noyb report analyses Commission’s Digital Omnibus changes to GDPR and ePrivacy rules
A new version of a report by noyb examines proposed amendments to the GDPR and ePrivacy Directive under the European Commission’s Digital Omnibus package, assessing their legal consistency and potential impact on fundamental rights.
The digital rights organisation noyb has published version 3 of its report analysing the European Commission’s proposed Digital Omnibus package, with a focus on amendments affecting the General Data Protection Regulation (GDPR) and the ePrivacy Directive.
The Digital Omnibus proposal was presented by the Commission on 19 November 2025. Shortly after its publication, noyb released an initial legal assessment of the changes related to data protection law. The newly updated version, published on 24 February 2026, consolidates earlier findings and adds further analysis.
According to noyb, the report provides a detailed comparison between existing legal provisions and the Commission’s proposed amendments. It examines how the draft changes interact with the EU Charter of Fundamental Rights and relevant case law of the Court of Justice of the European Union. The analysis also considers possible implications for data subjects, supervisory authorities and data controllers, including practical examples of how the changes could operate in practice.
Version 3 includes additional commentary on the joint opinion issued on 11 February 2026 by the European Data Protection Board and the European Data Protection Supervisor regarding the data-related aspects of the Digital Omnibus. The report assesses how that opinion addresses the proposed reforms.
noyb states that its analysis identifies areas where the proposed amendments could create inconsistencies within the GDPR framework or depart from established legal logic. Alongside the written report, the organisation has also published a video presentation outlining the key elements of the Commission’s proposal.
