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

Feedback from the IPoP Research Project 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…

Prosus Group welcomes the opportunity to present its feedback to Digital Omnibus (AI) proposal and accompanying Digital Omnibus data acquis. We believe 2026 is an inflection point for Europe and more needs to be done faster to ensure that Europe remains competitive on the global AI scene. Please find enclosed our position with an executive summary.

EFAMA welcomes the European Commissions Digital Omnibus proposals and the targeted amendments introduced to the GDPR and the AI Act. Overall, the proposed changes provide useful legal clarification and reduce potential administrative burdens while preserving the core objectives of the existing regulatory framework.

The Center for AI and Digital Policy welcomes the opportunity to share our comments on the Digital Omnibus on AI to address its significant impact on the implementation of the AI Act. While we encourage efforts to make implementation of the AI Act easier, simplification must not come at the expense of eroding core promises and objectives of the AI Actparticularly its rights-protecting regulation of high-risk AI…

The Industrialists’ Association sees the Digital and AI Omnibus as an important first step in the process of simplifying European legislation and administration, but both pieces of legislation still need to be fine-tuned in certain areas in order to achieve the desired relief for European companies and strengthen their competitiveness.

Filed in German · English published by the European Commission

The Industrialists’ Association sees the Digital and AI Omnibus as an important first step in the process of simplifying European legislation and administration, but both pieces of legislation still need to be fine-tuned in certain areas in order to achieve the desired relief for European companies and strengthen their competitiveness.

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Brüssel, 17. Februar 2026 Deutsche Industrie- und Handelskammer Stellungnahme • • • • Der Digitalomnibus ist ein richtiger Schritt, verfehlt aber das Ziel, die regulatorische Komplexität der fragmentierten digitalen Gesetzgebung zu reduzieren. Datenrechtsakte müssen zusammengeführt und widerspruchsfrei gestaltet werden, das gilt insbesondere für KI.

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

CEE Ambassador for AI and New Technologies POSITION ON DIGITAL OMNIBUS ON AI PROPOSAL CEE general view On 19 November 2025, the European Commission presented the Digital Omnibus on AI Proposal as targeted amendments to simplify implementation of the AI Act, ease regulatory burden and strengthen proportionality.

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

The Alliance for the Freedom of Car Repair (AFCAR) is a European coalition representing the broad ecosystem of multi-brand operators active in the automotive aftermarket and mobility services. Its membership encompasses independent parts distributors, independent, authorised and specialised repairers, independent data publishers, diagnostic tool manufacturers, mobility service providers, leasing and rental…

Dear Madam, Dear Sir, Attached please find the submission of the Frankfurt Competence Centre of German and Global Regulation, consisting of a policy paper and an appendix with detailed comments on the proposals of the Digital Omnibus. The German version (put first) is identical to the Engish one in terms of substance. Yours sincerely, Prof. Dr. [name removed]

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.

BoR (26) 23_2 BEREC response to the public consultation on the draft Digital Omnibus 10 March 2026 BoR (26) 23_2 Contents Executive Summary .............................................................................................................................. 2 1.

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

Please find our detailed report as feedback on the proposed changes to the GDPR and e-privacy Directive attached and published on our website: https://noyb.eu/en/digital-omnibus-report-v3-analysis-select-gdpr-and-eprivacy-proposals-commission In a nutshell, noyb conducted a thorough analysis of the proposed changes of the GDPR and the e-privacy Directive.

Senatsverwaltung für Arbeit, Soziales, Gleichstellung, Integration, Vielfalt und Antidiskriminierung1 SenASGIVA, [address removed] Geschäftszeichen [IV A 6] Berlin 10. März 2026 Stellungnahme der Berliner Senatsverwaltung für Arbeit, Soziales, Gleichstellung, Integration, Vielfalt und Antidiskriminierung zu den Vorschlägen der EU-Kommission  für eine Verordnung des Europäischen Parlaments und des Rates zur Änderung…

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

The following text is a summary. The full Eurocadres position can be found in the attached file. Eurocadres Position Summary Eurocadres, representing over six million European professionals and managers, expresses serious concerns about the Digital Omnibus proposal.

LAFNUM represents, in France, the digital manufacturers of the digital base (semiconductors, telecommunications antennas, servers, printing, computers, smartphones) on which the software solutions, applications are based. To this end, AFNUM is closely following all the regulations adopted at European level in recent years and calls for a regulatory break in order to ensure effective implementation.

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Artificial intelligence has undergone rapid development in recent years. It offers considerable prospects for progress if it is used to benefit human flourishing and social progress. It can contribute to improving healthcare systems, optimising public services, ecological transition and access to knowledge.

Feedback for 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) Save the Children Finland (SCF) states, that some streamlining of the “AI Act” is justified, since the Act is of a considerable size, possibly resulting in…

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

The digital omnibus is Europes first attempt to move its digital rulebook from expansion towards simplification. DIGITALEUROPE welcomes this shift. The proposal responds to several issues that industry has raised for years: fragmentation of the data acquis, uncertainty around pseudonymisation or the proliferation of incident-reporting portals.

Europes ambition to lead in AI will only succeed if the AI Act can be implemented in a way that is credible, predictable and workable across sectors. The AI omnibus is therefore a pivotal moment not just to adjust timelines, but to determine whether simplification will be real. At present, the proposal and surrounding debate miss the core issue.

The European Commission’s proposal for a Digital Omnibus (Proposal for a regulation COM(2025)837 – Digital Omnibus) aims to simplify various existing regulations and boost competitiveness. However, the current draft risks lowering existing data protection standards and thereby weakening the EU’s digital sovereignty.

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The Advertising Information Group (AIG) welcomes the simplification objectives of the European Commissions Digital Omnibus initiative, particularly Article 3s codification of the relative nature of personal data and expanded scientific research definitions.

PROPOSED AMENDMENTS TO THE COMMISSION’S PROPOSAL FOR A REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL ON EUROPEAN BUSINESS WALLETS General Council of the Spanish Notariat COM(2025) 838 final — 19 November 2025 March 2026 INDEX 1. INTRODUCTION .........................................................................................................................

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

EAU Response to the Digital Omnibus Proposal The European Association of Urology (EAU) welcomes the simplification of data acquis proposed by the European Commission in Regulation (2025/837), including recommendations to simplify certain provisions of the GDPR (2016/679).

March 2026 Ref. Ares(2026)2602830 - 10/03/2026 Verisure positioning on the EU Digital Omnibus Regulation Proposal Executive summary Verisure Group is Europe’s leading provider of professionally monitored security solutions for residential and small business customers, protecting more than six million customers across multiple EU Member States.

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

The European Commission has made proposals in the Digital Omnibus to clarify and simplify rules on data protection, ePrivacy and digital platforms. The aim is to increase consistency and legal certainty, reduce administrative burdens and support innovation and competitiveness in the digital economy, without lowering the level of protection for data subjects.

Filed in Dutch · English published by the European Commission

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

BSI Group submits this position paper in response to the AI Omnibus proposal to highlight its impact on notified bodies (NBs) and to recommend changes to ensure the AI Act remains workable, consistent and aligned with EU regulatory frameworks. BSI is a longestablished global conformity assessment body and fullscope EU NB with extensive experience across multiple regulated sectors. 1.

09 mars 2026 Omnibus Simplification Numérique Position de la Fédération des Industries Electriques, Electroniques et de Communication Nous saluons la volonté de la Commission européenne de simplifier le cadre de la réglementation numérique.

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

Feedback 10.3.2026 94/03.01.00/2026 Jaana Jormanainen, Niina Erkkilä Feedback to the European Commission’s Proposal on the Data Legislation in the Digital Omnibus package The Association of Finnish Cities and Municipalities (AFCM) is a national organisation with all 308 municipalities and cities in Finland as its members.

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

Feedback on Commission’s proposed Digital Omnibuses on AI and Data 10 March 2026 Digital Business Ireland’s mission is to accelerate the digital transformation of businesses in Ireland and drive the growth of Ireland’s digital economy. We welcome the opportunity to provide feedback on the Commission’s proposed Digital Omnibuses on AI and Data.

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

Feedback 10.3.2026 93/03.01.00/2026 Niina Erkkilä, Jaana Jormanainen Feedback to the European Commission’s Proposal on the AI Act in the Digital Omnibus package The Association of Finnish Cities and Municipalities (AFCM) is a national organisation with all 308 municipalities and cities in Finland as its members.

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

Netherlands Institute for Human Rights Feedback on the EU Digital Omnibus for AI & Digital Omnibus Proposal 1. Conduct a thorough impact assessment before proceeding We find the absence of comprehensive impact assessments for both Omnibus proposals deeply problematic.

The German Association of the Automotive Industry (VDA) welcomes the European Commissions initiative to simplify the digital legal framework through the Digital Omnibus. Consolidating existing regulations is an important step toward strengthening European industrys competitiveness and enhancing legal clarity for companies.

