Compare countries

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

Countries

SingaporeChecked 18 August 2026

Yes, with paperworkWork: MediumEnforcement: Active

In one paragraph: Singapore lets personal data leave the country, and we found no industry that is forced to keep data on Singaporean soil. What you must do instead is make the person receiving the data legally bound to protect it as well as Singapore law does. There is no government list of approved or banned countries and no permission to apply for. The privacy regulator is real, staffed, and publishes decisions.
The catch: The open headline is about location, not about paperwork or secrecy. Banks must follow a separate rulebook before customer information goes to any outside supplier, and that rulebook was completely replaced on 11 December 2024. Company accounting records held abroad must still have summaries sent back into Singapore. And a stricter rule in any other Singapore law beats the privacy law outright.
Does this apply to me?: Yes. The privacy law reaches a company that has never set foot in Singapore. It defines an organisation as any body of persons whether or not formed under Singapore law and whether or not it has an office here. There is no revenue or headcount threshold to fall below, and no in-country agent to appoint. You must name at least one person responsible for compliance and publish their contact details, but that person may sit anywhere in the world.High confidence
Can the data leave the country?: Yes, it can leave, and this is the unusual part: we searched banking, payments, insurance, securities, health, telecoms, government, education, gaming, mapping and defence and found no rule anywhere that forces personal data to stay in Singapore. What the law asks for is protection, not location. Before data goes abroad you must make sure the recipient is under a legal duty to protect it to a standard comparable to Singapore's.High confidence
What do I have to do to send it abroad?: There is no list of approved countries, no list of banned countries, and no form to file. You need one thing: the recipient must be under a legally enforceable duty to protect the data to a comparable standard. Most companies do this with a contract they draft themselves, because Singapore does not publish a template. Group companies can use internal group-wide rules instead, and since 2 March 2026 a recipient holding a Global Cross-Border Privacy Rules certificate also counts.High confidence
Who enforces this — and are they actually working?: The Personal Data Protection Commission, which is the same body as the media and telecoms regulator wearing a different hat. It is genuinely working: it publishes batches of decisions and settlements several times a year, with the most recent batches in 2026. Financial firms answer to the central bank as well, and anyone running critical national systems answers to the Cyber Security Agency. All three are staffed and issuing instruments.High confidence
How long must I keep it, and when must I delete it?: Both directions apply. The ceiling: you must stop keeping personal data once the purpose is finished and there is no legal or business reason to hold it, and there is no fixed number of days attached to that. The floor: company accounting records must be kept for at least five years, tax records for at least five years from the relevant year of assessment, and employment records for the latest two years, kept one year past the date an employee leaves.High confidence
What happens when something goes wrong?: There are at least three separate clocks and they run at very different speeds. Privacy: once you have decided a breach is serious enough to report, you have three calendar days to tell the regulator. Finance: a bank or other supervised firm has ONE HOUR to tell the central bank about a severe incident, then fourteen days for a root cause report. Critical national systems: TWO HOURS by phone to the national cyber agency, then a fuller report within seventy-two hours.High confidence
What's the trap?: Five things that are not in the summary. One: an individual employee can go to prison for two years for leaking personal data, and that is separate from any fine on the company. Two: any other Singapore law beats the privacy law, so banking secrecy and similar duties override it. Three: every organisation must stop using national identity card numbers as passwords by 31 December 2026. Four: the data portability right is printed in the Act but has never been switched on. Five: the banking outsourcing rulebook everyone cites was cancelled in December 2024.High confidence
What's about to change?: Three real things are in flight. A new health law has been passed but not started, and it will add its own breach reporting clocks for anyone handling health records. A draft law for big data centres and big cloud providers went out for public comment on 1 July 2026 and closed on 22 July 2026; it is not law yet. And every organisation must stop using national identity numbers as passwords by 31 December 2026. Separately, watch two switches the government can flip with no consultation at all.High confidence
Hardest industry wall: All industries — Companies Act 1967, section 199

