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

Countries

TurkeyChecked 18 August 2026

Depends on your industryWork: HighEnforcement: Active

In one paragraph: Turkey lets personal data leave, but only after you build the paperwork yourself. The regulator has never declared a single country safe, so the approved-destination list is empty. Most companies use a government-published standard contract and must file it within five working days. The regulator is busy: it fined 876 organisations in 2025.
The catch: The general rule is 'paperwork, then you may send it'. That stops being true the moment you touch payments, banking, telecoms networks, public-sector systems or critical infrastructure. Payment and electronic money firms must keep their systems, their backups and their data inside Turkey, and may only use cloud providers the central bank has approved by name.
Does this apply to me?: Yes. A company with no office in Turkey is still caught, and it is caught harder than a local one. Any organisation based outside Turkey that decides why and how Turkish people's data is used must appoint a representative inside Turkey and sign up to the public register of data controllers before it starts processing. That representative has to be a company set up in Turkey or a Turkish citizen. Turkish small businesses can escape the register if they have fewer than 50 staff and a balance sheet under 100 million lira, but there is no such let-off for foreign companies.High confidence
Can the data leave the country?: It depends entirely on your industry, which is why Turkey is rated 'sectoral'. Under the general privacy law data may leave, but only after you put an approved safeguard in place, because the regulator has not yet declared any country safe. In payments and banking the answer flips to no: systems, backups and data have to sit inside Turkey. Public bodies, critical infrastructure, telecoms networks and health records all carry their own extra restrictions on top.High confidence
What do I have to do to send it abroad?: The model is an approved-destination list, and the list is empty. Nobody can rely on their country being blessed, so almost everyone uses one of the safeguards instead. The usual route is signing one of four standard contracts the regulator publishes, then telling the regulator within five working days of signing. Group companies can instead get binding corporate rules approved, and there is a permission route for bespoke undertakings, but that route almost always fails.High confidence
Who enforces this — and are they actually working?: The Personal Data Protection Authority, and it is fully up and running. In 2025 its board met 42 times, took 2,528 decisions, handled 12,512 complaints and fined 876 organisations a combined 352.5 million lira, which is roughly 8 million US dollars. It publishes named breach announcements most weeks. Financial, telecoms and insurance regulators enforce their own rules alongside it, and a new Cybersecurity Directorate has taken over the national cyber incident centre.High confidence
How long must I keep it, and when must I delete it?: Both directions apply, and the ceiling is unusual. Turkey does not give you a fixed number of months to delete by. Instead, once your reason for holding data runs out, you must erase it at your next scheduled clear-out, and any organisation on the public register has to publish a written retention and destruction policy setting those dates. The floor comes from ordinary commercial and tax law, which forces you to keep books and invoices for years.Medium confidence
What happens when something goes wrong?: There are at least three clocks. The privacy one is 72 hours: from the moment you learn that data has been taken unlawfully, you have three days to tell the Personal Data Protection Board, and you must tell the affected people as soon as you reasonably can. If you miss the 72 hours you must still report and explain why you were late. Companies based abroad have to report too, if people in Turkey are affected.High confidence
What's the trap?: Five things bite people. One: most fines are for paperwork, not privacy. Two thirds of the organisations fined in 2025 were punished for the public register, not for mishandling anyone's data. Two: the bespoke permission route for sending data abroad is close to a dead end, with 76 of 89 applications refused in 2025. Three: filing your standard contract invites inspection rather than closing the file. Four: your representative in Turkey must be Turkish. Five: no country is on the safe list, so there is no shortcut.High confidence
What's about to change?: Two dated items and one direction of travel. Retailers running loyalty cards have until 28 February 2027 to build a way of checking that the person at the till really owns the card, after the regulator extended the original deadline in July 2026. Public bodies are working to a July 2026 ruling on what they may publish online. And the government is pushing openly on data sovereignty, with the President chairing a cyber security meeting in May 2026 that treated data as a strategic asset.High confidence
Hardest industry wall: Payments — Odeme ve Elektronik Para Kuruluslarinin Bilgi Sistemleri ile Odeme Hizmeti Saglayicilarinin Odeme Hizmetleri Alanindaki Veri Paylasim Servislerine Iliskin Teblig
Banking — Bankalarin Bilgi Sistemleri ve Elektronik Bankacilik Hizmetleri Hakkinda Yonetmelik
Government — 2019/12 sayili Bilgi ve Iletisim Guvenligi Tedbirleri Genelgesi ve Bilgi ve Iletisim Guvenligi Rehberi

