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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
GermanyChecked 18 August 2026
Yes, with paperworkWork: HighEnforcement: Active
In one paragraph
Contrary to widespread belief, neither Europe nor Germany requires personal data to be stored in Europe. What the law requires is a valid legal instrument before data leaves — an official decision that the destination is safe enough, or a standard contract, plus a documented risk assessment. Germany then adds its own layer on top, and one genuine hard wall: health and social data may only be processed in the cloud within Europe, by a provider holding a specific German security certificate.
The catch
'Germany doesn't require local storage' is true right up until you sell to a hospital, a health insurer, a doctor, a lawyer or a tax adviser. In health and social care it is simply false, and for the professional-secrecy trades a standard data processing agreement is not enough and getting it wrong is a criminal matter.
Does this apply to me?
Yes, it reaches you with no office in Germany. Europe's privacy law applies to any organisation anywhere that offers goods or services to people in Europe or monitors their behaviour. If you have no European establishment you must also appoint a representative inside Europe.High confidence
Can the data leave the country?
Yes — with paperwork. This is the single most misunderstood point in the field. European law does not say where data must sit; it says what you must have in place before it leaves Europe. Storage location is a risk factor in that assessment, never a prohibition. For non-personal data, Europe goes further and actually forbids member states from imposing storage-location rules.High confidence
What do I have to do to send it abroad?
One of three routes. Best case, the destination is on Europe's official 'adequate' list and you need nothing extra — currently 17 entries including the UK, Japan, South Korea, Switzerland, Canada for commercial bodies, Brazil since January 2026, and the United States but only for companies self-certified under the EU-US Data Privacy Framework. Otherwise you sign Europe's standard contract clauses, or get group-wide internal rules approved. In either of those two cases you must also document an assessment of whether the destination country's surveillance laws undermine the protection.High confidence
Who enforces this — and are they actually working?
Eighteen separate authorities, and for a private company it is almost never the federal one. Each of the 16 states has its own regulator, and you answer to the one where your German office is. The federal regulator handles government bodies plus telecoms and postal operators. Bavaria splits it further, with different bodies for private and public sector. If you operate across Europe, a separate rule lets you deal mainly with the regulator where your main European establishment sits.High confidence
How long must I keep it, and when must I delete it?
Business records have a floor: accounting vouchers must be kept 8 years (cut from 10 with effect from 2025, and from 2026 for banks and insurers), the annual accounts and trading books still 10 years, and business correspondence 6 years. Privacy law pushes the other way — don't keep personal data longer than you need it. Where the two collide, German law has an elegant answer: you restrict processing of the data instead of deleting it.High confidence
What happens when something goes wrong?
72 hours to tell your state regulator about a personal data breach, and without undue delay to tell affected people where the risk to them is high. Separately, since December 2025 Germany's cybersecurity law adds its own clocks for around 29,500 in-scope companies: a first warning within 24 hours, an update at 72 hours, and a full report within a month. Financial firms follow a separate European regime instead.High confidence
What's the trap?
Four. (1) Health and social data really does have to stay in Europe, with a specific German security certificate — the general 'no localisation' answer is wrong here. (2) For doctors, lawyers, tax advisers and notaries, a standard data processing agreement is NOT enough: you need explicit secrecy undertakings flowed down to every subcontractor, and breach is a criminal offence, not a fine. (3) Germany still requires a data protection officer at just 20 employees involved in data processing — far stricter than European law, and still in force despite a government promise to scrap it by the end of 2026. (4) The German rule people cite for employee data was effectively struck down by Europe's top court in 2023 but never removed from the statute book, so citing it as your legal basis is a mistake.High confidence
What's about to change?
Two hard dates and one live risk. From 12 January 2027 every cloud provider must drop switching and data egress fees to zero — renegotiate contracts now. By 31 December 2026 Germany's banking IT rulebook is fully withdrawn in favour of the European financial regime. The live risk is the US arrangement: Europe's data protection board formally asked the Commission on 31 July 2026 to review whether it is still valid, and a separate court appeal is pending. If it falls, thousands of transfers move to standard contracts overnight.High confidence
Hardest industry wall
  • Health and social care § 393 SGB V — Cloud-Einsatz im Gesundheitswesen
  • Telecoms §§ 175–181 TKG — Vorratsdatenspeicherung