EU Representative Services

EU Representative Services Under GDPR Article 27

If your company is based outside the European Union yet processes personal data of EU residents, GDPR Article 27 requires you to appoint an EU Representative to act as your point of contact with European data protection authorities. This requirement applies regardless of company size or data processing scope. An EU Representative is mandatory for GDPR compliance and is often the first step for non-EU companies establishing presence in or doing business with the European market.

Who Needs an EU Representative?

GDPR Article 27 specifies that a representative is required if:

• Your organisation is established outside the EU (headquarters in US, Asia, Australia, Africa, Latin America, or other non-EU jurisdiction)
• Your organisation processes personal data of EU residents or offers services/products to EU residents
• The processing is related to your offering of goods or services to EU data subjects or monitoring of their behaviour

Common scenarios include: a US technology company serving European customers; an Asian e-commerce platform shipping to Europe; a non-EU financial services firm accepting EU clients; a global technology platform with European user bases; or a non-EU manufacturer collecting personal data in the EU. If you meet these criteria, you need an EU Representative.

Exceptions: When You Don't Need an EU Representative

Article 27(1) provides two exceptions:

• Occasional processing: Your organisation occasionally (non-systematically) processes personal data of EU residents, and this processing doesn't require DPO appointment. This is narrow—most substantial processing doesn't qualify.
• Micro-enterprises: Your organisation employs fewer than 250 employees and processes data only incidentally to business. This exception has specific conditions and doesn't apply if your processing involves sensitive data or large-scale data collection.

If either exception applies, you don't strictly need an EU Representative. However, we still recommend formalising some relationship with an EU contact for regulatory purposes and building market credibility.

What an EU Representative Does

Your EU Representative acts as your designated agent for data protection matters in Europe. Specific responsibilities include:

• Authority engagement: Serving as your point of contact for European data protection authorities (national DPAs). If CNPD (Portuguese authority) or any EU authority investigates your processing, they contact your Representative.
• Data subject inquiries: Receiving and coordinating responses to EU data subject requests—access requests, deletion requests, objections, and other GDPR rights.
• Breach notification: Serving as a notification point for data breaches affecting EU residents and coordinating breach response with authorities.
• Compliance documentation: Maintaining processing documentation, records of assessments, and compliance evidence that authorities may request.
• Communication: Serving as translator and cultural bridge between your non-EU headquarters and European regulators who may not speak your company's primary language.

Importantly, your EU Representative does not replace your legal responsibility. They do not make ultimate compliance decisions or substitute for your organisation's own compliance efforts. Rather, they are a local contact point, liaison, and operational bridge.

Where to Appoint Your Representative

Your EU Representative must be established in an EU Member State. This means they must have a physical presence, office address, or formal establishment within the EU. You can appoint a representative in any EU country—not necessarily where you process most data or have most customers. Many non-EU companies appoint representatives in major EU hubs (Germany, Ireland, Netherlands) for practical reasons. However, Portugal is an increasingly attractive location for EU Representative services, offering good access to European markets, cost-effectiveness, and a growing professional services ecosystem.

Portugal as a Hub for EU Representatives

Portugal offers several advantages as a location for EU representation. Lisbon's growing international business presence, competitive professional services costs compared to major EU hubs, EU membership with full regulatory standing, and Portuguese government initiatives to attract international service providers make Portugal attractive. Additionally, Portugal's position as a gateway to both European and Portuguese-speaking markets (CPLP) appeals to companies with operations in both regions.

Our EU Representative Services

We provide comprehensive EU Representative services for non-EU organisations:

• Representative appointment and registration: Formal appointment as your GDPR Article 27 representative and registration with relevant authorities.
• Authority liaison: Serving as your point of contact with CNPD and other EU data protection authorities.
• Data subject request handling: Receiving and coordinating responses to access requests, deletion requests, and other data subject rights.
• Breach notification coordination: Managing breach notifications to authorities and affected individuals.
• Compliance documentation: Maintaining records of processing activities, assessments, and compliance evidence.
• Quarterly reporting: Regular reporting to your organisation on regulatory interactions, requests, and compliance status.
• Compliance advice: Guidance on GDPR requirements, data transfers, and European regulatory expectations.
• Update and maintenance: Keeping your representation current as regulations evolve and your processing activities change.

What You Still Must Do

Appointing an EU Representative does not eliminate your own obligations. You remain responsible for:

• Lawfully processing personal data according to GDPR principles
• Conducting Data Protection Impact Assessments where required
• Implementing security measures and safeguarding data
• Respecting data subject rights
• Conducting data transfer impact assessments for transfers outside the EU
• Maintaining processing records and documentation
• Cooperating with authorities in investigations

Your EU Representative helps you meet these obligations through liaison and support, but your organisation ultimately holds legal responsibility.

Implementation Timeline

Appointing an EU Representative typically takes 1-2 weeks. We verify your company details, assess your data processing to ensure GDPR Article 27 applies, formalise the representative appointment, register with relevant authorities, and prepare documentation for your privacy policy and terms of service. We provide you with formal confirmation of representation that you can share with customers, regulators, and business partners.