ChinaChecked 18 August 2026

Yes, with paperworkWork: Very highEnforcement: Active

In one paragraph: Data can leave China, but only through one of three official gates: a government security review, a government-written contract you file with the regulator, or a certificate from an approved body. Which gate you need depends on how many people's data you move, not on where you send it. Small exporters are exempt. Several industries are walled off entirely.
The catch: The 'paperwork, then it can go' answer is only true for ordinary companies. Payment firms, credit bureaus, hospitals, genetic labs, online map services, telecom and industrial operators, and anything the government labels critical national infrastructure must keep the data in China. In those areas a copy staying behind is not optional.
Does this apply to me?: Yes. China's privacy law reaches a company with no office and no staff in China if it offers goods or services to people in China, or analyses their behaviour. There is no revenue or headcount threshold that lets you out. If you are caught this way, you must set up a dedicated office in China or name a representative there, and give the regulator their details.High confidence
Can the data leave the country?: In general yes, once you clear the right gate — but the gate is set by volume, not by destination. China has no list of banned or approved countries. Below 100,000 people a year you can usually send data abroad with no filing at all. Above that you need a contract filed with the regulator or a certificate; above a million people, or if you hold data the state calls 'important', you need a full government security review. Then come the industry walls, which override all of this.High confidence
What do I have to do to send it abroad?: Three routes, and you do not get to pick freely — your volume picks for you. Route one is a government security review, run by the national internet regulator through your provincial office; an approval lasts three years and only covers the exact purpose, scope and method you declared. Route two is China's own standard contract, which you sign with the overseas recipient and file with the provincial regulator along with a risk assessment. Route three is a certificate from an accredited body, which since 1 March 2026 has a national standard behind it. You also need each person's separate, specific consent before their data goes abroad.High confidence
Who enforces this — and are they actually working?: The Cyberspace Administration of China leads, and it is fully staffed and busy. It runs a nationwide enforcement campaign every year, tests apps itself and publishes the names of the ones that fail, and puts out batches of worked enforcement cases. Police, the industry ministry and the market regulator enforce alongside it, and finance, health, mapping and securities regulators run their own rules. Fines are usually modest and paired with an order to fix things; the eye-watering penalties in the statute are rarely used.High confidence
How long must I keep it, and when must I delete it?: Both directions apply, and they pull against each other. The floor: network logs must be kept for at least six months, and accounting records have their own long minimum periods set by a national schedule. The ceiling: personal data may only be kept for the shortest time needed for the purpose you collected it for, and must be deleted once that purpose is met, the service ends, or consent is withdrawn. Where a law sets a minimum, that minimum wins over the delete duty — you keep the record and stop using it for anything else.High confidence
What happens when something goes wrong?: Three clocks, and they overlap. If you run critical national infrastructure you have ONE HOUR to report a serious incident to your supervising department and the police. Everyone else has four hours to tell the provincial internet office. On top of that, a network data incident that could harm national security or the public interest must be reported within 24 hours. You must also tell affected people immediately, by phone, text, message, email or public notice.High confidence
What's the trap?: Five things that ruin weekends. (1) Sending data abroad needs each person's separate, specific consent — a line buried in a global privacy notice will not do. (2) A child is anyone under 14, and their data is treated as sensitive, so you need a parent's consent and a separate set of processing rules. (3) You may not hand data stored in China to a foreign court, police force or regulator without Chinese government approval — this catches routine legal discovery and overseas audit requests. (4) You have to work out for yourself whether you hold 'important data' and report it, because the official catalogues are incomplete. (5) The widely repeated claim that all personal financial data must be stored in China does not appear where people think it does.High confidence
What's about to change?: The next twelve months are about size-based rules. A draft published on 7 August 2026 would create a heavy new tier for any company holding data on ten million people or more: store it in China, appoint a chief privacy officer, set up an outside supervision committee, publish an annual report and honour data portability requests within 30 working days. Comments closed on 7 September 2026 and it is not law yet. A companion draft going the other way would simplify life for small processors. Watch the dormant switches — several can flip with no consultation at all.High confidence
Hardest industry wall: All industries — 中华人民共和国网络安全法（2025年修正）
Payments — 非银行支付机构监督管理条例
Finance — 征信业务管理办法
Banking — 中国人民银行业务领域数据安全管理办法
Securities — 关于加强境内企业境外发行证券和上市相关保密和档案管理工作的规定
Health and social care — 国家健康医疗大数据标准、安全和服务管理办法（试行）
Mapping and location — 地图管理条例
Telecoms — 工业和信息化领域数据安全管理办法（试行）

