Simplification of the implementation of harmonised rules on artificial intelligence – Digital Omnibus on AI (Omnibus VII)

Please see our comments on the proposed Digital Omnibus for the GDPR and ePrivacy Directive from the perspective of a consumer and civil rights non-profit that helps people exercise their right to data protection in the attached PDF.

Digital Omnibus-VO: Vorschläge, Folgen, Änderungsvorschläge Stellungnahme zum Vorschlag der Kommission COM (2025) 837 final vom 19.11.2025 I Neue Rechtsgrundlagen – und deren Bedeutung für die digitale Wirtschaft Der Vorschlag für die Digital Omnibus-Verordnung („Omnibus“) bezweckt, datenregulierende Rechtsvorschriften zu vereinfachen und zu konsolidieren.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Free ICT Europe welcome the call to contribute to the European Commissions consultation on the Digital Omnibus Initiative. Our response highlights how simplification can strengthennot weakenEuropes digital sovereignty, the circular economy, and the competitiveness of SMEs and Small MidCaps active in the ICT aftermarket.

Syntonym welcomes the opportunity to provide feedback on the proposed amendments to the GDPR within the Digital Omnibus package. As a developer of privacy-preserving technologies for camera-collected data and visual AI systems, Syntonym focuses its comments on two elements of the proposal that will significantly affect the governance of visual data and AI development: (1) the proposed amendment to the definition of…

Privacy Next Feedback on the Digital Omnibus Proposal COM(2025)837 Introduction 1. The European Commission’s Digital Omnibus proposal comes at a time when the regional organisation and its Member States are pursuing a range of policy priorities competitiveness, simplification, better enforcement, increased cooperation, and more efficiency are all identified as necessary matters to address.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

We welcome the opportunity to provide feedback on the European Commissions consultation on the Digital Omnibus on Data. Please find attached the German AI Associations (KI Bundesverband) feedback outlining our assessment of the proposed amendments and recommendations to support responsible AI development while ensuring strong data protection safeguards.

The EAIF welcomes the opportunity to provide feedback on the European Commissions consultation on the Digital Omnibus on Data. Please find attached the European AI Forums feedback outlining our assessment of the proposed amendments and recommendations to ensure a coherent, proportionate and innovation-compatible data protection framework for AI development in Europe.

2026-03-15 Ref. Ares(2026)2788231 - 15/03/2026 AI Sweden’s comments on the Digital Omnibus AI Sweden is the Swedish national center for applied artificial intelligence. Our mission is to accelerate the use of AI for the benefit of our society, our competitiveness, and for everyone living in Sweden. We are broadly funded and not for profit, as a part of Lindholmen Science Park.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The National Bar of Attorneys-at-Law represents nearly 60,000 of attorneys-at-law in Poland. With regard to the role of the self-government of attorneys-at-law as a profession of public trust entrusted with the protection of individual rights and the public interest, we would like to draw the attention to the practical implications of the proposed Digital Omnibus package.

TikTok Feedback on the European Commission’s Proposal for a Digital Omnibus Executive summary We are supportive of the European Commission’s commitment to reducing the administrative burden of EU regulation, including through simplification, and enhancing European competitiveness.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Dedalus welcomes the opportunity to provide input to the European Commissions Digital Omnibus proposal. As a European leader in Software as a Medical Device (SaMD) and AIenabled medical devices (MDAI), serving large hospital networks across the Union, Dedalus strongly supports the objective of creating a predictable, innovationfriendly, and clinically safe digital regulatory environment.

We welcome the Commission's proposals on simplifying the regulations. However, we consider several aspects as being problematic, and therefore do not recommend accepting them at this stage. We summarise our views in the provided document as follows: (1) Definition of Personal Data: should be rejected as it drastically changes the scope of the GDPR, affects its rights, and has a material impact on the fundamental…

AI Chamber Submission on the European Commission’s “Digital Omnibus” package AI Chamber welcomes the direction the European Commission has taken with the proposed “Digital Omnibus” package. We see it as a necessary step toward reducing regulatory friction in Europe’s digital economy.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

CrowdStrike welcomes the opportunity to respond to the European Commission's Call for Feedback on the Digital Omnibus Proposal (COM(2025)837). As a leading global cybersecurity provider delivering AI-powered, cloud-native protection to enterprises worldwide, we strongly support the Commission's objective to simplify the EU digital rulebook while maintaining high standards.

CrowdStrike appreciates the opportunity to contribute to the European Commissions Call for Evidence on the Digital Omnibus on AI and welcomes the Commissions efforts to streamline implementation of the AI Act in a way that improves legal certainty and reduces unnecessary administrative burden while preserving high levels of safety, security, and fundamental rights protection.

The Austrian Social Insurance welcomes the European Commissions proposals for simplifying and streamlining data protection and processing governance in order to guarantee a timely, smooth and efficient enforcement of certain provisions of the AI Act as well as the General Data Protection Regulation (GDPR).

Credo AI's submission makes a single, sustained argument. The EU AI Act's normative foundations are sound and should not be reopened, but the regulatory architecture built around them is operationally fragmented in ways that will predictably undermine the Act's protective objectives unless the Omnibus intervenes decisively. Simplification is not a neutral concept.

Fostering regulatory coherence and legal certainty is essential to safeguard high standards of healthcare quality and patient safety, while enabling innovation in the medical sector. We welcome the establishment of a single-entry point for cybersecurity incident reporting via ENISA: incidents with patient safety implications that qualify as MDR vigilance events should continue to be reported through established…

As one of the worlds leading scientific innovation companies, Johnson & Johnson views the AI Omnibus as a critical opportunity to preserve and reinforce recent regulatory improvements, while ensuring that the EUs AI framework delivers regulatory coherence and legal certainty. This is essential to safeguard high standards of healthcare quality and patient safety, while enabling innovation in the medical sector.

Eurocities welcomes this opportunity to contribute to the European Commission's call for evidence on the adoption of a Proposal for a Regulation of the European Parliament and of the Council amending Regulations (EU) 2024/1689 and (EU) 2018/1139 as regards the simplification of the implementation of harmonised rules on artificial intelligence (Digital Omnibus on AI). Please find our input below.

Executive Summary Prighter welcomes the European Commissions initiative to simplify the digital regulatory framework and reduce administrative burdens, particularly for SMEs and the newly introduced category of small mid-cap companies (SMCs). Our submission focuses on the practical applicability of the proposed changes.

Executive Summary Prighter welcomes the Commissions Digital Omnibus proposal as a meaningful step towards simplifying the AI regulatory framework and reducing administrative burdens across the Single Market. Drawing upon feedback from our clients, including SMEs and non-EU-providers, Prighters assessment is grounded in the practical operability of the proposed changes.

AEPO-ARTIS POSITION ON THE DIGITAL OMNIBUS AEPO-ARTIS is a non-profit organisation that represents 42 European performers collective management organisations (CMOs) from 30 European countries. The number of performers from the music and audiovisual sectors represented by our members can be estimated at 650.000.

The Confederation of Swedish Enterprise welcomes the opportunity to respond to this consultation. For ease of reference, our detailed responses and recommendations are set out in the attached. The omnibus proposals must not stand alone but should be the first in a series of reforms. SN is pleased to see the Commissions committed to further simplification initiatives via the Digital Fitness Check.

The European CMP Association represents Consent Management Platform (CMP) providers operating across the European Union. Our members work closely with a wide range of organisations across Europe, from small businesses to large online services, that rely on consent management solutions to implement privacy choices and comply with EU data protection rules.

In general, EGDF supports clarifying and simplifying EU regulations to strengthen Europe's competitiveness. However, the Commission's proposal to repeal the P2B regulation would significantly increase the market risk of European operators and thus weaken their competitive and value chain position.

We welcome the European Commissions initiative to introduce the Digital Omnibus package and would like to express our appreciation for the Commissions efforts to simplify the EU digital regulatory framework and ensure the effective and innovation-friendly implementation of the Artificial Intelligence Act (AI Act).

The EU is at a critical turning point. While the United States and China surge ahead in artificial intelligence (AI) and digital innovation, Europe's share of cumulative global market capitalisation of the technology, media, and telecom sector has plunged from 30% in 2000 to 7% today. Not a single one of the worlds ten largest companies is European.

Proposal on the Digital Omnibus on AI Revisions to the Commission’s proposal and provisions that shouldn't be amended March 2026 I. Executive Summary This document proposes various changes to the AI Act and the Commission’s proposed amendments in the Digital Omnibus on AI, as well as pointing out amendments proposed by MEPs that we recommend rejecting: 1.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The German County Association welcomes the opportunity to contribute to this consultation. The attached document provides the Associations comments on the Commissions Digital Omnibus initiative, reflecting the perspective of German counties and their role in the implementation of digital legislation and the provision of public services.