ENGIE welcomes the publication of the Digital and AI omnibus proposals as a positive step toward rationalizing and clarifying the EU digital acquis and addressing existing implementation challenges. While the texts introduce relevant improvements, further systemic changes and a more pragmatic regulatory approach will be necessary to ensure a simple, clear and consistent digital rulebook.

ENGIE welcomes the publication of the Digital and AI omnibus proposals as a positive step toward rationalizing and clarifying the EU digital acquis and addressing existing implementation challenges. While the texts introduce relevant improvements, further systemic changes and a more pragmatic regulatory approach will be necessary to ensure a simple, clear and consistent digital rulebook.

Comments on the European Commission’s Digital Omnibus Proposal – Amendments to the General Data Protection Regulation (GDPR) We strongly support the European Commission’s simplification agenda. In the field of data protection and privacy, action is indeed needed: the current complexity, caused by conflicting rules resulting from different regulations with divergent approaches and broad interpretations, creates…

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

KAN, the Commission for Occupational Health and Safety and Standardisation, welcomes the opportunity to comment on the European Commission's proposal for a Regulation as regards the simplification of the implementation of harmonised rules on artificial intelligence (Digital Omnibus on AI). KAN kindly asks the European Commission to consider the attached position statement.

Siemens Energy | Recommendations for the Digital Omnibus proposal |11 December 2025 Ref. Ares(2026)2554219 - 09/03/2026 Siemens Energy’s Recommendations for the Digital Omnibus Proposal Siemens Energy is a global leader in energy technology.

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

CISPE welcomes the opportunity to comment on the Commissions Digital Omnibus proposal and especially its proposed changes to the Data Acts Cloud Switching chapter. While we agree that further clarifications, we have one serious concern about the law as currently drafted, as explained in the attached document.

The Finnish Food and Drink Industries Federation (ETL) appreciates the opportunity to participate in the European Commissions consultation on the simplification of digital regulation. We strongly support the Commissions efforts to streamline EU legislation related to artificial intelligence, data, data protection and cybersecurity, and to reduce unnecessary administrative burdens, particularly in the food sector…

EXECUTIVE SUMMARY - The European Network of Safety and Health Professional Organisations (ENSHPO) submits this comprehensive analytical report in response to the European Commission's Call for Evidence regarding the Digital Fitness Check. The evaluation of the cumulative impact of the European Union's digital rulebook on competitiveness, innovation, and strategic autonomy is a timely and strictly necessary exercise.

Regulatory Institute Submission on the Proposal for a Regulation on the Digital Omnibus on AI COM(2025) 836 final www.howtoregulate.org The Regulatory Institute is pleased to share its submission on the Proposal for a Regulation 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), COM(2025)…

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

The most impactful simplification for the animal health sector is a clear, operational and sufficiently broad R&D exemption under the AI Act. The way it reads now (specifically developed and put into service for the sole purpose of scientific research and development) risks being interpreted too narrowly by competent authorities, potentially excluding AI systems or models used to research, design or optimise…

Our position Feedback on the Digital Omnibus on AI Regulation proposal AmCham EU speaks for American companies committed to Europe on trade, investment and competitiveness issues. It aims to ensure a growth-orientated business and investment climate in Europe.

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

EUTA welcomes the Commissions Digital and AI Omnibus proposals as an important step towards simplifying the EU digital framework and improving its effectiveness in practice. European-born tech companies strongly support simplification that delivers legal certainty, reduces unnecessary compliance burdens and preserves the EUs risk-based regulatory approach, while fully protecting fundamental rights.

CECIMO welcomes the European Commissions Digital Omnibus proposals as a first step toward simplifying EU digital legislation. However, the proposals do not yet fully deliver on the EUs simplification objectives or sufficiently reduce the regulatory burden on European industry, particularly manufacturers of machinery and equipment.

Developers Alliance welcomes the proposed Digital Omnibus. Key points: 1. AI developers will benefit from relying on legitimate interest for training and operating AI models. A practical risk-mitigation approach is better than impossible data-scrubbing mandates for special categories of data 2.

Developers Alliance welcomes the targeted simplification measures for the AI Act and call for further ambitious efforts to ease the regulatory burden for software developers. We particularly call for: 1. Feasible compliance deadlines, aligned with the availability of standards, and a 12-month extension for transparency obligations. 2.

The Data of Democracy: the Omnibus must protect journalism from one-size-fits-all privacy rules Publishers are very concerned that the omnibus is not simplifying, but instead creating new rules that will harm their business and ability to process data. The proposal must be amended so that it may achieve its intended goals of simplification and supporting media services.

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

Paris, 6 February 2026 POSITION PAPER Digital Omnibus French large companies strongly support the Commission’s draft digital omnibus proposals covering several digital texts and encourage both colegislators to support the most ambitious approach possible in terms of (i) the scope of the texts to be included in this simplification exercise and (ii) the simplification, rationalisation and coordination of the…

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

The German Caritas Association (DCV) welcomes the European Commission’s aim of simplifying digital laws and thus making it easier for organisations to comply with the laws. Caritas’ associations are important pillars of social infrastructure in Germany and support the Draghi report’s approach of combining productivity growth with strong social inclusion.

Filed in German · English published by the European Commission

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

The most impactful simplification for the animal health sector is a clear, operational and sufficiently broad R&D exemption under the AI Act. The way it reads now (specifically developed and put into service for the sole purpose of scientific research and development) risks being interpreted too narrowly by competent authorities, potentially excluding AI systems or models used to research, design or optimise…

TikTok Feedback on Proposal for a Digital Omnibus on AI (AI Omnibus) – February 2026 TikTok is a world-leading video-sharing platform whose mission is to inspire creativity and bring joy. With more than 200 million people across Europe coming to the platform every month, our top priority is to promote a safe experience so that everyone - from emerging artists to grandparents - can express their creativity.

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

January 2026 Digital Omnibus on Data Regulation Position paper Schibsted is the largest news provider in the Nordics owning newspapers, digital news services and commercial broadcasters in Norway, Sweden and Finland. Europeans rely on our services every day for independent, fact-checked journalism.

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

Europes political focus on competitiveness marks a welcome and necessary paradigm shift, which is particularly relevant for the industrial ecosystem surrounding tourism and transport - one of Europes most economically significant sectors in terms of employment, contribution to GDP, and longterm growth potential.

The Federation of Finnish Enterprises welcomes the Commissions intention to simplify the European Unions digital regulation and improve its suitability for small and medium sized enterprises. It is essential that the reforms lead to a concrete reduction in administrative obligations, especially for micro and small companies whose processing of personal data is generally low risk.

As the EU advances its regulatory framework through the Digital Omnibus on AI, retailers and wholesalers stand ready to embrace rules that foster trust, safeguard consumers, and enable innovation to thrive. EuroCommerce has consistently supported a clear, futureproof, and riskbased approach to regulating AI, ensuring that only genuinely highrisk applications face stringent obligations while everyday AIenabled…

Esomar and EFAMRO welcome the European Commissions initiative to simplify and harmonise the EU digital rulebook and call for greater legal clarity in the application of the General Data Protection Regulation (GDPR), particularly in complex market, opinion and social research data chains.

CER takes note of the Digital Omnibus package and, in particular, of the proposed amendments to Articles 4 and 5 of the Data Act, which would allow data holders to refuse access to data qualifying as trade secrets where there is a high risk of unlawful acquisition, use, or disclosure, including risks linked to third countries or entities under their control.

POSITION PAPER On The 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 legislative framework, and repealing Regulations (EU) 2018/1807, (EU) 2019/1150, (EU) 2022/868, and Directive (EU) 2019/1024 (Digital Omnibus) Berlin…

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

We welcome the European Commissions initiative to simplify and harmonise the EU digital rulebook and call for greater legal clarity in the application of the General Data Protection Regulation (GDPR), particularly in complex market, opinion and social research data chains.

NCC Group (trading as Fox-IT in the Netherlands) is a leading pan-European cybersecurity company. With over 25 years experience of delivering digital resilience services, we protect many of the digital products and systems that are used daily by European Union (EU) citizens.

Please find attached the submission of Lionheart Squared (Europe) Ltd concerning the Digital Omnibus. As an Irish-based micro-company, we focus on the "Enforcement Gap" created by current liability models imposed on EU Representatives.

Stellungnahme zum Digital Package Omnibus COM (2025)836 (English version below) EU-Transparenzregisternummer: 031503449561-38 BUGLAS dankt der Kommission für die Möglichkeit, zu dem Vorschlag für das Omnibus-Paket „Digitales Europa“ Stellung zu nehmen. Wir begrüßen die geplanten Vereinfachungen, insbesondere für KMU.

