform every French business must use has to run entirely from inside Europe.
The catch: "France has no local storage rule" is true for an ordinary business and false the moment you touch health data, online gambling, electronic invoicing or a government contract involving sensitive state data. In those four areas France is among the strictest countries in Europe. Since March 2026 the health rule sits in a decree, not just a certification standard, so it now binds the customer as well as the supplier.
Does this apply to me?: Yes. France reaches a company with no office in the country. European law already applies to anyone offering goods or services to people in Europe. On top of that, France's own privacy law says its national rules apply as soon as the person concerned lives in France, even when the company is based somewhere else. There is no size or revenue threshold that lets you escape.High confidence
Can the data leave the country?: For an ordinary business, yes, with paperwork: the European transfer rules apply and nothing extra is added. But four French sectors override that. Health records must be stored inside Europe and nowhere else. Online gambling records must be archived in real time on hardware in mainland France. Electronic invoicing platforms must run their whole system from inside Europe. And sensitive state data must sit on a cloud that the French cyber agency has certified as beyond the reach of foreign authorities.High confidence
What do I have to do to send it abroad?: The model is an approved-list one, run from Brussels rather than Paris. Data may go to a country the European Commission has formally approved, or anywhere else if you sign the official standard contract and write down why you think the data will still be safe. The list of approved countries is full, not empty: it includes the United Kingdom, Japan, South Korea, Canada, Switzerland, Brazil and about a dozen others, plus American companies that have signed up to the transatlantic framework. France adds no separate national approval step.High confidence
Who enforces this — and are they actually working?: The privacy regulator is the CNIL, and it is one of the busiest in Europe. In 2025 alone it issued 83 penalties totalling about 487 million euros (roughly 530 million dollars), plus 143 formal warnings. It is still fining in 2026: 5 million euros against the national employment agency in January and 5 million against a health data company in May. Separate regulators run the sector walls, and all of them are staffed and working.High confidence
How long must I keep it, and when must I delete it?: There is a floor and a ceiling and they pull in opposite directions. You must keep accounting books and supporting documents for ten years, tax records for six, employment contracts and pay records for five, and telephone and internet subscriber identity data for five. In the other direction, European law says you must delete personal data once you no longer need it. France resolves the clash the same way most of Europe does: the legal minimum wins, but only for the specific documents the law names, and only for as long as it names.High confidence
What happens when something goes wrong?: Count the clocks, because France has at least four and they run at different speeds. Every organisation has 72 hours to tell the CNIL about a personal data breach. Telephone and internet providers have only 24 hours. Hospitals and clinics must report a serious computer security incident to their regional health agency immediately. Banks, insurers and investment firms have their own European deadlines: an initial report within 4 hours of classifying a major incident and no later than 24 hours after they notice it.High confidence
What's the trap?: Five things that are not in the summary. (1) Breaking the privacy law in France is a crime, not just a fine: sending data out of Europe unlawfully carries up to five years in prison and a 300,000 euro fine (about 330,000 dollars), and it attaches to people, not only companies. (2) A child is anyone under 15 for consent, not 13 or 16. (3) A 2023 law setting a social media age of 15 is printed in the statute book but has never come into force and cannot be enforced. (4) Handing documents to a foreign court or regulator can itself be a criminal offence in France. (5) Cookies are policed separately from the rest of privacy law, so a foreign company cannot hide behind its lead European regulator.High confidence
What's about to change?: Four dates in the next twelve months. 1 September 2026: every French business must be able to send and receive invoices through an approved platform, and those platforms must run entirely from inside Europe. Around 27 September 2026: the second phase of the health data hosting decree starts. 21 October 2026: the order forcing telephone and internet companies to keep everyone's connection records for a year expires unless the Prime Minister renews it. 12 January 2027: cloud providers across Europe must drop switching and data export fees to zero.Medium confidence
Hardest industry wall: Health and social care — Decret n° 2026-209 du 24 mars 2026 portant modification de certaines dispositions du code de la sante publique relatives a l'hebergement de donnees de sante a caractere personnel
Government — Decret n° 2026-272 du 14 avril 2026 relatif a la protection des donnees d'une sensibilite particuliere des administrations, operateurs et groupements d'interet public de l'Etat traitees par un service d'informatique en nuage fourni par un prestataire prive
All industries — Immatriculation des plateformes agreees (ex plateformes de dematerialisation partenaires) - facturation electronique
Online gaming — Article 31 de la loi n° 2010-476 du 12 mai 2010 relative a l'ouverture a la concurrence et a la regulation du secteur des jeux d'argent et de hasard en ligne

The eight framework questions answered for each selected country
Question	PolandChecked 18 August 2026	FranceChecked 18 August 2026
The three ratings	Yes, with paperwork Work: High Enforcement: Active	Depends on your industry Work: High Enforcement: Aggressive
In one paragraph	Poland is a European Union country, so data may leave as long as you use one of the approved European transfer routes. We found no general Polish rule forcing data to stay in the country. The privacy regulator is fully staffed and busy, and it fines government bodies as well as companies. Finance is the sector to watch: the financial supervisor wants cloud data kept in Europe.	France follows the European rule: data may leave, but only once the right paperwork is in place. France then adds hard walls of its own. Health records must be stored inside Europe. Online gambling records must sit on a machine in mainland France. From 1 September 2026 the invoicing platform every French business must use has to run entirely from inside Europe.
