APDP calls for a Monaco-specific approach to adequacy decisions
In Deliberation No. 2026-07 of 20 May 2026, the Autorité de Protection des Données Personnelles (APDP) advised the Monegasque Government against simply transposing the European Union’s adequacy list into Monaco law.
The APDP recommends excluding, at least initially, the following jurisdictions:
- Japan
- South Korea
- Brazil
- United States
- Israel
The authority also identified Canada as requiring particular scrutiny.
According to the APDP, Monaco must independently ascertain the level of protection effectively afforded to data subjects in the Principality and cannot rely automatically on EU adequacy decisions. The opinion highlights the need for Monaco-specific assessments, consideration of bilateral or sector-specific arrangements, and the use of contractual or supplementary safeguards where appropriate.
Practical implications for Monaco businesses
The opinion has important implications for organisations transferring personal data internationally.
Businesses should consider:
- reassessing international data flows;
- updating transfer impact assessments;
- reviewing and adapting contractual transfer clauses (CTTs);
- evaluating the use of binding corporate rules; and
- considering sector-specific or bilateral transfer arrangements where available.
Early alignment with APDP guidance may help organisations implement compliant transfer mechanisms while reducing legal uncertainty and operational disruption.
