REP27Brexit did not remove the EU representative obligation. It duplicated it, and that is the part most companies discover from a customer rather than from a lawyer.
A company appoints an EU representative under Article 27 of the GDPR, files the paperwork, publishes the name, and considers the matter closed. Then a client in London asks for the UK one. Same sentence, different country, different law — and the first designation covers none of it.
Here is why. Article 27 of the EU GDPR makes the representative the contact point for 27 supervisory authorities, one in each member state. The UK GDPR has its own Article 27, and it answers to a single regulator, the Information Commissioner's Office. A representative established in a member state has no standing before the ICO, and a UK representative has none before the European authorities. Selling into both markets means two designations, two certificates and two verification codes: two separate obligations, not one with wider coverage.
The honest half of the answer, before anyone buys anything.
If a company of your group is already established in a member state, it can take the role itself and there is no need for an EU representative at all: Article 27 binds only controllers not established in the Union.
If you have no customers and no tracking aimed at people in Britain, you do not need a UK representative, whatever anyone sells you.
If the processing is occasional, low risk and involves no special categories of data, Article 27(2) exempts you entirely.
When the designation is genuinely required and missing, it is the easiest breach to see from outside, because Articles 13 and 14 require the name and address to be published in the privacy notice. Anyone who opens the page can see it is absent. Under the EU GDPR the exposure is 10 million euro or 2% of worldwide turnover under Article 83(4)(a); under the UK GDPR it is 8.7 million pounds or 2%, the ICO standard maximum.
One order, one renewal date. European Union from 290 € a year, the United Kingdom added for 100 € more. Signed in 24 hours, no fee per request, companies and private individuals.
Free check of your privacy notice first, no account and no card: https://gdprrepresentative.com
The brand and the three companies: https://rep27.com
Responsible person GPSR and authorised representative 2019/1020: https://eulabelcompliance.com
Accessibility statement (EAA): https://accessibilitystatement.org
