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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

MexicoChecked 18 August 2026

Depends on your industryWork: MediumEnforcement: Waking up

In one paragraph: Mexico's general privacy law does not care where you store data. There is no approved-country list, no standard contract to sign and no permission to ask for. You need the right wording in your privacy notice and, usually, the person's consent. The rules that actually pin data to Mexico live in banking, money-laundering and tax law, not in the privacy law.
The catch: The relaxed headline stops the moment you are a bank, a stockbroker, a crowdfunding platform, an insurer or a phone company. Banks need written permission from the banking regulator before any processing happens abroad. Separately, anti-money-laundering law and tax law require many ordinary businesses to keep their records at a Mexican address for ten and five years. Those rules bind companies that have never read a privacy law.
Does this apply to me?: Probably yes, but Mexico is unusually vague about it. The privacy law says only that it applies across Mexican territory. It does not spell out when it reaches a company based abroad. The old rulebook did say the law caught a foreign company that used equipment or systems located in Mexico, and let that company appoint a local representative instead of opening an office. That old rulebook belonged to a law that was scrapped in March 2025, so its status today is genuinely unclear. There is no revenue or headcount threshold to fall below.Medium confidence
Can the data leave the country?: Under the general privacy law, yes, and with very little paperwork. Mexico has no list of approved countries and no list of banned ones. Sending data to a company abroad is treated exactly like sending it to a company down the road: say so in your privacy notice, get the person's consent unless one of seven exceptions applies, and pass the privacy notice on to whoever receives the data. Handing data to your own supplier who only follows your instructions is not even counted as a transfer. Five sectors override this, and in three of them the override is severe.High confidence
What do I have to do to send it abroad?: Nothing needs approval and no list exists in either direction. The model is simply unrestricted: any destination is allowed. What you need is a privacy notice that names the transfer and carries a clause where the person accepts or refuses it, plus that person's consent unless one of seven legal exceptions covers you. Because there is no list to populate, the government cannot make this stricter by adding a country. It would take a new law or a new regulation.High confidence
Who enforces this — and are they actually working?: Mexico abolished its independent privacy regulator. The National Institute for Transparency, Access to Information and Data Protection was wound up in March 2025 and its staff, files and cases were moved into a government ministry, the Anti-Corruption and Good Government Ministry. So the referee is now part of the government rather than independent of it. The ministry is staffed, but the law says the detailed procedure for complaints, inspections and fines will be set out in a regulation, and that regulation still has not been published. Financial regulators, by contrast, are visibly active and update their rulebooks almost monthly.Medium confidence
How long must I keep it, and when must I delete it?: There is no single retention period. The privacy law says delete data once it is no longer needed, after a blocking period equal to the time limit for suing over the relationship. One hard ceiling is written into the law: information about someone breaking a contract must be erased six years after the default. The floors are longer and come from other laws. Tax records must be kept five years and their supporting documents must be available at your Mexican tax address. Anti-money-laundering records must be kept ten years at an address you register with the Finance Ministry. Phone companies keep call and location records for two years. Where a floor and a ceiling clash, the floor wins, because the privacy law lets you keep data to meet a legal duty.High confidence
What happens when something goes wrong?: There are at least three clocks and they do not agree. Under the general privacy law you must tell the affected people immediately if a breach significantly harms their money or their reputation, and there is no duty to tell the regulator at all. Banks face a much tighter set: tell the banking regulator immediately, tell affected customers within forty-eight hours, file a full report within five working days, and send a remediation plan within fifteen working days of the incident ending. Phone companies must hand requested records to the authorities within twenty-four hours and keep a team available every hour of every day. Mexico has no general cyber-incident reporting law that catches everyone.High confidence
What's the trap?: Five things catch people out. Every private business in Mexico is now legally required to ask customers for their national population ID number. Anti-money-laundering rules force many ordinary businesses to keep ten years of records at a Mexican address, which quietly rules out a pure foreign cloud setup. Mishandling data can put a person in prison, not just cost a company money. Banks must get written permission before any processing happens abroad, and that includes routine cloud hosting. And the rulebook the privacy law keeps pointing at does not exist.High confidence
What's about to change?: The biggest thing coming is a regulation that is already overdue. The privacy law repeatedly says a rulebook will set the deadlines for complaints, inspections and fines, and the government missed its own June 2025 deadline to publish it. When it lands it could change how enforcement works overnight, with no consultation. Health law was changed in January 2026 to put telehealth on a statutory footing, and the biometric national ID is still being rolled out. The dangerous powers are the ones the government already holds rather than any bill in parliament.Medium confidence
Hardest industry wall: Payments — Disposiciones de carácter general aplicables a las instituciones de tecnología financiera, artículos 85 a 87
Finance — Ley Federal para la Prevención e Identificación de Operaciones con Recursos de Procedencia Ilícita, artículos 15 y 18
All industries — Código Fiscal de la Federación, artículos 28 y 30
Telecoms — Ley en Materia de Telecomunicaciones y Radiodifusión, artículo 183

