As a Ukrainian company that offers services or goods in the European Union (EU) or processes personal data of persons from the EU, the General Data Protection Regulation (GDPR) also applies to you. Particularly relevant: The appointment of an EU representative in accordance with Art. 27 GDPR – an obligation as soon as your company does not have a branch in the EU. Find out how you can ensure compliance as a non-EU company with a professional EU representative and gain the trust of your European partners.
What is an EU representative according to Art. 27 GDPR?
The EU representative is your official point of contact within the European Union for data protection issues. He represents Ukrainian companies that do not have an office or subsidiary within the EU, but offer goods or services in the EU or process data of EU citizens.
Legal basis:
Art. 27 GDPR obliges non-EU companies to appoint a representative if they process personal data of individuals in the EU. Typical examples are IT service providers, e-commerce shops, outsourcing agencies or SaaS providers from Ukraine.
When does your company need an EU representative?
Use the following checklist to check whether your company is affected:
- You do not have a registered office or branch in the EU.
- You offer goods or services to people in the EU (e.g. via online shops, apps or platforms).
- You monitor or analyse the behaviour of EU citizens (e.g. through tracking, web analytics or targeted marketing).
Note:
Smaller companies and start-ups from Ukraine are also often affected by this obligation!
Tasks and advantages of an EU representative
An EU representative performs important functions for your company:
- Communication with supervisory authorities: The representative is the first point of contact for enquiries and audits.
- Contact point for data subjects: EU citizens can contact the representative directly to request information or deletion of their data.
- Maintenance of the record of processing activities: The representative manages the relevant documentation vis-à-vis authorities.
- Support in implementing GDPR compliance: Professional advice helps to avoid fines and ensure that processes are legally compliant.
Your advantage:
With GDPR representation, you show your European partners that data protection and compliance are important to you – this creates trust and competitive advantages.
This is how the cooperation works
1. Initial discussion: Clarify whether your company is obliged to appoint an EU representative.
2. Conclusion of contract: Define tasks, responsibilities and information flows together.
3. Communication:** The EU representative will be named on your website and in your privacy policy.
4. Ongoing support: You will receive support with enquiries, audits and with setting up and maintaining the register of processing activities.
Further information can be found in the [Glossary](#) or on our [Data Protection Officer](#) pages.
FAQ on the EU representative for Ukrainian companies
Does every Ukrainian IT company have to appoint an EU representative?
Only if you process personal data of individuals in the EU or offer services there.
What happens if no representative is appointed?
There is a risk of heavy fines and a loss of trust from European customers and partners.
Does the obligation also apply to occasional business activities in the EU?
Yes, even one-off or sporadic offers may be sufficient.
How quickly must an EU representative be appointed?
Immediately, as soon as you fall under the requirements of the GDPR.
Is the EU representative the same as a data protection officer?
No, an EU Representative is a different role to the Data Protection Officer.
You can find more answers in our extended [FAQ section](#).
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Contact & advice
Ensure compliance with the GDPR for your company!
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[Learn more](#contact)
[More information in the glossary](#glossar)
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[More articles on data protection](#datenschutz-artikel)
[Official information from the EU Commission](https://ec.europa.eu/info/law/law-topic/data-protection_en)