Alternatives to Getting EU and UK GDPR Representatives from the Same Provider

• Article 27 GDPR/UK GDPR requires non-EU/UK companies to appoint local representatives.
• REP27 issues both designations in one order, with one renewal date.
• Alternatives include Janus Compliance, Euverify, and Gabsor (see table).
• Separate providers mean more admin, higher costs, and risk of lapsed coverage.
• Combined services typically cost less and reduce compliance errors.

Updated 17 October 2026 · 6 sources checked

Providers compared

Prices as published on each provider's website on 17 October 2026, excluding VAT unless stated. Each row links to its source.

What the Law Requires: Article 27 GDPR & UK GDPR

Article 27 of the EU GDPR and UK GDPR imposes a clear obligation: any company not established in the EU or UK, but offering goods or services to individuals in those territories or monitoring their behavior, must appoint a local representative. The representative must be established in the relevant territory (EU or UK) and is responsible for acting as a contact point for data subjects and supervisory authorities. This is not optional—failure to comply is a standalone infringement and can result in significant fines (up to €10 million or 2% of global turnover, whichever is higher, per GDPR Article 83).

• Separate obligations: Since Brexit, the EU and UK have distinct GDPR regimes. A single representative cannot cover both unless they have legal establishments in both territories. Most providers only cover one side and refer you elsewhere for the other.
• Who must appoint? Any non-EU/UK entity targeting customers, running analytics, or offering services in those regions. This includes SaaS, e-commerce, and marketplace sellers.
• Who is exempt? Public authorities, purely personal or household activities, and companies with a real establishment (not just a mailbox) in both territories.
• What is required? Written designation, public contact details, record of processing activities, and cooperation with authorities. The representative does not replace the DPO or provide legal advice unless specifically contracted.

For more on the legal text, see GDPR Article 27.

How to Choose: Combined vs Separate Providers

Choosing between a combined provider and separate providers for EU and UK GDPR representation depends on your business model, target markets, and appetite for administrative complexity. Here’s how the options compare:

• Combined provider (e.g., REP27): One onboarding process, one invoice, one renewal date, and consistent privacy notice wording. Both designations are issued simultaneously, reducing the risk of gaps or inconsistencies. This is especially useful for companies selling into both the EU and UK, or those with limited compliance resources.
• Separate providers: You will need to complete two onboarding processes, manage two contracts, receive two invoices, and handle two sets of privacy notice wording. This increases the risk of administrative errors, lapsed coverage (e.g., if one provider’s renewal is missed), and inconsistent compliance documentation. However, it may be suitable if you only need representation in one territory, or if you have existing relationships with local providers.

Consider these practical questions:

• Do you sell to both EU and UK customers, or just one?
• Do you want to minimize admin and compliance risk?
• Are you looking for bundled privacy tools (e.g., ROPA builder, compliance badge), or just the statutory minimum?
• Are there per-request fees or limits that could affect your costs?

For most companies targeting both markets, a combined provider is simpler and usually less expensive than appointing two separate providers.

What the Price Includes: Detailed Comparison

Not all GDPR representative services are equal. Here’s a side-by-side breakdown of what’s included, what’s not, and any extra fees for each provider. Always review the official terms before purchase.

REP27 is explicit about what is not included (no legal advice, no DPO, no compliance audits), and issues a full refund if representation is declined. Janus Compliance charges extra for high volumes of correspondence. Euverify and Gabsor offer additional privacy management tools, but published details on exclusions and extra fees are limited—always check the contract.

Hidden Costs & What Providers Usually Do Not Say

Most buyers focus on the headline price, but there are often hidden costs and exclusions that can impact your total spend and compliance risk:

• Per-request fees: Janus Compliance includes 50 items of correspondence per year, then charges £8 per additional item. REP27’s Standard and Multi plans have no per-request fees, while the Base plan limits requests to 10 per year. Euverify and Gabsor do not publish per-request fees—check their terms before signing.
• Renewal pricing: REP27 offers lower renewal prices for both territories from the second year. Some providers may increase prices at renewal or charge onboarding fees for switching.
• Scope of service: None of the providers listed offer legal advice, DPO services, or compliance audits as part of their standard representative service. If you need these, expect to pay extra or contract separately.
• Liability and exclusions: The representative’s role is limited by law. They forward requests and maintain records but are not responsible for answering on the merits or for your overall compliance. If your activities fall into excluded categories (e.g., special categories of data, services aimed at children, large-scale profiling), REP27 will not accept you and will refund in full.
• Notice periods: Not all providers specify notice periods for termination or switching. REP27 allows switching at renewal with no legal risk if the process is completed correctly.

