Digital Fitness Check

Response to the European Commissions call for evidence on the Digital Fitness Check We welcome the Commissions Digital Fitness Check and its stated objective of ensuring that the EU digital rulebook remains coherent, proportionate, innovation-friendly, and supportive of competitiveness.

Digital Fitness Check brings good opportunity for the review, simplification and re-design where needed- the structure of the digital rules. Instead of bringing new requirements it is important to reflect over the existing AI rulebook so as to streamline underling legislation and adhere to the needs of the industry and all its participants.

I am happy to be responding on behalf of the International Federation of Library Associations and Institutions (IFLA), in its capacity as administrator of the Knowledge Rights 21 Programme (KR21). KR21 works to ensure that the needs, experience and priorities of libraries and their users are reflected in decision-making around knowledge and digital law.

The Dutch municipalities welcome the evaluation of the Digital Rulebook and its fitness for purpose. Over the past few years, the legislative acquis on digitalisation has grown significantly. Dutch local authorities have built up lots of expertise when it comes to putting the digital regulatory framework into practice.

As a European technology company developing digital infrastructures for traceability and compliance across supply chains, Circularise operates at the intersection of several EU digital and sectoral regulatory frameworks. Our contribution highlights the strategic role of digital infrastructures - including Digital Product Passports - in translating regulatory data requirements into scalable and interoperable systems.

This response is submitted by the IMPULSE (IMmersive digitisation: uPcycling cULtural heritage towards new reviving StratEgies) project which works at the intersection of cultural heritage, digital innovation, and public governance.

As a global leader in enterprise applications and business AI, SAP SE enjoys the specific perspective of a European innovation company, active for over 50 years and present on five continents. Having supported and accompanied European companies and public bodies in their digitization, we want to offer our insights on the regulatory framework and the rightful effort to simplify and streamline it.

The National Chamber of Commerce, an independent organisation of economic self-government in Poland, bringing together more than 170 regional, sectoral and bilateral chambers and other economic actors, has been actively supporting the development of the digital economy for many years.

Filed in Polish · English published by the European Commission

SUBMISSION REGARDING COM(2025) 837 FINAL: Addressing the actuarial failure of the statutory EU representative model As a Statutory EU Representative (EU Transparency Register: 3190771102741-15), I provide this critical update to the reality checks (p. 14) and fundamental rights assessments (p. 15) described in the Digital Omnibus. 1.

Microsoft welcomes the opportunity to contribute to the Digital Fitness Check call for evidence. The current EU digital rulebook has been instrumental in establishing the core pillars of a Digital Single Market.

The appliedAI Institute for Europe is a non-profit company, based in Germany, with the goal to foster trustworthy AI Innovation at scale, by providing educational, technical and community-related offerings with a focus on Startups, SMEs and the public sector. We aim to shape the AI Act and secondary legislation with the stance of empowering small-scale AI Innovators and Governance bodies alike.

We welcome the opportunity to contribute to the Digital Fitness Check consultation and fully support the European Commissions ambitious goals to bolster Europes economic competitiveness. As the continent looks to capitalize on the AI revolution, we believe that regulatory simplification and coherence should be treated as strategic priorities.

The EU has adopted an extensive set of digital regulations in recent years, including the AI Act, Data Act, Digital Services Act, Digital Markets Act and the NIS2 Directive. While these initiatives pursue legitimate goals such as user protection, fair competition and cybersecurity, their combined impact creates a growing regulatory burden for startups and scale-ups.

Check My Ads welcomes the European Commissions effort to simplify the EU digital rulebook while strengthening Europes competitiveness in the digital economy. Online advertising is the central revenue stream of the modern internet, yet the ecosystem's governance has largely been delegated to industry-led bodies, creating conflicts of interest, opacity, and weak enforcement.

Liberties welcomes the opportunity to provide input to the Digital Fitness Check Communication. However, it is unfortunate that this opportunity only comes after the digital omnibus proposals were launched in November 2025.

CIPL welcomes the opportunity to provide input to the Digital Fitness Check and submits its attached paper, CIPLs Big Ideas for Simplification of Europes Digital Rulebook, as a practical contribution to this exercise. The paper draws on CIPLs extensive work on the practical implementation of the EU digital rulebook and is directly relevant to the issues identified in this call for evidence.

SPIR welcomes the Commission's intention to simplify the EU's digital rules, ensuring they are effective and proportionate. Many of the current EU digital norms were adopted relatively recently, and together they provide a robust and complex regulatory environment.

