EU Digital Omnibus: Resetting Europe’s digital rulebook

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Paolo Sasdelli

Regulatory and Public Affairs Advisor
Belgium

As a Regulatory and Public Affairs Advisor, I assist clients in understanding the EU decision-making processes and the impact of EU laws on their sectors.

The European Commission is preparing a major legislative initiative to streamline and modernise the EU’s digital regulatory framework. Known as the Digital Omnibus Package, this effort is part of the broader Commission’s simplification agenda aimed at reducing administrative burdens, enhancing legal clarity, and fostering innovation across key policy areas.

What is the Digital Omnibus?

The initiative, expected to be presented on 19 November 2025, responds to growing concerns from businesses that the EU’s digital rulebook has become fragmented, overly complex, and difficult to navigate. The Commission’s goal is to make compliance more coherent and predictable, while preserving Europe’s high standards for safety, trust, and technological sovereignty.

Rather than a wholesale overhaul, the Digital Omnibus is expected to deliver targeted legislative updates to existing laws. These include:

  • Simplifying the data acquisition, including the Data Governance Act, the Free Flow of Non-Personal Data Regulation, and the Open Data Directive.
  • Revising cookie and tracking rules under the ePrivacy Directive to reduce consent fatigue.
  • Clarifying and adjusting the AI Act to ensure smoother implementation and support innovation.
  • Aligning digital identity frameworks, including the launch of the EU Business Wallet, a secure interface for companies modeled on the EU Digital Identity Wallet.

The Commission has emphasised the need for a coherent compliance framework that reduces duplication, supports innovation, and ensures that Europe’s digital regulation remains fit for purpose in a fast-evolving technological landscape.

Consultation outcome – strong industry support for simplification

The Commission’s call for evidence, which closed on 14 October 2025, drew wide participation from industry groups, Member States, and civil society. Stakeholders broadly welcomed the initiative, and urged the Commission to:

  • Clarify overlaps between digital laws, especially the AI Act, GDPR, and sectoral legislation.
  • Reduce administrative burdens through harmonised reporting and fewer duplicative obligations.
  • Support innovation, particularly for SMEs and mid-cap firms, by expanding regulatory sandboxes and easing compliance pathways.
  • Ensure legal certainty in areas like data sharing and AI governance.

AI Act – Delay, clarity, and support for innovation

Among the most closely watched elements of the Digital Omnibus is the revision of the AI Act, particularly the rules for high-risk AI systems set to apply from August 2026. With technical standards delayed and national authorities still ramping up, both Germany and the Czech Republic have formally asked the Commission in their consultation responses to postpone the start date by one year, proposing that obligations kick in only after harmonised standards are published.

In response, the Commission is weighing a “stop-the-clock” mechanism to align the law’s timeline with practical readiness. Businesses, meanwhile, are calling for expanded exemptions for small mid-caps, faster rollout of innovation measures, and clearer rules for AI systems embedded in regulated products.

Data – Removing barriers and reducing burden

The Omnibus is expected to consolidate and simplify the EU’s fragmented data legislation. Leaked drafts indicate that the Commission plans to integrate the Data Act, Data Governance Act, and related instruments into a single, streamlined framework, reducing overlaps and compliance complexity. The goal is to boost data availability, harmonize rules across Member States, and remove legal barriers that hinder cross-sector data sharing.

Germany has been particularly active in shaping this agenda, pushing for carve-outs for medium-sized companies, simplified data request procedures, and the removal of prescriptive provisions on smart contracts. Berlin also advocates for lighter transparency obligations, such as replacing multiple notices with digital access points, to ease administrative burdens on SMEs.

Strategic outlook

The Digital Omnibus Package represents a pivotal moment in the EU’s approach to digital regulation. As the first step in a broader Digital Fitness Check, set to conclude by 2027, it reflects the Commission’s intent to recalibrate existing frameworks to better support innovation, reduce complexity, and improve legal coherence.

Rather than introducing new obligations, the package focuses on making current rules more workable and aligned with technological realities. Its success will depend on how effectively it balances regulatory clarity, business needs, and technological progress. If well-executed, the Omnibus could serve as a model for future digital policymaking, one that prioritises usability and impact over legislative expansion.

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