Home » UK GDPR and EU GDPR – Differences and Similarities

What are the main differences between UK GDPR and EU GDPR?

The UK GDPR is largely based on the EU GDPR but adapted for the UK. The main differences are: it applies to data subjects who are in the UK, instead of EU data subjects; and the Information Commissioner’s Office (ICO) is the sole supervisory authority.

Cross-border transfers require UK-specific adequacy decisions or safeguards, especially for EU transfers.

Terminology and legal references are UK-specific, e.g., the Data Protection Act 2018, and fines are in pounds rather than euros. In essence, the UK GDPR mirrors EU GDPR rules but operates independently under UK law.

On 19 June 2025, the Data (Use and Access) Act (DUAA) became law in the UK, marking one of the country’s first significant steps toward steering its data protection framework in a direction independent from that of the EU.

UK GDPR penalties for non-compliance

Under UK GDPR, non-compliance can lead to fines up to £17.5 million or 4% of global turnover, whichever is higher.

How to appoint a UK GDPR representative ?

Similarly to the EU GDPR, the UK GDPR also has the Representative role on its Article 27. The Representative must be authorised in writing to act on your behalf regarding UK GDPR compliance and to liaise with both the ICO and data subjects.

The appointment of the Representative should be formalised through a written mandate agreement, and the representative’s details should be made public, for example in a company’s privacy notice.

If you decide to appoint EDPO as your UK GDPR representative, our onboarding process is very simple and quick, and everything can be completed within a few hours. Here are the main steps:

1. We will send the agreement for electronic signature.
2. Once executed, we will send you an email containing:
   a) Your Article 27 Compliance Certificates, which you can download and add wherever needed
   b) Instructions on how to upload your company’s Record of Processing Activities (ROPA) to the secure third-party platform we use.

Still not sure if you need to appoint a representative? Feel free to take our assessment test here, to fill out our registration form here or to simply send us an email to info@edpo.com.