noyb analysis questions legal coherence of proposed EU Digital Omnibus changes
A new analysis by noyb examines selected elements of the European Commission’s proposed Digital Omnibus package, focusing on how planned amendments could affect the interpretation and enforcement of EU data protection law.
Published in January 2026, the report reviews proposed changes to the GDPR and ePrivacy framework put forward by the European Commission. It highlights areas where amendments would touch on core concepts, including the definition of personal data, the treatment of scientific research, limits on data subject rights, and new provisions related to AI.
According to the analysis, several proposals aim to simplify regulatory obligations but may also introduce legal uncertainty by relying on subjective assessments or broad exemptions. The report notes potential consequences for supervisory authorities’ enforcement capacity and for the practical exercise of individual rights, without taking a position on policy outcomes.
The document presents a structured, article-by-article review intended to inform legislative scrutiny by EU institutions as discussions on the Digital Omnibus continue.
Read the full analysis here.