The Digital Fitness Check should focus on the cumulative cost of compliance, not on single acts in isolation. The core problem for European businesses is the overlap of obligations under GDPR, the AI Act, NIS2, the Cyber Resilience Act and sector-specific regimes.

BEUC welcomes the opportunity to contribute to the Digital Fitness Check. From a consumer perspective, the EU digital rulebook is a fundamental framework to address structural problems in digital markets. Instruments such as the DSA, DMA, GDPR and AI Act have begun to tackle long-standing issues including opaque platform practices, excessive data collection, harmful commercial strategies and the concentration of…

Rockwell Automation appreciates the opportunity to share our perspective on the Digital Fitness Check. In addition to our detailed consultation input, we would like to share the attached document, which highlights an implementation issue within the CRA regarding the scope of the spare parts exemption in Article 2(6).

The European Banking Federation (EBF) welcomes the opportunity to contribute to the European Commissions simplification initiative under the Digital Fitness Check. In the attached document, we conducted an examination of 11 legal acts, identifying interplays, overlaps and priority areas for the financial sector where simplification, better coordination and effective enforcement are needed, with the objective of…

1. Reaffirming fundamental principles of Article 82 GDPR The European Commissions Digital Fitness Check should reaffirm the fundamental principle that compensation under Art.82 GDPR requires demonstrated, actual harm and a proven causal link to an infringement.

The European digital legal framework has evolved steadily in recent years. Harmonising key rules has helped facilitate cross-border online trade and boosted consumer trust in digital offers. At the same time, practical implementation shows that the Digital Single Market is not yet complete. For example, there are some inconsistencies between different legal acts.

Filed in German · English published by the European Commission

Please find attached the "Oslo Submission on the Digital Omnibus and the Digital Fitness Check". It is based on academic discussions held in Oslo between December 2025 and March 2026 among legal scholars specialising in data protection, digital regulation and technology law from the University of Oslo, BI Norwegian Business School, the University of Bergen, and Oslo Metropolitan University.

Suggestion of a Digital Meta-Legislation to upgrade proven existing legal frameworks, reducing the number of acts in total and eliminate any manual reporting effort for affected parties. The Bundesinnungsverband represents the car workshops in Germany, where the impact of the technical evolution in the field of Digitalisation for an increasingly connected and autonomous vehicle, digital services and digitized parts…

We welcome the opportunity to contribute to the European Commissions Digital Fitness Check and to share our views on the cumulative impact of EU digital legislation. As a company active across multiple digital and data driven value chains, we strongly support the objective of ensuring a coherent, proportionate and innovation friendly regulatory framework that strengthens Europes competitiveness while safeguarding…

Cisco welcomes the opportunity to comment on the upcoming Digital Fitness Check as it should assess how different laws work together, identifying synergies, good practices, and any remaining gaps, overlaps and inconsistencies.

The Computer & Communications Industry Association (CCIA Europe) applauds the European Commissions consultation on the upcoming Digital Fitness Check. As highlighted in the Draghi and Letta reports, overlapping digital regulations impose disproportionate compliance costs on companies operating across the European Union.

Schaeffler, the motion technology company, welcomes the opportunity to contribute with the European Commissions plan to simplify the EUs digital rules and also commented on the previously proposed adjustments under the Digital Omnibus.

Schneider Electric welcomes the European Commissions Digital Fitness Check, a timely and necessary initiative to assess the coherence, cumulative impact, and practical effectiveness of the EUs digital rulebook. We focus our response on the practical interactions between the Cyber Resilience Act (CRA) and other parts of the EU digital rulebook.

CLEPA, the European Association of Automotive Suppliers, represents over 3,000 companies across the automotive supply chain and serves as a key interlocutor for the sector. CLEPA welcomes the Digital Fitness Check as a timely opportunity to assess how major EU digital regulations interact and cumulatively impact competitiveness, particularly for SMEs.

Modern AI-enabled systems increasingly operate through agent-based architectures that interact with enterprise services, APIs, data stores and automated workflows. In practice, organisations implementing these systems frequently operate under multiple regulatory frameworks simultaneously, including cybersecurity, data protection and emerging AI governance rules.

EuroISPA, the European Internet Services Providers Association, welcomes the Digital Fitness Check initiative as an important opportunity for businesses, associations and other stakeholders to provide feedback on the current regulatory framework, including ongoing initiatives such as the Digital Omnibus Package.

MedTech Europe welcomes the Digital Fitness Check as a second step to stress-test the complementarity, efficiency, and effectiveness of the digital rulebook that will support Europe's position at the forefront of medical innovation and ensure that patients benefit from advances, more personalised treatments, and better outcomes. By simplification, our sector does not mean deregulation or lowering standards.

