Unpacking the Data Act: Between Regulatory Complexity and Digital Ambition
摘要
In line with this, on November 19, 2025, the Commission unveiled a Digital Omnibus Package specifically addressing the EU data acquis, including a major restructuring of existing data legislation. The Commission proposes to merge the Open Data Directive, the Data Governance Act and the Free Flow of Non-personal Data Regulation into the Data Act. However, these legal instruments are not only being merged but also amended. Targeted adjustments to the current Data Act are also part of the proposal. The omnibus initiative is promising insofar as it could improve the interplay between the various data-related laws. For example, it would introduce harmonized definitions across the framework. The Commission emphasized that the proposed amendments are technical in nature, aiming to refine the data acquis without altering its underlying objectives. However, it remains to be seen whether these adjustments will indeed reduce complexity and stimulate the European data economy, or whether, only a few weeks after the Data Act’s entry into application, they will instead create further confusion among market participants. Likewise, it will be interesting to observe how the co-legislators shape the final outcome of the proposal.