Introduction
The Omnibus Package consists of two proposals to simplify existing legislation and to stimulate growth in the EU in certain sectors.
The first proposal focuses primarily on:
(a) consolidating the EU’s data legislation, including the Data Act, the Data Governance Act and the Open Data Directive, into one single legislative instrument; and
(b) making targeted amendments to the GDPR to ease the administrative burden on organisations (particularly small and medium-sized enterprises).
The second proposal focuses on targeted simplification measures addressing challenges that have impeded the efficient and proportionate implementation of the EU AI Act.
While the Omnibus Package has received significant attention prior to its publication, it should be viewed in light of the relatively narrow nature of the proposals. The Omnibus Package is a European Commission proposal that will undergo European Council and European Parliamentary review before it can be adopted. During this review process, the Omnibus Package could be substantially modified, making it difficult to predict the tangible impact it will have on digital regulation.
Changes across the Omnibus Package range from potentially significant and impactful, to minor and clarificatory, and even to perhaps inconsequential in practice. While commentary has both criticised the dilution of privacy rules and praised a move towards stimulating innovation and growth in the EU, the actual impact of the Omnibus Package is far from certain.
As such, while organisations should keep an eye on the Omnibus Package, we do not recommend making any significant changes to your activities based on the Omnibus Package at this stage.
While the Omnibus Package is a preliminary step for simplifying digital regulation, some of the key changes are in GDPR, EU AI Act and the Data Legislation.
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