Living guide
Under GDPR Article 28, any business that uses a processor needs a Data Processing Agreement. The mandatory clauses are EU-wide; supervisory-authority expectations vary by country. This page tracks both, updated quarterly.
Last reviewed 11 July 2026 · updated quarterly
| Country | Supervisory authority / national note | Status | Basis | |
|---|---|---|---|---|
| DE | Germany | Federal BfDI plus 16 Länder authorities; German guidance is notably strict on technical and organisational measures (TOMs). Confirm with the authority for your Land. | In force | Art. 28(3) GDPR ↗ |
| FR | France | CNIL is the supervisory authority; it publishes DPA guidance and model processing clauses. Verify against current CNIL guidance. | In force | Art. 28(3) GDPR ↗ |
| ES | Spain | AEPD is the supervisory authority and issues detailed processor guidance. Confirm requirements against the AEPD. | In force | Art. 28(3) GDPR ↗ |
| IT | Italy | Garante per la protezione dei dati personali is the supervisory authority and has published its own guidance on processor designations. Confirm requirements against the Garante. | In force | Art. 28(3) GDPR ↗ |
| NL | Netherlands | Autoriteit Persoonsgegevens (AP) is the supervisory authority. The Article 28 clause set applies; check AP guidance for national emphasis. | In force | Art. 28(3) GDPR ↗ |
| IE | Ireland | The Data Protection Commission (DPC) supervises many large processors headquartered in Ireland; its enforcement decisions shape processor practice EU-wide. | In force | Art. 28(3) GDPR ↗ |
| BE | Belgium | The Belgian Data Protection Authority (APD/GBA) is the supervisory authority. Its 2026–2028 strategic plan shifts enforcement toward large-scale processing and AI; the Article 28 clauses still apply uniformly. Check APD/GBA guidance. | In force | Art. 28(3) GDPR ↗ |
| AT | Austria | The Datenschutzbehörde (DSB) is the supervisory authority. Article 28 clauses apply uniformly; check DSB guidance for national emphasis. | In force | Art. 28(3) GDPR ↗ |
| PL | Poland | The Personal Data Protection Office (UODO) is the supervisory authority. Article 28 clauses apply uniformly; check UODO guidance for national emphasis. | In force | Art. 28(3) GDPR ↗ |
| PT | Portugal | The Comissão Nacional de Proteção de Dados (CNPD) is the supervisory authority. Article 28 clauses apply uniformly; check CNPD guidance for national emphasis. | In force | Art. 28(3) GDPR ↗ |
| LU | Luxembourg | The Commission Nationale pour la Protection des Données (CNPD) is the supervisory authority. Article 28 clauses apply uniformly; check CNPD guidance for national emphasis. | In force | Art. 28(3) GDPR ↗ |
| FI | Finland | The Office of the Data Protection Ombudsman is the supervisory authority. Article 28 clauses apply uniformly; check the Ombudsman's guidance for national emphasis. | In force | Art. 28(3) GDPR ↗ |
| DK | Denmark | Datatilsynet is the supervisory authority and has published DPA templates and guidance. Verify against current Datatilsynet guidance. | In force | Art. 28(3) GDPR ↗ |
| SE | Sweden | IMY (Integritetsskyddsmyndigheten) is the supervisory authority and an active enforcer in the Nordics. Article 28 clauses apply; check IMY guidance. | In force | Art. 28(3) GDPR ↗ |
Each key date links to the authority it was verified against. Announced dates move — always confirm at source.
FAQ
Disclaimer
General information compiled from public sources, not individualised legal advice. Confirm requirements with your supervisory authority or counsel before relying on them.