Does My Company Need a UK Representative if We Only Have EU Customers?

Yes, if your company is based in the UK, has no presence in the EEA, and serves or tracks individuals in the EU, you will need to appoint an EU representative.

If you target EU-based individuals with goods or services, or you monitor their behaviour online, you are required to comply with the EU GDPR for that activity. Because you do not have an establishment inside the EEA, the law requires you to appoint a representative located in an EU or EEA country where at least some of those individuals are based.

This representative acts as your point of contact for EU regulators and data subjects and must be formally authorised in writing. They can be an individual or an organisation such as a consultancy, law firm, or specialist compliance provider. Their details must be clearly communicated to affected individuals, typically through your privacy notice, and made easily accessible to supervisory authorities, for example, on your website.

Appointing a representative does not reduce your own GDPR responsibilities or liabilities. The only exceptions are for UK organisations that are public authorities, or whose EU-related processing is genuinely occasional, low-risk, and does not involve large-scale use of special category or criminal-offence data.