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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