Best Legal Representative for Online Platforms Outside the EU (DSA Article 13)

• Article 13 DSA requires non-EU platforms to appoint an EU legal representative
• REP27 — Europe Services, SE: EUR 390/year, covers all EU states where service is offered
• Competitor prices range from EUR 1,200/year to 'On request'
• REP27 notifies the Czech Digital Services Coordinator and provides a public certificate
• Fines for non-compliance can reach up to 6% of global turnover
• Not required if you only sell your own products/content or have an EU establishment

Updated 22 October 2026 · 7 sources checked

Providers compared

Prices as published on each provider's website on 22 October 2026, excluding VAT unless stated. Each row links to its source.

What Article 13 of the Digital Services Act Requires

Article 13 of Regulation (EU) 2022/2065 (Digital Services Act, DSA) creates a binding obligation for any provider of intermediary services established outside the EU but offering services within the Union. This includes online platforms, marketplaces, hosting providers, cloud storage, social networks, and more. The law requires these providers to designate a legal representative in writing, located in a Member State where their service is offered. The representative acts as the official contact for EU authorities and can be held liable for non-compliance with the DSA.

• Who must comply? Any non-EU business providing intermediary services to users in the EU. This covers a wide range of services, from SaaS platforms with user-generated content to global online marketplaces and hosting providers.
• What does the representative do? The representative must be empowered and resourced to cooperate with authorities, receive and respond to official communications, and ensure the provider’s compliance with DSA decisions. The details of the representative must be published and kept up to date on the provider’s website and notified to the Digital Services Coordinator of the Member State where the representative is based.
• What happens if you do not comply? Failure to appoint a legal representative can result in fines of up to 6% of global annual turnover, as well as enforcement actions such as service restrictions or blocks within the EU. The Digital Services Coordinator in the Member State where the representative is established is responsible for enforcement.
• What does NOT count as compliance? Appointing a DSA legal representative does not create an EU establishment for the provider. The obligation is separate from other EU compliance requirements, such as GDPR Article 27 or the GPSR responsible person for product compliance.

For the full legal text and further details, see Article 13, Digital Services Act.

How to Choose a DSA Legal Representative

Choosing the right DSA legal representative is crucial for both compliance and operational efficiency. Here are the main factors to consider:

• Location: The representative must be established in an EU Member State where your service is offered. For instance, REP27 is based in the Czech Republic and can only act if your service is available there. If you target multiple Member States, ensure your representative covers all of them.
• Scope of service: Some providers only cover one Member State, while others, like REP27, cover all Member States where your service is offered (as long as the Czech Republic is included). This distinction is important for platforms operating across the EU.
• Price transparency: Only REP27 and Engage Compliance publish clear, upfront prices. Others require a quote. Transparent pricing helps avoid unexpected costs and simplifies budgeting.
• Included services: Compare what is included in the annual fee. REP27 provides a signed designation, notification to the Czech authority, a public certificate, ready-made text for your terms, and acts as a contact point for authorities. Some competitors may charge extra for similar services or do not specify what is included.
• Cancellation and renewal: REP27 allows cancellation at any time with no notice period. Always check for hidden notice periods or renewal traps with other providers.
• Authority notification: The provider should handle notification to the relevant Digital Services Coordinator. REP27 notifies the Czech Telecommunication Office and provides you with a copy.

When comparing providers, request a full list of included services, cancellation terms, and any potential extra fees. This ensures you get the coverage you need without surprises.

