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Prague, seat of the EU rep appointed under Article 27 GDPR

REP27 · Article 27 · EU rep

EU rep · GDPR rep · Article 27 representative

EU rep: one role, five names, and a lot of confusion.

EU rep, GDPR rep, EU representative, data protection representative, article 27 rep. They all describe the same statutory role, and the abbreviation is doing real damage because it makes the thing sound smaller than it is. An EU rep is a written mandate that puts a named company inside the Union on the receiving end of your regulatory correspondence. This page defines it, lists what it is not, and says plainly who needs one.

EU repGDPR repArticle 27Written mandateAll 27 statesFrom €290

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What it is, and the five things it is not

What an EU rep is under Article 27 and what it is commonly mistaken for
What an EU rep is under Article 27 and what it is commonly mistaken for

The right-hand column is where the money is wasted. Companies buy a law firm retainer expecting a designation, or buy a designation expecting legal advice, and discover the difference during an incident.

Who needs one

Which companies need an EU rep and the only genuine exemption
Which companies need an EU rep and the only genuine exemption
The shortest version: if you sell to or track people in the Union and have no real establishment there, you need one, whatever your size.

The names, and what they actually refer to

Term you searchedWhat it meansCorrect?
EU repArticle 27 representativeInformal but right
GDPR repThe same thingRight
Data protection representativeUsually the same thing, sometimes a DPOAmbiguous, ask which
EU authorised representativeProduct legislation, not the GDPRDifferent regime entirely
Legal representativeCompany law: who signs for the companyUnrelated to data
UK repThe UK GDPR equivalentA separate appointment

What the role does, day to day

  1. Receives

    Letters and emails from supervisory authorities and from data subjects, at an address published in your privacy notice.

  2. Logs

    Every request with a date and a reference, which is what turns a chaotic exchange into a defensible file.

  3. Holds the record

    The Article 30 record of processing activities, produced to authorities on request rather than assembled afterwards.

  4. Forwards

    To you, the same working day. The substantive decision on any request remains yours as controller.

  5. Cooperates

    Article 31: answering procedural questions promptly, which is what prevents an escalation about process rather than substance.

What to check before you buy one

Who signs

Ask for the legal entity and its registration number, and check it in the national register. Ours is Europe Services, SE, IČO 03571785, Prague.

Can it be verified

A certificate with a code checkable on a public page. A PDF proves only that a PDF exists.

Which languages

A data subject writes in their own. An English-only desk turns a request into a complaint about accessibility.

Renewal price

Ask it before the first invoice. Ours drops to €240; several providers move the other way.

What the mandate actually says

Clients ask what they are signing. The designation is short, and every clause exists for a reason.

ClauseWhat it does
Identification of the controllerNames your legal entity, its registration and its address outside the Union
Identification of the representativeEurope Services, SE, IČO 03571785, Prague, established in the Union
Scope of the mandateArticle 27 tasks: contact point, record keeping, cooperation with authorities
Duration and renewalTwelve months, renewable, with termination on notice from either side
Publication undertakingYou agree to publish the identity of the representative under Article 13(1)(a)
What is excludedLegal advice, DPO duties, decisions on requests, liability transfer
Read the last row before you compare prices. Providers charging several times more are usually selling advisory services bundled around the same one-page designation.

The lifecycle of an EU rep

Day one

Form completed, mandate countersigned within 24 hours, certificate issued with a verification code.

Week one

Privacy notice updated, the record of processing activities completed with our template and stored.

During the year

Requests arrive, are logged and forwarded the same working day; you answer the substance.

Renewal

One invoice at the lower renewal price, one expiry date, no gap in coverage.

If you change provider

New designation signed first, notice updated the same day, old one terminated after. Never the other way round.

If you open an EU office

You may no longer need it. We terminate rather than renew something you have outgrown.

What you receive, item by item

A designation is a short document, so the honest way to compare providers is to look at what arrives with it. This is our list, and anything not on it we do not claim to do.

ItemWhat it isWhy it matters
Signed designationThe mandate, countersigned by Europe Services, SEThe document an authority asks for first
Certificate with a codeCheckable on a public pageClients and auditors verify it without contacting you
Privacy notice paragraphArticle 13(1)(a) wording, translatedAn unpublished designation protects nobody
Article 30 template and storageThe record of processing activitiesProduced on request rather than written afterwards
Request desk in eight languagesLogged, answered, forwarded same working dayA German user writing in German gets German back
Renewal at a lower price€240 instead of €290The relationship is worth more to us than the first invoice

Questions worth asking any provider

Which legal entity signs?