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 Digital Opportunities Foundation recognizes the European Commissions Call for Evidence for a Digital Omnibus (Digital Package on Simplification). The general objective of the initiative is to reduce the administrative costs for compliance for businesses, administrations and citizens in the European Union in application of several regulations of the Unions digital acquis without compromising the objectives…

As a technology company developing artificial intelligence models for video monitoring, biometric recognition, pattern detection, responsible visual AI training, and AI-powered video anonymization, we understand the transformative power of AI and the opportunities it brings. However, we also believe that technology can only thrive in societies and communities where trust in technology exists.

JBCE urges the co-legislators to prioritise four areas in finalising the Digital Omnibus. First, JBCE considers that the proposed amendments to the trade secret safeguards under the Data Act remain insufficient. Trade secret protection must be recognised as a fully independent ground for refusing data access requests, without imposing mandatory notification obligations on data holders.

At Apple, our mission is to create technology that empowers people and enriches their lives. We put our users at the centre of everything we do, from how we design our products, services, and software to the policies we support. We believe privacy is a fundamental human right.

IAB Europe welcomes the European Commissions ambition to simplify the EU digital acquis through the Digital Omnibus proposal. Reducing regulatory fragmentation, addressing consent fatigue, and providing greater legal certainty are essential to strengthening Europes digital economy while maintaining high standards of data protection.

Kaiko supports the Digital Omnibus on AI Act as a constructive reform. We urge the colegislators to: (1) extend documentation/registration equivalence in Article 43, and a notified body fee reduction scheme so that SME/SMC simplifications genuinely reduce the dual MDR/IVDRAI Act burden; (2) adopt harmonized post-market obligations; and (3) provide guidance on GPAI incorporated into medical devices.

The German State Media Authorities (Landesmedienanstalten) welcome the Commissions commitment to a clear, innovation-friendly implementation of the AI Act. We support the principle of reducing administrative burdens, particularly for SMEs and small mid-caps (SMCs), provided that the high level of protection for fundamental rights, democracy, and the rule of law remains intact.

Delivery Hero is one of Europes leading technology platforms, operating food delivery and quick commerce services worldwide, including in 14 EU Member States through our brands Glovo, foodora, foody and e-food. Founded, headquartered and stock listed in Europe, Delivery Hero strongly supports the Commissions ambition to strengthen Europes competitiveness through regulatory simplification.

[The same text is also submitted as PDF for reader convenience.] Wikimedia Europe (WMEU) is a Brussels-based nonprofit association that unites the European groups of the Wikimedia movement. Wikimedia is a global community of people, projects and activities working together to create and share knowledge freely.

JBCE is a leading European organisation based in Brussels representing the interests of 115 multinational companies of Japanese parentage active in Europe. Our members have a strong European footprint and operate across multiple Member States.

Swedish Commerce welcomes the European Commissions Digital Omnibus as a critical opportunity to simplify, harmonise and future proof the EUs digital regulatory framework. For the retail and wholesale sectorsoperating closest to consumers and heavily reliant on scalable, cross border digital serviceseffective simplification must deliver clearer responsibilities, reduced duplication and genuinely risk based…

Dear Members of the European Parliament and Representatives of the Council of the European Union, The mission of Check My Ads is to shed light on and reform the online advertising ecosystem so that it serves people, publishers, and advertisers, and supports the healthy, thriving digital economy globally, including in the European Union.

Comments on the European Commission’s proposal from 19 November 2025 for a Regulation of the European Parliament and of the Council amending Regulations (EU) 2024/1689 und (EU) 2018/1139 as regards the simplification of the implementation of harmonised rules on artificial intelligence (Digital Omnibus on AI) – COM(2025) 836 final Lobby Register No R001459 EU Transparency Register No 52646912360-95 Contact: Dr.

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

ITI’s Comments on the Digital Simplification Package and Omnibus ITI - the Information Technology Industry Council - is the global trade association of the technology industry, representing 80 of the world’s most innovative tech companies. Our membership spans across the entire spectrum of technology, including global leaders on software and AI, hardware, cloud, infrastructure, cybersecurity and semiconductors.

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

ITI’s Comments on the Digital Simplification Package and Omnibus ITI - the Information Technology Industry Council - is the global trade association of the technology industry, representing 80 of the world’s most innovative tech companies. Our membership spans across the entire spectrum of technology, including global leaders on software and AI, hardware, cloud, infrastructure, cybersecurity and semiconductors.

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

The European Commission's proposal for the Digital Omnibus is not the team bus we had hoped for, but neither is it the small car we feared. We welcome the Digital Omnibus and the European Commissions intention to streamline and simplify the digital rulebook. However, the proposals cur-rently on the table do not deliver the relief and clarity that industry hoped for.

Middle Tech Europe (MTE) welcomes the Commission's Digital Omnibus proposals, as regulatory coherence and simplification of the digital acquis are essential for midsized companies. MTE therefore seeks to actively contribute towards the common goal of streamlining the digital acquis and advocate for a proportionate and flexible regulatory approach to the digital sector.

Emerson’s response to the call for feedback on the Digital Simplification Package Introduction Emerson Electric Co., a global technology and engineering company with significant operations in Europe, including approximately 19,500 staff and 45 manufacturing sites spread across 21 Member States, has reviewed the European Commission’s (Commission) Digital Package on Simplification, and welcomes the opportunity to…

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

ANEC fears that the Digital Omnibus proposal results in a reopening of the AI Act and risks undermining the carefully crafted political agreements reached by the co-legislators as well as the horizontal nature of the AI Act, thus lowering consumer protection. The proposal is creating a high level of legal uncertainty that not only puts at risk consumer rights but is also not in the interest of legitimate businesses.

The CERMI Movement welcomes with interest the initiative of the European Commission to simplify the digital legislative framework through future European legislation (Digital Omnibus Regulation on AI) aimed at simplifying the application of harmonised rules on artificial intelligence, in order to improve the functioning of the internal market while maintaining the high level of protection of the safety and…

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Insurance and Pension Denmarks key points are summarized below and elaborated in the attached file. High-risk rules: Insurance and Pension Denmark strongly support linking the implementation timeline of high-risk rules to the availability of standards or other support tools.

The Digital Omnibus will not achieve its objectives. The GDPR amendments do not simplify the law but introduce vague terms, numerous exceptions and additional assessments. No relief is provided for SMEs; legal certainty is weakened and diverging interpretations between Member States and courts with lengthy proceedings are likely.

ACEA welcomes the Commissions proposal for a Digital Omnibus Package as a crucial step toward a more coherent and business-friendly regulatory environment and put forward proposals on key areas which we believe can foster innovation, strengthen competitiveness, and help ensure that Europe remains a global leader in automotive technology and digital transformation.

Telefónica supports the core objective of the Digital Omnibus: simplifying Europes digital regulatory environment. To achieve this ambition, the company urges the co legislators to refine key provisions of the Data Act, clarify critical aspects of the GDPR, clarify some aspects of the functioning of the Single Point of Entry and fully repeal the outdated ePrivacy Directive.

Executive Summary Telefónica supports the European Commissions efforts to deliver a clear, proportionate, and workable AI regulatory framework and welcomes the AI Digital Omnibus as an important step toward legal certainty and simplification. To ensure effective implementation of the AI Act, Telefónica highlights five overarching priorities. 1.

Positionspapier zum Omnibus-Paket der EU-Kommission zur Vereinfachung der digitalen Gesetzgebung und der KI-Verordnung Brüssel, 10. Februar 2026 Unsere Ziele: • Weniger Bürokratie Ressourcen. Wichtig ist, dass auf die Vorschläge der Kommission nun schnelle Verhandlungsabschlüsse folgen. Nur so haben kommunale Unternehmen Planungs- und Rechtssicherheit.

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 Publishers Council (EPC), representing leading news media and publishing organisations across Europe, strongly supports the simplification objectives of the European Commission aimed at supporting growth and competitiveness. We welcome the objectives of the Commission for a pragmatic reform of the ePrivacy Directives outdated rules on cookies and tracking technologies.

The German Association of Tax Consultants (DStV) has issued an opinion on the digital omnibus. It provides an opinion on the proposed adjustments to the European data protection, data and AI legal framework and the introduction of the European Business Wallet (EUBW) and assesses the measures from the perspective of the profession.

Filed in German · English published by the European Commission

European doctors are concerned with several amendments proposed by the European Commission in the Digital Omnibus Package, as they seem to considerably reduce safeguards around personal data use and re-use, in particular when processing special categories of data such as health data in AI contexts.

Finansforbundet (Financial Services Union in Denmark) is grateful for the opportunity to contribute to the consultation on the Digital Omnibus. Finansforbundet broadly supports the regulation of AI in a way that both ensures innovation and competitiveness, while at the same time providing a high and effective level of protection for consumers, employees, and fundamental rights.

PRAGUE, DECEMBER 15TH 2025 POSITION OF THE CONFEDERATION OF INDUSTRY OF THE CZECH REPUBLIC (SP ČR) ON THE DIGITAL OMNIBUS The Digital Omnibus marks an important and long-awaited shift in the EU’s approach to digital regulation.

