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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
Sri LankaChecked 18 August 2026
Yes, with paperworkWork: MediumEnforcement: Waking up
In one paragraph
Sri Lanka has a full privacy law on the books, but almost none of the parts that create duties for companies are switched on yet. The government has now fixed 1 January 2027 as the day the core duties start. Data may leave the country freely today. From 2027 you will need a written contract or similar promise from whoever receives it abroad. No fines have ever been issued.
The catch
The 'conditional' rating describes 1 January 2027, not today. As of 18 August 2026 the transfer rule is not in force, the individual-rights section has no start date at all, and the penalty section has no start date either. There are no industry data-storage walls: banking, payments, insurance, securities, health and telecom all lack a localisation rule. The only place data location is even mentioned is government, and there it is a preference, not a ban.
Does this apply to me?
Yes. The law reaches a company with no office in Sri Lanka if it offers goods or services to people in Sri Lanka, or watches how they behave online. It also catches anyone processing data inside the country. There is no size or revenue floor to fall below, and no requirement to appoint a local representative. But none of this bites until 1 January 2027, because the scope section itself has not started yet.High confidence
Can the data leave the country?
Today, yes, with nothing to sign — the transfer section is not in force. From 1 January 2027 data can still leave, but you must first get a binding promise from the receiver abroad that Sri Lankan protections will be honoured. There is no banned-country list and no approved-country list: Sri Lanka scrapped its country-approval system in October 2025. No industry has a rule forcing data to stay in Sri Lanka.High confidence
What do I have to do to send it abroad?
Right now, nothing. There is no approval to get, no list to check and no form to file, because the transfer section has not started. From 1 January 2027 you will need a written, binding commitment from the overseas receiver. The Authority is supposed to say exactly what form that takes, and it has not done so — only a draft from October 2024 exists, and that draft was written for a version of the law that no longer exists.High confidence
Who enforces this — and are they actually working?
The Data Protection Authority of Sri Lanka. It genuinely exists: it has a chairman, a seven-person board, a director-general, an office in Colombo and it publishes circulars and draft rules. But it has never issued a fine or a decision, and legally it cannot yet. The Authority itself says in writing that it will only investigate complaints once the relevant sections are switched on. The penalty section still has no start date.High confidence
How long must I keep it, and when must I delete it?
The floor is clearer than the ceiling. Banks, finance companies and other reporting institutions must keep transaction records for six years, and identity records for six years after the account closes. The ceiling is a principle, not a number: from 1 January 2027 you must not keep personal data in a form that identifies someone for longer than the purpose needs. Where the two clash, the six-year legal duty wins.High confidence
What happens when something goes wrong?
There is no deadline, because there is no duty yet. This is unusual and worth saying plainly: as of 18 August 2026 a company suffering a data breach in Sri Lanka has no legal obligation to tell anyone. Reporting to the national cyber team is voluntary. From 1 January 2027 you must notify the Authority, but the rules that set the form and the clock are still a draft. Banks are the exception and must report technology and cyber incidents to the Central Bank.High confidence
What's the trap?
Five things that will cost you a weekend. A child in Sri Lanka is anyone under sixteen, not eighteen, and a parent must consent for them. Fines are small but personal: directors can be made to pay unless they prove they did not know. The advertised start date of 18 March 2025 was cancelled four days before it arrived, so anything written before November 2025 is wrong. Company data is not protected the way you would expect, because the individual-rights section still has no start date. And the published transfer guidance describes a law that no longer exists.High confidence
What's about to change?
One hard date and four switches. On 1 January 2027 the scope, the processing duties and the controller duties all start, and the Central Bank's new outsourcing rules for banks start the same day. Before then the Authority is expected to finalise its rules on breach reporting, impact assessments, data protection officers and overseas transfers. Watch also for a second gazette bringing individual rights and the penalty section into force — without it, the law has duties but no teeth.High confidence
Hardest industry wall
  • Government Personal Data Protection Act section 26(4) and 26(5), as substituted by Act No. 22 of 2025