Updates

Council negotiating mandate added

Added the Council’s mandate for negotiations with the European Parliament, agreed by Coreper on 21 October (ST 14756/26), and made it the latest Council text in the dossier. For the GDPR and ePrivacy provisions examined here it repeats the 2 October text, except for a new Commission report on controller and processor obligations for smaller and non-commercial organisations. The Digital Omnibus legislative tracker now includes the same text.

In GDPR reform in the Digital Omnibus

• Recorded Coreper’s agreement of the mandate in the overview, timeline and scope notes.
• Revised the Article 97 analysis, which now concerns a dedicated report due within six months rather than a point in the periodic evaluation.
• Noted the EDPB opinion added to the EUDPR pseudonymisation provision and the Data Act’s added reference to industrial manufacturing know-how.
• Extended the Council comparison table to the agreed mandate.

Sections updated: Overview, Council changes, Personal data, Enforcement, Practical compliance, Timeline, Evidence coverage

2 October Council mandate text added

Added the Presidency text of 2 October (ST 13886/26), submitted to Coreper as the proposed Council negotiating mandate, and made it the latest Council text in the dossier’s comparisons. The Digital Omnibus legislative tracker now includes the same text. The dossier also records the reported postponement of the Coreper vote from 7 to 11 October.

In GDPR reform in the Digital Omnibus

• Added the 2 October text to the Council comparison and to each affected issue chapter, compared directly with the 3 September text.
• Revised the pseudonymisation, AI, notice, access-request, research, cookie and transfer analysis, including the new measures duty in Article 25a, the right-to-object reference in Article 88 bis, the narrower Article 13(5) exemption and the four-month cookie re-request period.
• Reconciled MLex’s reports on the 21 September draft with the 2 October wording.
• Added timeline entries for the proposed mandate and the reported Coreper postponement, and updated the overview and scope notes.

Sections updated: Overview, Council changes, Personal data, Data-subject rights, AI, Cookies and ePrivacy, Scientific research, Practical compliance, Enforcement, Timeline, Evidence coverage

Second Irish Presidency draft reported

Added an attributed account of a second Irish Presidency Digital Omnibus draft reported on 21 September, covering cookies, AI, pseudonymisation and incident reporting. The detailed textual comparisons continue to use the 3 September Presidency text pending examination of the later draft.

In GDPR reform in the Digital Omnibus

• Added the MLex report and a timeline entry for the later draft and its scheduled discussion.
• Updated the cookies, AI, personal-data and compliance chapters to distinguish reported proposals from changes already present on 3 September.
• Clarified the date and source boundary of the dossier’s primary-text comparisons.

Sections updated: Overview, Personal data, AI, Cookies and ePrivacy, Practical compliance, Timeline, Evidence coverage

New dossier published: GDPR reform in the Digital Omnibus

The proposed GDPR and ePrivacy changes, the legislative file’s development, and my published assessments. Covers personal data, AI, cookies, data-subject rights, scientific research, practical compliance and enforcement, with a selected Council comparison and timeline.

New dossier published: Integrity under the DMA

How the DMA’s integrity safeguards interact with other legal duties, user protection and sensitive AI interfaces, centred on Apple and Google Android

New dossier published: Google Search data sharing

A clause-by-clause comparison of the European Commission’s final and preliminary Google Search data-sharing measures in case DMA.100209, including the principal changes, implementation timetable and redlines.

New dossier published: Google Android interoperability

A clause-by-clause comparison of the European Commission’s final and draft interoperability measures for Google Android in case DMA.100220, including the principal changes, implementation dates and redlines.