The Data & Technology for Compliance (DT4C) Alliance welcomes the Digital Fitness Check as an important second step in the Commissions wider simplification agenda for the EU digital rulebook, following the proposals set out under the Digital Omnibus.

We welcome the European Commissions intention to review the complementarity, efficiency and effectiveness of the EU digital rulebook. The EU digital sector, and particularly the digital health sector, are burdened by a large number of overlapping regulatory frameworks that enhance regulatory complexity and put a burden on different actors in the system.

The European Publishers Council (EPC), a high-level group of Chairmen and CEOs of leading European media corporations, actively involved in multimedia markets spanning newspaper, magazine, book, journal, internet and online database publishing, and radio and TV broadcasting, welcomes the opportunity to provide feedback to the European Commission on the EU Digital Rulebook.

We are glad that the Commission recognises that the EUs digital rulebook has brought significant benefits to businesses and people in the EU alike. It is a strong competitive advantage for businesses who want to innovate in an ethical and fundamental rights-respecting manner; whereas in many other jurisdictions with weaker standards, we witness peoples most sensitive data being commodified, and used to track…

Europes digital regulatory framework has grown rapidly in recent years, with important new rules aimed at strengthening safety, trust, resilience and fairness across the Single Market. While these objectives remain essential, the cumulative effect of overlapping obligations, fragmented enforcement structures, and parallel reporting and transparency duties is creating unnecessary complexity for businesses operating…

As the Spanish association of automobile and truck manufacturers, ANFAC supports the Commissions Digital Fitness Check initiative as an important step toward a more coherent and business-friendly regulatory framework, and puts forward proposals in key areas that we believe will encourage innovation, enhance competitiveness, and help ensure that Europe continues to lead globally in automotive technology and digital…

DOT Europe welcomes the European Commissions Digital Fitness Check as an opportunity to simplify and rationalise the EU digital rulebook, which has expanded significantly over the past decade. While these rules aim to support the Digital Single Market and ensure high standards of consumer protection, safety and privacy, their rapid development has created overlaps, duplication and legal uncertainty for companies…

The European Commission’s Digital Fitness Check is a crucial opportunity for the EU to conduct a strategic review of the digital regulatory framework. It must be a shift from an excessively risk-averse, mostly regulatory and burdensome approach to a more efficient, coherent, future-resilient and innovation-friendly model that protects fundamental values while strengthening Europe’s ambitions in global…

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The problems tackled in the Omnibus packages are only the tip of the iceberg. This DFC is an essential next step. We urge the Commission to be ambitious. That does not mean lowering Europes regulatory standards.

Eurochambres welcomes the Commissions initiative to assess the coherence, effectiveness, and administrative impact of EU digital legislation. European businesses, particularly SMEs, increasingly face overlapping and complex compliance obligations stemming from various digital regulatory acts.

Skyscanner welcomes the opportunity to provide its views on the impact of the EU's digital rules. Given the significant expansion of the digital rulebook in recent years, it is right that the Commission considers whether the framework is proportionate and effective and identifies opportunities to reduce the cumulative burden.

Independent Retail Europe welcomes the call for evidence on the Digital Fitness Check, which represents the second stage of the European Commissions efforts to simplify the EUs digital regulatory framework following the adjustments introduced through the Digital Omnibus.

On 19 November 2025, the European Commission opened a call for evidence on the digital fitness check initiative. Amadeus welcomes the opportunity to comment on the European Commissions consultation on this initiative, as a next step to follow up on the digital omnibus. We refer to our position paper on the EU Commissions Digital Omnibus proposal as the baseline for simplification proposals.

In our Digital Omnibus Call for Evidence, AFME highlighted the need for a sectoral exemption from the Cyber Resilience Act, in light of the level of overlap with DORA. As a general overarching rule, it is vital that horizontal initiatives respect the primacy of sectoral legislation already in operation.

The Global Legal Entity Identifier Foundation (GLEIF) welcomes the opportunity to contribute to the European Commissions (EC) Digital Fitness Check assessing the cumulative impact of the EUs digital rulebook. As the European Union aims to simplify its digital regulatory framework and ensure greater coherence across legislative initiatives, GLEIF believes that the Legal Entity Identifier (LEI) can play an important…

The Dutch Fund and Asset Management Association (DUFAS) supports the European Commissions Digital Fitness Check, which evaluates the cumulative impact of EU digital regulation. Strengthening digital resilience, protecting investors, and safeguarding market integrity are important objectives for the asset management sector.

