Asia-Pacific
APAC Coverage Directory
44 countries and 16 territories and markets across Southern, South-eastern and Eastern Asia and Oceania, with Central Asia listed as a commercial extension. For each, the data protection and cybersecurity rules SecureRoot has verified at an official source, where our services fit, and the questions to settle before an engagement.
How to read this directory
Delivery. SecureRoot works from India and delivers testing of internet-facing applications, APIs and cloud accounts remotely, the way an attacker would reach them. Remote delivery does not cover work that needs physical presence or a position inside your network. SecureRoot has no offices outside India.
Sources. A rule appears here only if we opened its official source (legislation site, regulator or gazette) on the date shown. Items we could not open are counted, not stated. Nothing here is legal advice, and a rule summarised here may have changed since the date it was checked.
Licensing. Some jurisdictions license security-testing providers. The open questions under each market say where that applies. Penetration testing is not offered through this site to organisations in Singapore or Malaysia, both of which license it; ask us before an enquiry for testing in any market where a licensing question is listed.
Names. Countries and markets are listed under the United Nations M49 geographic regions, with neutral names. Listing a territory separately says nothing about its status.
9 countries and markets
Southern Asia
Afghanistan
Country · Pashto, DariNot assessed. No market or regulatory research done, by instruction.
Not researched: see the open questions below before any enquiry.
Open questions before an engagement
- Sanctions and export-control position (UN, US, EU and Indian rules on dealing with entities in Afghanistan) not researched; the firm must resolve it before any engagement
- Security situation and availability of banking channels for payment not researched
- No primary-source regulatory research done
Bangladesh
Country · Bengali (Bangla), English (business)Bangladesh Bank's ICT Security Guideline v4.0 asks regulated financial organisations for internal/external penetration testing at least annually and independent vulnerability scans of critical systems each year, which fits remote VAPT. The 2026 cyber security and data protection Acts add annual CII audits, security-measure duties and independent data audits that support assessment and privacy readiness work.
Where the services fit: Banks and NBFIs; Mobile financial service and payment service providers; Organisations declared critical information infrastructure; Data fiduciaries and processors under the PDP Act 2026; Software exporters and BPO firms serving overseas clients.
Cyber Security Act, 2026 (Act No. 81 of 2026)
National Cyber Security Agency (Director General) and National Cyber Security Council
Repeals and re-enacts the Cyber Security Ordinance 2025. Section 16: the Director General may monitor and inspect critical information infrastructure (CII). Each declared CII must audit its internal and external infrastructure every year, in the manner set by rules, and submit the audit report to the Council. Cyber security experts must carry out the monitoring, inspection and audit work.
Passed 10 April 2026; s.1(2) deems it in force from 21 May 2025. Rules setting the audit method were not checked. A Cyber Security (Amendment) Act, 2026 (Act No. 99 of 2026) exists and was not reviewed.. Primary source, checked 2026-11-12.
Personal Data Protection Act, 2026 (Act No. 63 of 2026)
Authority under the National Data Management Act, 2026 (authority name and status unverified)
Covers processing in Bangladesh, and processing abroad linked to offering goods or services to, or monitoring, people in Bangladesh. Section 17: data fiduciaries (controllers) and processors must take appropriate technical and organisational security measures, including pseudonymisation, encryption, resilience and periodic risk assessment. Section 20: breaches likely to cause significant harm must be notified to the Authority, in the form and time set by regulation. Section 21: data fiduciaries in classes set by regulation must have their processing audited by an independent data auditor empowered by the Authority.
Dated 10 April 2026; deemed in force from 6 November 2025, except section 23 and sections 31-35 (including the Chief Data Officer, administrative fine and compensation provisions). Those start on a date the government notifies after 18 months from issue. Regulations (breach timeline, audit classes) not checked.. Primary source, checked 2026-11-12.
Bangladesh Bank Guideline on ICT Security, Version 4.0 (2023)
Bangladesh Bank
Applies to banks, NBFIs, mobile financial service providers, payment service providers, payment system operators, white-label ATM operators, merchant acquirers and other financial service providers regulated by Bangladesh Bank. Section 6.2: internal vulnerability scans at least half-yearly; vulnerability scans of critical systems and applications once a year by an independent party; internal and external penetration testing at least annually and after any significant infrastructure or application change, using an industry-accepted method (for example NIST SP 800-115).
Version 4.0, 2023 (file name dated June 2023); compliance deadline not confirmed.. Primary source, checked 2026-11-12.
Open questions before an engagement
- Content of the Cyber Security (Amendment) Act 2026 (Act No. 99 of 2026) not reviewed
- Name and status of the data authority under the National Data Management Act 2026 not verified (BD-3)
- A newer Bangladesh Bank cybersecurity framework is reported in the press but not verified; it may add to or replace parts of ICT Guideline v4.0 (BD-5)
- Not verified whether testers based outside Bangladesh are acceptable for CII audits or bank VAPT
- Cross-border transfer conditions under the PDP Act 2026 not reviewed; they may affect remote testing that touches production personal data
Bhutan
Country · Dzongkha, English (business)BICMA's cybersecurity code of practice requires covered telecom and ICT providers to run a penetration test at least every 12 months and to use third-party testers with recognised certifications, which fits remote VAPT. The market is small.
Where the services fit: Telecom and ICT service providers with critical information infrastructure; Banks and financial institutions (regulator expectations not verified).
Cybersecurity Code of Practice for ICT/Telecommunications Service Providers
Bhutan InfoComm and Media Authority (BICMA)
Issued under s.58 of the Information, Communications and Media Act of Bhutan 2018. Applies to telecom service providers and other ICT service providers that have critical information infrastructure. Section 11.6: penetration test of ICT facilities at least once every 12 months and after major system changes; third-party testing firms must hold industry-recognised accreditation and their testers industry-recognised penetration testing certifications.
In force 10 October 2024.. Primary source, checked 2026-11-12.
Open questions before an engagement
- Not verified whether SecureRoot meets BICMA's 'industry-recognised accreditation' expectation for third-party testing firms
- Royal Monetary Authority Financial Sector Cybersecurity Strategy 2026-2028 reported in the press; content and any testing requirements not verified (BT-2)
- Data protection provisions of the ICM Act 2018 not reviewed
India
Country · Hindi, English, other scheduled languagesSecureRoot is based in India, and the site covers Indian requirements in depth: DPDP Act compliance, the DPDP Consent Manager deadline, VAPT for banks, NBFCs and fintechs (RBI and SEBI), who can sign your security report (CERT-In empanelment and others).
Open questions before an engagement
- India claims in this file were not re-verified in this pass; rely on the sources already cited on the site's India pages
Iran
Country · Persian (Farsi)Not assessed. No market or regulatory research done, by instruction.
Not researched: see the open questions below before any enquiry.
Open questions before an engagement
- Sanctions and export-control constraints (UN, US OFAC, EU, UK and Indian rules) not researched; the firm must resolve them before any engagement, including whether providing security services or receiving payment is permitted
- Payment channels likely constrained; not verified
- No primary-source regulatory research done
Maldives
Country · Dhivehi, English (business)Maldives Monetary Authority circulars are reported to ask banks for a board-approved cyber security policy covering continuous vulnerability assessment and penetration testing, plus annual phishing simulations. None of this could be confirmed on the regulator's own site.
Where the services fit: Banks; Payment and fintech providers; Tourism and resort groups handling guest data (market observation, not a legal requirement).
No framework verified at an official source yet.
3 further items are awaiting verification at the official source and are not shown.
Open questions before an engagement
- MMA circulars not verified on the regulator's site (the site is a single-page app and the documents were not reachable)
- Status of the Personal Data Protection Bill after June 2026 not verified on majlis.gov.mv
Nepal
Country · Nepali, English (business)Nepal Rastra Bank's Cyber Resilience Guidelines 2023 expect licensed institutions to run penetration tests regularly and after major system changes, alongside vulnerability assessments and red-team tests, which fits remote VAPT.
Where the services fit: Class A-D banks and financial institutions; Payment system operators and payment service providers (wallets, PSPs); Organisations handling personal information under the Privacy Act.
Cyber Resilience Guidelines 2023
Nepal Rastra Bank (Payment Systems Department)
Applies to A, B, C and D class BFIs, payment system operators and payment service providers licensed by NRB's Payment Systems Department. Paragraphs 155-157: penetration tests should simulate real attacks on systems, networks, applications, people and processes, and should be run regularly and whenever there are major updates or new deployments. The testing section also covers vulnerability assessments, scenario-based tests and red-team tests. The guideline uses 'should' wording.
Issued August 2023 (PDF in NRB's 2023/08 uploads); exact issue and compliance dates not confirmed.. Primary source, checked 2026-11-12.
