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

JapanChecked 18 August 2026

Yes, with paperworkWork: MediumEnforcement: Active

In one paragraph: Japan lets personal data leave the country, but you need paperwork. Only Europe and the United Kingdom are pre-approved. For anywhere else you either sign a contract that binds the recipient to Japanese-standard protection, or you get the person's consent after telling them which country the data goes to. There is no general rule forcing data to stay in Japan.
The catch: Two things break the calm headline. If you sell to the Japanese government, the data must physically sit in Japanese data centres. And if you run a website, an app or any online service used from Japan, the telecoms law reaches you even with no office here, requires a representative in Japan, and makes leaking a communication a criminal offence rather than a fine.
Does this apply to me?: Yes. Japan's privacy law reaches a foreign company with no office and no staff in Japan, as long as it handles the personal information of people in Japan while supplying them goods or services. There is no size, revenue or headcount threshold to fall below. Unlike Europe, the privacy law does not make you appoint a representative in Japan — but the telecoms law does, if your service counts as a telecommunications service.High confidence
Can the data leave the country?: Yes, with paperwork. Japan's general rating is conditional: personal data may go abroad once you have one of three things in place. There is no across-the-board law keeping data in Japan, and no financial, insurance, securities or health localisation rule of the kind India or China have — we searched for one and did not find it. The real wall is government work: anything running on the national Government Cloud must sit in data centres inside Japan.High confidence
What do I have to do to send it abroad?: The model is an allowlist, and the list has exactly two entries: the European Union and the United Kingdom. Send data there and it is treated almost like a domestic transfer. For every other destination you need one of two things instead. Either the recipient is contractually bound to protect the data to Japanese standards and you keep checking that it does, or you get the person's consent after first telling them the destination country, what its privacy law is like, and what the recipient will do to protect the data.High confidence
Who enforces this — and are they actually working?: The Personal Information Protection Commission, and it is genuinely working. It has a chair, eight commissioners and a staff ceiling of 231 people. In the year to March 2025 it handled just over 19,000 breach reports, gave 395 pieces of formal guidance and made one recommendation. In the first six months of the following year it sharpened up: two recommendations and its first emergency order, against a company misusing personal information. What it cannot do yet is fine you — Japan has no administrative money penalty for privacy breaches until the 2026 amendment starts.High confidence
How long must I keep it, and when must I delete it?: The floor is firm and the ceiling is soft. Tax law makes you keep books and records for seven years, stretching to ten if you carry a loss forward. Company accounting books run ten years. Against that, the privacy law only asks you to try to delete personal data once you no longer need it — it is a best-efforts duty, not a hard deadline. So when the two collide, the keep-it rule wins in practice.Medium confidence
What happens when something goes wrong?: Count three clocks. For a personal data breach you file a first report to the privacy regulator within three to five days of finding out, and a full report within 30 days — 60 days if someone did it on purpose. You must also tell the people affected. Critical infrastructure operators have a separate cyber incident duty with a report to the government within 30 days. Telecoms operators report leaks of communications to the communications ministry on their own timetable.High confidence
What's the trap?: Five. (1) Putting data on a foreign server is often not a 'transfer' at all — if the provider is contractually barred from touching it — but you then have to work out that country's privacy law and publish the country's name to your users. Most people miss this. (2) The privacy law has no fines: the sanctions are criminal, and a company can be fined about $650,000 for a staff member stealing a customer database. (3) Leaking a communication is a crime punishable with prison, and telecoms staff face a longer term than outsiders. (4) The telecoms rules catch ordinary websites and apps, not just phone companies, and reach foreign operators with no office in Japan. (5) Consent to send data 'overseas' is not valid — you have to name the country.High confidence
What's about to change?: The big one has already passed. On 17 July 2026 Japan published a large amendment to its privacy law. It introduces the country's first money penalty for privacy breaches, sets 16 as the age below which a guardian must be involved, adds rules for face and other biometric data, and raises the criminal penalties. It is not in force yet: the government has up to two years to switch it on by order, and no date has been announced. The other thing to watch is the new cyber defence law, which is being switched on in stages through 2027.High confidence
Hardest industry wall: Government — デジタル庁におけるガバメントクラウド等の整備のためのクラウドサービスの提供 — 令和８年度募集調達仕様書

