Data privacy in 2026: How GDPR compliance landscape is evolving

07 May 2026 | 7 min read | Business to Government compliance, Data Privacy, SAP Data Management

The conversation around data privacy has shifted dramatically in recent years. What was once a niche concern for legal and IT teams has become a boardroom priority, driven by escalating regulatory requirements, rising consumer expectations, and the rapid adoption of AI technologies.

Data privacy in 2026 is not about a single landmark regulation. Instead, it is characterised by the maturation and enforcement of existing frameworks, the emergence of new regional laws, and a growing recognition that privacy governance must be embedded into every layer of an organisation’s operations. Over 80 per cent of the global population is now covered by some form of data privacy legislation, and that figure continues to climb.

For businesses operating across borders, this creates both a challenge and an opportunity. Those that treat data privacy compliance as a strategic advantage rather than a regulatory burden will be best positioned for long-term success.

One of the most significant shifts in 2026 is the transition from legislative creation to legislative enforcement. While the past decade saw an explosion of new data privacy laws worldwide, regulators are now turning their attention to ensuring that existing rules are properly followed.

The GDPR in the EU remains the global benchmark, influencing regulatory approaches in jurisdictions from South America to Southeast Asia. However, 2026 marks a pivotal year as the European Commission’s Digital Omnibus proposal seeks to reshape certain GDPR obligations, simplify compliance processes, and reduce operational burdens for small and mid-sized organisations, all without altering individuals’ core rights over their data.

At the same time, data protection frameworks are becoming more fragmented. Each country and, in some cases, each state or province is developing its own nuanced requirements. This fragmented landscape demands that organisations adopt flexible, scalable privacy governance models capable of adapting to multiple regulatory environments simultaneously.

GDPR compliance in 2026 is evolving in several important ways. The European Data Protection Board (EDPB) has announced that the right to erasure under Article 17 will be a key enforcement priority this year, signalling that organisations must have robust processes in place for handling deletion requests efficiently and transparently.

The aim is to modernise the GDPR compliance law as it approaches its tenth anniversary. Notable proposed changes include clarifying the definition of “personal data” so that key-coded information may fall outside GDPR obligations for entities lacking the means to identify individuals. The proposal also estimates that consent will no longer be required for approximately 60 per cent of cookies by establishing a list of low-risk purposes.

Cookie banners will need to include a single-click option for users to accept or refuse all cookies, and websites must respect a user’s refusal for at least six months. These changes are designed to combat consent fatigue while maintaining meaningful user control.

In the United Kingdom, the Data (Use and Access) Act 2025 (DUAA) received Royal Assent in June 2025, with its main data protection provisions commencing in February 2026. The DUAA amends but does not replace the UK GDPR. It introduces concepts such as “recognised legitimate interests,” clarifies rules around automated decision-making, and simplifies international data transfer requirements. For SAP system users navigating GDPR, these developments make it essential to review and update existing compliance processes.

The United States continues to lack a comprehensive federal privacy law, but the patchwork of state-level legislation is expanding rapidly. In 2025 alone, comprehensive privacy laws in New Jersey, Tennessee, and Minnesota came into force, joining established frameworks such as the California Consumer Privacy Act (CCPA) and Virginia’s CDPA.

Connecticut’s 2025 amendments to its Data Privacy Act lowered applicability thresholds and expanded the definition of sensitive data, while California imposed its largest CCPA fine to date, reinforcing the importance of compliance with opt-out mechanisms and privacy notices. The New Jersey Data Privacy Act (NJDPA) is another example of how individual states are crafting detailed, enforceable privacy requirements.

Looking ahead, 2026 is a critical preparation year for California’s Automated Decision-Making Technology regulations, which will begin enforcement in January 2027. Colorado’s AI Act, focusing on preventing algorithmic discrimination, also takes effect in 2026. For multinational organisations, understanding and complying with this mosaic of US privacy laws is now a significant operational undertaking.

The Asia-Pacific region is emerging as a major force in data privacy regulation. Vietnam’s comprehensive personal data protection law took effect on 1 January 2026, formalising data subject rights and controller obligations for the first time. South Korea is refining its Personal Information Protection Act and enforcement decrees throughout 2026, with a focus on access rights and security expectations.

Malaysia’s amended Personal Data Protection Act now requires mandatory Data Protection Officer (DPO) appointments and breach notification procedures. Meanwhile, Japan’s APPI continues to evolve, and several Asia-Pacific jurisdictions are incorporating AI governance provisions into their privacy frameworks, emphasising transparency and risk assessment.

These developments mean that organisations with operations or customers in the Asia-Pacific region must invest in understanding local requirements. A one-size-fits-all approach to data privacy compliance is no longer viable.

