Technology & Innovation

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Information Technology: Chambers Europe 2025

EU Digital Omnibus Regulations - What has been Proposed?

The European Commission has published the much anticipated draft Digital Omnibus Regulations, which are designed to simplify EU digital laws and reduce compliance costs for businesses. The proposals include amendments to the AI Act, GDPR, NIS2, the Data Act and e-Privacy Directive, as well as measures to consolidate existing legislation and streamline reporting obligations. These changes aim to foster innovation and support SMEs and start-ups across the EU.

In this article, we outline the key changes proposed by the European Commission, and consider what these reforms mean for organisations navigating compliance in a rapidly evolving digital landscape.

Digital Services Act – Recent Developments

  • Following the entry into force on 29 October 2025 of a delegated act detailing new rules under the Digital Services Act ("DSA"), vetted researchers are now able to gain unprecedented access to previously unavailable data from very large online platforms (“VLOPs”) and Very Large Online Search Engines (“VLOSEs”) in order to study the societal impact of the platforms' systems. As well as facilitating new studies, the delegated act (discussed in our July 2025 update) also includes measures to protect companies' interests as researchers will have to meet criteria prescribed by law. For further information see European Commission press release here.
  • As part of its legal obligations under Article 91(1) of the DSA to review the DSA, the European Commission has, on the 17 November 2025, published a report evaluating the interaction of the DSA with other EU laws, finding that, overall, the DSA complements other legal acts. The report also considers the designation process for VLOPs and VLOSEs, concluding that the criteria used are fit for purpose. For further details, see European Commission press release here.
  • The European Commission and the Board of the Digital Services Coordinators have, on 18 November 2025, published a report on the most prominent and recurrent systemic risks on VLOPs and VLOSEs in the EU, including discussion of mitigation measures taken by platforms. For further information, see European Commission press release here.
  • In parallel, the European Commission has also launched a targeted consultation on the notification process of suspected criminal offences under Article 18 of the DSA. The consultation, which is open until 19 December 2025, is seeking feedback on areas of the notification process that warrant further clarification. For further details, see European Commission press release here

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