Article 134(2) EPC provides that only natural persons can undertake representation before the EPO. Under Rule 152(11) EPC, the authorisation of an association is deemed to be an authorisation of any representative who practises within that association.
An association consists of at least two professional representatives. In decision J 08/10 dated 5 October 2011, the Legal Board of Appeal ruled that a legal practitioner cannot be treated as a member of an association of representatives.
For further information regarding the authorisation of an association of
representatives, please see part I of the Notice from the EPO dated 28
August 2013 on matters concerning representation before the EPO (OJ EPO 11/2013, 535-541).