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

France Invest welcomes the European Commissions proposed Digital Omnibus, viewing it as a positive step toward simplifying EU digital regulation while preserving safeguards and supporting innovation and competitiveness.

The Federation of German Consumer Organisations (vzbv) supports all recommendations submitted to this consultation by BEUC, the European consumer associations' umbrella organisation. vzbv would like to highlight four core recommendations, which are set out in the attached vzbv position paper on the AI Omnibus.

ZVEI recommendations on the „EU Digital Omnibus on Data, Privacy and Cybersecurity“ Summary ZVEI welcomes the European Commission’s initiative to streamline and adjust the EU’s data, cyber security and data protection framework through the Omnibus VII. The Commission’s recognition of the need to enhance Europe’s competitiveness and to strengthen the conditions for data-driven innovation is both timely and necessary.

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

The Digital Omnibus is a cornerstone of the EUs simplification agenda. Europes digital economy has long awaited this proposal, as companies are increasingly constrained by a fragmented regulatory framework and excessive reporting obligations.

BEUC welcomes the opportunity to contribute to the European Commission's public consultation on the Digital Omnibus proposals. The objective of simplification stands as a unique opportunity to improve the application and enforcement of the EU digital rulebook, making it easier for consumers to exercise their rights and seek redress. However, simplification should not lead to deregulation.

Impact OF THE FUTURE ON THE RIGHTS OF PERSONS WITH DISCAPACITY 1.The International Convention, mandatory reference. The proposal does not explicitly mention the Convention on the Rights of Persons with Disabilities, although it is binding on the EU. The future law should be aligned with this framework, which is the only guarantor of a human rights approach.

Filed in Spanish · English published by the European Commission

FH The Danish Trade Union Confederation thanks you for the opportunity to provide feedback on the general digital omnibus. FH welcomes real regulatory simplification that removes double rules and makes laws easier to use and understand. However, regulatory simplification must never come at the expense of workers' or citizens' rights and protection.

FH The Danish Trade Union Confederation is appreciative of the opportunity to provide feedback on the digital omnibus regarding artificial intelligence. FH generally supports real regulatory simplifications. However, this must never come at the expense of workers rights and protection.

I. Amendments to Regulation (EU) 2023/2854 the Data Act - New article 32y(5) of Data Act: rather than imposing higher fees on all very large enterprises, they should be directed specifically at gatekeepers, given their dominant role and significant influence over the market. II.

The La Poste group: Supports: — Simplifying and streamlining the European digital framework; — The targeted merger of the General Data Protection Regulation (GDPR)/ePrivacy into cookies and consent; Consolidation of the rules on non-personal data and open data.

Filed in French · English published by the European Commission

The Digital Omnibus proposal on Artificial Intelligence (AI) is a useful step forward to clarify and simplify the application of the Artificial Intelligence (AI) Act. The La Poste group supports the general approach, in particular the expected publication of operational guides (including the Fundamental Rights Impact Assessment (FRIA)), proportionate easing of obligations for SMEs and small mid-cap companies…

Filed in French · English published by the European Commission

The Spanish Association for the Digital Economy (Adigital), through its permanent Office in Brussels to the EU, kindly shares its response to the feedback period for the proposal about the Digital Omnibus on AI. The document includes three main areas: - Areas of agreement, while including further need for precision. - Policy recommendations of different approaches presented by the Omnibus proposal.

Representing the datadriven marketing sector, FEDMA welcomes the European Commissions efforts to simplify the digital acquis and the AI Act, particularly for SMEs and small midcap companies. Ensuring that regulatory frameworks remain workable and geared toward economic growth is essential to safeguarding Europes competitiveness and the smaller companies that rely on personalised advertising to innovate and create…

Technology Industries of Finland (TIF) welcomes the European Commissions intention to simplify EU digital legislation through the Digital Omnibus proposals on AI as well as data and cyber. European digital investments need better regulation.

SUBMISSION Call for Evidence: Simplification – digital package and omnibus JANUARY 2026 COMMUNIA’s mission is to protect and promote the Public Domain, including access to and re-use of public sector data. For this reason, our contribution focuses specifically on the proposed changes affecting the non-personal data framework.

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

Informatics Europe, the non-for-profit association representing the academic and research informatics community in Europe, is pleased to respond to the call for feedback on the proposal to simplify the digital legislative framework and to the Digital Omnibus.

Informatics Europe, the non-for-profit association representing the academic and research informatics community in Europe, is pleased to respond to the call for feedback on the proposal to simplify the digital legislative framework and to the Digital Omnibus.

Europäische Kommission Datum GZ: COM(2025) 836 final Unser Zeichen Bearbeiter/in Tel GEBU/BAK/2025/0859 [name removed] E-Mail 29.01.2026 [phone removed] [email removed] 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…

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)

Europäische Kommission Datum GZ: COM(2025) 836 final Unser Zeichen Bearbeiter/in Tel GEBU/BAK/2025/0859 [name removed] E-Mail 29.01.2026 [phone removed] [email removed] 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…

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)

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.

The views of the Internet Foundation are expressed by an independent, public benefit organisation whose mission is to promote an Internet that makes a positive contribution to both people and society. Our vision is that everyone in Sweden should want, dare and be able to use the internet. Through research and education, we provide insights into the impact of digitalisation on individuals and society.

Filed in Swedish · English published by the European Commission

Anbei übermitteln wir die Stellungnahme der BRAK zu den beiden Kernrechtsakten des Digital-Omnibus-Pakets. Es handelt sich dabei um eine erste Einschätzung zu besonders wichtigen Punkten. Wir behalten uns vor, noch einmal umfassender Stellung zu nehmen.

Stellungnahme Nr. 66 Januar 2026 Registernummer: 25412265365-88 Stellungnahme zum Vereinfachungspaket für den Digitalbereich „digitaler Omnibus“ Mitglieder des Ausschusses Datenschutzrecht RA Klaus Brisch, LL.M. RA Malte Dedden RA Michael Dreßler RA Peter Hense RA Prof. Dr. Armin Herb (Vorsitzender) RAin Heike Kraus, MLE, LL.M RA Jörg Martin Mathis RAin Simone Rosenthal RA Dr.

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)

TIC Council, the global association representing the Testing, Inspection, and Certification (TIC) sector, provides the attached feedback on the AI Omnibus (https://www.tic-council.org/news-and-events/news/tic-council-releases-recommendations-digital-omnibus-ai). We highlight the importance of simplifying legislation and supporting smart compliance, while preserving the safety safeguards of the AI Act.

To Whome it may Concern, Please see the attached file, which includes recommendations from our Europe Technology Policy Committee. Specifically, we include recomenations for the following Articles: Article 4a: Bias Detection and the Synthetic Data Hierarchy Article 6(4): Defining Narrow in an Era of General-Purpose (or Frontier) Models Article 11(1): Simplification Without Sacrificing Auditability Article 50(7)…

Call for feedback, Ref, Ares(2025)7724296 Opinion of the National Land Survey of Finland on the SINGLE digital package AND RECOGNISATION The National Land Survey of Finland praises the opportunity to comment on the European Commission’s call for evidence, Simplification digital package and Omnibus regulation. The National Land Survey of Finland states the following in that regard.

Filed in Finnish · English published by the European Commission

his paper provides technical and policy analysis demonstrating why the EU Omnibus consent framework cannot deliver valid consent under Convention 108+ Article 5.2 requirements. We document "permission fatigue by design"the systematic engineering of consent theater that presents coerced permission- granting as valid consent while hiding international tracking and surveillance infrastructure.

This submission proceeds from the premise that effective monitoring, supervision, and enforcement of the AI Act depends on an appropriate allocation of responsibilities across Union and national authorities, rather than on further centralisation as an end in itself.

The Digital Omnibus risks weakening existing protection standards under the GDPR. The Commission argues that the recasting of the notion of personal data merely codifies the case-law of the CJEU. That is not the case. It is true that, in SRB (C-413/23 P), the Court of Justice confirmed that pseudonymised data cannot contain a reference to a person for a recipient who cannot be identified.

Filed in German · English published by the European Commission

VDMA welcomes in principle the Digital Omnibus proposals of the EU-Commission as the first small step in the right direction. However, the proposed changes to the AI Act are not enough to keep the promises of the EU´s simplification agenda.

VDMA welcomes in principle the Digital Omnibus proposals of the EU-Commission as the first small step in the right direction: It is positive that three of the most burdensome pieces of Digital legislation are addressed (Data Act, GDPR, AI). However, the proposed changes are not enough to keep the promises of the EU´s simplification agenda.

