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ARTICLE · 09 NOVEMBER 2026

Saudi Arabia's Proposed PDPL Implementing Regulation Amendments: What Businesses Deploying AI, Cloud And Data-driven Technologies Need To Know

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Saudi Arabia's Data and Artificial Intelligence Authority has published draft amendments to the Personal Data Protection Law's Implementing Regulation that raise critical questions for businesses deploying AI and cloud technologies. When does AI qualify as an 'emerging technology' triggering impact assessments? Where is data actually 'stored' in distributed AI architectures? How do international technology providers affect registration requirements?

Saudi ArabiaPrivacy
Christine Khoury
Christine Khoury
Noor Al Wari
Noor Al Wari
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On 6 October 2026, the Saudi Data and Artificial Intelligence Authority (SDAIA) published a revised set of draft amendments to the Implementing Regulation of the Personal Data Protection Law (PDPL) for public consultation, open until 5 November 2026. The proposals follow an earlier consultation in 2025 and remain, for now, draft.

The proposed amendments are not primarily focused on AI or technology. Instead they would amend the Personal Data Protection Law framework more broadly. But several proposals raise practical questions for businesses developing or deploying AI, cloud and other data-driven technologies in the Kingdom. Some of those questions arise not from entirely new obligations, but from how existing data protection concepts would apply to increasingly complex technology architectures.

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