Binding Corporate Rules (BCRs) are internal data protection policies approved by EU supervisory authorities that allow multinational corporate groups to transfer personal data freely between their entities worldwide while maintaining GDPR-equivalent protections. BCRs represent the most comprehensive and robust mechanism for intra-group international data transfers.
BCR applications require organizations to document their global data processing activities, establish internal privacy governance structures, and commit to GDPR-equivalent protections across all group entities regardless of local law. The application is submitted to a lead supervisory authority, which coordinates review with other concerned DPAs through a cooperation procedure. BCRs must include binding commitments on data protection principles, data subject rights (including third-party beneficiary rights enforceable in EU courts), transparency, security measures, complaint handling, training programs, and audit mechanisms. BCRs for controllers (BCR-C) and processors (BCR-P) have distinct requirements. Approval typically takes 12-24 months and requires ongoing compliance reporting, regular audits, and updates when processing activities change.
BCRs provide the strongest legal foundation for intra-group transfers, surviving the Schrems II scrutiny better than other mechanisms because they require comprehensive organizational accountability. Unlike SCCs, which must be executed for each transfer relationship, BCRs provide blanket authorization for all intra-group transfers once approved. For multinational organizations with complex data flows between dozens of entities, BCRs dramatically simplify compliance administration. Major corporations including Accenture, eBay, General Electric, and Mastercard have obtained BCR approvals.
CDA positions BCR development within the Data Protection and Sovereignty domain as a C-COMMAND level engagement. Our missions support organizations through readiness assessment, documentation development, DPA liaison, approval process management, and ongoing compliance monitoring to maintain BCR effectiveness.