Filed in German · English published by the European Commission

Berlin/Brussels, 13 March 2026 Statement of the German AI Association on the: Digital Omnibus on AI1 Executive Summary The German AI Association / KI Bundesverband (KIBV) broadly welcomes the Digital Omnibus on AI as a necessary corrective to an implementation framework that has imposed disproportionate burdens on European startups, SMEs, and Small Mid-Cap Companies.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Dear receiver, Please find attached Alliance Digitale's feedback on the Commission's Digital Omnibus proposal. The Digital Marketing and Data Association - Alliance Digitale is dedicated to representing all professions and professionals linked to data and digital marketing in France, with the aim of promoting their development and defending their interests.

The European AI Forum (EAIF) welcomes the opportunity to contribute to this consultation and provide feedback on the proposal. The attached document sets out our detailed feedback on the Digital Omnibus on AI, reflecting the perspective of European AI companies and startup ecosystems. We hope our contribution can support the development of a workable and proportionate implementation framework.

Legal Research Institute of the Romanian Academy (ICJ) welcomes the European Commissions initiative to simplify the digital legislative framework through the Digital Omnibus package, while emphasizing the need to preserve the balance between technological innovation and the effective protection of the fundamental rights of data subjects.

Digital Omnibus: supporting innovation and consumer protection in the insurance sector Insurance Europe expresses its support for the overarching aim of the European Commission’s Digital Omnibus initiative. European insurers are challenged by a growing patchwork of complex and sometimes inconsistent digital regulations.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Please find attached the feedback for SRI and geste, 2 French trade bodies on Article 88. Geste and SRI represent Frances leading online media organisations including television, radio, press publishers and digital-native media as well as their advertising sales houses.

Filed in French · English published by the European Commission

Insurance Europe views on the Digital Omnibus on AI Insurance Europe expresses its support for the overarching aim of the European Commission’s Digital Omnibus initiative – to lessen the administrative and compliance burdens faced by European businesses arising from the implementation of multiple regulations within the EU’s digital framework and to simplify and streamline existing rules to boost competitiveness.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The European Broadcasting Union is the worlds leading alliance of public service media (PSM). The EBU has 115 member organizations in 56 countries who operate nearly 2,000 television, radio and online channels and services and reach an audience of more than one billion people in 160 languages.

Unrestricted IATA Comments on the Proposed Amendments to the GDPR under the Digital Omnibus Regulation 1. Proposed Amendments to Article 9 GDPR – Processing of Biometric Data The proposed new exception under Article 9 of the GDPR would allow the processing of biometric data for the purpose of 1:1 identity verification, but only when the biometric data or the technical means used for verification remain fully under…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Proofpoint welcomes the European Commissions Digital Packagethe Digital Omnibus and the Digital Omnibus on AI (COM(2025) 836 and COM(2025) 837)as a pragmatic step toward simplifying Europes digital rulebook while maintaining high protection standards.

Vodafone welcomes the Commission's ambition to enhance the efficiency and competitiveness of the European digital landscape through simplifying and streamlining digital regulation, via the Digital Omnibus proposal. Resilient and modern connectivity infrastructure, underpinned by strong, safe networks, is a fundamental enabler of this boost for Europe's digital future.

The European Council for Motor Trades and Repairs (CECRA) is the European federation of professional associations representing the interests of automotive dealers and repairers. Through its members, national motor trade associations and European Dealer Councils, CECRA represents the interests of 336,720 automotive businesses all over Europe and beyond.

The German Childrens Fund is committed to democratic education through participation, sufficient opportunities for play, cultural education, competent media handling and overcoming child poverty in Germany. It focuses on childrens rights according to the UN Convention on the Rights of the Child and for Childrens Rights in the digital world particularly the General Comment 25.

Please find enclosed the feedback of Veridas in the context of the European Commissions public consultation on simplification: digital package and omnibus. Our contributions focus on ensuring a risk-based harmonization between the AI Act and the GDPR, redefining user sovereignty through functional control in secure environments, and safeguarding the technical viability of European AI development by normalizing bias…

Please find enclosed the feedback of Veridas in the context of the European Commissions public consultation on simplification: digital package and omnibus. Our contributions focus on ensuring a risk-based harmonization between the AI Act and the GDPR, redefining user sovereignty through functional control in secure environments, and safeguarding the technical viability of European AI development by normalizing bias…

AIM - the European Brand Association's feedback is as follows on this initiative. We call for the alignment of the applicability date for Annex I and Annex II high-risk AI systems to 2 August 2028 in order to avoid conditional timelines linked to future standards and guidance that risk creating legal uncertainty; A clear, predictable and uniform implementation timeline for high-risk AI obligations that provides…

ACCIS broadly supports the Digital Omnibus proposal as a meaningful step towards reducing compliance costs, unlocking the potential of data-driven markets, and strengthening the EU's competitiveness objectives our members embody through their role in enabling responsible lending across the internal market.

Business & Science Poland (BSP) welcomes the European Commissions proposal for the Digital Omnibus, introduced as part of the broader simplification agenda. The initiative represents a timely effort to rationalise elements of the EUs increasingly complex digital regulatory framework.

AIM - the European Brand Association's feedback is as follows on Digital Omnibus proposal. We would urge: A proportionate, risk-based application of new Article 88a on storing and accessing personal data in terminal equipment, recognising distinctions between low-risk first-party uses and cross-site tracking; Careful calibration of Article 88b on automated and machine-readable consent signals to ensure technical…

Bonn, Bucharest, Dublin, Lisbon, Luxembourg, Madrid, Milan, Paris, The Hague, Vienna, Warsaw Omnibus Survey Report Analysis of the CEDPO Questionnaire on Omnibus IV and VII March 2026 Contact information: https://cedpo.eu [email removed] 1 Contents Introduction .................................................................................................................4 Results Analysis…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

MFE-MEDIAFOREUROPE – Posi on Paper on the Digital Omnibus MFE-MEDIAFOREUROPE is an interna onal holding that brings together leading commercial broadcasters across Italy, Spain, Germany, Austria Switzerland and Portugal. MFE-MEDIAFOREUROPE is headquartered in Amsterdam (NL), and fiscal resident in the countries where it operates. It controls Mediaset S.p.A.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Microsoft welcomes the European Commissions ongoing work on Digital Simplification. By embracing a forward-looking and ambitious approach to simplifying key digital rules, the EU can ensure a pivotal step-change towards strengthening Europes competitiveness and meaningfully contribute to achieving its AI continent ambitions.

ESR Response to the Digital Omnibus on Data, Cybersecurity & Privacy Please find below a summary of the European Society of Radiologys (ESR) response to the European Commissions Digital Omnibus on AI. The full response is provided in the attachment. The ESR is committed to maintaining constructive dialogue with the Commission and other stakeholders moving forward.

DIGITAL OMNIBUS – DATA PROTECTION Contribution to the public consultation launched by the European Commission on the Proposal for a Regulation of the European Parliament and of the Council COM(2025) 837 amending Regulation (EU) 2016/679 BonelliErede, drawing on our experience and insights from clients, welcomes the opportunity to contribute to the public consultation on the Proposal for a Regulation of the European…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Please find below a summary of the European Society of Radiologys (ESR) response to the European Commissions Digital Omnibus on AI. The full response is provided in the attachment. The ESR is committed to maintaining constructive dialogue with the Commission and other stakeholders moving forward.

BioMed Alliance believes that certain aspects of the Omnibus proposals might reduce some of the barriers to data driven health research, and quality assurance of AI-based software tools implemented in clinical practice, while others may open the door for potential misuse and reidentification of patients based on sensitive health data.

Health data is one of the most valuable resources for improving cancer prevention, diagnosis, treatment, and survivorship outcomes. Through its Digital Health Network and Research Policy Network, the European Cancer Organisation (ECO) has consistently highlighted that Europe can only fully harness the potential of cancer data through a framework that is sufficiently open to enable scientific progress while remaining…

Scientific research, especially health and biomedical research rely on access to personal data, for example to develop AI tools for earlier diagnosis, personalised treatments that enable cost-effective healthcare. The GDPR has strengthened privacy and data protection, but fragmented national interpretations hinder cross-border research, slowing innovation and reducing Europes competitiveness potential.

IDEMIA Public Security submits in the attached document some comments and propositions of amendments to support the objectives of the Digital Omnibus while ensuring legal clarity, and coherence in the treatment of biometric data.

Europe is entering a decisive phase in shaping how AI, data legislation and digital markets will function for decades to come. This paper sets out how the Digital Omnibus can strengthen repairability, interoperability and fair competitionwhile preventing new forms of lockin across AIenabled hardware, cloud services and IoT ecosystems.