The Digital Omnibus presents a false choice: weaken GDPR or fall behind in AI. We need to reject this framing. UBava is an Estonian startup that has built working infrastructure proving European companies can use frontier AI while maintaining full data protection compliance. No regulatory rollback required. THE SOVEREIGNTY PARADOX European SMEs face a genuine tension.

KL’s response to the consultation General Digital Omnibus KL has received the European Commission’s proposal for a General Digital Omnibus. The proposal is part of the Commission’s overall digital legislative package and sets out a number of initiatives to modernise the EU’s digital rulebook. KL supports the simplification and harmonisation of the digital rulebook and welcomes the modernisation of the GDPR.

Filed in Danish · English published by the European Commission

The Chamber of Auditors is a body governed by public law whose members are all auditors, sworn auditors, audit firms and audit firms in Germany. In order to protect the right of professional retention, the Chamber of Auditors calls for Article 15 of the GDPR to be adapted in order to prevent abuse of the right of access. Your opinion on the Digital Omnibus is available here.

Filed in German · English published by the European Commission

Personal statement: Why the EU Should Fix Banners, Not Ban Them My name is Francisco Plácido Leite de Castro, CEO and Founder of Super Agent. Since 2021, Super Agent has proven that Consent Assistants solve cookie fatigue without eliminating user choice.

Orgalim, representing Europes technology industries, believes that the digital omnibuses lack ambition and will fall significantly short of delivering on the desired simplification objectives of the European Commission.

Orgalim, representing Europes technology industries, believes that the digital omnibuses lack ambition and will fall significantly short of delivering on the desired simplification objectives of the European Commission.

UNIFE - the European Rail Supply Industry Association welcomes the opportunity to answer the public consultation: Simplification - digital package and omnibus. Please find attached the UNIFE reaction statement to the proposal published on 19 November 2025.

Warsaw, December 10, 2025 Position of Polish Confederation Lewiatan on Digital Omnibus on AI I. General remarks The Omnibus report on the AI Act falls short of delivering the regulatory clarity and competitive edge Europe urgently needs.

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

DI generally welcomes the Commissions digital omnibus but stresses the need for further simplification and harmonization to strengthen Europes competitiveness and innovation. DI supports postponing requirements for high-risk AI systems until relevant standards are in place and welcomes simplified requirements for SMEs. DI prefers promoting AI skills through guidance and education rather than general obligations.

The planned changes to the GDPR under the Digital Omnibus (COM(2025)837/836) systematically shift the balance in favour of data-intensive business models to the detriment of the fundamental rights and security of EU citizens and the cybersecurity of the entire EU economy and public sector. 1.

Filed in German · English published by the European Commission

The Actuarial Association of Europe (AAE) welcomes the Commissions objective to ensure a smooth, coherent and innovation-friendly implementation of the AI Act. Actuaries play a key role across insurance, pensions and financial risk management, where AI is increasingly integrated into pricing, underwriting, claims, investment and operational risk processes.

The recent development of the European digital identification tool, the EU ID Wallet, poses significant risks for citizens, especially if it is based on biometrics. The focus on administrative simplification is not proportional to the need to ensure legal certainty and fundamental rights.

The Consejo General de Colegios de Gestores Administrativos de España (General Council of Administrative Managers’ Associations of Spain) is the public-law corporation that represents the official associations of administrative managers and the professionals authorised to exercise this activity throughout Spain.

Filed in Spanish · English published by the European Commission

To whom this may concern, PHOENIX group welcomes the publication of the Digital Omnibus proposal on 19 November. We look forward to working with the Commission on their efforts aimed at setting digital simplification agenda for the years to come.

Palo Alto Networks welcomes the Commissions Simplification digital package and omnibus consultation, advocating for a regulatory framework that is secure by design, agile in implementation, and innovation-friendly. Our goal is to reduce administrative burdens, enhance legal certainty, and create a coherent EU digital rulebook.

While the objective of clarification and simplification is welcome, the proposal in its current form requires substantial improvement. Moreover, the scope and scale of changes introduced through this Omnibus instrument go well beyond what can reasonably be expected of such a vehicle, particularly given the speed at which it is being advanced. Specific observations are set out below.

THE EXECUTIVE BRIEF: REMOVING REGULATORY BURDEN FOR A MORE COMPETITIVE AND RESILIENT EUROPE Europe’s tech future is a geopolitical imperative. Staying competitive in critical technologies like AI, quantum computing and advanced semiconductors is essential for our economic resilience, defence capability and global relevance.

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

Aanbevelingen door AI Kapitein – Risicoscenario’s en gedrag Inleiding Digitale technologie vormt het kloppend hart van veel ondernemingen. Processen worden steeds meer geautomatiseerd en data-gedreven, waardoor bedrijven operationeel en strategisch sterk afhankelijk zijn van digitale systemen. Toch blijkt dat veel ondernemers de risico’s hiervan onderschatten en pas na een incident in actie komen[1][2].

Filed in Dutch · English published by the European Commission

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

AIUSE CASE - SUBMISSION CARD NAAM: DATUM: USE CASE: AFDELING: 1 2 3 4 5 Ref. Ares(2025)8742407 - 15/10/2025 6 7 WENSELIJKHEID CLIËNT CENTRAAL Sluit het AI-project aan bij de behoeften en wensen van de eindgebruiker? STAKEHOLDERBELANG - INTERN In hoeverre sluit het project aan bij de belangen van onze medewerkers?

Filed in Dutch · 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 Paper on the Simplification of the EUDI Framework Introduction This paper presents the position of InfoCert on simplifying the European Digital Identity (EUDI) Framework. We support the simplification goal that should not hinder trust and interoperability but highlight major obstacles based on their experiences: high compliance costs, lack of legal clarity, and market fragmentation.

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

Dedalus, a European medical software manufacturer, welcomes the Digital Omnibus initiative and urges the EU to simplify and harmonize digital regulations. The current landscape (GDPR, MDR, IVDR, NIS2, CRA, AI Act, etc.) is complex, with overlapping and sometimes conflicting requirements that increase compliance risks and administrative burden.

The Ada Lovelace Institute acknowledges the need for a straightforward, clear application of digital rules, however the proposed simplification agenda should not come at the expense of people, society or fundamental rights. The objectives of the Digital Omnibus cannot be fulfilled without assessing the real world impact and enforcement of the digital acquis.

Usercentrics, provider of both Usercentrics CMP and Cookiebot CMP, welcomes the European Commissions initiative to simplify and harmonize the EUs digital regulatory framework through the Digital Omnibus. As a leading provider of Consent Management Platforms (CMP), we strongly support efforts that aim to reduce administrative burdens for businesses while ensuring that privacy, transparency, and user control remain at…

ROWDSTRIKE RESPONSE TO THE EUROPEAN COMMISSIONCALL FOR EVIDENCE C ON THE DIGITAL OMNIBUS (DIGITAL PACKAGE ON SIMPLIFICATION) 14 October 2025 I. INTRODUCTION I n response to the European Commission’s (“Commission”) Call for Evidence on the Digital Omnibus, CrowdStrike offers the following views.

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

Europe stands at a crossroads. As highlighted by former European Central Bank President Mario Draghi, the multiplication of digital regulators, the accumulation of EU-level legislation, its increased complexity, and the challenges companies face in implementing the rules are having a detrimental impact on Europes competitiveness.

Snap welcomes the European Commissions (EC) initiative to simplify the EU's digital rulebook. To enhance the overall effectiveness and applicability, particularly for challenger platforms, and in line with the EUs broader simplification and competitiveness agenda, we also recommend the following: - Expand impact assessments to explicitly examine the effects of new legislation on challenger companies in digital…

The German Farmers’ Association (DBV) thanked for the opportunity to provide an opinion in the context of the consultation of the European Commission’s simplification agenda with regard to the Digital Package. I. Preliminary comments The DBV is an association of entrepreneurs and stakeholders for all farmers, their families and rural areas, was established in 1948 and is independent from party politics.

Filed in German · English published by the European Commission

Equinet welcomes the European Commission's commitment to ensuring predictable and effective application of the AI Act through the Digital Omnibus proposal. As the European Network of National Equality Bodies, representing 48 independent public equality authorities across Europe and with 21 European Union member states listing one or more Equality Bodies as Article 77 authorities, we emphasize that regulatory clarity…

We welcome the opportunity to provide our contribution to the European Commissions digital policy work, particularly in the context of the upcoming Digital Simplification Package. We welcome the Commissions commitment to enhancing Europes competitiveness and resilience through regulatory streamlining and simplification, and we fully support the ambition to reduce administrative burdens and improve coherence across…

Response of the Free ICT Europe Foundation to the European Commission Call for Evidence: Digital Omnibus Initiative Gouda, 14 October 2025 Free ICT Europe (FIE) welcomes the European Commission’s initiative on the Digital Omnibus as part of the Digital Package on Simplification.

