Singapore is the regional headquarters of many Asia-Pacific businesses and home to fintech, SaaS, e-commerce and logistics companies that sell into Germany and the European Union. English is the working language, which makes direct sales into the EU easy, but the GDPR applies to that activity under Art. 3(2) GDPR and requires an EU representative under Art. 27 GDPR where the company has no EU establishment. Kanzlei Matutis, a German data protection law firm, acts as EU representative for Singapore companies for 350 EUR per year.
Does a company from Singapore need an EU representative?
Yes, if it has no establishment in the EU and its processing of personal data relates to offering goods or services to people in the EU or to monitoring their behaviour there (Art. 3(2) in conjunction with Art. 27(1) GDPR). Examples: a Singapore fintech app offered to users in Germany; a regional e-commerce platform with a German storefront and EUR pricing; a Singapore SaaS provider whose product analytics track users in the EU. A Singapore holding company whose group has a subsidiary in the Netherlands or Germany does not need a representative, provided the EU entity is involved in the EU-facing processing. A Singaporean company that already has a subsidiary, branch or office in an EU Member State does not need a representative; that EU entity is the point of contact. The exceptions of Art. 27(2) GDPR (occasional, low-risk processing without large-scale sensitive data; public authorities) are narrow and rarely apply to a business that actively markets to the EU. The full criteria are explained on the page What is the legal situation?.
The Singapore PDPA and the GDPR
Singapore’s Personal Data Protection Act 2012 (PDPA), as amended in 2020, is supervised by the Personal Data Protection Commission (PDPC). The PDPA is a mature framework, but it is not the GDPR, and there is no EU adequacy decision for Singapore under Art. 45 GDPR; transfers from the EU to Singapore require standard contractual clauses or another Art. 46 GDPR safeguard. For a Singapore company targeting the EU market, PDPA compliance is therefore necessary but not sufficient. The EU-facing processing is subject to the GDPR, with its own legal bases (Art. 6 GDPR), information duties (Art. 13 GDPR), data subject rights (Art. 15 to 22 GDPR) and, under Art. 27 GDPR, the representative in the EU.
What we do as EU representative for Singaporean companies
Rechtsanwaltskanzlei Matutis is a German law firm in Potsdam, near Berlin, specialised in data protection law. Under a written mandate pursuant to Art. 27(1) GDPR we act as your point of contact in the EU for all supervisory authorities of the Member States and for data subjects. Letters and emails addressed to us are checked, scanned and forwarded to your contact person without undue delay; we point out deadlines, such as the one-month period for data subject requests under Art. 12(3) GDPR. With a time difference of six to seven hours, our morning overlaps with your afternoon, so forwarded mail can usually be discussed the same day. We communicate in English and German. We do not replace your Data Protection Officer and do not take over your compliance decisions; the difference is explained on the page EU representative vs. Data Protection Officer.
Cost for companies from Singapore
The annual flat fee is 350 EUR. Because the service is provided by a German law firm to a business customer outside Germany, German VAT is not charged (reverse charge), so net equals gross. We invoice in EUR; payment by international transfer or by credit card or PayPal is possible. Forwarding of scanned mail by email is included; postal forwarding of originals is charged at 2 EUR per item plus postage. Full details: What does it cost and what is included?
Next step
Send us your company name, website and a short description of your activities in the EU via the inquiry form. We confirm whether a representative is required in your case and send you the contract and written mandate. The complete process is described on the page How to appoint an EU GDPR representative. Other countries: EU representative by country.