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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

BulgariaChecked 18 August 2026

Depends on your industryWork: MediumEnforcement: Active

In one paragraph: Bulgaria is an ordinary European Union country for data. Personal data can leave, as long as you use one of the standard European transfer tools. There is no general rule forcing data to stay in Bulgaria. But online gambling is a hard exception: a control server must physically sit on Bulgarian soil. Bulgaria switched to the euro on 1 January 2026, so all fines are now in euro.
The catch: The relaxed headline stops being true in two places. First, online gambling: an operator licensed in Bulgaria must keep a control local server on Bulgarian territory and stream live game data to the tax authority's server. Second, telecoms: operators must build and pay for interception equipment wired into two Bulgarian state agencies, which cannot be run from abroad. Mapping and aerial survey work also needs clearance from five Bulgarian ministries and agencies before you may even collect the data.
Does this apply to me?: Yes, it can reach you with no office in Bulgaria. The European Union's privacy rulebook applies to anyone who offers goods or services to people in Europe or watches what they do online. Bulgaria's own Personal Data Protection Act sits on top of that and adds extra local duties. There is no revenue or headcount threshold, and no Bulgaria-specific representative: the European-wide requirement to name a representative in Europe is the only one, and it can be in any European country.High confidence
Can the data leave the country?: In general, yes. Bulgaria has no law telling ordinary businesses to keep personal data inside the country. Data moves freely to the rest of Europe, to Switzerland, and to countries Europe has approved; anywhere else needs a standard contract or a similar tool. Two industries break that pattern. Online gambling operators must keep a control server physically in Bulgaria. Telecoms operators must build interception equipment that plugs into Bulgarian state agencies, which cannot sit abroad.High confidence
What do I have to do to send it abroad?: Bulgaria uses Europe's system, not its own. There is no Bulgarian list of banned countries and no Bulgarian permit to apply for. If the destination is inside Europe, the wider European Economic Area or Switzerland, nothing extra is needed. Otherwise you need either an official European approval of that country, or the standard European contract, or approved group-wide rules. One Bulgarian twist: Bulgarian law explicitly puts Switzerland on the same footing as a European Union country.High confidence
Who enforces this — and are they actually working?: The Commission for Personal Data Protection is the main regulator. It is real, staffed and it does issue formal decisions, including ones published across Europe. But it is not a heavy hitter. In a Europe-wide check on deletion rights reported in February 2026, it contacted twenty-three organisations, opened no formal investigations, imposed no penalties, and said it did not plan to. A separate inspectorate polices the courts and prosecutors. Cybersecurity has its own separate regulators.Medium confidence
How long must I keep it, and when must I delete it?: Bulgaria has strong minimum-keeping rules and a few sharp delete-by rules. You must keep payroll records for fifty years, accounting books and financial statements for ten years, and other accounting papers for three years. Telecoms firms keep connection records for six months. Going the other way, job applicants' data must be deleted within six months unless they agree otherwise, and data you were given with no legal basis must be returned or destroyed within one month.High confidence
What happens when something goes wrong?: There are at least three clocks and they do not agree. A personal data breach must reach the privacy regulator within seventy-two hours. Under the cybersecurity law rewritten in February 2026, an early warning must reach the response team within twenty-four hours and a fuller report within seventy-two hours. Trust service providers get twenty-four hours for that fuller report. Financial firms answer to the separate European financial-resilience rules on top.High confidence
What's the trap?: Five things bite people in Bulgaria. You may not photocopy someone's identity card, driving licence or residence permit unless a law lets you. Children need a parent's consent up to age fourteen, not sixteen. Job applicant files must go within six months. Your accounting software must be able to output in Bulgarian. And one clause of the privacy law was struck down by the Constitutional Court in 2019 but is still printed in the statute.High confidence
What's about to change?: Two dated changes are already fixed. From 12 January 2027 every cloud provider must let customers move their data out for free. Bulgaria's new cybersecurity duties started on 13 February 2026 and enforcement is only now warming up. The biggest live risk is not Bulgarian at all: Europe's approval of United States data transfers is being challenged, and Europe's own privacy board asked the Commission on 31 July 2026 to re-examine it.High confidence
Hardest industry wall: Online gaming — Закон за хазарта

