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Digital Omnibus legislative tracker
Texts to 22 Oct 2026

Article 35

Source
IMCO-AM-791061, page 40 pp. 40–43

Amendments as tabled

Four amendments, each tabled separately · IMCO amendments 329–532 to the draft opinion

  1. 390 Alternative Morten Løkkegaard +3Renew · IMCO “The template and methodology shall be proportionate, risk-based and easily usable by SMEs and small mid-cap enterprises, including in cross-border…”

    6. The Board shall prepare and transmit to the Commission a proposal for a common template and a common methodology for conducting data protection impact assessments. The template and methodology shall be proportionate, risk-based and easily usable by SMEs and small mid-cap enterprises, including in cross-border processing activities.

    Justification

    Keeps the simplification agenda credible for smaller businesses and not only for large compliance departments.

    Tabled by
    Morten Løkkegaard, Svenja Hahn, Jeannette Baljeu, Sandro Gozi
    Group
    Renew
    Document
    IMCO amendments 329–532 to the draft opinion
    Printed header
    Article 3 – paragraph 1 – point 9 – point a / xx / xx
  2. 391 Addition Virginie JoronPfE · IMCO “The common template and methodology for conducting data protection impact assessments shall require the controller to evaluate the following: (a) the…” numbered 6a

    6a.The common template and methodology for conducting data protection impact assessments shall require the controller to evaluate the following:

    (a)the risk of reidentification, including using algorithms, and taking into account the means reasonably likely to be used;

    (b)the availability and suitability of state-of-the-art privacy-preserving and privacy-strengthening methods to remove or mitigate this risk, including pseudonymisation, encryption, aggregation, synthetic data, federated analytics and secure processing environments; and

    (c)the risk remaining after applying such techniques.

    Tabled by
    Virginie Joron
    Group
    PfE
    Document
    IMCO amendments 329–532 to the draft opinion
    Printed header
    Article 3 – paragraph 1 – point 9 – point a / Regulation (EU) 2016/679 / Article 35 – paragraph 6 a (new)
  3. 392 Alternative Morten Løkkegaard +3Renew · IMCO “which shall be directly applicable across the Union. Supervisory authorities shall not require controllers to use additional national templates…”

    6a. The proposals for the lists referred to in paragraphs 4 and 5 and for the template and methodology referred to in paragraph 6 shall be submitted to the Commission within [OP date = 9 months of the entry into application of this Regulation]. The Commission after due consideration reviews them, as necessary, and is empowered to adopt them by way of an implementing act, which shall be directly applicable across the Union. Supervisory authorities shall not require controllers to use additional national templates, methodologies or lists for the same processing operations covered by that implementing act. in accordance with the examination procedure set out in Article 93(2).

    Justification

    A common DPIA template only reduces burden if it prevents 27 additional national variants.

    Tabled by
    Morten Løkkegaard, Svenja Hahn, Jeannette Baljeu, Sandro Gozi
    Group
    Renew
    Document
    IMCO amendments 329–532 to the draft opinion
    Printed header
    Article 3 – paragraph 1 – point 9 – point b / xx / xx
  4. 393 Addition Virginie JoronPfE · IMCO “The proposals referred to in paragraphs 4, 5 and 6 shall be without prejudice to the right of the competent authorities and the supervisory…” numbered 6a

    6a.The proposals referred to in paragraphs 4, 5 and 6 shall be without prejudice to the right of the competent authorities and the supervisory authorities of the Member States to draw up their own guidance, standards and lists, in particular the lists referred to in Article 35(4) and (5). The Board shall take into account this national guidance and these national standards and lists when developing the common templates, methodology and lists referred to in these paragraphs.

    Tabled by
    Virginie Joron
    Group
    PfE
    Document
    IMCO amendments 329–532 to the draft opinion
    Printed header
    Article 3 – paragraph 1 – point 9 – point b / Regulation (EU) 2016/679 / Article 35 – paragraph 6