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Clifford Chance
Briefings

Briefings

All aboard the Digital Omnibus? An overview of the EU's Digital Simplification Package

25 November 2025

On 19 November 2025 the European Commission published the much-anticipated EU Digital Simplification Package. Also referred to as the "Digital Omnibus", the package is made up of two proposed omnibus laws:

  • a Regulation on the simplification of the implementation of harmonised rules on artificial intelligence (the "Digital Omnibus on AI"); and
  • a Regulation simplifying and consolidating parts of the EU's digital acquis, making targeted amendments to data, privacy and cyber laws ("Digital Legislation Omnibus").

The Digital Omnibus package is a pivotal step in the EU's push towards harmonising and streamlining its digital regulatory framework, including for AI, data access, privacy, and cybersecurity. Some of the key proposals relate to:

  • facilitating use of personal data in AI training, development and operation;
  • postponed entry into application for high-risk AI provisions, transitional periods for entry of certain transparency requirements for generative AI and targeted amendments to other EU AI Act provisions on oversight, AI literacy, documentation and registration;
  • consent fatigue and cookie rules;
  • codifying a subjective, entity-driven approach to the definition of personal data in the EU's General Data Protection Regulation (GDPR);
  • minimising the burden on controllers for certain data subject rights under the GDPR;
  • creating a single point for incident reporting under a number of EU laws, and increasing reporting thresholds and timeframes under the GDPR;
  • amending and consolidating key EU laws on data access and re-use; and 
  • repealing the Platform-to-Business Regulation.

This briefing provides an overview of the main proposals of the Digital Omnibus package and their practical implications.

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