UK GDPR sits on the same Bubble DPA as EU GDPR — Bubble's own page even names the UK explicitly. The harder bits sit around the edges: the UK IDTA / Addendum for transfers, the new Data (Use and Access) Act 2025 changes that take effect Feb 5 2026, and the £17.5M PECR fine ceiling for cookies and marketing. For most UK enterprise deals the honest path is Bubble Enterprise on a UK or EU region plus the DPA — not a rebuild.
The honest verdict
Partially. Not the way you’d ship UK GDPR in production.
Bubble has the certification at platform level — but it does not transfer to your app. Bubble's Enterprise security page lists GDPR and the UK explicitly in the same sentence — the published DPA covers both jurisdictions, and the UK transfer story is handled by the UK IDTA / Addendum. As with EU GDPR, Bubble acts as processor and the controller-side obligations stay with the developer.
including the General Data Protection Regulation in the EU and the UK
Reviewed by
Greg· Founder, bubbletocode.com — has migrated 30+ Bubble apps to code
Bubble's stance
Partial
DPA names the UK; controller obligations stay with you
Worst-case penalty
£17.5M / 4%
DUAA 2025 raised PECR fines to the same ceiling
Industries impacted
B2B SaaS · Consumer · Public sector · Fintech
Compliant rebuild
$40k–$100k · 6–14 weeks
Only when UK-only residency forces it
What UK GDPR actually requires
UK GDPR is the retained, post-Brexit version of GDPR plus the Data Protection Act 2018. The Information Commissioner's Office (ICO) enforces it, the Data (Use and Access) Act 2025 amends it from 2026, and the higher-tier fine is the greater of £17.5M or 4% of global turnover.
Process UK personal data only on a valid lawful basis, including the new "recognised legitimate interests" basis the DUAA 2025 added to Article 6 (UK GDPR Art. 6).
Honour data-subject rights — access, rectification, erasure, portability — using the DUAA's stop-the-clock and reasonable-and-proportionate search standards for SARs (UK GDPR Arts. 12–22).
Implement data protection by design and by default and put in place appropriate technical and organisational measures (UK GDPR Arts. 25, 32).
Notify the ICO of a personal-data breach within 72 hours where the breach risks the rights and freedoms of individuals (UK GDPR Art. 33).
Maintain a written data-protection complaints procedure and respond to complaints, a new explicit duty added by the DUAA 2025 (DUAA 2025 amendment to UK GDPR).
Pay the annual ICO data-protection fee and keep the records of processing the accountability principle requires (Data Protection (Charges and Information) Regulations 2018).
Official source: legislation.gov.uk
Why Bubble fails UK GDPR
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.
For shared-tier apps, UK personal data lives in the US on shared AWS. The Bubble DPA covers the transfer via the UK IDTA / EU-US DPF UK Extension, but the physical residency is still American. To anchor data in the UK or EU you need Bubble Enterprise dedicated and a London or Frankfurt AWS region — a contractual move, not a checkbox.
Bubble's continuous point-in-time backups default to a 20-year window on Enterprise dedicated. UK GDPR Article 17 still applies across backups, and the ICO has been clear that retention has to be defensible. You can shorten the window down to 8 days on Enterprise, but the controller needs to document exactly how the right to erasure is met against the backup chain.
Sources[05]
Article 28 expects a transparent, current sub-processor list a UK DPO can diff over time. The bubble.io/subprocessors page is JavaScript-rendered, so it can't be scraped automatically, and only AWS and Cloudflare are confirmed from other bubble.io pages. UK procurement teams accustomed to receiving a downloadable list have to email Sales.
Third-party Bubble plugins load JavaScript in the user's browser and can ship server actions on Bubble's servers. Under UK GDPR each one is a separate processor relationship the controller has to assess. Bubble's DPA does not extend to them, so the UK DPO needs an inventory of every plugin and a sign-off (or DPA) per third party.
Sources[07]
UK GDPR Article 33 keeps the 72-hour clock. Bubble runs annual penetration tests and a 99.9% uptime SLA on Enterprise dedicated, but no contractual hours-based breach commitment. Your IR plan should assume Bubble may need longer than 72 hours to confirm a personal-data incident, so build your own monitoring and disclosure routes.
