28/05/2026

Data Protection Essentials #3 – When is the appointment of a Data Protection Officer mandatory in Monaco?

Phoenix Data Protection Essentials #3

Today’s focus: when is the appointment of a Data Protection Officer mandatory in Monaco?

In Monaco, the appointment of a Data Protection Officer (DPO) is mandatory in certain cases provided for under Law No. 1.565 of 3 December 2024.

The appointment of a DPO is required where the organisation:

➡️ carries out a task in the public interest or is entrusted with the operation of a public service
➡️ carries out regular and systematic monitoring of individuals on a large scale
➡️ processes, on a large scale, special categories of personal data or personal data relating to criminal convictions and offences

Failure to comply with this obligation may expose the organisation to significant risks, including penalties, litigation, reputational damage and loss of trust.

However, today the issue goes well beyond the legal obligation alone.

Even where the appointment of a DPO is not mandatory, it remains strongly recommended because it helps to:

➡️ secure personal data processing through appropriate procedures and controls
➡️ strengthen internal practices and governance
➡️ anticipate risks and reduce the costs associated with data incidents
➡️ enhance the confidence of customers, business partners and employees

In practice, having a DPO can make a real difference: reassuring a customer, strengthening internal confidence or enhancing the organisation’s credibility in certain business relationships.

Not yet ready to appoint a DPO?
Designating an internal data protection coordinator is already an important first step.

In practice, the question is no longer simply: “Am I required to appoint a DPO?”
It is also: “Can my organisation really afford not to structure its approach to data protection?”