1 further item is awaiting verification at the official source and is not shown.
Open questions before an engagement
- Privacy Act 2075 text not opened on lawcommission.gov.np (connection reset); obligations unverified
- NRB IT Guidelines 2012 and any later NRB IT directives not reviewed
- Any national cyber security bill or policy from 2023 onwards not reviewed
Pakistan
Country · Urdu, English (official and business)The State Bank of Pakistan and SECP have issued technology-risk and cybersecurity frameworks that are reported to include security testing. Both regulators' sites blocked automated access, so no testing requirement is confirmed here.
Where the services fit: Banks, DFIs and microfinance banks; Payment system operators and EMIs; Insurers and securities market entities; IT and BPO exporters serving overseas clients.
No framework verified at an official source yet.
3 further items are awaiting verification at the official source and are not shown.
Open questions before an engagement
- sbp.org.pk and secp.gov.pk returned 403 / Cloudflare blocks, and na.gov.pk and pakistancode.gov.pk refused connections; every regulator testing expectation is unverified
- SECP cybersecurity guidelines (insurance sector 2020, and any for brokers) unverified (PK-5)
- SBP PSOD Circular No. 04 of 2025 (technology risk for payment institutions) not reviewed
- Personal Data Protection Bill status unverified
- India-Pakistan cross-border service, payment or regulatory constraints not researched; the firm must resolve them before any engagement
Sri Lanka
Country · Sinhala, Tamil, English (link language)CBSL Banking Act Direction No. 16 of 2021 requires licensed banks to commission penetration tests from independent external experts (critical systems at least annually, other qualifying systems every two years) and to run quarterly vulnerability assessments, which fits remote VAPT directly. The PDPA adds controller security and readiness work.
Where the services fit: Licensed commercial and specialised banks; Controllers and processors under the PDPA, including BPO and IT exporters; Finance companies (separate CBSL direction, not reviewed).
Banking Act Directions No. 16 of 2021: Regulatory Framework on Technology Risk Management and Resilience for Licensed Banks
Central Bank of Sri Lanka
Section 5.8.2: vulnerability assessments on production at least quarterly. Section 5.8.3: penetration tests by independent external experts on critical systems, on systems exposed to customer data, and on customer-data repositories (including those at agents and third-party providers). Critical systems are tested at least annually and the others at least every two years. Tests run on live systems, with non-production allowed at first under the transitional arrangements; both black-box and grey-box testing; scope documented.
Dated 9 December 2021; compliance follows the transitional timelines in section 10 of the framework. Amended by Direction No. 05 of 2023, which was not verified and is reported to extend some penetration-testing timelines to 2028.. Primary source, checked 2026-11-12.
Personal Data Protection Act, No. 9 of 2022, as amended by Act No. 22 of 2025
Data Protection Authority of Sri Lanka
General personal data law for controllers and processors. The 2025 amendment lets the Minister bring provisions into force by gazette order. It also gives controllers one month to answer data subject requests, extendable to three months.
Amendment certified 30 October 2025. Reported but unverified: Extraordinary Gazette No. 2498/16 of 22 July 2026 sets 1 January 2027 for ss.2-3 and Parts I and III (including DPO, breach notification, DPIA and cross-border transfer); data subject rights (Part II) are not included.. Primary source, checked 2026-11-12.
Open questions before an engagement
- Gazette No. 2498/16 (1 January 2027 commencement) not opened; the date comes from press reports citing the DPA (LK-3)
- CBSL Direction No. 05 of 2023 amendments not verified (LK-5)
- Not verified whether CBSL accepts foreign testing firms as 'independent external experts'
- Status of Sri Lanka's draft cyber security legislation not reviewed
11 countries and markets
South-eastern Asia
Singapore
Country · English, Malay, Mandarin, TamilMAS TRM Guidelines set expectations for penetration testing, source code review and vulnerability assessment, and the PDPC recommends security testing of ICT systems. Penetration testing for the Singapore market is a licensed activity, so the licence question in unresolved_restrictions has to be settled before anything is offered.
Where the services fit: MAS-regulated banks and capital markets firms; fintech and payment firms; SaaS and technology exporters; organisations handling personal data under the PDPA.
Personal Data Protection Act 2012, Part 6A data breach notification
Personal Data Protection Commission (PDPC)
A breach is notifiable if it causes or is likely to cause significant harm, or is of significant scale (500 or more individuals). The organisation must assess a suspected breach within 30 calendar days and notify the PDPC within 3 calendar days of assessing it as notifiable. Affected individuals are notified at the same time or after (s26D).
Mandatory breach notification in force; PDPC guide revised 15 Mar 2021 (Part 6A commencement date not opened at source). Primary source, checked 2026-11-12.
PDPC Guide to Data Protection Practices for ICT Systems
PDPC
Guidance, not law. It recommends security testing (vulnerability assessment, penetration testing or red teaming) before go-live, promptly after, periodically and after major changes, with High-rated findings fixed first.
Guidance revised 20 Jul 2026. Primary source, checked 2026-11-12.
Cybersecurity Act 2018 (amended 2024)
Cyber Security Agency of Singapore (CSA) / Commissioner of Cybersecurity
Covers Critical Information Infrastructure (CII) owners, incident powers and information sharing, and licenses penetration testing and managed SOC providers. The 2024 amendments widen incident reporting (including supply-chain incidents) and add new regulated categories, including Foundational Digital Infrastructure such as cloud and data centres.
Act 2018; amendment Bill passed May 2024 (commencement date not stated at source). Primary source, checked 2026-11-12.
Cybersecurity service provider licensing (penetration testing)
Cybersecurity Services Regulation Office (CSRO), CSA
Penetration testing service providers need a CSRO licence (valid 5 years). Per the CSRO FAQ, overseas providers serving the Singapore market also need one; providers serving only related companies do not.
Licensing in force (start date not opened at a primary source); Cyber Trust Mark certification condition from 16 Mar 2026 per CSRO FAQ. Primary source, checked 2026-11-12.
MAS Technology Risk Management Guidelines
Monetary Authority of Singapore (MAS)
Guidelines, not a Notice. FIs should have secure-coding, source-code-review and application-security-testing standards, run regular vulnerability assessments, and penetration-test internet-facing systems at least once a year or after major changes. MAS considers how far an FI follows them.
Issued 18 Jan 2021. Primary source, checked 2026-11-12.
MAS Notice FSM-N06 on Cyber Hygiene (replaces Notice 655)
MAS
Binding on all banks in Singapore. Banks must secure admin accounts, apply security patches on a timeline that matches the risk, keep and follow written security standards, filter traffic at the network perimeter, run malware protection, and use MFA on admin accounts of critical systems and on internet access to customer information.
10 May 2024 (Notice 655 cancelled the same day). Primary source, checked 2026-11-12.
Open questions before an engagement
- CSRO FAQ: overseas providers serving the Singapore market need a penetration testing licence. SecureRoot's site shows no CSRO licence, so advertising or delivering penetration testing to Singapore clients is unresolved; needs legal review before any page offers it.
- Cyber Trust Mark certification condition for licensees from 16 Mar 2026 (CSRO FAQ) not reviewed.
- CII owner audit/risk-assessment frequency under the Cybersecurity Act not verified (SSO statute site returned 403).
Malaysia
Country · MalayBNM RMiT requires quarterly vulnerability assessment and annual intelligence-led penetration testing by suitably accredited testers. NCII entities must run yearly risk assessments and two-yearly audits. Penetration testing is a licensed activity under Act 854.
Where the services fit: BNM-regulated banks, insurers, e-money issuers and payment operators; NCII entities and their suppliers; SaaS and technology firms handling personal data.
Personal Data Protection Act 2010 (Act 709) as amended 2024, s12B data breach notification
Personal Data Protection Commissioner (JPDP)
Data controllers notify the Commissioner as soon as practicable and within 72 hours of a breach that causes or may cause significant harm or affects more than 1,000 data subjects, then notify affected data subjects within 7 days of that.
s12B effective 1 Jun 2025 (per JPDP DBN user manual); Guideline v1.0 issued 25 Feb 2025. Primary source, checked 2026-11-12.
Cyber Security Act 2024 (Act 854)
National Cyber Security Agency (NACSA)
NCII entities must do a cyber security risk assessment at least once a year and an audit at least every two years, or more often if the Chief Executive directs.
Act in force 26 Aug 2024 (P.U.(B) 334); Regulations P.U.(A) 219 from 26 Aug 2024. Primary source, checked 2026-11-12.
