The EU Digital Services Act already applies. Ensure your compliance across every intermediary service.

Your official EU legal representative under Article 13, handling communication with Member States’ competent authorities, the Commission and the Board.
Digital Services Act · Art. 13
Date of applicability
17 Feb 2024
6%
of global annual turnover, maximum penalty

A safer digital space, with one addressee for the rules that enforce it

The Digital Services Act sets the rules for intermediary services reaching users in the European Union, from illegal content and seller traceability to transparency and advertising. If you offer such a service to EU users without an establishment there, Article 13 requires a legal representative: someone who ensures effective communication with Member States’ competent authorities, the Commission and the European Board for Digital Services, on all issues necessary for the receipt of, compliance with and enforcement of decisions issued in relation to the DSA. Appointing one does not itself create an establishment in the EU.

Who has to appoint a Legal Representative

Mere conduit

Internet access providers, VPNs and DNS services.

Caching

Content delivery networks and comparable caching services.

Hosting

Web hosting and cloud storage of user-supplied content.

Online platforms

Marketplaces, social networks and app stores.

Online search engines

Services which allow users to input queries in order to perform searches on the web.

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You offer your service to users established or located in the European Union.

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You have no establishment in the EU able to act as the point of contact for authorities.

Micro and small enterprises — fewer than 250 employees and under €50 million turnover — receive partial exemptions from certain transparency and additional platform obligations. That does not automatically remove the need to appoint a representative.

A representative does not create an establishment. It creates an address the regulator can use.

Why you must act now: risks of non-compliance

DSA enforcement is shared between national Digital Services Coordinators and the Commission, and it is public — which makes the reputational exposure as real as the financial one.
6%

of global annual turnover — the maximum penalty, enforced by coordinators and the Commission.

Content

illegal content flagging, seller traceability and removal appeals must be operational.

Transparency

enhanced reporting, minor protection and crisis response protocols are expected.

Public

enforcement decisions are published, so findings travel further than the fine.

Three steps to a
compliant appointment

01

Initial consultation & assessment

We review how your intermediary service is offered in the EU and confirm exactly what representation you need.

02

Official appointment

You sign a mandate agreement and complete onboarding digitally — no paperwork back-and-forth.

03

Ongoing compliance & support

Communications and compliance decisions from authorities are received and forwarded to your team, with continuous updates as enforcement evolves.

DSA representation is delivered by EDSR, EDPO’s specialist entity

EDSR is EDPO’s Brussels-based sister company, dedicated to DSA, TCOR and e-Evidence representation. Same group, same standards — one contract, one point of contact for authorities across the EU and EEA.
Brussels & Dublin FR · NL · EN

Onboarding, pricing and the full FAQ are handled on edsr.eu.

Your questions, answered

  • $The General Data Protection Regulation (GDPR) – EU & UK
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  • $The Digital Services Act (DSA)

The Digital Services Act (DSA) is an EU regulation that, alongside with the Digital Markets Act (DMA), aims to create a safer digital space for users. This is done through rules targeting digital services that act as intermediaries, connecting consumers with goods, services, and content. These rules foster a safe, predictable and trusted online environment in which fundamental rights are protected.

Pursuant to article 13 of the DSA, the legal representative of intermediary service providers ensures effective communication with Member States’ competent authorities, the Commission and the European Board for Digital Services (the “Board”), including receiving, complying with, and enforcing decisions related to the DSA. Providers of intermediary services must equip their legal representative with the necessary powers and resources for efficient cooperation and to comply with such decisions.

While this role doesn’t create an establishment in the EU, designating a legal representative confers competence to the Member State where the representative is located. In cases where providers do not designate a legal representative, competence lies with all Member States or the Commission, as applicable.

The legal representative of intermediary service providers must be designated in writing. Intermediary service providers must provide their legal representative’s contact details to the Digital Services Coordinator in the relevant Member State, ensuring the information is public, accessible, accurate, and updated.

Full FAQ, pricing and onboarding details are on EDSR’s DSA page →

Still not sure whether you need to appoint a DSA Legal Representative?