REP27Two numbers sit next to each other in this market, and the gap between them is the whole argument.
€525,000 — the fine the Dutch supervisory authority issued to Locatefamily.com for failing to designate an EU representative, with periodic penalties running until the company complied.
€290 — a year, for the designation that would have prevented it.
The second number is not a discount or an introductory rate. It is simply what the obligation costs, because Article 27 asks for one thing: a named contact point established in the Union, in writing. There is no audit to pass, no certification to maintain, no annual review.
What makes the gap unusual is not the size of the fine. It is how little work finding the breach requires.
Most GDPR infringements have to be uncovered. Someone complains, a breach is notified, an inspection is opened, documents are requested. A missing representative is different: you publish the evidence yourself. Articles 13 and 14 require the privacy notice to name the representative, so the absence of that name is visible in a browser tab, from outside, with no investigation at all. A regulator checks it the way a customer would.
Three things worth knowing before deciding it does not apply to you.
The maximum is not theoretical. Article 83(4)(a) sets €10 million or 2% of worldwide turnover, whichever is higher, for infringements of Article 27.
There is no single authority to deal with. Without an establishment in the Union you sit outside the one-stop-shop, so any of the 27 national regulators whose residents you reach can open a file independently.
And the EDPB treats the omission as a standalone infringement under Guidelines 3/2018 — not as an aggravating detail attached to something else.
Fixing it takes a form, a signature and a day. Europe Services, SE — Prague, established in the EU since 2014, IČO 03571785 — for the Union; REP27 LTD, company number 17385889, for the United Kingdom. €290 a year, €240 from the second, no fee per request.
Open your own privacy notice and search for the word "representative". That is the entire test.
gdprrepresentative.com · rep27.com