Cyber Security (Licensing of Cyber Security Service Provider) Regulations 2024
NACSA
Providing, advertising or holding yourself out as providing penetration testing or managed SOC monitoring requires a NACSA licence. The Regulations do not apply where the tested computer or computer system is located outside Malaysia, or to Government entities or services to a related company.
26 Aug 2024 (P.U.(A) 221). Primary source, checked 2026-11-12.
BNM Policy Document on Risk Management in Technology (RMiT)
Bank Negara Malaysia (BNM)
Financial institutions must have VAPT procedures, run quarterly vulnerability assessments on network components supporting critical systems, and run annual intelligence-led penetration tests of networks, critical systems and web/mobile/external apps using suitably accredited testers, plus tests before new systems go live. NCII entities must use NACSA-licensed providers for penetration testing.
Effective 28 Nov 2025; revised document issued 25 Sep 2026. Primary source, checked 2026-11-12.
Open questions before an engagement
- Act 854 licensing: providing or advertising penetration testing needs a NACSA licence unless the system tested is located outside Malaysia. SecureRoot holds no NACSA licence per the site; a Malaysia page that advertises penetration testing may count as 'holding out'. Needs legal review.
- BNM RMiT requires 'suitably accredited' testers; what counts as accredited is not defined in the extract reviewed.
Indonesia
Country · IndonesianThe PDP Law requires controllers to secure the personal data they process and to notify breaches within 3 x 24 hours. OJK rules on bank IT and cyber resilience reportedly include periodic security testing, but that is unverified here.
Where the services fit: banks and fintechs supervised by OJK; e-commerce and digital platforms; SaaS firms processing Indonesian personal data.
Law No. 27 of 2022 on Personal Data Protection (UU PDP)
The agency (lembaga) established under the Law; its operational status not verified
Controllers must protect and secure the personal data they process with technical and operational measures matched to the data's risk (Art. 35). After a personal data protection failure, they must notify the data subjects and the agency in writing within 3 x 24 hours (Art. 46). Parties had 2 years from promulgation to comply (Art. 74).
Promulgated and in force 17 Oct 2022; 2-year transition ended 17 Oct 2024. Constitutional Court ruling of 30 Jul 2025 altered the wording of Art. 53(1)(b). Primary source, checked 2026-11-12.
1 further item is awaiting verification at the official source and is not shown.
Open questions before an engagement
- OJK regulations not verified (site unreachable 2026-11-12).
- Status of the PDP supervisory agency and of the implementing Government Regulation not verified.
- Any local licensing or registration requirement for foreign security testers not researched.
Philippines
Country · Filipino, EnglishThe Data Privacy Act's security section requires a process for identifying vulnerabilities in computer networks and regular monitoring for breaches. BSP IT risk rules reportedly add VAPT for supervised institutions, but that is unverified here.
Where the services fit: BSP-supervised banks and e-money issuers; BPO and outsourcing firms; organisations processing personal data under the Data Privacy Act.
Data Privacy Act of 2012 (Republic Act No. 10173), Section 20
National Privacy Commission (NPC)
Controllers must apply reasonable organisational, physical and technical security measures. These include a process for identifying reasonably foreseeable vulnerabilities in their computer networks and regular monitoring for breaches. Controllers must promptly notify the NPC and affected people of breaches of sensitive or identity-fraud-enabling information that risk serious harm.
Approved 15 Aug 2012. Primary source, checked 2026-11-12.
2 further items are awaiting verification at the official source and are not shown.
Open questions before an engagement
- BSP and NPC circular texts not verified (bsp.gov.ph Access Denied; privacy.gov.ph circular pages 403).
- Any local licensing or registration requirement for foreign security testers not researched.
Thailand
Country · ThaiCII organisations must have their cybersecurity risk assessment examined by an auditor at least once a year. PDPA security and breach duties apply to controllers, but the PDPA primary text was not opened here.
Where the services fit: Critical Information Infrastructure organisations (finance, telecoms, energy, health, transport); banks and payment firms; organisations processing personal data under the PDPA.
Cybersecurity Act B.E. 2562 (2019), CII provisions (ss. 54, 56, 57)
National Cyber Security Agency (NCSA) / ThaiCERT
CII organisations must run a cybersecurity risk assessment, have it examined at least once a year by an information security, internal or independent external auditor, and send a summary to the Office within 30 days. They must also monitor threats and report significant incidents.
Act of 2019 (Royal Gazette date not opened at source). Primary source, checked 2026-11-12.
1 further item is awaiting verification at the official source and is not shown.
Open questions before an engagement
- PDPA primary text not verified (pdpc.or.th bot challenge not bypassed; ratchakitcha 403).
- Bank of Thailand / SEC IT risk rules not researched.
- A 2025 draft amendment to the Cybersecurity Act was reported by secondary sources; status not verified.
- Any local licensing or registration requirement for foreign security testers not researched.
Viet Nam
Country · VietnameseA new Personal Data Protection Law took effect on 1 Jan 2026 and a new Cybersecurity Law is reported in force from 1 Jul 2026. Most specific duties (breach timelines, impact assessments) are unverified here, so the service-fit case is not yet sourced.
Where the services fit: banks and fintechs supervised by the State Bank of Vietnam; digital platforms and e-commerce; foreign firms processing Vietnamese personal data.
Law on Personal Data Protection No. 91/2025/QH15
Ministry of Public Security (specialised agency; not verified at primary source)
Passed 26 Jun 2025 and in force 1 Jan 2026. The Government issued an implementation plan (Decision 2623/QD-TTg, 29 Nov 2025). Specific duties such as breach notification timelines are not verified.
1 Jan 2026. Primary source, checked 2026-11-12.
2 further items are awaiting verification at the official source and are not shown.
Open questions before an engagement
- PDP Law and Cybersecurity Law texts not verified (vbpl.moj.gov.vn DNS failure; chinhphu.vn document not located).
- Cross-border transfer / data localisation duties under the new laws not verified.
- Any local licensing requirement for foreign security testers not researched.
Brunei Darussalam
Country · MalayThe new PDPO requires reasonable security arrangements and breach notification, but the market is small and the PDPO's commencement date is unverified.
Where the services fit: banks and financial institutions; private-sector organisations covered by the PDPO.
Personal Data Protection Order, 2025 (S 1/2025)
Authority for Info-communications Technology Industry (AITI)
Organisations must protect personal data with reasonable security arrangements (s22). They must assess breaches and notify the Authority no later than 3 days after assessing a breach as notifiable (significant harm or significant scale), then notify affected individuals (s28).
Commences on a date appointed by the Minister; appointed date not verified. Primary source, checked 2026-11-12.
Open questions before an engagement
- PDPO commencement date not verified.
- Cybersecurity Order 2020 not researched.
Cambodia
Country · KhmerGeneral remote VAPT and secure code review. No local framework was verified.
Where the services fit: banks and microfinance institutions; telecoms and digital services.
No framework verified at an official source yet.
Open questions before an engagement
- Status of any personal data protection or cybersecurity law not researched.
Lao PDR
Country · LaoGeneral remote VAPT. No local framework was verified.
Where the services fit: banks; telecoms.
No framework verified at an official source yet.
Open questions before an engagement
- Electronic data protection and cybersecurity laws not researched.
Myanmar
Country · BurmeseNot assessed. Sanctions and export-control position unresolved.
Not researched: see the open questions below before any enquiry.
Open questions before an engagement
- Sanctions and export-control restrictions (e.g. measures by the US, EU, UK and others against Myanmar persons and entities) not researched; unresolved. Needs legal review before any marketing or engagement.
- Local cybersecurity and data laws not researched.
Timor-Leste
Country · Tetum, PortugueseGeneral remote VAPT. No local framework was verified.
Where the services fit: banks; government-linked entities.
No framework verified at an official source yet.
Open questions before an engagement
- Data protection and cybersecurity laws not researched.
8 countries and markets
Eastern Asia
Japan
Country · JapaneseThe FSA cybersecurity guideline expects regular vulnerability assessments and penetration tests (including web, platform and mobile app assessments) and recommends threat-led penetration testing, which maps to manual VAPT, mobile and API testing. APPI's security-control duty is general and does not itself name testing.
Where the services fit: Banks, insurers, securities firms and other FSA-supervised financial institutions; Payment, e-money and crypto-asset exchange service providers; SaaS and API businesses handling personal data; Firms with outsourced development that need code review.
Act on the Protection of Personal Information (APPI), as amended
Personal Information Protection Commission (PPC)
Businesses must take necessary and appropriate measures to keep personal data secure (Art. 23); report qualifying leaks, loss or damage to the PPC and notify affected individuals (Art. 26); and generally obtain consent or rely on an equivalent-protection route before providing personal data to a third party in another country (Art. 28). The law does not name penetration testing.
