Data Sovereignty

From Schrems II to the EU-US Data Framework: What's Changed for CX Teams

What still needs a transfer impact assessment, and what does not.

Sofia KellerCompliance Lead, InsightNarrator21 April 202610 min read

The state of EU-US data transfers in 2026, in practical terms.

Adequacy reduces paperwork, not diligence

An adequacy decision changes the legal basis for a transfer. It does not remove your obligation under Article 5 to know where data goes, who processes it and for how long it is kept.

Key takeaways

Keep the sub-processor register current regardless of adequacy status.

About the author

Sofia Keller

Compliance Lead, InsightNarrator

Advises European CX teams on GDPR, transfer impact assessments and hosting architecture. Based in Zurich.

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