Compare countries

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

Countries

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

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	UkraineChecked 18 August 2026	JapanChecked 18 August 2026
The three ratings	Depends on your industry Work: Medium Enforcement: Active	Yes, with paperwork Work: Medium 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.	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 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.	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?	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. 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, 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	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 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	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 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 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 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	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?	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	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) 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. (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 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 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 — 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	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