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Transfer Impact Assessment

Belgian Data Protection Authority: EU Standard Contractual Clauses Are Invalid Without a Transfer Impact Assessment

October 30, 2026 By Alice Portnoy and Wim Nauwelaerts

On October 9, 2026, the Belgian Data Protection Authority (APD) issued a decision (available in French here) finding that a data exporter’s failure to conduct a Transfer Impact Assessment (TIA) rendered its EU Standard Contractual Clauses (SCCs) invalid. For companies sending personal data outside the EU, the message is clear: signing SCCs is only the […]

Filed Under: European Privacy & Cybersecurity, Privacy & Cyber Regulatory Enforcement Tagged With: EU Standard Contractual Clauses, International Data Transfers, Transfer Impact Assessment

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