Janus Compliance Nigeria
UK GDPR representative for Nigerian companies with UK customers
A Nigerian company that serves people in the UK without a UK entity must designate a UK representative under Article 27 UK GDPR. Janus Compliance Limited, a UK company run by a Nigerian lawyer, provides that appointment for £249 a year, the total price, from a registered London office, with ICO correspondence forwarded within one working day.
Remittance, payments, diaspora property, edtech, healthtech, membership bodies and agencies. The obligation is the same; the reasons it turns up are particular to you.
£249 a year. No VAT. Cancel at renewal. Last verified 18 September 2026.
When a Nigerian company falls inside UK GDPR
Article 3(2) UK GDPR reaches a company with no UK establishment where its processing relates to “the offering of goods or services, irrespective of whether a payment of the data subject is required, to such data subjects in the United Kingdom” or “the monitoring of their behaviour as far as their behaviour takes place within the United Kingdom”. Where it applies, Article 27(1) requires the company to “designate in writing a representative in the United Kingdom”.
Being established in Nigeria does not take you out of it. Having UK customers takes you into it. These are the business models where it comes up most.
Diaspora remittance and payments
The sender in Peckham or Manchester is a UK data subject and the app offers her a service in the UK. Article 3(2)(a) applies from the first UK sign-up, whether or not the receiving side is in Lagos.
Property sold to UK-resident Nigerians
Marketing Lekki or Abuja developments to buyers living in the UK, collecting their details, following up by WhatsApp and email. That is offering goods to people in the UK, and the CRM holding their details is not occasional processing.
Edtech, healthtech and other platforms with UK users
A tutoring, telehealth or subscription platform built in Nigeria that UK residents sign up to. Health data adds a second reason to take the obligation seriously, since Article 9 data is what the exemption is most careful about.
Churches, associations and membership bodies with UK members
A Lagos-headquartered body with UK branches or UK members on its lists. If the UK branch is a UK-registered entity, that entity may be the UK establishment; if it is not, the obligation is the parent body’s.
Agencies and outsourcers handling UK customers’ data
A Nigerian company processing data on behalf of a UK client is usually a processor. Article 27(1) applies to processors too, and the UK client’s contract review is often where it comes up.
The exemption in Article 27(2) is for processing that is occasional, involves no large-scale special category or criminal data, and is unlikely to result in a risk to people. A business that sells into the UK on purpose is not doing occasional processing, so the exemption rarely helps the companies above. The decision guide walks through the test question by question.
How the question reaches a Nigerian company
The ICO is not writing to Lagos to ask. The question arrives from a counterparty in the UK who has to tick a box, and the box is empty.
The UK bank or payment partner’s questionnaire
Onboarding with a UK sponsor bank, an EMI or a card scheme partner brings a data protection questionnaire, and one line of it asks for the name of your UK representative. A blank there stalls the onboarding.
A UK enterprise customer’s vendor due diligence
The procurement team at a UK company buying your product sends a supplier assessment. It asks the same question, and the answer goes into their Article 28 file.
An investor’s data room checklist
A seed or Series A investor, especially one with UK or EU limited partners, runs a legal checklist across the markets you sell into. UK GDPR is on it, and the representative is the cheapest item on the list to close.
What you get, and what it costs
- Janus Compliance Limited named as your UK representative under Article 27, with a written designation you can show a bank, a customer or an investor the same day
- A registered London address for the ICO and for UK data subjects, with everything forwarded to you within one working day
- Your record of processing held for the ICO under Article 30, built from a ten-question intake if you do not have one
- The exact wording for your privacy notice under Articles 13 and 14
UK representative
£249
a year, the total you pay. No VAT.
Twelve months, renewed annually, cancel at renewal. Paid by card or sterling transfer against a UK invoice. A drafted reply to the ICO or a translation, if you ever ask for one, is £250 an hour agreed in writing first.
Appointing a UK representative does not create a UK branch, a UK tax presence or a Companies House filing in your name, and it does not change your obligations under the Nigeria Data Protection Act 2023. It answers one UK question, properly, for the price of a few hours of a lawyer’s time.
Questions Nigerian founders ask
Does appointing a UK representative make us subject to UK tax or UK company law?+
No. The representative is a UK point of contact designated under Article 27 UK GDPR. It is not a UK branch, a place of business or a permanent establishment of your company. Nothing is registered at Companies House in your name and nothing is filed with HMRC. It changes your data protection position and nothing else.
We already comply with the Nigeria Data Protection Act 2023. Does that cover the UK?+
No. The NDPA governs your processing as a Nigerian controller or processor and the NDPC supervises it. UK GDPR applies in parallel to your processing of people in the UK under Article 3(2), with its own regulator, the ICO, and its own representative obligation. Appointing a UK representative adds nothing to your NDPA obligations and takes nothing away.
Can our UK-based director or a friend in London be the representative?+
A natural person established in the UK can be designated under Article 4(17). Whether they should be is a different question: the representative is the address the ICO writes to and the person data subjects contact, and Article 30(1) puts the record of processing on them. Most companies prefer a company whose job it is, with an office that opens the post, for the price of a few hours of a lawyer’s time.
Why use a Nigerian lawyer in the UK for this?+
The incumbents do not market to Nigerian companies and do not know the business models. Michael is called to the Nigerian Bar, holds the CIPP/E, has spent over ten years in UK and international compliance, and writes the Janus Compliance Nigeria pages you are reading. The conversation about a remittance app or a diaspora property sale starts from understanding, not from a form.
How do we pay from Nigeria?+
By card or bank transfer in pounds sterling against a UK invoice. £249 a year is the total; Janus Compliance Limited is not VAT registered, so nothing is added.
Do we need an EU representative as well?+
If you also serve people in the EU without an EU establishment, yes, under Article 27 of the EU GDPR, and a UK representative does not cover it. We expect to offer the EU appointment through an Irish company; ask and we will tell you where that stands.
Appoint Janus as your UK representative
Four details. The agreement, the intake and the invoice come back within one working day.
Sources, read on 18 September 2026
- UK GDPR, Articles 3, 4(17), 13, 14, 27 and 30, legislation.gov.uk, revised text as at 19 June 2026.
- Nigeria Data Protection Act 2023, for the statement that UK GDPR applies in parallel to it and does not replace it.