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PDPL (Saudi Arabia)
Personal Data Protection Law (Saudi Arabia)
WhenIn effect since 14 September 2023
Who enforces itSaudi Data and AI Authority (SDAIA)
Who it applies toAnyone processing the personal data of people in Saudi Arabia, including from abroad.
Tell the regulatorNotify SDAIA within 72 hours of becoming aware of a breach that may harm data subjects
DPO requiredDPO required for public entities processing at large scale, and where core activities involve…
RegistrationNational Register of Controllers applies to public entities, controllers whose main activity i…
Transfers abroadTransfers need a specified purpose, minimum data, and adequacy, BCRs, standard clauses, certif…
Request deadlineRespond within 30 days, extendable by a further 30 days in limited circumstances
Maximum fineFines up to SAR 5 million (about USD 1.3m) per violation, doubled for repeat violations
Every requirement we score, with the rule in plain words and the section it comes from. Darker means more demanding. See every law side by side →
Reach and lawful basis
Reach abroad
3
Applies to processing in the Kingdom and to processing outside it of personal data of individuals residing in the Kingdom, by any means.PDPL Art. 2 · secondary source · source ↗
Article number not confirmed against official text (sdaia.gov.sa not reachable); source gives substance only.
Lawful basis
1
Consent plus other bases, including legitimate interests (since 2023 amendment) after a documented assessment; not for sensitive data.PDPL Arts. 5-6 · secondary source · source ↗
Article number not confirmed against official text (sdaia.gov.sa not reachable); source gives substance only.
Consent
3
Consent must be freely given, specific, clear, separate for each purpose and documented; explicit consent for sensitive data, credit data and automated decisions.PDPL Art. 5; Implementing Regulation · secondary source · source ↗
Article number not confirmed against official text (sdaia.gov.sa not reachable); source gives substance only.
Sensitive data
2
Sensitive data needs explicit consent or a listed basis; legitimate interests cannot be used; DPIA and DPO triggers apply.PDPL Art. 6; Implementing Regulation · secondary source · source ↗
Article number not confirmed against official text (sdaia.gov.sa not reachable); source gives substance only.
Children
3
No fixed age in the PDPL; legal guardians act for persons lacking full legal capacity, including minors.Implementing Regulation (guardian provisions) · secondary source · source ↗
Uncertain: Latham notes the age at which a child can consent is unclear. Level assumes full capacity at 18. Article number not confirmed against official text (sdaia.gov.sa not reachable); source gives substance only.
People's rights
Rights
2
Rights to be informed, access and copy, correction, restriction and destruction; no portability right.PDPL Art. 4 · secondary source · source ↗
Counted: access, correction, deletion, restriction. Art. 4 number confirmed by Akin Gump.
Request deadline
2
Respond within 30 days, extendable by a further 30 days in limited circumstances.Implementing Regulation · secondary source · source ↗
Article number not confirmed against official text (sdaia.gov.sa not reachable); source gives substance only.
Marketing
3
Consent required before sending advertising or using personal data for direct marketing; easy opt-out required; no existing-customer exception confirmed.PDPL Arts. 25-26; Implementing Regulation Arts. 28-29 · secondary source · source ↗
Implementing Regulation Arts. 28-29 confirmed by Trowers; PDPL article numbers not confirmed.
Governance
DPO required
1
DPO required for public entities processing at large scale, and where core activities involve systematic monitoring or sensitive data.DPO Rules Art. 5 (First) · source ↗
Third-party host of official DPO Rules text. Oct 2026 draft amendments would broaden triggers.
DPO qualifications
1
Appropriate academic qualifications and experience, risk and breach knowledge, regulatory knowledge, integrity; no mandatory certification.DPO Rules Art. 4(1) · source ↗
DPO contact details filed with SDAIA on the National Data Governance Platform (Art. 7(2)).
Registration
1
National Register of Controllers applies to public entities, controllers whose main activity is processing, sensitive-data processors and some individuals; no fees seen.Implementing Regulation Art. 34 · secondary source · source ↗
Article number per secondary sources; foreign entities cannot currently create platform accounts. Oct 2026 draft would add cross-border transfer trigger.
DPIA
2
Impact assessment required for sensitive data, combining datasets, large-scale children's data, monitoring, new technology, automated decisions and high-harm products.PDPL Art. 22 · secondary source · source ↗
Article number not confirmed against official text (sdaia.gov.sa not reachable); source gives substance only.
Records
2
Keep a written record of processing during processing and five years after it ends; provide to SDAIA on request.PDPL Art. 31 · secondary source · source ↗
Article number not confirmed against official text (sdaia.gov.sa not reachable); source gives substance only.
Retention
2
Destroy data when no longer needed for its purpose or processed unlawfully, subject to legal retention exceptions.PDPL Art. 18 · secondary source · source ↗
Art. 18 confirmed by Trowers secondary summary.
Breaches
Tell the regulator
2
Notify SDAIA within 72 hours of becoming aware of a breach that may harm data subjects.Implementing Regulation Art. 24 · secondary source · source ↗
Article number per Clyde & Co. Oct 2026 draft would drop the harm threshold.
Tell people
2
Notify data subjects without undue delay in clear language where the breach may cause harm or conflicts with their rights.Implementing Regulation Art. 24 · secondary source · source ↗
Article number not confirmed against official text (sdaia.gov.sa not reachable); source gives substance only.
Transfers
Transfers abroad
2
Transfers need a specified purpose, minimum data, and adequacy, BCRs, standard clauses, certification or listed derogations, with a risk assessment.PDPL Art. 29; Transfer Regulation Arts. 5-7 · secondary source · source ↗
No adequacy list published. Akin Gump confirms Art. 29 and Transfer Regulation article numbers.
Localization
1
No general localization in force; sectoral rules (SAMA, telecom, government cloud) require local storage.PDPL Art. 29; sectoral rules · secondary source · source ↗
Oct 2026 draft Implementing Regulation Art. 23 would require storage within the Kingdom (consultation to 5 Nov 2026).
Enforcement
Maximum fine
2
Fines up to SAR 5 million (about USD 1.3m) per violation, doubled for repeat violations.PDPL Art. 36 · secondary source · source ↗
Article number not confirmed against official text (sdaia.gov.sa not reachable); source gives substance only.
Criminal liability
2
Unlawful disclosure of sensitive data with intent to harm or for gain: up to 2 years' imprisonment and/or SAR 3 million.PDPL Art. 35 · secondary source · source ↗
Article number not confirmed against official text (sdaia.gov.sa not reachable); source gives substance only.
Private action
2
Anyone harmed may seek proportionate compensation for material or moral damage before the competent court.PDPL Art. 40 · secondary source · source ↗
Article number not confirmed against official text (sdaia.gov.sa not reachable); source gives substance only.
Scores are our reading on the published rubric, checked 18 October 2026. Not legal advice.
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