131filers, current period
129the period before
4controls it touches
4frameworks
Cross Border Data Transfer in 10-K and 10-Q filings, by month.
The marked line is the first month any public company in our record used the phrase; everything left of it is nobody writing it down.
Companies disclosing it
131
wrote this into a filing with the SEC
What it obligates
4
controls across 4 frameworks whose text speaks to it
Employers hiring for it
775
open US roles name it, and the ones below are hiring now
The long view, in annual and quarterly filings
A 10-K or 10-Q is a periodic report, so this counts how often the phrase appears in routine annual and quarterly reporting. It moves far more slowly and the numbers are larger.
Every month since 2008. The last point is the current month and is still
filling, so it always looks lower than it will be.
2008
peak 144 in March 2026
2026
Who disclosed it
From SEC full-text search over 8-K filings. Every row links to the filing itself.
| Company | Form | Filed | |
|---|
| INOVIO PHARMACEUTICALS, INC. INO | 10-Q | 2026-08-12 | filing |
| Quantum Computing Inc. QUBT | 10-Q | 2026-08-10 | filing |
| PFIZER INC PFE | 8-K | 2026-08-04 | filing |
| Kimball Electronics, Inc. KE | 10-K | 2026-08-19 | filing |
| Kodiak Sciences Inc. KOD | 10-Q | 2026-08-13 | filing |
| Tectonic Therapeutic, Inc. TECX | 10-Q | 2026-08-06 | filing |
| Outlook Therapeutics, Inc. OTLK | 8-K | 2026-08-12 | filing |
| AppLovin Corp APP | 10-Q | 2026-08-05 | filing |
| Cytek Biosciences, Inc. CTKB | 10-Q | 2026-08-05 | filing |
| NEUROCRINE BIOSCIENCES INC NBIX | 10-Q | 2026-07-31 | filing |
| Vivid Seats Inc. | 10-Q | 2026-08-04 | filing |
| TWILIO INC TWLO | 10-Q | 2026-08-07 | filing |
| Datadog, Inc. DDOG | 10-Q | 2026-08-06 | filing |
| Maplebear Inc. CART | 10-Q | 2026-08-07 | filing |
| Rapport Therapeutics, Inc. RAPP | 10-Q | 2026-08-05 | filing |
| BeOne Medicines Ltd. | 10-Q | 2026-08-05 | filing |
The full search on EDGAR
Which industries file it
Companies grouped by the industry classification on their own filing. A count, not a
survey.
| Industry | | Companies |
|---|
| Chemicals and pharmaceuticals | | 189 |
| Software and IT services | | 109 |
| Instruments and medical devices | | 31 |
| Services and entertainment | | 21 |
| Holding and investment offices | | 20 |
| Electronics and electrical equipment | | 19 |
| Retail | | 14 |
| Industrial machinery | | 10 |
| Transport equipment | | 10 |
| Business services | | 8 |
What it obligates
Our corpus holds 4 controls across
4 frameworks whose text speaks to this. Not a judgement:
these controls say so, and each is one lookup from its source document. Ordered by how much each
framework has to say about it, so the one that will cost you the most work is first. Every name
opens that framework in the corpus.
What an auditor will ask you to produce
The artefacts named on those controls, most frequently cited first.
- KVKK evidence for TURKEYKVKK-5
- Adequacy determination records
- Consent for transfers to non adequate countries
- Transfer impact assessments
- Recipient lists with countries
- Transfer mapping covering Swiss originated data flows
- Executed Swiss compatible standard contractual clauses
- FDPIC notification records where required
How it usually fails
Recorded when each control was verified against its source. This is where programmes
that think they are covered turn out not to be.
- VERBIS + 2024 amendments + 72hr breach partial
- Adequacy assumed without analysis
- Onward transfers from processors not tracked
- Consent not specific to international transfer
- Standard clauses not adapted to Swiss requirements
- Adequacy reliance not refreshed for changes in destination law
GDPR Evidence & Implementation Kit
40 controls sit behind GDPR, and this is the documentation set for them: an adopt-ready artifact per control, and the evidence an auditor asks for against each.
See what is in it, $249
The same set every buyer of this kit receives. Nothing here is produced on request.
40If you already run GDPR, that is the 40 controls behind this disclosure, already evidenced.
103And ISO 27701:2019 is not a separate programme. 103 of its controls are the same controls. If it is on next year's plan, that part of it is already done.
36And ISO 27002:2022 is not a separate programme. 36 of its controls are the same controls. If it is on next year's plan, that part of it is already done.
