Does the article 27 obligation apply to you?

Article 27 obligation

There might be an obligation to appoint a EU representative for your organisation


If your organisation is not stated within the EU, and delivers services to EU citizens, by which you process personal data, the obligation to appoint a representative within the EU might apply to you. The GDPR states:


GDPR Article 27 – Representatives of controllers or processors not established in the Union


  1. Where Article 3(2) applies, the controller or the processor shall designate in writing a representative in the Union.

  2. The obligation laid down in paragraph 1 of this Article shall not apply to:
    (a) processing which is occasional, does not include, on a large scale, processing of special categories of data as referred to in Article 9(1) or processing of personal data relating to criminal convictions and offences referred to in Article 10, and is unlikely to result in a risk to the rights and freedoms of natural persons, taking into account the nature, context, scope and purposes of the processing; or
    (b) a public authority or body.

  3. The representative shall be established in one of the Member States where the data subjects, whose personal data are processed in relation to the offering of goods or services to them, or whose behaviour is monitored, are.

  4. The representative shall be mandated by the controller or processor to be addressed in addition to or instead of the controller or the processor by, in particular, supervisory authorities and data subjects, on all issues related to processing, for the purposes of ensuring compliance with this Regulation.

  5. The designation of a representative by the controller or processor shall be without prejudice to legal actions which could be initiated against the controller or the processor themselves.


By reading several documents below you can check and judge if the specific situation of your organisation will or will not make the obligation apply to you.


Title: All your art. 27 questions answered


Source: European Data Protection Board (EDPB)
Title: Chapter 4 of Guidelines on the territorial scope of the GDPR


Source: ICO UK
Title: European-representatives