ICO unveils updated guidance
The Information Commissioner’s Office (ICO) has released a significant update to its guidance on international data transfers, aiming to streamline UK GDPR compliance for organisations. Announced on 15 January 2026, the refreshed materials form part of the ICO’s wider programme to modernise and clarify its data protection resources.
The ICO has reorganised its previous guidance into a new suite of focused documents, making it easier for organisations to locate relevant information. The updated guidance now includes dedicated sections covering:
- When a transfer is considered an international transfer
- The UK’s adequacy regulations
- Appropriate safeguards for restricted transfers
- Conducting transfer risk assessments (TRAs)
- Exceptions available under the UK GDPR
- Receiving personal data from the EEA
A new “brief guide” has also been introduced to support those who need a high-level overview before engaging with more detailed material.
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Key takeaways
The expanded guidance introduces updated terminology reflecting the Data (Use and Access) Act 2025, including:
- Revised adequacy standards
- Updated definitions of appropriate safeguards
- A new “data protection test” framework
The ICO also offers a clearer three-step test to help organisations determine whether a restricted transfer is taking place - an area that has historically caused uncertainty.
The updates form part of the ICO’s broader project to enhance its guidance on areas such as:
- Transfer risk assessments (TRAs)
- The International Data Transfer Agreement (IDTA)
- Cloud services and global data flows
The ICO also plans to introduce an interactive tool to assist organisations in identifying restricted transfers, alongside additional case studies addressing increasingly complex global data ecosystems.
Final thoughts
Businesses undertaking international transfers of personal data should familiarise themselves with the structured guidance and new terminology. The updated material offers clearer navigation, more practical examples and a modernised framework that reflects legislative developments in 2025.
If you have any queries regarding the contents of this legal article, please get in touch with Kaitlin Traynor.
The content of this page is a summary of the law in force at the date of publication and is not exhaustive, nor does it contain definitive advice. Specialist legal advice should be sought in relation to any queries that may arise.
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