ACEA represents Europe's 16 major car, van, truck, and bus manufacturers. ACEA welcomes the Commissions Digital Fitness Check as an opportunity to improve regulatory coherence and create a more business-friendly framework that supports innovation, competitiveness, and Europes leadership in automotive technology and digital transformation.

DI calls for an ambitious simplification agenda beyond the existing omnibus proposals that prioritise practical, risk-based, and innovation-friendly rules, with, cross-legislation consistency, and real reductions in administrative burdens, aiming at at least a 25% reduction overall, 35% for SMEs. Find our detailed recommendations attached.

ABBL welcomes the Digital Fitness Check as an opportunity to address the cumulative impact of overlapping EU digital rules on regulated sectors. From the perspective of financial institutions, the main sources of complexity are not digital interfaces as such, but fragmented legal definitions, diverging notification triggers, parallel assessment obligations, and overlapping supervisory processes across GDPR, NIS2…

In response to the Digital Fitness Check Call for Evidence, Resmed urges policymakers to ensure a coherent, harmonised and innovation-friendly European Union digital framework for medical technologies. Over the past decade, the EU has developed an extensive body of legislation on data protection, health data, cybersecurity, artificial intelligence and product safety.

Finnish Energy, representing around 270 Finnish companies active in the production, acquisition, transmission and sale of electricity, gas, district heating and district cooling (and related services), supports the Digital Fitness Check objective of creating a simpler, clearer and more coherent EU legal framework for digitalisation.

The Association for Electronic Commercials (APEK) thanks for the opportunity to send input to the Digital Fitness Check consultation. APEK is an association of 575 e-commerce firms, entrepreneurs and professionals. Members include Czechia’s largest online shops, leading software companies and financial institutions. APEK represents the e-commerce market in communications with the media and government.

Filed in Czech · English published by the European Commission

SMEunited, the European SME organisation, emphasises that the Digital Fitness Check must guarantee that EU digital legislation supports the competitiveness of SMEs by being proportionate, coherent, and easy to implement.

EFAMA welcomes the European Commissions Digital Fitness Check and its objective of reviewing the EU Digital Rulebook. We consider that several horizontal digital regulations overlap with existing financial legislation, creating unnecessary duplication for asset managers. EFAMA therefore encourages the Commission to prioritise simplification and regulatory coherence across the digital rulebook.

NDM is grateful for the opportunity to respond to the Commissions consultation on the Digital Fitness Check on the need to reform of the EUs digital legislation. The Stockholm-based NDM (a Confederation of Swedish Business Organisations) comprises 24 Swedish industry and interest organisations from various sectors.

The EUs digital framework has grown complex, with multiple laws, such as the AI Act, Data Act, DSA, DMA and NIS2, creating overlapping compliance burdens for startups and scale-ups. The Digital Fitness Check should assess cumulative impacts, legal coherence, and innovation risks, prioritising consolidation over new legislation.

Technology Ireland is the leading representative body for the technology sector in Ireland consisting of the ICT, Digital and Software industry. The Association is a proactive membership organisation with companies located throughout Ireland. With origins dating back to 1968, the Association was formed in 2017 by the merger of ICT Ireland and the Irish Software Association.

The European Association of Urology (EAU) welcomes the opportunity to submit evidence to the Digital Fitness Check. The EAU has made significant investments in data infrastructure and analytics through the EAU UroEvidenceHub, a dedicated platform designed to generate high-quality datasets and real-world data.

Video Games Europe welcomes the opportunity to respond to the Call for Evidence on the Digital Fitness Check. In summary, we would like to make following recommendations: - The Digital Fitness Check should assess the full compliance burden on digital businesses, including from the EU consumer law acquis, the AI Act, and more.

Opinion in the context of the public consultation on the Digital Fitness Check The DatNet Data Trust Models Competence Network welcomes the European Commission’s initiative to collect opinions as part of a Digital Fitness Check. DatNet is happy to comment on the effects of the Data Governance Act (DGA) and the proposals put forward by the Digital Omnibus.

Filed in German · English published by the European Commission

The Digital Fitness Check is an important opportunity to strengthen Europes innovation capacity by improving the coherence and effectiveness of existing digital rules. Europes data economy remains fragmented, cross border data use is limited, and overlapping or conflicting obligations create high fixed compliance costs without proportional benefits.

The EUs digital regulatory framework has expanded rapidly over the past decade, including the GDPR, Data Act, Data Governance Act, Digital Services Act, and Digital Markets Act. While each of these initiatives pursues legitimate objectives, their cumulative effect has created a regulatory framework that is increasingly complex and difficult to navigate.

