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Data Act (including the review of the Directive 96/9/EC on the legal protection of databases)

Digital economy and society

This legislative initiative will aim at facilitating data access and use and review the rules on the legal protection of databases. The initiative is about ensuring fairness in the allocation of data value among actors of the data economy, including in business-to-business and business-to-government situations. The initiative would not alter data protection legislation, and would ensure a good balance between data use and incentives for investment in data generation.

Links

Public consultation

ID: 13045

Lobbying Activity

182 responses

Meta urges limited data sharing focused on privacy protection

Meta Platforms Ireland Limited and its various subsidiaries, 25 Jun 2021

Meta requests that data sharing requirements be purpose-specific rather than indiscriminate, with strong privacy protections and respect for trade secrets. They advocate for voluntary frameworks over mandatory obligations and want exemptions for inferred or derived data involving proprietary algorithms.
This would protect their proprietary algorithms and reduce compliance burdens from sharing requirements.
Smaller businesses and researchers lose access to valuable platform data for innovation.

Microsoft seeks limits on government data access powers

Microsoft Corporation, 13 May 2022

Microsoft requests clearer protections for trade secrets and customer data, limiting which entities can be compelled to share data. They want government data access requests directed only to parties contractually responsible, not infrastructure providers. They oppose mandated technical interoperability standards that would make all services identical.
This would protect their contractual relationships with cloud customers and preserve differentiation of services.
Governments lose broader emergency access powers to privately held data for public interest purposes.

Microsoft urges voluntary data sharing over government mandates

Microsoft Corporation, 25 Jun 2021

Microsoft requests flexible voluntary frameworks for data sharing instead of mandatory government access rights. They advocate for industry-led standards and model agreements rather than technical mandates that could stifle innovation.
This would avoid mandatory disclosure of customer data and preserve their competitive advantage.
Public authorities lose direct access to private sector data for public interest purposes.

AmCham EU urges voluntary data sharing and international flow protections

American Chamber of Commerce to the European Union, 13 May 2022

AmCham EU recommends focusing on voluntary sharing to boost innovation and protecting international data flows. They also request the exclusion of trade secrets and more realistic cloud switching timelines.
U.S. firms would maintain control over proprietary data and avoid costly mandatory disclosure.
Government bodies would face higher legal hurdles when requesting private data for public needs.

Consultation response

American Chamber of Commerce to the European Union, 25 Jun 2021

The American Chamber of Commerce to the EU (AmCham EU) shares the objectives of the European Commission to increase access to and further the use of data through the proposed “Data Act”. AmCham EU provides below some suggestions and recommendations to ensure that the outcome of the Data Act will be…

European carmakers seek three-year delay for Data Act

Association des Constructeurs Européens d'Automobiles, 13 May 2022

ACEA requests a 36-month implementation period instead of 12 months, clearer definitions of accessible data, and protections against forced disclosure of trade secrets. They want exemptions from providing free data access to commercial users and restrictions on third parties developing competing services with shared data.
This would reduce their compliance costs and protect competitive advantages from shared vehicle data.
Third-party service providers lose immediate access to vehicle data for innovative services and applications.

German Industry Urges Stronger Protections for Industrial Trade Secrets

Bundesverband der Deutschen Industrie e.V., 13 May 2022

BDI demands stronger protections for trade secrets and sensitive industrial information. They advocate for contractual freedom and a sector-specific approach over horizontal regulation.
This would safeguard competitive advantages by preventing the disclosure of sensitive algorithms.
Public authorities would lose mandatory access to data for public interest tasks.

Consultation response

Bundesverband der Deutschen Industrie e.V., 25 Jun 2021

BDI-Feedback BDI is convinced, that in order to make the EU data economy successful, it is necessary to increase the use and exchange of data based on legal certainty and trustworthy data infrastructures. However, in addition to making data accessible to many interested parties, the legal and…

EuroCommerce urges voluntary terms and trade secret protections

EuroCommerce, 13 May 2022

The organization supports voluntary contract terms especially for smaller companies that lack resources. They request clarifications on definitions like data and products to provide businesses with legal certainty. Additionally, they demand stronger safeguards for trade secrets and stricter limits on government access to private data.
This would help retailers avoid high compliance costs and protect their proprietary business insights.
Public authorities would face stricter limits when requesting private datasets for general public interest tasks.

Consultation response

EuroCommerce, 25 Jun 2021

EuroCommerce welcomes the opportunity to provide feedback to the European Commission’s Inception Impact Assessment on the Data Act. We welcome the effort of the European Commission to establish legal certainty and to promote more data sharing. It is important to ensure that any future (legislative)…

Consultation response

DIGITALEUROPE, 25 Jun 2021

DIGITALEUROPE welcomes the possibility to provide feedback on the European Commission’s inception impact assessment for a Data Act and a revision of the Database Directive. Find attached all our comments. We also plan to reply to the public consultation. - Scope: The different notions applicable…

Pharmaceutical group calls for tighter protections on sensitive data

European Federation of Pharmaceutical Industries and Associations, 13 May 2022

EFPIA requests robust protections for proprietary data to safeguard pharmaceutical innovation. They also want clearer definitions for government data requests during emergencies.
Stronger rules would help firms keep their competitive commercial strategies private.
Public sector bodies could lose easy access to private data during crises.

Consultation response

European Federation of Pharmaceutical Industries and Associations, 25 Jun 2021

Thank you for the opportunity to respond to the Inception Impact Assessment on the Data Act. Please find attached the response of EFPIA

Consultation response

Telefonica, S.A., 24 Jun 2021

Please read Telefonica's comments in the attachment. Thank you.

