Algeria Decree 25-320: A Practical Data Governance Compliance Guide for Public Sector IT Teams

Why December 2025 Was a Turning Point for Algerian Public Sector Data

Algeria’s public sector has accumulated vast stores of citizen data — civil registration records, health databases, social security files, land registries, tax identifiers — with little standardization across how that data is classified, stored, or shared between agencies. Two ministries maintaining records on the same citizen might use incompatible formats, different sensitivity labels, or siloed systems that cannot communicate securely. The result is duplication, inconsistent data quality, and security exposure at every integration boundary.

Presidential Decree No. 25-320, issued on 30 December 2025, is the structural response to this problem. According to CMS Law’s expert guide on Algeria’s data and cybersecurity framework, the decree defines the scope of “data classification, cataloguing, and secure interoperability between public administrations, in line with cybersecurity and personal data protection.” In operational terms, it mandates that every public administration adopt a standardized approach to labeling its data assets, building inventories of what data it holds, and sharing that data only through secure, approved channels.

The decree does not exist in isolation. It sits at the intersection of two other major instruments: Decree No. 20-05, which in January 2021 mandated dedicated information security officers in public bodies and established Algeria’s cybersecurity governance structure under CNSSI (Conseil National de Sécurité des Systèmes d’Information) and ANSSI (Agence Nationale de Sécurité des Systèmes d’Information), and Law No. 25-11 (July 2025), which aligned Algeria’s personal data protection regime with GDPR standards. Decree 25-320 is the data management layer that connects the security infrastructure and the personal data protections into a coherent governance stack.

The Three Pillars of the Decree

Understanding what Decree 25-320 actually requires means breaking it down into its three operational components.

Data classification is the foundational obligation. Public administrations must assign sensitivity labels to all data assets — at minimum distinguishing between open public data, internal administrative data, restricted data (access limited to designated staff or agencies), and confidential data (requiring formal authorization). The classification scheme must be documented, versioned, and reviewed periodically. Classification determines which interoperability channels are permissible, which encryption standards apply, and which incident reporting thresholds are triggered.

Data cataloguing is the inventory obligation. Each agency must build and maintain a structured catalogue of its data assets — recording what data it holds, the legal basis for holding it, its classification level, retention periods, the systems where it resides, and the responsible data officer. This catalogue serves dual purposes: it enables the agency to demonstrate compliance with Law No. 25-11’s record-keeping requirements, and it provides the interoperability layer through which other authorized agencies can discover what data is available for exchange without redundant collection.

Secure interoperability is the exchange obligation. When public administrations need to share data — for integrated citizen services, for law enforcement purposes, for social benefit eligibility determinations — the decree mandates that this sharing occur through secure, documented channels with appropriate access controls and audit trails. The objective is to eliminate ad-hoc data transfers via email, USB drives, or unprotected shared drives, replacing them with controlled API-based or managed file transfer mechanisms that can be audited.

What Public Sector IT Teams Should Do About Decree 25-320

The decree was issued at the end of December 2025. Compliance timelines have not been publicly detailed, but the pattern in Algerian administrative law suggests a 12-to-24-month implementation window with phased agency reviews by ANSSI and CNSSI. Early preparation will determine which agencies lead the compliance curve.

1. Conduct a Data Asset Inventory Before Attempting Classification

The most common mistake in data governance implementations is attempting to classify data without first knowing what data exists. Public-sector IT teams should begin with a structured discovery exercise: cataloguing all databases, file shares, data warehouses, and third-party integrations operated by the agency. This inventory does not need to be perfect from the start — an 80% complete catalogue is vastly more useful than no catalogue. Tools range from manual spreadsheet-based registers (acceptable for smaller agencies) to automated data discovery platforms that scan storage systems and tag assets. The catalogue becomes the foundation for both classification and the interoperability register mandated by the decree.

2. Design a Classification Schema That Maps to Existing Legal Obligations

The decree requires classification “in line with cybersecurity and personal data protection” — meaning the schema must account for both security sensitivity (under the Decree No. 20-05 framework) and personal data status (under Law No. 25-11). A workable public-sector schema has four to five tiers. Tier 1 covers non-sensitive public data (press releases, published statistics). Tier 2 covers internal administrative data with no personal information. Tier 3 covers personal data subject to Law No. 25-11 standard protections. Tier 4 covers sensitive personal data (health, judicial, financial) requiring enhanced protections. Tier 5, where applicable, covers data subject to national security classifications. Aligning this schema to both legal instruments simultaneously — rather than building separate classification systems for cybersecurity and data protection — avoids the duplication error that has undermined classification exercises in comparable North African administrations.

3. Appoint a Data Governance Officer Distinct from the Security Officer

Decree No. 20-05 already requires a dedicated information systems security officer (RSSI — Responsable de la Sécurité des Systèmes d’Information). Decree 25-320 adds a data governance layer that requires ongoing catalogue maintenance and interoperability governance. In practice, these are different skill profiles: the RSSI focuses on threat detection, access control, and incident response; the data governance role requires data modelling expertise, catalogue management, and legal alignment. Agencies that assign both responsibilities to the same officer typically see the security function crowd out the governance function. Nominating a distinct data governance coordinator — even a junior analyst with appropriate training — creates the organizational accountability the decree’s cataloguing and interoperability obligations require.

4. Build Interoperability on the National Digital Infrastructure, Not Point-to-Point Links

The decree’s interoperability pillar is best implemented through Algeria’s emerging national digital infrastructure — the e-government API platform the Ministry of Digital Transformation has been developing as part of the broader Algeria Digitale 2030 strategy. Building bilateral point-to-point integrations between agencies (Ministry A’s system directly connecting to Ministry B’s system) is technically feasible but creates a web of unmaintainable dependencies. The national API platform provides a governed exchange layer where both the data request and the data response are logged, access-controlled, and traceable — precisely the audit trail the decree envisions. Agencies should engage the Ministry of Digital Transformation’s integration team early to position their data assets for national platform onboarding rather than reinventing bilateral plumbing.

Where This Fits in Algeria’s 2025-2026 Governance Stack

Decree 25-320 is the third major instrument in a governance stack that has taken shape rapidly since 2023. The ANPDP (National Data Protection Authority), established in August 2023, provides the regulatory oversight body. Law No. 25-11 of July 2025, which amended the foundational personal data law (Law No. 18-07), added GDPR-aligned accountability requirements including data protection impact assessments, detailed processing records, and formal data protection officer roles for high-risk processing. DataGuidance’s Algeria jurisdiction page notes that these 2025 amendments brought Algeria’s privacy framework substantially in line with international standards, raising the compliance bar across both public and private sector actors. Decree 25-320 now provides the data management infrastructure layer that makes compliance with those obligations operationally achievable.

For public sector IT teams, the practical implication is that compliance is not three separate projects. Classification under Decree 25-320 feeds directly into the processing records required by Law No. 25-11. The data catalogue provides the inventory against which the ANPDP can conduct audits. The secure interoperability channels operationalize the access controls that cybersecurity Decree No. 20-05 mandates. The organizations that build their compliance program as a unified stack — rather than siloed responses to each decree — will be the ones that pass regulatory review without last-minute remediation.

Frequently Asked Questions

Sources & Further Reading

• CMS Expert Guide: Data Protection and Cybersecurity Laws — Algeria — CMS Law
• DLA Piper Data Protection: Algeria — DLA Piper
• Digital Policy Alert: Algeria Digital Digest — Digital Policy Alert
• DataGuidance: Algeria — DataGuidance