What the Price Really Includes

Understanding what you get for your annual fee is essential. Providers differ in transparency and scope. Here’s a breakdown based on published data:

• REP27 — Europe Services, SE: For EUR 390/year (EUR 350 with a GDPR plan), you receive a signed DSA Article 13 designation, notification to the Czech Digital Services Coordinator, a public certificate with verification code, a public information page, ready-made text for your terms, and a contact point for authorities. There is no setup fee, and you can cancel at any time. Weekly checks ensure your compliance wording is present on your site, and you are reminded if it lapses. Communication with authorities is handled in Czech and English.
• Engage Compliance: Charges EUR 1,200/year for DSA legal representative services. The published price is verified, but details on what is included must be requested. No information about setup fees, cancellation, or included extras is published.
• MLL Legal, OSTRAI, EDPO: Prices are only available on request. Each offers DSA legal representation, with some mentioning regulatory contact infrastructure or communication with authorities, but specifics and any extra fees are not published.

Always request a detailed service description and ask about:

• Whether the fee covers all Member States where your service is offered
• Notification to authorities and public certificate issuance
• Response times for authority requests
• Any per-request or document update fees
• Cancellation and renewal terms

Transparent providers like REP27 make it easier to budget and avoid compliance gaps. Others may require negotiation or clarification before you can be sure of full coverage.

Hidden Costs and Exclusions

When appointing a DSA legal representative, it is critical to understand what is not included in the published price and where hidden costs may arise. Providers often do not advertise these details upfront.

• REP27: No setup fee, and cancellation is possible at any time with no notice period. There are no extra fees stated for standard services, such as authority notifications or certificate issuance. REP27 only acts if your service is offered in the Czech Republic; if not, you must appoint a representative in another Member State.
• Engage Compliance, MLL Legal, OSTRAI, EDPO: None of these providers publish detailed exclusions or extra fees. This means you must request specifics about per-request charges, document updates, or additional services such as acting as a contact point for authorities or providing compliance certificates.
• Scope limitations: Some representatives may only cover the Member State where they are established. If your service is offered in multiple EU countries, clarify whether you are covered in all relevant jurisdictions or only one.
• Notice periods and renewals: REP27 allows cancellation at any time, but other providers may require notice periods or have automatic renewal clauses. Always check the contract for these terms.
• Liability and authority: The extent of the representative’s liability and authority to act on your behalf may be limited in the contract. Ask for the full terms and clarify what happens if you receive a regulatory request or enforcement action.

In summary, always request a copy of the full service agreement and ask direct questions about exclusions, extra fees, and the scope of representation before signing.

How Appointment Works: Step by Step

Appointing a DSA legal representative is a structured process, but the details can vary by provider. Here is a step-by-step guide based on REP27’s published process and general best practice:

1. Determine your obligation: Confirm that your service is an intermediary service (e.g., online platform, marketplace, hosting, cloud, social network) and that you have no establishment in the EU. Use the decision matrix below for guidance.
2. Identify your target Member States: List all EU countries where your service is offered. Your representative must be established in at least one of these countries.
3. Choose a provider: Select a representative established in a relevant Member State. For example, REP27 is based in Prague and can act if your service is available in the Czech Republic.
4. Sign up and provide details: Complete the provider’s onboarding form with your company, service, and contact details. REP27 requests information about your service and the Member States where it is offered.
5. Payment: Pay the annual fee (e.g., EUR 390/year for REP27). REP27 accepts card, SEPA, or PayPal, and also offers AWS Marketplace billing.
6. Receive documentation: After review, you receive a signed designation letter, a public certificate (with QR code and verification code), and ready-made text for your terms and privacy notice. REP27 provides these in English and Czech.
7. Authority notification: The provider notifies the relevant Digital Services Coordinator (e.g., Czech Telecommunication Office for REP27) and provides you with a copy of the notification.
8. Update your website: Add the representative’s details to your terms and privacy policy as required by Article 13(4) DSA.
9. Ongoing compliance: Maintain the relationship, respond to authority requests via your representative, and renew the contract annually. REP27 checks your compliance wording weekly and reminds you if it is missing.

This process ensures you meet the DSA’s requirements and are prepared for regulatory scrutiny.

