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Countries

UzbekistanChecked 18 August 2026

Yes, with paperworkWork: HighEnforcement: Waking up

In one paragraph: Uzbekistan used to say that data about its citizens had to sit on machines inside the country. In March 2026 it dropped that blanket rule. Most personal data may now be stored abroad if the destination country is on a new government approved list, or you use an approved contract, or you meet international standards. Three kinds of data still cannot leave at all.
The catch: The relaxed headline stops at three walls. Face and fingerprint data, genetic data, and data about customers of telephone and internet companies must be kept inside Uzbekistan. Banks face a separate rule that bans handing the running of their systems to an outside supplier, which blocks most managed cloud arrangements. Detailed maps are handled under state-secrecy rules.
Does this apply to me?: The law is written to cover the handling of personal data whatever tools are used, and it was aimed at foreign online platforms when the storage rules were first tightened in 2021. It does not set a size or revenue threshold, so a small foreign company is treated the same as a large one. We found no clear wording that forces a foreign company to appoint a representative living in Uzbekistan, and no explicit sentence saying the law follows the data outside the country.Medium confidence
Can the data leave the country?: Mostly yes, but only if you can point to one of three permissions. Face and fingerprint data, genetic data, and data about customers of telephone and internet companies must stay in Uzbekistan. Everything else may be stored and processed abroad if the destination country is on the government's approved list, or you sign an approved standard contract or use approved group rules, or you follow recognised international data standards.Medium confidence
What do I have to do to send it abroad?: The model is an approved list. Before ordinary personal data leaves the country you need one of three things: the destination is on the Cabinet of Ministers' list of countries with adequate protection, or you use the standard contract terms or group rules approved by the data authority, or you meet recognised international data standards. The country list was signed on 29 July 2026 and started on 3 August 2026, so it is brand new. We could not read which countries are on it, and no approved standard contract template appears to have been published yet.Medium confidence
Who enforces this — and are they actually working?: The data regulator is the State Centre for Personalization, which sits under the Cabinet of Ministers. It keeps the national register of personal data databases and can issue orders that companies and individuals must obey. It is a working government body and the registration service has run since 2020, but we found no published fines or decisions, so treat enforcement as waking up rather than active. Cyber incidents are handled by a different body, the State Security Service, and banks answer separately to the Central Bank.Medium confidence
How long must I keep it, and when must I delete it?: The ceiling is clear: personal data must be destroyed once the purpose is achieved, once consent is withdrawn, once the agreed period ends, or when a court orders it. The floor is thinner. Organisations covered by the cybersecurity law must keep backup copies covering at least the last three months. We did not verify the general tax and accounting minimum keeping periods during this run, so plan on the usual company record rules as well.Medium confidence
What happens when something goes wrong?: There are two clocks and they are not the same. The privacy law itself contains no duty to report a data breach to the regulator or to the people affected — we checked the text on 18 August 2026 and found none. The cybersecurity law is where reporting lives: organisations covered by it must tell the State Security Service about cyber incidents. Banks also report to the Central Bank under its security rules. We could not confirm a firm deadline in hours for any of these.Medium confidence
What's the trap?: First, every database of personal data has to be entered in a national register — it is a notification, it is free and it takes five working days, but skipping it is still a breach. Second, breaking the personal data rules can be a crime, not just a fine, so a named person can be prosecuted. Third, the face and fingerprint wall catches ordinary products like fingerprint logins and identity checks, not just spy technology. Fourth, banks are banned from handing the running of their technology and security systems to an outside supplier, which rules out most managed cloud and outsourced security operations. Fifth, the standard contract route for sending data abroad exists on paper but no approved template appears to have been published.Medium confidence
What's about to change?: The big change already happened in March 2026 and the follow-up is still landing. The approved country list started on 3 August 2026 and can be widened or cut by the Cabinet of Ministers at any time. The approved standard contract for sending data abroad is still missing, so watch for it. A new Tashkent International Financial Centre opened its legal regime on 25 July 2026 and its law also touched the privacy law, which may create a separate rulebook inside the centre. A national cybersecurity strategy was signed in March 2026.Medium confidence
Hardest industry wall: All industries — Закон «О персональных данных», статья 27-1, часть 2
Telecoms — Закон «О персональных данных», статья 27-1, часть 2 (данные пользователей услуг операторов телекоммуникаций)
Finance — Кредит бюроларининг ахборот хавфсизлиги ва киберхавфсизлигига доир минимал талаблар тўғрисидаги низом
Mapping and location — Положение о порядке установления ограничительных грифов картографических и геодезических материалов (данных)
Government — О мерах по организации деятельности Центра обработки данных системы «Электронное правительство»

