OpenRouter
AI API · openrouter.ai · last read 2026-11-09
At a glance
- Is OpenRouter GDPR compliant?
- No tool is GDPR compliant on its own: compliance depends on what you process with it and how. What follows is what OpenRouter itself publishes, each answer linked to its source and the date we read it.
- Does OpenRouter have a data processing agreement (DPA)?
- Yes. OpenRouter publishes a data processing agreement at openrouter.ai. It gives 30 days' notice before a new subprocessor is added. It commits to telling you of a personal data breach within 72 hours. Source and date
- Does OpenRouter have a SOC 2 report?
- OpenRouter says a SOC 2 Type 2 report is available on request. We read this on 2026-11-09. Source and date
- How does OpenRouter transfer personal data out of the EU?
- OpenRouter's agreement relies on the EU standard contractual clauses and the UK transfer addendum. Source and date
- Does OpenRouter offer EU data residency?
- An EU location exists but requires a paid plan or add-on. Plan it needs: Business. Source and date
- Who are OpenRouter's subprocessors?
- OpenRouter lists 19 third-party subprocessors; 18 of them name at least one processing country outside the EEA. We last read the list on 2026-11-09. Source and date
- How do you report a security vulnerability to OpenRouter?
- OpenRouter publishes a security.txt at openrouter.ai naming [email protected]. Source and date
The same questions for any vendor, and the rule behind each: the vendor due diligence checklist.
Identity
| Legal entity | OpenRouter, Inc. |
|---|---|
| HQ | US |
| Parent company | — |
| Ultimate ownership | US |
| EU contracting entity | — |
| LEI | 25490031S9HFEP339478 |
| US CLOUD Act reach | Contracting entity incorporated in the US |
| Source | openrouter.ai · 2026-11-09 |
Legal entity from the vendor's own terms. LEI, registered country and parent company from the Global LEI Index (GLEIF); ownership is left empty where GLEIF names no parent. The CLOUD Act row is arithmetic over those countries, not an assessment of risk.
OpenRouter data residency
| Region | EU data location | Minimum plan | Source | Observed |
|---|---|---|---|---|
| EU | Paid upgrade | Business | openrouter.ai | 2026-11-09 |
EU: EU in-region routing is offered to Business and Enterprise customers and is self-serve on Business, with no contract and no monthly minimum. It requires upgrading to Business, a paid plan below Enterprise. The document applies EU routing to prompts and completions only; account, billing and other operational records may be stored or processed in the US.
The same question for every vendor: where SaaS vendors store EU data.
OpenRouter's subprocessor list names Google for hosting or infrastructure. Which SaaS vendors run on which cloud, and the sovereign offerings of each: sovereign clouds.
Subprocessor chain
19 third parties · 18 with a country outside the EEA · all read 2026-11-09
| Subprocessor | Country | Purpose |
|---|---|---|
| Clerk | US | Authentication |
| ClickHouse | US | Database |
| Cloudflare | US | Cloud Infrastructure |
| Coinbase | US | Payments |
| Customer.io | US | Email Notifications |
| Datadog | US | Observability |
| Fivetran | US | Integrations |
| GitHub | US | Version Control |
| Google Cloud | US | Cloud Infrastructure, Inference |
| Microsoft Azure | US | Inference |
| Model Providers | — | Inference — Optional based on customer selection |
| OpenAI | US | Inference |
| Plain | US | Customer Support |
| PostHog | US | Analytics |
| Pylon | US | Customer Support |
| Resend | US | Email Notifications |
| Stripe | US | Payments |
| Upstash | US | Cache |
| Vercel | US | Website Hosting |
The count outside the EEA is arithmetic over the country column, not a judgement about lawfulness. A transfer outside the EEA can be perfectly lawful; whether this one is depends on your use, not on the vendor.
Every subprocessor in the registry, and which vendors name it: subprocessors.
