Texts to 22 Oct 2026

Digital Omnibus proposal· Recital 27a

Analysis in our dossiers
The definition of “personal data”
Same number elsewhere
Recital 27a in ST 9547/26 (a different provision)·Recital 27a in ST 10426/26 (a different provision)·Recital 27a in ST 10677/26 (a different provision)

Text

Recital 27a Digital Omnibus proposal as printed in the Council text of 22 October 2026

Source Council, 22 October 2026. Recital 27a: ST 14756/26, page 25 · exact text page

Pseudonymisation is one of the possible measures within the meaning of Article 25 and Article 32 of Regulation (EU) 2016/679 and does not necessarily have to be applied in all cases. Controllers and processors should remain free to use other equally effective or more effective technical and organisational measures capable of achieving the substantive confidentiality, integrity and data-protection outcomes required by this Regulation. Whether pseudonymisation is appropriate, should be assessed on a case-by-case basis and depends on the context, the nature of the personal data and the existence of other appropriate technical and organisational measures. It is important that pseudonymised data remains subject to appropriate security measures, taking into account the circumstances of a particular processing, in order to protect from the risk of loss, theft or unauthorised disclosure. The effective application of pseudonymisation may also be clarified for controllers and processors through the approval of specific codes of conduct in accordance with Article 40 of Regulation (EU) 2016/679, taking account of the specific characteristics of the processing carried out in certain sectors and the specific needs of micro, small and medium enterprises. It is important that Member States, supervisory authorities, the Board and the Commission support and encourage the drawing up of such code of conducts with regard to the pseudonymisation of personal data. Apart from pseudonymisation, other privacy-enhancing technologies could be applied as appropriate.

How the recitals changed

Each text against the text before it

Recital Commission19 Nov 2025Rec 27Council21 May 2026Rec 27–27bCouncil10 Jun 2026Rec 27–27bCouncil18 Jun 2026Rec 27–27bCouncil3 Sep 2026Rec 27–27cCouncil2 Oct 2026Rec 27–27cCouncil22 Oct 2026Rec 27–27c
Compared withlaw in forcethe proposal21 May text10 Jun text18 Jun text3 Sep text2 Oct text
Recital 27 27 Added 27 Changed keeps only the first sentence 27 Unchanged 27 Unchanged 27 Unchanged 27 Unchanged 27 Unchanged
Recital 27a In neither text 27b Added 27b Unchanged 27b Unchanged 27a Changed 27a Changed 27a Unchanged
Recital 27b In neither text 27a Added 27a Changed 27a Unchanged 27b Changed 27b Changed 27b Unchanged
Recital 27c In neither text In neither text In neither text In neither text 27c Added Wording moved 27c Unchanged 27c Unchanged

Each text against the text before it: +Added in this text, not in the text before~Changed wording changed=Unchanged same as the text before— in neither text

Wording moved the wording comes from a different earlier recital

Parliament amendments propose other recitals under these numbers: Recital 27a (new), Recital 27b (new), Recital 27c (new) and Recital 27d (new).