HungaryChecked 18 August 2026

Yes, with paperworkWork: HighEnforcement: Active

In one paragraph: Hungary has no general rule that data must stay in the country. It runs on the European rulebook: you may send data abroad if you have the right legal paperwork in place. Hungary used to force state registers to be processed on Hungarian soil, but that rule was scrapped in April 2024. The privacy regulator is real, staffed and issuing decisions, though its fines are small by European standards.
The catch: Two things break the easy answer. Since January 2025 a large slice of the economy — energy, transport, banking, health, water, digital infrastructure, waste, manufacturing and most of the public sector — may only use a shared cloud or process data outside Hungary after completing a formal data classification under the cybersecurity law. And an online casino serving Hungarian players must keep its game server inside the European Economic Area, full stop.
Does this apply to me?: Yes. A company with no office in Hungary is still caught if it offers goods or services to people in Hungary or watches their behaviour, because the European privacy rules reach outside Europe. There is no revenue or headcount threshold to hide under. If you have no establishment anywhere in Europe you must appoint a written representative inside Europe, and Hungary is a perfectly ordinary place to put one.High confidence
Can the data leave the country?: Yes, on the normal European terms — nothing in general Hungarian law says data must be stored in Hungary. This is a change worth noticing: the rule that state registers could only be processed on Hungarian soil was repealed with effect from 1 April 2024, and the law that replaced it has no territorial restriction at all. Two sectors override this. An online casino must keep its game server inside the European Economic Area. And any company or public body inside the scope of Hungary's cybersecurity law must finish a formal data classification before it uses a shared cloud service or processes data abroad.Medium confidence
What do I have to do to send it abroad?: You need a European transfer tool before the data leaves, and Hungary adds no extra permit, filing or fee on top. The model is an approved-list one: you may send data to a country the European Commission has declared safe, or you sign the standard European contract clauses and write down a risk assessment of the destination. There is no Hungarian government sign-off, and no Hungarian list of banned countries. For police, security and other work outside the European privacy rules, Hungary's own Info Act sets the conditions instead.High confidence
Who enforces this — and are they actually working?: The National Authority for Data Protection and Freedom of Information, known by its Hungarian initials NAIH, and it is genuinely working. It has published decisions right through to May 2026, released its report on 2025 activity on 30 March 2026, and issued public statements in July and August 2026. Its president is Dr Attila Peterfalvi. The catch is size, not activity: a typical fine is small — two million forint, roughly six thousand dollars, in an April 2025 data-security case.High confidence
How long must I keep it, and when must I delete it?: Hungary pushes hard in both directions. The floor is long: accounting records and vouchers must be kept for eight years, and health records for decades — the health data law works in periods of thirty years and more. The ceiling is the European rule that you delete personal data once the purpose is spent. When the two collide, the specific statutory keep-period wins, so a deletion request does not empty your ledgers or a hospital's files.Medium confidence
What happens when something goes wrong?: Count at least two clocks, and three if you are a bank. A personal data breach goes to the privacy regulator within 72 hours. A cyber incident at a company or public body covered by the cybersecurity law goes to the national incident response centre, and the European rules that Hungary is copying use a 24-hour first alert followed by a fuller report at 72 hours. Financial firms have a separate and faster set of deadlines under the European operational resilience rules.Medium confidence
What's the trap?: Five things that are not in the summary. One: mishandling personal data is a crime in Hungary, not just a fine — up to one year in prison, two years for sensitive data, three years for public officials. Two: the old rule forcing state data to stay in Hungary is dead, so quoting it makes you look out of date, while the new cybersecurity classification gate is very much alive and most checklists miss it. Three: several cybersecurity deadlines have already passed, so newly in-scope companies are late on day one. Four: an online casino's game server must sit in the European Economic Area. Five: Hungary's freedom-of-information regime can make your contract with a state body public.High confidence
What's about to change?: Three dated items. The Court of Justice will rule on Hungary's sovereignty protection law; the court's adviser said on 12 February 2026 that it breaks European law, and the judgment could land any time. From 12 January 2027 cloud providers across Europe, Hungary included, must charge nothing to move your data out. And Hungary's cybersecurity supervision moves from paperwork to inspections now that the first audit deadline of 30 June 2026 has passed.Medium confidence
Hardest industry wall: Online gaming — 1991. evi XXXIV. torveny a szerencsejatek szervezeserol es a vegrehajtasi rendeletei (online kaszinojatek engedelyezesi feltetelei)
Government — 2021. evi XCI. torveny a nemzeti adatvagyonrol, 13. §

