CIPP/E Study Guide
Ch 12.4 - Adequacy decision procedure

Procedure to designate adequate countries

The Commission designates adequacy by implementing act, guided by the WP29 Adequacy Referential (6 February 2018) on essential equivalence. Each decision must include a periodic review at least every four years and ongoing monitoring; the Commission can repeal, amend or suspend it. Old Directive adequacy decisions remain valid. The UK adequacy decision automatically expires 27 June 2025 unless extended.

The Commission adopts adequacy by an implementing act, guided by the WP29 Adequacy Referential|Adequacy Referential of 6 February 2018, which sets the core principles needed for essential equivalence. The decision must specify its territorial and sectoral application and identify the relevant supervisory authority.

  • A periodic review at least every four years considering all relevant developments
  • Ongoing monitoring of developments in the third country or international organisation
  • Power and duty to repeal, amend or suspend a decision if adequacy is no longer ensured
  • Adequacy decisions made under the old Data Protection Directive|Directive remain in force until amended, replaced or repealed
Recognised adequate jurisdictions
Adopted underJurisdictions
The DirectiveAndorra, Argentina, Canada, Faroe Islands, Guernsey, Isle of Man, Israel, Jersey, New Zealand, Switzerland, Uruguay
Since the GDPRJapan, South Korea, the United Kingdom
UK sunset clause

A peculiarity unique to the UK decision: it automatically expires 27 June 2025 unless formally extended.

Key terms - quick answers

What is “Implementing act”?
The legal instrument by which the Commission formally adopts an adequacy decision.
What is “WP29 Adequacy Referential”?
Article 29 Working Party guidance (6 February 2018) setting the core data protection principles needed for essential equivalence with the EU framework.
What is “Essential equivalence”?
The standard a third-country framework must meet - protection essentially equivalent to, not identical with, the EU regime.