Which Provider Can Act as Both EU and UK GDPR Representative in One Order?

• REP27 issues both EU and UK GDPR designations in one order, two entities.
• Combined price: €390/year (Base), €590 (Standard), €990 (Multi) as of Oct 2026.
• Competitors: Gabsor ($79/month), Euverify (£41/month), GDPR Gateway (£1,450/year).
• REP27 provides separate certificates, privacy notice wording, and renewal date.
• REP27 does not provide legal advice, DPO services, or compliance audits.

Updated 14 October 2026 · 8 sources checked

Providers compared

Prices as published on each provider's website on 14 October 2026, excluding VAT unless stated. Each row links to its source.

What the Law Requires: Article 27 GDPR and UK GDPR

Article 27 of the GDPR requires any organization outside the EU that offers goods or services to individuals in the EU, or monitors their behavior, to appoint a representative within the EU (GDPR Article 27). This representative must be established in one of the EU member states where the data subjects are located and be formally mandated in writing. The representative acts as a contact point for data subjects and supervisory authorities, and must be able to produce records of processing activities on request. The UK GDPR, which came into force after Brexit, mirrors these requirements for the United Kingdom. Since January 2021, the UK is no longer covered by the EU GDPR, so companies outside both the EU and UK must appoint two separate representatives: one in the EU and one in the UK. Each must be a legal entity established in the respective territory. The representative’s role is strictly defined: they forward requests and communications from authorities and individuals, but do not assume liability for the controller’s or processor’s compliance. The appointment must be documented and verifiable. Failure to appoint a representative is a standalone infringement and can result in significant fines (up to EUR 10 million or 2% of worldwide turnover under Article 83(4)(a)). Supervisory authorities have already enforced these rules, as seen in the Dutch authority’s fine against Locatefamily.com for failing to designate a representative. If your company is established in both the EU and UK with real, ongoing operations (not just a mailbox), you do not need a representative. However, if you are outside both and target or monitor individuals in both, you must appoint one for each regime.

How to Choose a Combined EU and UK GDPR Representative

Choosing the right provider for combined EU and UK GDPR representation requires careful consideration of several practical factors. First, confirm that the provider is genuinely established in both the EU and UK. Only such providers can issue valid designations for both regimes in a single process. REP27 — Europe Services, SE, for example, operates through Europe Services SE (Prague, Czech Republic) for the EU and REP27 LTD (Mildenhall, Suffolk) for the UK, allowing both certificates to be issued together. Many providers only cover one territory and refer you elsewhere for the other, resulting in duplicated onboarding, separate invoices, and inconsistent privacy notice wording. Next, compare pricing structures. REP27 offers a combined service at €390/year (Base), €590 (Standard), or €990 (Multi), with renewals discounted from the second year. Competitors like Gabsor ($79/month), Euverify (£41/month), and GDPR Gateway (£1,450/year) offer different pricing and feature bundles. Check what is included: look for signed designation letters, verifiable certificates, privacy notice wording for both regimes, and a request desk for handling communications. Consider the onboarding process: REP27 uses a single form for both territories, reviewed by a person to ensure consistency. Also, review the renewal process—having one renewal date for both designations reduces the risk of accidental lapses. Finally, assess support and transparency. Providers should clearly state what is and isn’t included (e.g., legal advice, DPO services, compliance audits are not part of REP27’s offering). If your business needs additional compliance tools, some competitors bundle extras like ROPA builders or compliance badges. Always verify that the provider’s certificates and wording meet the requirements of both the EU and UK regulators, and that their process is streamlined to avoid administrative headaches.

What the Price Really Includes

The published price for a combined EU and UK GDPR representative service can vary widely depending on the provider and the features included. REP27’s combined service includes two signed designation letters (one for the EU, one for the UK), each issued by a separate legal entity established in the relevant territory. You receive two certificates, each with a unique verification code (R27- for the EU, UK27- for the UK), and both can be publicly verified. Privacy notice wording is provided for both regimes, in multiple languages, ensuring compliance with Article 13/14 GDPR and the UK equivalent. A request desk is included for forwarding data subject and authority requests within two business days, and the Standard and Multi plans add unlimited request forwarding and Article 30 record holding. All plans renew on a single date, simplifying compliance management. In contrast, Gabsor includes a Trust Center, privacy policy snippet, badge, ROPA builder, and email support in its $79/month plan, but does not specify the legal separation of entities for EU and UK coverage. Euverify offers inbox and request tracking, badge, ROPA builder, and team management for £41/month, with the option to cover either or both territories. GDPR Gateway provides formal designation, a London/EU address, forwarding, and confirmation letters for £1,450/year. Representa offers written mandates and privacy notice naming, but pricing is on request. Always check if the price covers both territories in a single process, or if you will need to pay twice and manage two separate relationships. Also, confirm whether the provider’s certificates and privacy notice wording are accepted by both EU and UK regulators. REP27’s approach ensures strict separation of data and legal standing for each regime, reducing the risk of regulatory challenges.

