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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

Saudi ArabiaChecked 18 August 2026

Yes, with paperworkWork: HighEnforcement: Waking up

In one paragraph: Data can leave Saudi Arabia, but never for free. You need a purpose the law allows, a written safeguard such as the government's own standard contract, and a written risk assessment that asks whether the transfer could harm the Kingdom itself. Banks need the central bank's written permission before anything goes abroad. The privacy regulator is fully set up but publishes no fines.
The catch: The 'paperwork and you can send it' answer is true for an ordinary business. It is false for banks and finance companies, where the central bank must give written no-objection first and cloud is expected to sit inside the country. It is also unsettled for government bodies and critical national infrastructure: the old rule forcing them to host inside Saudi Arabia was deleted in 2024 and replaced by a duty to ask a government office for a decision, and that office has published no replacement rule.
Does this apply to me?: Yes. The law reaches a company anywhere in the world with no office in Saudi Arabia, as long as it handles the data of people living in the Kingdom. There is no size, revenue or headcount threshold to fall below. There is no general duty to appoint a local representative, but many organisations must register on the government's data platform and some must name a data protection officer.High confidence
Can the data leave the country?: Yes, with real paperwork. First the reason for sending it has to be on the government's short list of allowed purposes. Then you need a safeguard: the government's own standard contract, approved group-wide rules, or a certificate from a licensed body. Then you must write a risk assessment that includes whether the transfer could damage the Kingdom's vital interests. Two industries are much harder. Banks and finance companies must get the central bank's written no-objection before any data goes to an overseas supplier, and the central bank's rules say cloud services should sit inside Saudi Arabia unless it approves otherwise. For government bodies and critical national infrastructure the picture changed in 2024 and is now genuinely unclear.High confidence
What do I have to do to send it abroad?: The model is an approved-destination list, and the list is empty. The law says data may go to a country the regulator has judged good enough, but no such list has been published, so in practice nobody uses that route. Instead almost everyone relies on the escape hatches: sign the government's word-for-word standard contract, or get approved group-wide rules for a multinational, or send to a body holding a certificate from a licensed Saudi accreditation body. On top of that you must run a written risk assessment before the data moves.High confidence
Who enforces this — and are they actually working?: The Saudi Data and Artificial Intelligence Authority is the privacy regulator, and it is genuinely up and running. Its National Data Governance Platform is live and takes registrations, self-assessments, breach reports and complaints, and it has published the rulebook for the panels that hear violations and issue fines. What we could not find is a single published fine or named decision, so how hard it bites is still unknown. The financial regulator and the cybersecurity authority, by contrast, have supervised their sectors for years.Medium confidence
How long must I keep it, and when must I delete it?: Both directions apply, and the floor wins when they clash. The ceiling: you must destroy personal data without undue delay once the reason you collected it has gone, and also when someone asks, when they withdraw the only consent you relied on, or when you learn you processed it unlawfully. Destruction must reach backups too. The floor: your written record of processing activities must be kept for five years after the activity ends. If another law sets a keeping period, the law says keep the data until whichever is longer.High confidence
What happens when something goes wrong?: The main clock is 72 hours. If personal data is breached, lost or accessed unlawfully and that could harm the people involved, you must tell the privacy regulator within 72 hours of finding out, through the government's data platform — and you have to be registered on that platform before you can use the service. You must also tell the affected people without undue delay, in plain language. A second, separate clock runs for government bodies and critical national infrastructure, which owe cyber incident reports to the national cybersecurity authority under its own rules. Suppliers owe you notice without undue delay so you can meet your own deadline.High confidence
What's the trap?: Five things that are not in the summary. One: sending data abroad is not only about protecting the individual — you must also assess whether the transfer could harm the Kingdom's own vital interests, and there is a government guide telling you how. Two: the standard contract must be copied word for word, and changing it is itself a breach of the law, while the overseas recipient has to accept Saudi courts. Three: leaking or publishing sensitive data to hurt someone or to profit can put a person in prison for up to two years — this is a criminal charge, not a fine. Four: your supplier contract must go beyond a normal data processing agreement and say whether the supplier is subject to foreign laws and how that affects its compliance. Five: the widely quoted rule that all government and critical infrastructure data must be hosted inside Saudi Arabia was deleted in 2024, and quoting it today is wrong.High confidence
What's about to change?: Nothing is scheduled to commence on a fixed date in the next twelve months — the law and all its main regulations are already fully in force. The risk is the opposite kind: several switches the government already holds and can flip with no consultation. The biggest is the approved-country list, which the regulator is legally required to publish and has not; the day it appears, every transfer plan in the country needs rechecking. The second biggest is the missing localisation rule for government and critical infrastructure, which one office was handed in 2024 and has not yet written.Medium confidence
Hardest industry wall: None found.