Risks and Fines for Non-Compliance

Failing to appoint a DSA legal representative exposes your business to significant risks:

• Fines: The DSA allows for fines up to 6% of your global annual turnover for non-compliance, including failure to appoint a legal representative. This is among the highest penalty rates in EU digital regulation.
• Service restrictions: The Digital Services Coordinator in the Member State where your representative should be established can order the restriction or blocking of your service in the EU. This can result in immediate loss of access to the European market.
• Regulatory investigations: Without a representative, you may be unable to respond to regulatory requests, leading to investigations, additional penalties, and reputational harm.
• Contractual consequences: Marketplaces and business partners may suspend your account or refuse to do business if you cannot demonstrate DSA compliance.
• Public exposure: The DSA requires the representative’s details to be public. If you are not listed as compliant, competitors or customers may report you to authorities.

Enforcement is handled by the Digital Services Coordinator in the Member State where your representative is located. For REP27 clients, this is the Czech Telecommunication Office. The risks of non-compliance far outweigh the annual cost of appointing a representative.

Decision Matrix: Do You Need a DSA Legal Representative?

This matrix helps clarify if your business needs a DSA legal representative. The requirement depends on your business model, location, and service type.

Always review your service model and customer base. If in doubt, consult the law or a compliance specialist.

Checklist: How to Appoint a DSA Legal Representative Today

1. Confirm your service is an intermediary service (platform, marketplace, hosting, etc.).
2. Check if you have an EU establishment. If yes, you do not need a DSA representative.
3. Identify all EU Member States where your service is offered.
4. Choose a provider established in one of those Member States (e.g., REP27 for Czech Republic).
5. Sign up, pay the annual fee, and provide required details.
6. Receive the signed designation and public certificate.
7. Update your terms and privacy policy with the representative’s details.
8. Ensure the provider notifies the relevant Digital Services Coordinator.
9. Maintain ongoing compliance: respond to authority requests, keep details up to date, and renew annually.
10. Document your compliance steps for audit purposes.

Following this checklist ensures you meet DSA Article 13 requirements efficiently and avoid regulatory pitfalls.

What Providers Usually Do Not Say

• Coverage limitations: Some representatives only cover the Member State where they are established. If your service is offered in multiple countries, you may need multiple representatives unless your provider covers all relevant states (REP27 does, if Czech Republic is included).
• Extra fees: Providers may charge for additional services such as responding to authority requests, updating certificates, or acting as a contact point. These fees are rarely published—always ask for a full fee schedule.
• Notice periods and renewals: Automatic renewals and required notice periods for cancellation can lock you into unwanted contracts. REP27 allows cancellation at any time, but always check your provider’s terms.
• Liability limits: The extent of the representative’s liability and authority to act on your behalf is often limited by contract. Request the full agreement and clarify these limits before signing.
• Public visibility: The DSA requires your representative’s details to be public. If your provider does not ensure this, you risk non-compliance.

Transparency and clear communication are essential. Always request a detailed contract and ask direct questions about coverage, fees, and responsibilities.

3 Realistic Scenarios Explained

• US SaaS with EU users: A US-based SaaS platform with no EU office but users in Germany, France, and the Czech Republic, allowing user-generated content, must appoint a DSA legal representative. REP27 can provide a signed designation, notify the Czech authority, and supply a public certificate for EUR 390/year if the service is available in the Czech Republic. The provider updates its website with REP27’s details and remains compliant.
• Chinese Amazon seller: A Chinese business selling only its own products via Amazon EU does not need a DSA legal representative. Amazon, as the platform, is the intermediary service provider and is responsible for DSA compliance, including appointing a representative. The seller should still ensure product and data compliance under other EU laws.
• UK online shop selling only own products: A UK-based online shop with no EU office, selling only its own products and not hosting user content, does not need a DSA legal representative. The shop is not an intermediary service provider. However, if it processes EU customer data, it may still need a GDPR Article 27 representative.

These scenarios show how the obligation depends on your business model and service type. Always map your service against DSA definitions before deciding.