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UkraineChecked 18 August 2026

Depends on your industryWork: MediumEnforcement: Active

In one paragraph: Ukraine still runs its 2010 privacy law, not a European-style one. Personal data may leave the country only to a country the law treats as safe — that means Europe and the 50-odd countries that signed a Council of Europe data treaty. The United States is not on that list. Fines are tiny, but the human rights Commissioner really does inspect, and misusing data can be a crime.
The catch: The general picture changes completely once government is involved. If a Ukrainian state body is the organisation deciding how personal data is used, only a Ukrainian state-owned or municipal company may process that data for it — a private or foreign supplier cannot. State systems, defence data and critical infrastructure also carry hard location rules, and several of the current permissions exist only because the country is under martial law.
Does this apply to me?: Probably not, if you have nothing in Ukraine. The 2010 law simply says it covers the processing of personal data by automated means or in structured paper files. It contains no clause reaching foreign companies that only sell into Ukraine from abroad, and it does not make you appoint a local representative. There is no size or revenue threshold either — a corner shop and a bank are treated the same.Medium confidence
Can the data leave the country?: Yes, but only to countries Ukraine already treats as safe. Those are the European Economic Area countries plus every country that has signed the Council of Europe's data protection treaty — roughly 55 states. The United States has signed neither, so routine transfers to American servers do not fit the safe-country route and need one of the narrow exceptions instead. Whole sectors then override this: government, defence and critical infrastructure are far tighter, and securities firms are unusually looser.High confidence
What do I have to do to send it abroad?: There is no form to file and no government permission to obtain. You either send the data to a country the law already treats as safe, or you rely on one of five narrow exceptions. Those are: the person's clear consent, necessity for a contract made for that person's benefit, protecting someone's life, an important public interest or a legal claim, and the sender giving guarantees that private and family life will not be interfered with. That last one is a catch-all that a lot of Ukrainian practice leans on.High confidence
Who enforces this — and are they actually working?: The Ukrainian Parliament Commissioner for Human Rights — the national ombudsman — is the data protection regulator, and it is genuinely working. It publishes a fresh inspection programme every three months; the one for July to September 2026 went up on 2 July 2026. It also publishes what it found, including a run of checks on the national electronic health system. The catch is the money: the regulator cannot fine anyone itself, it writes up a case and sends it to a court, and the maximum penalty is about $800.High confidence
How long must I keep it, and when must I delete it?: The floor comes from tax law. Companies must keep primary accounting documents and financial statements for 1,825 days — five years. Papers needed for transfer pricing checks run to 2,555 days, which is seven years. Everything else the tax authority may ask for runs 1,095 days, three years. The ceiling comes from the privacy law: you must delete personal data when the agreed storage period runs out, or when your relationship with the person ends, unless another law tells you to keep it.High confidence
What happens when something goes wrong?: This is the biggest surprise in Ukrainian law: if you lose personal data, there is no duty to tell the regulator and no duty to tell the people affected. The 2010 privacy law simply has no breach reporting clause. The only mandatory clocks sit in the cyber security regime, and they only bite if you run a state system or a piece of critical information infrastructure. Even there the law does not set the hours — it leaves the deadline to an order of the cyber agency.Medium confidence
What's the trap?: Five. (1) If a Ukrainian government body is the one deciding how personal data is used, only a Ukrainian state-owned or municipal company may handle that data for it — a private or foreign supplier is not allowed at all. (2) Misusing personal data is a crime, not just a fine, and repeat offences carry up to five years in prison. (3) The fines are aimed at named individuals and sole traders, not at companies. (4) Posting anything that shows where Ukrainian troops are carries five to eight years in prison. (5) Martial law lets the government limit the constitutional right to privacy that the whole system rests on.High confidence
What's about to change?: The date to watch is not a new law — it is the end of the war. Martial law was extended again on 13 July 2026 and now runs from 2 August 2026 for 90 days, so to about 31 October 2026. Several of today's permissions exist only while it lasts, and they die six months after it ends. A European-style replacement privacy law has been discussed for years and has still not been passed, so nothing about the current regime should be planned around its arrival.High confidence
Hardest industry wall: Government — Закон України "Про захист персональних даних", частина третя статті 4
Government — Закон України "Про захист інформації в інформаційно-комунікаційних системах"
Defence — Закон України "Про хмарні послуги"
Mapping and location — Кримінальний кодекс України, стаття 114-2

