When is an EU Representative required under GDPR?

An EU representative is required under GDPR in any situation where a person who’s holding data on behalf of a data subject based in the EU, but doesn’t actually have an establishment in the EU themselves. So for instance, if a business outside of the EU is collecting or holding data in relation to people who are in the EU, but that business doesn’t have any presence in the EU itself, it needs to appoint a representative in the EU, for the purposes of the GDPR compliance.