European Union: Commission announced Proposal for Digital Omnibus Regulation (EU 2025/0360) including government access to data

On 19 November 2025, the European Commission announced its Proposal for a Digital Omnibus Regulation (EU 2025/0360) on the simplification of the digital legislative framework. The Digital Omnibus would amend a number of existing regulations, including the GDPR, the Data Act, the EU AI Act, and the NIS 2 Directive, while repealing the Regulations on non-personal data, the P2B Regulation, the Data Governance Act, and the Open Data Directive. The Digital Omnibus would amend the Data Act's legal framework concerning the obligation for private data holders to make data available to public sector bodies on the basis of exceptional need. The Digital Omnibus would redefine the obligation to make it applicable to the response to, mitigation of, or recovery from a public emergency. Where requested data is necessary to respond to a public emergency, the public sector body request would concern non-personal data by default, and, where non-personal data is insufficient, further requests can be made for personal data, which should be made available in pseudonymised form where possible. Where data is necessary to mitigate or support the recovery from a public emergency, the public sector body may request specific non-personal data. The Digital Omnibus would also amend the provisions regarding compensation for data provision allowing microenterprises and small enterprises to claim compensation for providing data necessary to respond to a public emergency.