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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

United StatesChecked 18 August 2026

Depends on your industryWork: HighEnforcement: Active

In one paragraph: In general the United States lets data go anywhere. There is no national privacy law and no permit is needed to move data abroad. Two things bite hard. Six countries are effectively off limits for large amounts of sensitive data, with prison sentences attached. And anything connected to government work must physically stay on American soil.
The catch: The open headline stops the moment you touch one of six areas: government contracting, police records, federal tax records, defence technical data, telecom licences, and bulk sensitive data flowing to China, Russia, Iran, North Korea, Cuba or Venezuela. Also note that the rule that actually binds you is almost always a state law or an industry regulator's rule, not a national privacy act. There isn't one.
Does this apply to me?: Yes. American rules reach a foreign company with no office in the country. California's privacy law applies to any for-profit business that 'does business in California' and crosses one of three thresholds, and physical presence is not one of them. The children's rule covers foreign websites aimed at American children. No state and no federal law requires you to appoint a local representative — a real difference from Europe.High confidence
Can the data leave the country?: It depends entirely on your industry, so the single national answer is misleading. For ordinary consumer or employee data, yes — send it anywhere, no paperwork. But six sectors have hard walls. Government contracting, police data, federal tax data and defence work require the data to physically stay in the United States. Telecom licences restrict which foreign staff may even look at records. And for anyone, sending large volumes of sensitive data to six named countries is now a crime.High confidence
What do I have to do to send it abroad?: For ordinary data, nothing. No standard contract, no government approval, no destination approval list. The model is a blocklist and it is now populated: six countries are named. Before you move large volumes of sensitive data, your only real job is to work out whether a country of concern, or a company or person they control, could end up with access — including through a vendor, an investor or an employee.High confidence
Who enforces this — and are they actually working?: Nobody, and everybody. There is no national privacy regulator. Instead the consumer protection regulator, the health department, the securities regulator, the communications regulator, the Justice Department, all fifty state attorneys general and one dedicated state privacy agency each enforce a slice. Almost all of them are visibly working right now. The one exception is the new national data transfer programme: it is staffed and issuing guidance but has published no enforcement action yet.High confidence
How long must I keep it, and when must I delete it?: There is a strong floor and a weak but growing ceiling. Investment firms must keep some books for six years and most others for three, with the first two years easy to reach. Health providers keep their paperwork for six years. In the other direction, state privacy laws now force you to publish how long you keep each type of data and to stop keeping it longer than you said, and since April 2026 children's data may no longer be kept indefinitely. Where a keep-it rule and a delete-it rule collide, the keep-it rule wins: every state law carves out data you are required by law to retain.High confidence
What happens when something goes wrong?: Count the clocks — there are at least seven, and they disagree. New York financial firms: 72 hours to the state regulator, and only 24 hours to report paying a ransom. Telecom carriers: seven working days to the police agencies and the communications regulator, and you may not warn customers until seven working days after that. Investment and finance firms: 30 days to affected customers. Health organisations: 60 days. Texas and many other states: 30 days to the state attorney general. Listed companies: four working days to disclose a material incident. The overlap, not any single deadline, is what people fail.High confidence
What's the trap?: Five that cost people their weekend. One: the national data transfer programme carries prison — up to twenty years for a deliberate breach. Two: Illinois lets individuals sue over fingerprints and face scans with fixed damages per person, no proof of harm needed, and that is where the largest privacy payouts happen. Three: the children's rule uses under 13, but several state laws use under 18, so a single age gate will not do. Four: government work means American soil, and police data allows only the United States, its territories, tribal lands and Canada. Five: a rule can be printed in the law book and still be unenforceable, because a court has blocked it.High confidence
What's about to change?: Four things in the next twelve months. The national critical infrastructure reporting rule should be finalised in late 2026, which will switch on a 72-hour incident clock and a 24-hour ransom-payment clock for a very wide range of businesses. California's rules on automated decision-making bite on 1 January 2027. The open banking rule is being rewritten after a court blocked it. And a federal privacy bill is moving in Congress, but it is only a bill and binds nobody.High confidence
Hardest industry wall: Government — Criminal Justice Information Services (CJIS) Security Policy
Government — Publication 1075, Tax Information Security Guidelines for Federal, State and Local Agencies
Defence — Defense Federal Acquisition Regulation Supplement clause 252.239-7010, Cloud Computing Services
Telecoms — National security agreement / letter of assurance conditioning a section 214 authorisation, reviewed by the Committee for the Assessment of Foreign Participation in the United States Telecommunications Services Sector