The eight framework questions answered for each selected country
Question	TurkeyChecked 18 August 2026	HungaryChecked 18 August 2026
The three ratings	Depends on your industry Work: High Enforcement: Active	Yes, with paperwork Work: High Enforcement: Active
In one paragraph	Turkey lets personal data leave, but only after you build the paperwork yourself. The regulator has never declared a single country safe, so the approved-destination list is empty. Most companies use a government-published standard contract and must file it within five working days. The regulator is busy: it fined 876 organisations in 2025.	Hungary has no general rule that data must stay in the country. It runs on the European rulebook: you may send data abroad if you have the right legal paperwork in place. Hungary used to force state registers to be processed on Hungarian soil, but that rule was scrapped in April 2024. The privacy regulator is real, staffed and issuing decisions, though its fines are small by European standards.
The catch	The general rule is 'paperwork, then you may send it'. That stops being true the moment you touch payments, banking, telecoms networks, public-sector systems or critical infrastructure. Payment and electronic money firms must keep their systems, their backups and their data inside Turkey, and may only use cloud providers the central bank has approved by name.	Two things break the easy answer. Since January 2025 a large slice of the economy — energy, transport, banking, health, water, digital infrastructure, waste, manufacturing and most of the public sector — may only use a shared cloud or process data outside Hungary after completing a formal data classification under the cybersecurity law. And an online casino serving Hungarian players must keep its game server inside the European Economic Area, full stop.
Does this apply to me?	Yes. A company with no office in Turkey is still caught, and it is caught harder than a local one. Any organisation based outside Turkey that decides why and how Turkish people's data is used must appoint a representative inside Turkey and sign up to the public register of data controllers before it starts processing. That representative has to be a company set up in Turkey or a Turkish citizen. Turkish small businesses can escape the register if they have fewer than 50 staff and a balance sheet under 100 million lira, but there is no such let-off for foreign companies.High confidence	Yes. A company with no office in Hungary is still caught if it offers goods or services to people in Hungary or watches their behaviour, because the European privacy rules reach outside Europe. There is no revenue or headcount threshold to hide under. If you have no establishment anywhere in Europe you must appoint a written representative inside Europe, and Hungary is a perfectly ordinary place to put one.High confidence
Can the data leave the country?	It depends entirely on your industry, which is why Turkey is rated 'sectoral'. Under the general privacy law data may leave, but only after you put an approved safeguard in place, because the regulator has not yet declared any country safe. In payments and banking the answer flips to no: systems, backups and data have to sit inside Turkey. Public bodies, critical infrastructure, telecoms networks and health records all carry their own extra restrictions on top.High confidence	Yes, on the normal European terms — nothing in general Hungarian law says data must be stored in Hungary. This is a change worth noticing: the rule that state registers could only be processed on Hungarian soil was repealed with effect from 1 April 2024, and the law that replaced it has no territorial restriction at all. Two sectors override this. An online casino must keep its game server inside the European Economic Area. And any company or public body inside the scope of Hungary's cybersecurity law must finish a formal data classification before it uses a shared cloud service or processes data abroad.Medium confidence
What do I have to do to send it abroad?	The model is an approved-destination list, and the list is empty. Nobody can rely on their country being blessed, so almost everyone uses one of the safeguards instead. The usual route is signing one of four standard contracts the regulator publishes, then telling the regulator within five working days of signing. Group companies can instead get binding corporate rules approved, and there is a permission route for bespoke undertakings, but that route almost always fails.High confidence	You need a European transfer tool before the data leaves, and Hungary adds no extra permit, filing or fee on top. The model is an approved-list one: you may send data to a country the European Commission has declared safe, or you sign the standard European contract clauses and write down a risk assessment of the destination. There is no Hungarian government sign-off, and no Hungarian list of banned countries. For police, security and other work outside the European privacy rules, Hungary's own Info Act sets the conditions instead.High confidence
