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Countries

SerbiaChecked 18 August 2026

Yes, with paperworkWork: HighEnforcement: Active

In one paragraph: Serbia copied Europe's privacy law almost word for word, so the duties feel familiar. Data can leave the country, and for most of Europe and a long list of other countries it can leave with no paperwork at all. The privacy regulator is busy — over a thousand inspections in 2025 — but it hands out warnings, not fines. The biggest fine any Serbian court imposed for a privacy breach in 2025 was about $950.
The catch: Two industries break the general picture. Online gambling operators must keep a copy of their whole player and transaction database physically inside Serbia. Banks, insurers and other financial firms cannot move any IT work abroad without telling the central bank 30 days ahead, proving the foreign country would let Serbian supervisors inspect on site, and risking a veto that forces them to cancel the contract.
Does this apply to me?: Yes. The law reaches a company anywhere in the world if it offers goods or services to people in Serbia, or watches what they do in Serbia. There is no size or revenue threshold to hide behind. If you are caught this way you must appoint a written representative living or based in Serbia, unless your processing is occasional and low risk or you are a public body.High confidence
Can the data leave the country?: Yes, with paperwork — and often with none at all. Serbia treats a very long list of countries as automatically safe: every member of the Council of Europe's data protection treaty, which covers all of Europe plus Argentina, Mexico, Morocco, Mauritius, Senegal, Tunisia, Uruguay, Cape Verde and others, and separately every country the European Union has approved. Sending data there needs no permission and no contract. Everywhere else you sign the Commissioner's standard contract or use approved group rules. Only one industry has a hard wall: online gambling. Banking has a gate rather than a wall.High confidence
What do I have to do to send it abroad?: First check the destination. If it is on the safe list, you need nothing — no contract, no filing, no approval. If it is not, you sign the standard contract the Serbian regulator published in January 2020, or you get approved group-wide rules. If you want to use your own wording instead of the standard contract, the regulator must approve it and has 60 days to answer. As a last resort there are narrow exceptions such as the person's explicit consent.High confidence
Who enforces this — and are they actually working?: The Commissioner for Information of Public Importance and Personal Data Protection, and it is genuinely working. In 2025 it finished 1,169 inspections, received 5,310 cases and issued 102 corrective orders. But it almost never fines. Of those 102 orders, 101 were warnings and one was a ban on processing. It asked the courts to punish only three organisations all year. Banks answer to the National Bank of Serbia instead, and it is fully active. A brand-new Office for Information Security exists on paper since October 2025 but we could find no sign it is running yet.High confidence
How long must I keep it, and when must I delete it?: There is no single national rule. The privacy law says keep data only as long as you need it, and each sector sets its own clock. Online gambling operators must keep every transaction for at least ten years. Phone and internet companies must keep who-called-whom records for exactly 12 months and then destroy them. Anyone selling a phone line must keep the customer's identity check for 12 months after the service ends. Financial firms must keep a live register of every outsourced service, including which countries the data sits in.High confidence
What happens when something goes wrong?: Count three clocks. Privacy breach: tell the Commissioner without delay and at the latest within 72 hours, and if you miss that you must explain why. Cyber incident: if you run an information system the state has classed as important, you have only 24 hours to report it. Then a third clock starts — updates every 24 hours for a serious incident, every three days for a middling one, and a final report within 15 days of the incident ending. Banks report cyber incidents to the central bank instead, promptly, with no fixed hour count.High confidence
What's the trap?: Five. (1) A child can consent for themselves at 15, not 13 or 16 — plan your age gates around 15. (2) A foreign court order or foreign tax authority demand for data is recognised in Serbia only if a treaty backs it, so handing data to an overseas authority on request can itself be unlawful. (3) Individuals, not just companies, can be prosecuted; the regulator has filed 49 criminal complaints since 2010. (4) Dozens of older Serbian laws still contradict the privacy law and were never fixed. (5) The government's official list of safe destination countries has not been touched since 2019 and still names a United States framework that died in 2020.High confidence
What's about to change?: One dated change and several unscheduled ones. From 1 January 2027 the ministry formally takes over supervising the new Office for Information Security, which should mean the office is actually up and running by then. A rewrite of the privacy law is being drafted by a special working group covering video surveillance, biometrics, genetic data and artificial intelligence, and a separate group is drafting an artificial intelligence law. Neither has been published as a bill, so neither is binding.High confidence
Hardest industry wall: Online gaming — Pravilnik o informaciono-komunikacionom sistemu za priređivanje posebnih igara na sreću preko sredstava elektronske komunikacije

