EU Representative for US Companies
A US company with no branch or office in the European Union can still have to name someone inside the Union whom authorities and users can address. Regingada UG (haftungsbeschränkt) holds that role — GDPR, DSA, AI Act, NIS2, Data Act — from Bamberg, Germany.
Attorney-owned. One onboarding, in English. Responses within one business day, CET/CEST.
Software & appointed EU representation: Regingada UG (haftungsbeschränkt) · Legal advice exclusively: the law firm Theo Funk — separate mandate
Does a US company need an EU representative?
Not automatically — having no EU subsidiary is the starting point, not the trigger. GDPR Article 27 turns on selling to or monitoring people in the Union; DSA Article 13 on intermediary services; AI Act Article 54 on general-purpose AI models; NIS2 Article 26(3) and Data Act Article 37(11) on listed entity types — NIS2 mostly from medium-sized enterprise upwards.
Which applies, and whether an exemption fits, is a legal question — not ours. The law firm Theo Funk works through it: which EU representative duty applies to your business model.
What does Regingada take over, regime by regime?
One written mandate per regime. The table names the norm behind each role, what Regingada does under it and the fixed annual fee it starts at — GDPR Article 27, DSA Article 13, AI Act Article 54, NIS2 Article 26(3) and Data Act Article 37(11).
| Regime | What we take over | Fixed annual fee |
|---|---|---|
| GDPRArticle 27, Regulation (EU) 2016/679 | We become your address in the Union: authorities and data subjects write to us (Article 27(4)), and we hold the representative's Article 30 record. Article 27(3) limits the choice to a Member State where the affected people are. | from €490 / year |
| DSAArticle 13, Regulation (EU) 2022/2065 | We are your named legal representative, notify the German Digital Services Coordinator on your behalf (Article 13(4)) and serve as the Article 11 point of contact. | from €1,480 / year |
| AI ActArticle 54, Regulation (EU) 2024/1689 | If you provide a general-purpose AI model, we act as your authorised (US: authorized) representative: the Article 54(3) mandate tasks, documentation held ready for the AI Office, cooperation on request. | from €690 / year |
| NIS2Article 26(3), Directive (EU) 2022/2555 · § 60(3) BSIG (German BSI Act) | If your entity is on the Article 26(1)(b) list and in scope (Article 2: medium-sized enterprise upwards; DNS, TLD registries and registrars regardless of size), our German address goes into your registration with the Federal Office for Information Security (BSI, § 34 BSIG). | quoted individually |
| Data ActArticle 37(11), Regulation (EU) 2023/2854 | Authorities may address us in addition to or instead of your company; on request we show them the compliance measures you have taken (Article 37(12)). | from €1,480 / year |
Article 22 AI Act (high-risk) is not on this list yet: Regulation (EU) 2026/1744 set 2 December 2027 for Annex III, 2 August 2028 for Annex I. Quoted separately. Also available: the Data Governance Act role. Duties in detail: EU representative duties compared.
How does onboarding work?
Three steps per regime, and several regimes run through one onboarding: scoping and vetting, the written mandate, then notification and publication. The designation takes effect when the mandate is signed; from then on authority mail reaches a German address and is forwarded within one business day.
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Scoping and vetting
You describe where you are established and what you offer in the Union; we record it as a structured self-assessment and run our own vetting. An engagement can be declined.
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Written mandate
The GDPR, the DSA and the AI Act all require the designation in writing. The mandate names tasks, channels, escalation paths and response times, and is signed in English.
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Notification and publication
We file what each act requires and hand you the text to publish: the Digital Services Coordinator notification, the BSI register entry, your privacy-notice wording.
Every item is logged and forwarded to the people you name. Legal walkthrough: how to appoint an EU representative.
What does it cost?
Fixed annual fees per regime and company size, published instead of quoted: GDPR Article 27 from €490, AI Act Article 54 from €690, DSA Article 13 and Data Act Article 37(11) from €1,480 a year; each further regime cuts the combined fee by 10%, capped at 30%.
Fees are net of VAT (business customers only), payable annually in advance in euros, locked for 24 months. At the ECB reference rate of 11 September 2026 (1 EUR = 1.1592 USD), €490 is about $568. See the full price list →
The fee never covers legal assessment — what an authority letter means and how to answer it. That is a service of the law firm under a separate mandate, billed separately.
Who will you be dealing with?
Regingada UG (haftungsbeschränkt), Bamberg, Germany — HRB 12595, Amtsgericht Bamberg (local court, commercial register) — is owned by Theo Funk, a German attorney (Rechtsanwalt). It holds the appointed representative role and builds the software; it does not give legal advice. Legal assessment is a separate mandate with the law firm Theo Funk, which is bound by professional secrecy (§ 43a BRAO). Two contracts, billed separately: neither engagement requires the other, and no referral fees are paid in either direction.
Working language is English; business hours are CET/CEST (UTC+1/+2).
Last reviewed: 12 September 2026
Does appointing a representative create an EU establishment?
Not under the Digital Services Act, which says so: “The designation of a legal representative within the Union pursuant to paragraph 1 shall not constitute an establishment in the Union” (Article 13(5) DSA). It gives authorities an address inside the Union; it does not give your company one.
The GDPR has no such sentence but works the same way: under recital 80 the representative acts “on behalf” of the controller, and Article 27(5) keeps enforcement against the company untouched.
What changes is which Member State is competent: under NIS2 the one where your representative sits (Article 26(3)); under the Data Act one counterparty instead of twenty-seven (Article 37(13)).
What do US companies ask most often?
Is it “authorised representative” or “authorized representative”?
Both are correct. The AI Act is published in British spelling — “authorised representative” (Articles 22 and 54); US contracts write “authorized representative”. We use the statutory spelling in the mandate, yours in correspondence.
We already comply with US privacy laws — does that cover the GDPR?
No. US state privacy laws are separate regimes. Article 3(2) GDPR applies to a company outside the Union that offers goods or services to people in the Union or monitors their behavior there; Article 27 attaches the representative duty.
Do we need a data protection officer as well as a representative?
Different roles; neither replaces the other. The Article 27 representative is your addressee in the Union; the data protection officer under Articles 37 to 39 is an advisory function with its own triggers. Side by side: EU representative vs. data protection officer.
We are a marketplace seller, not the marketplace — are we in scope?
Article 13 DSA attaches to providers of intermediary services, so a seller listing on someone else's marketplace is normally not the addressee. The GDPR is separate: if you process personal data of people in the Union, Article 27 can apply.
We release our model under an open-source license — does Article 54 still apply?
Article 54(6) exempts general-purpose AI models released under a free and open-source license allowing access, usage, modification and distribution, whose parameters — weights, architecture, usage information — are public, unless the model presents systemic risks.
Can you also advise us on the underlying compliance questions?
Not as Regingada: the company holds representative roles and builds software, and gives no legal advice. Advice comes from the law firm Theo Funk under a separate mandate.
One German address for your EU obligations.
Tell us where your company is incorporated and what it offers into the Union; you get back the designations we can hold and what they cost.
Contact Regingada → See the price listLegal advice on representative obligations — the law firm Theo Funk (separate mandate)