Regulatory simplification aimed at strengthening European competitiveness requires careful design. Removing safeguards alone does not tackle structural constraints affecting AI development in Europe. Additionally, while it is a significant step toward improving EU competitiveness, it lacks substance for addressing areas of public interest and benefits, such as governance and democracy.

As the EU agency for gender equality, we welcome the Commissions initiative to assess the fitness of the EU digital rulebook and provide evidence to feed into that process based on EIGEs research. The EU commitment to gender mainstreaming enshrined in the EU legal and policy framework on gender equality, in the Roadmap for Womens Rights and more recently the Gender Equality Strategy 2026-2030, would be improved by a…

Please find attached the coordinated submission of the Czech public administration to the public consultation on the Digital Fitness Check. This document reflects the consolidated position of the Czech Republic prepared within the national public administration.The input is both in CZ and EN.

Practical experience with reporting obligations (Annex V) The cumulative impact of digital legislation is particularly visible in the area of incident reporting. Example: cybersecurity incident affecting personal data If a company experiences a ransomware attack that disrupts service availability, affects network infrastructure and results in a personal data breach, several reporting regimes may apply…

Executive Summary Telefónica responds to the European Commissions Digital Fitness Check, stressing the need to simplify, modernise, and harmonise the EUs digital regulatory framework. The company argues that decades of accumulated and overlapping regulations have created a complex, inconsistent, and burdensome environment, reducing legal certainty and hindering innovation.

VNO-NCW and MKB-Nederland welcome the Digital Fitness Check as a step to stress-test the efficiency and effectiveness of the cumulative Digital Rulebook1. We stress the importance of European legislators to continuously assess, now and in the future, the coherence, clarity, proportionality, enforceability and required implementation efforts of the cumulative rules of the Digital Rulebook to support EUs…

To whom it may concern, I am writing top submit the comments of the International Center for Law & Economics (ICLE). These comments are organised as follows. Section II addresses the need for methodological rigour in the Fitness Check, including the assessment of indirect effects, the gap between projected and actual compliance costs, and the problem of last-minute legislative additions that bypass the impact-…

Ecommerce Europe, the united voice of digital commerce in Europe, welcomes the opportunity to provide feedback to the Call for Evidence on the Digital Fitness Check, the second stage of the Commissions plan to simplify the EUs digital rules following the adjustments under the Digital Omnibus.

My Agile Privacy shares the Commission's objective of making the European digital regulatory framework simpler, more coherent and more applicable in practice. Simplification is in the interest of all parties involved: of users, who would benefit from a more streamlined digital experience; of SMEs, which need stable and comprehensible rules to carry out their economic activities; and of the European digital…

IP2Innovate is a coalition of small and large research-intensive companies that develop innovative products and services in Europe, collectively holding thousands of European patents, as well as industry associations representing more than 40 companies.

From the FESE perspective, we observe several overlaps between sector-specific legislation such as DORA and horizontal regulation such as the NIS 2 Directive and the Cyber Resilience Act. Our longstanding position is to support the use of DORA as the reference framework for ICT security in the financial sector, and we therefore welcome recital 16, which recognises that DORA constitutes lex specialis to the NIS…

FEBIS members are business information providers (BIPs) whose core business model is to provide creditworthiness assessments, credit scores and business information reports on businesses for businesses. Business Information Providers operate at the intersection of EU digital, data, AML/CFT, company law and sector-specific rules.

Europe's technological competitiveness depends on a regulatory environment that genuinely enables digitalisation and data-driven research and innovation. CSC thanks the European Commission for the effort to check EU legislation broadly from this point of view, as EU legislation often remains too fragmented and complex, limiting cross border data use and slowing research and innovation.

ACT | The App Association (hereafter ACT) hereby submits comments to the European Commission in response to the Public Consultation on the Digital Fitness Check. ACT is a policy trade association for the small business technology developer community. Our members are entrepreneurs, innovators, and independent developers within the global app ecosystem who engage with verticals across every industry.

Middle Tech Europe (MTE) is a growing alliance whose members currently include Automattic, Dailymotion, Discord, Dropbox, Grindr, Patreon, Pinterest, Reddit, WeWard, Yahoo, and Yubo. Our members operate a wide variety of services, ranging from video-sharing and e-commerce to e-mail, forums, communication, media, online dating and hosting services representing the often missing middle-voice in tech policy…

As Europe seeks to strengthen its competitive position in an increasingly interconnected world, it must ensure that the rules are clear, simple, and predictable. BusinessEurope welcomes the European Commissions initiative to assess the effectiveness, coherence, and cumulative impact of the EU digital rulebook.

