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GCC zone / saudi-pdpl-sovereign

Saudi PDPL, NDMO and UAE PDPL in-country AI inference routing

In-Kingdom routing for Saudi data, in-country routing for the UAE, and signed proof for SDAIA, NCA and free zone reviews.

Route card / GCC

base_url https://gcc.yttsecunet.com/v1

X-YTT-Policy saudi-pdpl-sovereign

endpoints 4 certified, 4 providers

primary Riyadh

failover Another in-Kingdom endpoint

never Dubai, for Saudi tenants

plans Enterprise, Dedicated

Laws and instruments that govern the GCC zone

InstrumentCitationWhat it means for an inference call
Saudi Personal Data Protection Law (PDPL)Royal Decree M/19 of 1443H, amended by Royal Decree M/148 of 1444H; in force 14 September 2023Article 29 restricts transfers of personal data outside the Kingdom. Enforcement began on 14 September 2024 after a one-year grace period. SDAIA is the competent authority.
Regulation on Personal Data Transfer outside the KingdomIssued by SDAIA; amended version in force 1 September 2024Sets the purposes for which transfers are allowed, the assessment of the destination's level of protection, and safeguards such as SDAIA standard contractual clauses and binding common rules.
NCA Cloud Cybersecurity ControlsNational Cybersecurity Authority, CCC-2:2024Mandatory for government entities and their cloud providers, and widely required of critical national infrastructure operators. Includes data hosting and localisation requirements for classified data.
UAE Federal Personal Data Protection LawFederal Decree-Law No. 45 of 2021, Articles 22 and 23Cross-border transfers to states with adequate protection (Art. 22) or, otherwise, on listed grounds such as contract or consent (Art. 23). Free zones with their own data protection law, such as DIFC and ADGM, are outside its scope.
DIFC and ADGM data protection regimesDIFC Data Protection Law No. 5 of 2020; ADGM Data Protection Regulations 2021GDPR-style regimes with their own transfer rules and regulators for entities in the two financial free zones.

Middle East (GCC): routing guide

Saudi PDPL and the SDAIA transfer regime

The Saudi PDPL has applied since 14 September 2023, with enforcement from 14 September 2024. Article 29 allows transfers outside the Kingdom only for specified purposes and only where the transfer does not prejudice national security or the vital interests of the Kingdom, with the detail in SDAIA's Regulation on Personal Data Transfer outside the Kingdom, as amended from 1 September 2024. SDAIA has published its own standard contractual clauses and binding common rules as safeguards.

For a bank, insurer or government contractor in the Kingdom, the operational reading is simple: unless legal has documented a transfer basis, personal data in prompts should be processed in-Kingdom. The saudi-pdpl-sovereign pack enforces that default and treats any exception as an explicit, reviewed policy entry with a reference to the safeguard used.

NDMO standards and NCA Cloud Cybersecurity Controls

NDMO, which sits within SDAIA, publishes the National Data Management and Personal Data Protection Standards and the data classification policy that public entities apply: top secret, secret, restricted and public. The NCA's Cloud Cybersecurity Controls, now CCC-2:2024, build on the Essential Cybersecurity Controls and add cloud-specific requirements for providers and tenants, including hosting requirements for classified data.

YTT Secunet maps those rules onto routing decisions. The tenant passes a classification label, or the PII guardrail infers one from the Saudi national ID, Iqama numbers and other markers it detects. Restricted data can only reach endpoints flagged as in-Kingdom and operated under the tenant's approved cloud arrangement; public data can use wider zones the tenant approves. Air-gapped Sovereign Dedicated is available for entities that cannot use any shared service.

  • Classification-aware routing for NDMO labels, enforced before the request leaves the gateway.
  • Saudi national ID and Iqama detection with in-Kingdom token vault.
  • Receipts naming the in-Kingdom facility, for NCA compliance assessments and internal audit.

UAE PDPL, DIFC and ADGM

The UAE is three regimes in one country. Onshore entities follow Federal Decree-Law No. 45 of 2021, supervised by the UAE Data Office, which allows transfers to adequate states and otherwise on listed grounds. DIFC entities follow DIFC Data Protection Law No. 5 of 2020 and ADGM entities the ADGM Data Protection Regulations 2021, each with its own regulator and transfer rules. Sector rules, such as those for health data and for Central Bank regulated firms, can be stricter than all three.

The uae-pdpl-local pack routes UAE tenants to UAE endpoints by default and lets legal teams set a different allowed zone per entity: an ADGM fund manager may accept EEA processing for some workloads while an onshore health provider stays UAE-only. Saudi and UAE tenants never fail over into each other's country, because neither regime treats the other as a domestic destination.