Finnish Industry Urges Data Act to Limit Sharing to Raw Data

Confederation of Finnish Industries EK, 12 May 2022

The organization demands that data sharing obligations strictly target raw data and provide robust protection for trade secrets. They also argue that the proposed article on international safeguards is unnecessary and should be removed.
This approach protects corporate investments and prevents competitors from exploiting proprietary business intelligence.
Public authorities and third-party firms would be restricted from accessing highly valuable processed data.

Swedish business group warns Data Act risks European competitiveness

Confederation of Swedish Enterprise, 13 May 2022

The organization requests limiting mandatory sharing to sectors with clear market failures and strengthening trade secret protections. They also call for the removal of restrictions on international transfers of non-personal data.
This would protect companies' competitive advantages and prevent the undermining of investment incentives.
Third-party maintenance providers and consumers lose access to cheaper aftermarket repair and data services.

Energy giant EDF calls for narrower EU Data Act scope

ELECTRICITE DE FRANCE, 13 May 2022

EDF argues that sharing requirements should only apply to raw data. They want unfair contract protections expanded to larger firms and a longer implementation period.
Limiting mandates to raw data protects the company's proprietary investments and intellectual property.
Public bodies lose broader access to data during emergencies due to proposed safeguards.

Consultation response

ENEL SpA, 25 Jun 2021

Dear Members of DG CNECT G.1, Enel SpA, a multinational company in the energy sector, highly appreciates the EC proposal for a regulation aimed to create fairness in the data economy by addressing the difficulties of access to and use of data. Enel especially welcomes the willingness to…

German car industry warns Data Act could stifle innovation

Verband der Automobilindustrie, 13 May 2022

The VDA requests a narrower definition of data that excludes internal vehicle functions. They demand strong protections for trade secrets and a longer implementation timeline for manufacturers.
This would protect their technical investments and avoid excessive data processing costs.
Independent service providers would lose access to essential internal vehicle sensor data.

Orgalim Warns EU Data Act Risks Harming Industrial Competitiveness

Orgalim – Europe's Technology Industries, 12 May 2022

The industry calls for mandatory data sharing to be limited to clear market failures while maintaining freedom of contract as the guiding principle. They request extending exemptions to include medium-sized enterprises and lengthening the implementation period to 36 months.
These changes would protect proprietary trade secrets and significantly reduce administrative and technical compliance costs for manufacturers.
Public bodies and third-party service providers would face more restricted access to valuable industrial data.

Consultation response

Orgalim – Europe's Technology Industries, 25 Jun 2021

Orgalim supports the facilitation of data access and use in business-to-business (B2B) and business-to-government (B2G) situations. Orgalim believes that the role of the legislator in this field should be limited only to measures that would encourage and foster B2B and B2G data sharing. Freedom of…

IBM advocates for open standards and balanced cloud switching rules

IBM Corporation, 13 May 2022

IBM wants rules for sharing business data to match personal data rules. Providers should share responsibility for moving data instead of just the original host. Global technical standards should be used to make moving between clouds easier.
Reducing switching barriers benefits IBM's hybrid and multi-cloud service business model.
Incumbent providers face high costs if forced to guarantee performance on other networks.

Consultation response

IBM Corporation, 25 Jun 2021

IBM welcomes the opportunity to comment on the policy options that the European Commission is examining and contemplating for the ‘Data Act’. Creating and promoting more fairness in the data economy, with the aim to increase legal certainty for data sharing in Europe, is a laudable objective and…

Insurance Europe urges specific automotive rules and trade secret protections

Insurance Europe, 13 May 2022

The group demands dedicated laws for vehicle data and exemptions for trade secrets to protect innovation. They also want protections against unfair contracts extended beyond small businesses to all companies.
Better access allows insurers to refine risk models and reduces reliance on dominant cloud providers.
Car manufacturers and cloud giants lose the power to unilaterally dictate data access and pricing.

Consultation response

Insurance Europe, 25 Jun 2021

Insurance Europe welcomes the overall objective of the European Commission to create a single market for data, where data from public bodies, businesses and citizens can be used safely and fairly for the common good. For insurers, a greater availability of data could lead to improved risk…

Consultation response

Siemens AG, 12 May 2022

The Data Act constitutes a horizontal regulation for all IoT application fields even though there appears to be no apparent evidence of market failure or information asymmetries, or only in very specific market segments. Therefore, such a broad regulatory intervention seems premature and could…

German Chambers Demand Clearer Rules to Protect Industrial Data Assets

Deutsche Industrie- und Handelskammer, 13 May 2022

The DIHK calls for precise legal definitions to ensure business planning security. They advocate for shared data rights instead of exclusive user control over information. Additionally, they demand high protection levels for trade secrets and intellectual property.
Companies would maintain their competitive edge and continue investing in digital products.
Individual users would lose the exclusive data control rights originally proposed.

Austrian Business Chamber Demands Stronger SME Protections in Data Act

Wirtschaftskammer Österreich, 2 May 2022

The chamber supports voluntary data sharing through contracts and seeks broader exemptions for smaller firms. They want precise definitions for public data requests to protect trade secrets.
Local firms could innovate while becoming less dependent on large foreign technology giants.
Customers face higher prices as businesses pass on the technical costs of compliance.

Automotive suppliers seek fairer access to vehicle data

European Association Automotive Suppliers, 13 May 2022

CLEPA calls for extending data sharing rules to cover functional external devices. They demand that interoperability requirements apply to manufacturers acting as data holders.
This would prevent vehicle manufacturers from monopolizing in-vehicle data and services.
Vehicle manufacturers lose exclusive control over profitable data and proprietary communication interfaces.