The eight framework questions answered for each selected country
Question	SerbiaChecked 18 August 2026	BulgariaChecked 18 August 2026
The three ratings	Yes, with paperwork Work: High Enforcement: Active	Depends on your industry Work: Medium Enforcement: 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.	Bulgaria is an ordinary European Union country for data. Personal data can leave, as long as you use one of the standard European transfer tools. There is no general rule forcing data to stay in Bulgaria. But online gambling is a hard exception: a control server must physically sit on Bulgarian soil. Bulgaria switched to the euro on 1 January 2026, so all fines are now in euro.
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 relaxed headline stops being true in two places. First, online gambling: an operator licensed in Bulgaria must keep a control local server on Bulgarian territory and stream live game data to the tax authority's server. Second, telecoms: operators must build and pay for interception equipment wired into two Bulgarian state agencies, which cannot be run from abroad. Mapping and aerial survey work also needs clearance from five Bulgarian ministries and agencies before you may even collect the data.
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	Yes, it can reach you with no office in Bulgaria. The European Union's privacy rulebook applies to anyone who offers goods or services to people in Europe or watches what they do online. Bulgaria's own Personal Data Protection Act sits on top of that and adds extra local duties. There is no revenue or headcount threshold, and no Bulgaria-specific representative: the European-wide requirement to name a representative in Europe is the only one, and it can be in any European country.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	In general, yes. Bulgaria has no law telling ordinary businesses to keep personal data inside the country. Data moves freely to the rest of Europe, to Switzerland, and to countries Europe has approved; anywhere else needs a standard contract or a similar tool. Two industries break that pattern. Online gambling operators must keep a control server physically in Bulgaria. Telecoms operators must build interception equipment that plugs into Bulgarian state agencies, which cannot sit abroad.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	Bulgaria uses Europe's system, not its own. There is no Bulgarian list of banned countries and no Bulgarian permit to apply for. If the destination is inside Europe, the wider European Economic Area or Switzerland, nothing extra is needed. Otherwise you need either an official European approval of that country, or the standard European contract, or approved group-wide rules. One Bulgarian twist: Bulgarian law explicitly puts Switzerland on the same footing as a European Union country.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	The Commission for Personal Data Protection is the main regulator. It is real, staffed and it does issue formal decisions, including ones published across Europe. But it is not a heavy hitter. In a Europe-wide check on deletion rights reported in February 2026, it contacted twenty-three organisations, opened no formal investigations, imposed no penalties, and said it did not plan to. A separate inspectorate polices the courts and prosecutors. Cybersecurity has its own separate regulators.Medium 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	Bulgaria has strong minimum-keeping rules and a few sharp delete-by rules. You must keep payroll records for fifty years, accounting books and financial statements for ten years, and other accounting papers for three years. Telecoms firms keep connection records for six months. Going the other way, job applicants' data must be deleted within six months unless they agree otherwise, and data you were given with no legal basis must be returned or destroyed within one month.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	There are at least three clocks and they do not agree. A personal data breach must reach the privacy regulator within seventy-two hours. Under the cybersecurity law rewritten in February 2026, an early warning must reach the response team within twenty-four hours and a fuller report within seventy-two hours. Trust service providers get twenty-four hours for that fuller report. Financial firms answer to the separate European financial-resilience rules on top.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 things bite people in Bulgaria. You may not photocopy someone's identity card, driving licence or residence permit unless a law lets you. Children need a parent's consent up to age fourteen, not sixteen. Job applicant files must go within six months. Your accounting software must be able to output in Bulgarian. And one clause of the privacy law was struck down by the Constitutional Court in 2019 but is still printed in the statute.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	Two dated changes are already fixed. From 12 January 2027 every cloud provider must let customers move their data out for free. Bulgaria's new cybersecurity duties started on 13 February 2026 and enforcement is only now warming up. The biggest live risk is not Bulgarian at all: Europe's approval of United States data transfers is being challenged, and Europe's own privacy board asked the Commission on 31 July 2026 to re-examine it.High confidence
Hardest industry wall	Online gaming — Pravilnik o informaciono-komunikacionom sistemu za priređivanje posebnih igara na sreću preko sredstava elektronske komunikacije	Online gaming — Закон за хазарта