Official consolidated English translation is stated as of 1 April 2023, with all amended Acts in full force. Only the Japanese text has legal effect. Any later amendment review was not checked.. Primary source, checked 2026-11-12.
Guidelines on Cybersecurity for the Financial Sector
Financial Services Agency (FSA)
Applies to financial institutions under the FSA's comprehensive supervisory guidelines. As a 'fundamental' measure, they should regularly conduct vulnerability assessments and penetration tests based on risk, covering platform and web application assessments for public websites and APIs and assessments of mobile apps, and report significant findings to senior management (s.2.2.4(1)). As a 'recommended' measure, they should regularly conduct threat-led penetration testing (TLPT) using vendors with the necessary experience and skills (s.2.2.4(b)). There is also a third-party risk management section (s.2.6).
Dated 4 October 2024 (English provisional translation). The FSA policy page reportedly lists a 20 October 2025 publication, which may be a revised edition (unverified).. Primary source, checked 2026-11-12.
Open questions before an engagement
- Japanese-language deliverables and contracting expectations of Japanese buyers not researched.
- Whether the FSA guideline was revised in October 2025 (FSA page lists a 20 Oct 2025 publication) is unverified.
- APPI Art. 28 cross-border rules apply if client personal data is provided to SecureRoot in India; how this applies to testing engagements is not assessed.
Republic of Korea
Country · KoreanReadiness and gap work against PIPA safeguards and the ISMS / personal information certification schemes fit SecureRoot's regulatory-readiness and VAPT services. Certification itself is granted under the Korean schemes, not by SecureRoot.
Where the services fit: Information and communications service providers above the ISMS thresholds; Large personal information controllers (mandatory certification from July 2027); Fintech and e-commerce platforms; Korean firms with Indian development centres.
Personal Information Protection Act (PIPA), Act No. 21445
Personal Information Protection Commission (PIPC)
Controllers must take technical, managerial and physical safeguards, including an internal management plan and access records (Art. 29). They must notify data subjects and report qualifying leaks to the PIPC or a designated institution without delay; details are set by Presidential Decree (Art. 34). Cross-border transfers need one of the listed bases, such as separate consent, contract necessity with disclosure, recognised certification, or an adequacy-type recognition (Art. 28-8). The PIPC may certify compliance for three years, and controllers meeting revenue and scale criteria must obtain certification (Art. 32-2).
Amendment promulgated 10 March 2026; enters into force six months after promulgation (Addenda Art. 1). The mandatory-certification proviso of Art. 32-2(1) applies from 1 July 2027. English translation has no legal effect.. Primary source, checked 2026-11-12.
Information Security Management System (ISMS) certification under the Network Act
Ministry of Science and ICT (scheme operated with KISA, unverified)
Telecommunications business operators, integrated information and communication facility operators, and providers above Presidential Decree thresholds (for example sales, ICT revenue or average daily users) must obtain ISMS certification, valid for three years (Network Act Art. 47).
Version checked: Act No. 21066, 1 October 2025.. Primary source, checked 2026-11-12.
1 further item is awaiting verification at the official source and is not shown.
Open questions before an engagement
- ISMS-P scheme details (control items, technical testing in audits) unverified: isms.kisa.or.kr did not resolve on 2026-11-12.
- Presidential Decree thresholds and timing for PIPA breach notification not checked.
- Exact enforcement date of Act No. 21445 (six months after 10 Mar 2026; a law.go.kr listing shows 11 Sep 2026) not confirmed from the Korean original.
- PIPA Art. 28-8 cross-border rules apply if client personal data is transferred to SecureRoot in India; not assessed.
Mongolia
Country · MongolianPossible fit for VAPT and readiness work, but the 2021 laws' obligations could not be read from the official text, so no specific testing requirement is stated.
Where the services fit: Banks and fintechs; Mining and telecom operators; Organisations designated as critical information infrastructure.
Law on Cyber Security (adopted 17 December 2021)
unverified
A 2026 study commissioned by the State Great Khural (Parliament) Secretariat describes the law as in force and as covering duties of critical information infrastructure organisations and legal entities, incident response, audit and risk assessment. The law's own text was not opened, so the specific obligations are not stated.
Adopted 17 December 2021 (per parliamentary study); entry-into-force date unverified. A new 'Cyber Resilience Law' is under study/draft in 2026 (status unverified).. Primary source, checked 2026-11-12.
1 further item is awaiting verification at the official source and is not shown.
Open questions before an engagement
- Official texts of both 2021 laws not opened (legalinfo.mn returned 403).
- Pending Cyber Resilience Law could replace or supplement the 2021 Cyber Security Law; status unverified.
Democratic People's Republic of Korea
Country · KoreanNot a target market. Listed for completeness of the UN M49 Eastern Asia definition only.
Not researched: see the open questions below before any enquiry.
Open questions before an engagement
- Sanctions: UN Security Council sanctions regime and national implementing measures (including India's) are likely to prohibit or restrict services. Not researched; legal review required before any engagement.
China
Country · Chinese (Standard Mandarin)The law expects MLPS compliance, annual testing and assessment by critical information infrastructure operators (by themselves or a cybersecurity service institution), and regular PIPL compliance audits. Whether a firm outside China can perform this work is unresolved (see restrictions).
Where the services fit: Network operators subject to the multi-level protection scheme (MLPS); Critical information infrastructure operators; Important-data processors; Multinationals with China operations.
Cybersecurity Law (as amended 28 October 2025)
Cyberspace Administration of China (CAC) with relevant departments; public security for MLPS
Network operators must meet the multi-level protection scheme (MLPS) duties, including security policies, technical controls, logs kept at least six months, and data classification, backup and encryption (Art. 23). Cybersecurity certification, testing and risk-assessment activities must follow state regulations (Art. 28). Critical information infrastructure (CII) operators must store personal information and important data collected in China in China, with a security assessment for exports (Art. 39). They must also test and assess their network security and risks at least once a year, by themselves or through a cybersecurity service institution, and report the results (Art. 40).
Original law in force 1 June 2017; amending decision in force 1 January 2026 (articles renumbered).. Primary source, checked 2026-11-12.
Personal Information Protection Law (PIPL)
CAC and departments with PI-protection duties
Cross-border provision of personal information needs a CAC security assessment, certification or the standard contract (Art. 38). Handlers must regularly audit their compliance (Art. 54), carry out impact assessments for listed processing including overseas transfers (Art. 55), and take remedial action and notify the authority and individuals of leaks (Art. 57).
1 November 2021. Primary source, checked 2026-11-12.
Data Security Law (DSL)
Relevant competent departments; CAC coordinates
Data processors must have full-lifecycle data security management, building on MLPS for online processing (Art. 27). They must remediate vulnerabilities and report incidents (Art. 29). Important-data processors must run periodic risk assessments and file reports (Art. 30). Data stored in China must not be provided to foreign judicial or law-enforcement bodies without approval (Art. 36).
1 September 2021. Primary source, checked 2026-11-12.
Network Data Security Management Regulations (State Council Order No. 790)
CAC and relevant departments
Important-data processors must name a responsible person and unit that runs regular risk monitoring, risk assessments and drills (Art. 30), and must assess risk before providing or entrusting important data (Art. 31).
1 January 2025. Primary source, checked 2026-11-12.
Provisions on Promoting and Regulating Cross-Border Data Flows (CAC Order No. 16)
CAC
Sets thresholds. A CAC security assessment is needed for CII operators exporting personal information or important data, and for other processors exporting important data or personal information on 1 million+ people (or sensitive personal information on 10,000+) in a year (Art. 7). Lower volumes need the standard contract or certification (Art. 8). Listed exemptions apply.
22 March 2024 (on publication). Primary source, checked 2026-11-12.
Provisions on the Management of Network Product Security Vulnerabilities
MIIT, CAC, Ministry of Public Security
Undisclosed network-product vulnerability information must not be provided to overseas organisations or individuals other than the product provider (Art. 9(7)). Vulnerability collection platforms must file with MIIT (Art. 10).
1 September 2021. Primary source, checked 2026-11-12.
Open questions before an engagement
- Cross-border data: sending personal information, important data or logs from China to SecureRoot in India may trigger PIPL Art. 38 and the CAC Order 16 assessment, standard-contract or certification routes, and CSL Art. 39 localisation for CII operators. Not assessed per engagement.
- Overseas testers and vulnerability data: Vulnerability Management Provisions Art. 9(7) bar providing undisclosed product vulnerability information to overseas organisations other than the product provider. Whether this restricts an India-based firm receiving findings during a client test is unverified (legal interpretation needed).
