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REP27 · EU and UK · Cost

Article 27 GDPR · Article 27 UK GDPR · combined

Holding both representatives, and what the second one really costs.

Since Brexit the same company can need two separate representatives: one established in the Union under Article 27 GDPR, one established in the United Kingdom under the UK GDPR. They are different statutes, different regulators and different designations — a single provider cannot merge them into one piece of paper. What a provider can do is issue both on the same day, against one invoice, expiring on the same date. This page is the arithmetic.

€390 combined Base€590 Standard€990 MultiTwo certificatesOne renewal date

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Combined EU and UK representative service: the arithmetic, without the sales framing

Two providers charge two subscriptions. That is the whole comparison, and it is worth seeing as a picture before reading the feature lists.

Annual cost of covering the EU and the United Kingdom with one provider compared with two
Annual cost of covering the EU and the United Kingdom with one provider compared with two
PlanUnion onlyUnited Kingdom onlyBoth
Base€290€290€390
Standard€490€490€590
Multi€890€890€990
Renewal, Base€240€240€320
The second territory costs €100, not a second subscription. That is the only real argument for buying them together, and it is enough on its own.

What arrives, in duplicate

Two designations means two of everything that matters, issued in one pass rather than two onboardings.

What a combined EU and UK representative appointment delivers
What a combined EU and UK representative appointment delivers
Union designation

Signed by Europe Services, SE, Na Čečeličce 425/4, Praha 5, IČO 03571785, active since 2018 and covering data subjects in all 27 Member States.

United Kingdom designation

Signed by REP27 LTD, company number 17385889, Unit 82a James Carter Road, Mildenhall, Suffolk IP28 7DE.

Strict separation

The UK certificate carries no Czech data and the EU certificate carries no British data. Each stands on its own in front of its own regulator.

One renewal

A single invoice and a single expiry date, so a designation never lapses because two suppliers renewed in different months.

Who needs both, and who is buying one too many

  1. Needs both

    A US, Indian, Chinese or Hong Kong company selling to consumers in both territories. This is the standard case and it is not optional in either.

  2. Needs the Union only

    A British company selling into the Union. It is established in the UK already, so it needs an EU representative and no UK one.

  3. Needs the United Kingdom only

    An EU-established company selling to British consumers, in the mirror image of the case above.

  4. Needs neither

    A company with a genuine establishment in both territories, carrying out real activity through stable arrangements rather than a mailbox.

Why two providers cost more than twice as much

The invoice is only the visible part. The rest shows up in the weeks around each renewal, and it is the reason companies consolidate after the first year rather than the third.

Two onboardings

The same corporate documents, signatories and processing description assembled twice, for two suppliers with different forms.

Two renewal dates

The most common cause of a lapsed designation is not refusal to pay: it is an invoice arriving in a month nobody was watching.

Two privacy notice edits

Each provider gives its own wording. Two edits a year to the same paragraph is where inconsistencies appear.

Two verification systems

A client checking your compliance has to be sent to two portals, which is exactly the moment procurement starts asking questions.

What happens at renewal, and the switch price

A designation is a continuing relationship, so the renewal price matters more than the first invoice. Ours is lower than the entry price rather than higher, and moving an existing designation from another provider is priced as a switch rather than as a new appointment.

SituationBaseStandardMulti
First year, one territory€290€490€890
First year, both territories€390€590€990
Renewal, one territory€240€390€690
Renewal, both territories€320€470€790
Coming from another provider€240€390€690
Moving provider is a document exercise, not a legal risk: the new designation is signed, the privacy notice is updated the same day, and the old one is terminated afterwards so there is never a gap.

What is not included, said plainly

A representative is a defined statutory role, and the fastest way to be disappointed by one is to expect it to be a compliance department. Here is the line we draw before you pay rather than after.

Included

The designation itself, the certificate, the privacy notice wording, the record of processing activities, and a request desk that receives and forwards everything addressed to the representative.

Not included

Writing your privacy policy, running a data protection impact assessment, negotiating your processor contracts or acting as your DPO. Those are advisory services and we do not pretend the designation covers them.

Not possible

Taking on your liability. Article 27(5) prevents it, in the Union and in the United Kingdom alike, and any provider implying otherwise is describing something the law does not allow.

Available separately

The Article 16 GPSR responsible person, for companies shipping physical consumer goods, which is a different regulation and a different designation again.

How the paired designation is issued, step by step

  1. One form

    Company details, the territories you need, and a short description of what you process and for whom. Ten minutes, not a questionnaire.

  2. Two mandates prepared

    One naming Europe Services, SE for the Union, one naming REP27 LTD for the United Kingdom, each drafted under its own law.

  3. Countersignature within 24 hours

    Both are countersigned together. Approving one of a pair approves the other, by design, so they cannot drift apart.

  4. Two certificates issued

    Each carries a verification code on a public page, so a client or an authority can confirm it without contacting you.

  5. Publication

    You paste the two supplied paragraphs into your privacy notice. That publication is what makes the designation useful to a data subject.

From completed form to two published contact points, the whole exercise is a working day. The part that takes longer is deciding, which is what this page is for.

Consultation on holding an EU and a UK representative at the same time
Consultation on holding an EU and a UK representative at the same time
Office of the UK GDPR representative REP27 LTD in Suffolk

Questions we are actually asked

Why two at all?

Because since Brexit the EU GDPR and the UK GDPR are separate instruments. Falling under both means designating in both territories; there is no single appointment that satisfies the two.

Can one entity sign both?

No, and any provider claiming otherwise is describing a group structure rather than one entity. Europe Services, SE signs for the Union; REP27 LTD signs for the United Kingdom. They are issued as a pair.

What do two separate providers cost?

Two full subscriptions, commonly around €780 a year at entry level, with two contracts and two renewal dates. The combined plan starts at €390.

Northern Ireland only. Which one?

The UK GDPR applies there, so the UK designation is the one you need. Product safety in Northern Ireland follows a different arrangement and is a separate question.

We already have an EU representative elsewhere.

Buy the UK designation alone. If you later move the EU one across, the switch price applies rather than the full one.

What happens at approval?

Approving one designation of a pair approves the other, so both certificates issue together and cannot drift apart over time.

Does the UK representative deal with the ICO?

It is the contact point for the ICO and for UK data subjects, in the same way the EU representative is for supervisory authorities in the Union.

Which entity appears in our privacy notice?

Both, each under its own heading: Europe Services, SE for data subjects in the Union and REP27 LTD for data subjects in the United Kingdom. We supply the wording for both.

Do the renewals stay linked?

Yes. The pair renews together on a single invoice, which is the main reason clients consolidate after a year of managing two suppliers.

Is the UK representative required by law or by custom?

By law. The UK GDPR carries its own Article 27, and a controller outside the United Kingdom that targets or monitors people there designates a representative established in the UK.

What if we already pay another provider until next year?

Buy the missing territory now and move the second one at renewal, at the switch price. Nothing is gained by cancelling a paid year early.

Are the certificates verifiable separately?

Yes. Each carries its own code and its own verification page, and neither page displays data belonging to the other territory.

Can we add the GPSR responsible person to the same account?

Yes, that is what the Multi plan covers: the Article 27 representative and the Article 16 responsible person on one onboarding and one renewal date.

Related: how the paired designation works · what Brexit changed

Two territories, one onboarding

Both designations signed within 24 hours of a completed form, each with its own certificate and verification code, on a single invoice and a single renewal date.

See the combined plans