Processing terms
From the vendor's data processing agreement · read 2026-11-09 · openrouter.ai
| Term | What the agreement says |
|---|---|
| Transfer mechanism | SCC module 2 |
| Transfer mechanism | Swiss FADP clauses |
| Transfer mechanism | UK Addendum |
| Notice of new subprocessors | 30 days (SCC Clause 9(a) option 2, general written authorisation) |
| Notice of new subprocessors | 30 days' notice before a new subprocessor is authorized, only to customers who subscribe by emailing [email protected]; does not apply to AI Model Providers |
| Notice of new subprocessors | 30 days' notice before authorizing a new subprocessor, to customers who subscribe by emailing [email protected]; does not apply to processing by AI Model Providers |
| If you object to one | Customer may object in writing within 30 days of the notice. OpenRouter will make reasonable efforts to offer a change that avoids the subprocessor. If it cannot do so within 60 days, the customer may terminate the affected parts of the Order Form(s) and get a refund of prepaid fees, with no penalty |
| Breach notification | promptly, for confirmed or reasonably suspected unauthorized disclosure of Customer Data |
| Breach notification | within 72 hours (security controls list) |
| Breach notification | without undue delay and in any case within 72 hours of becoming aware |
| Audit | On reasonable request and at the customer's sole expense: access to compliance information, plus audits or inspections by an independent auditor agreed by both parties, no more than once a year, during normal business hours |
| Audit | On-site audit of data protection procedures; Customer must limit impact on OpenRouter and Subprocessors by combining Affiliate audit requests into one single audit |
| Audit | On-site audit of procedures relevant to protection of Personal Data by the contracting Customer; must take reasonable measures to limit impact on OpenRouter and its Subprocessors, combining requests for Authorized Affiliates |
Terms as the agreement states them. Where it is silent on a term, there is no row; that is not a statement that the vendor does not offer it.
Which version applies
We found no version number or date in the agreement as we read it.
These terms side by side for every vendor: data processing agreements compared. What vendors give you for a transfer impact assessment: transfer impact assessments.
Assurance
Does OpenRouter have a SOC 2 report?
OpenRouter says a SOC 2 Type 2 report is available on request. We read this on 2026-11-09.
Of the 114 vendors in this registry whose own pages mention SOC 2, 57 say the report is available on request, 1 links to the report itself, and 56 state it without saying how to get it. The type is the one the vendor names.
| Scheme | Status | Scope | Source | Observed |
|---|---|---|---|---|
| SOC 2 Type 2 · SOC2T2 | Available on request | — | trust.openrouter.ai | 2026-11-09 |
Claimed means the vendor asserts the scheme on its own page and offers nothing further. Available on request means the report or certificate exists but sits behind a request, a login or an NDA. Neither is a certificate we have seen. That is a distinction an auditor makes, so we make it too.
SecNumCloud, C5, ENS and HDS for every vendor, with the pages for ISO standards, SOC 2 and TISAX: certifications compared.
Official registers
| Register | Offering, as the register names it | Status | Level | Valid until | Observed |
|---|---|---|---|---|---|
| Global LEI Index (GLEIF) | OPENROUTER, INC. · OPENROUTER, INC. | ISSUED | US-DE | 2027-10-16 | 2026-11-09 |
- ACN qualified cloud (Italy): checked 2026-11-09, no entry under OpenRouter; OpenRouter, Inc.
- DORA critical ICT third-party providers (ESAs): checked 2026-11-09, no entry under OpenRouter; OpenRouter, Inc.
- ENS certificates of conformity (CCN, Spain): checked 2026-11-09, no entry under OpenRouter; OpenRouter, Inc.
- EU Cloud Code of Conduct (GDPR Art. 40): checked 2026-11-09, no entry under OpenRouter; OpenRouter, Inc.
- FedRAMP Marketplace (US): checked 2026-11-09, no entry under OpenRouter; OpenRouter, Inc.
- SecNumCloud qualified services (ANSSI, France): checked 2026-11-09, no entry under OpenRouter; OpenRouter, Inc.
What the authority publishes, not what the vendor claims. An entry covers the offering it names and nothing else: a FedRAMP authorisation for a government edition says nothing about the commercial service. No entry is not a finding about security - most vendors never apply - and an entry filed under a name not listed above would not have been found.
Support window
Not yet collected. This row will say not declared only once we have read a lifecycle or security page and found no period stated — see support windows.
Vulnerability reporting: [email protected] (security.txt, expires 2027-08-12; read 2026-11-09)
How other vendors publish theirs: security.txt across the registry.
Documents
| Document | Disclosure | Transcription | HTTP | Observed |
|---|---|---|---|---|
| certifications | Public | full | 200 | 2026-11-09 |
| dpa | Public | full | 200 | 2026-11-09 |
| residency | Public | full | 200 | 2026-11-09 |
| subprocessors | JavaScript only | full | 200 | 2026-11-09 |
History
Nothing has moved since we started watching this vendor on 2026-11-09. Changes appear here only after a human has reviewed them.
Every reviewed change across the registry, newest first: vendor changes.