Fostering European Competitiveness Through Streamlined Compliance and Market-Driven Innovation As highlighted by recent strategic reports on the future of Europe, the cumulative administrative burden of overlapping digital rules is acting as a severe drag on European competitiveness, with over 60% of businesses citing regulation as a primary obstacle to investment.

From a practical perspective, the Conference of Independent Data Protection Supervisory Authorities of the Federal Government and the Länder (DSK) participates in the European Commission’s Digital Fitness Check on European Union data and digital law.

Filed in German · English published by the European Commission

We share the Commissions objective to stress-test the complementarity, efficiency and effectiveness of the digital rulebook. At a time when the EU is signalling it is ready to reform and compete globally, a review of its digital rules is a welcome development. This submission outlines four main recommendations for the Commissions ongoing consultation: 1. Return to tech-neutral and sector-specific rulemaking 2.

Consumer confidence in digitalisation and thus in the openness to use new innovative technologies and services is essential for the wider and desired digital transformation of society. The European Commission’s Digital Fitness Check offers the opportunity to close identified protection gaps in European digital legislation that are relevant to consumers, with the aim of further enhancing consumer trust and thus…

Filed in German · English published by the European Commission

The Confederation of Industry of the Czech Republic (SP ČR) has long supported reducing the regulatory burden and the systematic assessment of the cumulative impacts of European digital legislation. The Digital Fitness Check initiative could be an appropriate instrument to identify overlaps, inconsistencies, and disproportionate administrative requirements. However, we fundamentally disagree with its current timing.

The S Group welcomes the easing of digital regulation in terms of administrative burden, duplicative documentation and unnecessary permitting processes. Regulatory objectives should not be dismantled, but regulation should be better targeted to real risks and to what is essential for e-commerce, customer programmes and the practical functioning of a conglomerate.

Filed in Finnish · English published by the European Commission

The Center for AI and Digital Policy welcomes the opportunity to share our comments on the Digital Fitness Check. Our feedback focuses on the Digital Omnibus on AI to address its significant impact on the implementation of the AI Act.

The digital fitness check is the second stage of the Commission’s plan to simplify the EU’s digital rules, following the adjustments under the Digital Omnibus. To ensure that the EU’s digital rules are effective, proportionate and fit for the future, the Digital Fitness Check will analyse the interplay between the different rules, their cumulative impact on businesses, and how effectively they support EU…

Filed in Italian · English published by the European Commission

We welcome the opportunity to contribute to the Digital Fitness Check consultation and fully support the European Commissions ambition to bolster Europes economic competitiveness. For the continent to capture the AI opportunity, regulatory simplification and coherence are essential.

Gen Digital supports the Commissions digital simplification agenda, with a clear red line: simplify processes, not outcomes, and do not shift risk to citizens. It calls for unified incident reporting across NIS2, the Cyber Resilience Act, GDPR, DORA and related regimes, with aligned definitions, mandatory single entry reporting, and timelines that match standards readiness.

Trellix supports the Commissions simplification agenda, focusing on the Digital Omnibus, NIS2 simplification in the CSA2 context, and the Digital Fitness Check. We argues that fragmented incident reporting, inconsistent definitions, and duplicative compliance processes pull scarce cyber talent away from active defence and can slow response in the first hours of an attack.

INFOBALT, the Lithuanian association representing the countrys DigiTech sector, welcomes the European Commissions initiative to conduct a Digital Fitness Check assessing the cumulative impact of the EUs digital rulebook.

The existing digital rulebook provides a common regulatory framework, yet its practical impact is limited by overly complex, interpretation-heavy legislation that at times generates more uncertainty than clarity. Key regulationsmost notably the EU AI Actare drafted in broad and abstract terms, leaving businesses without the operational guidance needed for consistent and efficient implementation.

FIGIEFA is the European federation representing independent distributors of automotive replacement parts and their associated repair networks. FIGIEFA welcomes the European Commissions Digital Fitness Check as an opportunity to assess the cumulative impact of the EUs digital rulebook and ensure that it delivers on its core objectives: innovation, fair business environment in the EU and user empowerment.

BSA welcomes the European Commissions simplification efforts, notably through the two omnibus proposals from November 19, last year. The Omnibus introduces several positive developments that respond to long-standing industry concerns, including efforts to reduce fragmentation and conflicting requirements, eliminate redundant administrative obligations, and promote a more coherent and streamlined digital framework.

