Ukrainian Company Without an EU Office: When GDPR Applies and What to Check Before Your First European Client
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A typical scenario: a Ukrainian IT company or SaaS provider reaches an agreement with a client from the EU. Prior to contract execution, the counterparty requests a DPA, a list of sub-processors, a description of security measures, data retention and deletion policies, and clarification regarding the legal basis for transferring data to Ukraine. It is precisely at this stage that the company discovers that, despite having standalone policies, it lacks an understanding of which GDPR requirements genuinely apply to its business model.
For the business, the risk extends beyond potential liability for non-compliance. Unpreparedness can delay contract execution, force the team to urgently rewrite documentation, or result in accepting obligations that the product cannot technically fulfill.
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