On 19 November 2025, the European Commission published its proposal for the "Digital Omnibus", subsequently sparking significant criticism and opposition. noyb conducted a thorough analysis of all the changes relevant to the GDPR and the ePrivacy Directive, which we firstly published a few days after the proposal was issued by the European Commission. The comprehensive report provides a comparison of the existing law with the Commission's proposal and compiles all our insights. The report also discusses relevant case law and the impact on data subjects, authorities and controllers, providing real-life examples of potential consequences.
This new version, published on 20 January 2026, supplements the report with specific recommendations for the EU legislator on each of the most important articles, including on whether to reject or maintain the proposed changes.
Background. The EU Commission has published its Digital Omnibus proposal on 19 November 2025. Our analysis reveals that the parts amending the GDPR and the ePrivacy Directive would lead to multiple conflicts with the EU’s Charter of Fundamental Rights, inconsistencies, risks of reduced data subjects’ rights and a clear departure from the current logic of the GDPR or CJEU case law.
Detailed legal analysis. We have worked tirelessly on the matter over the past weeks, trying to conduct a deep analysis of all relevant changes. We compiled our findings concerning the GDPR and the ePrivacy directive in a detailed report, which you can download here. In Version 2, the report also provides recommendations to the EU legislator on what to reject and what to improve.
Deep dive video. Our legal team has also recorded a video, which talks about all the relevant changes proposed by the European Commission. You can watch that video here.
