DSA Legal Representative under Article 13
Providers of intermediary services that have no establishment in the European Union but offer their services in the Union must designate a legal representative — in writing, in one of the Member States where they operate (Article 13(1) DSA). Regingada UG (haftungsbeschränkt) takes on that named role under its own representation contract: service of documents, authority routing and documentation — not legal advice.
Digital Services Act representative service for non-EU hosting providers, online platforms, marketplaces and search engines.
Software & appointed EU representation: Regingada UG (haftungsbeschränkt) · Legal advice exclusively: Kanzlei Theo Funk — separate mandate
Who must appoint a DSA legal representative
Article 13(1) of Regulation (EU) 2022/2065 (Digital Services Act — DSA) addresses providers of intermediary services: mere conduit, caching and hosting services — including online platforms such as marketplaces and social networks, and online search engines (Article 3(g) DSA). The duty applies where such a provider has no establishment in the European Union but offers its services in the Union.
Whether services are “offered in the Union” turns on a substantial connection to the Union (Article 3(d) and (e) DSA) — for example a significant number of recipients of the service in one or more Member States in relation to their population, or the targeting of activities towards one or more Member States.
If both apply to you — no EU establishment, services offered in the Union — Article 13(1) DSA requires you to designate, in writing, a legal or natural person as your legal representative in one of the Member States where you offer your services.
What the legal representative does
The legal representative is your named addressee in the Union. Member States’ authorities, the European Commission and the European Board for Digital Services address the representative “on all issues necessary for the receipt of, compliance with and enforcement of decisions issued in relation to this Regulation” (Article 13(2) DSA). You must provide the representative with the necessary powers and sufficient resources to guarantee efficient and timely cooperation with those authorities (Article 13(2), second sentence, DSA).
- Named EU point of contact — receipt and service of official documents and authority correspondence
- Authority routing — documented, timely forwarding to the people you designate, with a defined escalation path
- Documentation — an audit trail of what arrived, when, and what happened next
Under Article 13(3), the legal representative can be held liable for non-compliance with obligations under the DSA — without prejudice to the liability of the provider itself. That is why our representation contract defines duties, information flows and escalation paths precisely.
The representative’s contact details are notified to the Digital Services Coordinator in the Member State where the representative resides or is established (Article 13(4) DSA).
How the appointment works
Three steps take you from scoping to a notified and documented representative function.
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Scoping
A guided question set — the same wizard you can start on this page — records your establishment, your services and your EU nexus.
Deliverablea structured self-assessment record of your Article 13 status — not a legal determination; for that, the law firm advises under a separate mandate.
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Representation contract
We prepare the representation contract that names the role and its limits: tasks, information channels, escalation paths, response times.
Deliverablea draft representation contract naming role, duties and information flows — model terms on request.
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Notification & handover
We assemble the notification to the competent Digital Services Coordinator and put the operational contact channel in place.
Deliverablea notification package for the competent Digital Services Coordinator (Article 13(4) DSA) plus a documented contact channel.
A named EU role, held by a registered German company.
“The representative role is operational: documents arrive, deadlines run, someone must receive, route and document — reliably. Regingada holds that named role under its own contract. Legal judgment stays with my firm, under a separate mandate.”
Regingada UG (haftungsbeschränkt), HRB 12595, AG Bamberg
Appointed EU representative & software: Regingada UG (haftungsbeschränkt) — wholly owned by German attorney Theo Funk, no legal advice · Legal advice: independent law firm Kanzlei Theo Funk (RAK Bamberg) — separate mandate.
EU data discipline → Trust Center · security.txt (RFC 9116)
The same regulatory corpus powers the Regingada Compliance Suite — digital-twin software that maps the DSA alongside the GDPR, the AI Act, the DMA and NIS2.
From the Regingada Radar — we track what we represent
What determines the cost
The engagement is priced by what the role actually has to carry: the scope of your services, the expected volume of authority contacts, your documentation and reporting needs, whether the role is combined with Article 27 GDPR, AI Act or NIS2 representation (multi-regime setups reduce coordination overhead), and the response times we commit to.
Engagement terms on request.
Frequently asked questions
Who must appoint a DSA legal representative under Article 13?
Providers of intermediary services — mere conduit, caching and hosting services, including online platforms and online search engines (Article 3(g) DSA) — that have no establishment in the European Union but offer their services in the Union. Whether services are offered in the Union turns on a substantial connection to the Union (Article 3(d) and (e) DSA), such as a significant number of recipients in one or more Member States or the targeting of activities towards one or more Member States.
Can the legal representative be held liable?
Yes, within limits the DSA itself draws: under Article 13(3) DSA, the designated legal representative can be held liable for non-compliance with obligations under the DSA — without prejudice to the liability of the provider itself. That is why our representation contract defines duties, information flows and escalation paths precisely.
DSA Article 13 vs GDPR Article 27 — can one provider cover both?
They are different roles under different regulations: Article 13 DSA addresses providers of intermediary services; Article 27 of Regulation (EU) 2016/679 (GDPR) addresses controllers and processors. Both roles can sit with one provider — each requires its own designation. See our GDPR Article 27 representative service.
In which Member State must the representative be located?
In one of the Member States where you offer your services (Article 13(1) DSA). Regingada UG (haftungsbeschränkt) is established in Bamberg, Germany.
What happens after the appointment?
The name, postal address, e-mail address and telephone number of your legal representative are notified to the Digital Services Coordinator in the Member State where the representative resides or is established (Article 13(4) DSA). From then on the role is operational: ongoing reachability, receipt of authority correspondence, and documented forwarding to you.
Does designating a representative create an EU establishment?
Article 13(5) makes clear that the designation does not in itself constitute an establishment in the Union. Questions of tax law are outside our role — please consult your own tax adviser.
Is this legal advice?
Regingada UG (haftungsbeschränkt) is the software and EU-representation company, wholly owned by attorney Theo Funk. It does not provide legal advice. For legal advice under a separate mandate, please see the independent law firm Kanzlei Theo Funk.
What does it cost?
The engagement depends on the scope of your services, the expected volume of authority contacts, documentation and reporting needs, whether the role is combined with Article 27 GDPR, AI Act or NIS2 representation (multi-regime setups reduce coordination overhead), and agreed response times. Engagement terms on request.
Appoint your Article 13 legal representative.
Start with the scoping check — it records your Article 13 status and leads straight into the representation request.
Legal advice on representative obligations — Kanzlei Theo Funk (separate mandate)