- Constraint on foreign firms performing security testing: CSL Art. 28 requires testing and risk-assessment activities to follow state regulations. Whether MLPS grading evaluations or CII testing must use domestically recognised evaluation institutions is unverified; the MLPS implementing rules were not opened.
- DSL Art. 36 bars providing China-stored data to foreign judicial or law-enforcement bodies without approval. This is relevant to evidence handling; not assessed.
- Remote active testing of networks in China from abroad: legality and authorisation requirements unverified.
Hong Kong SAR
Territory or market · Chinese (Cantonese), EnglishThe HKMA sectoral Code of Practice under Cap. 653 expects the risk assessment to include a vulnerability assessment (scanning, source code review, configuration review) and a penetration test by suitably qualified people. This maps directly to manual VAPT, secure code review and configuration review. iCAST under C-RAF is a separate, qualification-gated simulation test.
Where the services fit: Authorized institutions (banks) supervised by the HKMA; Stored value facility licensees; Designated critical infrastructure operators under Cap. 653; Fintechs and SaaS vendors to Hong Kong banks.
Protection of Critical Infrastructures (Computer Systems) Ordinance (Cap. 653)
Commissioner of Critical Infrastructure (Computer-system Security); designated authorities including the HKMA for designated banks
Designated operators must keep an office in Hong Kong, set up a computer-system security management unit, notify material changes, submit and implement a security management plan, conduct computer-system security risk assessments, and arrange security audits. Ordinance sections are cited in the HKMA Code. In the HKMA's sectoral Code, the risk assessment should include a vulnerability assessment and a penetration test by suitably qualified people (Code s.6.3.4 to 6.3.6). The audit is run by an appointed assessor (Code s.6.4). The Code is not subsidiary legislation.
Ordinance gazetted 28 March 2025; in operation 1 January 2026 (Secretary for Security notice). HKMA sectoral Code G4/58C dated 2 June 2026.. Primary source, checked 2026-11-12.
Cybersecurity Fortification Initiative 2.0: Cyber Resilience Assessment Framework (C-RAF 2.0) and iCAST
Hong Kong Monetary Authority (HKMA)
Applies to all authorized institutions. C-RAF 2.0 is the HKMA's cyber resilience risk assessment, with updated control principles and blue-team requirements for iCAST (intelligence-led Cyber Attack Simulation Testing). The HKMA lists accepted qualifications for C-RAF assessors and iCAST roles, such as CREST certifications or listed equivalents (for example OSCP, GPEN, OSWE, GWAPT, HKIB CCASP).
1 January 2021, phased implementation. Primary source, checked 2026-11-12.
1 further item is awaiting verification at the official source and is not shown.
Open questions before an engagement
- Tester qualifications: iCAST roles require CREST or HKMA-listed equivalents, and the Cap. 653 Code requires 'appropriate professional qualifications'. Whether SecureRoot's team holds these is not stated on the site and was not verified.
- Cap. 653 risk-assessment and audit frequencies (s.24(1), s.25(1)) and incident-reporting timelines not confirmed from the Ordinance text (e-Legislation did not render).
- Commissioner's generic Code of Practice (occics.gov.hk) not opened.
- PDPO content unverified (PCPD site blocked automated fetches).
Macao SAR
Territory or market · Chinese (Cantonese), PortuguesePossible VAPT and readiness fit for critical infrastructure operators, but the official texts could not be opened, so no requirement is stated.
Where the services fit: Gaming and integrated resort operators (reported as critical infrastructure, unverified); Telecom operators; Banks.
No framework verified at an official source yet.
2 further items are awaiting verification at the official source and are not shown.
Open questions before an engagement
- Official texts of Lei 13/2019, Administrative Regulation 35/2019 and Lei 8/2005 not opened.
- Cross-border transfer rules under Lei 8/2005 not checked.
Taiwan
Territory or market · Chinese (Mandarin)The amended Cyber Security Management Act and its subordinate regulations (audits, responsibility levels, incident notification) are the main assurance driver. The specific testing duties per responsibility level could not be verified from the official text.
Where the services fit: Government agencies and specific non-government agencies under the Cyber Security Management Act; Semiconductor and electronics supply chain; Financial institutions and fintechs.
Cyber Security Management Act (as amended 2025)
Ministry of Digital Affairs (MODA), Administration for Cyber Security
The amendment was promulgated 24 September 2025. Seven subordinate regulations were scheduled, covering enforcement rules, classification of cyber security responsibility levels, audits of maintenance-plan implementation, incident notification and response, and review of products endangering national cyber security. Specific testing obligations were not verified.
Amendment in effect 1 December 2025; subordinate regulations tentatively 1 January 2026; product-review regulations issued 19 December 2025, applying from 1 December 2025.. Primary source, checked 2026-11-12.
1 further item is awaiting verification at the official source and is not shown.
Open questions before an engagement
- law.moj.gov.tw refused connections on 2026-11-12. CSMA subordinate regulations and PDPA text not read.
- PDPA amendment effective date (set by Executive Yuan) unverified.
- The CSMA amendment restricts products deemed to endanger national cyber security (per MODA). Whether this affects use of overseas service providers is not assessed.
27 countries and markets
Oceania
Australia
Country · EnglishAPRA CPS 234 requires systematic testing of information security controls by functionally independent specialists, and the SOCI CIRMP Rules name ISO/IEC 27001 and the Essential Eight among the frameworks a risk management program can comply with; remote VAPT, secure code review, cloud configuration review and ISO 27001 implementation map to these. SecureRoot is not an IRAP assessor and cannot perform IRAP assessments.
Where the services fit: APRA-regulated entities (banks/ADIs, insurers, superannuation RSE licensees); SOCI critical infrastructure responsible entities and their suppliers; SaaS and fintech firms handling personal information (APP entities above the small-business threshold); Suppliers to Commonwealth agencies.
Privacy Act 1988 (Cth), APP 11 and Notifiable Data Breaches scheme
Office of the Australian Information Commissioner (OAIC)
APP entities must take reasonable steps to protect personal information from misuse, interference, loss and unauthorised access, modification or disclosure; since the 2024 amendments those steps expressly include technical and organisational measures (APP 11.3). A suspected eligible data breach must be assessed within 30 days, and an eligible breach notified as soon as practicable. Small businesses with annual turnover of $3,000,000 or less are generally outside the Act. Maximum civil penalty for a body corporate for serious interference is the greater of $50m, 3x the benefit, or 30% of adjusted turnover.
In force (compilation No. 104, 4 June 2026). NDB scheme provisions added 2017.. Primary source, checked 2026-11-12.
Privacy and Other Legislation Amendment Act 2024
OAIC
Amended the Privacy Act: APP 11 technical and organisational measures, Children's Online Privacy Code, overseas data flows, new civil penalty tiers and infringement notices, a statutory tort for serious invasions of privacy, and automated-decision transparency in privacy policies.
Assent 10 Dec 2024; most of Sch 1 commenced 11 Dec 2024; Sch 2 (serious invasions of privacy) 10 Jun 2025; Sch 1 items 87-89 (Part 15, automated decisions and privacy policies) 10 Dec 2026.. Primary source, checked 2026-11-12.
Cyber Security Act 2024
Department of Home Affairs / National Cyber Security Coordinator (unverified which body administers each Part)
Businesses above a turnover threshold set by rules (and SOCI responsible entities) that make a ransomware payment must report it within 72 hours; mandatory security standards for smart devices; a Cyber Incident Review Board; limited-use protections for incident information shared with the National Cyber Security Coordinator.
Assent 29 Nov 2024; Parts 1, 4, 6, 7 from 30 Nov 2024; Parts 3 (ransomware reporting) and 5 (Review Board) 29 May 2025 per the Register's column 3; Part 2 (smart devices) 29 Nov 2025. Turnover threshold amount in the rules not verified.. Primary source, checked 2026-11-12.
Security of Critical Infrastructure Act 2018 (SOCI)
Department of Home Affairs (Cyber and Infrastructure Security Centre) (administering body not verified from the Act text)
Responsible entities for critical infrastructure assets must report critical cyber incidents within 12 hours and other cyber incidents with a relevant impact within 72 hours (Part 2B); specified asset classes must keep a written critical infrastructure risk management program (Part 2A); for systems of national significance the Secretary may by notice require a vulnerability assessment (s 30CU) and other enhanced obligations (Part 2C).
In force (compilation No. 9, 4 June 2026).. Primary source, checked 2026-11-12.