Hidden Costs and Exclusions

When comparing GDPR representative providers, it is crucial to look beyond the headline price and consider potential hidden costs and exclusions. REP27’s published prices are exclusive of VAT, but customers outside the EU are not charged VAT, and EU customers with a valid VAT number are invoiced under the reverse charge mechanism. There are no extra fees per request within the plan limits (Base plan includes up to 10 forwarded requests per year; Standard and Multi plans allow unlimited requests). However, services such as legal advice, DPO services, compliance audits, and answering requests on the merits are not included—REP27’s role is strictly limited to forwarding requests and holding records as required by Article 27. Some providers may charge additional fees for onboarding, document review, or for handling requests beyond a certain threshold. Renewal pricing is another area to watch: REP27 offers discounted renewals from the second year (€320 for Base, €470 for Standard, €790 for Multi), and a special switch price for clients moving from another provider. Other providers may increase prices at renewal or charge separately for each territory, resulting in higher ongoing costs. Administrative burdens can also be a hidden cost: using two providers for EU and UK means double onboarding, two sets of documents, two privacy notice edits, and two renewal dates, increasing the risk of accidental lapses and inconsistent compliance. Some competitors bundle compliance tools (e.g., ROPA builders, badges) that may be useful for some clients but unnecessary for others. Always review the provider’s terms to ensure you understand what is—and is not—included, and factor in the time and effort required to manage the relationship over time.

How Appointment Works: Step by Step

The process for appointing a combined EU and UK GDPR representative with REP27 is designed to be straightforward and efficient, minimizing administrative burden and ensuring compliance with both regimes. Here is a step-by-step guide based on REP27’s process:

1. Single Form Submission: You complete one online form covering both territories. This form collects information about your company and your data processing activities, ensuring that the answers are consistent for both the EU and UK mandates.
2. File Review: A person at REP27 reviews your submission. Both mandates are drafted from the same answers, ensuring there are no contradictions between the two documents. This manual review helps prevent common errors, such as inconsistent privacy notice wording.
3. Separate Entity Signatures: Europe Services SE (Prague, Czech Republic) countersigns the EU designation, while REP27 LTD (Mildenhall, Suffolk) countersigns the UK designation. This ensures that each certificate is legally valid in its respective jurisdiction.
4. Certificate and Wording Delivery: You receive two signed designation letters, two certificates (each with a unique verification code), and two lines of privacy notice wording—one for the EU, one for the UK. These can be added to your website and documentation immediately.
5. Approval and Renewal: Approving one designation in REP27’s admin system automatically approves the other. Both designations renew on the same date, at a discounted rate from the second year, simplifying ongoing compliance management.

This process ensures that you have valid, verifiable representation in both the EU and UK, with all documentation and privacy notice wording tailored to each regime. Competitors may require separate onboarding processes, forms, and renewal dates for each territory, increasing the risk of errors and administrative overhead. With REP27, the entire process can typically be completed within 24 hours of submission, ensuring rapid compliance and minimal disruption to your business operations.

Risks, Fines, and Who Needs Both

Failing to appoint a GDPR representative where required is a serious compliance risk. Under Article 83(4)(a) of the GDPR, failure to designate a representative can result in fines of up to EUR 10 million or 2% of worldwide annual turnover, whichever is higher. The Dutch supervisory authority has already fined companies for non-compliance, such as the EUR 525,000 penalty against Locatefamily.com. The UK Information Commissioner’s Office (ICO) has similar enforcement powers under the UK GDPR. The risk is not limited to fines: without a representative, you may be unable to respond to data subject requests or regulatory inquiries, leading to reputational damage and further enforcement action. You need both an EU and UK representative if you are established outside both territories and offer goods or services to, or monitor the behavior of, individuals in both the EU and UK. This includes companies based in the US, India, China, Hong Kong, and other non-EU/non-UK countries selling into both markets or running analytics/ad pixels for both EU and UK visitors. If you are established in the UK but sell to the EU, you need only an EU representative; if you are established in the EU but sell to the UK, you need only a UK representative. Companies with a real, stable establishment (not just a mailbox) in both territories do not need a representative. It is important to assess your business model and customer base carefully to determine your obligations. Appointing a representative is not optional if you fall within the scope of Article 27 GDPR or the UK equivalent. The designation does not transfer liability: your company remains responsible for compliance, but the representative acts as your local point of contact for authorities and individuals.