The AI Standards Lab has published analysis and recommendations about the AI Act omnibus proposal (COM(2025) 836) online on 20 Jan 2026. This feedback submission submits the same pdf file available online at the link https://aistandardslab.org/recommendations-on-the-digital-omnibus-amendments-to-the-eu-ai-act/ .

Audicom Srl (“Audicom”) is the Italian company resulting from the merger by incorporation of Audiweb Srl and Audipress Srl, effective as of March 1st, 2023. Audicom’s corporate purpose is carrying out and offering to the market an integrated audience measurement service for multimedia, editorial and/or advertising content through both the Internet and paper press.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Euralarm actively supports the development of forward-looking regulatory frameworks that enable technological progress, foster legal certainty and protect citizens, infrastructure and assets across Europe. The attached paper sets out Euralarms strategic assessment of the Digital Omnibus initiative on Artificial Intelligence Regulation.

VAUNET Position Paper on the Proposal of the European Commission from 19 November 2025 for a Regulation of the European Parliament and the Council ,amending Regulations (EU) 2016/679, (EU) 2018/1724, (EU) 2018/1725, (EU) 2023/2854 and Directives 2002/58/EC, (EU) 2022/2555 and (EU) 2022/2557 as regards the simplification of the digital legislative framework, and repealing Regulations (EU) 2018/1807, (EU) 2019/1150…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Euralarm actively supports the development of forward-looking regulatory frameworks that enable technological progress, foster legal certainty and protect citizens, infrastructure and assets across Europe. The attached paper sets out Euralarms strategic assessment of the Digital Omnibus initiative on Data and Cybersecurity.

PensionsEurope's position paper on the EC digital omnibus regulation proposal March 2026 www.pensionseurope.eu PensionsEurope acknowledges the Commission’s initiative to simplify the EU digital rulebook through the digital omnibus package.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

France Assureurs is the common name of the Fédération Française de l’Assurance (French Insurance Federation) Fédération Française de l’Assurance is registered under EU transparency number No.5149794935-37 FRANCE ASSUREURS POSITION ON THE DIGITAL OMNIBUS PACKAGE The insurance sector is facing an unprecedented level of regulatory inflation at the European level, characterised by the proliferation of Level 1, Level 2…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Match Groups position on the Digital Omnibus advocates for a risk-based EU regulatory framework that distinguishes between intrusive biometric surveillance and targeted "liveness" verification used for user safety as part of the GDPR simplification. The policy recommendations aim to reconcile modern privacy standards with the evolving reality of online fraud.

France Assureurs is the common name of the Fédération Française de l’Assurance (French Insurance Federation) Fédération Française de l’Assurance is registered under EU transparency number No.5149794935-37 FRANCE ASSUREURS POSITION ON THE DIGITAL OMNIBUS AI The insurance sector is facing an unprecedented level of regulatory inflation at the European level, characterised by the proliferation of Level 1, Level 2 and…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

CLEPA, the European Association of Automotive Suppliers, represents more than 3,000 companies across the automotive supply chain and is recognised as a key interlocutor for the sector. CLEPA welcomes the European Commissions initiative to revise the EU digital acquis through the Digital Omnibus proposal, highlighting the urgent need to harmonise and simplify overlapping digital and data regulations that affect…

The EACB welcomes the Commissions objective to streamline and align elements of the EUs digital regulatory framework through the Digital Omnibus. For cooperative banks, highly regulated, data-intensive and subject to multiple overlapping frameworks, clarity, coherence and proportionality are essential to ensure that obligations remain workable without undermining consumer protection or security.

ACT | The App Association (hereafter ACT) hereby submits comments to the European Commission in response to the Public Consultation on Simplification - digital package and omnibus. ACT is a policy trade association for the small business technology developer community.

Consultation on the European Commission’s Digital Package and Omnibus. Response from the American Chamber of Commerce Ireland (AmCham Ireland) to the European Commission on the Public Consultation on the Digital Package and Omnibus.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

COCIR Response to the European Commission Consultation on the AI Omnibus Proposal March 2026 We welcome the European Commission’s initiative to simplify and improve the implementation of harmonised rules on artificial intelligence through the AI Omnibus proposal.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Please see attached, Workdays position on the European Commissions Digital Omnibus Regulations, identifying amendments we support and where we believe additional changes are required to clarify or simplify further. Workday is the enterprise AI platform for managing people, money and agents.

Eurofinas Response to the European Commission´s Digital Fitness Check Eurofinas, representing specialised consumer credit providers at EU level, welcomes the Commission’s Digital Fitness Check as a timely opportunity to assess whether the EU’s digital regulatory framework operates coherently, proportionately and competitively in practice. The provision of consumer credit is inherently data-driven.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

On 19 November 2025, the European Commission issued two proposals at the core of the current public consultation the Digital Omnibus Proposal and the AI Omnibus Proposal. Both proposals include a number of simplifying amendments of the current digital acquis ranging from data protection, to cyber-security, to AI governance.

Please find attached the feedback on Article 88b from 2 French trade bodies, GESTE and SRI. GESTE and SRI represent Frances leading online media organisations including television, radio, press publishers and digital-native media as well as their advertising sales houses.

Eurofinas Response to the European Commission´s Digital Fitness Check Eurofinas, representing specialised consumer credit providers at EU level, welcomes the Commission’s Digital Fitness Check as a timely opportunity to assess whether the EU’s digital regulatory framework operates coherently, proportionately and competitively in practice. The provision of consumer credit is inherently data-driven.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

DANSK ERHVERV Børsgade 4 1217 København K www.danskerhverv.dk [email removed] T. [phone removed] Ref. Ares(2026)2752595 - 13/03/2026 13. march 2026 Consultation feedback on the Digital Omnibus on Data & Cyber and the Digital Omnibus on AI General remarks The Danish Chamber of Commerce welcomes the European Commission’s initiative to simplify the EU’s digital regulatory framework through the Digital Omnibus proposals…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

**BDVA Response to EU Digital Omnibus Consultation Summary** The Big Data Value Association (BDVA) broadly welcoms the effort to reduce administrative barriers to AI innovation while maintaining the EU's value-based approach to fundamental rights. The attached document addresses five key areas where BDVA offers analysis and recommendations.

DANSK ERHVERV Børsgade 4 1217 København K www.danskerhverv.dk [email removed] T. [phone removed] Ref. Ares(2026)2752653 - 13/03/2026 13. march 2026 Consultation feedback on the Digital Omnibus on Data & Cyber and the Digital Omnibus on AI General remarks The Danish Chamber of Commerce welcomes the European Commission’s initiative to simplify the EU’s digital regulatory framework through the Digital Omnibus proposals…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Confindustria Radio Televisioni expresses its appreciation for the work done by the European Commission in boosting the simplification of regulations at European level of central issues for the radio and television sector, and beyond.

On 19 November 2025, the European Commission issued two proposals at the core of the current public consultation the Digital Omnibus Proposal and the AI Omnibus Proposal. Both proposals include a number of simplifying amendments of the current digital acquis ranging from data protection, to cyber-security, to AI governance.

Decathlon welcomes the European Commission's proposal on the Digital Omnibus and appreciates the opportunity to provide feedback. As a global and European leader in the sporting goods industry, with a deep commitment to digital innovation, we believe that a clear, harmonised, and targeted legal environment is essential for European businesses to remain competitive.

2026-03-13 AI Sweden’s Comments on the Digital Omnibus on AIs AI Sweden is the Swedish national center for applied artificial intelligence. Our mission is to accelerate the use of AI for the benefit of our society, our competitiveness, and for everyone living in Sweden. We are broadly funded and not for profit, as a part of Lindholmen Science Park.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Dutch local and regional authorities welcome efforts to reduce unnecessary and disproportionate regulatory burdens in the EU digital rulebook. In recent years, digital legislation has expanded significantly. Local and regional authorities have gained extensive experience in implementing this framework and have identified inconsistencies between regulations and duplicative reporting obligations.

Decathlon welcomes the European Commission's proposal on the Digital Omnibus on AI and appreciates the opportunity to provide feedback. As a global and European leader in the sporting goods industry, with a deep commitment to digital innovation, we believe that a clear, harmonised, and targeted legal environment is essential for European businesses to remain competitive.

Pour Demain welcomes the Commission's Digital Omnibus on AI as a timely opportunity to ensure the AI Act is implemented smoothly and proportionately. We support the goal of reducing unnecessary administrative burdens, and we recognise the logic of centralising enforcement of AI systems based on general-purpose AI (GPAI) models within the AI Office under the amended Article 75.