The eight framework questions answered for each selected country
Question	SingaporeChecked 18 August 2026	ChinaChecked 18 August 2026
The three ratings	Yes, with paperwork Work: Medium Enforcement: Active	Yes, with paperwork Work: Very high Enforcement: Active
In one paragraph	Singapore lets personal data leave the country, and we found no industry that is forced to keep data on Singaporean soil. What you must do instead is make the person receiving the data legally bound to protect it as well as Singapore law does. There is no government list of approved or banned countries and no permission to apply for. The privacy regulator is real, staffed, and publishes decisions.	Data can leave China, but only through one of three official gates: a government security review, a government-written contract you file with the regulator, or a certificate from an approved body. Which gate you need depends on how many people's data you move, not on where you send it. Small exporters are exempt. Several industries are walled off entirely.
The catch	The open headline is about location, not about paperwork or secrecy. Banks must follow a separate rulebook before customer information goes to any outside supplier, and that rulebook was completely replaced on 11 December 2024. Company accounting records held abroad must still have summaries sent back into Singapore. And a stricter rule in any other Singapore law beats the privacy law outright.	The 'paperwork, then it can go' answer is only true for ordinary companies. Payment firms, credit bureaus, hospitals, genetic labs, online map services, telecom and industrial operators, and anything the government labels critical national infrastructure must keep the data in China. In those areas a copy staying behind is not optional.
Does this apply to me?	Yes. The privacy law reaches a company that has never set foot in Singapore. It defines an organisation as any body of persons whether or not formed under Singapore law and whether or not it has an office here. There is no revenue or headcount threshold to fall below, and no in-country agent to appoint. You must name at least one person responsible for compliance and publish their contact details, but that person may sit anywhere in the world.High confidence	Yes. China's privacy law reaches a company with no office and no staff in China if it offers goods or services to people in China, or analyses their behaviour. There is no revenue or headcount threshold that lets you out. If you are caught this way, you must set up a dedicated office in China or name a representative there, and give the regulator their details.High confidence
Can the data leave the country?	Yes, it can leave, and this is the unusual part: we searched banking, payments, insurance, securities, health, telecoms, government, education, gaming, mapping and defence and found no rule anywhere that forces personal data to stay in Singapore. What the law asks for is protection, not location. Before data goes abroad you must make sure the recipient is under a legal duty to protect it to a standard comparable to Singapore's.High confidence	In general yes, once you clear the right gate — but the gate is set by volume, not by destination. China has no list of banned or approved countries. Below 100,000 people a year you can usually send data abroad with no filing at all. Above that you need a contract filed with the regulator or a certificate; above a million people, or if you hold data the state calls 'important', you need a full government security review. Then come the industry walls, which override all of this.High confidence
What do I have to do to send it abroad?	There is no list of approved countries, no list of banned countries, and no form to file. You need one thing: the recipient must be under a legally enforceable duty to protect the data to a comparable standard. Most companies do this with a contract they draft themselves, because Singapore does not publish a template. Group companies can use internal group-wide rules instead, and since 2 March 2026 a recipient holding a Global Cross-Border Privacy Rules certificate also counts.High confidence	Three routes, and you do not get to pick freely — your volume picks for you. Route one is a government security review, run by the national internet regulator through your provincial office; an approval lasts three years and only covers the exact purpose, scope and method you declared. Route two is China's own standard contract, which you sign with the overseas recipient and file with the provincial regulator along with a risk assessment. Route three is a certificate from an accredited body, which since 1 March 2026 has a national standard behind it. You also need each person's separate, specific consent before their data goes abroad.High confidence
Who enforces this — and are they actually working?	The Personal Data Protection Commission, which is the same body as the media and telecoms regulator wearing a different hat. It is genuinely working: it publishes batches of decisions and settlements several times a year, with the most recent batches in 2026. Financial firms answer to the central bank as well, and anyone running critical national systems answers to the Cyber Security Agency. All three are staffed and issuing instruments.High confidence	The Cyberspace Administration of China leads, and it is fully staffed and busy. It runs a nationwide enforcement campaign every year, tests apps itself and publishes the names of the ones that fail, and puts out batches of worked enforcement cases. Police, the industry ministry and the market regulator enforce alongside it, and finance, health, mapping and securities regulators run their own rules. Fines are usually modest and paired with an order to fix things; the eye-watering penalties in the statute are rarely used.High confidence