Always read the contract and ask about renewal terms, per-request fees, and any exclusions before committing.

How Appointment Works: Step by Step

Appointing a GDPR representative—especially for both the EU and UK—follows a clear process. Here’s what to expect:

1. Assess your obligations: Confirm whether you need an EU, UK, or both representatives using the decision matrix below.
2. Choose your provider(s): Decide whether to use a combined provider (e.g., REP27) or separate ones (e.g., Janus for UK, another for EU).
3. Onboarding: Complete the provider’s onboarding form. For combined services, this is a single form covering both territories. You’ll provide company details, processing description, and contact information.
4. Review and drafting: The provider reviews your file. For combined services, both mandates are drafted from the same answers, ensuring consistency and avoiding contradictions.
5. Designation and signatures: The provider’s EU entity signs the EU designation; the UK entity signs the UK designation. Both are issued as separate documents, each with its own certificate and verification code.
6. Delivery: You receive two certificates (one for each territory), privacy notice wording for both, and verification codes. Combined providers synchronize renewal dates and approval processes.
7. Implementation: Update your privacy notice with the supplied wording and verification details. Ensure your records of processing activities are up to date and available for inspection.
8. Renewal and monitoring: Monitor renewal dates. Combined providers offer a single invoice and expiry date, reducing the risk of lapsed coverage.

Switching providers is straightforward: appoint the new provider, update your notice, and terminate the old appointment. There is no legal gap if done correctly.

Risks, Fines, and Who Needs What: Decision Matrix

Non-compliance with Article 27 can result in substantial fines and enforcement actions. The risk is not theoretical: authorities have fined companies for failing to appoint a representative. Use the following matrix to determine your obligations and avoid unnecessary costs or penalties:

Fines for non-compliance can reach up to €10 million or 2% of global turnover. The representative is not a shield: authorities can still take action directly against your company. The designation is a statutory role, not a compliance guarantee.

Buyer Checklist: Steps to Compliance

1. Map your data flows: Identify if you offer goods/services or monitor individuals in the EU, UK, or both.
2. Check Article 27 applicability: Does your activity fall under the scope (see above matrix)?
3. Decide on provider structure: Combined (easier, cheaper for both) or separate (if only one territory or for legacy reasons)?
4. Compare providers: Verify published prices, included services, and exclusions. Use the table above for reference.
5. Check for hidden fees: Look for per-request fees, onboarding charges, and renewal pricing in the contract.
6. Appoint representative(s): Complete onboarding and receive certificates and privacy notice wording.
7. Update documentation: Add representative details to your privacy notice and ensure records of processing activities are available.
8. Monitor renewals: Set reminders for renewal dates, especially if using separate providers.
9. Review annually: Reassess your obligations if your business expands or contracts in the EU or UK.

Realistic Scenarios: Which Route to Take?

• US SaaS selling to EU & UK: Needs both representatives. Simplest route: appoint REP27 for both territories (€390/year base). Receive two certificates, one onboarding, one renewal date. Update privacy notice with both lines of wording.
• Chinese Amazon seller shipping to Germany and UK: Needs both representatives. Can use a combined provider (e.g., REP27, Euverify, Gabsor) for simplicity, or appoint Janus Compliance for UK and another provider for EU. Combined route reduces admin and risk of inconsistent documentation.
• UK online shop selling only to UK: Needs only UK representative. Janus Compliance offers UK-only service for £349/year. No EU representative required if not targeting EU customers.
• EU-based SaaS with UK customers: Needs only UK representative. Can use Euverify, Gabsor, or Janus Compliance for UK coverage. No EU representative needed if established in the EU.
• Marketplace seller (Etsy, eBay) outside EU/UK: If selling to both markets, needs both representatives unless the marketplace acts as representative (rare; check marketplace policy).