Compare countries

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

Countries

RussiaChecked 18 August 2026

A copy must stayWork: Very highEnforcement: Active

In one paragraph: If you collect personal data from people in Russia, the database you collect it into must sit inside Russia. You may then send a copy abroad, but only after you tell the regulator first and only to a country on its approved list. The United States is not on that list. Breaking the storage rule costs up to 6 million roubles, about $75,000, and leaking data can now put a person in prison.
The catch: The 'copy may go abroad' part disappears in several industries. Payments, electronic money, biometrics, telecoms, internet messaging services, government systems and detailed mapping are hard walls: the data must stay in Russia and no copy may leave. Since 1 September 2025 any company running 'significant' critical infrastructure — which includes most banks, telecoms operators and large energy and health providers — must also run Russian-registered software on those systems.
Does this apply to me?: Yes. The law reaches a foreign company with no office in Russia. It applies whenever you process the personal data of Russian citizens under a contract with them, under any other agreement with them, or on the basis of their consent. There is no size or revenue threshold. Almost every organisation must also file a notice with the regulator before it starts processing, and file a second, separate notice before any data leaves the country.High confidence
Can the data leave the country?: A copy can leave, but the original must stay. When you collect personal data about Russian citizens, the database you record, store, update or retrieve it from has to be physically in Russia. Since 1 July 2025 the law says this as a flat ban on using databases outside Russia for those steps. After that, sending a copy abroad is a separate question with its own paperwork. Several industries are stricter still and allow no copy out at all.High confidence
What do I have to do to send it abroad?: Russia runs an approved-destinations list, so a transfer is banned unless the destination is on it. Before any data leaves you must send the regulator a separate written notice naming the countries, the data and the recipients, and you must first collect written assurances from the recipient about how it will protect the data. If the destination is on the approved list you may start as soon as the notice is sent. If it is not, you must wait, and in practice you will be refused. The United States is not on the list.High confidence
Who enforces this — and are they actually working?: Roskomnadzor, the federal communications and media supervisor, is the data protection regulator. It is a long-established federal service, fully staffed, and it is still issuing binding orders — its most recent inspection check-list order was published on the state legal portal in December 2025. It is not the only enforcer. The security service runs the national cyber-attack reporting system, the technical regulator FSTEC sets security requirements for government and critical systems, and the Bank of Russia supervises banks and payment firms.Medium confidence
How long must I keep it, and when must I delete it?: Both directions apply and they collide. Personal data must be destroyed within 30 days of the purpose being achieved, or within 30 days of consent being withdrawn, and within 10 working days if the processing was unlawful. Against that, staff records must be kept for 50 years, telecoms and messaging metadata for three years, and message content for up to six months. Where a statute sets a minimum, the minimum wins and you keep the data.High confidence
What happens when something goes wrong?: There are at least three clocks and they run at once. You have 24 hours to tell the data regulator that personal data has leaked, and 72 hours to give it the results of your internal investigation. Separately, if the leak came from a computer attack you must report it to the security service's national attack-detection system. Banks and payment firms report to the Bank of Russia as well. Missing the 24-hour notice is itself a fine of up to 3 million roubles, about $37,000.High confidence
What's the trap?: Five things catch people out. First, leaking data is now a crime, and doing it across a border carries up to eight years in prison. Second, repeat leaks are fined as a share of worldwide-style annual revenue, between 1 and 3 percent, with a floor of 20 million roubles, about $250,000. Third, staff files must be kept 50 years, which flatly conflicts with the 30-day deletion duty. Fourth, biometric data can only be handled by a Russian-controlled company using databases in Russia. Fifth, refusing to serve a customer because they will not give biometrics is itself a fine.High confidence
What's about to change?: One dated change is already fixed: from 1 September 2027, Moscow's public bodies move onto a single city technology platform, which will pull a large volume of citizen data into one place. Much more important are the switches the government already holds and can flip with no consultation. The approved-country list can be cut by a single regulator order. Any transfer can be banned outright on security or economic grounds. And the rules for foreign use of Russian mapping technology have been written into the law but never issued.High confidence
Hardest industry wall: All industries — Федеральный закон от 27.07.2006 № 152-ФЗ «О персональных данных», статья 18 часть 5
All industries — Федеральный закон № 152-ФЗ, статья 21 часть 3.1 и статья 19 часть 12
All industries — Уголовный кодекс Российской Федерации, статья 272.1
Payments — Федеральный закон от 27.06.2011 № 161-ФЗ «О национальной платежной системе», статьи 12 и 16
All industries — Федеральный закон от 29.12.2022 № 572-ФЗ об идентификации и аутентификации с использованием биометрических персональных данных
Telecoms — Федеральный закон от 07.07.2003 № 126-ФЗ «О связи», статья 64; Федеральный закон от 27.07.2006 № 149-ФЗ, статья 10.1
Government — Приказ ФСТЭК России от 11.04.2025 № 117; Указ Президента РФ от 30.03.2022 № 166; Указ Президента РФ от 01.05.2022 № 250; Федеральный закон от 07.04.2025 № 58-ФЗ
Mapping and location — Федеральный закон от 30.12.2015 № 431-ФЗ «О геодезии, картографии и пространственных данных», статьи 23 и 24
Health and social care — Федеральный закон от 21.11.2011 № 323-ФЗ «Об основах охраны здоровья граждан в Российской Федерации», статья 13
Social media and online platforms — Федеральный закон от 01.07.2021 № 236-ФЗ «О деятельности иностранных лиц в информационно-телекоммуникационной сети «Интернет» на территории Российской Федерации»