The catch	True in general, much weaker in finance. Banks, insurers, brokers and payment firms follow a supervisory notice telling them to keep cloud data in European data centres, to put critical firms' data inside Poland first where they can, and to warn the financial supervisor 14 days before any cloud project starts. That notice is a strong recommendation, not a ban — but the supervisor checks it. Classified government information sits outside all of this and is effectively locked inside Poland.	"France has no local storage rule" is true for an ordinary business and false the moment you touch health data, online gambling, electronic invoicing or a government contract involving sensitive state data. In those four areas France is among the strictest countries in Europe. Since March 2026 the health rule sits in a decree, not just a certification standard, so it now binds the customer as well as the supplier.
Does this apply to me?	Yes, it reaches you with no office in Poland. European privacy law applies to any organisation anywhere that offers goods or services to people in Poland, or that monitors their behaviour. There is no size or revenue threshold. An organisation based outside Europe normally has to name a representative inside Europe. Poland then adds one local step that foreign groups routinely miss: if you must appoint a data protection officer, you have to tell the Polish regulator that person's name and contact details within 14 days of appointing them.High confidence	Yes. France reaches a company with no office in the country. European law already applies to anyone offering goods or services to people in Europe. On top of that, France's own privacy law says its national rules apply as soon as the person concerned lives in France, even when the company is based somewhere else. There is no size or revenue threshold that lets you escape.High confidence
Can the data leave the country?	Yes, with paperwork. Poland has not added a general rule of its own that keeps data inside the country, and European law actually forbids member states from imposing storage-location rules on data that is not about people, except on public-security grounds. We searched for industry walls in banking, payments, insurance, securities, health, telecoms, government cloud, mapping and gambling. The only one we could confirm from an official Polish source is in finance, and it is a firm supervisory recommendation rather than an outright ban.Medium confidence	For an ordinary business, yes, with paperwork: the European transfer rules apply and nothing extra is added. But four French sectors override that. Health records must be stored inside Europe and nowhere else. Online gambling records must be archived in real time on hardware in mainland France. Electronic invoicing platforms must run their whole system from inside Europe. And sensitive state data must sit on a cloud that the French cyber agency has certified as beyond the reach of foreign authorities.High confidence
What do I have to do to send it abroad?	Think of it as an approved-routes list. Personal data may go outside Europe if the destination country has been officially approved, or if you sign the standard European contract with the recipient, or if your corporate group has rules approved by a regulator. The approved-country list is real and populated — roughly sixteen countries plus one international organisation. For the United States it only covers companies that have signed up to a specific certification scheme, so you have to check the recipient, not the country.High confidence	The model is an approved-list one, run from Brussels rather than Paris. Data may go to a country the European Commission has formally approved, or anywhere else if you sign the official standard contract and write down why you think the data will still be safe. The list of approved countries is full, not empty: it includes the United Kingdom, Japan, South Korea, Canada, Switzerland, Brazil and about a dozen others, plus American companies that have signed up to the transatlantic framework. France adds no separate national approval step.High confidence
Who enforces this — and are they actually working?	The Personal Data Protection Office, and it is genuinely working. It is led by Mirosław Wróblewski, it publishes news several times a week, and its public decisions database held 581 decisions when we checked on 18 August 2026, with new ones published through June and July 2026. It fines public bodies too: it penalised the Minister of Justice in June 2026 and a local social welfare centre later the same month. Three other regulators matter — the financial supervisor for banks and insurers, the electronic communications office for telecoms and post, and the Ministry of Digital Affairs for cyber security.High confidence	The privacy regulator is the CNIL, and it is one of the busiest in Europe. In 2025 alone it issued 83 penalties totalling about 487 million euros (roughly 530 million dollars), plus 143 formal warnings. It is still fining in 2026: 5 million euros against the national employment agency in January and 5 million against a health data company in May. Separate regulators run the sector walls, and all of them are staffed and working.High confidence