SOCI CIRMP Rules (LIN 23/006) 2023, s 8 cyber and information security hazards
Department of Home Affairs
Responsible entities for listed asset classes (e.g. electricity, gas, water, data storage/processing, hospitals, food and grocery, freight, liquid fuel, broadcasting, DNS, certain financial market infrastructure) must, within 12 months after the applicable period, comply with one of: AS ISO/IEC 27001:2015; ASD Essential Eight at maturity level one; NIST CSF; US DoE C2M2 at MIL1; AESCSF 2020-21 Security Profile 1; or an equivalent framework.
In force (compilation No. 2, 10 June 2026); framework deadline runs 12 months after the applicable period in s 4(2).. Primary source, checked 2026-11-12.
APRA Prudential Standard CPS 234 Information Security
Australian Prudential Regulation Authority (APRA)
Regulated entities must test the effectiveness of information security controls through a systematic testing program, performed by appropriately skilled and functionally independent specialists, reviewed at least annually; internal audit must review control design and effectiveness including third parties; material incidents must be notified to APRA within 72 hours and unremediated material control weaknesses within 10 business days.
1 July 2019 (third-party-managed assets: earlier of contract renewal or 1 July 2020).. Primary source, checked 2026-11-12.
APRA Prudential Standard CPS 230 Operational Risk Management
APRA
Register of critical operations with tolerance levels, business continuity planning and annual testing, material service provider register, due diligence and contracts, and notification to APRA within 24 hours when a critical operation is disrupted beyond tolerance.
The version on APRA's page commences 1 July 2026, replacing the version made under Determination No. 2 of 2023.. Primary source, checked 2026-11-12.
2 further items are awaiting verification at the official source and are not shown.
Open questions before an engagement
- Essential Eight, IRAP and PSPF Policy 10 claims unverified: cyber.gov.au and protectivesecurity.gov.au timed out; OAIC returned 403.
- Cyber Security Act ransomware turnover threshold (set by rules) not verified.
- Whether suppliers to Commonwealth agencies must be IRAP-assessed or Australian-located (e.g. Hosting Certification Framework) not researched.
- Offshore testing of APRA-regulated entities may need APRA notification as a material offshoring arrangement under CPS 230; the client's obligation, not verified for a testing engagement.
New Zealand
Country · English, Māori, New Zealand Sign LanguageThe Privacy Act 2020 (IPP 5) requires reasonable security safeguards and mandatory notification of serious breaches; remote VAPT, secure code review and cloud configuration review support those safeguards. RBNZ cyber resilience expectations could not be read from the primary source.
Where the services fit: RBNZ-regulated banks, insurers and non-bank deposit takers; SaaS and fintech firms holding personal information; Suppliers to NZ government agencies.
Privacy Act 2020, IPP 5 (storage and security) and notifiable privacy breaches
Office of the Privacy Commissioner (OPC)
Agencies must protect personal information with security safeguards that are reasonable in the circumstances against loss, unauthorised access, use, modification or disclosure, and other misuse; privacy breaches that have caused or are likely to cause serious harm must be notified to the Commissioner and affected people as soon as the agency is practically able. The Commissioner can issue compliance notices; personal information sent overseas must receive comparable protection.
1 December 2020 (replaced the Privacy Act 1993).. Primary source, checked 2026-11-12.
Privacy Amendment Act 2025, IPP 3A (indirect collection)
OPC
An agency that collects personal information from someone other than the individual must notify the individual unless an exception applies (e.g. information already publicly available, or the source agency already told them).
1 May 2026; applies to information collected from that date.. Primary source, checked 2026-11-12.
New Zealand Information Security Manual (NZISM)
Government Communications Security Bureau / National Cyber Security Centre (NCSC), for the Government Chief Information Security Officer
Information security manual for NZ government agencies (applicability to GCISO-mandated agencies under the Protective Security Requirements not verified from the manual itself). Version 3.9 updated authentication (phishing-resistant MFA), incident reporting expectations for GCISO-mandated agencies, printing and wireless (WPA3) controls.
v3.9 announced by NCSC on 9 May 2025.. Primary source, checked 2026-11-12.
1 further item is awaiting verification at the official source and is not shown.
Open questions before an engagement
- legislation.govt.nz and rbnz.govt.nz returned 403; Act text and RBNZ guidance not read directly.
- NZISM applicability statement (s 1.2) not opened.
- FMA expectations for market services licensees not researched.
Fiji
Country · English, iTaukei (Fijian), Fiji HindiNo comprehensive data protection law was found; remote VAPT and secure code review would be voluntary assurance rather than a sourced legal requirement.
Where the services fit: Banks and financial institutions; Telecommunications and online service providers.
Cybercrime Act 2021 (Act No. 3 of 2021)
Not a regulator-led regime (criminal law; enforcement by police/prosecution)
Creates offences against the confidentiality, integrity and availability of computer data and systems, computer- and content-related offences, procedural powers for electronic evidence and international cooperation. It does not impose security-testing duties on organisations.
Assent 12 Feb 2021; commences on a date appointed by the Minister by Gazette notice (gazette date not verified).. Primary source, checked 2026-11-12.
Open questions before an engagement
- Online Safety Act 2018 and any Data Protection Bill status not verified from official sources (laws.gov.fj links returned 404).
- Reserve Bank of Fiji ICT/cyber guidelines not researched.
Papua New Guinea
Country · English, Tok Pisin, Hiri MotuGovernment digital and data obligations sit in the Digital Government Act 2022 and policy rather than a general data protection statute; any fit would be voluntary assurance.
Where the services fit: Government agencies and state-owned enterprises; Banks and telecommunications providers.
Digital Government Act 2022
Department of Information and Communications Technology (DICT)
Listed by DICT as legislation guiding government digital transformation, cybersecurity and data use; operative obligations not read.
Unverified.. Primary source, checked 2026-11-12.
National Data Protection and Governance Policy
DICT
A policy, not legislation; DICT announced completion on 21-22 May 2024, pending ministerial committee and Cabinet endorsement at that time.
Policy; Cabinet endorsement not verified.. Primary source, checked 2026-11-12.
Open questions before an engagement
- Cybercrime Code Act 2016 not verified from an official government source.
Solomon Islands
Country · English, Solomons PijinNo data protection or cyber law found from an official source in this pass.
Where the services fit: Banks and telecommunications providers.
No framework verified at an official source yet.
Open questions before an engagement
- No official legislation source located for data protection or cybercrime.
Vanuatu
Country · Bislama, English, FrenchThe Data Protection and Privacy Act 2024 requires reasonable and appropriate security measures for personal data; remote VAPT and cloud configuration review can support that, though the Act sets no testing requirement.
Where the services fit: Banks and financial institutions; Telecommunications and online service providers; Government agencies.
Data Protection and Privacy Act No. 13 of 2024
Deputy Commissioner of Data Protection and Privacy (appointed under the Digital Safety Authority Act No. 15 of 2024)
General data protection law: processing rules and lawful purposes, special categories, children, consent, data subject rights (including on automated decisions), conditions for transfer outside Vanuatu, and a principle that personal data be processed with reasonable and appropriate security measures. Detailed security and breach-notification obligations are left to regulations.
Assent 05/12/2024; commencement 02/01/2025.. Primary source, checked 2026-11-12.
Open questions before an engagement
- Whether regulations on security of processing and breach notification have been made is not verified.
- Cybercrime Act No. 22 of 2021 only seen on PacLII, not an official site.
Kiribati
Country · English, GilberteseA data protection bill/Act is reported in 2025 but could not be verified from an official source.
Where the services fit: Government agencies; Telecommunications providers.
No framework verified at an official source yet.
1 further item is awaiting verification at the official source and is not shown.
Open questions before an engagement
- Official text and enactment status of the Data Protection Bill/Act 2025 not found.
Marshall Islands
Country · Marshallese, EnglishNo data protection or cyber law found from an official source in this pass.
Where the services fit: Banks and financial institutions.
No framework verified at an official source yet.
Open questions before an engagement
- Not researched beyond a regional search; no official source located.
Micronesia (Federated States of)
Country · EnglishNo data protection or cyber law found from an official source in this pass.
Where the services fit: Government agencies; Telecommunications providers.
No framework verified at an official source yet.
Open questions before an engagement
- Not researched beyond a regional search; no official source located.
Nauru
Country · Nauruan, EnglishNo data protection or cyber law verified from an official source in this pass.
Where the services fit: Government agencies.
No framework verified at an official source yet.
Open questions before an engagement
- Not researched beyond a regional search; no official source located.
Palau
Country · Palauan, EnglishNo data protection or cyber law verified from an official source in this pass.
Where the services fit: Banks and financial institutions; Tourism and hospitality.
No framework verified at an official source yet.
Open questions before an engagement
- Not researched beyond a regional search; no official source located.
Samoa
Country · Samoan, EnglishNo general data protection law verified; reported digital ID legislation not confirmed from an official source.
