Compare countries

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

Countries

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

BulgariaChecked 18 August 2026

Depends on your industryWork: MediumEnforcement: Active

In one paragraph: Bulgaria is an ordinary European Union country for data. Personal data can leave, as long as you use one of the standard European transfer tools. There is no general rule forcing data to stay in Bulgaria. But online gambling is a hard exception: a control server must physically sit on Bulgarian soil. Bulgaria switched to the euro on 1 January 2026, so all fines are now in euro.
The catch: The relaxed headline stops being true in two places. First, online gambling: an operator licensed in Bulgaria must keep a control local server on Bulgarian territory and stream live game data to the tax authority's server. Second, telecoms: operators must build and pay for interception equipment wired into two Bulgarian state agencies, which cannot be run from abroad. Mapping and aerial survey work also needs clearance from five Bulgarian ministries and agencies before you may even collect the data.
Does this apply to me?: Yes, it can reach you with no office in Bulgaria. The European Union's privacy rulebook applies to anyone who offers goods or services to people in Europe or watches what they do online. Bulgaria's own Personal Data Protection Act sits on top of that and adds extra local duties. There is no revenue or headcount threshold, and no Bulgaria-specific representative: the European-wide requirement to name a representative in Europe is the only one, and it can be in any European country.High confidence
Can the data leave the country?: In general, yes. Bulgaria has no law telling ordinary businesses to keep personal data inside the country. Data moves freely to the rest of Europe, to Switzerland, and to countries Europe has approved; anywhere else needs a standard contract or a similar tool. Two industries break that pattern. Online gambling operators must keep a control server physically in Bulgaria. Telecoms operators must build interception equipment that plugs into Bulgarian state agencies, which cannot sit abroad.High confidence
What do I have to do to send it abroad?: Bulgaria uses Europe's system, not its own. There is no Bulgarian list of banned countries and no Bulgarian permit to apply for. If the destination is inside Europe, the wider European Economic Area or Switzerland, nothing extra is needed. Otherwise you need either an official European approval of that country, or the standard European contract, or approved group-wide rules. One Bulgarian twist: Bulgarian law explicitly puts Switzerland on the same footing as a European Union country.High confidence
Who enforces this — and are they actually working?: The Commission for Personal Data Protection is the main regulator. It is real, staffed and it does issue formal decisions, including ones published across Europe. But it is not a heavy hitter. In a Europe-wide check on deletion rights reported in February 2026, it contacted twenty-three organisations, opened no formal investigations, imposed no penalties, and said it did not plan to. A separate inspectorate polices the courts and prosecutors. Cybersecurity has its own separate regulators.Medium confidence
How long must I keep it, and when must I delete it?: Bulgaria has strong minimum-keeping rules and a few sharp delete-by rules. You must keep payroll records for fifty years, accounting books and financial statements for ten years, and other accounting papers for three years. Telecoms firms keep connection records for six months. Going the other way, job applicants' data must be deleted within six months unless they agree otherwise, and data you were given with no legal basis must be returned or destroyed within one month.High confidence
What happens when something goes wrong?: There are at least three clocks and they do not agree. A personal data breach must reach the privacy regulator within seventy-two hours. Under the cybersecurity law rewritten in February 2026, an early warning must reach the response team within twenty-four hours and a fuller report within seventy-two hours. Trust service providers get twenty-four hours for that fuller report. Financial firms answer to the separate European financial-resilience rules on top.High confidence
What's the trap?: Five things bite people in Bulgaria. You may not photocopy someone's identity card, driving licence or residence permit unless a law lets you. Children need a parent's consent up to age fourteen, not sixteen. Job applicant files must go within six months. Your accounting software must be able to output in Bulgarian. And one clause of the privacy law was struck down by the Constitutional Court in 2019 but is still printed in the statute.High confidence
What's about to change?: Two dated changes are already fixed. From 12 January 2027 every cloud provider must let customers move their data out for free. Bulgaria's new cybersecurity duties started on 13 February 2026 and enforcement is only now warming up. The biggest live risk is not Bulgarian at all: Europe's approval of United States data transfers is being challenged, and Europe's own privacy board asked the Commission on 31 July 2026 to re-examine it.High confidence
Hardest industry wall: Online gaming — Закон за хазарта

