Can I file an EDPS complaint if I don’t know exactly what data Europol holds on me?

Yes. You can file a complaint based on reasonable grounds to believe Europol processes your data — such as unexplained banking restrictions, visa refusals referencing security concerns, or information from national authorities suggesting Europol involvement. The EDPS can investigate Europol’s databases even without you providing specific file references. In practice, many successful complaints begin with circumstantial evidence. The EDPS has independent investigative powers under Regulation 2018/1725 and can compel Europol to disclose whether data exists and its lawful basis.