Consultation response

EUROCHAMBRES – Association of European Chambers of Commerce and Industry, 23 Jun 2021

We welcome the aim of the Data Act initiative of creating a fairer and more competitive data economy in Europe and consider the creation of a European data space to be an important step towards strengthening the competitiveness and innovative capacity of European companies in international…

Eurocities urges expanded mandatory data sharing for local public services

Eurocities, 10 May 2022

The organization calls for expanding data sharing beyond emergencies to include law enforcement and service development. They request clearer definitions of public interest that reflect local government responsibilities.
Cities would secure reliable access to urban data while avoiding repetitive fees for datasets.
Private companies would lose the power to restrict access to their proprietary urban datasets.

European Banking Federation urges cross-sectoral data portability expansion

European Banking Federation, 25 Jun 2021

The organization requests that enhanced data portability rights extend beyond IoT devices to all sectors including telecommunications, utilities, e-commerce, and mobility services. They argue the current narrow scope creates market asymmetries and barriers.
This would allow banks to leverage existing PSD2 interfaces and expand services like green financing and personalized financial advice.
Other sectors excluded from standard-setting would face technical barriers and competitive disadvantages in data sharing.

MedTech Europe urges Data Act alignment with health regulations

MedTech Europe, 13 May 2022

Narrow definitions of 'data' and 'user' to prevent unintended consequences for medical devices. Align the Data Act with existing healthcare legislation and data protection rules. Tighten rules for data disclosure to public bodies during emergencies.
Manufacturers would avoid duplicative regulations and protect critical intellectual property from reverse-engineering.
Patients may face safety risks if data is misinterpreted outside of clinical oversight.

European rail industry demands sector-specific data sharing rules

UNIFE, 12 May 2022

UNIFE proposes sector-specific regulations instead of a horizontal approach for the railway sector. They request excluding derivative data and software services to protect intellectual property and trade secrets.
This approach would protect their proprietary technology and maintain current business models based on bilateral contracts.
Third parties and public authorities may face limited data access if access requirements are strictly defined.

French lobby MEDEF demands protection for strategic corporate data

Mouvement des Entreprises de France, 13 May 2022

MEDEF requests narrower definitions to distinguish raw data from processed information. They also seek to preserve contractual freedom in business-to-business data relationships. The group demands stronger safeguards to protect trade secrets and research investments.
Tighter rules would help companies protect intellectual property and maintain their competitive edge.
Public bodies and third-party competitors would face greater restrictions when accessing corporate data.

Consultation response

Mastercard Europe, 25 Jun 2021

Mastercard welcomes the opportunity to provide feedback on the Inception Impact Assessment (IIA) of the European Commission’s future Data Act (including the review of the Directive 96/9/EC on the legal protection of databases). Mastercard is supportive of the development of a human-centric data…

Technology Industries of Finland urges data sharing limits

Technology Industries of Finland (Teknologiateollisuus ry), 13 May 2022

The association demands sharing obligations cover only raw, unprocessed data. They suggest enhancing manufacturers' access to machine data and excluding small-business contracts.
Narrowing the data definition helps companies safeguard trade secrets and avoid losing competitive advantages.
Public authorities and service providers would have more restricted access to valuable, processed industrial data.

Consultation response

Connect Europe, 25 Jun 2021

ETNO, the European Telecommunications Network Operators' Association, welcomes the opportunity to provide feedback on the European Commission’s Inception Impact Assessment for a future Data Act. Please find attached our comments: "ETNO_response to Data Act IIA.pdf". Best regards,

Consultation response

Technology Industries of Finland (Teknologiateollisuus ry), 25 Jun 2021

Initial Comments to the Data Act Technology Industries of Finland has more than 1,600 members in various fields of technology, of which roughly 1,500 are SME companies. We have been actively advancing data usage within our member companies and developing balanced and practical models for data…

CropLife Europe seeks clear "Farm Data" category in Data Act

CropLife Europe, 13 May 2022

The organization requests a new "Farm Data" category to solve data classification dilemmas. They argue the law should only apply to raw data, excluding processed information.
Excluding processed data allows companies to protect high-value proprietary algorithms from reverse engineering.
Tech competitors lose access to processed agricultural data needed for service innovation.

Consultation response

General Electric Company, 25 Jun 2021

For aeronautics Business 2 Government (B2G), GE Aviation would like to state that this aspect is fully covered by the applicable aviation Regulations, as they cover which data must be shared with authorities for certification, organisational oversight, safety monitoring etc. Therefore, there is…

Huawei urges clarity on data sharing rules

Huawei Technologies, 12 May 2022

Huawei requests narrower definitions of 'related services' and 'functional equivalence', protection for confidential business data alongside trade secrets, and clearer technical standards. They argue current definitions are too broad and create legal uncertainty across industries.
This would reduce compliance burdens and legal uncertainty for their IoT products and cloud services.
Consumers and third-party service providers lose stronger data access rights and portability guarantees.

Airlines for Europe urges open access to aircraft operational data

Airlines for Europe, 13 May 2022

A4E requests that airlines own and control all data generated during aircraft operations. They advocate for open access to sensor data to improve fuel efficiency and maintenance. The group also calls for legal clarity to avoid conflicts with data protection laws.
Airlines would reduce operational costs and improve sustainability by breaking manufacturer data monopolies.
Aircraft manufacturers lose their exclusive control over data and the technical maintenance market.

German insurers demand car-specific data rules and fairness

Gesamtverband der Deutschen Versicherungswirtschaft e.V., 13 May 2022

The association requests dedicated rules for vehicles to ensure a level playing field. They want protections against unfair contracts extended to all firms, regardless of size. Finally, they demand better safeguards for trade secrets when data is shared.
Insurers would gain the right to access vehicle dashboards to offer competing services.
Car manufacturers would lose their exclusive control over vehicle data and customer interfaces.

