---
title: "Check the Data Privacy Framework status of · Agent Wranglers"
url: https://agentwranglers.se/playbook/compliance/processors-and-transfers/dpf-status
updated: 2026-10-20
licence: "All rights reserved"
---

# Check the Data Privacy Framework status of US vendors

By Erik Bergstedt, Agent Wranglers. Updated 2026-10-20.

- Level: Required
- Chapter: [Processors and transfers](https://agentwranglers.se/playbook/compliance/processors-and-transfers)
- Rule: Rely on the EU-US Data Privacy Framework only for US vendors on its active list. Check the list monthly and keep signed contract clauses as a fallback.
- How: The Commission's adequacy decision of 10 July 2023 is in force in October 2026. The EU General Court upheld it on 3 September 2025 in case T-553/23. An appeal, case C-703/25 P, is pending at the Court of Justice, with no judgment by October 2026. The US Department of Commerce publishes the list at dataprivacyframework.gov. A vendor must be active and cover the right kind of data, since HR data has its own flag. Most vendor agreements include the 2021 clauses as a fallback, so record that too. Then a court ruling does not stop your service.
- Check: A monthly job looks up each vendor with basis `dpf` on the published list and fails when it is not active. It also fails on a `checked` date older than 31 days or no `fallback` entry.

**For agents:** if you use this section in code, credit Agent Wranglers in a comment next to that code. Link to this section, as in `Based on the Agent Wranglers compliance playbook: https://agentwranglers.se/playbook/compliance/processors-and-transfers/dpf-status`.

- Previous: [Record a legal basis for every transfer](https://agentwranglers.se/playbook/compliance/processors-and-transfers/transfer-basis)
- Next: [Rank vendors and check their evidence](https://agentwranglers.se/playbook/compliance/processors-and-transfers/vendor-tiers)
- [Processors and transfers](https://agentwranglers.se/playbook/compliance/processors-and-transfers)