13 March 2026 VIA ELECTRONIC SUBMISSION Re: Proposal for a Digital Omnibus The Cybersecurity Coalition (“the Coalition”) submits the following comments in response to the European Commission’s consultation on the proposal for a Regulation of the European Parliament and of the Council amending Regulations (EU) 2016/679, (EU) 2018/1724, (EU) 2018/1725, (EU) 2023/2854 and Directives 2002/58/EC, (EU) 2022/2555 and (EU)…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The AI Act hinders the innovation and competitiveness of European industry in key areas. There is an urgent need for reform in three areas in particular in order to reduce double regulation and burdens on industry. Our key demands are: 1. The industrial use of AI is already covered by sectoral regulation.

Feedback – COM(2025)837 About us Sveriges Annonsörer (eng: Swedish Association of Advertisers) is the industry association for Swedish advertisers and was founded in 1924. Sveriges Annonsörer has about 400 member companies/organizations, which together account for more than half of the total advertising and media investments in Sweden.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The European Crypto Initiative (EUCI) welcomes the Digital Omnibus as an important opportunity to improve legal certainty, simplify the EU digital rulebook, and ensure that core digital legislation remains technically accurate, proportionate, and innovation-compatible for decentralised, permissionless blockchain infrastructures.

The European FinTech Association (EFA) supports the European Commission's objective of boosting European competitiveness through simplification. Measures aimed at reducing the regulatory burden, increasing legal certainty and promoting a balanced approach are key to boosting the Digital Single Market.

Train de mesures omnibus sur le numérique ( Digital Omnibus ) Contribution du groupe SNCF 13 mars 2026 Le groupe SNCF accueille favorablement l’omnibus numérique, dont l’objectif général est de réduire les coûts administratifs de mise en conformité supportés par les entreprises pour appliquer plusieurs dispositions réglementaires de l’acquis de l’Union dans le domaine du numérique .

Filed in French · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

POSITION NETCOMM 2026 NETCOMM POSITION DIGITAL OMNIBUS Netcomm welcomes the initiative promoted by the European legislator concerning the EU Digital Omnibus package, given its stated objective of regulatory simplification and enhanced operational efficiency within the frameworks of the GDPR, the AI Act, and NIS2/DORA.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

We support many of the simplification measures outlined in this proposal; in particular, the amendment to Article 4 to ensure obligations to install AI literacy within businesses that are proportionate to the existing operational knowledge and the context in which AI is used.

The Digital Omnibus represents a positive step forward in simplifying and improving the coherence of existing EU digital legislations, with the aim of enhancing legal certainty and operational efficiency. Dassault Systèmes appreciates the publication of the two Omnibus, AI and Digital, recognizing its potential to clarify certain obligations and address some of the practical challenges faced by industry actors.

Booking.com welcomes the Commissions simplification agenda. As a global travel platform, founded and headquartered in the Netherlands, we share the European Commissions objective to boost European competitiveness, including by addressing regulatory complexity. In this spirit, we broadly welcome the two Digital Omnibus proposals as a step in the right direction.

Allied For Startups welcomes the Commissions AI and Digital Omnibus proposals as a long-overdue step toward a clearer and more coherent regulatory framework for Europes digital economy. Startups and scale-ups, particularly fast-growing companies with limited compliance capacity, have long faced overlapping obligations, fragmented enforcement, and legal uncertainty that divert scarce resources from innovation and…

The European press publishers' associations EMMA and ENPA appreciate this opportunity to provide feedback on the proposal for a Digital Omnibus. Please find attached our position paper, that focuses on proposed new GDPR provisions in the Digital Omnibus on data.

APORTACIÓN ASEDIE CONSULTA PÚBLICA SIMPLIFICACIÓN: PAQUETE DIGITAL Y ÓMNIBUS Madrid, 13 de marzo de 2025 Salvo que se indique lo contrario, se autoriza la reutilización de este documento bajo una licencia Creative Commons Attribution 4.0 International (CC-BY 4.0).

Filed in Spanish · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Council of European Dentists (CED), representing over 340,000 dentists across Europe, welcomes the European Commissions ambition to foster innovation through the Digital Omnibus package. However, the healthcare and dental profession is built on a foundation of unwavering patient confidentiality.

The Association of German Public Banks (VÖB) welcomes the European Commissions objective to modernise, streamline and simplify the EU digital legislative framework while preserving a high level of protection for fundamental rights. For public-sector banks, promotional banks and Landesbanken, legally certain and operationally workable rules are of particular importance.

Please find attached Opinion No 21/2026, prepared by the Legislative Committee on Information Rights of the German Bar Association (DAV), on the European Commission’s proposal for a Regulation COM(2025) 837 final (Digital Omnibus Regulation). The DAV welcomes the Commission’s plan to simplify and cut red tape in European digital legislation.

Filed in German · English published by the European Commission

While there are several valuable elements in the Digital Omnibus proposal, there are four high-priority changes that would make a significant impact: (1) Remove proposed Article 88b amending GDPR, and fix cookie banners by excluding low-risk activities from requiring consent, (2) Enact the revised definition of personal data in the proposed GDPR new Article 41a, (3) Enshrine the use of data for AI training in new…

Enel, a multinational power company and the largest EU renewable private player, has long embraced the digitalisation of electricity networks, transforming them into Smart Grids and integrating advanced digital technologies to accelerate the deployment of renewable energy.

Fedoweb welcomes the call for evidence (“Call for Evidence”) promoted by the European Commission to collect stakeholders’ views, expertise and evidence on the Proposal for a Regulation of the European Parliament and of the Council amending Regulations (EU) 2016/679, (EU) 2018/1724, (EU) 2018/1725, (EU) 2023/2854 and Directives 2002/58/EC, (EU) 2022/2555 and (EU) 2022/2557 as regards the simplification of the digital…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Digital Omnibus 1. Video Games Europe strongly supports the Commission’s ambitious simplification agenda. In her Political Guidelines, Commission President von der Leyen explicitly announced the intention “to simplify, consolidate and codify legislation to eliminate any overlaps and contradictions while maintaining high standards”, while promising “to address the patchwork of national regulations that makes…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

E.ON welcomes the opportunity to provide feedback on the Commission proposal for the Digital Omnibus. In general, E.ON welcomes the Commission's ambition for simplification and has repeatedly advocated for the reduction of bureaucracy and the streamlining and simplification of legislation at both national and European levels.

ANIE ASSIFER, Italian Railway Industry Association, represents companies operating in Italy that design, manufacturer and install technologies most innovative in the world for railways transport and urban public electrified transport (subway, tram), around 160 companies with more than 7 billion euros of turnover for year.

The AMC advocates for a Digital Omnibus Regulation that supports independent audience measurement. Independent audience measurement provided by JICs and research suppliers is indispensable for fair competition, media pluralism, public transparency and effective compliance with article 24 of the European Media Freedom Act.

TCO supports the improvement of rules that is jeopardised by a forced legislative process and a lack of impact assessment. TCO supports genuine simplification of rules and wishes to see an effective regulatory framework that can at the same time protect workers’ rights and yet be managed by SMEs.

Filed in Swedish · English published by the European Commission

As a European technology company with over two decades of experience in travel innovation, Skyscanner supports the Digital Omnibus goal of simplifying digital regulation and reducing administrative burdens while maintaining strong data protection standards. This initiative is an important opportunity to strengthen the EUs competitiveness and improve users online experience.

INFORME CÁMARA DE COMERCIO DE ESPAÑA Consulta pública de la Comisión Europea relativa a Simplificación: paquete digital y ómnibus Marzo de 2026 Informe de la Cámara de Comercio de España: Simplificación: paquete digital y ómnibus 1 1 | INTRODUCCIÓN El presente documento constituye una contribución al proceso de consulta pública abierto por la Comisión Europea el 21 de noviembre de 2025 sobre simplificación: paquete…

Filed in Spanish · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Invest Europe is the trade association representing private equity (PE), venture capital (VC), and infrastructure fund managers, as well as their investors, across Europe. Our members are mostly small and mid sized management companies that play a key role in financing innovative and growing European businesses.

AI literacy is a precondition for the effective implementation of the AI Act without trained users, risk management and human oversight simply cannot work. Article 4 ensures that AI governance is not only technical but also operational, by developing the competence of those who actually deploy and supervise AI systems.

TCO supports the improvement of rules that is jeopardised by a forced legislative process and a lack of impact assessment. TCO supports genuine simplification of rules and wishes to see an effective regulatory framework that can at the same time protect workers’ rights and yet be managed by SMEs.

