On 15 January 2026, the ICO released updated guidance on international transfers which aims to reduce complexity and support responsible data transfers. The guidance includes:
– A three-step test to identify whether the transfer is a “restricted transfer” (and therefore the transfer rules apply)
– More developed guidance on roles and responsibilities to reflect the increasingly complex nature of data transfers
– FAQs dealing with issues such as transferring information to colleagues in another country, a glossary and a brief guide to transfers for those less familiar with the rules.
The ICO has indicated this update is part of an ongoing project in relation to international transfers, so expect further updates along the line.
You can find the updated guidance here.
