Why this matters.
The EU General Data Protection Regulation (Regulation 2016/679) applies to any organisation established in the EU, or that targets goods or services at EU residents, or monitors their behaviour within the EU — regardless of where the organisation itself is based. Following Brexit, EU GDPR and UK GDPR are now separate legal frameworks with different supervisory authorities. Lead supervisory authorities under the one-stop-shop mechanism handle cross-border complaints. Fines reach up to €20 million or 4% of total worldwide annual turnover, whichever is higher, for the most serious infringements.
The EU’s enforcement environment has intensified significantly: the Irish Data Protection Commission has issued hundreds of millions in fines against large technology companies; national DPAs across Germany, France, Italy, and Spain have been active against SMEs. For any non-EU business processing EU residents’ data, Article 27 requires appointment of an EU representative, and Chapter V governs cross-border data transfers — with Standard Contractual Clauses (SCCs) being the most common transfer mechanism following the Schrems II ruling.