The Short Answer: Probably Yes

If your US company serves EU customers, has EU website visitors, or processes any personal data of people in the EU — you almost certainly need an EU Representative under GDPR Article 27.

The requirement has been in effect since May 2018, and enforcement is increasing as EU supervisory authorities become more active in pursuing non-EU companies.

Common Scenarios Where Article 27 Applies

Here are the most frequent situations we see with US companies:

SaaS Companies

If your SaaS product has EU users — even on free tiers — you're likely processing their personal data and need an EU representative. This includes user account data, analytics, support tickets, and any other personal data.

E-Commerce Businesses

If you ship products to EU addresses, accept orders from EU customers, or run marketing campaigns targeting EU audiences, Article 27 applies.

Marketing and AdTech

If you track EU website visitors through analytics, retargeting pixels, or behavioral profiling, you're monitoring EU data subjects — a clear trigger for Article 27.

B2B Services

Even B2B companies need representation if they process personal data of EU-based contacts, employees of EU clients, or EU individuals within their services.

What US Companies Get Wrong

Common misconceptions we encounter:

  • "We're too small." — Article 27 is based on your processing activities, not your revenue or headcount
  • "We don't target the EU." — If your website is accessible to EU users and you process their data, that may be sufficient
  • "Our privacy policy says we don't serve EU users." — A disclaimer doesn't override factual processing activities
  • "A mailbox service is enough." — It checks a box but provides no real protection when regulators engage

The Enterprise Deal Factor

Beyond regulatory compliance, there's a practical business reason: EU enterprise buyers increasingly require GDPR evidence during procurement. Missing Article 27 representation is a visible compliance gap that can stall or kill deals.

Having a licensed attorney as your EU representative — rather than a mailbox — signals serious compliance to enterprise procurement teams.

Getting Started

The process is simple and fast:

  1. Take our free 2-minute risk assessment
  2. Review your results and recommended plan
  3. Sign up and provide basic company documentation
  4. We designate your EU representative within 24-48 hours
  5. Update your privacy policy to include our details

Plans start at €29/month (billed annually). See all pricing options.