How long must I keep it, and when must I delete it?	Both directions apply. The ceiling: you must stop keeping personal data once the purpose is finished and there is no legal or business reason to hold it, and there is no fixed number of days attached to that. The floor: company accounting records must be kept for at least five years, tax records for at least five years from the relevant year of assessment, and employment records for the latest two years, kept one year past the date an employee leaves.High confidence	Both directions apply, and they pull against each other. The floor: network logs must be kept for at least six months, and accounting records have their own long minimum periods set by a national schedule. The ceiling: personal data may only be kept for the shortest time needed for the purpose you collected it for, and must be deleted once that purpose is met, the service ends, or consent is withdrawn. Where a law sets a minimum, that minimum wins over the delete duty — you keep the record and stop using it for anything else.High confidence
What happens when something goes wrong?	There are at least three separate clocks and they run at very different speeds. Privacy: once you have decided a breach is serious enough to report, you have three calendar days to tell the regulator. Finance: a bank or other supervised firm has ONE HOUR to tell the central bank about a severe incident, then fourteen days for a root cause report. Critical national systems: TWO HOURS by phone to the national cyber agency, then a fuller report within seventy-two hours.High confidence	Three clocks, and they overlap. If you run critical national infrastructure you have ONE HOUR to report a serious incident to your supervising department and the police. Everyone else has four hours to tell the provincial internet office. On top of that, a network data incident that could harm national security or the public interest must be reported within 24 hours. You must also tell affected people immediately, by phone, text, message, email or public notice.High confidence
What's the trap?	Five things that are not in the summary. One: an individual employee can go to prison for two years for leaking personal data, and that is separate from any fine on the company. Two: any other Singapore law beats the privacy law, so banking secrecy and similar duties override it. Three: every organisation must stop using national identity card numbers as passwords by 31 December 2026. Four: the data portability right is printed in the Act but has never been switched on. Five: the banking outsourcing rulebook everyone cites was cancelled in December 2024.High confidence	Five things that ruin weekends. (1) Sending data abroad needs each person's separate, specific consent — a line buried in a global privacy notice will not do. (2) A child is anyone under 14, and their data is treated as sensitive, so you need a parent's consent and a separate set of processing rules. (3) You may not hand data stored in China to a foreign court, police force or regulator without Chinese government approval — this catches routine legal discovery and overseas audit requests. (4) You have to work out for yourself whether you hold 'important data' and report it, because the official catalogues are incomplete. (5) The widely repeated claim that all personal financial data must be stored in China does not appear where people think it does.High confidence
What's about to change?	Three real things are in flight. A new health law has been passed but not started, and it will add its own breach reporting clocks for anyone handling health records. A draft law for big data centres and big cloud providers went out for public comment on 1 July 2026 and closed on 22 July 2026; it is not law yet. And every organisation must stop using national identity numbers as passwords by 31 December 2026. Separately, watch two switches the government can flip with no consultation at all.High confidence	The next twelve months are about size-based rules. A draft published on 7 August 2026 would create a heavy new tier for any company holding data on ten million people or more: store it in China, appoint a chief privacy officer, set up an outside supervision committee, publish an annual report and honour data portability requests within 30 working days. Comments closed on 7 September 2026 and it is not law yet. A companion draft going the other way would simplify life for small processors. Watch the dormant switches — several can flip with no consultation at all.High confidence
Hardest industry wall	All industries — Companies Act 1967, section 199	All industries — 中华人民共和国网络安全法（2025年修正） Payments — 非银行支付机构监督管理条例 Finance — 征信业务管理办法 Banking — 中国人民银行业务领域数据安全管理办法 Securities — 关于加强境内企业境外发行证券和上市相关保密和档案管理工作的规定 Health and social care — 国家健康医疗大数据标准、安全和服务管理办法（试行） Mapping and location — 地图管理条例 Telecoms — 工业和信息化领域数据安全管理办法（试行）