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

Clever Cloud Position Paper Digital Omnibus (Digital Package on Simplification) Founded in 2010 in Nantes, France, Clever Cloud has established itself as a prominent player in the European cloud computing landscape, specializing in innovative Platform as a Service (PaaS) solutions.

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

Emerson’s response to the call for evidence on the Digital Omnibus on simplification Introduction Emerson Electric, a global technology and engineering company with significant operations in Europe, including approximately 19,500 staff and 45 manufacturing sites spread across 21 Member States, has reviewed the Digital Omnibus, part of the Digital Package on Simplification (referred to within as “the Digital…

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

14 October 2025 Response to the Call for Evidence on the Digital Omnibus Package To the European Commission, We welcome the Commission's Digital Omnibus initiative and its objective to reduce administrative costs while maintaining high standards for citizens' rights and interests.

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

Experience with the implementation of the digital acquis, its application, enforcement and effectiveness in reaching the respective legislative objectives is still lacking. The Commissions simplification agenda should not lead to rushed proposals without proper consultation, evaluation and impact assessments. Such changes can easily lead to reduction of protection and further legal uncertainty.

Contribution to the Consultation on the Digital Omnibus as part of the Digital Package on Simplification The Austrian Chamber of Civil-Law Notaries welcomes the opportunity to contribute to the consultation on the Digital Omnibus as part of the Digital Package on Simplification, and in particular the Commission’s quest to launch a Fitness Check stress-testing the coherence and cumulative impact of the EU digital…

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

Prosus Group very much believes that time is now to invest, scale and support the investment and development of the EU tech champions. Therefore, we very much welcome the European Commission strategy to streamline and where necessary, simplify EU Digital Regulation. As mentioned in detail in previous pertinent consultations, we would like to put forward the following overall points: 1.

Adyen is a globally supervised bank providing end-to-end payments and financial services on a single platform, with full banking licenses in the EU, UK, and US. Our response to the European Commissions Digital Omnibus supports efforts to simplify and align the EUs digital rulebook while maintaining high standards for trust, security, and consumer protection.

Zentralverband der deutschen Werbewirtschaft ZAW e.V. Response to the European Commission's Call for Evidence: Digital Omnibus – Data Aquis and AI Act Implementation 14th October 2025 www.zaw.de 14. October 2025 About ZAW The German Advertising Federation (ZAW) is the central association of the advertising industry in Germany.

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

European Entrepreneurs CEA-PME, representing over 1.5 million SMEs and mid-cap companies across Europe, welcomes the European Commissions Digital Omnibus initiative to simplify and harmonise Europes digital legislation. As the backbone of Europes economy, SMEs are most affected by fragmented and inconsistent digital rules.

This is a contribution from two academic transdiscipilnary experts: Prof. Cristiana Santos (Data Protection Law at Utrecht University, The Netherlands) and Dr. Nataliia Bielova (Computer Science at Inria, France).

The La Poste group and its subsidiaries, including Docaposte, are engaged in building a sovereign, secure and interoperable digital ecosystem for the benefit of citizens, businesses and administrations. The Group welcomes the European initiative to simplify and modernise the digital acquis for a more competitive and less administratively burdensome Europe.

Filed in French · English published by the European Commission

APPLiA represents household appliance industry in Europe. Attached please find out detailed input to the call for evidence "Simplification - digital package and omnibus". We strongly believe that the elements addressed by us should be seriously taken into consideration if the digital omnibus intends to provide a real simplification of the existing rules.

AIRIA’s contribution to the European Commission call for evidence Digital Omnibus (Digital Package on Simplification) AIRIA is the first association fully dedicated to the Regulation of Artificial Intelligence (AI).

Filed in Italian · English published by the European Commission

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

General: If EU could ensure harmonised application of all digital regulations, it would make compliance less burdensome. Further, it would be rational to clear burdens of administrative requirements like documentation that do not increase the protection of consumers or society.

Too Good To Go welcomes the opportunity to contribute to the European Commissions ambition to simplify and streamline the EUs digital framework under the Digital Omnibus. As a platform that operates fully digitally, Too Good To Go relies heavily on a coherent and predictable EU digital regulatory framework.

JANE-2, part of Europe's Beating Cancer Plan, unites 121 partners across 29 countries to advance seven European Networks of Expertise in cancer care, including a dedicated Network on Omics Technologies. This Network aims to integrate cutting-edge omics tools into routine cancer care to achieve equitable access for all EU citizens.

Digital Omnibus Initiative Position | Digitalisation Brüssel, 14.10.2025 Introduction DER MITTELSTANDSVERBUND welcomes the opportunity to comment on the planned Digital Omnibus. Fragmented digital regulation increasingly burdens SMEs, particularly in retail, and hampers innovation. The Omnibus should create clarity, reduce overlap, and ensure proportionality in the implementation of EU digital law.

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

The Data Acts implementation creates several conflicts and disproportionate burdens for operators of critical infrastructure such as wind farms. Access to operational data is essential to fulfil service contracts and ensure energy security. Yet many customers do not respond to consent requests, making compliance with the Data Act impossible without breaching contractual duties.

Logitech welcomes the European Commissions Digital Omnibus initiative, particularly to streamline and align digital regulations across the EU. We welcome this effort to reduce complexity, enhance legal clarity, and foster innovationparticularly in areas such as cybersecurity, data governance, and artificial intelligence.

Access Now is first and foremost concerned that the Digital Package on Simplification will in effect amount to a programme of deregulation with serious negative consequences for fundamental rights protections in the European Union.

Digital Omnibus Feedback to the Call for Evidence Datum 14. Oktober 2025 A. About VAUNET VAUNET is the umbrella organization of private audio and audiovisual (AV) media in Germany. The diverse business areas of the approximately 160 members include TV, radio, web and streaming offerings.

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

Relyens, a European expert in insurance and risk management in the health sector, responds to the Commission’s consultation by sharing practical experience. We recommend simplifying reporting procedures for cyber incidents and harmonising EU rules to reduce the administrative burden for health institutions.

Filed in French · English published by the European Commission

As a major German automotive and industry supplier actively engaged in the digital and green transition, working with stakeholders ranging from global big tech to local SMEs, we can provide the European Commission with a comprehensive picture of the different challenges encountered by the current legislative framework.

Proposal for Simplifying Digital Legislation of the EU Estonia fully supports and welcomes the significant progress made in the European Union in shaping a strong and forward-looking digital regulatory framework. Instruments such as the General Data Protection Regulation, Digital Services Act and Artificial Intelligence Act have positioned the EU as a global standard-setter in the digital domain.

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

/Veridas Contribution to the European Commission’s Call for Evidence on the Digital Omnibus (Digital Package on Simplification) October 2025 Veridas is a European technology company specialised in digital identity, and biometric authentication. Our technologies are embedded by public and private organisations to provide secure, privacy-preserving, and user-centric digital interactions.

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

We support the Omnibus objective to reduce cookie consent fatigue, strengthen users privacy rights online, provide clear and straightforward options, and facilitate the use of cookies and other technologies for increased data availability in alignment with the GDPR. Proposal: Recognise Trusted Data Collection (TDC).

Call for evidence Digital Package (Digital Package on Simplification) Ref. Ares(2025)7724296 - 16/09/2025 Bonn, 14th October 2025 Bundesverband Glasfaseranschluss e.V. | Geschäftsstelle | Eduard-Pflüger-Str. 58 | 53113 Bonn Ansprechpartner: [name removed] | Leiter Recht und Regulierung | [email removed] Feedback Call for evidence – Digital Package Omnibus German version below We would like to thank you for the…

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

Companies operating within the European Union face numerous challenges due to a highly complex and overlapping legislative landscape, especially regarding digital laws such as the AI Act, GDPR, NIS2 Directive, and Cyber Resilience Act (CRA). The European Commission should focus on addressing these overlaps to enable a more pragmatic and streamlined compliance approach.

We are grateful for the opportunity to provide feedback on this consultation as the International Federation of Library Associations and Institutions (IFLA). IFLA is the global organisation for libraries of all types, many of which play a key role both in administering research data, and in supporting researchers to access data to fulfil their missions.

Finnish Media Federation (Finnmedia) response to the Commissions Consultation on the Digital Omnibus. Finnmedia is an advocacy organisation for companies in the media and graphic industries. Our member organisations represent news and magazine media, publishing of books and learning materials, radio and printing companies.

GDPR is an essential part of the European digital regulatory framework and should be included in the digital omnibus review: (1) GDPR should be updated to impose statutory duties for all digital regulators to find compromising solutions in case of overlap with other digital laws, and/or duties for data protection authorities (DPAs) to strive towards a harmonised decision praxis in the EU; (2) GDPR should be updated…

The European Society of Radiology (ESR) welcomes the Digital Omnibus proposal, the initiative of the Commission to simplify obligations in the Artificial Intelligence Act, and it is eager to contribute to the call for feedback on the proposal.