Where the services fit: Banks and financial institutions; Government agencies (digital ID).
No framework verified at an official source yet.
Open questions before an engagement
- National Digital Identification Act 2024 and Crimes Act 2013 cyber provisions reported by secondary sources only.
Tonga
Country · Tongan, EnglishNo data protection law found; a 2003 computer crimes statute is reported but not verified from an official source.
Where the services fit: Banks and financial institutions; Telecommunications providers.
No framework verified at an official source yet.
Open questions before an engagement
- Computer Crimes Act 2003 seen only on WIPO Lex, not an official Tongan site.
Tuvalu
Country · Tuvaluan, EnglishNo data protection or cyber law found from an official source in this pass.
Where the services fit: Government agencies.
No framework verified at an official source yet.
Open questions before an engagement
- Not researched beyond a regional search; no official source located.
Cook Islands
Territory or market · English, Cook Islands MāoriSelf-governing in free association with New Zealand; no local data protection or cyber law verified in this pass.
Where the services fit: Financial services; Tourism and hospitality.
No framework verified at an official source yet.
Open questions before an engagement
- Local privacy/financial-sector rules not researched.
Niue
Territory or market · Niuean, EnglishSelf-governing in free association with New Zealand; no local data protection or cyber law verified.
Where the services fit: Government agencies.
No framework verified at an official source yet.
Open questions before an engagement
- Not researched beyond scoping.
Tokelau
Territory or market · Tokelauan, EnglishNon-self-governing territory of New Zealand; whether the NZ Privacy Act 2020 applies there was not verified.
No framework verified at an official source yet.
Open questions before an engagement
- Territorial application of NZ law not verified.
New Caledonia
Territory or market · FrenchFrench law applies with overseas-specific provisions; the Loi Informatique et Libertés has an overseas title (arts 125-128) whose content was not read, so GDPR/French-law applicability is unverified.
Where the services fit: Mining and energy; Banks and financial services; Public sector.
No framework verified at an official source yet.
1 further item is awaiting verification at the official source and is not shown.
Open questions before an engagement
- Whether GDPR or a modified Loi 78-17 regime applies not verified.
- French-language delivery not stated on the site.
French Polynesia
Territory or market · French, TahitianAs for New Caledonia: Loi 78-17 overseas provisions exist but were not read.
Where the services fit: Tourism and hospitality; Banks and financial services; Public sector.
No framework verified at an official source yet.
1 further item is awaiting verification at the official source and is not shown.
Open questions before an engagement
- Applicable data protection regime not verified.
- French-language delivery not stated on the site.
Wallis and Futuna
Territory or market · French, Wallisian, FutunanAs for other French Pacific territories: applicable regime unverified; negligible market.
Where the services fit: Public sector.
No framework verified at an official source yet.
1 further item is awaiting verification at the official source and is not shown.
Open questions before an engagement
- Applicable data protection regime not verified.
Guam
Territory or market · English, ChamorroUS territory; US federal sector rules (e.g. HIPAA for healthcare) would be the likely frame, but applicability and any Guam breach-notification law were not verified in this pass.
Where the services fit: Healthcare; Banks and financial services; Defence-sector suppliers.
No framework verified at an official source yet.
Open questions before an engagement
- Local Guam statutes and US federal applicability not verified.
- Defence-sector work may carry US export-control/CMMC constraints; not researched.
Northern Mariana Islands
Territory or market · English, Chamorro, CarolinianUS commonwealth; applicable regime not verified.
Where the services fit: Tourism and hospitality; Healthcare.
No framework verified at an official source yet.
Open questions before an engagement
- Local and US federal applicability not verified.
American Samoa
Territory or market · English, SamoanUS territory; applicable regime not verified.
Where the services fit: Public sector; Healthcare.
No framework verified at an official source yet.
Open questions before an engagement
- Local and US federal applicability not verified.
Norfolk Island
Territory or market · English, Norf'kAustralian external territory; the Privacy Act 1988 extends to all external Territories (s 5A), so Australian privacy content applies.
Where the services fit: Tourism and hospitality; Local government.
Privacy Act 1988 (Cth), s 5A extension to external Territories
OAIC
The Privacy Act, including APP 11 and the NDB scheme, extends to all external Territories.
In force (compilation No. 104, 4 June 2026).. Primary source, checked 2026-11-12.
Open questions before an engagement
- Whether SOCI and the Cyber Security Act extend to this territory not checked.
Christmas Island
Territory or market · EnglishAustralian external territory; Privacy Act 1988 extends to it (s 5A).
Where the services fit: Local government.
Privacy Act 1988 (Cth), s 5A extension to external Territories
OAIC
The Privacy Act extends to all external Territories.
In force (compilation No. 104, 4 June 2026).. Primary source, checked 2026-11-12.
Cocos (Keeling) Islands
Territory or market · English, Cocos MalayAustralian external territory; Privacy Act 1988 extends to it (s 5A).
Privacy Act 1988 (Cth), s 5A extension to external Territories
OAIC
The Privacy Act extends to all external Territories.
In force (compilation No. 104, 4 June 2026).. Primary source, checked 2026-11-12.
Pitcairn
Territory or market · English, PitkernUK overseas territory; no commercial fit identified and no regime researched.
No framework verified at an official source yet.
Open questions before an engagement
- Not researched beyond scoping.
5 countries and markets
Central Asia (commercial extension)
Kazakhstan
Country · Kazakh, RussianARDFM rules require banks to run penetration tests of their digital infrastructure by independent external experts, vulnerability scanning at least every six months, and static code and component analysis for remote-service software, which map to SecureRoot's VAPT and secure code review services. Personal-data localisation and the licensing/accreditation rules for cybersecurity audit and conformity testing limit what a foreign remote provider can deliver, and these limits are unresolved.
Where the services fit: Second-tier banks and organisations performing certain banking operations; Credit bureaus; Fintech and remote (online/mobile) financial service providers; Owners of critically important digital objects (energy, telecoms, healthcare, transport); SaaS and digital platforms processing Kazakh personal data.
Law on Personal Data and their Protection No. 94-V (21 May 2013)
Authorised body in the field of personal data protection (central executive body; ministry not named in the text checked)
Personal data must be stored in a database or digital storage facility located in Kazakhstan (Art. 12(2)). Cross-border transfer is allowed to countries that protect personal data, otherwise only on listed grounds such as the data subject's consent (Art. 16). Owners and operators must prevent and detect unauthorised access (Art. 22) and notify the authorised body of a personal-data security breach from the moment it is detected (Art. 25).
In force since 2013 (six months after publication); Art. 12 last amended by Law No. 326-VIII of 24.06.2026 (effective 60 calendar days after publication). Primary source, checked 2026-11-12.
Law On Cybersecurity No. 418-V (24 November 2015; formerly 'On Informatization', retitled by Law No. 256-VIII of 09.01.2026)
Authorised body in the field of cybersecurity; National Cybersecurity Coordination Centre
Owners of critically important digital objects must run or buy a cybersecurity centre, report incidents and send backups to a national platform (Art. 18). Mandatory cybersecurity-compliance testing of listed objects, including critically important digital objects, is done by accredited testing laboratories (Art. 49). Owners of critically important objects, or of objects processing legally protected secrets, must have a cybersecurity audit at least once a year, done internally or bought from legal entities licensed in the field of cybersecurity, with results sent to the authorised body (Art. 50).
Law in force since 2016; Arts. 18, 49, 50 in the wording of Law No. 256-VIII of 09.01.2026, effective six months after its first official publication (exact date not verified). Primary source, checked 2026-11-12.
ARDFM Board Resolution No. 53 of 3 April 2026: Requirements for information security in the financial sector, including cybersecurity of banks
Agency of the Republic of Kazakhstan for Regulation and Development of Financial Market (ARDFM)
Banks must have penetration testing of their digital infrastructure done by independent external experts at a frequency the bank sets, including load and denial-of-service simulation (para. 89); scan information assets for vulnerabilities at least every six months (para. 124); and run static source-code analysis and component/third-party library analysis for remote-service software, fixing critical vulnerabilities before release (paras. 148-151). Information placed in cloud services must be stored encrypted with the key held by the bank.
Effective ten calendar days after first official publication (registered with the Ministry of Justice 6 April 2026, No. 38336); amended by ARDFM Resolution No. 153 of 30.10.2026. Replaced NBK Resolution No. 48 of 27.03.2018.. Primary source, checked 2026-11-12.
NBK Resolution No. 288 of 06.11.2018 (ICT and information security requirements for credit bureaus)
ARDFM
Credit bureaus must security-test remote service software, at minimum by static source-code analysis and analysis of components and third-party libraries, and fix critical vulnerabilities before commissioning (paras. 81-7 to 81-10).
