Connected Digital Omnibus Special Edition – December 2025
Contacts
The end of year 2025 edition has been edited by Anthony Rosen with contributions from the Regulatory & Public Affairs team and Bird & Bird colleagues across our Bird & Bird One Firm network.
In our final edition of 2025, we are delighted to present a Digital Omnibus Special Edition of Connected. This edition provides an overview of the Digital Omnibus package together with in-depth analyses of the proposed changes to the Data Act, GDPR and other data regulations, the AI Act and the establishment of an EU-wide single reporting portal for incident reporting. We also include a brief update on reforms to the UK’s cybersecurity regime.
Look out for the January edition, which will outline some key priorities for 2026.
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Introduction to the European Commission’s Digital Omnibus Package
The European Commission’s Digital Omnibus Package, unveiled on 19 November 2025, is a crucial step towards simplifying and streamlining the digital regulatory framework across data access, privacy and cybersecurity. It aims to reduce complexity and make compliance easier and less costly for businesses. This wide-ranging Proposal for a Regulation on simplification of existing digital legislation will now be discussed and amended by the European Parliament and Council. Whilst these proposals are subject to the outcome of months of institutional discussions to come, they should be considered as the Commission's viewpoint at the start of what is likely to be a lively debate and intense negotiation.
For more information, please contact Francine Cunningham and Feyo Sickinghe.
Digital Omnibus Package: Significant changes to the Data Act proposed
As part of the Digital Omnibus package, the European Commission has unveiled proposals to simplify and streamline Europe's data rules whilst maintaining robust protections.
For more information, please contact Berend Van Der Eijk, Tobias Brautigam, Lennart Schusler and Lea Noemi Mackert.
Digital Omnibus Package: AI Act 2.0 – The Commission's regulatory remix proposal
Part of the Commission’s Digital Omnibus Package includes amendments to the EU AI Act, which has certain provisions already in force while other provisions are yet to come into force.
For more information, please contact Nora Santalu, Toby Bond and Dr Miriam Ballhausen.
Digital Omnibus Package: GDPR, ePrivacy, Data Governance Act, Free Flow of Non-Personal Data Regulation and Open Data Directive proposed changes
The Digital Omnibus package sets out a range of measures designed to simplify and streamline the EU’s data rules whilst maintaining robust protections. The proposal governing the GDPR, ePrivacy, Data Governance Act, Free Flow of Non-Personal Data Regulation and Open Data Directive are addressed below.
For more information, please contact Ruth Boardman, Gabriel Voisin, Alex Dixie, Benjamin Docquir and Francine Cunningham.
Digital Omnibus package: Single EU harmonised incident reporting regime across cyber and data protection regime
A key compliance burden that will be addressed as part of the Digital Omnibus Package is incident/breach reporting. Today, companies need to comply with multiple EU laws which impose overlapping and sometimes inconsistent cybersecurity-related incident reporting obligations on organisations across many sectors, including NIS2, CER, GDPR, DORA, the Cyber Resilience Act, eIDAS, aviation and electricity rules, and other sector-specific regulations as well as telecoms.
For more information, please contact Adam Simon and Kinga Kalman.
Cyber Security and Resilience Bill: Strengthening the UK’s Digital Defences
On 12 November 2025 the UK Cyber Security and Resilience Bill was introduced to Parliament. The Bill is designed to update the existing Network and Information Systems Regulations 2018 (NIS Regulations) to respond to growing concerns about cyber threats targeting essential infrastructure and services. The need for this is obvious given the increase in high-profile and damaging cyberattacks that we have seen over the last few years.
For more information, please contact Matt Buckwell.