Artificial intelligence is reshaping the data privacy landscape in profound ways. The EU AI Act, adopted in 2024, is phasing in its high-risk system requirements throughout 2026 and 2027. Organisations deploying AI in sensitive areas such as healthcare, employment, or law enforcement must now conduct regular audits, ensure transparency, and rigorously document their data processing activities.

The EDPB has indicated that AI models trained on personal data cannot always be considered anonymous, a position that could have far-reaching implications for how organisations develop and deploy machine learning systems. This intersection of AI and privacy regulation is creating new compliance challenges that require cross-functional collaboration between privacy, security, and product teams.

According to ISACA’s State of Privacy 2026 report, only 13 per cent of organisations currently use AI in their privacy function, though 38 per cent plan to do so within the next 12 months. This gap represents both a risk and an opportunity. Organisations that leverage AI responsibly for privacy management, while ensuring their AI systems themselves comply with emerging regulations, will gain a competitive edge.

For SAP users, tools such as SAP Information Lifecycle Management (ILM) provide a structured approach to managing data retention and destruction in line with privacy requirements. SAP has also introduced a licence-free solution to support GDPR compliance, making it more accessible for organisations to implement proper data lifecycle controls.

One of the most notable trends in data privacy in 2026 is the global focus on protecting children’s data. The G7 data protection authorities have called for stronger safeguards, and multiple countries are implementing age assurance requirements in their digital regulations.

In the United States, updated COPPA rules have expanded the definition of personal information and introduced stricter retention requirements for children’s data. California’s CCPA amendments, effective January 2026, now classify data of individuals under 16 as sensitive personal information. Australia has implemented a social media ban for under-16-year-olds, requiring platforms to verify user ages.

The UK’s Online Safety Act provisions around age verification came into effect in 2025, and the DUAA further mandates that online services likely to be accessed by children must consider their protection during the design phase. Organisations that collect or process data from younger users must prioritise compliance in this area, as enforcement is expected to be particularly rigorous.

Regulatory enforcement in 2026 is more targeted and sophisticated than ever before. Rather than relying solely on heavy financial penalties, authorities are adopting nuanced strategies that include reprimands, engagement programmes, and mandatory investigation reports.

The UK’s Information Commissioner’s Office (ICO) has signalled that cookie compliance will be a renewed area of enforcement, particularly regarding meaningful opt-out mechanisms. The ICO’s enforcement powers have also been expanded under the DUAA, with potential fines under PECR now aligned with those of the UK GDPR.

In the EU, the focus on the right to erasure and the technical accuracy of consent management means organisations must ensure their processes are not merely compliant on paper but function correctly in practice. A notable example from late 2025 saw a US company fined $1.35 million for providing a non-functional opt-out web form under the CCPA.

This enforcement trend underscores the importance of robust data management practices and the need to regularly audit privacy processes. Legacy systems, in particular, pose a significant risk, as outdated infrastructure often lacks the controls needed for modern privacy compliance. Decommissioning legacy systems and addressing their cybersecurity vulnerabilities should be a priority for any organisation serious about data privacy.

Navigating this complex landscape requires a proactive, structured approach. Here are several strategies organisations should consider:

Rather than treating privacy as an afterthought, integrate data protection principles into the design of new products, services, and systems from the outset. This includes conducting data protection impact assessments and implementing data minimisation practices.

Effective privacy compliance depends on knowing what data you hold, where it resides, and how long you need to retain it. Solutions such as SAP ILM and automated data archiving help organisations define retention policies and ensure timely destruction of data that is no longer needed. Regular data archiving is a foundational practice for maintaining compliance.

Older systems often store vast amounts of personal data without adequate protection controls. Understanding the hidden costs of legacy systems and planning for their decommissioning is essential. Migrating to modern platforms such as S/4HANA also presents an opportunity to improve data governance, and data archiving plays a critical role in that transition.

Privacy can no longer sit solely within the legal or IT department. Effective data privacy compliance in 2026 requires alignment across privacy, AI, security, product development, and executive leadership. Quebec’s Law 25 is just one example of how regional laws demand organisation-wide accountability.

With regulations evolving rapidly, organisations need mechanisms to monitor and respond to new requirements. TJC Group, with over 25 years of expertise in data management, helps businesses navigate this complex environment by implementing compliant data archiving and information lifecycle management solutions tailored to each organisation’s regulatory obligations.

Data privacy in 2026 is defined not by any single regulation but by the convergence of global enforcement, AI governance, expanded regional laws, and heightened expectations around children’s data protection. The landscape is more complex than ever, yet the fundamentals remain clear: organisations must know their data, manage it responsibly, and be prepared to demonstrate compliance at any moment.

The complexity of global data privacy compliance demands specialist knowledge. TJC Group’s expertise in SAP data management, ILM, and GDPR archiving helps organisations turn compliance challenges into strategic advantages.

Contact TJC Group to discover how we can support your data privacy journey.