In force; heading and para. 1 amended by ARDFM Resolution No. 59 of 16.08.2024. Primary source, checked 2026-11-12.
Open questions before an engagement
- Data localisation (Law 94-V Art. 12(2)): personal data must be stored in Kazakhstan. Whether test evidence containing personal data (screenshots, extracted records, logs) may be held by SecureRoot in India is unresolved; an engagement would need evidence handling that keeps personal data in Kazakhstan or a lawful transfer basis (Art. 16).
- Law On Cybersecurity Art. 50(2): cybersecurity audits bought from third parties must come from legal entities licensed in the field of cybersecurity. SecureRoot holds no Kazakh licence; whether a foreign remote VAPT engagement falls under this is unresolved.
- Law On Cybersecurity Art. 49(4): mandatory compliance testing is done by accredited testing laboratories; SecureRoot is not one.
- Astana International Financial Centre (AIFC) has its own data-protection regime; not researched.
- English texts on adilet.zan.kz are marked 'Unofficial translation'; the ARDFM resolution was read in Russian.
Uzbekistan
Country · UzbekCentral Bank rules require banks to scan for vulnerabilities, check systems for vulnerabilities before launch, and use data centres that run penetration tests at least once a year, and they allow banks to use external organisations for security audit or expertise, which fits SecureRoot's VAPT. A Central Bank rule limiting staff remote access to within Uzbekistan and the personal-data storage rules are unresolved for remote delivery.
Where the services fit: Commercial banks; Data-centre operators hosting bank systems; Fintech and remote financial service providers; Operators of critical information infrastructure; Telecom operators and digital platforms processing Uzbek personal data.
Law on Personal Data No. ZRU-547 (2 July 2019)
State Personalization Center under the Cabinet of Ministers (authorised state body)
Since 27 March 2026 (Law ZRU-1125), biometric data, genetic data, and data of users of telecom operators working in Uzbekistan must be stored in Uzbekistan; other personal data may be stored and processed abroad if the country is recognised as giving equal protection, or the operator adopts standard contractual clauses or binding corporate rules meeting requirements approved by the authorised body, or follows international standards on a list approved by that body (Art. 27-1). Cross-border transfer is governed by Art. 15. Personal databases must be registered (Art. 20).
Law in force 01.10.2019; Art. 27-1 in the wording of Law ZRU-1125 of 26.03.2026, in force 27.03.2026. Primary source, checked 2026-11-12.
Law on Cybersecurity No. ZRU-764 (15 April 2022)
State Security Service of the Republic of Uzbekistan (authorised state body for cybersecurity)
Information resources and systems of state bodies and systems classed as critical information infrastructure must undergo mandatory expertise for compliance with cybersecurity requirements, under a procedure set by the State Security Service (Art. 18). The law also provides for attestation (Art. 20) and assessment of the level of cybersecurity (Art. 21), and requires incidents to be reported to the authorised body.
In force 17.07.2022. Primary source, checked 2026-11-12.
Central Bank Regulation on minimum information security and cybersecurity requirements for commercial banks (Board resolution No. 19/1 of 1 August 2025; MoJ reg. No. 3669 of 18.08.2025)
Central Bank of the Republic of Uzbekistan
Banks must regularly scan assets for vulnerabilities using CVE and CVSS and patch (para. 156), check systems for vulnerabilities before launch (para. 164), and use data centres that, among other things, run vulnerability analysis and penetration tests at least once a year (para. 168). Banks may use external organisations for audit or expertise and must govern sharing confidential data with them by contract (paras. 174-175). Staff remote access to bank systems is to be ensured only within Uzbekistan (para. 40).
In force 20.11.2025 (per lex.uz). Primary source, checked 2026-11-12.
Open questions before an engagement
- Data localisation (ZRU-547 Art. 27-1, as amended 27.03.2026): biometric, genetic and telecom-subscriber data must stay in Uzbekistan; other personal data may go abroad only on the listed conditions. Handling of test evidence containing such data outside Uzbekistan is unresolved.
- Central Bank regulation para. 40: banks must ensure staff remote access to information systems only from within Uzbekistan. Whether banks apply this to external testers connecting from India is unresolved and would affect remote testing of bank systems.
- Cybersecurity law Art. 18: mandatory expertise follows a State Security Service procedure; whether a foreign provider may perform it is not verified.
- The English translation of ZRU-547 on lex.uz predates the 2026 amendment; the current Art. 27-1 was read in the Uzbek original. The Central Bank regulation and cybersecurity law were read in Uzbek.
Kyrgyzstan
Country · Kyrgyz, RussianThe Digital Code sets risk-management, incident-notification and cross-border transfer duties that buyers may want assessed; SecureRoot's VAPT and privacy readiness work fits as general assurance, not as a named legal requirement. No in-force National Bank testing rule was verified.
Where the services fit: Commercial banks and payment providers; Digital service providers and SaaS processing Kyrgyz personal data; Holders of personal-data arrays; Operators of critical information infrastructure.
Digital Code of the Kyrgyz Republic No. 178 (31 July 2025)
Sectoral regulator for personal data (the State Agency for Personal Data Protection under the Cabinet of Ministers publishes the Code text)
Record owners must place digital records on media located in Kyrgyzstan only in cases the Code provides (Art. 31(3)); no specific personal-data case was identified in the text checked. Cross-border transfer goes to countries on the regulator's adequacy list, or otherwise on listed grounds such as consent, contract performance or adequate contractual terms (Art. 89). Incidents affecting digital resilience or rights must be notified to the sectoral regulator within 72 hours; processors must tell the record owner within 48 hours (Art. 63). Owners run a risk-management system (Art. 64).
Enacted by Law No. 179 of 31.07.2025, in force six months after official publication of that law; replaced the 2008 Law on personal information (5 February 2026 reported by secondary sources, not verified on the official gazette). Primary source, checked 2026-11-12.
Open questions before an engagement
- Digital Code Art. 31(3) lets the Code require storage in Kyrgyzstan 'in cases provided by this Code'; the specific cases were not identified. Treat localisation as unresolved for test evidence containing personal data.
- Cross-border transfer of personal data (Art. 89) to India would need India on the adequacy list or another listed ground; not checked.
- National Bank of the Kyrgyz Republic information-security requirements: only a 2026 draft reported in the press; official text not verified.
- Official text read from the State Agency for Personal Data Protection's site (reestr.dpa.gov.kg), not from cbd.minjust.gov.kg, which could not be searched without a browser session.
Tajikistan
Country · TajikGeneral VAPT and privacy readiness could serve banks and telecoms, but no local legal requirement could be verified from an official source, so nothing country-specific can be claimed.
Where the services fit: Banks and microfinance organisations; Telecom operators; Organisations processing Tajik personal data.
Not researched: see the open questions below before any enquiry.
1 further item is awaiting verification at the official source and is not shown.
Open questions before an engagement
- All legal claims unverified: official Tajik legislation sites were unreachable on 2026-11-12/13.
- Any data-localisation or cross-border rule unverified; treat as unresolved for evidence handling.
- Cybersecurity law and National Bank of Tajikistan information-security requirements not researched (sources blocked).
Turkmenistan
Country · TurkmenLimited fit: the personal-data law requires storage in Turkmenistan and a cybersecurity law exists but could not be read, so no testing expectation can be stated. Remote delivery feasibility is unknown.
Where the services fit: State-owned banks and financial institutions; Energy and telecom operators; Organisations processing Turkmen personal data.
Law on Information about Personal Life and its Protection No. 519-V (20 March 2017)
Prosecutor General of Turkmenistan supervises compliance (Art. 30); the Cabinet of Ministers may create an authorised body (Art. 28)
Personal data is stored by the operator or a third party in a database located in Turkmenistan (Art. 12(2)). Cross-border transfer applies to data held in a database in Turkmenistan and is allowed only to states that protect personal data, otherwise on listed grounds such as written consent (Art. 17).
In force 1 July 2017 (as-enacted text; later amendments not verified). Primary source, checked 2026-11-13.
1 further item is awaiting verification at the official source and is not shown.
Open questions before an engagement
- Data localisation (Law 519-V Art. 12(2)): personal data stored in a database in Turkmenistan. Holding test evidence with personal data outside Turkmenistan is unresolved.
- The official 'Adalat' database (law.minjust.gov.tm) requires a Turkmen phone login; the law was read from an as-enacted copy on a government ministry site (api.saglykhm.gov.tm), so the consolidated current text is unverified.
- Cybersecurity law and Central Bank of Turkmenistan cyber requirements unverified.