Australia's Privacy Act 1988 got a lot sharper in late 2024. Tier 3 penalties for serious interferences now reach the greater of A$50M, 3× benefit, or 30% of adjusted turnover, with a new statutory tort (in force June 10, 2025) and automated-decision transparency obligations commencing December 10, 2026. Bubble has no Australian-specific stance, but the work is contractual: a Bubble DPA addendum aligned to the 13 APPs, and Bubble Enterprise on AWS Sydney for buyers who insist on Australian residency. A rebuild only earns its keep when residency is a hard gate.
The honest verdict
Not officially. Not the way you’d ship Australian Privacy Act in production.
Bubble has no public stance. The platform's architecture makes a real audit hard. Bubble's compliance pages do not mention the Australian Privacy Act or the Australian Privacy Principles, and the standard does not appear in the manual's "Other frameworks" list. Bubble is also silent on Australian data residency — the shared tier hosts in the United States, and Sydney is only reachable through Bubble Enterprise dedicated. The controller-side work — APP-aligned privacy policy, NDB scheme readiness, APP 11 security statement — is the developer's.
Reviewed by
Greg· Founder, bubbletocode.com — has migrated 30+ Bubble apps to code
Bubble's stance
Silent
Not named in the manual's compliance pages
Worst-case penalty
AU$50M / 30%
Tier 3 — greater of AU$50M, 3× benefit, or 30% adj. turnover
Industries impacted
B2B SaaS · Consumer · Fintech · Healthcare · Retail
Compliant rebuild
$40k–$100k · 6–14 weeks
Only when Australian residency forces it
What Australian Privacy Act actually requires
The Privacy Act regulates handling of personal information under the 13 Australian Privacy Principles (APPs). The Office of the Australian Information Commissioner (OAIC) enforces it. The 2024 amendment built a tiered civil-penalty regime topping out at the greater of AU$50M, three times the benefit obtained, or 30% of adjusted turnover for the relevant period.
Maintain a clearly expressed, up-to-date privacy policy and only collect personal information by lawful, fair means for necessary purposes (APP 1; APP 3).
Notify individuals about the collection and the intended use or disclosure of their personal information (APP 5).
Use and disclose personal information only for the primary purpose or a permitted secondary purpose (APP 6).
Take reasonable steps — now expressly including "technical and organisational measures" — to protect personal information from misuse, interference, loss, and unauthorised access or disclosure (APP 11, as amended December 2024).
Notify the OAIC and affected individuals of eligible data breaches as soon as practicable under the Notifiable Data Breaches scheme (Privacy Act Part IIIC).
Disclose automated decision-making that significantly affects individuals in your privacy policy, commencing December 10, 2026 (new APP requirement from the 2024 amendment).
Official source: oaic.gov.au
Why Bubble fails Australian Privacy Act
Every reason below comes from Bubble’s published platform limits or their own documentation. Reading the list top-to-bottom tells you which one will bite you first.
Shared-tier Bubble apps live in US AWS. APP 8 governs cross-border disclosure and keeps the disclosing entity accountable for the overseas recipient's handling — that's workable, but Australian government buyers and many enterprise procurement teams expect data in country. Only Bubble Enterprise dedicated lets you pick a region, and AWS Sydney (ap-southeast-2) is on the menu when you ask Sales.
Sources[03]
Bubble's "Other frameworks" page lists several US state and national privacy laws but does not name the Australian Privacy Act or the APPs. That doesn't make compliance impossible — APP 11 is principle-based — but it does mean Bubble has not produced a published statement an OAIC inquiry could rely on. The developer has to do the APP-by-APP mapping themselves.
Sources[01]
APP 11.1 expects you to take reasonable steps including "technical and organisational measures" to protect personal information. Bubble's continuous point-in-time backups default to a 20-year window on Enterprise dedicated. That helps with availability but means destruction of personal information once it is no longer needed (APP 11.2) is harder to evidence than a single-database wipe. Window is configurable on Enterprise, not on shared.
Sources[04]
The Notifiable Data Breaches scheme requires notification "as soon as practicable" after assessing that a breach is likely to result in serious harm. Bubble runs annual penetration tests and a 99.9% uptime SLA on Enterprise dedicated, but no contractual hours-based breach-notification commitment. Your IR plan should assume Bubble may need longer than the OAIC's expected window to confirm scope.
Sources[06]
Third-party Bubble plugins load JavaScript in the user's browser and may ship server actions on Bubble's servers. Under APP 8, sending personal information through a plugin to an overseas vendor counts as a cross-border disclosure that you remain accountable for. Each plugin needs an APP-aware assessment; Bubble's DPA does not extend to plugin authors.
Sources[05]
Bubble vs a compliant stack
The same 7requirements an auditor will ask about, scored on both stacks. Read across each row — every red cell is a deal you can’t close on Bubble.