AzerbaijanChecked 18 August 2026

Yes, with paperworkWork: HighEnforcement: Waking up

In one paragraph: Azerbaijan has had a personal data law since 2010. Data may leave the country, but only if you decide the destination protects it as well as Azerbaijan does, and you must declare those exports up front. The real cost is not the export rule. It is that you must register your database with the state before you collect a single record.
The catch: The easy-sounding export rule hides where the work actually is. Nothing may be collected until the system holding it sits on a state register, and the government's security rules are unusually specific, down to the encryption key length and where the archive building may stand. Banking and payments have no separate storage wall, but a new cybersecurity regime started in August 2026 and a social media law bites in 2027.
Does this apply to me?: The law is silent about foreign companies, and that silence is the answer. Unlike Europe's rules, Azerbaijan's personal data law has no clause reaching organisations abroad that sell to Azerbaijanis. What it does have is a duty on the 'owner' of a database to register it with the state before collecting anything, and that duty is enforced through the register in Baku. A foreign company with no Azerbaijani entity has no realistic way to register, and no regulator has said whether it must. From 2027 one narrow group of foreign firms is caught by name: social network providers offering services to users in Azerbaijan must set up a local branch or representative office.Medium confidence
Can the data leave the country?: Yes, with conditions, and the condition is a judgement call you make yourself. Azerbaijan bans sending personal data abroad in only two situations: where it would threaten national security, or where the destination country's law does not protect the data to the standard Azerbaijani law sets. Nobody publishes a list of good or bad countries, so you decide, and you carry the risk. If the person has consented, or if the transfer is needed to protect their life or health, the destination's standard stops mattering at all. We looked hard for industry walls in banking, payments, insurance, securities, telecoms and health and found none that force data to stay in the country.High confidence
What do I have to do to send it abroad?: There is no form to file and no approval to get. You need three things instead: a lawful basis for the processing in the first place, your own written assessment that the destination country protects the data well enough, and a declaration of the transfer in your entry on the state register. That last point is the one people miss. The registration form asks you to list the categories of personal data you send to other countries and to international organisations, so an undeclared export is also a registration failure.High confidence
Who enforces this — and are they actually working?: This changed three months ago. On 3 June 2026 the President abolished the Electronic Security Service and created the National Cybersecurity Agency in its place, under the Ministry of Digital Development and Transport, with express powers over personal data as well as cyber security. The agency is real and working: it runs the state register, takes complaints about data misuse through its website, publishes advisories most weeks, and signed a cooperation agreement with Latvia's data protection inspectorate in July 2026. It is not independent of government, and we found no published fines. The register itself is the strongest evidence it functions: 444 systems are listed and the most recent approval is dated 7 August 2026.High confidence
How long must I keep it, and when must I delete it?: The ceiling is strict and the floor is thin. Once you have achieved the purpose you collected the data for, and there is no longer a need to keep it, you must destroy it without delay. If your registration is cancelled, everything in that system must be blocked immediately and destroyed. Sensitive data must go as soon as the reason for holding it disappears, unless the person agrees to it staying or being archived. In the other direction, the personal data law itself sets no minimum keeping period. The clearest floor we could verify is new: from 2026, records of a digital forensic investigation into a cyber incident must be kept for at least three years.Medium confidence
What happens when something goes wrong?: There is no personal data breach notification duty at all. The 2010 law never created one, and nothing since has added one, so losing customer records triggers no report to any regulator and no letter to the people affected. What does exist is a cyber incident duty, and it is fast: since August 2026, organisations that run information infrastructure must pass information about cyber threats, attacks and incidents to the National CERT immediately. Once the National CERT asks you something, you have 24 hours to answer a threat research request and 5 working days to answer a digital investigation request. Financial firms have a second clock through the Central Bank's FinCERT portal.High confidence
What's the trap?: Five. One: you cannot start. Collecting or processing personal data in an unregistered system is an offence, and registration takes up to a month. Two: the security rules are engineering specifications, not principles, and include a minimum 256-bit encryption key, a data centre archive system housed in a separate building, and state expert review of your system design documents. Three: every operator must set things up so that police and intelligence bodies can carry out surveillance, and must keep the methods secret. Four: the fine for breaking the data law is 300 to 500 manat, roughly 175 to 290 US dollars, which tells you the real risk is being ordered to stop, not being fined. Five: the law says data system work needs a special licence, and no licensing regime matching it appears to be running.High confidence
What's about to change?: One big date and one big gap. The big date is roughly August 2027, twelve months after publication, when Azerbaijan's minimum age of 16 for social network accounts starts. Providers must verify age using a bank card, an email address and a mobile number, must delete what they collected for that check immediately, and must open a local branch. The penalty ladder ends with a court ordering the platform's traffic in Azerbaijan cut by 90 per cent. The big gap is that the July 2026 cybersecurity law leaves the important lists and technical requirements to be written by ministries, and they are not out yet.High confidence
Hardest industry wall: Government — “Hökumət buludu”nun (G-cloud) yaradılması və “bulud” xidmətlərinin göstərilməsi sahəsində tədbirlər haqqında Azərbaycan Respublikası Prezidentinin Fərmanı

