DATEV eG

We support the Commissions agenda to simplify the digital policy regulatory framework through the first Digital Omnibus. However, we would also like to emphasize that further simplification steps remain necessary, as this package will not resolve the most pressing issues. The most influential digital laws such as the GDPR, the CRA or the Data Actand their interplay are notably left unaddressed.

DATEV eG welcomes the opportunity to provide feedback on the European Commission’s proposal for a Data Governance Act COM (2020) 767. Data access is essential for any successful European data-driven business model. Therefore, DATEV shares the European Commission’s overall objective to foster the availability of data by both increasing trust and by strengthening data-sharing mechanisms across the EU.

DATEV welcomes the objectives the EU Commission is pursuing with the roadmap on a legislative framework for the governance of common European data spaces. • In order to provide the public sector as well as the European economy and the civil society with data of sufficient quality and quantity, the public sector should take a front-runner position.

On September 15th, 2022, the EU Commission presented a proposal on a Cyber Resilience Act (CRA). DATEV fully shares the Commissions objective to increase the level of cybersecurity of both hardware and software products in the European Union. In order to unfold their full potential, the foreseen legal requirement should be feasible in practice and serve the intended purpose.

DATEV welcomes the draft guidance published by the European Commission regarding the interpretation of the Cyber Resilience Act (CRA). In particular, the clarification that standalone software is considered placed on the market when it is first commercially made available in the EU provides much-needed legal certainty.

DATEV welcomes this initiative. We observe with concern the increasing governmental interventions and the resulting mounting administrative burden on businesses. The increasing red tape significantly impacts entrepreneurship, the competitiveness, and the innovative capacity of the EU.

As the European Commission prepares its next steps towards a Quantum Act, we would like to highlight that Quantum Key Distribution (QKD) should not be neglected. While Post-Quantum Cryptography (PQC) is rightly receiving significant attention, QKD offers a unique level of protection, particularly in domains where the highest levels of confidentiality are required.

DATEV expressly welcomes the draft regulation and is pleased to contribute with the attached position paper. In brief, the following aspects should be taken into account in the ongoing legislative process: All economically active individuals, in particular self-employed individuals and sole traders, should have access to the European Business Wallet, as they can benefit significantly from the EUBW.

Position Paper on a European Business Wallet June 2025 DATEV eG is the software company and IT services provider for tax consultants, auditors, lawyers as well as their clients. With over 9,000 employees, the company is one of the largest IT service providers in Germany and Europe.

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

DATEV welcomes the EU Commission's initiative to combat VAT fraud and to exploit the opportunities offered by digital technologies. In view of the different digital reporting systems for combating VAT fraud in the Member States, the European initiative is to be welcomed, especially the focus on combating fraud in cross-border cases and the interoperability of the different existing approaches.

DATEV eG welcomes the opportunity to provide feedback on the European Commission’s Inception Impact Assessment on an initiative on instant payments in the EU. DATEV approves the EU Commission’s intention to foster SEPA Instant Payments in order to strengthen the Single Market of financial services and thereby to enhance Europe’s digital sovereignty.