Insights · PDPL

Saudi PDPL changes 2026: what SDAIA's proposed amendments mean for your IT

In October 2026 SDAIA published draft amendments to the Personal Data Protection Law’s Implementing Regulation. They are not final yet, but they point clearly to where the rules are heading. Here’s what is proposed, and the IT work worth starting now.
The short answer

On 6 October 2026 the Saudi Data and Artificial Intelligence Authority (SDAIA) published draft amendments to the PDPL Implementing Regulation for public consultation, which closed on 5 November 2026. The proposals include a requirement to store personal data inside the Kingdom (with transfers still allowed under the law), a lower threshold for reporting personal data breaches, wider triggers for data protection impact assessments, rules on Data Protection Officers and controller registration moved into the regulation, and a 20-business-day deadline to answer SDAIA’s requests. These are proposals, not law, but most of the IT work they imply is worth doing anyway.

Key points
  • The amendments are a draft. The consultation closed on 5 November 2026, and the final text may change.
  • Draft Article 23(2) would require controllers to store personal data inside Saudi Arabia, while still allowing transfers under the law.
  • Breach notification to SDAIA would be triggered by damage to personal data, without the current “potential harm” test, so more incidents may need reporting.
  • DPIAs would be needed for more processing, including emerging technologies and solely automated decisions.
  • Organisations outside the NCA’s scope would need to follow “recognised cybersecurity standards” and best practice.

What has SDAIA proposed, and is it law yet?

SDAIA published draft amendments to the Implementing Regulation of the Personal Data Protection Law on 6 October 2026, and invited comments until 5 November 2026. At the time of writing they have not been finalised, so the current regulation still applies.

The PDPL itself has been fully enforceable since 14 September 2024. If you want the current rules, start with our Saudi PDPL IT checklist.

The proposed changes at a glance

AreaWhat is proposedWhat it means for IT
Data localisationDraft Article 23(2): controllers store personal data inside the Kingdom; transfers abroad still possible under the law and regulationsKnow where every system stores personal data, including backups and support tools, and plan in-Kingdom options
Breach notificationNotification to SDAIA triggered by damage to personal data, without the “potential harm” test; notification contents adjustedBetter detection and triage, and a documented decision for every incident
Security measuresArticle 23(1): measures to prevent leakage, damage or unauthorised access; NCA standards for those in NCA scope, recognised standards and best practice for othersA recognised baseline, such as the NCA Non-CNI controls or ISO 27001, applied and evidenced
Impact assessmentsDPIA triggers widened: minors, large-scale processing or systematic monitoring, emerging technologies, solely automated decisionsIT input on new systems, especially AI and monitoring tools, before go-live
DPOsDPO rules moved into the regulation; appointments documented and DPO details kept current on SDAIA’s platformA named DPO with access to IT reports, incidents and access reviews
RegistrationController registration rules moved into the regulation, including controllers that transfer data outside the KingdomA list of transfers and the systems behind them
Data subject requests30 days, extendable by up to 30 more, with narrower grounds for extensionBeing able to find and export one person’s data quickly
SDAIA requestsRespond within 20 business daysEvidence that can be produced quickly, not rebuilt each time

What would data localisation mean for your IT?

The headline proposal is that controllers would store personal data within Saudi Arabia, while still being able to transfer or disclose it abroad in line with the law. How strictly that will be applied is one of the biggest open questions in the consultation.

Whatever the final wording, the first step is the same: know where your personal data actually lives. That includes Microsoft 365, CRM and HR systems, file sharing, backups, logs and the tools your IT provider uses. Microsoft has announced a Saudi Arabia East cloud region, and more providers now offer in-Kingdom hosting. Our guide to Saudi data residency covers the options.

Would more breaches need reporting?

Today, a controller must notify SDAIA within 72 hours of becoming aware of a personal data breach, through the National Data Governance Platform, and tell affected individuals without undue delay. The draft appears to lower the threshold for which breaches must be notified, by removing the requirement for potential harm to individuals and tying notification to damage to personal data.