The eight framework questions answered for each selected country
Question	SerbiaChecked 18 August 2026	AzerbaijanChecked 18 August 2026
The three ratings	Yes, with paperwork Work: High Enforcement: Active	Yes, with paperwork Work: High Enforcement: Waking up
In one paragraph	Serbia copied Europe's privacy law almost word for word, so the duties feel familiar. Data can leave the country, and for most of Europe and a long list of other countries it can leave with no paperwork at all. The privacy regulator is busy — over a thousand inspections in 2025 — but it hands out warnings, not fines. The biggest fine any Serbian court imposed for a privacy breach in 2025 was about $950.	Azerbaijan has had a personal data law since 2010. Data may leave the country, but only if you decide the destination protects it as well as Azerbaijan does, and you must declare those exports up front. The real cost is not the export rule. It is that you must register your database with the state before you collect a single record.
The catch	Two industries break the general picture. Online gambling operators must keep a copy of their whole player and transaction database physically inside Serbia. Banks, insurers and other financial firms cannot move any IT work abroad without telling the central bank 30 days ahead, proving the foreign country would let Serbian supervisors inspect on site, and risking a veto that forces them to cancel the contract.	The easy-sounding export rule hides where the work actually is. Nothing may be collected until the system holding it sits on a state register, and the government's security rules are unusually specific, down to the encryption key length and where the archive building may stand. Banking and payments have no separate storage wall, but a new cybersecurity regime started in August 2026 and a social media law bites in 2027.
Does this apply to me?	Yes. The law reaches a company anywhere in the world if it offers goods or services to people in Serbia, or watches what they do in Serbia. There is no size or revenue threshold to hide behind. If you are caught this way you must appoint a written representative living or based in Serbia, unless your processing is occasional and low risk or you are a public body.High confidence	The law is silent about foreign companies, and that silence is the answer. Unlike Europe's rules, Azerbaijan's personal data law has no clause reaching organisations abroad that sell to Azerbaijanis. What it does have is a duty on the 'owner' of a database to register it with the state before collecting anything, and that duty is enforced through the register in Baku. A foreign company with no Azerbaijani entity has no realistic way to register, and no regulator has said whether it must. From 2027 one narrow group of foreign firms is caught by name: social network providers offering services to users in Azerbaijan must set up a local branch or representative office.Medium confidence
Can the data leave the country?	Yes, with paperwork — and often with none at all. Serbia treats a very long list of countries as automatically safe: every member of the Council of Europe's data protection treaty, which covers all of Europe plus Argentina, Mexico, Morocco, Mauritius, Senegal, Tunisia, Uruguay, Cape Verde and others, and separately every country the European Union has approved. Sending data there needs no permission and no contract. Everywhere else you sign the Commissioner's standard contract or use approved group rules. Only one industry has a hard wall: online gambling. Banking has a gate rather than a wall.High confidence	Yes, with conditions, and the condition is a judgement call you make yourself. Azerbaijan bans sending personal data abroad in only two situations: where it would threaten national security, or where the destination country's law does not protect the data to the standard Azerbaijani law sets. Nobody publishes a list of good or bad countries, so you decide, and you carry the risk. If the person has consented, or if the transfer is needed to protect their life or health, the destination's standard stops mattering at all. We looked hard for industry walls in banking, payments, insurance, securities, telecoms and health and found none that force data to stay in the country.High confidence
What do I have to do to send it abroad?	First check the destination. If it is on the safe list, you need nothing — no contract, no filing, no approval. If it is not, you sign the standard contract the Serbian regulator published in January 2020, or you get approved group-wide rules. If you want to use your own wording instead of the standard contract, the regulator must approve it and has 60 days to answer. As a last resort there are narrow exceptions such as the person's explicit consent.High confidence	There is no form to file and no approval to get. You need three things instead: a lawful basis for the processing in the first place, your own written assessment that the destination country protects the data well enough, and a declaration of the transfer in your entry on the state register. That last point is the one people miss. The registration form asks you to list the categories of personal data you send to other countries and to international organisations, so an undeclared export is also a registration failure.High confidence
Who enforces this — and are they actually working?	The Commissioner for Information of Public Importance and Personal Data Protection, and it is genuinely working. In 2025 it finished 1,169 inspections, received 5,310 cases and issued 102 corrective orders. But it almost never fines. Of those 102 orders, 101 were warnings and one was a ban on processing. It asked the courts to punish only three organisations all year. Banks answer to the National Bank of Serbia instead, and it is fully active. A brand-new Office for Information Security exists on paper since October 2025 but we could find no sign it is running yet.High confidence	This changed three months ago. On 3 June 2026 the President abolished the Electronic Security Service and created the National Cybersecurity Agency in its place, under the Ministry of Digital Development and Transport, with express powers over personal data as well as cyber security. The agency is real and working: it runs the state register, takes complaints about data misuse through its website, publishes advisories most weeks, and signed a cooperation agreement with Latvia's data protection inspectorate in July 2026. It is not independent of government, and we found no published fines. The register itself is the strongest evidence it functions: 444 systems are listed and the most recent approval is dated 7 August 2026.High confidence