Bitkom warns Data Act may harm innovation without trade secret protections

Bitkom e.V., 19 Apr 2022

Bitkom requests excluding trade secrets from sharing obligations and extending the implementation timeline for complex products. They also advocate for reasonable compensation for data holders to maintain investment incentives.
These changes would lower compliance risks and protect the commercial value of proprietary data.
Third-party service providers would face more restricted access to data needed for competing after-market services.

VDMA warns EU Data Act threatens industrial innovation

Verband Deutscher Maschinen- und Anlagenbau e.V., 12 May 2022

Data sharing should remain voluntary and based on private contractual freedom. The industry seeks exemptions for medium-sized companies to prevent excessive burdens. Proprietary trade secrets and industry-driven standards must be legally protected.
Exemptions would prevent smaller manufacturers from facing unscalable costs and legal risks.
Independent service providers lose the right to access data for machine maintenance.

German engineering association VDMA opposes mandatory B2B data sharing

Verband Deutscher Maschinen- und Anlagenbau e.V., 24 Jun 2021

VDMA demands that freedom of contract remains the central principle for industrial data exchange. They oppose mandatory sharing rules and suggest the EU adopt voluntary model contract terms.
This would protect their proprietary industrial knowledge and ensure returns on machinery investments.
Technology giants lose a potential legal mechanism to gain access to industrial datasets.

IRU urges binding EU framework for transport data transparency

International Road Transport Union Permanent Delegation to the EU, 13 May 2022

The IRU requests a binding legal framework to guarantee transport operators access to generated data. They insist on explicit consent for data re-use and clearer rules for government data requests.
These measures would prevent data monopolies and ensure operators are compensated for providing their data.
Large online platforms acting as gatekeepers would lose their exclusive control over aggregated business data.

ITI Urges Stronger Protections for Trade Secrets in Data Act

ITI - The Information Technology Industry Council, 13 May 2022

ITI recommends that policymakers strengthen the possibility for data holders to apply safeguards for trade secrets. They also urge an implementation timeline of three years to manage technical costs.
This would help companies protect proprietary information and avoid high immediate compliance expenses.
Third-party innovators lose access to technical critical data needed to offer novel business services.

Consultation response

ITI - The Information Technology Industry Council, 25 Jun 2021

Please find enclosed ITI's detailed feedback to the Inception Impact Assessment.

German craft businesses demand fair access to repair data

Zentralverband des Deutschen Handwerks e.V., 13 May 2022

The organization requests clearer rules to prevent manufacturers from using trade secrets or privacy laws as excuses to block data. They also want a broader definition of products to stop companies from bypassing the regulations.
This would allow small businesses to remain competitive in modern repair markets.
Large manufacturers lose their monopoly over the data generated by their products.

Consultation response

Zentralverband des Deutschen Handwerks e.V., 25 Jun 2021

ZDH welcomes the possibility to provide feedback on the inception impact assessment (IIA) regarding the planned Data Act. General observations: The IIA pinpoints the core challenges for SMEs in acquiring data access and using data in business-to- business situations (B2B) and rightly focuses on…

Consultation response

The Danish Chamber of Commerce, 25 Jun 2021

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Volvo Group Demands Extended Timelines and Trade Secret Protections

Volvo AB, 13 May 2022

Volvo requests extending the implementation period to 36 months and ensuring data holders receive fair compensation for costs. They also demand that the regulation does not compromise trade secrets during disclosure.
A longer transition period prevents development delays and protects Volvo's valuable proprietary technical information.
Third-party service providers would face higher costs to access necessary industrial data.

E.ON demands stronger protections for data holders in Data Act

E.ON SE, 13 May 2022

E.ON requests clarification on how the Data Act interacts with energy laws. They seek narrower definitions for public data requests and stronger trade secret protections. The company wants better recognition of the data holder’s commercial investments and rights.
This would safeguard E.ON's commercial secrets and maintain incentives for data-driven innovations.
Public sector bodies and competitors would lose easy access to valuable energy-related datasets.

SAFRAN Urges Sectoral Exemptions and Limited Data Scope

SAFRAN, 13 May 2022

SAFRAN requests that the regulation only apply to raw data. They propose a differentiated regime for the sensitive aerospace and defense sectors. They also seek to prevent technical data transfers to third countries.
Limiting the scope would reduce implementation costs and protect proprietary technical designs.
Non-EU users and competitors would face restricted access to industrial technical information.

Consultation response

Booking.com B.V., 25 Jun 2021

Booking.com welcomes the opportunity to provide input to the Commission’s work on the future Data Act initiative. We share the view that data is at the centre of the digital transformation of today’s economy and society. We therefore support the Commission’s intention to explore the possibility,…

Consultation response

Verband der Chemischen Industrie e.V., 13 May 2022

Der VCI bedankt sich für die Möglichkeit einer Rückmeldung zum "EU Data Act" und nimmt im beigefügten Dokument Stellung.

Wrtsil seeks clarity on Data Act for maritime industry

Wärtsilä Corporation, 13 May 2022

Wrtsil requests that derived data be explicitly excluded from the regulation's scope. They also seek a clearer definition of a user within complex shipping contracts. Finally, they urge the Commission to address how rules apply to non-EU parties.
These clarifications would help the company protect its proprietary digital innovations.
Non-EU service providers and shipowners would lose access to free engine data.

BBVA Urges EU to Expand Data Sharing Across All Sectors

BANCO BILBAO VIZCAYA ARGENTARIA, 10 May 2022

BBVA calls for a broader framework including data from different sectors like telecommunications and utilities. They support mandatory compensation for data holders and clearer cloud switching rules.
Accessing cross-sectoral data helps the bank improve credit assessments and financial products.
Large digital platforms lose the ability to restrict data access for competing services.