Who enforces this — and are they actually working?	The Personal Data Protection Authority, and it is fully up and running. In 2025 its board met 42 times, took 2,528 decisions, handled 12,512 complaints and fined 876 organisations a combined 352.5 million lira, which is roughly 8 million US dollars. It publishes named breach announcements most weeks. Financial, telecoms and insurance regulators enforce their own rules alongside it, and a new Cybersecurity Directorate has taken over the national cyber incident centre.High confidence	The National Authority for Data Protection and Freedom of Information, known by its Hungarian initials NAIH, and it is genuinely working. It has published decisions right through to May 2026, released its report on 2025 activity on 30 March 2026, and issued public statements in July and August 2026. Its president is Dr Attila Peterfalvi. The catch is size, not activity: a typical fine is small — two million forint, roughly six thousand dollars, in an April 2025 data-security case.High confidence
How long must I keep it, and when must I delete it?	Both directions apply, and the ceiling is unusual. Turkey does not give you a fixed number of months to delete by. Instead, once your reason for holding data runs out, you must erase it at your next scheduled clear-out, and any organisation on the public register has to publish a written retention and destruction policy setting those dates. The floor comes from ordinary commercial and tax law, which forces you to keep books and invoices for years.Medium confidence	Hungary pushes hard in both directions. The floor is long: accounting records and vouchers must be kept for eight years, and health records for decades — the health data law works in periods of thirty years and more. The ceiling is the European rule that you delete personal data once the purpose is spent. When the two collide, the specific statutory keep-period wins, so a deletion request does not empty your ledgers or a hospital's files.Medium confidence
What happens when something goes wrong?	There are at least three clocks. The privacy one is 72 hours: from the moment you learn that data has been taken unlawfully, you have three days to tell the Personal Data Protection Board, and you must tell the affected people as soon as you reasonably can. If you miss the 72 hours you must still report and explain why you were late. Companies based abroad have to report too, if people in Turkey are affected.High confidence	Count at least two clocks, and three if you are a bank. A personal data breach goes to the privacy regulator within 72 hours. A cyber incident at a company or public body covered by the cybersecurity law goes to the national incident response centre, and the European rules that Hungary is copying use a 24-hour first alert followed by a fuller report at 72 hours. Financial firms have a separate and faster set of deadlines under the European operational resilience rules.Medium confidence
What's the trap?	Five things bite people. One: most fines are for paperwork, not privacy. Two thirds of the organisations fined in 2025 were punished for the public register, not for mishandling anyone's data. Two: the bespoke permission route for sending data abroad is close to a dead end, with 76 of 89 applications refused in 2025. Three: filing your standard contract invites inspection rather than closing the file. Four: your representative in Turkey must be Turkish. Five: no country is on the safe list, so there is no shortcut.High confidence	Five things that are not in the summary. One: mishandling personal data is a crime in Hungary, not just a fine — up to one year in prison, two years for sensitive data, three years for public officials. Two: the old rule forcing state data to stay in Hungary is dead, so quoting it makes you look out of date, while the new cybersecurity classification gate is very much alive and most checklists miss it. Three: several cybersecurity deadlines have already passed, so newly in-scope companies are late on day one. Four: an online casino's game server must sit in the European Economic Area. Five: Hungary's freedom-of-information regime can make your contract with a state body public.High confidence
What's about to change?	Two dated items and one direction of travel. Retailers running loyalty cards have until 28 February 2027 to build a way of checking that the person at the till really owns the card, after the regulator extended the original deadline in July 2026. Public bodies are working to a July 2026 ruling on what they may publish online. And the government is pushing openly on data sovereignty, with the President chairing a cyber security meeting in May 2026 that treated data as a strategic asset.High confidence	Three dated items. The Court of Justice will rule on Hungary's sovereignty protection law; the court's adviser said on 12 February 2026 that it breaks European law, and the judgment could land any time. From 12 January 2027 cloud providers across Europe, Hungary included, must charge nothing to move your data out. And Hungary's cybersecurity supervision moves from paperwork to inspections now that the first audit deadline of 30 June 2026 has passed.Medium confidence
Hardest industry wall	Payments — Odeme ve Elektronik Para Kuruluslarinin Bilgi Sistemleri ile Odeme Hizmeti Saglayicilarinin Odeme Hizmetleri Alanindaki Veri Paylasim Servislerine Iliskin Teblig Banking — Bankalarin Bilgi Sistemleri ve Elektronik Bankacilik Hizmetleri Hakkinda Yonetmelik Government — 2019/12 sayili Bilgi ve Iletisim Guvenligi Tedbirleri Genelgesi ve Bilgi ve Iletisim Guvenligi Rehberi	Online gaming — 1991. evi XXXIV. torveny a szerencsejatek szervezeserol es a vegrehajtasi rendeletei (online kaszinojatek engedelyezesi feltetelei) Government — 2021. evi XCI. torveny a nemzeti adatvagyonrol, 13. §