Filed in Swedish · English published by the European Commission

INFORME CÁMARA DE COMERCIO DE ESPAÑA Consulta pública de la Comisión Europea relativa a Simplificación: paquete digital y ómnibus – Reglamento de ómnibus digital sobre IA Marzo de 2026 Informe de la Cámara de Comercio de España: Simplificación: paquete digital y ómnibus – Reglamento de ómnibus digital sobre IA 1 1 | INTRODUCCIÓN El presente documento constituye una contribución al proceso de consulta pública abierto…

Filed in Spanish · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

We thank the European Commission for the opportunity to comment on data-privacy provisions of the Digital Omnibus. ICLE is a nonprofit, nonpartisan research centre that applies law & economics analysis to technology governance, competition, and consumer-protection policy.

The EACB welcomes the Commissions intention to simplify elements of the AI Act through the AI Omnibus. For cooperative banks, the success of the AI framework depends on whether its requirements can be implemented in a predictable and operational way.

The Belgian State Archives propose the following changes to the Digital Omnibus Proposal in order to better enable the crucial functioning of archival institutions: A. Reconsider the merging of the Open Data Directive, the Data Governance Act and the Data Act; B. Clarifying the legal regime for documents; C. Defining and recentring the archives.

Insurance and Pension Denmarks key points are summarized below and elaborated in the attached file. The insurance and pension sector welcomes the European Commissions Digital Omnibus initiative, which seeks to simplify and clarify the EUs digital regulatory framework while maintaining a high level of data protection.

The International Association of Public Transport (UITP) and its European members support the Commissions objective of simplifying and improving the coherence of the EUs regulatory framework on data through the Digital Omnibus initiative.

RfII: STATEMENT ON THE EUROPEAN COMMISSION'S PROPOSAL ON SIMPLIFICATION OF THE DIGITAL LEGISLATIVE FRAMEWORK From RfII's point of view, the EU's strategic shift towards consolidating previously dispersed regulations within two "major" digital laws is, in principle, a suitable approach for achieving coherent, contradiction-free regulation.

The Estonian Information Technology and Telecommunications Union (ITL) provides the following feedback on the Digital Omnibus: 1. The ITL supports the initiative’s objective of simplifying the complex and voluminous legislation in force. Many of the changes included in the package will benefit businesses, including those that do not exist specifically for smaller companies.

Filed in Estonian · English published by the European Commission

AseBio, the Spanish Bioindustry Association representing more than 350 entities across the biotechnology ecosystem, welcomes the European Commissions Digital Omnibus proposal aimed at simplifying the regulatory framework for artificial intelligence (AI) in the European Union.

Dear Sir or Madam Please find the response of the European Law Institute (ELI) to the European Commissions public consultation on the Digital Omnibus in the following link: https://www.europeanlawinstitute.eu/fileadmin/user_upload/p_eli/Publications/ELI_Response_-_Proposed_Revisions_to_the_Digital_Omnibus.pdf ELI is an independent, non-profit organisation bringing together legal professionals, academics, judges…

SweFinTech Association Feedback on the Digital Omnibus Package AI Regulation and High-Risk Systems We welcome the objective of the Digital Omnibus initiative to simplify the EU digital regulatory framework and reduce unnecessary administrative burdens for businesses operating in the EU digital economy.

(Recommendation 1) Preserve the Data Act's Balanced Trade Secret Regime The original Data Act strikes a carefully calibrated balance: it guarantees access to data generated by connected products while safeguarding trade secrets through confidentiality obligations, technical and organisational measures, and the possibility to refuse disclosure where there is a demonstrated high likelihood of serious economic damage.

Intesa Sanpaolo welcomes the European Commissions initiative to simplify and clarify the implementation of the AI Act through the AI Omnibus, supporting the objective of a clear and innovation-friendly regulatory framework.

I will present the views of the Estonian Information Technology and Telecommunications Union on the Digital Omnibus related to the Artificial Intelligence Act: 1. We welcome the logic of postponing the implementation of the commitments until the tools (standards and guidelines) for the implementation of the respective commitments have been developed.

Filed in Estonian · English published by the European Commission

(Recommendation 1) Preserve the Data Acts Balanced Trade Secret Regime The original Data Act strikes a carefully calibrated balance: it guarantees access to data generated by connected products while safeguarding trade secrets through confidentiality obligations, technical and organisational measures, and the possibility to refuse disclosure where there is a demonstrated high likelihood of serious economic damage.

PHARMIG welcomes the European Commission’s (EC) Digital Omnibus package as an important opportunity to create more coherence and legal certainty in the EU’s digital rulebook. Data is a critical enabler for pharmaceutical research, development and production, as well as for the use of AI-based applications throughout the lifecycle of medicines.

Filed in German · English published by the European Commission

Merkur supports the EU Data Act because access to operational and historical data is particularly important in offshore wind. Offshore repairs often require specialised vessels, costly logistics and longer intervention times, so delayed fault detection can translate into substantial downtime and avoidable cost.

Policy paper 2026-02-20 Bld. Brand Whitlock 114 B-1200 Brussels [email removed] | www.applia-europe.eu APPLiA Home Appliance Europe AISBL Transparency number: 04201463642-88 VAT BE 0460 033 584 APPLiA’s recommendations and amendments proposal for the Digital Omnibus: Data Act and GDPR 1/7 1.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The German Social Insurance Agency (DSV) welcomes the European Commission’s initiative to use a digital omnibus to simplify and harmonise the multitude of existing legal acts in the digital field. Social security institutions, with their own IT infrastructure, data-intensive administrative processes and the prospective use of artificial intelligence (AI) systems, are faced with the task of integrating the…

Filed in German · English published by the European Commission

The Austrian Federal Ministry of Labour, Social Affairs, Health, Care and Consumer Protection (BMASGPK), Section III Consumer Policy and Consumer Health submits its comments on the Digital Omnibus proposals EC COM (2025) 837 final and EC COM (2025) 836 final, both dated 19 November 2025, as set out in the attached document.

Policy paper 3 févr. 2026 Bld. Brand Whitlock 114 B-1200 Brussels [email removed] | www.applia-europe.eu APPLiA Home Appliance Europe AISBL Transparency number: 04201463642-88 VAT BE 0460 033 584 APPLiA’s recommendations and amendments proposal for the AI Omnibus 1/9 AI Omnibus Europe’s home appliance sector is built on decades of trust, following rigorous safety standards.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Humanists International is the global representative body of the humanist movement, uniting a diversity of non-religious organizations and individuals worldwide. Founded in 1952, Humanists International champions human rights, secularism, and the defence of vulnerable minorities.

Bundesverband E-Commerce und Versandhandel Deutschland e.V. (bevh) - Stellungnahme zum Vorschlag für eine VERORDNUNG 2025/0360 (COD) (Digital Omnibus) Berlin, den 13.03.2026 Der Bundesverband E-Commerce und Versandhandel Deutschland e.V.

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

MedTech Europe welcomes the opportunity to provide feedback on the Digital Simplification Package (Digital Omnibus) which represents a timely initiative to enhance regulatory coherence and support Europes competitiveness.

BZDV - Bundesverband Digitalpublisher und Zeitungsverleger e. V. MVFP - Medienverband der freien Presse e. V. Stellungnahme zum Vorschlag der Kommission COM(2025) 837 final vom 19.11.2025 für eine Verordnung des Europäischen Parlaments und des Rates zur Änderung der Verordnungen (EU) 2016/679, (EU) 2018/1724, (EU) 2018/1725 und (EU) 2023/2854 sowie der Richtlinien 2002/58/EG, (EU) 2022/2555 und (EU) 2022/2557…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

APELL The European Open Source Software Business Association and its members represent hundreds of Open Source businesses with a collective turnover in the order of several tens of billions of euros each year, among them mostly SMEs, some large companies, as well as public administrations, research institutions, and individuals throughout Europe.

APELL The European Open Source Software Business Association and its members represent hundreds of Open Source businesses with a collective turnover in the order of several tens of billions of euros each year, among them mostly SMEs, some large companies, as well as public administrations, research institutions, and individuals throughout Europe.

Unipol Group’s response to the EU Commission consultation on “Digital Omnibus” Bologna, 13 March 2026 * * * 1 Preliminary remarks: the Digital Omnibus, an opportunity not to be missed Unipol Group welcomes the European Commission's intent to streamline digital oversight through the "Digital Omnibus" program.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

CIO Platform Netherlands (CIOPN) responds on behalf of business users of digital technologies. From this perspective, CIOPN supports the overarching objectives of the Digital Omnibus and AI Omnibus packages, in particular the ambition to improve coherence, legal clarity and practical enforceability of the EU digital regulatory framework.

carVertical welcomes the efforts of the European Commission, the Council of the EU, and civil society to reach a compromise that supports the EU data economy, addresses AI development challenges, and safeguards Europeans digital rights and privacy. Wed like to draw your attention to a couple of matters that are missing from the Digital Omnibus regarding the Amendments to Regulation (EU) 2016/679 (GDPR).