The eight framework questions answered for each selected country
Question	UkraineChecked 18 August 2026	United StatesChecked 18 August 2026
The three ratings	Depends on your industry Work: Medium Enforcement: Active	Depends on your industry Work: 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.	In general the United States lets data go anywhere. There is no national privacy law and no permit is needed to move data abroad. Two things bite hard. Six countries are effectively off limits for large amounts of sensitive data, with prison sentences attached. And anything connected to government work must physically stay on American soil.
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 open headline stops the moment you touch one of six areas: government contracting, police records, federal tax records, defence technical data, telecom licences, and bulk sensitive data flowing to China, Russia, Iran, North Korea, Cuba or Venezuela. Also note that the rule that actually binds you is almost always a state law or an industry regulator's rule, not a national privacy act. There isn't one.
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. American rules reach a foreign company with no office in the country. California's privacy law applies to any for-profit business that 'does business in California' and crosses one of three thresholds, and physical presence is not one of them. The children's rule covers foreign websites aimed at American children. No state and no federal law requires you to appoint a local representative — a real difference from Europe.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	It depends entirely on your industry, so the single national answer is misleading. For ordinary consumer or employee data, yes — send it anywhere, no paperwork. But six sectors have hard walls. Government contracting, police data, federal tax data and defence work require the data to physically stay in the United States. Telecom licences restrict which foreign staff may even look at records. And for anyone, sending large volumes of sensitive data to six named countries is now a crime.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	For ordinary data, nothing. No standard contract, no government approval, no destination approval list. The model is a blocklist and it is now populated: six countries are named. Before you move large volumes of sensitive data, your only real job is to work out whether a country of concern, or a company or person they control, could end up with access — including through a vendor, an investor or an employee.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	Nobody, and everybody. There is no national privacy regulator. Instead the consumer protection regulator, the health department, the securities regulator, the communications regulator, the Justice Department, all fifty state attorneys general and one dedicated state privacy agency each enforce a slice. Almost all of them are visibly working right now. The one exception is the new national data transfer programme: it is staffed and issuing guidance but has published no enforcement action yet.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	There is a strong floor and a weak but growing ceiling. Investment firms must keep some books for six years and most others for three, with the first two years easy to reach. Health providers keep their paperwork for six years. In the other direction, state privacy laws now force you to publish how long you keep each type of data and to stop keeping it longer than you said, and since April 2026 children's data may no longer be kept indefinitely. Where a keep-it rule and a delete-it rule collide, the keep-it rule wins: every state law carves out data you are required by law to retain.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	Count the clocks — there are at least seven, and they disagree. New York financial firms: 72 hours to the state regulator, and only 24 hours to report paying a ransom. Telecom carriers: seven working days to the police agencies and the communications regulator, and you may not warn customers until seven working days after that. Investment and finance firms: 30 days to affected customers. Health organisations: 60 days. Texas and many other states: 30 days to the state attorney general. Listed companies: four working days to disclose a material incident. The overlap, not any single deadline, is what people fail.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 that cost people their weekend. One: the national data transfer programme carries prison — up to twenty years for a deliberate breach. Two: Illinois lets individuals sue over fingerprints and face scans with fixed damages per person, no proof of harm needed, and that is where the largest privacy payouts happen. Three: the children's rule uses under 13, but several state laws use under 18, so a single age gate will not do. Four: government work means American soil, and police data allows only the United States, its territories, tribal lands and Canada. Five: a rule can be printed in the law book and still be unenforceable, because a court has blocked it.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	Four things in the next twelve months. The national critical infrastructure reporting rule should be finalised in late 2026, which will switch on a 72-hour incident clock and a 24-hour ransom-payment clock for a very wide range of businesses. California's rules on automated decision-making bite on 1 January 2027. The open banking rule is being rewritten after a court blocked it. And a federal privacy bill is moving in Congress, but it is only a bill and binds nobody.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 — Criminal Justice Information Services (CJIS) Security Policy Government — Publication 1075, Tax Information Security Guidelines for Federal, State and Local Agencies Defence — Defense Federal Acquisition Regulation Supplement clause 252.239-7010, Cloud Computing Services Telecoms — National security agreement / letter of assurance conditioning a section 214 authorisation, reviewed by the Committee for the Assessment of Foreign Participation in the United States Telecommunications Services Sector