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28 November 2025

Digital Omnibus Package: How Will These Changes Affect Your Business?

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A&O Shearman

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The Digital Omnibus Package, presented by the European Commission (EC) on November 19, 2025, includes much anticipated changes across European...
European Union Technology
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The Digital Omnibus Package, presented by the European Commission (EC) on November 19, 2025, includes much anticipated changes across European technology regulatory frameworks of high relevance for market players.

Why now?

Europe's digital rulebook—covering data, cybersecurity, AI, and ePrivacy—has grown increasingly complex over the past decade. While these frameworks have been praised for their consumer-centric focus (often cited as the "Brussels Effect"), critics argue they impose high compliance costs and risk stifling innovation. The Digital Omnibus Package aims to address these concerns by streamlining rules, reducing fragmentation, and introducing a "digital by default" approach.

Highlights

The package contains three separate proposals for regulations. The most notorious two introduce amendments to simplify existing legislation, and are addressed in detail throughout this analysis:

  • Proposal for a regulation on the simplification of the digital acquis (Digital Omnibus for the Digital Acquis)
  • Proposal for a regulation on the simplification of the implementation of Artificial Intelligence rules (Digital Omnibus on AI)

A separate proposal for a regulation on the EU Business Wallet completes the legislative acquis of the package. With the overarching goal of expanding the European Digital Identity Framework to economic operators and public administrations, it seeks to address key problems—fragmentation of national portals, inefficient administrative processes, and compliance obligations—by providing a single, secure, interoperable cloud-based identity solution. This, in turn, enables businesses to identify and authenticate themselves, share credentials, and receive official notifications across the EU using a harmonized, legally recognized identity infrastructure.

Furthermore, the package is complemented by two communications: the European Data Union Strategy, and the EU Consumer Agenda. While they remain non-legislative documents, their relevance lies in the fact that they provide insights into the EC's direction of travel for upcoming legislative reviews.

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The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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