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	RussiaChecked 18 August 2026	BulgariaChecked 18 August 2026
The three ratings	A copy must stay Work: Very high Enforcement: Active	Depends on your industry Work: Medium Enforcement: Active
In one paragraph	If you collect personal data from people in Russia, the database you collect it into must sit inside Russia. You may then send a copy abroad, but only after you tell the regulator first and only to a country on its approved list. The United States is not on that list. Breaking the storage rule costs up to 6 million roubles, about $75,000, and leaking data can now put a person in prison.	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 'copy may go abroad' part disappears in several industries. Payments, electronic money, biometrics, telecoms, internet messaging services, government systems and detailed mapping are hard walls: the data must stay in Russia and no copy may leave. Since 1 September 2025 any company running 'significant' critical infrastructure — which includes most banks, telecoms operators and large energy and health providers — must also run Russian-registered software on those systems.	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 foreign company with no office in Russia. It applies whenever you process the personal data of Russian citizens under a contract with them, under any other agreement with them, or on the basis of their consent. There is no size or revenue threshold. Almost every organisation must also file a notice with the regulator before it starts processing, and file a second, separate notice before any data leaves the country.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?	A copy can leave, but the original must stay. When you collect personal data about Russian citizens, the database you record, store, update or retrieve it from has to be physically in Russia. Since 1 July 2025 the law says this as a flat ban on using databases outside Russia for those steps. After that, sending a copy abroad is a separate question with its own paperwork. Several industries are stricter still and allow no copy out at all.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?	Russia runs an approved-destinations list, so a transfer is banned unless the destination is on it. Before any data leaves you must send the regulator a separate written notice naming the countries, the data and the recipients, and you must first collect written assurances from the recipient about how it will protect the data. If the destination is on the approved list you may start as soon as the notice is sent. If it is not, you must wait, and in practice you will be refused. The United States is not on the list.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?	Roskomnadzor, the federal communications and media supervisor, is the data protection regulator. It is a long-established federal service, fully staffed, and it is still issuing binding orders — its most recent inspection check-list order was published on the state legal portal in December 2025. It is not the only enforcer. The security service runs the national cyber-attack reporting system, the technical regulator FSTEC sets security requirements for government and critical systems, and the Bank of Russia supervises banks and payment firms.Medium 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?	Both directions apply and they collide. Personal data must be destroyed within 30 days of the purpose being achieved, or within 30 days of consent being withdrawn, and within 10 working days if the processing was unlawful. Against that, staff records must be kept for 50 years, telecoms and messaging metadata for three years, and message content for up to six months. Where a statute sets a minimum, the minimum wins and you keep the data.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?	There are at least three clocks and they run at once. You have 24 hours to tell the data regulator that personal data has leaked, and 72 hours to give it the results of your internal investigation. Separately, if the leak came from a computer attack you must report it to the security service's national attack-detection system. Banks and payment firms report to the Bank of Russia as well. Missing the 24-hour notice is itself a fine of up to 3 million roubles, about $37,000.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 things catch people out. First, leaking data is now a crime, and doing it across a border carries up to eight years in prison. Second, repeat leaks are fined as a share of worldwide-style annual revenue, between 1 and 3 percent, with a floor of 20 million roubles, about $250,000. Third, staff files must be kept 50 years, which flatly conflicts with the 30-day deletion duty. Fourth, biometric data can only be handled by a Russian-controlled company using databases in Russia. Fifth, refusing to serve a customer because they will not give biometrics is itself a fine.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 is already fixed: from 1 September 2027, Moscow's public bodies move onto a single city technology platform, which will pull a large volume of citizen data into one place. Much more important are the switches the government already holds and can flip with no consultation. The approved-country list can be cut by a single regulator order. Any transfer can be banned outright on security or economic grounds. And the rules for foreign use of Russian mapping technology have been written into the law but never issued.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	All industries — Федеральный закон от 27.07.2006 № 152-ФЗ «О персональных данных», статья 18 часть 5 All industries — Федеральный закон № 152-ФЗ, статья 21 часть 3.1 и статья 19 часть 12 All industries — Уголовный кодекс Российской Федерации, статья 272.1 Payments — Федеральный закон от 27.06.2011 № 161-ФЗ «О национальной платежной системе», статьи 12 и 16 All industries — Федеральный закон от 29.12.2022 № 572-ФЗ об идентификации и аутентификации с использованием биометрических персональных данных Telecoms — Федеральный закон от 07.07.2003 № 126-ФЗ «О связи», статья 64; Федеральный закон от 27.07.2006 № 149-ФЗ, статья 10.1 Government — Приказ ФСТЭК России от 11.04.2025 № 117; Указ Президента РФ от 30.03.2022 № 166; Указ Президента РФ от 01.05.2022 № 250; Федеральный закон от 07.04.2025 № 58-ФЗ Mapping and location — Федеральный закон от 30.12.2015 № 431-ФЗ «О геодезии, картографии и пространственных данных», статьи 23 и 24 Health and social care — Федеральный закон от 21.11.2011 № 323-ФЗ «Об основах охраны здоровья граждан в Российской Федерации», статья 13 Social media and online platforms — Федеральный закон от 01.07.2021 № 236-ФЗ «О деятельности иностранных лиц в информационно-телекоммуникационной сети «Интернет» на территории Российской Федерации»	Online gaming — Закон за хазарта