34And ISO 27001:2022 is not a separate programme. 34 of its controls are the same controls. If it is on next year's plan, that part of it is already done.
Run as two programmes
143 controls
GDPR and ISO 27701:2019 scoped separately, each with its own
evidence, its own owner and its own budget line. This is how almost everybody does it.
Run once, counted twice
103 already done
103 of ISO 27701:2019's controls are controls you evidenced for
GDPR. Same artefacts, same owner, no second effort. The mapping is the
only reason anybody knows.
Cross Border Data Transfer in 10-K and 10-Q filings, by month.
The marked line is the first month any public company in our record used the phrase; everything left of it is nobody writing it down.
What this actually means
- Why now
- 131 public companies wrote this into an 8-K in the last seven days, 2% more than the seven before. That is not sentiment or a survey. It is a count of companies choosing to put a phrase into a document they are legally accountable for.
- Who already cares
- 775 open US roles name this work today, which suggests increased attention to it beyond what any filing says. A job advertisement clears a budget holder and a filing clears legal, so the two answer to different people. We have not measured which moves first, only that both are moving.
- What comes into scope
- Once the phrase is on the record it maps to obligations within GDPR, Romania Law No. 190/2018 on Data Protection Measures (GDPR Implementation), ISO/IEC 27701:2019. 79 controls behind those, and the difference between asserting them and evidencing them is the whole of the work.
- Who is quietly ahead
- Anyone already running GDPR has done 103 of the controls that carry ISO 27701:2019 too. Same evidence, second standard. Most organisations run those as two programmes with two budgets because nobody told them the mapping existed.
- Who is exposed
- 8 companies disclosed this for the first time in the last ninety days, out of 477 in total. A first mention is a company deciding it can no longer not say it. Whoever has not yet is either genuinely unaffected or has not looked, and nothing here distinguishes the two.
What this obligates
The instruments in our corpus that govern this disclosure, and how many controls sit
behind each. This is not a filing count. It is what applies once a company has written the
phrase down.
5 frameworks, 79 controls between them.
GDPR holds 40 controls. They appear again inside
268 other frameworks in our corpus; the 10 strongest are shown. Thickness and
size both carry the number of controls shared, so work done once counts in every framework on
this diagram.
What closing it also moves
The same controls appear in other frameworks through mappings held in our corpus. Work
done here is already progress there. This is the part that is not in EDGAR and not in any public
dataset: it comes from mappings built and verified by hand, control by control.
ISO 27701:2019103
ISO 27002:202236
ISO 27001:202234
NIS2 Directive23
Counted as controls reached through cross-framework mappings. It measures
overlap of work, not compliance with the named framework.
Run as two programmes
143 controls
GDPR and ISO 27701:2019 scoped separately, each with its own
evidence, its own owner and its own budget line. This is how almost everybody does it.
Run once, counted twice
103 already done
103 of ISO 27701:2019's controls are controls you evidenced for
GDPR. Same artefacts, same owner, no second effort. The mapping is the
only reason anybody knows.
40If you already run GDPR, that is the 40 controls behind this disclosure, already evidenced.
103And ISO 27701:2019 is not a separate programme. 103 of its controls are the same controls. If it is on next year's plan, that part of it is already done.
36And ISO 27002:2022 is not a separate programme. 36 of its controls are the same controls. If it is on next year's plan, that part of it is already done.
34And ISO 27001:2022 is not a separate programme. 34 of its controls are the same controls. If it is on next year's plan, that part of it is already done.
Tell me when Cross Border Data Transfer files something new
One email when a public company newly discloses this, naming the company and what our corpus says it puts in scope. Nothing else, and one click to stop.
Where this comes from
The left half is public record: SEC full-text search over 8-K filings, counted across a
14 day window against the equivalent window before it. You can check
every row.
The right half is ours: 723 frameworks and
20,473 controls, 531 of those frameworks verified against
their source documents, with the auditor evidence and common failure modes recorded control by
control. Controls appear here because their own text names this term.
Cite this
The Art of Service Signals. Cross Border Data Transfer corporate disclosure activity: 131 filers against 129 in the prior period, in 10-K and 10-Q filings, this quarter against the same quarter last year. Accessed 23 September 2026. https://signals.theartofservice.com/t/cross-border-data-transfer/
Free to use with attribution, no permission needed. The chart downloads as an SVG
with the source printed on it. If you cite it we would like to know, but you do not need to
ask.
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