Software alliance urges narrower scope for new EU Data Act

Business Software Alliance, 13 May 2022

BSA requests narrowing the regulation's scope to raw data from connected devices. They want software processors excluded from the definition of data holders. They also recommend exempting trade secrets from mandatory sharing obligations.
Software firms would avoid costly compliance and protect their proprietary business models.
Public authorities would have less power to access data outside of emergencies.

Consultation response

Business Software Alliance, 25 Jun 2021

BSA | The Software Alliance (“BSA”) welcomes this opportunity to offer these comments in response to the European Commission’s Inception Impact Assessment on a proposed Data Act (the “IIA”). Please find our comments attached. Thomas Boué

Philips seeks tighter data rules and 48-month implementation delay

Koninklijke Philips, 13 May 2022

Philips wants to narrow the definition of data to information actively created by users while excluding trade secrets. They also request extending the implementation period from 12 months to at least 48 months. Additionally, data sharing must not compromise the safety or performance of medical devices.
Limiting data sharing helps the company protect its intellectual property and innovation.
Smaller rivals lose the opportunity to access valuable datasets held by industry leaders.

Consultation response

Verband Kommunaler Unternehmen e.V., 25 Jun 2021

Der VKU bedankt sich für die Möglichkeit, zur Folgenabschätzung der Kommission zum sogenannten Datengesetz Stellung zu nehmen. Position des VKU in Kürze: Der VKU begrüßt das Vorhaben der Kommission, Daten des Privatsektors für das Gemeinwohl nutzbar machen zu wollen. Im Rahmen des Datengesetzes…

Spanish Banking Association urges broader data sharing scope

Asociación Española de Banca, 11 May 2022

The association requests excluding banking hardware like ATMs from the scope while broadening the regulation to include telco and utility data. They also emphasize that data holders must receive fair compensation to prevent market asymmetries.
Banks would gain access to diverse datasets to improve credit assessments and financial service offerings.
Telecoms and utility companies lose exclusive control over consumer data that banks wish to access.

Tyre industry urges specific rules for vehicle data access

European Tyre & Rubber Manufacturers' Association, 12 May 2022

The association supports the right of users to share data with third parties. They request a specific regulation for the automotive sector to standardize data access. This should include an independent authority to govern access rights.
Sector-specific rules would prevent vehicle manufacturers from unfairly blocking access to valuable technical data.
Vehicle manufacturers lose their ability to act as exclusive gatekeepers of in-vehicle data.

Finnish Innovation Fund Sitra urges SME-friendly Data Act rules

Suomen itsenäisyyden juhlarahasto, 6 May 2022

Sitra requests that regulations are simplified for smaller firms to prevent excessive compliance costs. They also suggest using industry-led standards and ensuring that new laws do not overlap with existing rules.
Simplification would help Finnish companies overcome major regulatory barriers to data innovation.
Large cloud providers will lose market power as customers gain rights to switch services.

German consumer federation calls for clearer data protection rules

Verbraucherzentrale Bundesverband, 13 May 2022

The group demands that data protection laws always take precedence over the proposal. They request clearer definitions and a ban on commercializing personal data by third parties.
Consumers would gain more control and technical protection over their generated data.
Car manufacturers lose their exclusive power to dictate access terms for mobility data.

Consultation response

Video Games Europe, 25 Jun 2021

Please find attached the response from the Interactive Software Federation of Europe to the Inception Impact Assessment Consultation on the Data Act and amended rules on the legal protection of databases. Many thanks for your consideration.

TIM calls for voluntary agreements and narrower Data Act scope

TIM S.p.A., 13 May 2022

TIM requests that data exchanges remain primarily voluntary and contract-based to preserve innovation and investment incentives. They call for connectivity services and mobile devices to be explicitly excluded from the regulation's scope. The company also insists that mandatory government data access be strictly limited to exceptional cases with guaranteed cost recovery.
Restricting the scope protects TIM's existing commercial data services and reduces its regulatory compliance burden.
Public authorities face higher costs and more restrictions when accessing private data for public needs.

Merck urges liability protections and security safeguards in Data Act

Merck, 13 May 2022

Merck requests incentives for data sharing instead of broad distribution of rights. They want data holders shielded from liability for third-party errors or cybersecurity failures. Additionally, they call for clearer rules on data retention and public sector access.
Limiting liability for third-party actions protects the company from unforeseen legal and financial costs.
Increased infrastructure and technical requirements could lead to higher prices for individual consumers.

Consultation response

News Media Europe, 24 Jun 2021

Please find attached News Media Europe's contribution to the roadmap.

Consultation response

Federation of European Securities Exchanges, 15 Jun 2021

FESE supports the plan of the European Commission in proposing an overarching data strategy that has the potential to achieve the benefits of the single market. To this end, we believe a harmonised European approach is preferable to speed up the use/investment in technologies while effectiveness,…

OVHcloud Urges Faster Removal of Cloud Switching Barriers

OVH Groupe, 12 May 2022

The company calls for the immediate removal of fees when customers switch cloud providers. They advocate for open-source standards and mandatory reversibility to prevent user lock-in. They also demand exclusive European jurisdiction for sensitive data to ensure sovereignty.
Ending switching barriers helps the European firm compete with dominant global rivals.
Global cloud giants would lose their market dominance and ability to lock-in customers.

European Co-operative Banks Urge Fairer Data Sharing Framework

European Association of Co-operative Banks, 12 May 2022

The association insists data sharing remains voluntary and contractual while ensuring a level playing field. They call for clearer definitions of connected products and more time to switch cloud services.
This would ensure they receive financial compensation and protect their competitive business models.
Public authorities would face more hurdles and delays when requesting data for the common good.

