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ARTICLE 27 KNOWLEDGE CENTER

EU GDPR Representative
Questions & Answers

Clear answers for US and other non-EU companies doing business with people in the European Union.

Do US companies need an EU GDPR representative?

A US company may need an EU representative when Article 3(2) GDPR applies to its processing and no Article 27(2) exception applies.

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What is an Article 27 GDPR representative?

An Article 27 representative is a person or organisation designated in writing in the EU to represent certain non-EU controllers or processors regarding GDPR obligations.

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Does GDPR apply to US companies?

Yes, GDPR can apply to a US company even when it has no office in the EU.

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Who needs an EU representative under GDPR?

Certain controllers and processors outside the EU whose processing is subject to Article 3(2) must designate an EU representative unless a specific exception applies.

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How much does an EU GDPR representative cost?

EU representative pricing varies by provider and by the complexity and risk of the organisation's processing.

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Can a US company appoint an EU GDPR representative?

Yes. A US company that falls within Article 27 can designate a representative established in an appropriate EU Member State.

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Where must my GDPR representative be located?

The representative must be established in the European Union and Article 27 links its location to Member States where relevant data subjects are located.

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What happens if I do not appoint an EU representative?

If Article 27 requires an organisation to appoint a representative, failing to do so is a GDPR compliance issue.

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Is an EU representative the same as a DPO?

No. An EU representative under Article 27 and a Data Protection Officer under Articles 37–39 are different roles.

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Do SaaS companies need an EU GDPR representative?

A non-EU SaaS company can need an EU representative when its EU-facing processing falls within Article 3(2) and no Article 27 exception applies.

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Does a US e-commerce company need an EU representative?

A US e-commerce company may need one when it intentionally offers goods or services to people in the EU and the Article 27 conditions are met.

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Does GDPR apply if I have no office in Europe?

Yes. Having no European office does not by itself put a company outside the GDPR.

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Do I need an EU representative in every EU country?

Article 27 does not require a separate representative in every EU Member State.

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Where should I publish my EU representative's details?

The representative must be identifiable to data subjects and supervisory authorities, so organisations commonly include the representative's contact details in their privacy information.

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Does a UK company need an EU GDPR representative?

A UK company can require an EU GDPR representative if its processing falls within Article 3(2) EU GDPR and no exception applies.

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Can my EU representative handle data subject requests?

The Article 27 representative must be addressable by data subjects and supervisory authorities on issues related to the represented processing.

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Does appointing an EU representative make my company GDPR compliant?

No. Appointment addresses the Article 27 representation requirement; it does not by itself make all processing GDPR compliant.

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What information does an EU GDPR representative need from my company?

The representative needs enough accurate information to perform the written mandate and fulfil relevant GDPR duties.

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How quickly can I appoint an EU GDPR representative?

A straightforward eligible organisation can complete much of the EURepNow appointment process online, but activation depends on payment, onboarding, mandate completion and geographic coverage.

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What is the difference between an EU representative and an EU establishment?

An Article 27 representative is not the same thing as the controller or processor having its own establishment in the EU.

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