The eight framework questions answered for each selected country
Question	United StatesChecked 18 August 2026	BulgariaChecked 18 August 2026
The three ratings	Depends on your industry Work: High Enforcement: Active	Depends on your industry Work: Medium Enforcement: 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.	Bulgaria is an ordinary European Union country for data. Personal data can leave, as long as you use one of the standard European transfer tools. There is no general rule forcing data to stay in Bulgaria. But online gambling is a hard exception: a control server must physically sit on Bulgarian soil. Bulgaria switched to the euro on 1 January 2026, so all fines are now in euro.
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.	The relaxed headline stops being true in two places. First, online gambling: an operator licensed in Bulgaria must keep a control local server on Bulgarian territory and stream live game data to the tax authority's server. Second, telecoms: operators must build and pay for interception equipment wired into two Bulgarian state agencies, which cannot be run from abroad. Mapping and aerial survey work also needs clearance from five Bulgarian ministries and agencies before you may even collect the data.
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	Yes, it can reach you with no office in Bulgaria. The European Union's privacy rulebook applies to anyone who offers goods or services to people in Europe or watches what they do online. Bulgaria's own Personal Data Protection Act sits on top of that and adds extra local duties. There is no revenue or headcount threshold, and no Bulgaria-specific representative: the European-wide requirement to name a representative in Europe is the only one, and it can be in any European country.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	In general, yes. Bulgaria has no law telling ordinary businesses to keep personal data inside the country. Data moves freely to the rest of Europe, to Switzerland, and to countries Europe has approved; anywhere else needs a standard contract or a similar tool. Two industries break that pattern. Online gambling operators must keep a control server physically in Bulgaria. Telecoms operators must build interception equipment that plugs into Bulgarian state agencies, which cannot sit abroad.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	Bulgaria uses Europe's system, not its own. There is no Bulgarian list of banned countries and no Bulgarian permit to apply for. If the destination is inside Europe, the wider European Economic Area or Switzerland, nothing extra is needed. Otherwise you need either an official European approval of that country, or the standard European contract, or approved group-wide rules. One Bulgarian twist: Bulgarian law explicitly puts Switzerland on the same footing as a European Union country.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	The Commission for Personal Data Protection is the main regulator. It is real, staffed and it does issue formal decisions, including ones published across Europe. But it is not a heavy hitter. In a Europe-wide check on deletion rights reported in February 2026, it contacted twenty-three organisations, opened no formal investigations, imposed no penalties, and said it did not plan to. A separate inspectorate polices the courts and prosecutors. Cybersecurity has its own separate regulators.Medium 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	Bulgaria has strong minimum-keeping rules and a few sharp delete-by rules. You must keep payroll records for fifty years, accounting books and financial statements for ten years, and other accounting papers for three years. Telecoms firms keep connection records for six months. Going the other way, job applicants' data must be deleted within six months unless they agree otherwise, and data you were given with no legal basis must be returned or destroyed within one month.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	There are at least three clocks and they do not agree. A personal data breach must reach the privacy regulator within seventy-two hours. Under the cybersecurity law rewritten in February 2026, an early warning must reach the response team within twenty-four hours and a fuller report within seventy-two hours. Trust service providers get twenty-four hours for that fuller report. Financial firms answer to the separate European financial-resilience rules on top.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	Five things bite people in Bulgaria. You may not photocopy someone's identity card, driving licence or residence permit unless a law lets you. Children need a parent's consent up to age fourteen, not sixteen. Job applicant files must go within six months. Your accounting software must be able to output in Bulgarian. And one clause of the privacy law was struck down by the Constitutional Court in 2019 but is still printed in the statute.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	Two dated changes are already fixed. From 12 January 2027 every cloud provider must let customers move their data out for free. Bulgaria's new cybersecurity duties started on 13 February 2026 and enforcement is only now warming up. The biggest live risk is not Bulgarian at all: Europe's approval of United States data transfers is being challenged, and Europe's own privacy board asked the Commission on 31 July 2026 to re-examine it.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	Online gaming — Закон за хазарта