GDPR vs PIPL vs LGPD vs PIPEDA vs Other Global Privacy Laws

In 2026, over 75% of countries have some form of data protection legislation. If your business operates internationally, understanding how these laws intersect with GDPR is essential — because GDPR applies to you even if you also comply with your local law.

GDPR — The Global Standard

The EU General Data Protection Regulation (GDPR) remains the gold standard for data protection. Key features: extraterritorial scope (Article 3(2)), mandatory EU Representative for non-EU entities (Article 27), fines up to EUR 20 million or 4% of global turnover, and expansive data subject rights.

PIPL (China)

China’s Personal Information Protection Law (PIPL), effective 2021, mirrors many GDPR principles but with distinct differences. PIPL requires a local representative for entities processing Chinese personal data (similar to Article 27). However, China also imposes stringent cross-border data transfer restrictions, data localisation requirements, and government access provisions that do not exist in GDPR. For a detailed comparison, see our China GDPR guide.

LGPD (Brazil)

Brazil’s Lei Geral de Proteção de Dados (LGPD) is almost a direct translation of GDPR. It has extraterritorial scope, requires a DPO, and reaches similar enforcement levels. Brazil has not received an EU adequacy decision. Read our guide for Brazilian companies.

PIPEDA (Canada)

Canada’s PIPEDA shares principles with GDPR but has significant gaps: no mandatory breach notification within 72 hours, no mandatory EU Representative equivalent, and no EU adequacy decision for the commercial sector. See our Canadian compliance guide.

CCPA/CPRA (California)

The California Consumer Privacy Act, amended by CPRA, provides rights similar to GDPR but covers California residents only. Enforcement is capped per violation rather than as a percentage of turnover. Compare GDPR vs CCPA/CPRA.

Your Article 27 Obligation Applies Regardless

Whatever laws you comply with at home, if you process EU personal data, you need an EU Representative. See pricing →