The City of Espoo supports the Commissions objective to simplify and clarify the EU digital rulebook. Simplification must, however, translate into clearer obligations, consistent terminology, practical implementation support, and a reduced administrative burden also from the perspective of competent authorities, including municipalities.

FESI Position Paper AI OMNIBUS PROPOSAL February 2026 Summary: 1. Delayed Deadlines for High-Risk AI (“Stop the Clock” – Article 113) 2. AI Literacy (Article 4) 3. Registration of non-high-risk AI systems (Art. 6(3)-(4)) 4.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

This position paper focuses on the AI-related aspects of the Digital Omnibus initiative. It outlines VBO-FEBs key concerns and recommendations regarding the interaction between the Digital Omnibus and the existing and forthcoming EU framework on artificial intelligence.

Opinion on the digital omnibus 2025-06-12 Introduction Saco would like to present a number of comments on the European Commission’s proposal for a Digital Omnibus on AI, cybersecurity and data. Saco limits its comments mainly to certain proposed substantive amendments to the General Data Protection Regulation (EU) 2016/679 (GDPR) and the AI Act (EU) 2024/1689.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

RATP Group fully supports the goal of the Digital Omnibus which is to simplify the European digital framework. Data is central to this digital framework, it flows through the public transport value chain to enable safe, effective, and efficient services to passengers. The Data Act (Regulation (EU) 2023/2854) is the regulation that enables this data flow from the rolling stock to the passenger.

Filed in French · English published by the European Commission

AENA proposes blending European ambition with Pragmatism, calling for harmonised frameworks that reduce burdens and enable innovation for critical infrastructure such as airports. We request accessible regulatory sandboxes, testing tailored to air transport, clear guidance on data protection, and exemptions for Non-critical systems.

Filed in Spanish · English published by the European Commission

The Europeana Foundation is interested in the changes brought by the Digital Omnibus to the Open Data Directive. In our submission, we indicate our support for differentiated fees for large companies but stress that charges should apply to value-added services (such as bulk data preparation), not to basic access to data.

AbbVie is a global, research-driven biopharmaceutical company committed to delivering life-changing solutions for patients. With 11 manufacturing sites, 4 R&D hubs and clinical studies active in 24 EU countries, the European Union (EU) plays an important role in our mission to discover and deliver innovative medicines.

Eurosmart, the voice of the European digital security industry, welcomes the opportunity to provide comments on the European Commissions proposal for a Digital Omnibus Regulation. Eurosmart supports the objective of improving clarity and consistency across the EU digital regulatory framework.

windwise supports the EU Data Act in its original form because without access to high-resolution operational data, turbine operators cannot detect and prevent outages at an early stage. Creeping defects in transmission, clutch or transformer occur in vibration, pressure and high-frequency electrical signals to power electronics and control systems, providing data in the kilohertz range containing crucial early…

Filed in German · English published by the European Commission

This position paper sets out VBO-FEBs views on the European Commissions Digital Omnibus initiative. It assesses the proposed approach from a business perspective, with a particular focus on regulatory coherence, simplification and legal certainty.

The Chair in Cyber Policy, led by Dr. Niovi Vavoula, submits its recommendations to the second phase of the call for evidence initiated by the Commission on the Digital Package on Simplification regarding the adopted act Proposal for a regulation COM(2025)836.

DOT Europe supports the objectives of the Digital Omnibus and AI Omnibus initiatives as steps towards simplifying the EU digital regulatory framework by reducing reporting obligations, clarifying rules and addressing overlaps between different pieces of legislation.

Eurosmart, the voice of the European digital security industry, welcomes the European Commissions initiative to introduce a Digital Omnibus on Artificial Intelligence, which proposes targeted amendments to the Artificial Intelligence Act.

ENNHRI, in collaboration with Equinet (the European Network of National Equality Bodies), has issued a joint statement urging co-legislators to preserve strong equality and fundamental rights protections in the AI Act and the GDPR which are currently subject to substantial amendments through the Digital Omnibus Regulation Proposal and the Digital Omnibus AI Regulation Proposal.

On 19 November 2025, the Commission revealed the Digital Omnibus package. This package is only one in a series of increasing omnibus bills (giant laws that modify several laws at once) that are part of the deregulatory agenda of the new Von der Leyen Commission.

Wolt welcomes the European Commissions simplification agenda and its objective to streamline the EUs digital regulatory framework. As a company firmly committed to robust privacy, data protection, and cybersecurity standards, Wolt views regulatory simplification as a way to strengthen legal certainty and effective enforcement while maintaining a high level of protection.

Bending Spoons welcomes the Digital and AI Omnibus initiative and sees it as a necessary step to simplify and clarify a digital regulatory framework that has become increasingly complex to apply consistently and costly to navigate competitively.

TIM response to the Digital Omnibus Consultation TIM welcomes the opportunity to provide its feedback on the European Commission's public consultation regarding the 'digital omnibus' legislative proposal. We strongly support the Commission's focus on regulatory simplification, which we consider a crucial step towards creating a more agile and future-proof framework for the European telecommunications sector.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The European press publishers' associations EMMA and ENPA appreciate this opportunity to provide feedback on the proposal for a Digital Omnibus. Please find attached our position paper, that focuses on proposed new GDPR provisions in the Digital Omnibus on data.

Confindustria Radio Televisioni expresses its appreciation for the work done by the European Commission in boosting the simplification of regulations at European level of central issues for the radio and television sector, and beyond.

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.

Please find ENTSO-E's contribution to the Digital Omnibus Proposal for a Regulation in the attachment ENTSO-E, the European Network of Transmission System Operators for Electricity, brings together 40 member TSOs from 36 countries to ensure the secure and coordinated operation of Europes electricity system one of the worlds largest interconnected grids.

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.

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.

IPoP's feedback in the attached document Interdisciplinary Project on Privacy - IPoP IPoP is a French interdisciplinary research project that focuses on new forms of personal information collection, on the learning of Artificial Intelligence (AI) models that preserve the confidentiality of personal information used, on data anonymisation techniques, on securing personal data management systems, on differential…

EGEA is the European Garage Equipment Association, representing the European industry across EU and non-EU Member States, providing technical equipment and services for diagnosing, inspecting, repairing, and maintaining combustion, hybrid, and electric vehicles across all categories.

The European Federation of Pharmaceutical Industries and Associations (EFPIA) represents the research-based pharmaceutical industry operating in Europe and is committed to advancing patient care through responsible innovation.

NDM response to the Digital omnibus NDM is grateful for the opportunity to respond to the Commission’s consultation on the Digital Omnibus on the need to reform of the EU’s digital legislation. The Stockholm-based NDM (a Confederation of Swedish Business Organisations) comprises 24 Swedish industry and interest organisations from various sectors.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The European Association of Nuclear Medicine (EANM) represents a medical specialty where clinical outcomes are inseparable from high-fidelity data. We welcome the European Commissions move to streamline the Unions digital regulatory framework through the Digital Omnibus.

Japan Association of New Economy (JANE) has submitted feedback on the European Commissions Digital Omnibus Proposal (COM/2025/837). JANE considers the proposal an important opportunity to simplify the EUs digital rulebook, reduce overlapping obligations, and improve legal certainty across the Single Market.

This statement was developed through a collaborative process involving the Weizenbaum Institute and the German Society for Law and Informatics. The first part of the position paper analyses EU digital legislation, highlighting structural problems within the European digital regulatory framework.

The French Mobilities Alliance, by Mobilians, brings together around one hundred innovative companies from the Mobility Tech sector. We welcome the European Commissions initiative to simplify and improve the coherence of the European framework relating to data.

The French Mobilities Alliance of Mobilians, a French professional federation bringing together around one hundred innovative companies from the Mobility Tech sector, welcomes the European Commissions initiative to simplify and clarify the implementation of the European framework on artificial intelligence.

Linkbycar is a European technology company specialising in the aggregation and analysis of connected vehicle data and mobility infrastructure data. Our solutions are deployed by insurers, fleet operators and energy stakeholders to improve safety, operational efficiency and energy performance.

Energy sovereignty in Europe must inevitably include full access for asset owners to data from wind turbines. It is therefore essential that we use the data from our turbines and work together with service partners, specialist service providers and our own in-house experts to further optimise the production of renewable energies.

Wolt welcomes the European Commissions simplification agenda and its first concrete steps to streamline the EUs digital legislative framework, including the proposal to delay and simplify certain provisions of the AI Act under the Digital Omnibus on AI.