Workday calls for Data Act to reflect SaaS market realities

Workday, 13 May 2022

Workday urges regulators to refine the law to account for the complexity of enterprise software. They request longer switching timelines and clearer definitions for cloud-based services to avoid stifling innovation.
These changes would protect Workday's competitive advantage and reduce its regulatory compliance burden.
European IT consultants risk losing their business model to mandated provider-led switching.

Consultation response

Workday, 25 Jun 2021

Workday is pleased to have the opportunity to comment on the European Commission’s Inception Impact Assessment (IIA) for the proposed Data Act. Workday is a leading provider of enterprise cloud applications for finance and human resources, helping customers adapt and thrive in a changing world.…

Consultation response

Computer & Communications Industry Association, 24 Jun 2021

The Computer & Communications Industry Association (‘CCIA Europe’) appreciates the opportunity to provide comments on the policy options which the European Commission (‘Commission’) is considering ahead of its proposal for a new Data Act. CCIA Europe remains a staunch supporter of policies…

Liberty Global urges stricter limits on data sharing requirements

Liberty Global Corporate B.V., 13 May 2022

Liberty Global requests that data sharing remains limited and proportionate to avoid excessive administrative burdens. They argue requests must be specific and granular to protect trade secrets. Furthermore, they demand that public sector bodies avoid “data fishing” by clearly stating their legal basis.
Narrower requirements would lower administrative costs and protect the company from sharing commercially sensitive information.
Public sector bodies would have less flexibility and a higher legal burden when requesting essential data.

RELX seeks clearer rules to protect its processed data assets

RELX, 12 May 2022

RELX requests clearer definitions for which products and actors must share data under the new rules. They want to ensure that complex mixed datasets and existing business contracts remain protected from mandatory disclosure requirements.
This would prevent the forced sharing of their high-value, processed information tools.
Public authorities may face greater hurdles when attempting to access private sector data.

Health tech group COCIR seeks to narrow Data Act scope

European Coordination Committee of the Radiological, Electromedical and healthcare IT Industry, 12 May 2022

COCIR requests narrowing the data definition to protect intellectual property and trade secrets. They propose extending the transition period from 12 to 48 months for compliance.
This would protect proprietary manufacturing secrets and significantly reduce immediate compliance burdens.
Researchers and third-party service providers would lose access to valuable machine-generated diagnostic data.

Consultation response

European Coordination Committee of the Radiological, Electromedical and healthcare IT Industry, 25 Jun 2021

COCIR welcomes the opportunity to provide feedback to the European Commission’s inception impact assessment for a Data Act. COCIR fully endorses the Commission’s view that the availability of and access to data holds immense potential for innovation and value creation, and that this will greatly…

Consultation response

Fédération Internationale de l'Automobile, 21 Jun 2021

The FIA European Bureau welcomes the Commission’s plans to address the systemic challenges of data access and use, as well as enhance citizens control over their data by means of a Data Act. Data-driven mobility The IIA recognizes the essential role of data in the digital economy. With the advent…

Finnish SMEs urge stronger data access rights for smaller firms

Suomen Yrittäjät ry, 11 May 2022

The federation supports exempting small businesses from data sharing obligations and broadening accessible data definitions. They also demand technical feasibility guarantees before cloud service providers can sell services.
SMEs would benefit from improved data access and reduced costs when switching providers.
Cloud service providers would lose revenue from the withdrawal of customer switching charges.

Consultation response

Suomen Yrittäjät ry, 15 Jun 2021

We welcome the aim of the Data Act initiative of creating a fairer and more competitive data economy in Europe. To achieve this, it is crucial that especially SMEs have better and more equitable opportunities to access, share and use data. Business-to-government data sharing for the public…

Consultation response

Fédération Nationale des Syndicats d'Exploitants Agricoles, 25 Jun 2021

(Cf. PJ pour avis complet) Le secteur agricole et agroalimentaire est caractérisé en Europe par un très grand nombre de petites et moyennes entreprises. À l’échelle européenne, on compte plus de 10 millions d’exploitations agricoles. L’interconnexion entre ces structures est importante et…

La Poste demands clearer rules and fair data compensation

LA POSTE, 13 May 2022

The organization requests clearer legal definitions for the internet of things and data types to prevent legal uncertainty. They argue that data sharing should prioritize voluntary agreements and processed data must be distinguished from raw information. Additionally, they call for strict limits on government requests for private data to protect business secrets.
These changes would protect their commercial investments and unique business models from competitors.
Smaller businesses and public authorities would face higher costs for accessing data.

ESBG urges fair compensation for data sharing costs

European Savings and Retail Banking Group, 12 May 2022

The ESBG supports mandatory compensation for data access costs and preventing negative business impacts. They want credit cards excluded from the regulation's scope for security reasons. Additionally, they argue that inferred and derived data should remain protected.
Banks would protect their proprietary insights and recoup technical costs for data sharing.
Small companies and data users face higher costs if exemptions are narrowed.

Consultation response

Confédération des Petites et Moyennes Entreprises, 13 Apr 2022

Les TPE-PME prennent dûment part à l’économie numérique et en perçoivent des bénéfices concrets. Selon le baromètre France Num, réalisé en octobre 2021, 78 % des dirigeants de TPE-PME considèrent que le numérique représente un bénéfice réel pour leur entreprise. La perception de ces bénéfices est…

ZVEI Warns Data Act Risks Industrial Trade Secrets

ZVEI e.V. - Verband der Elektro- und Digitalindustrie, 13 May 2022

The group wants separate rules for business and consumer data. They demand stronger protection for trade secrets and a longer implementation period.
This would lower compliance costs and protect proprietary research from industrial competitors.
Third-party service providers lose easy access to industrial data for new services.