The eight framework questions answered for each selected country
Question	UkraineChecked 18 August 2026	Saudi ArabiaChecked 18 August 2026
The three ratings	Depends on your industry Work: Medium Enforcement: Active	Yes, with paperwork Work: High 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.	Data can leave Saudi Arabia, but never for free. You need a purpose the law allows, a written safeguard such as the government's own standard contract, and a written risk assessment that asks whether the transfer could harm the Kingdom itself. Banks need the central bank's written permission before anything goes abroad. The privacy regulator is fully set up but publishes no fines.
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 and you can send it' answer is true for an ordinary business. It is false for banks and finance companies, where the central bank must give written no-objection first and cloud is expected to sit inside the country. It is also unsettled for government bodies and critical national infrastructure: the old rule forcing them to host inside Saudi Arabia was deleted in 2024 and replaced by a duty to ask a government office for a decision, and that office has published no replacement rule.
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. The law reaches a company anywhere in the world with no office in Saudi Arabia, as long as it handles the data of people living in the Kingdom. There is no size, revenue or headcount threshold to fall below. There is no general duty to appoint a local representative, but many organisations must register on the government's data platform and some must name a data protection officer.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 real paperwork. First the reason for sending it has to be on the government's short list of allowed purposes. Then you need a safeguard: the government's own standard contract, approved group-wide rules, or a certificate from a licensed body. Then you must write a risk assessment that includes whether the transfer could damage the Kingdom's vital interests. Two industries are much harder. Banks and finance companies must get the central bank's written no-objection before any data goes to an overseas supplier, and the central bank's rules say cloud services should sit inside Saudi Arabia unless it approves otherwise. For government bodies and critical national infrastructure the picture changed in 2024 and is now genuinely unclear.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 approved-destination list, and the list is empty. The law says data may go to a country the regulator has judged good enough, but no such list has been published, so in practice nobody uses that route. Instead almost everyone relies on the escape hatches: sign the government's word-for-word standard contract, or get approved group-wide rules for a multinational, or send to a body holding a certificate from a licensed Saudi accreditation body. On top of that you must run a written risk assessment before the data moves.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 Saudi Data and Artificial Intelligence Authority is the privacy regulator, and it is genuinely up and running. Its National Data Governance Platform is live and takes registrations, self-assessments, breach reports and complaints, and it has published the rulebook for the panels that hear violations and issue fines. What we could not find is a single published fine or named decision, so how hard it bites is still unknown. The financial regulator and the cybersecurity authority, by contrast, have supervised their sectors for years.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	Both directions apply, and the floor wins when they clash. The ceiling: you must destroy personal data without undue delay once the reason you collected it has gone, and also when someone asks, when they withdraw the only consent you relied on, or when you learn you processed it unlawfully. Destruction must reach backups too. The floor: your written record of processing activities must be kept for five years after the activity ends. If another law sets a keeping period, the law says keep the data until whichever is longer.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	The main clock is 72 hours. If personal data is breached, lost or accessed unlawfully and that could harm the people involved, you must tell the privacy regulator within 72 hours of finding out, through the government's data platform — and you have to be registered on that platform before you can use the service. You must also tell the affected people without undue delay, in plain language. A second, separate clock runs for government bodies and critical national infrastructure, which owe cyber incident reports to the national cybersecurity authority under its own rules. Suppliers owe you notice without undue delay so you can meet your own deadline.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 are not in the summary. One: sending data abroad is not only about protecting the individual — you must also assess whether the transfer could harm the Kingdom's own vital interests, and there is a government guide telling you how. Two: the standard contract must be copied word for word, and changing it is itself a breach of the law, while the overseas recipient has to accept Saudi courts. Three: leaking or publishing sensitive data to hurt someone or to profit can put a person in prison for up to two years — this is a criminal charge, not a fine. Four: your supplier contract must go beyond a normal data processing agreement and say whether the supplier is subject to foreign laws and how that affects its compliance. Five: the widely quoted rule that all government and critical infrastructure data must be hosted inside Saudi Arabia was deleted in 2024, and quoting it today is wrong.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	Nothing is scheduled to commence on a fixed date in the next twelve months — the law and all its main regulations are already fully in force. The risk is the opposite kind: several switches the government already holds and can flip with no consultation. The biggest is the approved-country list, which the regulator is legally required to publish and has not; the day it appears, every transfer plan in the country needs rechecking. The second biggest is the missing localisation rule for government and critical infrastructure, which one office was handed in 2024 and has not yet written.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	None found.