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This guide compares the Singapore Personal Data Protection Act (PDPA) with the EU General Data Protection Regulation (GDPR) as they stand in 2026.
While the GDPR was historically the “gold standard,” Singapore’s PDPA has undergone major transformations in the last few years (specifically via the 2024 Amendments) to bring it closer to European levels of accountability, especially regarding mandatory breach notifications and data portability.
PDPA vs. GDPR: The 2026 Comparison Table
| Feature | Singapore PDPA (2026) | EU GDPR (2026) |
| Applicability | Private sector only (Public agencies are exempt). | Both Private and Public sectors. |
| Sensitive Data | Recently expanded to include Biometric Data. | Strict “Special Categories” (Health, Race, Religion, etc.). |
| DPO Requirement | Mandatory for all organizations (must be registered). | Mandatory for specific entities (Public bodies/Large scale). |
| Breach Notification | Mandatory (3 days to PDPC / Immediate to subjects). | Mandatory (72 hours to Authority / Immediate to subjects). |
| Max Financial Fine | 10% of annual turnover (if >S$10M) or S$1M. | 4% of annual turnover or €20M. |
| Right to Erasure | Limited (No universal “Right to be Forgotten”). | Yes (Comprehensive Right to be Forgotten). |
| Data Portability | Yes (Fully enforceable as of 2025). | Yes. |
Key Differences & 2026 Updates
1. Mandatory Data Protection Officers (DPO)
By 2026, Singapore has made it a strict requirement for every organization to appoint at least one DPO and register their contact details with the PDPC via the ACRA portal. While the GDPR only requires a DPO in specific high-risk circumstances, Singapore views the DPO as the cornerstone of its “Accountability” model for every business, regardless of size.
2. Financial Penalties: The “10% Rule”
The era of “soft fines” in Singapore is over. Since the 2022/2024 escalations, the PDPC can now impose a financial penalty of up to 10% of an organization’s annual gross turnover in Singapore. This aligns the financial risk of non-compliance directly with the GDPR’s 4% global turnover cap, making data protection a board-level priority in 2026.
3. Data Breach Notification (DBN)
In the past, Singapore relied on voluntary reporting. In 2026, the Mandatory Data Breach Notification is in full swing:
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To the PDPC: Within 3 calendar days if the breach affects 500+ individuals or causes “significant harm.”
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To Individuals: If the breach is likely to result in significant harm (e.g., identity theft or financial loss).
4. Data Portability: The Final Piece
A major update for 2026 is the full implementation of the Right to Data Portability. Singaporean residents can now request that a business transfer their personal data directly to another provider (e.g., switching from one insurance firm to another) in a machine-readable format. This was a long-standing feature of the GDPR that is now a reality in Singapore.
Where They Still Differ
The “Right to be Forgotten”
The GDPR remains unique in its “Right to Erasure.” Under the PDPA, individuals have the right to withdraw consent, which forces the organization to stop using the data, but it does not technically grant a universal right to have every trace of that data deleted if there are legal or business reasons to retain it.
Fees for Access Requests
Under the GDPR, access requests must be free of charge unless they are excessive. In Singapore, organizations are still permitted to charge a “reasonable fee” to recover the administrative costs of providing an individual with their data.
Conclusion
As of 2026, complying with the Singapore PDPA gets you about 85% of the way to GDPR compliance. The convergence of these two laws means that multinational corporations can now maintain more unified data privacy frameworks across Europe and Asia than ever before.