Field Map Β· 2026-05-06

Cybersecurity & Data Protection in MENA

Nine jurisdictions. Nine different regulators. 89 documented breaches and enforcement actions. This is the field map nobody publishes in English.

The Gulf and broader MENA region runs on a regulatory landscape that is younger, more fragmented, and more rapidly evolving than the GDPR-aligned European model. Saudi Arabia's PDPL entered full enforcement in September 2024. The UAE operates federal and free-zone regimes in parallel. Qatar has already issued its first PDPL fine. Lebanon has the law on paper but not the institutional muscle.

What follows is every documented breach, enforcement action, and surveillance program ZERO|TOLERANCE has investigated across the region, organized by jurisdiction, with the regulatory framework that applies in each case. Click any incident to read the full analysis.

πŸ‡ΈπŸ‡¦ Saudi Arabia 18 incidents documented

Regulatory Framework

Regulator
SDAIA (Saudi Data and Artificial Intelligence Authority); NCA (National Cybersecurity Authority) on cybersecurity scope
Key Law
Personal Data Protection Law (PDPL) - Royal Decree M/19 (Sept 16, 2021), amended by Royal Decree M/148 (March 27, 2023)
In Force
Effective September 14, 2023; one-year transition; full enforcement September 14, 2024
Breach Notification
72 hours to SDAIA per Article 24 of the Implementing Regulations (no materiality threshold - all breaches affecting personal data must be reported regardless of size)

Administrative fines up to SAR 5,000,000 per violation, doubled for repeat offences. SDAIA published 48 enforcement decisions in PDPL's first year covering: processing without legal basis, unauthorized disclosure, missing technical/organizational safeguards, and unconsented marketing communications. Cross-border transfers require SDAIA-approved Standard Contractual Clauses (SCCs) or other adequacy safeguards; transfers may not conflict with national interests.

Documented Incidents

πŸ‡¦πŸ‡ͺ United Arab Emirates 14 incidents documented

Regulatory Framework

Regulator
UAE Data Office (federal regulator established under Federal Decree-Law 44/2021). Free-zone scopes operate separate regimes: DIFC (DPL 5/2020) and ADGM (DPR 2021).
Key Law
Federal Decree-Law No. 45/2021 on Personal Data Protection
In Force
January 2, 2022. Executive Regulations not yet finalized as of mid-2026.
Breach Notification
Article 9(1) requires controllers to notify the UAE Data Office "immediately" upon awareness of a breach that may harm privacy or data security - exact timeline deferred to forthcoming Executive Regulations

Notification must include nature, form, reasons, approximate number, breach records, DPO details, expected effects, and rectification measures. Cross-border transfers require either: (a) Data Office adequacy decision for the destination, (b) appropriate contract incorporating PDPL requirements, (c) explicit data-subject consent, or (d) public-interest/contract-execution/judicial-cooperation necessity.

Documented Incidents

πŸ‡§πŸ‡­ Bahrain 8 incidents documented

Regulatory Framework

Regulator
Personal Data Protection Authority (PDPA), Kingdom of Bahrain - operates under supervision of Ministry of Justice, Islamic Affairs and Endowments but exercises functions independently
Key Law
Law No. 30 of 2018 with Respect to Personal Data Protection (PDPL)
In Force
August 1, 2019
Breach Notification
72 hours from awareness; affected data subjects must be informed without undue delay where breach poses high risk

Fines up to BHD 20,000 (~$53K USD) for serious violations (e.g., processing without lawful basis, unauthorized cross-border transfers); up to BHD 10,000 (~$26K USD) for failure to notify. Sensitive data includes race, ethnicity, religion, health conditions, and political opinions - explicit consent required absent statutory exception. PDPA mandate: compliance monitoring, complaint investigation, audits, guidance, enforcement.

Documented Incidents

πŸ‡ΆπŸ‡¦ Qatar 8 incidents documented

Regulatory Framework

Regulator
National Data Privacy Office (NDPO) within the National Cyber Security Agency (NCSA). QFC (Qatar Financial Centre) operates a separate data protection regime for QFC-licensed entities.
Key Law
Law No. 13 of 2016 Concerning Personal Data Privacy Protection (PDPPL)
In Force
December 29, 2016
Breach Notification
Articles 13-14 require notification of breaches likely to "cause serious damage." Guidelines specify a 72-hour deadline from breach detection.

Fines up to QAR 1,000,000 (~$275K USD) per violation for failure to report breaches; up to QAR 5,000,000 (~$1.4M USD) for serious special-data or child-protection violations. NDPO has become increasingly active - December 2024 compliance ruling against an ICT-sector company, March 2025 enforcement order against an e-commerce company. QFC issued its first-ever data protection fine ($150,000 penalty) in 2024 - see linked article below.