In-country capacity in the Gulf

Model capacity in the region has grown quickly but remains uneven. The registry lists Azure OpenAI in UAE North, Core42 Compass operated from Abu Dhabi, Google Cloud's Dammam region for Vertex AI, and self-hosted vLLM in in-Kingdom facilities. Not every model is served in every region, and the registry shows current availability per model. Where a model is not available in-country, the policy refuses the call rather than quietly sending it abroad, and the application can fall back to an in-country open-weight model.

Where our responsibility stops

YTT Secunet enforces where inference runs and signs a receipt for it. It does not give legal advice and does not replace your DPIA or transfer impact assessment.

In-region endpoints certified for GCC

Each entry is a specific deployment, not a provider as a whole. The registry pins region and deployment type, and refuses a route to a model the region does not serve instead of falling back to another zone.

  • Google Cloud Vertex AI logo

    Google Cloud Vertex AI

    me-central2, Dammam, Saudi Arabia

    Regional endpoint only; per-model availability varies and is checked before routing.

  • vLLM on customer infrastructure logo

    vLLM on customer infrastructure

    In-Kingdom data centre, Saudi Arabia

    Open-weight models for restricted data; supports air-gapped deployments.

  • Microsoft Azure OpenAI logo

    Microsoft Azure OpenAI

    UAE North, Dubai

    Regional deployments for UAE tenants; capacity varies by model.

  • Core42 Compass logo

    Core42 Compass

    Abu Dhabi, United Arab Emirates

    UAE-operated inference API for open-weight and partner models.

Policy pack: saudi-pdpl-sovereign

This is the rule set the gateway evaluates for Middle East (GCC) traffic. Your application names it in the X-YTT-Policy header, pinned to a version, and the decision is made before the request is forwarded to any provider.

  • Evaluated by Open Policy Agent in the regional data plane, under 3 ms median (YTT Secunet production telemetry)
  • Pack id and version are written into every signed receipt, so an auditor can match traffic to the rule that allowed it
  • A denial returns HTTP 451 with the decision id and reason; there is no silent reroute
  • Legal teams review changes in the visual policy editor before engineering merges them
How Rego packs are versioned and tested
regosaudi-pdpl-sovereign.rego
package yttsecunet.saudi_pdpl_sovereign

default allow := false

restricted_labels := {"top_secret", "secret", "restricted"}

# Classified or personal data: in-Kingdom endpoints only.
allow if {
	input.tenant.domicile == "SA"
	input.endpoint.country == "SA"
	input.endpoint.zdr == true
}

# Public, non-personal content may use an approved zone.
allow if {
	input.tenant.domicile == "SA"
	input.classification.label == "public"
	not input.pii.detected
	input.endpoint.country in input.tenant.approved_countries
}

deny contains "classified data outside the Kingdom" if {
	input.classification.label in restricted_labels
	input.endpoint.country != "SA"
}

deny contains "personal data outside the Kingdom" if {
	input.pii.detected
	input.endpoint.country != "SA"
}

In-zone failover route

Saudi traffic to another in-Kingdom endpoint only; UAE traffic within the UAE; never between the two. Resilience comes from a second facility or provider inside the zone. If none is healthy the gateway refuses the request rather than sending it to the nearest region across the border.

  1. Client app, tenant domicile GCC, calls gcc.yttsecunet.com
  2. Primary: Riyadh
  3. In-zone failover: Another in-Kingdom endpoint
  4. Never: Dubai, for Saudi tenants. With no healthy in-zone endpoint the gateway fails closed with HTTP 503.

Middle East (GCC): questions from DPOs and architects

Does the Saudi PDPL ban all transfers abroad?

No. Article 29 and SDAIA's transfer regulation allow transfers for specified purposes with safeguards such as SDAIA's standard contractual clauses. Many regulated entities still keep personal data in-Kingdom by default because NCA controls and sector rules expect it, and because the exception analysis has to be documented.

Who supervises personal data protection in Saudi Arabia?

SDAIA is the competent authority under the PDPL. NDMO, part of SDAIA, issues data management and classification standards. The NCA sets cybersecurity controls, including the Cloud Cybersecurity Controls.

Does UAE federal law apply to a company in DIFC?

Entities in DIFC and ADGM are generally governed by those free zones' own data protection laws rather than the federal PDPL. YTT Secunet lets you set a different policy per legal entity.

What happens when a model is not available in-country?

The call is refused with a policy reason, and your application can route to an in-country open-weight model instead. YTT Secunet never sends restricted Saudi data abroad to find capacity.

Sovereign route ready

Route GCC inference inside the GCC zone, with proof.

Change the base URL, name the policy pack, and every response carries a signed residency receipt your DPO can verify offline.