Artifact GuideEU

EU GDPR deadlines and compliance calendar

Track the GDPR dates and response clocks that are actually supported by official sources: applicability, rights requests, breach notification, DPIA review, prior consultation, transfer assessments, and retention checks.

Use this calendar as a source-linked operations reference, not as a substitute for national authority procedures or sector-specific timelines that are not grounded in the cited sources.

Author
Sorena AI
Published
May 9, 2026
Updated
May 26, 2026
Sections
6

Structured answer sets in this page tree.

Primary sources
6

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated May 26, 2026
Overview

This GDPR calendar separates fixed dates, event-driven clocks, and recurring review triggers. It includes only deadlines and timing rules grounded in the cited official sources, so teams do not add unsupported national timelines or informal service levels to the public compliance record.

Section 1

Fixed GDPR dates to anchor the calendar

The GDPR was adopted in 2016 and applies from 25 May 2018. Use 25 May 2018 as the baseline applicability date for EU GDPR calendar records and avoid treating adoption, publication, or corrigendum dates as separate operational compliance deadlines unless a specific source-linked task depends on them.

Directive 95/46/EC was repealed with effect from the same 25 May 2018 date. For legacy privacy program records, keep that as a migration context date rather than a recurring deadline.

  • Calendar entry: GDPR applies from 25 May 2018.
  • Legacy entry: Directive 95/46/EC repeal took effect on 25 May 2018.
  • Do not add annual GDPR anniversary tasks unless they are tied to a real review obligation, such as accountability updates, retention checks, DPIA review, or transfer monitoring.
Section 2

Event-driven response clocks

The two clocks most likely to need operational routing are the data subject request clock and the personal data breach clock. Both should start from a documented trigger, not from an internal weekly privacy meeting.

For rights requests under Articles 15 to 22, the controller must respond without undue delay and in any event within one month of receipt. A two-month extension can be used where necessary because of complexity and number of requests, but the data subject must be told about the extension and reasons within one month of receipt.

For personal data breaches, the controller must notify the competent supervisory authority without undue delay and, where feasible, not later than 72 hours after becoming aware, unless the breach is unlikely to result in a risk to individuals' rights and freedoms. If the notification is late, the notification must include reasons for the delay.

  • DSAR clock: receipt of a GDPR rights request starts the one-month response period.
  • DSAR extension control: record complexity or request volume, notify the data subject within one month, and set the extended due date no more than two further months out.
  • Breach clock: awareness of a personal data breach starts the Article 33 authority-notification assessment and 72-hour target.
  • Breach evidence: record awareness time, risk assessment, notification decision, Article 33 content, data-subject communication decision, and reasons for any delayed authority notification.
  • Processor handoff: processors should route suspected breaches to the controller without undue delay so the controller can run the Article 33 assessment.
Section 3

DPIA and prior consultation timing

Schedule the DPIA before processing starts when the planned type of processing is likely to result in a high risk to individuals. The calendar trigger should be a project, product, supplier, architecture, data-category, or scope change that may create high-risk processing, not a fixed annual date.

If a DPIA shows that processing would still result in high risk without mitigation, consult the supervisory authority before processing. The GDPR gives the authority up to eight weeks from receipt of the consultation request to provide written advice, extendable by six weeks for complex processing, and the period can be suspended while requested information is outstanding.

After implementation, review the DPIA where necessary at least when the risk represented by processing operations changes. Treat major design changes, new data categories, expanded monitoring, changed sharing, or changed safeguards as calendar reopen triggers.

  • DPIA trigger: likely high-risk processing, assessed before processing begins.
  • Prior consultation trigger: residual high risk shown by the DPIA before processing proceeds.
  • Authority timing: up to eight weeks for written advice, with a possible six-week extension for complexity.
  • DPIA review trigger: change in risk represented by the processing operation.
  • Evidence: DPIA scope, necessity and proportionality assessment, risks, mitigations, DPO advice if requested, residual-risk decision, and review trigger.
Section 4

Transfer and SCC review triggers

Do not put a generic annual SCC deadline in the GDPR calendar unless the organization has adopted that cadence internally. The grounded public rule is event-driven: before concluding SCC-based transfers, assess the specific transfer, destination-country laws and practices, and safeguards; then monitor developments that could affect the assessment.

The European Commission Q&A explains that the SCCs require a transfer impact assessment before concluding the SCCs and that the exporter must suspend the transfer if appropriate safeguards cannot be ensured. The EDPB supplementary-measures roadmap adds an ongoing re-evaluation obligation at appropriate intervals and continuous vigilance for developments affecting protection.

Calendar transfer reviews should therefore be tied to new transfer tools, new data importers, changed destinations, changed processing chains, government-access developments, importer notices that it cannot comply, adequacy decision changes, or material changes to supplementary safeguards.

  • Pre-transfer check: map the transfer, select the Article 45 or Article 46 basis, and document whether SCCs or adequacy apply.
  • SCC check: before concluding SCCs, document transfer circumstances, destination laws and practices, and additional safeguards.
  • Ongoing check: monitor destination-country, importer, legal, and safeguard changes that may affect the initial assessment.
  • Escalation: suspend, end, or avoid the transfer where no appropriate safeguards can be ensured.
  • Source limit: this page does not assert a universal fixed SCC annual review date.
Section 5

Retention and accountability review operations

The GDPR does not give one universal retention period for all personal data. Calendar retention work should therefore be attached to purposes, legal bases, data categories, systems, contracts, statutory retention needs, and deletion or anonymisation controls.

Use the storage limitation principle as the calendar anchor: personal data should not be kept in identifiable form for longer than necessary for the processing purposes, subject to the GDPR's longer-storage conditions for archiving in the public interest, research, or statistical purposes with safeguards.

Article 24 also requires controllers to implement measures to ensure and demonstrate GDPR compliance and to review and update those measures where necessary. That supports recurring operational reviews, but it does not create a single fixed EU-wide date for every organization.

  • Retention register row: purpose, data category, system, legal basis, retention criterion or period, deletion action, owner, and evidence location.
  • Review trigger: new purpose, new lawful basis, contract change, product retirement, litigation hold, incident finding, DPIA change, or data subject request trend.
  • Deletion evidence: system logs, purge report, anonymisation record, exception approval, or legal-hold reference.
  • Source limit: do not invent sector retention periods or national archival rules unless a cited source in the relevant jurisdiction supports them.
Section 6

Source limits for this calendar

This page intentionally excludes unsupported national authority timelines, informal SLA targets, and sector procedures. Add those only in a separate jurisdiction-specific artifact when the grounding folder contains a source for the exact timeline.

Use this artifact as a public-facing GDPR operations calendar for source-linked clocks. Internal teams can add stricter service levels, but those should be labelled as internal controls rather than GDPR deadlines.

  • Included: GDPR applicability date, DSAR response clock, breach 72-hour clock, DPIA and prior consultation timing, transfer review triggers, and retention/accountability review operations.
  • Excluded: national complaint handling times, authority-specific breach form deadlines beyond Article 33, sector retention periods, and unsupported annual review dates.
  • Citation rule: every public source URL on this page is external, HTTPS, and includes ref=sorena.io.
Recommended next step

Use this GDPR calendar as a cited operating reference

Sorena can help convert these source-linked GDPR clocks into request queues, incident runbooks, DPIA gates, transfer reviews, and retention checks with owner and evidence fields.

Primary sources

References and citations

eur-lex.europa.eu
Referenced sections
  • Primary legal source for the included GDPR timing rules and source limits.
"binding in its entirety"
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