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

The eight framework questions answered for each selected country
Question	UzbekistanChecked 18 August 2026	UkraineChecked 18 August 2026
The three ratings	Yes, with paperwork Work: High Enforcement: Waking up	Depends on your industry Work: Medium Enforcement: Active
In one paragraph	Uzbekistan used to say that data about its citizens had to sit on machines inside the country. In March 2026 it dropped that blanket rule. Most personal data may now be stored abroad if the destination country is on a new government approved list, or you use an approved contract, or you meet international standards. Three kinds of data still cannot leave at all.	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 relaxed headline stops at three walls. Face and fingerprint data, genetic data, and data about customers of telephone and internet companies must be kept inside Uzbekistan. Banks face a separate rule that bans handing the running of their systems to an outside supplier, which blocks most managed cloud arrangements. Detailed maps are handled under state-secrecy rules.	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?	The law is written to cover the handling of personal data whatever tools are used, and it was aimed at foreign online platforms when the storage rules were first tightened in 2021. It does not set a size or revenue threshold, so a small foreign company is treated the same as a large one. We found no clear wording that forces a foreign company to appoint a representative living in Uzbekistan, and no explicit sentence saying the law follows the data outside the country.Medium confidence	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?	Mostly yes, but only if you can point to one of three permissions. Face and fingerprint data, genetic data, and data about customers of telephone and internet companies must stay in Uzbekistan. Everything else may be stored and processed abroad if the destination country is on the government's approved list, or you sign an approved standard contract or use approved group rules, or you follow recognised international data standards.Medium confidence	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?	The model is an approved list. Before ordinary personal data leaves the country you need one of three things: the destination is on the Cabinet of Ministers' list of countries with adequate protection, or you use the standard contract terms or group rules approved by the data authority, or you meet recognised international data standards. The country list was signed on 29 July 2026 and started on 3 August 2026, so it is brand new. We could not read which countries are on it, and no approved standard contract template appears to have been published yet.Medium confidence	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 data regulator is the State Centre for Personalization, which sits under the Cabinet of Ministers. It keeps the national register of personal data databases and can issue orders that companies and individuals must obey. It is a working government body and the registration service has run since 2020, but we found no published fines or decisions, so treat enforcement as waking up rather than active. Cyber incidents are handled by a different body, the State Security Service, and banks answer separately to the Central Bank.Medium confidence	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 ceiling is clear: personal data must be destroyed once the purpose is achieved, once consent is withdrawn, once the agreed period ends, or when a court orders it. The floor is thinner. Organisations covered by the cybersecurity law must keep backup copies covering at least the last three months. We did not verify the general tax and accounting minimum keeping periods during this run, so plan on the usual company record rules as well.Medium confidence	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?	There are two clocks and they are not the same. The privacy law itself contains no duty to report a data breach to the regulator or to the people affected — we checked the text on 18 August 2026 and found none. The cybersecurity law is where reporting lives: organisations covered by it must tell the State Security Service about cyber incidents. Banks also report to the Central Bank under its security rules. We could not confirm a firm deadline in hours for any of these.Medium confidence	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?	First, every database of personal data has to be entered in a national register — it is a notification, it is free and it takes five working days, but skipping it is still a breach. Second, breaking the personal data rules can be a crime, not just a fine, so a named person can be prosecuted. Third, the face and fingerprint wall catches ordinary products like fingerprint logins and identity checks, not just spy technology. Fourth, banks are banned from handing the running of their technology and security systems to an outside supplier, which rules out most managed cloud and outsourced security operations. Fifth, the standard contract route for sending data abroad exists on paper but no approved template appears to have been published.Medium confidence	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 big change already happened in March 2026 and the follow-up is still landing. The approved country list started on 3 August 2026 and can be widened or cut by the Cabinet of Ministers at any time. The approved standard contract for sending data abroad is still missing, so watch for it. A new Tashkent International Financial Centre opened its legal regime on 25 July 2026 and its law also touched the privacy law, which may create a separate rulebook inside the centre. A national cybersecurity strategy was signed in March 2026.Medium confidence	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	All industries — Закон «О персональных данных», статья 27-1, часть 2 Telecoms — Закон «О персональных данных», статья 27-1, часть 2 (данные пользователей услуг операторов телекоммуникаций) Finance — Кредит бюроларининг ахборот хавфсизлиги ва киберхавфсизлигига доир минимал талаблар тўғрисидаги низом Mapping and location — Положение о порядке установления ограничительных грифов картографических и геодезических материалов (данных) Government — О мерах по организации деятельности Центра обработки данных системы «Электронное правительство»	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