When is an EU representative required under Art. 27 GDPR?

Written by Aylin Stadtsholte on 9. September 2025.

A non-European organisation requires an EU representative in accordance with Art. 27 GDPR if it does not have a branch within the EU but nevertheless:

offers goods or services to persons in the EU, whether for payment or free of charge,
or observes the behavior of persons within the EU—in particular through measures such as tracking, profiling, or web analysis.

In these cases, the market location principle applies, which means that the organisation falls within the scope of the GDPR.

Note: This information is for general guidance only and does not constitute individual legal advice.