The eight framework questions answered for each selected country
Question	SingaporeChecked 18 August 2026	JapanChecked 18 August 2026
The three ratings	Yes, with paperwork Work: Medium Enforcement: Active	Yes, with paperwork Work: Medium 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.	Japan lets personal data leave the country, but you need paperwork. Only Europe and the United Kingdom are pre-approved. For anywhere else you either sign a contract that binds the recipient to Japanese-standard protection, or you get the person's consent after telling them which country the data goes to. There is no general rule forcing data to stay in Japan.
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.	Two things break the calm headline. If you sell to the Japanese government, the data must physically sit in Japanese data centres. And if you run a website, an app or any online service used from Japan, the telecoms law reaches you even with no office here, requires a representative in Japan, and makes leaking a communication a criminal offence rather than a fine.
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. Japan's privacy law reaches a foreign company with no office and no staff in Japan, as long as it handles the personal information of people in Japan while supplying them goods or services. There is no size, revenue or headcount threshold to fall below. Unlike Europe, the privacy law does not make you appoint a representative in Japan — but the telecoms law does, if your service counts as a telecommunications service.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	Yes, with paperwork. Japan's general rating is conditional: personal data may go abroad once you have one of three things in place. There is no across-the-board law keeping data in Japan, and no financial, insurance, securities or health localisation rule of the kind India or China have — we searched for one and did not find it. The real wall is government work: anything running on the national Government Cloud must sit in data centres inside Japan.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	The model is an allowlist, and the list has exactly two entries: the European Union and the United Kingdom. Send data there and it is treated almost like a domestic transfer. For every other destination you need one of two things instead. Either the recipient is contractually bound to protect the data to Japanese standards and you keep checking that it does, or you get the person's consent after first telling them the destination country, what its privacy law is like, and what the recipient will do to protect the data.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 Personal Information Protection Commission, and it is genuinely working. It has a chair, eight commissioners and a staff ceiling of 231 people. In the year to March 2025 it handled just over 19,000 breach reports, gave 395 pieces of formal guidance and made one recommendation. In the first six months of the following year it sharpened up: two recommendations and its first emergency order, against a company misusing personal information. What it cannot do yet is fine you — Japan has no administrative money penalty for privacy breaches until the 2026 amendment starts.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	The floor is firm and the ceiling is soft. Tax law makes you keep books and records for seven years, stretching to ten if you carry a loss forward. Company accounting books run ten years. Against that, the privacy law only asks you to try to delete personal data once you no longer need it — it is a best-efforts duty, not a hard deadline. So when the two collide, the keep-it rule wins in practice.Medium 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	Count three clocks. For a personal data breach you file a first report to the privacy regulator within three to five days of finding out, and a full report within 30 days — 60 days if someone did it on purpose. You must also tell the people affected. Critical infrastructure operators have a separate cyber incident duty with a report to the government within 30 days. Telecoms operators report leaks of communications to the communications ministry on their own timetable.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. (1) Putting data on a foreign server is often not a 'transfer' at all — if the provider is contractually barred from touching it — but you then have to work out that country's privacy law and publish the country's name to your users. Most people miss this. (2) The privacy law has no fines: the sanctions are criminal, and a company can be fined about $650,000 for a staff member stealing a customer database. (3) Leaking a communication is a crime punishable with prison, and telecoms staff face a longer term than outsiders. (4) The telecoms rules catch ordinary websites and apps, not just phone companies, and reach foreign operators with no office in Japan. (5) Consent to send data 'overseas' is not valid — you have to name the country.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 big one has already passed. On 17 July 2026 Japan published a large amendment to its privacy law. It introduces the country's first money penalty for privacy breaches, sets 16 as the age below which a guardian must be involved, adds rules for face and other biometric data, and raises the criminal penalties. It is not in force yet: the government has up to two years to switch it on by order, and no date has been announced. The other thing to watch is the new cyber defence law, which is being switched on in stages through 2027.High confidence
Hardest industry wall	All industries — Companies Act 1967, section 199	Government — デジタル庁におけるガバメントクラウド等の整備のためのクラウドサービスの提供 — 令和８年度募集調達仕様書