EPSU, the European Public Service Union, represents the voice of millions of public service workers. We call on the European Commission to refrain from any de-regulatory efforts in the name of flexibility for corporations or to enhance competitiveness.

Digitalisation and digital transformation are essential for competitiveness, resilience and innovation in the European economy. EU digital regulation should therefore support innovation and operational resilience rather than create unnecessary complexity or uncertainty. Legislation must be streamlined, coherent and proportionate across the EU digital and cybersecurity framework.

VDMA, the European machinery association, calls for an ambitious and far-reaching Digital Fitness Check. The Omnibus initiatives have streamlined certain details but have fallen short of addressing the lack of consistency and assessing the cumulative overall impact of the digital acquis. There is a need for general alignment of definitions and provisions across all legal acts.

Please find attached the GBIC comments on the European Commissions Digital Omnibus proposal of 19 November 2025. In particular, we would like to draw your attention to our remarks on the proposed new GDPR provision, especially concerning the processing of personal data in the context of AI training, as well as to our recommendations for ensuring that the envisaged uniform cybersecurity incident-reporting mechanism…

COCIR welcomes the European Commissions Digital Fitness Check as an opportunity to assess how EU digital legislation interacts with existing sectoral frameworks and how this interaction affects innovation, competitiveness, and the functioning of the Single Market. First, the Digital Fitness Check should ensure stronger coherence between horizontal digital legislation and sector-specific regulatory frameworks.

ZVEI supports the European Commissions initiative to conduct a Digital Fitness Check of the EUs digital regulatory framework. We see this process as an important opportunity to assess how the growing body of EU digital legislation interacts in practice and how it affects Europes competitiveness and innovation capacity.

The German Association of the Automotive Industry (VDA) welcomes the European Commissions decision to conduct a comprehensive Digital Fitness Check of the Unions digital regulatory framework. The automotive industry, as one of Europes largest industrial sectors and a central driver of research and innovation, is particularly dependent on a coherent, innovation friendly and neutral regulatory environment.

The Test & Measurement (T&M) Coalition, represented by its permanent secretariat EPPA, welcomes the Call for Evidence as an opportunity to provide input on the future direction of the EU digital rules. We highly appreciate the Commissions effort to simplify the digital rulebook.

Its important that the EU places competitiveness at the centre of its political reform agenda. The proposals for the Data and AI Omnibuses, the Regulation to establish EU Business Wallets, the Cybersecurity Package and the Digital Networks Act underline that the European Commission recognises in principle the necessity to cut unnecessary complexity, simplify regulatory requirements, and enhance coherence across the…

This submission responds to the European Commission's Call for Evidence for a Digital Fitness Check, which aims to assess the cumulative impact of the EUs digital legislation on competitiveness and identify synergies, good practices, and remaining gaps, overlaps and inconsistencies.

The EU’s digital rules are, in principle, an important legal framework. However, the digital rules impose a significant implementing burden on businesses. The review of the digital rules should follow the following principles: Harmonisation of different digital and sectoral legislation: 1. Terms/definitions within the different digital rules 2.

Filed in German · English published by the European Commission

Digitalisation and digital transformation are crucial for competitiveness and innovation. Digital regulation must support innovation, not bring it to a halt. This requires legislation to be streamlined and coherent.

Effective regulation must accurately reflect the underlying technological architecture it seeks to govern; laws that rely on outdated technical proxies or fail to recognize the realities of software engineering inadvertently stifle beneficial innovation. The Digital Fitness Check offers an opportunity to ensure the digital rulebook remains technologically sound and future-proof.

The digital fitness check is the second stage of the Commission’s plan to simplify the EU’s digital rules, following the adjustments under the Digital Omnibus. To ensure that the EU’s digital rules are effective, proportionate and fit for the future, the Digital Fitness Check will analyse the interplay between the different rules, their cumulative impact on businesses, and how effectively they support EU…

Filed in Italian · English published by the European Commission

We welcome the opportunity to share our perspective and participate in the call for evidence for the Digital Fitness Check Evaluation. Element is an encrypted messaging startup founded in the UK and with branches in Germany and France, which employs over 80 people, and develops solutions based on an open standard for secure communications called Matrix.

BSI as an EU Notified Body is in favour of enhanced digitalisation. We support the transparency and reduced duplication of efforts that documents require. Overall compliance of any particular product can not be assessed differently based on the size of the manufacturer/producer/provider. Notified Bodies can not be expected to lose money to fulfil their obligations in legislation.