How long must I keep it, and when must I delete it?	There is no single national rule. The privacy law says keep data only as long as you need it, and each sector sets its own clock. Online gambling operators must keep every transaction for at least ten years. Phone and internet companies must keep who-called-whom records for exactly 12 months and then destroy them. Anyone selling a phone line must keep the customer's identity check for 12 months after the service ends. Financial firms must keep a live register of every outsourced service, including which countries the data sits in.High confidence	The ceiling is strict and the floor is thin. Once you have achieved the purpose you collected the data for, and there is no longer a need to keep it, you must destroy it without delay. If your registration is cancelled, everything in that system must be blocked immediately and destroyed. Sensitive data must go as soon as the reason for holding it disappears, unless the person agrees to it staying or being archived. In the other direction, the personal data law itself sets no minimum keeping period. The clearest floor we could verify is new: from 2026, records of a digital forensic investigation into a cyber incident must be kept for at least three years.Medium confidence
What happens when something goes wrong?	Count three clocks. Privacy breach: tell the Commissioner without delay and at the latest within 72 hours, and if you miss that you must explain why. Cyber incident: if you run an information system the state has classed as important, you have only 24 hours to report it. Then a third clock starts — updates every 24 hours for a serious incident, every three days for a middling one, and a final report within 15 days of the incident ending. Banks report cyber incidents to the central bank instead, promptly, with no fixed hour count.High confidence	There is no personal data breach notification duty at all. The 2010 law never created one, and nothing since has added one, so losing customer records triggers no report to any regulator and no letter to the people affected. What does exist is a cyber incident duty, and it is fast: since August 2026, organisations that run information infrastructure must pass information about cyber threats, attacks and incidents to the National CERT immediately. Once the National CERT asks you something, you have 24 hours to answer a threat research request and 5 working days to answer a digital investigation request. Financial firms have a second clock through the Central Bank's FinCERT portal.High confidence
What's the trap?	Five. (1) A child can consent for themselves at 15, not 13 or 16 — plan your age gates around 15. (2) A foreign court order or foreign tax authority demand for data is recognised in Serbia only if a treaty backs it, so handing data to an overseas authority on request can itself be unlawful. (3) Individuals, not just companies, can be prosecuted; the regulator has filed 49 criminal complaints since 2010. (4) Dozens of older Serbian laws still contradict the privacy law and were never fixed. (5) The government's official list of safe destination countries has not been touched since 2019 and still names a United States framework that died in 2020.High confidence	Five. One: you cannot start. Collecting or processing personal data in an unregistered system is an offence, and registration takes up to a month. Two: the security rules are engineering specifications, not principles, and include a minimum 256-bit encryption key, a data centre archive system housed in a separate building, and state expert review of your system design documents. Three: every operator must set things up so that police and intelligence bodies can carry out surveillance, and must keep the methods secret. Four: the fine for breaking the data law is 300 to 500 manat, roughly 175 to 290 US dollars, which tells you the real risk is being ordered to stop, not being fined. Five: the law says data system work needs a special licence, and no licensing regime matching it appears to be running.High confidence
What's about to change?	One dated change and several unscheduled ones. From 1 January 2027 the ministry formally takes over supervising the new Office for Information Security, which should mean the office is actually up and running by then. A rewrite of the privacy law is being drafted by a special working group covering video surveillance, biometrics, genetic data and artificial intelligence, and a separate group is drafting an artificial intelligence law. Neither has been published as a bill, so neither is binding.High confidence	One big date and one big gap. The big date is roughly August 2027, twelve months after publication, when Azerbaijan's minimum age of 16 for social network accounts starts. Providers must verify age using a bank card, an email address and a mobile number, must delete what they collected for that check immediately, and must open a local branch. The penalty ladder ends with a court ordering the platform's traffic in Azerbaijan cut by 90 per cent. The big gap is that the July 2026 cybersecurity law leaves the important lists and technical requirements to be written by ministries, and they are not out yet.High confidence
Hardest industry wall	Online gaming — Pravilnik o informaciono-komunikacionom sistemu za priređivanje posebnih igara na sreću preko sredstava elektronske komunikacije	Government — “Hökumət buludu”nun (G-cloud) yaradılması və “bulud” xidmətlərinin göstərilməsi sahəsində tədbirlər haqqında Azərbaycan Respublikası Prezidentinin Fərmanı