General regulatory approach The regulatory options proposed here are based on an ordo-liberalist understanding of society. According to this, the state must create an effective and efficient regulatory framework in which fair and socially sustainable behavior is rewarded (based on market economy mechanisms).

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

This submission is regarding the EU AI Act, though the feedback on harmonised standards could be applicable to other regulations as well. Regarding general-purpose AI (GPAI) models, there is sufficient progress on guidance and compliance mechanisms, in particular the GPAI Code of Practice (CoP), that no delays or changes in the essential requirements on GPAI are necessary.

Regarding the scope and method of the omnibus proposal, AIAL has concerns regarding the justification of removing 'red tape' without a corresponding assessment of impacts to fundamental rights and freedoms. While the need for competitiveness is well understood, this lapse in typical rule making procedure is a severe risk to citizens as we increasingly see rights, especially those regarding digital services…

Call for Evidence: Digital Omnibus (Digital Package on Simplification) Submitted by the Software & Information Industry Association to the Directorate-General for Communications Networks, Content and Technology of the European Commission 14 October 2025 Thank you for the opportunity to submit feedback on the Digital Omnibus (Digital Package on Simplification).

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

The Dutch Startup Association (DSA) supports the European Commissions goal to simplify the EUs complex digital rules through the Digital Omnibus Package. Startups currently face overlapping regulations from the DSA/DMA to the AI Act and Data Act which hinder growth and cross-border scaling.

The Council of European Municipalities and Regions (CEMR) is the organisation representing over 100 000 local and regional governments (LRGs) across Europe. CEMR welcomes the Commissions request for input on its initiative to simplify and streamline the EUs digital legislation to reduce regulatory complexity and compliance costs, provided that such measures will not undermine the objectives of existing legislation.

Culture Action Europe considers it essential that any measures aimed at simplifying rules, increasing data availability, or facilitating data sharing under the Digital Omnibus do not come at the expense of citizens cultural rights. With this in mind, we recommend: 1. Protecting creators rights in the age of generative AI. 2. Enabling cultural agency in data and digital governance. 3.

The Digital Omnibus represents a great opportunity to transform Europes regulatory framework from a source of fragmentation into a catalyst for innovation, competitiveness, and adoption. At Mistral AI, we believe Europes strength lies not in the rigidity of its rules, but in their adaptability, coherence, and ambition.

EU: digitaler Omnibus IHK für München und Oberbayern Rückmeldungen / Positionen: Digitaler Omnibus DSGVO Informations-, Berichts- und Dokumentationspflichten müssen generell auf das notwendige Maß reduziert und eine einheitliche Umsetzung innerhalb der EU durchgesetzt werden. Die DSGVO muss einen stabilen Rechtsrahmen bilden. Aufgrund des hohen Abstraktionsgrades mit der Vielzahl an sog.

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

TOPCASHBACK GROUP LIMITED (“TOPCASHBACK”) RESPONSE TO EUROPEAN COMMISSION CALL FOR EVIDENCE IN RESPECT OF THE PROPOSED DIGITAL OMNIBUS (DIGITAL PACKAGE ON SIMPLIFICATION) Storage or access of information on user devices for attribution typically falls within regulation 5(3) of Directive 2002/58/EC of the European Parliament and of the Council of 12 July 2002 concerning the processing of personal data and the…

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

Mirakl welcomes the European Commissions objective to simplify and harmonise the EU digital rulebook through the Digital Omnibus. We support the aim of reducing unnecessary administrative burdens while maintaining Europes high standards of responsibility, trust and innovation. For the European tech ecosystem to thrive, simplification must focus on clarity, coherence and proportionality. 1.

October 2025 Public consultation of the European Commission Digital Omnibus The European Commission's work program provides for the forthcoming presentation of an omnibus simplification package covering several digital texts, the list of which has not yet been drawn up.

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

The Open Source Security Foundation (OpenSSF) welcomes the European Commissions initiative to simplify and streamline cybersecurity and data incident reporting obligations across EU-level rules. We strongly support the objective of minimizing compliance costs while maintaining a high level of cybersecurity protection.

Please consult the attached file for the detailed response. The Digital Omnibus is a timely opportunity to remove friction from the EUs digital rulebook without diluting protections. EUCI and its members welcome the Commissions focus on reducing administrative burdens while preserving standards, as outlined in the A simpler and faster Europe programme and in the Call for Evidence.

AI Swiftly is an AI-first company focused on responsible innovation and compliance with EU digital and AI regulations. AI Swiftly welcomes the Digital Omnibus initiative and supports the Commissions goal to reduce administrative burdens and improve legal clarity. As a company working with AI and digital services, we see value in streamlining the data acquis and simplifying cookie consent rules.

(1) Critique of Scope and Consultation Inclusivity While the stated objective of simplification is very much welcomed, ECIS believes the current, limited scope of the call for evidence represents a misalignment with the broader expectations set by the political discourse (e.g., State of the Union: far-reaching simplification of our sustainable finance and due diligence rules & streamlining rules and reducing…

Alliance for Responsible Data Collection Comments on EU Digital Simplification Package on Digital Regulations, submitted October 14, 2025 The Alliance for Responsible Data Collection (ARDC) submits the following feedback on the impact of Measure 1.3(1)(a) of the EU AI Act Code of Practice.

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

Enedis is Frances main Distribution System Operator (DSO), delivering electricity to over 38 million consumers and managing Europes largest electricity distribution grid. We welcome the opportunity to share opinions on recent measures regarding data, cyber and the AI Act application.

The European Express Association (EEA) is pleased to provide its feedback to the call for evidence regarding the "Simplification digital package and omnibus" in its attached position paper. The EEA is available to address any questions or requests for clarification via our Secretariat's functional email: [email removed].

The European Network Against Racism (ENAR) welcomes the European Commissions call for evidence in an important topic such as the Omnibus Package. As a network of more than 160 members across Europe, we would like to stress the concerning moves that the Commission is endeavoring for the sake of competitiveness and innovation.

The enclosed submission is provided by leading Baltic technology companies, other businesses, and professional associations listed within. It represents the collective perspective of the Baltic regionLithuania, Latvia, and Estoniaand its major technology stakeholders, reflecting both strong European values and a deep commitment to digital innovation.

Europes ability to lead in the AI era depends not only on investment and innovation, but also on clear, aligned, and proportionate rules. Our contribution attached sets out five pragmatic pillars for simplification, each paired with concrete solutions and recommendations.

14 October 2025 CIPL Response to the European Commission’s Call for Evidence on the Digital Omnibus (Digital Package on Simplification) The Centre for Information Policy Leadership (CIPL)1 appreciates the opportunity to provide input to the European Commission’s Call for Evidence on the Digital Omnibus, as part of the Digital Package on Simplification.

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

Indeed appreciates the Commissions commitment to building a simpler, more coherent regulatory landscape. The Digital Omnibus presents a constructive opportunity to promote clarity and coordination across the EUs digital rulebook. For this Call for Evidence, Indeed's overarching messages to the Commission are: - Use the Omnibus to enhance coherence across existing legislation.

Europe has built one of the worlds most ambitious digital regulatory frameworks. Yet the interaction of overlapping instruments pursuing similar objectivessafety, fairness, and transparencybut through different processes and reporting requirements can result is legal uncertainty, administrative duplication, and fragmented national implementation. Simplification would not mean deregulation.

STM is grateful for the opportunity to respond to the call for evidence on the Digital Omnibus initiative, part of the Digital Package on Simplification. We support efforts to reduce unnecessary administrative burden and to ensure greater coherence and clarity across Europes digital rulebook.

BEUC welcomes the objective of simplification but stresses that this must not lead to deregulation. Any simplification exercise must not undermine the protection of consumers rights but ensure more effective enforcement. BEUC positions in detail are attached. i) Data acquis: we refer to BEUCs position on the Data Union Strategy in attachment.

Esomar welcomes the Commissions initiative to simplify and harmonise the EUs digital rulebook, aiming to increase legal clarity and ensure consistent application of digital rules across the Union. Representing the global market research, insights, and data analytics sector, we advocate for a coherent and streamlined EU digital framework that enables the sector to continue delivering high-quality insights that…

As the European Union (EU) advances its efforts to streamline digital regulatory frameworks under the simplification agenda, the Global Legal Entity Identifier Foundation (GLEIF) believes that the Legal Entity Identifier (LEI) could play an important role in helping companies reduce compliance costs related to the digital acquis, while maintaining the highest standards.

Alliance Digitale welcomes the European Commissions ambitious simplification agenda for the EU rulebook. We strongly support those efforts to lower administrative costs for businesses while maintaining a high level of trust and protection in the online environment. As the leading trade body for digital advertising and marketing in France, Alliance Digitale respectfully recommends to the Commission to: 1.

Schneider Electric welcomes the European Commissions willingness to simplify the European digital regulatory acquis. Targeted simplification will bring enhanced regulatory stability by addressing the most significant hurdles to European competitiveness.