The eight framework questions answered for each selected country
Question	UkraineChecked 18 August 2026	MexicoChecked 18 August 2026
The three ratings	Depends on your industry Work: Medium Enforcement: Active	Depends on your industry Work: Medium Enforcement: Waking up
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.	Mexico's general privacy law does not care where you store data. There is no approved-country list, no standard contract to sign and no permission to ask for. You need the right wording in your privacy notice and, usually, the person's consent. The rules that actually pin data to Mexico live in banking, money-laundering and tax law, not in the privacy law.
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 relaxed headline stops the moment you are a bank, a stockbroker, a crowdfunding platform, an insurer or a phone company. Banks need written permission from the banking regulator before any processing happens abroad. Separately, anti-money-laundering law and tax law require many ordinary businesses to keep their records at a Mexican address for ten and five years. Those rules bind companies that have never read a privacy 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	Probably yes, but Mexico is unusually vague about it. The privacy law says only that it applies across Mexican territory. It does not spell out when it reaches a company based abroad. The old rulebook did say the law caught a foreign company that used equipment or systems located in Mexico, and let that company appoint a local representative instead of opening an office. That old rulebook belonged to a law that was scrapped in March 2025, so its status today is genuinely unclear. There is no revenue or headcount threshold to fall below.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	Under the general privacy law, yes, and with very little paperwork. Mexico has no list of approved countries and no list of banned ones. Sending data to a company abroad is treated exactly like sending it to a company down the road: say so in your privacy notice, get the person's consent unless one of seven exceptions applies, and pass the privacy notice on to whoever receives the data. Handing data to your own supplier who only follows your instructions is not even counted as a transfer. Five sectors override this, and in three of them the override is severe.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	Nothing needs approval and no list exists in either direction. The model is simply unrestricted: any destination is allowed. What you need is a privacy notice that names the transfer and carries a clause where the person accepts or refuses it, plus that person's consent unless one of seven legal exceptions covers you. Because there is no list to populate, the government cannot make this stricter by adding a country. It would take a new law or a new regulation.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	Mexico abolished its independent privacy regulator. The National Institute for Transparency, Access to Information and Data Protection was wound up in March 2025 and its staff, files and cases were moved into a government ministry, the Anti-Corruption and Good Government Ministry. So the referee is now part of the government rather than independent of it. The ministry is staffed, but the law says the detailed procedure for complaints, inspections and fines will be set out in a regulation, and that regulation still has not been published. Financial regulators, by contrast, are visibly active and update their rulebooks almost monthly.Medium 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	There is no single retention period. The privacy law says delete data once it is no longer needed, after a blocking period equal to the time limit for suing over the relationship. One hard ceiling is written into the law: information about someone breaking a contract must be erased six years after the default. The floors are longer and come from other laws. Tax records must be kept five years and their supporting documents must be available at your Mexican tax address. Anti-money-laundering records must be kept ten years at an address you register with the Finance Ministry. Phone companies keep call and location records for two years. Where a floor and a ceiling clash, the floor wins, because the privacy law lets you keep data to meet a legal duty.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	There are at least three clocks and they do not agree. Under the general privacy law you must tell the affected people immediately if a breach significantly harms their money or their reputation, and there is no duty to tell the regulator at all. Banks face a much tighter set: tell the banking regulator immediately, tell affected customers within forty-eight hours, file a full report within five working days, and send a remediation plan within fifteen working days of the incident ending. Phone companies must hand requested records to the authorities within twenty-four hours and keep a team available every hour of every day. Mexico has no general cyber-incident reporting law that catches everyone.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 catch people out. Every private business in Mexico is now legally required to ask customers for their national population ID number. Anti-money-laundering rules force many ordinary businesses to keep ten years of records at a Mexican address, which quietly rules out a pure foreign cloud setup. Mishandling data can put a person in prison, not just cost a company money. Banks must get written permission before any processing happens abroad, and that includes routine cloud hosting. And the rulebook the privacy law keeps pointing at does not exist.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 biggest thing coming is a regulation that is already overdue. The privacy law repeatedly says a rulebook will set the deadlines for complaints, inspections and fines, and the government missed its own June 2025 deadline to publish it. When it lands it could change how enforcement works overnight, with no consultation. Health law was changed in January 2026 to put telehealth on a statutory footing, and the biometric national ID is still being rolled out. The dangerous powers are the ones the government already holds rather than any bill in parliament.Medium 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	Payments — Disposiciones de carácter general aplicables a las instituciones de tecnología financiera, artículos 85 a 87 Finance — Ley Federal para la Prevención e Identificación de Operaciones con Recursos de Procedencia Ilícita, artículos 15 y 18 All industries — Código Fiscal de la Federación, artículos 28 y 30 Telecoms — Ley en Materia de Telecomunicaciones y Radiodifusión, artículo 183