Digital Omnibus - First Legal Analysis

22 November 2025

This week the "Digital Omnibus" came out. noyb is right now working on an in-dept written analysis that we hope to publish the next days. As a preview, we brought together team members that worked on the various aspects of the Omnibus proposal by the European Commission in a video, to go into more details on select topics (the new personal data definition, the new research exemption, limitations on transparency rules and the new rules on access to the terminal equipment). We hope this video is useful for you!

Chapters:
00:00 - Intro and Overview
11:50 - The Narrow Personal Data Definition - Article 4(1)
32:00 - The Broad Research Exemption - Articles 4(38), 5(1)(b), 13 and 89
41:40 - The AI rules - Articles 9(2)(k), 9(5) and 88c
56:10 - Limitation to the Right to Access - Articles 12 and 15
1:00:50 - "SME" Exemption from Privacy Policies - Article 13
1:06:45 - Access to the Terminal Equipment ("Cookie Law") - Articles 88a, 88b and 5(3) ePrivacy
1:17:35 - Summary

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