Consultation response

ZVEI e.V. - Verband der Elektro- und Digitalindustrie, 25 Jun 2021

ZVEI feedback to the consultation on the Data Act Roadmap The EU-Commission addresses a variety of aspects of data economy potentially affecting a multitude of legal questions in competition, contract, intellectual property and data protection law. In general, the enormous potential of data…

Consultation response

ACT | The App Association, 25 Jun 2021

Please find attached the feedback of ACT | The App Association (Transparency Reg. # 72029513877-54) to the European Commission’s roadmap for a Data Act. Anna Bosch Policy Associate ACT | The App Association (Transparency Reg. # 72029513877-54) Rue de Trèves 45 B-1040 Brussels

MFE demands smart TV inclusion in EU Data Act

MFE - MEDIAFOREUROPE N.V, 13 May 2022

MFE requests that the regulation include devices like smart TVs in its scope. They demand that media providers retain exclusive access to their service data.
Broadcasters would regain control over audience data currently captured by device manufacturers.
Large technology platforms would lose their ability to exploit data from European media.

Consultation response

vbw - Vereinigung der Bayerischen Wirtschaft e. V., 3 May 2022

Mit dem Entwurf des Data Acts zur Schaffung harmonisierter Vorschriften für einen fairen Datenzugang und eine faire Datennutzung legt die EU-Kommission einen weiteren Baustein der umfassenden Datenstrategie vor. So richtig das Ziel auch ist, eine starke Datenwirtschaft in der EU aufzubauen, so…

Siemens Healthineers warns Data Act could stifle medical innovation

Siemens Healthineers AG, 13 May 2022

The organization urges policymakers to protect trade secrets and narrow the broad definition of data. They advocate for sector-specific rules rather than a premature, one-size-fits-all regulatory intervention.
Restricting data sharing protects their proprietary medical software and maintains their market leadership.
Tech competitors lose mandatory access to datasets needed to build competing health services.

Finnish IT Center Urges Broader Data Access for Scientific Research

CSC – IT CENTER FOR SCIENCE LTD., 13 May 2022

The organization supports the Data Act but requests clarifications on scientific research implications and expansion of business-to-government data sharing beyond exceptional needs. They want beneficial treatment for micro and small enterprises extended to research organizations.
This would increase their access to data for research purposes and reduce costs.

Visa Europe urges clear guidance on international data sharing rules

Visa Europe, 13 May 2022

Visa requests harmonized rules for government data access and specific guidance on international transfers. They seek clarity on how data sharing requirements interact with existing data protection laws.
Clearer regulatory guidance would lower the cost of assessing transfer conditions and prevent operational risks.
Consumers and small businesses face higher fraud risks if data localization limits security monitoring.

Scientific Publishers Seek Clearer Data Act Protections for Databases

International Association of Scientific, Technical and Medical Publishers, 13 May 2022

The association requests that exclusions be written into the Articles instead of Recitals to ensure legal certainty. They want speech and text recognition services added to the list of excluded products. They also request consistent language between Article 35 and Recital 84 regarding database protection rights.
This would protect their database investments from forced data sharing requirements.

Consultation response

Broadcom, 25 Jun 2021

Please find a short paper with our contribution to the impact assessment consultation. We are thankful to the Commission for giving us the opportunity to contribute

Scientific Publishers Oppose Changes to EU Database Protection Rules

International Association of Scientific, Technical and Medical Publishers, 25 Jun 2021

STM asks the Commission to retain current Database Directive provisions, particularly the sui generis right. They argue it enables rather than obstructs data sharing and that additional exceptions or compulsory licensing are unnecessary.
This would protect their ability to monetize curated databases and maintain existing licensing revenue streams.
Researchers and commercial users lose easier access to scientific databases for analysis and innovation.

Consultation response

Fédération Française de l'Assurance, 12 May 2022

10 May 2022 Joint Statement on Data Act and the need for a sector-specific legislation on access to in-vehicle data By ACA, FFEA, FRANCE ASSUREURS, MOBILIANS, MOBIVIA, SESAM LLD, SNSA & UFE; connected mobility players New services arising from vehicle connectivity will improve peaceful…

ADAC urges fair data access for vehicle owners and competitors

Allgemeiner Deutscher Automobil-Club e.V., 12 May 2022

The organization requests that data access occurs independently of manufacturers and without their monitoring. They demand sector-specific legislation to address complex data flows and ensure all product-generated data is accessible.
This enables independent providers to offer roadside assistance and grants consumers sovereignty over their vehicle data.
Automobile manufacturers lose their complete control over data streams and their ability to monitor competing services.

Consultation response

UNION FRANCAISE DE L'ELECTRICITE - UFE, 12 May 2022

New services arising from vehicle connectivity will improve peaceful driving, comfort and life of drivers and passengers, while contributing to road safety, infrastructure optimization, ecological transition and vehicle electrification. As with any digital technology, data represents the key…

Consultation response

Leaseurope, 25 Jun 2021

Please find attached Leaseurope feedback to the Data Act.

Consultation response

Hauptverband der Deutschen Bauindustrie, 18 Jun 2021

Challenges with Data in Construction Sector The German Construction Industry would like to draw the European Commission’s attention to the specific challenges the industry faces in Europe with regards to Data. Introduction Digitalisation is a key driver for the construction industry. The…

DEKRA calls for better data access for safety inspections

DEKRA e.V., 13 May 2022

DEKRA calls for the removal of the "exceptional need" requirement for public bodies to access data. They demand that data for sovereign uses like vehicle inspections be unfiltered, unmodified, and shared under fair conditions.
Guaranteed access to raw vehicle data enables DEKRA to maintain its testing and certification business.
Vehicle manufacturers lose their dominant market position and exclusive control over valuable technical data.

