Service Overview
Are you a non-EU data intermediation service provider offering services in the European Union?
Article 11(3) of the EU Data Governance Act requires data intermediation service providers (DISPs) not established in the European Union but offering services within it to designate, in writing, a legal representative in one of the Member States where the services are offered. The legal representative is the formal counterparty for the competent authority that supervises DISPs in the Member State of designation, and the contact details published in the public register of DISPs maintained by the Union are those of the representative — not the provider.
A data intermediation service is the technical and legal infrastructure that establishes commercial relationships between data holders and data users for the sharing of data, with the intermediary remaining strictly neutral in relation to that data — neither using it for its own purposes nor enabling its onward use beyond the terms of the sharing relationship. The DGA's structural neutrality requirements distinguish DISPs from data brokers, cloud service providers and analytics platforms; not every business that touches third-party data is a DISP. Whether a particular service falls within the DISP definition is a fact-specific assessment, and one we encourage clients to take advice on before signing the mandate.
Service Detail
What this service covers
Our focus
Established in Ireland for Union-wide DISP representation
Lionheart provides Article 11(3) representation through Lionheart Squared (Europe) Limited, our Dublin-based EU entity. The legal representative's establishment determines which national competent authority supervises your service for DGA purposes — Ireland in our case. Your contact details on the public DISP register maintained by the Union will reflect Lionheart's Dublin address, with a dedicated representative email address.
Built around the duties Article 11(3) actually imposes
As your legal representative, we accept that we may be addressed in addition to or instead of you by competent authorities on DISP-related matters, and that we may receive written instructions from you on DISP-related obligations and tasks. Our duties under the mandate are concrete: promptly inform you of correspondence received from competent authorities, cooperate with those authorities by providing copies of the mandate, the underlying agreement and related materials concerning your DISP compliance, and permit you to disclose our appointment and approved contact details for publication on the Union's DISP register.
Notification of intent — your obligation, our support
DISPs are required to notify the competent authority of their intent to provide data intermediary services in the Member State where the legal representative is established, before commencing those services. The substantive notification, and any associated administrative fees, remain your obligation as DISP — but we provide the contact-information component of that notification, support its submission, and are the formal addressee for the competent authority's response.
Forward-positioned for the Digital Omnibus
The proposed Digital Omnibus for Data (COM(2025) 837) is expected to migrate the DISP representative obligation from Article 11(3) DGA into Article 32e(2) of the amended Data Act, anticipated 2027 or 2028.
Our services include
Formal designation
Acting as your EU legal representative under Article 11(3) DGA (or Article 32e(2) of the Data Act once the Digital Omnibus is enacted), by written mandate, with clearly documented scope and procedures.
Ireland-based contact details
Lionheart's Dublin address and a dedicated representative email address, available for publication on the Union's public DISP register and for inclusion in your DISP-facing disclosures.
Authority liaison
Acting as the formal contact point for the Irish competent authority designated for DISP supervision under the DGA, and for cross-border cooperation with competent authorities in other Member States where your services are offered.
Authority correspondence handling
Prompt receipt, logging and forwarding of regulatory correspondence; provision of mandate and agreement copies to competent authorities on request, in cooperation with you.
Notification support
Practical support with the contact-information component of your notification of intent to provide data intermediary services, and acting as the formal addressee for the competent authority's confirmation.
Public register listing
Lionheart's contact details listed against your organisation in the Union's public DISP register, maintained accurately for the duration of the mandate.
Coordinated mandates
Single-relationship handling where DISP obligations sit alongside other Lionheart representative services — under one coordinated engagement and one escalation path.
Legal basis: Article 11(3), EU Data Governance Act (Regulation (EU) 2022/1724); transitional reference to Article 32e(2) of the Data Act under proposed Digital Omnibus COM(2025) 837.
Substantive obligations remain with you
The legal representative is a statutory contact point and support function, not a substitute for the DISP itself. You remain responsible and accountable for fulfilling all DISP obligations under the DGA — including the structural neutrality requirements, transparency disclosures, conflict-of-interest safeguards, and any obligations applicable to the categories of data you intermediate.
Penalty regime
Penalties for failure to comply with the DGA representative obligation are determined by Member State law under Article 45 DGA and have not been harmonised at EU level. The applicable Irish penalty framework is set out in the master representative services agreement, with the calibrated indemnity provisions disclosed before any mandate is signed.
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