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Does Every Non-EU Company Need a GDPR Representative?

· 1 min read

In briefThe obligation depends on who you process data about, not where you are.
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GDPR Article 27 requires non-EU companies to appoint an EU representative — but not unconditionally.

The obligation applies when your organisation, established outside the EU, processes personal data of individuals in the EU in connection with offering goods or services to them, or monitoring their behaviour within the EU (Article 3(2) GDPR).

If your only processing activity involves your own non-EU employees and you have no interaction with EU residents as data subjects, Article 27 does not apply to you.

If you sell to EU customers, run a platform accessible to EU users, or track behaviour of people located in the EU — it does apply, regardless of company size or annual revenue.

One practical check: look at your privacy notice. If it addresses EU residents, the obligation almost certainly follows.

When it does apply, the representative must be designated in writing, named publicly in your privacy notice, and accessible to both supervisory authorities and data subjects.

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