Zalando welcomes the European Commission's Digital Omnibus Package, particularly the proposed modernisation of the General Data Protection Regulation (GDPR), as a timely and necessary strategic step towards strengthening European competitiveness.

Feedback on: Simplification – digital package and omnibus We welcome the Commission’s proposal for a digital omnibus addressing the implementation of the Artificial Intelligence Act, including the introduction of targeted simplification measures.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The protection of personal data is one of the fundamental pillars of European law and a hallmark of the European Union’s regulatory capacity at global level. However, the General Data Protection Regulation (GDPR), years after its entry into force, shows increasingly clear limitations in its application: inconsistencies in interpretation, operational uncertainties, fragmentation of the implementation framework…

Filed in Italian · English published by the European Commission

The EU Data Act enables the development of new data ecosystems in Europe and lays the foundation for a sustainable modernisation of renewable energy production. Operators will thus have access to the operational data of their wind farms and will be able to optimise their operation across Europe, with the concrete potential to generate millions of additional kilowatt-hours of European energy through efficiency…

Filed in German · English published by the European Commission

[UTPF - Union des Transports Publics et Ferroviaires -is the professional organisation representing urban public transport operators, rail operators, infrastructure and railway station managers in France]. UTPF fully supports the objective of the Digital Omnibus: to simplify and make the European digital framework more consistent.

The Electronic Frontier Foundation (EFF), the leading nonprofit organization defending civil liberties in the digital world, appreciates the opportunity to offer feedback on the digital package. Our feedback mainly focuses on the data legislation proposal. For any questions, reach out to [email removed]

COMMENTS IN RESPONSE TO EUROPEAN COMMISSION CALL FOR EVIDENCE SURVEY ON THE “DIGITAL OMNIBUS- COM (2025)837” Steph Housden, Ahmed Nagy ACM Europe Technology Policy Committee February 2026 The Association for Computing Machinery (ACM) is the world’s longest-established professional society of individuals involved in all aspects of Computing. It annually bestows the ACM A.M.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

BEUC - The European Consumer Organisation welcomes the opportunity to contribute to the public consultation on the Digital Omnibus package. BEUC acknowledges that the EUs simplification agenda offers an opportunity to streamline procedures, improve the application and enforcement of digital rules, and make it easier for consumers to exercise their rights.

FIGIEFA, the International Federation of Automotive Aftermarket Distributors, welcomes the opportunity to contribute to the European Commissions public consultation on the simplification of the EU digital legislative framework, including the Digital Omnibus initiative. FIGIEFA represents Europes independent distributors of automotive replacement parts and components, as well as their associated repair networks.

Tyres Europe takes note of European Commissions call for evidence on the Digital Omnibus initiative. The tyre industry has vested interests on the Data policy and legislative frameworks, and has been active with EU policymakers in order to contribute to the EUs data policy framework.

The European Utilities Telecom Council (EUTC) welcomes the European Commissions Digital Omnibus Simplification package as an opportunity to streamline the EU digital regulatory framework and support investment in secure and resilient digital infrastructure.

The Coalition of Creators and Content Industries (hereinafter ‘the Coalition’ or simply ‘LC’) is an association launched in 2009, made up of associations and rights management organisations from all sectors of cultural content such as film, book, press, music and video games, the main purpose of which is to protect intellectual property rights in the digital sphere; in particular by combating illegal activities…

Filed in Spanish · English published by the European Commission

The Snitem thanks the European Commission for giving it the opportunity to give its opinion on the proposal for a Digital Omnibus Regulation, which represents a timely initiative to simplify the EU’s digital regulatory framework, reduce the administrative burden and strengthen the competitiveness of European organisations.

Filed in French · English published by the European Commission

The APDC Digital Business Community welcomes the European Commission’s initiative on simplifying the digital regulatory framework, recognising the importance of ensuring a more coherent, proportionate and supportive regulatory environment for innovation and the competitiveness of European businesses.

Filed in Portuguese · English published by the European Commission

greenwind supports the swift implementation of the EU Data Act as an important step toward strengthening Europes energy system, improving operational transparency, and fostering innovation in the renewable energy sector. In particular within the wind industry, access to operational data plays a crucial role in enabling efficient asset management, optimized maintenance strategies, and informed investment decisions.

The Online Dating and Discovery Association (ODDA) is the recognised trade body for the sector with a mission to create safe, responsible and enjoyable experiences for everyone. Representing nearly 500 brands world-wide, we would like to thank the European Commission for the opportunity to provide feedback on this important proposal.

EDRi is Europes largest network of digital human rights organisations working for fundamental rights, justice and the public interest in EU tech policy. We use this consultation to raise our serious concerns about the Commissions Digital Omnibus package.

BZDV - Bundesverband Digitalpublisher und Zeitungsverleger e. V. MVFP - Medienverband der freien Presse e. V. Stellungnahme zum Vorschlag der Kommission COM(2025) 837 final vom 19.11.2025 für eine Verordnung des Europäischen Parlaments und des Rates zur Änderung der Verordnungen (EU) 2016/679, (EU) 2018/1724, (EU) 2018/1725 und (EU) 2023/2854 sowie der Richtlinien 2002/58/EG, (EU) 2022/2555 und (EU) 2022/2557…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

CONFIDENTIAL ACT POSITION PAPER ON THE DIGITAL OMNIBUS 12 MARCH 2026 - FINAL Ref. Ares(2026)2705267 - 12/03/2026 PAGE | 1 ACT POSITION PAPER ON THE DIGITAL OMNIBUS ABOUT THE ACT The Association of Commercial Television and Video on Demand Services in Europe (ACT) is the voice of commercial television and video on demand services in Brussels.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Schaeffler, the motion technology company, welcomes the European Commission's initiatives to revise the digital acquis through both the Digital Omnibus proposal and the Digital Fitness Check. The harmonization and simplification of the various digital and data regulations are well needed.

Equinet, in collaboration with ENNHRI (the European Network of National Human Rights Institutions), has issued a joint statement urging co-legislators to preserve strong equality and fundamental rights protections in the AI Act and the GDPR currently subject to substantial amendments through the Digital Omnibus Regulation Proposal and the Digital Omnibus AI Regulation Proposal.

The European Alliance for Research Excellence (EARE) welcomes the European Commissions Digital Simplification Omnibus package as a positive first step towards simplifying and clarifying the EUs data and AI regulatory framework. EARE supports the overarching objectives of reducing administrative burdens, increasing legal clarity, and fostering open access and re-use of data for research and innovation.

Federation of Business Information Services Föderation für Wirtschaftsinformationsdienste e.V. FEBIS comments on the Digital Omnibus Proposal Contents 1.The revision of personal data definition proposed to the GDPR. ....................................... 3 2. The need to ensure that legitimate interest is recognized as a valid ground for data processing for business information providers.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The German Diagnostics Industry is calling for the clear prioritisation of AI-specific regulations within the existing regulatory framework for medical devices (IVDR/MDR). Moreover, the VDGH seeks an exemption for commercially used AI-enabled research products from the scope of the AI Act.

The European Commission’s digital omnibus aims to clarify, simplify and harmonise the application of key elements of European data law, in particular data protection law. The Zentrale Immobilien Ausschuss e.V. (ZIA), as the umbrella organisation for the German real estate industry, warmly welcomes this European initiative.

Filed in German · English published by the European Commission

Artificial intelligence is increasingly central to Spanish automotive sector, influencing everything from manufacturing to mobility services. To enable this transformation, the industry needs a regulatory framework that is clear, coherent, and practical.

CECIMO welcomes the European Commissions Digital Omnibus proposals as an important first step toward simplifying EU digital legislation. While this initiative moves in the right direction, the current proposals do not yet fully achieve the EUs simplification objectives nor sufficiently reduce the regulatory burden on European industry, particularly on manufacturers of machinery and equipment.

The Commission's proposal seeks to harmonise cybersecurity and privacy regulations by amending the ePrivacy and GDPR frameworks. RG welcomes this initiative as it enables car manufacturers to bolster vehicle cybersecurity and safety.

The automotive sector is at the centre of an unprecedented digital transition. In this context, it is essential to ensure a coherent, harmonised and technologically realistic digital regulatory framework that enables companies to innovate, invest and develop new data-driven solutions.

The Bulgarian Entrepreneurial Association (BESCO) welcomes the European Commissions Digital Omnibus on AI and emphasises the need for a proportionate, predictable and innovation-friendly framework that reflects the realities of startups and scale-ups.

Data and Artificial Intelligence are rapidly transforming Europes independent retail sector, changing how retailers serve consumers and offering new potential to optimize their supply chain, logistics and stores.

