UK Adequacy Decision Monitoring Template

The EU granted the UK an adequacy decision in June 2021, allowing free flow of personal data from the EU to the UK without additional safeguards. This template helps EU-facing UK businesses monitor the adequacy decision and prepare contingency plans.

Quick Answer

The UK holds an EU adequacy decision granted June 2021, allowing EU-to-UK personal data transfers without SCCs. The decision is subject to ongoing review and can be revoked if the UK diverges significantly from EU data protection standards. UK businesses should monitor adequacy status and maintain contractual fallback mechanisms.

Compliance Checklist (8 items)

Confirm your EU-to-UK data transfers currently rely on the EU adequacy decision — no SCCs required while it stands
Monitor EU Commission reviews — the UK adequacy decision is subject to a four-year sunset review (due 2025) and political developments
Document the adequacy decision as your Article 46 transfer mechanism in your Record of Processing Activities
Prepare a contingency IDTA (UK-to-EU direction) and UK Addendum to EU SCCs (EU-to-UK direction) in case adequacy lapses
Identify which vendors and customers depend on EU-UK free transfers — notify them if adequacy status changes
Subscribe to ICO and EU Commission adequacy news alerts
Review any UK domestic legislation changes (e.g. DPDI Bill / Data Protection Reform) that could affect adequacy
Update vendor contracts to include fallback SCCs that activate automatically if adequacy lapses

Penalty if not compliant

If adequacy lapses and businesses continue to receive EU personal data without adequate safeguards, both EU GDPR fines (up to €20M / 4% turnover) and UK GDPR enforcement apply. Transfer suspension orders are also possible.

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UK adequacy decisionEU adequacy UK GDPREU-UK data transferspost-Brexit data flowsadequacy review