While Eurosmart welcomes the Commissions work on the Digital Omnibus, we note with concern that the current Call for Evidence appears to narrow the initial ambition of this initiative. The Omnibus was originally conceived as a bold and strategic exercise to streamline Europes increasingly complex digital regulatory landscape and to remove inconsistencies between key legislative acts.

The German Construction Federation (ZDB) is the largest and oldest construction association in Germany. We represent the interests of around 35,000 construction companies from the skilled trades and SMEs, which are family-run and owner-managed and have largely been active locally for generations - in traditional building construction, road construction and civil engineering.

CERMI welcomes the digital simplification promoted by the Commission, but reminds that it must not entail a reduction of rights or a lack of protection for social groups requiring enhanced safeguards, such as persons with disabilities (PwD). This process must be approached from the human rights perspective mandated by the CRPD.

We would like to thank you for the opportunity to comment on the omnibus legislation in the digital sector. From the point of view of the German industry, the following points are central: Focus on simplification and innovation – Ensure consistency of regulation across the digital sector, including data protection – strengthen cyber resilience and reduce regulatory inconsistencies – Strengthen definitions in all…

Filed in German · English published by the European Commission

AIMs Key Asks We call for: The prohibition of gold plating and the consistent application of digital rules across all Member States to avoid fragmentation and strengthen the Single Market. The simplification of the EU data acquis (Data Governance Act, Free Flow of Non-Personal Data Regulation, Open Data Directive) to reduce compliance burdens while safeguarding policy objectives.

Skyscanner welcomes the Digital Omnibus as a chance to simplify the EUs digital rulebook while maintaining strong privacy protections and user trust. As a priority, we recommend the EU update the legislative framework for tracking technology towards a risk-based approach that reduces consent fatigue, incentivises the use of privacy-enhancing solutions, and allows organisations to collect important information more…

This contribution focuses solely on the European Business Wallet (EUBW) within the Digital Omnibus package. It addresses a concrete and implementation-relevant gap: how a Relying Party (RP) can securely initiate an initial credential request to an organizations EUBW when no prior trust link exists.

Mastercard’s Response to the Public Consultation on the Digital Omnibus Package Introduction As a global payments and digital infrastructure provider with a strong presence in the EU for more than 45 years, Mastercard welcomes the opportunity to contribute to the European Commission’s consultation on the Digital Omnibus package.

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

The DT4C Alliance welcomes the European Commissions Digital Omnibus as a timely instrument to simplify the EUs digital rulebook and deliver the Draghi Reports burden-reduction goals and the Competitiveness Compass targets. Europes digital competitiveness depends on clear, coherent rules that enable innovation while preserving high standards of trust, safety and fairness.

Europe's digital regulatory framework has reached a critical point. The proliferation of horizontal and sectoral acts including the NIS 2 Directive, Cyber Resilience Act (CRA), Artificial Intelligence Act (AI Act), revised eIDAS Regulation, Data Act, and GDPR has created a complex ecosystem that absorbs resources, slows innovation, and limits the competitiveness of European digital service providers.

Ideas for Simplification - SPCR proposals No. Name and number of Responsible Legal the EU legal act Directorate obligation General Problem definition: reasons for simplification or deregulation How to amend (abolish or Estimated impact change wording, concrete (financial or human proposal how) resources) Proposal Provide the official title ID and citation (e.g., Directive 2006/112/EC on the common system of VAT)…

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

Euroconsumers welcomes the opportunity to share its input for the Commission's Simplification digital package and omnibus package. Please find attached our contribution regarding cookie fatigue. In addition, and with regard to the implementation of the AI Act, Euroconsumers supports a practical and effective implementation of the incoming rules.

ISP Alliance a.s. is an association representing providers of electronic communications services in the Czech Republic. Our membership consists mainly of micro and small enterprises. We appreciate the opportunity to respond to the Commissions Call for Evidence concerning simplification of legislation under the planned Digital Omnibus. More you can find in the file.

Europe has long been at the forefront of regulation and requirements in the digital sector with the aim of creating a safe and secure environment for the use of digital technologies, as well as strengthening digital security against growing threats. While the intention is both right and necessary, the volume and complexity of the legislation has increasingly led to uncertainty and burdens for European businesses.

Shopify welcomes the opportunity to contribute to the European Commissions call for evidence on the Digital Simplification Package and Omnibus. Entrepreneurs across the EU continue to face significant challenges when expanding their businesses across borders many of which stem from digital regulatory barriers.

Supply chain Italy supports a vision of digital simplification based on the balance between innovation and protection, between efficiency and sovereignty. The success of the Digital Omnibus will be measured in its ability to put technology at the service of people and businesses: only an approach that values data sovereignty, promotes ethical and inclusive use of artificial intelligence and ensures the full…

Filed in Italian · English published by the European Commission

The Association of European Radios (AER), representing commercial radio across Europe, welcomes the opportunity to provide feedback on the Call for evidence regarding the Commission's Digital Omnibus (Digital Package for Simplification). Please find attached our contribution for your consideration.

EDRi is Europes biggest network of over sixty civil society groups working together for the protection of human rights in the digital age. Whilst EDRi has always called for clear, coherent and enforceable tech and data laws, we are extremely concerned that the Commissions simplification push will undermine the EUs digital acquis and erode the legal certainty and vital protections it provides.

AMETICs Position Paper on the EU Digital Simplification Omnibus Plan contains specific recommendations and concerns regarding recent and future reforms in digital policy. As Spains leading association representing the electronics, ICT, telecommunications, and digital content sectors, AMETIC welcomes the European Commissions objectives to reduce administrative burdens, streamline regulatory compliance, and modernize…

Contribution on the Simplification Capital Estatutário: 26.260.689,00 Euros - NIPC 509 540 716 Contribution on the Simplification SPMS – Serviços Partilhados do Ministério da Saúde, E.P.E. | Av. da República, n.º 61, 1050-189 Lisboa | Tel.: [phone removed] | Fax: [phone removed] Contribution on the Simplification ABSTRACT This contribution is submitted within the public consultation Simplification – Digital Package…

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

Wolt welcomes the European Commissions Digital Omnibus as an important opportunity to simplify the EUs complex digital rulebook and make it more innovation-friendly while preserving high standards of trust and user protection.

Coldiretti supports a vision of digital simplification based on the balance between innovation and protection, between efficiency and sovereignty. The success of the Digital Omnibus will be measured in its ability to put technology at the service of people and businesses: only an approach that values data sovereignty, promotes ethical and inclusive use of artificial intelligence and ensures the full participation of…

Filed in Italian · English published by the European Commission

We welcome the opportunity to respond to the European Commission Consultation regarding a Digital Omnibus Proposal. Listed below are our main points of simplification measures: 1. A full and inclusive mapping and stress-testing of the EUs Digital Rulebook, alongside setting a high threshold for any new digital regulation, during this legislative term.

We welcome the European Commission’s intention to reduce administrative burdens, increase legal certainty and make existing regulatory burdens workable through a digital omnibus package. Our focus is on improving the framework conditions for data-driven online advertising, which is the main source of funding for commercially active editorial media companies, especially for the news and magazines sector.

Filed in German · English published by the European Commission

Call For Evidence – Digital Omnibus LinkedIn Ireland (‘LinkedIn’) welcomes the opportunity to contribute to the European Commission’s call for evidence on the upcoming Digital Omnibus initiative. We believe that legal clarity and consistency are essential to fostering business stability, driving investment, and ultimately enhancing Europe’s global competitiveness.

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

Position Paper on the Simplification of the EUDI Framework Introduction This paper presents the position of Trans Sped on simplifying the European Digital Identity (EUDI) Framework. We support the simplification goal that should not hinder trust and interoperability but highlight major obstacles based on their experiences: high compliance costs, lack of legal clarity, and market fragmentation.

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

Simplification – digital package and omnibus DCGG Response to the European Commission Call for Evidence About DCGG The Digital Currencies Governance Group (DCGG) is a trade association that represents digital assets issuers and service providers and artificial intelligence firms in the European Union, United Kingdom, Latin America, United Arab Emirates, Asia and Africa.

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

Comments of the International Center for Law & Economics Call for Evidence, Digital Omnibus: Simplifying Rules on Data, Cybersecurity & Ar tificial Intelligence 14 October 2025 Authored by: Mikołaj Barczentewicz (Senior Scholar, International Center for Law & Economics) Kristian Stout (Director of Innovation Policy, International Center for Law & Economics) ICLE C OMMENTS , D IGITAL O MNIBUS P AGE 2 OF 9…

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

Free and effective data use is crucial for Europes digital economy, healthcare, and research, but inconsistent national rules and outdated laws create barriers and increase compliance costs for cross-border solutions. Data availability underpins AI and innovation, but overly complex or fragmented rules risk can discourage data sharing and reuse.