EU Article 27
Representative
An EU-established representative for non-EU companies that need a local GDPR contact point for supervisory authorities and individuals under Article 27.
Your local GDPR anchor in the European Union
If your company is not established in the EU but falls within Article 3(2) GDPR, you generally need an EU representative under Article 27.
Our representative service gives regulators and data subjects a reliable EU contact point while keeping your internal team focused on operations, seamlessly integrating into your Privacy Governance Framework.
Why Article 27 matters
Without a representative, non-EU organisations can struggle to respond to supervisory enquiries and data-subject requests in a credible, timely way. Article 27 closes that enforcement gap and forms a critical foundation for a compliant GDPR Compliance Program.
The Strategic Imperative of Article 27
The extraterritorial scope of the General Data Protection Regulation (GDPR) profoundly altered the landscape of global digital commerce. Prior to the GDPR, entities without a physical establishment in the European Union largely operated outside the direct purview of European data protection authorities. The introduction of Article 3(2) GDPR fundamentally shifted this paradigm, extending European legal jurisdiction to non-EU controllers and processors.
However, jurisdiction without enforceability is practically void. To bridge this enforcement gap, the European legislator mandated Article 27 GDPR, requiring entities falling under Article 3(2) to designate in writing a data protection officer within the Union. This data protection officer acts as the localized anchor for regulatory oversight and data subject interaction.
Consequences of Non-Compliance
The failure to appoint an EU Data Protection Officer is an administrative infringement categorized under Article 83(4)(a) of the GDPR. Specifically, non-compliance with the obligations of the controller and the processor pursuant to Articles 8, 11, 25 to 39, and 42 to 43 subjects an organization to administrative fines up to €10,000,000, or in the case of an undertaking, up to 2% of the total worldwide annual turnover of the preceding financial year, whichever is higher.
Beyond immediate financial penalties, the absence of an EU Data Protection Officer signals to supervisory authorities a systemic disregard for European privacy legislation. This often triggers more invasive audits, leading to the discovery of supplementary non-compliances (such as inadequate RoPA under Article 30, defective consent mechanisms under Article 7, or unlawful International Data Transfers).
Our Senior Legal Approach
At The Data Protection Officers, our approach transcends mere "postbox" data protection officer service. As senior European lawyers deeply integrated into the mechanics of EU law, we provide an active, defensive shield for your enterprise.
- Regulatory Liaison: We actively interface with Data Protection Authorities (DPAs) in their native languages and legal terminologies, diffusing regulatory friction before it escalates.
- Data Subject Requests (DSR): We establish secure, branded portals for EU citizens to submit their requests. We legally filter these requests, distinguish valid claims from unfounded ones, and guide your internal team on the precise execution.
- Article 30 RoPA Maintenance: According to Article 27(3), the data protection officer must maintain a copy of the Records of Processing Activities (RoPA). We audit and securely harbor your EU-facing data inventory, ready for immediate disclosure upon DPA request.
- Breach Notification Facilitation: In the critical 72-hour window following a data breach (Article 33), our rapid-response legal desk coordinates with the appropriate Lead Supervisory Authority on your behalf, supported by our comprehensive Data Breach Management protocols.
Exemptions: Who Does NOT Need a Data Protection Officer?
Article 27(2) provides narrow exemptions. An entity is relieved from the obligation to appoint a data protection officer only if the processing:
- Is occasional, does not include, on a large scale, processing of special categories of data as referred to in Article 9(1) or processing of personal data relating to criminal convictions and offences referred to in Article 10, and is unlikely to result in a risk to the rights and freedoms of natural persons; OR
- Is carried out by a public authority or body.
The European Data Protection Board (EDPB) interprets "occasional" strictly. Any routine, automated, or systematic processing directed at the EU market inherently nullifies this exemption.
Interaction with Other Frameworks (AI Act & Digital Services Act)
As the European Union expands its digital regulatory perimeter, the role of the EU Data Protection Officer is becoming an anchor point for multifaceted compliance. Under the newly enacted EU AI Act (Regulation (EU) 2024/1689), providers of high-risk AI systems established in third countries must also appoint an authorized data protection officer in the Union (Article 22 AI Act).
By choosing a legal partner proficient in the broader European Acquis, organizations can strategically consolidate their data protection officer service obligations, ensuring harmonious compliance across GDPR, AI Act, and DSA mandates.
Statutory Framework: GDPR Articles 3 & 27
GDPR Article 27
- Article 3(2): Territorial Scope
"This Regulation applies to the processing of personal data of data subjects who are in the Union by a controller or processor not established in the Union, where the processing activities are related to: (a) the offering of goods or services, irrespective of whether a payment of the data subject is required, to such data subjects in the Union; or (b) the monitoring of their behaviour as far as their behaviour takes place within the Union." - Article 27(1): Data Protection Officers of controllers or processors not established in the Union
"Where Article 3(2) applies, the controller or the processor shall designate in writing a data protection officer in the Union." - Article 27(4): Mandate and Liability
"The data protection officer shall be mandated by the controller or processor to be addressed in addition to or instead of the controller or the processor by, in particular, supervisory authorities and data subjects, on all issues related to processing, for the purposes of ensuring compliance with this Regulation."
How the service works
We establish your Article 27 representation in four steps:
Eligibility review
We confirm whether Article 27 applies and which member state is most appropriate.
Formal designation
We document the representative appointment and publish contact details.
Notice support
We provide wording for privacy notices and related disclosures.
Request handling
We act as the contact point for authorities and individuals.
Selling into the EU without an establishment?
Appoint an Article 27 representative and give regulators a proper local contact point.
View representative pricingProduct snapshot
| Role | Representative |
| Regulation | GDPR Article 27 |
| Supervisory authority | EU data protection authorities |
| Setup fee | None |
| Pricing | Tiered monthly plans on the order page |
Frequently Asked Questions
Common questions about EU Article 27 representation.
Who needs an Article 27 representative?
Typically non-EU organisations that process personal data of individuals in the EU in connection with offering goods or services or monitoring behaviour.
Is a representative the same as a DPO?
No. A representative is a local contact under Article 27. A DPO is an independent compliance oversight role under Article 37.
Can we use one representative for the whole EU?
In many cases yes, provided the representative is established in a member state where relevant data subjects are located.
What happens if we do not appoint an EU representative?
Failure to appoint an EU representative when required is a direct violation of the GDPR. This can result in administrative fines of up to €10 million or 2% of the total worldwide annual turnover of the preceding financial year, whichever is higher. Supervisory authorities have increasingly penalized companies exclusively for failing to meet this obligation.
Can any employee or entity act as our EU representative?
The EU representative must be established in one of the Member States where the data subjects whose personal data are processed in relation to the offering of goods or services, or whose behavior is monitored, are located. They must possess sufficient knowledge of the GDPR to facilitate communication between you, the data subjects, and the supervisory authorities. Relying on an unqualified entity increases liability.
How does The Data Protection Officers handle data subject requests?
As your appointed EU representative, we serve as the primary contact point. When a data subject submits a request (e.g., right to access, right to be forgotten), we log the request, verify identity, immediately notify your internal legal/compliance team, and guide you through the mandatory response timeline (typically one month) ensuring strict adherence to European legal standards.
Appoint your EU Article 27 representative
Give EU regulators and individuals a proper local contact under GDPR Article 27.
Select representative pricingDisclaimer: This content is for informational purposes only and does not constitute legal advice or create a solicitor-client relationship. Data protection regulations are subject to change and specific application depends on the context of your processing activities. Please consult directly with our legal team for advice tailored to your organization.