This article on Habeas Data is the second part in our ‘Prepare for 2026’ series, designed to help you navigate Colombia’s legal landscape with confidence in the upcoming year. Check out the first article of our series here.

For companies operating in Colombia, Habeas Data compliance is not optional: its a legal and operational cornerstone. As you prepare for 2026, understanding the annual obligations imposed by Law 1581 of 2012, Decree 1074 of 2015, and the SIC’s guidelines will help you avoid penalties and strengthen your data-governance framework.

This CLE habeas data compliance summary focuses on three pillars:

1. Implementing legal obligations and good practices
2. Maintaining and updating accurate registry information
3. Ensuring ongoing protection of personal data

To make compliance simpler, we have created a practical guide that outlines what every organization must complete throughout the year. From updating your privacy notices and reviewing processor agreements to refreshing your internal policies and filing the mandatory RNBD annual update (if its mandatory for your company), this article will give you a clear roadmap for staying compliant.

2026 Habeas Data Obligations & CLEs Good Practice Recommendations

The table we’ve drafted explains obligations and recommended good practices for the two company types our law distinguishes between:

1. RNBD companies only: Companies with assets >100,000 UVT (COP $ 4.979.900.000 or roughly USD $1,297,373) must maintain and annually update their database registry in the National Registro of Data Bases (“Registro Nacional de Bases de Datos”)
2. All companies: Any entity that handles personal data (employees, customers, suppliers, users, CCTV, etc.) under Law 1581 of 2012

Description	Applies To	Legal Basis	Fixed Deadline?
Maintain a privacy policy and make it available to data subjects OR Privacy Notice if unable to communicate	All companies	Decree 1074/2015 Art. 2.2.2.25.3 Decree 1377/2013 Art. 14	No, continuous obligation
Guarantee ARCO rights (access, correction, deletion, objection)	All companies	Law 1581/2012 Arts. 8–14	No, continuous obligation
Process information requests	All companies	Law 1581/2012 Art. 14	Yes: per request, 10 business days
Process complaints	All companies	Law 1581/2012 Art. 15	Yes: per request, 15 business days
Implement security measures to protect personal data	All companies	Law 1581/2012 Arts. 17-18	No, continuous obligation
Sign specific contracts with data processors (“encargados”)	All companies using vendors	Decree 1074/2015 Art. 2.2.2.25.5.2	No, continuous obligation
Register databases in the RNBD	RNBD companies only	Decree 1074/2015 Art. 2.2.2.26.1.3	Yes: initial registration deadline (depending on creation date)
Update the RNBD annually	RNBD companies only	SIC Circular Única 03/2018	Yes: annual fixed window: Jan 2 to Mar 31
Report substantial changes to the RNBD	RNBD companies only	SIC Circular Única 03/2018	Yes: within first 10 business days of the month following the change
Report claims received from data subjects to the RNBD	RNBD companies only	SIC Circular Externa 03/2018	Yes: first 15 business days of Feb and Aug
Report security incidents that compromise data	All companies (if incident occurs)	SIC Circular Externa 03/2018	Yes: within 15 business days of detection
Internal compliance audit	All companies	Not defined in law	No: CLE good practice
Annual review/update of privacy policy	All companies	Not defined in law	No: CLE good practice
Vendor data protection review	All companies using vendors	Not defined in law	No: CLE good practice
DPIA risk assessment for sensitive or high-risk processing	Companies handling sensitive data	Not explicitly required (in general)	No: CLE good practice (also recommended by SIC and GDPR)
Cybersecurity risk assessment	All companies	Not defined in law	No: CLE good practice

Bottom Line

Compliance with Colombia’s Habeas Data regulations is a continuous responsibility for any company handling personal data. However, meeting the minimum legal requirements won’t make your business stand out. That’s why CLE’s best practice recommendations help elevate your data protection standards, aligning them with international frameworks like the European GDPR.

By distinguishing between mandatory legal obligations and good-practice recommendations, organizations can focus their efforts where the law requires it while also building a strong internal data governance framework that mitigates risks and fosters trust with clients, employees, and partners.

Lastly, check out this article our where our Co-Founder Martha Bonett details compliance trends, including habeas data regulatory obligations that have become mandatory for Colombian companies in the past five years.