On 13 March 2026, ETAF responded to the public consultation of the European Commission on its proposal for a Digital Omnibus (COM(2025) 837), a horizontal simplification package amending several key pieces of EU digital legislation, including the GDPR and the Data Act.
ETAF welcomes the Digital Omnibus initiative as an important step towards simplifying the EU's digital regulatory framework and supports its ambition to reduce compliance costs for businesses while preserving fundamental rights and data protection standards.
ETAF supports the reinforced protection of trade secrets introduced under articles 4(8) and 5(11) of the Data Act against unlawful access by third-country entities, while calling for a general right to object to data access and sharing requests that avoids disproportionate procedural burdens. ETAF also welcomes the narrowing of the B2G data sharing regime to public emergencies under the new article 15a of the Data Act but considers that stronger and more consistent safeguards are needed, including explicit carve-outs for data subject to professional secrecy and size-based exemptions aligned across all paragraphs of that provision.
Finally, ETAF welcomes the clarification introduced by the new article 88c GDPR on the processing of personal data for AI development but considers that it must not operate as an automatic presumption of legitimacy. ETAF further calls for explicit EU-level clarifications to ensure that the rights of access and data portability under articles 15 and 20 GDPR do not undermine professionally recognised rights of retention under national law.