Sources[01]
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.
DPA covering UK personal data
Pass
Published DPA names the UK
Enterprise security page is explicit
Pass
Your own DPA with Vercel / AWS London
UK or EU data residency
Partial
Enterprise dedicated only
Shared tier stays in the US
Pass
Region pinned in your contract
UK IDTA / Addendum for transfers
Pass
Covered via Bubble DPA + Addendum
Pass
Direct UK IDTA with your host
Article 17 erasure across backups
Partial
20-year default; configurable
Can be shortened to 8 days on Enterprise
Pass
Backup window under your control
Transparent sub-processor list
Partial
JS-rendered page, AWS + Cloudflare confirmed
Pass
Maintained in your DPA
72-hour ICO breach notification
Fail
No hours-based SLA documented
Pass
Contracted hours-based SLA
PECR / cookie consent under DUAA 2025
Partial
Build-your-own consent flow
Pass
Server-rendered consent + audit log
What it costs your business
UK enterprise procurement asks the same three questions every time: do you have a UK DPA addendum, where does the data sit, and can you produce ICO-ready breach evidence. Bubble's DPA gives you the first answer; Bubble Enterprise on a UK or EU region gives you the second; the third is on you. The October 2025 Capita £14M fine is the warning shot for buyers — they will push on the third point.
A UK insurer's third-party risk team requires the UK IDTA Addendum signed alongside the DPA; without it the deal stalls in procurement for weeks.
An ICO complaint follows a DSAR you couldn't action against backups — even short of a fine, the ICO investigation closes pilots in motion.
The DUAA 2025 raised PECR (cookie / marketing) fines from £500k to the GDPR ceiling of £17.5M or 4% of global turnover from Feb 5 2026 — sloppy cookie consent now sits inside the headline penalty regime.
The October 2025 Capita £14M ICO fine and the £3.07M Advanced Computer Software fine prove the ICO is willing to penalise inadequate security around vendor estates; buyers expect security-questionnaire answers that survive that level of scrutiny.
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 UK GDPR.
Cheapest now · riskiest later
ViableSign Bubble's DPA, add the UK IDTA / Addendum, move to Bubble Enterprise on a London (eu-west-2) or EU AWS region, and document the ICO-side controls. The recommended path for the great majority of UK enterprise deals.
Pros
Cons
Phased · auditor-defensible
Partial fitKeep Bubble Enterprise for the bulk of the app, move the workflows the buyer wants UK-only or with tighter audit retention to a separate Next.js service on AWS London or Vercel UK under your own UK DPA.
Pros
Cons
Highest upfront · clean audit
ViableOnly earns its keep when a UK buyer mandates UK-only residency, sub-processor approval rights, or PECR-grade marketing controls. Target stack: Next.js on Vercel Enterprise (UK Extension to EU-US DPF, SOC 2 Type 2, ISO 27001) or AWS London under your own DPA.
Pros
Cons
Composite case study
UK fintech · 16 months on Bubble · enterprise insurer pilot
Founder had three paying SMB customers and a UK enterprise insurer in late-stage procurement when the buyer's privacy team blocked the deal on UK residency and a UK IDTA addendum. The team moved the app to Bubble Enterprise on the eu-west-2 (London) region, signed the Bubble DPA with the UK Addendum, attached the published sub-processor list with AWS and Cloudflare confirmed, and produced a one-page Article 32 statement against Bubble's platform controls plus their own app-level controls. They also configured backup retention down to 30 days and documented the erasure process across that window.
Outcome: Buyer privacy sign-off in 11 working days; the same artefact pack unblocked two further UK pilots the next quarter.
Composite case study assembled from patterns we've seen across multiple UK enterprise migrations. Anonymised for client privacy — happy to walk you through the actual ICO conversations 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.manual.bubble.io
Bubble Group Inc.bubble.io
Bubble Group Inc.manual.bubble.io
Bubble Group Inc.manual.bubble.io
Bubble Group Inc.bubble.io
Bubble Group Inc.manual.bubble.io
UK Government — National Archiveslegislation.gov.uk
Information Commissioner's Officeico.org.uk
UK Parliament · 2025-06-19legislation.gov.uk
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