There is no single global “right to be forgotten”. The phrase means different things in different countries, and in some places it hardly exists at all. This guide compares how the main markets treat requests about old or harmful content online, so you can understand what the law may and may not offer. It is general information as of October 2026, not legal advice.
New to the topic? Start with our explainer on what the right to be forgotten means, and see what it does and doesn’t cover.
What “right to be forgotten” can mean
- A right to erasure of personal data. Under the EU and UK GDPR, people can ask organizations to erase their personal data in certain situations.
- Delisting from search results. The page stays online, but a search engine may stop showing it for searches on your name. Whether this is available depends on the country.
- Protection against false or harmful content. Defamation, harassment and online safety laws can apply to specific content, whatever the country’s approach to erasure.
Country comparison
| Country or region | Main laws | General right to be forgotten? | Key limits and our guide |
|---|---|---|---|
| European Union (including Ireland, France, the Netherlands) | GDPR, Article 17 (right to erasure) | Yes, in defined situations | Freedom of expression, journalism, public interest and legal duties can outweigh it. See our guides for Ireland, France and the Netherlands. |
| United Kingdom | UK GDPR and the Data Protection Act 2018 | Yes, similar to the EU | Journalism and public interest are weighed against it. UK guide. |
| United States | No federal right. Some state privacy laws, such as California’s | No general right | The First Amendment and Section 230 limit what can be required of publishers and platforms. US guide. |
| Canada | PIPEDA and provincial privacy laws | Not settled | Whether search results can be delisted has been considered by regulators and courts, and the position is still developing. Canada guide. |
| Australia | Privacy Act 1988 and the Online Safety Act 2021 | No general right | Reform of privacy law has been under discussion. Australia guide. |
| New Zealand | Privacy Act 2020 and the Harmful Digital Communications Act 2015 | No general right | Aimed at seriously harmful communications. New Zealand guide. |
| Singapore | PDPA and the Protection from Online Falsehoods and Manipulation Act (POFMA), plus harassment and defamation law | No general right | Targets specific harms rather than general deletion. Singapore guide. |
| South Africa | POPIA | Limited rights over personal information | Press regulation and free expression also apply. South Africa guide. |
| United Arab Emirates | Federal Decree-Law 45 of 2021 (PDPL) and the cybercrime law | Limited | Strict defamation and cybercrime rules mean caution is needed. UAE guide. |
| Brazil | LGPD | Case by case | The Supreme Federal Court held in 2021 that a general right to be forgotten does not fit the Constitution. Brazil guide. |
| Mexico | Federal Law on the Protection of Personal Data Held by Private Parties (2025) | No settled general right | The Supreme Court limited a Mexico City provision in 2022. Mexico City guide. |
| India | Digital Personal Data Protection Act 2023 | Right to erase personal data, being phased in | Exceptions and phased rules mean the practical effect is still emerging. |
Limits that apply almost everywhere
- Freedom of expression and the public interest. Accurate reporting on matters of public interest is far more likely to stay online.
- Who controls the content. A publisher, a platform or a search engine each has its own rules and decisions.
- Jurisdiction. Many platforms are based in other countries, which limits what a local law can do in practice.
- The facts of your case. Outcomes depend on the content, the context and the people involved, so nobody can honestly guarantee one.
What this means in practice
Where the law offers little, many people focus on what appears when someone searches their name: building accurate, current and credible content so it appears first. We explain how this works in our guide to search suppression, and the difference between the two approaches in removal vs. suppression. If more than one country is involved, see our international hub.
For legal advice about your rights in a particular country, speak to a qualified lawyer there. We are not a law firm, and we do not promise outcomes.
Primary sources
- General Data Protection Regulation (EU) 2016/679, including Article 17 on erasure
- Data Protection Act 2018 (UK)
- Personal Information Protection and Electronic Documents Act (Canada)
Laws change and courts interpret them. Check the current text or ask a qualified local lawyer before relying on any summary here.
How to cite this comparison
Remove Negative Articles, “Right to Be Forgotten by Country: A 2026 Comparison”, https://removenegativearticles.com/right-to-be-forgotten-by-country-comparison/. Last reviewed October 2026. You are welcome to link to this page; please keep the “general information, not legal advice” note when you quote it.
General information as of October 2026, not legal advice. Laws change, so check the current position with a qualified local lawyer.