How long must I keep it, and when must I delete it?	There is a ceiling and a floor. The ceiling is European: you may not keep personal data in a form that identifies someone for longer than you need it, and you have to be able to state that period. The floor is Polish: tax, accounting, employment and medical rules force you to keep certain records for years. When the two collide, the specific keeping duty wins for those records and everything else must still be deleted on time. We could not open the official Polish texts for the exact periods on the day we checked, so treat any specific number you read elsewhere as unverified until you see the statute.Medium confidence	There is a floor and a ceiling and they pull in opposite directions. You must keep accounting books and supporting documents for ten years, tax records for six, employment contracts and pay records for five, and telephone and internet subscriber identity data for five. In the other direction, European law says you must delete personal data once you no longer need it. France resolves the clash the same way most of Europe does: the legal minimum wins, but only for the specific documents the law names, and only for as long as it names.High confidence
What happens when something goes wrong?	Count at least two clocks, often three. For a personal data breach you have 72 hours to tell the Polish privacy regulator, and you must warn the people affected without undue delay if the risk to them is high. Separately, Poland rewrote its cyber security law and the new version started on 3 April 2026; if you are on the new register of key or important organisations you also report to the national cyber teams, on a much shorter first clock. Financial firms add a third set of reporting duties to the financial supervisor. The overlap is what breaks people, because the same incident triggers all three with different content and different deadlines.Medium confidence	Count the clocks, because France has at least four and they run at different speeds. Every organisation has 72 hours to tell the CNIL about a personal data breach. Telephone and internet providers have only 24 hours. Hospitals and clinics must report a serious computer security incident to their regional health agency immediately. Banks, insurers and investment firms have their own European deadlines: an initial report within 4 hours of classifying a major incident and no later than 24 hours after they notice it.High confidence
What's the trap?	Five things that are not in the summary. First, appointing a data protection officer is not the end of it — you have 14 days to file that person's name and contact details with the Polish regulator, and foreign groups miss this constantly. Second, the list of Polish organisations that must appoint one is wider than expected and includes the central bank and state research institutes. Third, a brand-new Polish law on data management started in July 2026 and can fine you about two million złoty, roughly $550,000, for sending protected public-sector data to the wrong country. Fourth, the financial supervisor expects to be told 14 days before a cloud project starts and wants critical firms' data inside Poland where possible. Fifth, being a public body is no shield — the regulator fined the Minister of Justice in June 2026.High confidence	Five things that are not in the summary. (1) Breaking the privacy law in France is a crime, not just a fine: sending data out of Europe unlawfully carries up to five years in prison and a 300,000 euro fine (about 330,000 dollars), and it attaches to people, not only companies. (2) A child is anyone under 15 for consent, not 13 or 16. (3) A 2023 law setting a social media age of 15 is printed in the statute book but has never come into force and cannot be enforced. (4) Handing documents to a foreign court or regulator can itself be a criminal offence in France. (5) Cookies are policed separately from the rest of privacy law, so a foreign company cannot hide behind its lead European regulator.High confidence
What's about to change?	Three dated things and one live risk. Poland's new cyber security register is being phased in through 2026: self-registration opened on 7 May 2026, and organisations the ministry enters itself get six months from being served notice to complete their details. On 12 January 2027 European rules ban cloud providers from charging you anything to move your data out. On 2 April 2027 a new European regulation on how privacy regulators run cross-border cases starts to apply, which will change how Polish complaints against foreign companies are handled. The live risk is the European Union–United States data transfer arrangement, which is valid today but being challenged.High confidence	Four dates in the next twelve months. 1 September 2026: every French business must be able to send and receive invoices through an approved platform, and those platforms must run entirely from inside Europe. Around 27 September 2026: the second phase of the health data hosting decree starts. 21 October 2026: the order forcing telephone and internet companies to keep everyone's connection records for a year expires unless the Prime Minister renews it. 12 January 2027: cloud providers across Europe must drop switching and data export fees to zero.Medium confidence
Hardest industry wall	None found.	Health and social care — Decret n° 2026-209 du 24 mars 2026 portant modification de certaines dispositions du code de la sante publique relatives a l'hebergement de donnees de sante a caractere personnel Government — Decret n° 2026-272 du 14 avril 2026 relatif a la protection des donnees d'une sensibilite particuliere des administrations, operateurs et groupements d'interet public de l'Etat traitees par un service d'informatique en nuage fourni par un prestataire prive All industries — Immatriculation des plateformes agreees (ex plateformes de dematerialisation partenaires) - facturation electronique Online gaming — Article 31 de la loi n° 2010-476 du 12 mai 2010 relative a l'ouverture a la concurrence et a la regulation du secteur des jeux d'argent et de hasard en ligne