APP-aligned processor / DPA terms
Partial
Adapt standard DPA via addendum
Pass
APP-native DPA with AWS / Azure Australia
Australian data residency
Partial
Enterprise dedicated; confirm Sydney with Sales
Shared tier stays in the US
Pass
ap-southeast-2 pinned in your contract
APP 11 "technical and organisational measures"
Partial
Document against Bubble platform controls
Pass
Mapped to your own SOC 2 / ISO controls
APP 8 cross-border disclosure accountability
Partial
Disclose AWS US via your DPA addendum
Pass
Disclose your own onshore stack
Notifiable Data Breaches scheme readiness
Fail
No hours-based SLA from Bubble
Pass
Contracted hours-based SLA with host
Long-retention audit log for OAIC inquiries
Fail
Logs limited to two weeks
Pass
Immutable log shipped to long-term store
Automated-decision transparency (from Dec 10, 2026)
Partial
Build disclosure in privacy policy + UI
Pass
Inline disclosure rendered server-side
What it costs your business
Australian deals usually break in legal review on three things: an APP-aligned DPA addendum, an APP 11-compatible security statement, and a residency answer. Bubble Enterprise on Sydney plus a tight DPA addendum handles all three for most buyers. The OAIC's first compliance sweep in January 2026 (60 organisations across six sectors) is the cue that 2026 is the year buyers will push harder.
An Australian enterprise buyer's privacy officer asks for an APP-aligned addendum to the Bubble DPA naming the cross-border disclosure mechanism — without it the contract sits in legal for weeks.
A government-adjacent buyer requires AWS Sydney residency; only Bubble Enterprise lets you pick the region, and the manual's worked examples don't name Sydney explicitly, so you need Sales confirmation.
An eligible data breach surfaces and you can't reconstruct the timeline because Bubble's log search is limited to the previous two weeks — the OAIC turns the inquiry into a formal investigation.
Tier 3 penalties reach the greater of AU$50M, three times the benefit, or 30% of adjusted turnover; the 2024 amendments also created a statutory tort for serious invasion of privacy (in force June 10, 2025), so plaintiffs can now sue directly.
Three honest paths forward
We don’t recommend a rebuild for every founder. Below: what each path costs you, what it preserves, and where it breaks for Australian Privacy Act.
Cheapest now · riskiest later
ViableSign Bubble's DPA, attach an APP-aligned addendum covering APP 8 cross-border disclosure and APP 11 security measures, move to Bubble Enterprise on AWS Sydney (ap-southeast-2) if the buyer requires Australian residency, and document your NDB-scheme runbook. Recommended for the vast majority of Australian deals.
Pros
Cons
Phased · auditor-defensible
Partial fitKeep Bubble Enterprise for the bulk of the app; move only the tables a government-adjacent buyer requires kept in Australia to a separate Next.js service on AWS Sydney or Azure Australia East under your own APP-aligned DPA.
Pros
Cons
Highest upfront · clean audit
ViableOnly justified when the buyer mandates Australian residency Bubble can't confirm, or when the Privacy Act stacks with another standard that already forces a rebuild. Target stack: Next.js on AWS ap-southeast-2 (Sydney) or Azure Australia East (Sydney) under your own APP-aligned DPA.
Pros
Cons
Composite case study
B2B SaaS · 14 months on Bubble · Sydney enterprise pilot
Founder had two paying Australian customers and a Sydney enterprise pilot in late-stage procurement when the buyer's privacy officer blocked the deal on three asks: an APP-aligned DPA addendum, AWS Sydney residency, and an APP 11 security statement that covered the December 2024 "technical and organisational measures" wording. The team moved the app to Bubble Enterprise on ap-southeast-2 with Sales confirmation in writing, negotiated the APP-aligned addendum on top of Bubble's DPA, drafted an APP-by-APP mapping document for the 13 APPs, and stood up an internal NDB-scheme runbook with timestamps that shipped to long-term storage off Bubble.
Outcome: Privacy-officer sign-off in 12 working days; the same artefact pack moved two additional Australian enterprise pilots from procurement into signed within the next quarter.
Composite case study assembled from patterns we've seen across multiple APAC privacy migrations. Anonymised for client privacy — happy to walk you through the actual OAIC-aligned playbooks on a scoping call.
Frequently asked
Pulled from real conversations with founders running healthcare, fintech, and B2B SaaS apps off Bubble. Every answer is grounded in the source we cited above — no marketing fluff.
Sources
The numbered references in the body link here. We cite first-party documents — regulator guidance, vendor manuals, industry standards — never marketing copy.
Bubble Group Inc.manual.bubble.io
Bubble Group Inc.bubble.io
Bubble Group Inc.manual.bubble.io
Bubble Group Inc.manual.bubble.io
Bubble Group Inc.manual.bubble.io
Bubble Group Inc.manual.bubble.io
Office of the Australian Information Commissioneroaic.gov.au
Federal Register of Legislation, Australialegislation.gov.au
Office of the Australian Information Commissioner · 2024-12-10oaic.gov.au
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