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	UkraineChecked 18 August 2026	ChinaChecked 18 August 2026
The three ratings	Depends on your industry Work: Medium Enforcement: Active	Yes, with paperwork Work: Very high Enforcement: Active
In one paragraph	Ukraine still runs its 2010 privacy law, not a European-style one. Personal data may leave the country only to a country the law treats as safe — that means Europe and the 50-odd countries that signed a Council of Europe data treaty. The United States is not on that list. Fines are tiny, but the human rights Commissioner really does inspect, and misusing data can be a crime.	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 general picture changes completely once government is involved. If a Ukrainian state body is the organisation deciding how personal data is used, only a Ukrainian state-owned or municipal company may process that data for it — a private or foreign supplier cannot. State systems, defence data and critical infrastructure also carry hard location rules, and several of the current permissions exist only because the country is under martial law.	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?	Probably not, if you have nothing in Ukraine. The 2010 law simply says it covers the processing of personal data by automated means or in structured paper files. It contains no clause reaching foreign companies that only sell into Ukraine from abroad, and it does not make you appoint a local representative. There is no size or revenue threshold either — a corner shop and a bank are treated the same.Medium 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, but only to countries Ukraine already treats as safe. Those are the European Economic Area countries plus every country that has signed the Council of Europe's data protection treaty — roughly 55 states. The United States has signed neither, so routine transfers to American servers do not fit the safe-country route and need one of the narrow exceptions instead. Whole sectors then override this: government, defence and critical infrastructure are far tighter, and securities firms are unusually looser.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 form to file and no government permission to obtain. You either send the data to a country the law already treats as safe, or you rely on one of five narrow exceptions. Those are: the person's clear consent, necessity for a contract made for that person's benefit, protecting someone's life, an important public interest or a legal claim, and the sender giving guarantees that private and family life will not be interfered with. That last one is a catch-all that a lot of Ukrainian practice leans on.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 Ukrainian Parliament Commissioner for Human Rights — the national ombudsman — is the data protection regulator, and it is genuinely working. It publishes a fresh inspection programme every three months; the one for July to September 2026 went up on 2 July 2026. It also publishes what it found, including a run of checks on the national electronic health system. The catch is the money: the regulator cannot fine anyone itself, it writes up a case and sends it to a court, and the maximum penalty is about $800.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?	The floor comes from tax law. Companies must keep primary accounting documents and financial statements for 1,825 days — five years. Papers needed for transfer pricing checks run to 2,555 days, which is seven years. Everything else the tax authority may ask for runs 1,095 days, three years. The ceiling comes from the privacy law: you must delete personal data when the agreed storage period runs out, or when your relationship with the person ends, unless another law tells you to keep it.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?	This is the biggest surprise in Ukrainian law: if you lose personal data, there is no duty to tell the regulator and no duty to tell the people affected. The 2010 privacy law simply has no breach reporting clause. The only mandatory clocks sit in the cyber security regime, and they only bite if you run a state system or a piece of critical information infrastructure. Even there the law does not set the hours — it leaves the deadline to an order of the cyber agency.Medium 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. (1) If a Ukrainian government body is the one deciding how personal data is used, only a Ukrainian state-owned or municipal company may handle that data for it — a private or foreign supplier is not allowed at all. (2) Misusing personal data is a crime, not just a fine, and repeat offences carry up to five years in prison. (3) The fines are aimed at named individuals and sole traders, not at companies. (4) Posting anything that shows where Ukrainian troops are carries five to eight years in prison. (5) Martial law lets the government limit the constitutional right to privacy that the whole system rests on.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?	The date to watch is not a new law — it is the end of the war. Martial law was extended again on 13 July 2026 and now runs from 2 August 2026 for 90 days, so to about 31 October 2026. Several of today's permissions exist only while it lasts, and they die six months after it ends. A European-style replacement privacy law has been discussed for years and has still not been passed, so nothing about the current regime should be planned around its arrival.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	Government — Закон України "Про захист персональних даних", частина третя статті 4 Government — Закон України "Про захист інформації в інформаційно-комунікаційних системах" Defence — Закон України "Про хмарні послуги" Mapping and location — Кримінальний кодекс України, стаття 114-2	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）