Documented Incidents

πŸ‡΄πŸ‡² Oman 8 incidents documented

Regulatory Framework

Regulator
Ministry of Transport, Communications and Information Technology (MTCIT) - designated Regulator under the PDPL
Key Law
Royal Decree No. 6/2022 (Personal Data Protection Law)
In Force
Royal Decree issued February 9, 2022; one-year transition; Executive Regulations published 2024; fully enforceable as of February 5, 2026
Breach Notification
72 hours to MTCIT for any breach posing risk to data subject rights; affected individuals notified within same 72-hour window where breach is likely to result in serious harm

Cross-border: data subject's consent generally sufficient for transfer outside Oman, provided no prejudice to national security. Controller responsible for ensuring foreign processor's protection meets PDPL standard. No prior MTCIT approval required for routine transfers.

Documented Incidents

πŸ‡°πŸ‡Ό Kuwait 9 incidents documented

Regulatory Framework

Regulator
CITRA (Communications and Information Technology Regulatory Authority) - telecom-sector only
Key Law
No comprehensive PDPL. CITRA Resolution No. 26 of 2024 (Data Privacy Protection Regulation), replaced Resolution 42/2021. Sector-specific to telecom and IT service providers licensed by CITRA.
In Force
CITRA Resolution 26/2024 effective February 19, 2024
Breach Notification
Pending verification against primary CITRA Resolution 26/2024 text

Scope limited to CITRA-licensed telecom/internet/IT providers. Imposes consent, transparency, security, transfer-notice, and breach-notification duties on Licensees only. Other sectors (healthcare, finance) operate under separate regulatory regimes. Kuwait remains the major Gulf state without a unified general PDPL - sector-specific patchwork.

Documented Incidents

πŸ‡―πŸ‡΄ Jordan 8 incidents documented

Regulatory Framework

Regulator
Personal Data Protection Unit under the Ministry of Digital Economy and Entrepreneurship (MoDEE). National Cyber Security Center (NCSC) coordinates cybersecurity-incident response separately.
Key Law
Personal Data Protection Law No. 24 of 2023
In Force
Published in Official Gazette September 17, 2023; effective March 17, 2024 (six months after publication); applies retrospectively to data collected before entry into force
Breach Notification
24 hours to inform affected data subjects of breaches likely to cause serious harm; 72 hours to the Unit with breach source and affected-subject details

Cross-border transfers prohibited to jurisdictions with lower protection level than PDPL absent: international judicial cooperation, agency cooperation on crime/prosecution, medical data exchange for treatment, public-health emergency, or explicit informed consent. NCSC reported 6,758 cyber incidents in 2024 (175% YoY surge - see linked article). Cybercrime Law 2023 operates in parallel with broader speech-restriction concerns.

Documented Incidents

πŸ‡ͺπŸ‡¬ Egypt 9 incidents documented

Regulatory Framework

Regulator
Personal Data Protection Center (PDPC) under the Ministry of Communications and Information Technology. NTRA for telecom-specific overlay.
Key Law
Law No. 151 of 2020 (Personal Data Protection Law). Executive Regulations issued November 2025 by Minister Decision No. 81 of 2025 - one-year compliance countdown began.
In Force
PDPL published October 14, 2020. Executive Regulations: November 2025.
Breach Notification
72 hours to PDPC under Article 5; affected data subjects to be notified within 3 working days

Egypt requires a formal license/permit from PDPC for most controllers and processors - distinct from EU-style notification regimes. Cross-border transfers require a SEPARATE license/permit (fee = 50% of controller/processor license fee), with PDPC assessing destination adequacy. License application must specify destination, purpose, data types, and security measures. Most onerous registration regime in the region.

Documented Incidents

πŸ‡±πŸ‡§ Lebanon 7 incidents documented

Regulatory Framework

Regulator
No dedicated independent Data Protection Authority. COLIBAC (Lebanese Accreditation Council) oversees electronic authentication services. Practical enforcement structurally weak.
Key Law
Law No. 81/2018 - Electronic Transactions and Personal Data (Articles 80-106 cover personal data protection specifically)
In Force
October 10, 2018
Breach Notification
Law 81/2018 contains no specified breach-notification deadline; absence of independent DPA means no enforced timeline in practice

Law on the books but no institutional enforcement muscle. Ministry of Economy and Trade has consumer-protection overlap; Ministry of Justice handles judicial recourse. Data subjects technically retain rights to access, correct, and object - but absence of independent DPA means no centralized complaint mechanism, no audit regime, and no fine schedule actively administered.

Documented Incidents

How ZERO|TOLERANCE Covers MENA

Every case on this page was investigated through passive external reconnaissance - no intrusion, no exploitation. Sources are corroborated against primary regulator filings, vendor disclosures, and independent threat intelligence wherever possible. Severity ratings are calibrated against the ZERO|TOLERANCE disclosure framework.

For advisory engagements, named-source citations, or research collaboration on MENA cybersecurity: about ZERO|TOLERANCE.