Ask for the name and registration number, then check it in the national register. If the answer is a brand rather than a company, stop.

How long has it existed?

A representative that disappears mid-year leaves you with a published contact point that no longer answers.

What happens on day one of a complaint?

Ask for the process in writing: who logs it, in what language, within how many hours you hear about it.

Is liability transferred?

The only correct answer is no. Article 27(5) settles it, and a provider claiming otherwise is describing something the law does not permit.

What is excluded?

A provider that cannot tell you plainly what is outside the scope has not thought about the scope.

What does year two cost?

Ask before signing. Renewal is where the real price of a cheap first year shows up.

Three things that void a designation in practice

A designation is not void because a lawyer disapproves of it. It stops working for three concrete reasons, all of them avoidable.

  1. It was never published

    Article 13(1)(a) requires the identity of the representative to be given to data subjects. A designation sitting in a folder is invisible to the person the regulation was written for.

  2. The address does not answer

    A representative that does not respond within a reasonable time is treated as no contact point at all, and the failure is attributed to you.

  3. The provider disappeared

    Small providers wind up, and the published address goes dead without anyone telling the controller. Check that the entity behind your certificate still exists in the national register.

  4. The facts changed

    You opened an EU office, or you stopped selling into the Union. Either way the designation should be terminated deliberately rather than left to renew.

The short version

An EU rep is a company inside the Union that has signed a mandate to receive your regulatory correspondence, hold your record of processing activities and answer when an authority or a user writes. It does not advise you, does not decide anything for you and does not absorb your liability. It costs €290 a year, takes 24 hours to put in place, and its entire value shows up on one day: the day a letter arrives with your name on it and somebody in Europe has to answer it properly.

If you take one thing from this page, make it the difference between having bought a designation and being able to show one. The first is a receipt. The second is a signed mandate, a published paragraph in your privacy notice, a certificate anyone can verify and a record produced within days rather than written afterwards.

Signing the mandate that creates an EU rep under Article 27
Signing the mandate that creates an EU rep under Article 27
Company reviewing what an EU rep does and does not cover

Questions we are actually asked

Is an EU rep the same as a GDPR rep?

Yes. Both refer to the representative designated under Article 27 GDPR. The short forms are informal, the role is statutory.

Is it the same as an EU authorised representative?

No. That term belongs to product legislation, where an authorised representative acts for a manufacturer. Different regulation, different duties.

Can our DPO be our EU rep?

Only if the DPO is a company established in the Union willing to sign the designation and hold the record. In practice the roles are held separately.

Does the EU rep make decisions for us?

No. It receives, logs and forwards. You remain the controller and you answer the substance.

Does it protect us from fines?

No. Article 27(5) expressly preserves proceedings against the controller or processor.

Do we need one in every Member State?

No. One designation covers the Union and, through the EEA Agreement, Iceland, Norway and Liechtenstein.

What about the United Kingdom?

A separate representative established in the UK, under the UK GDPR. Ours is REP27 LTD, company number 17385889.

Can an individual act as EU rep?

Legally a natural or legal person established in the Union can. In practice authorities and enterprise buyers expect a company with a verifiable registration.

How is it published?

In your privacy notice, under Article 13(1)(a), with the identity and contact details.

What happens if we ignore this?

Article 83(4)(a): up to €10 million or 2% of worldwide turnover, and in practice it is discovered while an authority investigates something else.

Do processors need an EU rep?

Yes, whenever Article 3(2) reaches them, on the same terms as controllers.

How fast is it?

Signed within 24 hours of a completed form, with the privacy notice wording ready to paste.

Can we switch provider?

Yes, at the switch price. The new designation is signed, the notice updated the same day, the old one terminated afterwards.

Is a virtual office enough?

Not for us and not for an authority. The representative must be an entity that accepts the role and answers, not an address that forwards post.

Does it cover product safety?

No. That is the Article 16 GPSR responsible person, a separate appointment we also provide.

What is included in the price?

The designation, the certificate, the privacy notice wording, the Article 30 record and a request desk in eight languages.

Related: when the requirement applies · the terminology explained

An EU rep you can name today

Europe Services, SE in Prague, active since 2018, signed within 24 hours with a certificate anyone can verify and a desk that answers in eight languages.

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