White paper on Disability Inclusive Digital Legislative Environments Protecting the Rights of Persons with Disabilities in the age of Digitalization and Artificial Intelligence in the Digital Fitness Check. This whitepaper brings together the legislative obligations concerning Digitalization and Artificial Intelligence in Europe as well as the obligation in protection of human rights to ensure full participation of…

Technology Industries of Finland sets out these recommendations to contribute to the Digital Fitness Check and to support a regulatory approach that strengthens Europes competitiveness in the digital domain. Europe should restore the link between regulation and the Single Market. Instead of rushed volume and omnibus-scale mistakes, regulation should be guided by necessity, consistency, andabove allquality.

ABSTRACT - With approximately 180,000 active and retired managers, senior executives, and high-level professionals, Federmanager is the leading association representing Italian management. It manages their contractual, institutional, social, professional, and cultural interests.

The European Savings and Retail Banking Group (ESBG) welcomes the opportunity to contribute to the simplification efforts of the EUs digital rulebook. Please find attached our contribution, focused on overlapping areas of legislation, harmonization of horizontal and sectoral legislation, implementation timelines and standards and clarification and overlaps in definitions throughout the digital rulebook.

The Open Search Foundation e.V. welcomes the opportunity to provide feedback regarding the interplay between the different EU digital rules, their cumulative impact on businesses, and how effectively they support the EUs competitiveness, values and fundamental rights. Please find our policy paper including the assessment in the context of a European Web Data Infrastructure attached.

The Digital Fitness Check cannot assess cumulative impact on competitiveness without examining the European open source professional services sector - a sector currently invisible in EU classification systems. This response connects the newly established Digital Commons EDIC with the fitness check's objectives, arguing that procurement directives must be included in scope, compliance burden must be assessed against…

HOPE thinks that great care must be taken that simplification measures, primarily requested by technology companies to reduce administrative and cost burdens, do not generate detrimental effects (privacy, liability, safety, security, uncertainty) for the institutions and individuals charged with overseeing and using advanced digital tools in healthcare, including hospital staff, healthcare workers, and patients.

UNIFE welcomes the opportunity to reply to this public consultation and to contribute constructively to the effective and proportionate implementation of the Cyber Resilience Act (CRA) and the Data Act. As the European rail supply industry association, UNIFE and its members fully support the objectives of strengthening cybersecurity across products with digital elements and improving access to and use of industrial…

This document sets out AMETIC’s position on the European Commission’s Digital Omnibus proposal, with a particular focus on its implications for the Artificial Intelligence Act (RIA). AMETIC welcomes the general approach of the proposal, aimed at adjusting implementation deadlines, simplifying regulatory burdens and eliminating redundant formalities, while maintaining the essential objective of ensuring trustworthy…

Filed in Spanish · English published by the European Commission

This response addresses the Digital Fitness Check from the perspective of a UK data protection practitioner working with organisations that operate across UK and EU jurisdictions. Our focus is on autonomous AI agents and the regulatory challenges they present under both the GDPR and the AI Act. The proposed Digital Omnibus amendments reduce administrative burden, which we welcome.

1. Regulatory harmonization We consider it essential to harmonize the requirements set out by the various regulations (e.g., DORA, GDPR, NIS2). In this regard, within incident management, it would be useful to introduce a unified classification model to achieve better alignment of incident classification criteria.

Introducing a subjective approach of the definition of personal data under article 4.1 seems to lower the European vision of what is to be considered as part of the private sphere of individuals, especially in the digital / online world and businesses. It looks like it tends to align it with the north American definition of PII.

Especially for Trust Services under Regulations 910/2014 and 2024/1183, a key challenge arises from their subjection to multiple overlapping laws.​ These include the GDPR (EU 2016/679), Cyber Resilience Act (EU 2024/12847), DORA (EU 2022/2553) as a financial sector supplier, Critical Entity Resilience (EU 2022/2557), and NIS2 (EU 2022/2555).

The EU digital regulatory framework imposes fragmented and technically inconsistent logging and evidence requirements across the AI Act (Articles 1214), MiFID II/MiFIR (RTS 6, RTS 25), MAR (order sequence integrity), and GDPR (erasure and minimisation).

Europe has made significant strides in establishing the Digital Single Market (DSM). Since launching the DSM strategy in 2015, the EU has adopted several digital regulations to harmonise rules across Member States, promoting regulatory consistency. However, the DSM remains incomplete.

The most important act in digital era is to include perfect lawyers involved with regulations to be available as complement to all legal actions we Can support via Digital Tools as Well as Omnibus to have controll over all companies & activities as We check up all important decisions to prevent harm Or create safety for the society.