Please find enclosed Clever Cloud feedback on: Simplification - digital package and Omnibus Clever Cloud supports the Digital Omnibus where it: Simplifies regulatory frameworks; Strengthens coordination through ENISA and improves the coherence of European cybersecurity governance; Effectively removes vendor lock-in in cloud services while preserving fair contractual conditions for European providers; Calibrates…

Inter IKEA Group Position on Digital & AI Omnibus Creating trusted, competitive, people centric digital ecosystems The IKEA business has supported the extensive work of the European Union to create a trusted digital ecosystem.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Swedish Internet Foundation’s opinions on Simplification – digital package and omnibus – Proposal for a Regulation COM(2025)837 The Swedish Internet Foundation is an independent, private foundation that works for the positive development of the internet.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Cigref, representing 150 leading French companies and public administrations, welcomes the publication of the Digital Package and Omnibus Initiative on 19 November 2025. We broadly support the Commissions objective to simplify and streamline the European digital acquis, ensure consistent application across Member States, and strengthen legal clarity.

The aim of simplifying and optimising the European digital rulebook is in principle to be welcomed. However, the Commission’s proposals are not suitable for achieving the objective and may even lead to serious interferences with personality rights in the employment context.

Filed in German · English published by the European Commission

European Commission DG Internal Market, Industry, Entrepreneurship and SMEs B-1049 Brussels (Belgium) E-Mail: [email removed] Abt. Digitalisierung/IT-Projekte Unser Zeichen: Ka/[name removed].: [phone removed] Fax: [phone removed] E-Mail: [email removed] 11.

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The German machine tool industry appreciates the opportunity to provide feedback. We welcome any simplification of the actual and planned regulations in the digital realm, especially with respect to the Cyber Resilience Act. From our point of view, CRA overwhelms machine tool builders, most of them small and medium sized enterprises.

Ecommerce Europe is overall broadly supportive of the proposed EU Digital Omnibus package, as it is expected to deliver meaningful regulatory simplification and operational efficiencies across the GDPR, AI Act, and NIS2/DORA frameworks. However, efforts to simplify the EU data legislative framework must be coherent and workable in practice.

egta – Position Paper on the Digital Omnibus egta is the international trade body of multiplatform TV and audio businesses. We represent more than 180 members in over 40 markets. Our mission is to contribute to the commercial sustainability of the media industry. We enable our members to flourish as they connect brands with audiences.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

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.

Simplify EU Digital Regulation 12 March 2026 Digital and AI Omnibus Proposals 2nd Input to the European Policy Makers 12 March 2026 Contents 1. Introduction .................................................................................................................. 2 2. General Comments ....................................................................................................... 3 3.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Simplify EU Digital Regulation 12 March 2026 Digital and AI Omnibus Proposals 2nd Input to the European Policy Makers 12 March 2026 Contents 1. Introduction .................................................................................................................. 2 2. General Comments ....................................................................................................... 3 3.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

POSITION Ref. Ares(2026)2693812 - 12/03/2026 12.03.2026 Janek Kuberzig, Public Affairs Manager Data & Technology, [email removed] Stellungnahme zum Vorschlag der Europäischen Kommission für eine digitale Omnibus-Verordnung über KI Allgemeine Einordnung Der Bundesverband Digitale Wirtschaft (BVDW) e. V.

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The European Data Act provides the foundation for operators to access the highresolution operational data they need to identify technical risks early in renewable energy assets. This binding data access strengthens system availability, reduces outages, and measurably enhances Europes security of supply.

As a reference body representing the major players in digital trust, the Federation of Digital Third Parties (FNTC) is a pioneering organisation in the development of doctrines aimed at reliable and secure digitalisation. Its expertise is based on structuring work.

Filed in French · English published by the European Commission

The Federal Association for Digital Economy (BVDW) welcomes the Digital Omnibus launched by the European Commission as a timely and necessary update of the European digital rulebook. We support the objective of simplifying requirements, reducing administrative burdens and strengthening Europe’s competitiveness.

Filed in German · English published by the European Commission

IBM welcomes the timely publication of the Digital Omnibus proposal, aiming at simplifying the EUs digital rulebook in cybersecurity, data governance and privacy. We believe these proposals are a good starting point toward cutting red tape for all businesses operating in Europe and will help support innovation.

IBM welcomes the timely publication of the AI Omnibus Regulation, aiming at simplifying and harmonising the implementation of the EU AI Act, which is a good starting point toward cutting red tape for all businesses operating in Europe, and will help support innovation in this area. Simplifying rules for AI is essential to foster innovation within European industries.

The FBF welcomes the European Commissions initiative to simplify, and not to deregulate, the digital legislative framework. This simplification has been widely acclaimed in the financial sector, particularly in view of the need for innovation and competitiveness in an international context and of the cybersecurity rules.

BVMed supports reinforcing the primacy of the Medical Devices Regulation (MDR) as the applicable sectoral legislation for AI medical devices under a sector-first approach within the AI Act framework, ensuring legal clarity and avoiding duplicative horizontal obligations. For further details please see position paper attached.

FiCom welcomes the Commissions aim to simplify EU digital regulation. Clear and predictable rules are essential, but simplification must be practical: it should genuinely reduce administrative burden, remove overlaps and avoid shifting uncertainty from one instrument to another. The final outcome must support effective implementation for organisations of all sizes.

Delivery Platforms Europe (DPE) represents the leading local commerce platforms in Europe, providing digital services connecting consumers with local merchants through courier partners. DPE welcomes the Commission proposals on the Digital Omnibus Package and the possibility to contribute to the additional feedback period on the two proposals, the Omnibus on AI (2025/0359(COD)) and the Digital Omnibus…

FiCom welcomes the Commissions effort to address practical implementation challenges of the AI Act. The adjustments are useful, but they must not introduce new uncertainty or leave companies unsure which obligations apply. The framework must remain predictable, technically workable and proportionate for organisations of all sizes.

The AI Policy Lab at Umeå University welcomes the opportunity to provide feedback on the Simplification of the Digital Package and Omnibus. Below, we share our considerations and recommendations. Residual sensitive data (§33) The proposed derogation allowing the processing of residual special categories of personal data during model training may increase the amount of sensitive data processed without ex ante…

Paris Europlace WG strongly supports the proposed extension of compliance deadlines. However, we express concerns regarding the European Commissions ability to shorten these extended deadlines if it considers that sufficient standards, guidelines, or implementing acts have been published. Such discretionary power introduces a significant source of regulatory uncertainty for market participants.

As a European AI champion developing cutting-edge language technology, DeepL welcomes the Commission's efforts to simplify digital regulation while maintaining fundamental safeguards for the protection of Citizens. The AI Act provides a sound foundation for trustworthy AI in Europe.

RTE feedback Digital Omnibus March 12th, 2026 RTE examined the European Commission proposal for a ‘digital omnibus’ simplification package targeting, in particular, the General Data Protection Regulation (GDPR) and the Data Act.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Turbit strongly supports the swift and unchanged implementation of the EU Data Act as an essential foundation for Europe's energy sovereignty and industrial competitiveness. The stakes are concrete and already measurable: across Europe's wind fleet, data that is generated every second remains inaccessible to the operators who own and bear the financial risk of these assets.

Consultation on the Digital Omnibus As a high-tech company providing manufacturing solutions in the fields of complex machine tools, laser technology, electronics and Industry 4.0, TRUMPF occupies a unique and vulnerable position in the Cyber Resilience Act (CRA) supply chain. Therefore, digital security and resilience are of specific importance for TRUMPF.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

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.

LSEG supports the Digital Package and Omnibus initiative as an opportunity to simplify and better align the EUs digital regulatory framework. As a global provider of financial-market infrastructure and data solutions, we identify gaps in lawful-basis clarity, supervisory coordination and the treatment of sector-specific technologies such as data and AI-enabled compliance systems.

EuroISPA, the European Internet Services Providers Association, welcomes the European Commissions efforts to simplify the EU digital regulatory framework through the Digital Omnibus Package. A forward-looking and ambitious simplification agenda is essential to strengthen Europes competitiveness, enhance legal certainty, and ensure that the EU digital acquis is fit for the next decade.

The European Energy Information Sharing and Analysis Centre (EE-ISAC) welcomes the European Commissions Digital Package and the Digital Omnibus initiative, which aim to simplify the EUs digital regulatory framework while maintaining strong cybersecurity and data protection standards.

The Data & Technology for Compliance (DT4C) Alliance welcomes the Digital Omnibus proposals as a timely opportunity to simplify the EUs digital regulatory framework to simultaneously reduce administrative burdens and strengthen competitiveness and innovation across Europes digital economy.