Hesham Elmahdy العربية

My company works in Saudi Arabia. What does the law ask of us when an AI agent reads our data?

The short answer

The Personal Data Protection Law applies, and it has been enforceable since September 2024. Consent is the default basis for processing personal data. If the model that serves your agent runs outside the Kingdom, every request that carries personal data is a transfer abroad, and that is allowed only under the conditions of the transfer regulation. SDAIA's AI ethics principles and generative AI guidelines are not laws.

The law that applies

The Personal Data Protection Law was issued by Royal Decree M/19 of 1443H and amended by Royal Decree M/148 of 1444H. It came into force on 14 September 2023, and companies were expected to comply by 14 September 2024. The Saudi Data and AI Authority, SDAIA, is the authority that enforces it.

The law covers personal data of people living in the Kingdom, including processing done from outside the Kingdom. The only exception is personal or family use, and the implementing regulation says that business use never counts as personal use. So a foreign model provider that processes your clients’ data is within its reach.

Can the agent read personal data at all?

Yes, if you have a legal basis. The default basis is the person’s consent, and consent can be withdrawn at any time. The law also allows processing without consent in a few cases:

Three rules matter most for an agent:

The model provider is your processor

When the agent sends text to a model run by a provider, the provider processes that data on your behalf. The law allows you to use only processors that give the necessary guarantees. Your contract with the provider must state, among other things, whether the provider is subject to the laws of other countries, and it must name the sub-processors. A sub-processor needs your prior acceptance.

Sending data outside the Kingdom

The law allows a transfer abroad for a set of purposes, and normally only if three conditions hold. It must not harm national security or the Kingdom’s vital interests. The destination must offer protection at least equivalent to Saudi law. And only the minimum data needed may be sent. The transfer regulation exempts some cases from the second and third conditions, but those cases still need safeguards.

The transfer regulation, version 2.0 of August 2024, sets out how this works:

Before you start, and when something goes wrong

The penalties are real. A breach of the law can bring a warning or a fine of up to 5 million riyals, doubled for a repeat offence. Disclosing sensitive data to harm someone or for personal gain can bring up to 2 years in prison.

What SDAIA says about AI itself

SDAIA has published AI Ethics Principles, version 1.0 of September 2023, with 7 principles that include privacy and security, transparency and explainability, and accountability. It has also published generative AI guidelines, in one version for government and one for the public. These are not laws, but the AI Ethics Principles state that they apply to everyone who builds or uses AI in the Kingdom. The generative AI guidelines are guidance. I found no Saudi law that regulates AI as such, as of October 2026. For an agent that handles personal data, the binding rules are the data protection law and its regulations.

Sector rules

Banks and finance companies also answer to the Saudi Central Bank, whose powers the law preserves. Government entities and operators of critical national infrastructure must apply the National Cybersecurity Authority’s Essential Cybersecurity Controls, which now refer questions of data localization to the National Data Management Office.

What this means for you

I am not a lawyer. This page summarizes the official texts as I read them in October 2026. Ask a lawyer about your own case.

References

  1. SDAIA, Personal Data Protection Law, National Data Governance Platform
  2. SDAIA, Implementing Regulation of the Personal Data Protection Law
  3. SDAIA, Guide to the Personal Data Protection Law for controllers and processors, December 2023
  4. SDAIA, Regulation on Personal Data Transfer outside the Kingdom, version 2.0, August 2024
  5. SDAIA, Standard Contractual Clauses for Personal Data Transfer, September 2024
  6. SDAIA, Risk Assessment Guideline for Transferring Personal Data Outside the Kingdom, February 2025
  7. SDAIA, Rules for Registering on the National Data Governance Platform
  8. SDAIA, AI Ethics Principles, version 1.0, September 2023
  9. SDAIA, Regulations and Policies
  10. National Cybersecurity Authority, Essential Cybersecurity Controls

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