If an analysis shows that a company does not need to have a DPO, is the processing register still required? Is it sufficient to appoint a data protection team and maintain the register?

ANSWER

The obligation (or lack thereof) to appoint a DPO and the obligation to maintain a record of processing activities are two separate matters. Even if the company has not appointed a DPO (because it had no such obligation), it remains obliged to maintain the record of processing activities.