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.
Selling subscriptions to EU users can be relevant to the territorial-scope assessment. The answer depends on the service, target market and processing.
What should you do next?
If you are unsure whether Article 27 applies to your organisation, use the EURepNow eligibility assessment before purchasing representation.
Primary legal reference: Regulation (EU) 2016/679 — Articles 3 and 27. Official text.