If that goes through, more incidents will need a formal decision and possibly a report. That makes 24/7 monitoring, good logs and a tested incident process more important, not less. See our guide to cyber incident reporting in Saudi Arabia.

What should IT do now, before the final text?

  1. Map where personal data is stored and processed, system by system, including backups and suppliers.
  2. List every transfer of personal data outside the Kingdom, and the safeguard you rely on for each.
  3. Check whether in-Kingdom hosting is available for your main systems, and what moving would involve.
  4. Make sure security monitoring and logging would let you investigate and report an incident within 72 hours.
  5. Adopt a recognised security baseline, such as the NCA Non-CNI controls or ISO 27001, and keep the evidence.
  6. Add an IT check to new projects, so impact assessments happen before AI or monitoring tools go live.
  7. Confirm who your DPO is and that they get regular IT reports.
  8. Practise finding and exporting one person’s data across email, files and systems.

How does this connect to the NCA's new controls?

The draft would require organisations within the NCA’s scope to follow NCA standards, and everyone else to follow recognised cybersecurity standards and best practice. For many private companies, the NCA’s new Non-CNI controls are the obvious recognised baseline to use. See our guide to the NCA Non-CNI cybersecurity controls.

How Cre8 IT can help

Cre8 IT is registered with the National Cybersecurity Authority (NCA) as a cybersecurity service provider through the Haseen platform. We’re ISO 27001:2022 certified, and we help Saudi organisations with the IT side of data protection: data mapping, in-Kingdom hosting options, Microsoft 365 security, 24/7 monitoring and incident response. We work alongside your DPO and legal advisers, and we’ll update this guide when SDAIA publishes the final text.

Want to know how ready you are? Book a free review.

Sources and further reading

Last reviewed 10 November 2026. This guide explains the IT side of the rules and is not legal advice. Check the current position with the regulator or your legal adviser.

Written by
CEO, Cre8 IT
Rob Crossley is CEO of Cre8 IT, a Dubai-born managed IT and cyber security company that has supported businesses across the UAE, Saudi Arabia and the UK since 2012. Cre8 IT is certified to ISO 27001:2022 and ISO 9001 and is a certified Microsoft Partner.
FAQ

Frequently asked questions

Has the Saudi PDPL Implementing Regulation changed?

Not yet. SDAIA published draft amendments on 6 October 2026 and the public consultation closed on 5 November 2026. Until the final text is issued, the current Implementing Regulation applies.

Will personal data have to be stored in Saudi Arabia?

The draft proposes that controllers store personal data inside the Kingdom, while still allowing transfers under the law and regulations. How strictly that applies will depend on the final text.

How quickly must a personal data breach be reported to SDAIA?

Under the current rules, within 72 hours of becoming aware of the breach, through the National Data Governance Platform. The draft amendments would lower the threshold for which breaches must be reported.

Do we need to do anything before the amendments are final?

It is sensible to map where personal data is stored, list your transfers abroad, adopt a recognised security baseline and test your incident process. Those steps help under the current rules and the proposed ones.

Related guides

Keep reading

Each guide links to the regulator’s own text and shows when it was last reviewed.
NCA controls

NCA Non-CNI cybersecurity controls (NCNICC-1:2025): what Saudi private companies need to do

NCNICC-1:2025 explained: which Saudi private companies are in scope, Category A vs B, the 26 or 65 controls, and an IT checklist to get ready.
5 min read · Reviewed 10 November 2026
PDPL

Saudi PDPL: an IT checklist for the Personal Data Protection Law

What the Saudi PDPL means for IT: enforced since September 2024, the 72-hour breach notice to SDAIA, the penalties and the technical measures needed.
4 min read · Reviewed 20 September 2026
Data residency

Data residency in Saudi Arabia: where your data can be stored

Can your data leave Saudi Arabia? What the NDMO, the PDPL transfer rules, the NCA, SAMA and the CMA say about where data is stored, plus a practical IT checklist.
7 min read · Reviewed 20 October 2026

Get ready for the new PDPL rules

We’ll map where your personal data lives, check your security baseline and incident readiness, and give you a practical plan.