Consultation response

DEKRA e.V., 21 Jun 2021

For DEKRA, an independent TIC company, safety, security, and sustainability are our vision and mission. In the field of vehicle inspection, DEKRA represents a leader, whose objective is to ensure that vehicles are safe during their whole life cycle. To guarantee that future automated vehicles (AVs)…

EDSO urges sector-specific rules for smart meter data access

EDSO for Smart Grids, 6 May 2022

They want smart meters excluded from the product definition to avoid conflicting with energy sector rules. They propose making real-time data requirements optional because current infrastructure often cannot support them. They also seek to limit the definition of public sector bodies to prevent excessive data sharing.
This would shield operators from duplicative regulatory requirements and lower technical costs of data compliance.
Public researchers and government bodies would face stricter limitations when attempting to access energy data.

Japan Business Council seeks 36-month grace period for Data Act

Japan Business Council in Europe, 13 May 2022

The council requests extending the application deadline from 12 to 36 months to accommodate complex technical requirements. They also advocate for clearer definitions of data scope and stronger safeguards for trade secrets.
A longer transition period prevents immediate high costs of redesigning established manufacturing processes.
Public authorities lose the ability to request business data during non-emergency situations.

Consultation response

Institut der deutschen Wirtschaft Köln e.V., 11 May 2022

Please find the full comments of the German Economic Institute (institut der deutschen Wirtschaft) on the Data Act enclosed (in German). Our key feedback is the following: The aim of the Data Act is to ensure that more data is available in Europe and that the potential of the data economy can be…

German Property Federation urges GDPR alignment and data safeguards

Zentraler Immobilien Ausschuss, 13 May 2022

The federation demands resolving contradictions with GDPR to ensure legal certainty for businesses. They call for stronger controls on government data requests to protect sensitive trade secrets. They insist that technical standards must be developed in close consultation with industry.
Clearer rules would reduce legal risks and facilitate new digital services in real estate.
Public authorities would face greater restrictions when requesting sensitive private data from companies.

Consultation response

European Council for Motor Trades and Repairs, 25 Jun 2021

See attached document: "Feedback CECRA - Data Act - 210625.pdf"

Consultation response

Belron International Limited, 13 May 2022

Belron® is the world’s leading vehicle glass repair, replacement, and recalibration service provider, operating in over 25 countries in Europe with brands such as Carglass®, Autoglass® and Safelite®. Belron supports the Commission’s proposal for a Data Act and considers it an important step in…

German banking committee urges broader data access and compensation

Die Deutsche Kreditwirtschaft, 13 May 2022

The committee wants the Data Act to cover more than machine-generated data. Banks should receive fair compensation for providing access to customer data. They request longer timelines for switching between data processing service providers.
Broader data access allows banks to offer new customer-focused lending products.
Tech giants lose market power as they are excluded from accessing data.

Consultation response

Belron International Limited, 25 Jun 2021

Belron® is the worlds leading vehicle glass repair, replacement and recalibration service provider, operating in over 25 countries in Europe with brands such as Carglass®, Autoglass® and Safelite®. As a key provider of aftermarket services in the automotive industry, Belron is cognisant of the…

Credit bureau association ACCIS seeks clarity on EU Data Act

ACCIS, 13 May 2022

ACCIS requests explicit clarification on how data sharing rules apply to credit bureaus. They seek a watertight definition of when governments can access private business data. They also demand consistent interpretation with existing data protection laws.
Precise definitions would provide legal certainty and shield their proprietary data from government requests.
Public authorities lose broad powers to collect private data during crises.

Wikimedia Europe proposes opt-in system for database protection

Wikimedia Europe, 10 May 2022

Wikimedia proposes granting database protection only when producers expressly reserve rights. They advocate for machine-readable markers to indicate when data is not free for reuse.
This change would facilitate free information sharing and resolve licensing conflicts.
Database producers lose automatic legal control over facts and non-original data.

Consultation response

Wikimedia Europe, 25 Jun 2021

As a global movement that, among others, develops and runs the world's largest free knowledge base Wikidata (made in the EU!) we acknowledge and welcome the hard work of the Data Policy and Innovation unit in freeing up data and making it re-usable over the past years. Thank you! In this feedback…

Consultation response

PFA - Filière Automobile Mobilités, 10 May 2022

The PFA (Plateforme de la Filière Automobile) welcomes the European Commission’s Data Act proposal and its intention to increase the breadth and depth of data usage within the European Single Market. In our attached position paper (short version), we provide general feedback on the text to feed…

Developers Alliance warns Data Act will stifle innovation and increase costs

Application Developers Alliance, 13 May 2022

The group calls for stronger safeguards for trade secrets and alignment with GDPR. They oppose mandatory technical standards for cloud services and interoperability.
Limiting mandates would help software developers avoid higher business costs and protect intellectual property.
Startups and ambitious entrepreneurs face regulatory burdens that could discourage them from growing in Europe.

Consultation response

French Publishers Association (Syndicat National de l'Edition), 12 May 2022

The French Publishers Association (SNE) welcomes the opportunity to provide a feedback on the European Commission’s proposal for a Data Act. SNE is France's trade association of book publishers. It represents approximately 788 member companies whose combined business endeavors account for the bulk…

Consultation response

Régie Autonome des Transports Parisiens, 25 Jun 2021

RATP welcomes the Commission's effort to foster a more competitive and fairer data economy. Indeed, more than ever, a few actors of the digital economy are in position to capture available data and use them in services where the data producer will not get his fair value share. Therefore, it…

Consultation response

French Publishers Association (Syndicat National de l'Edition), 25 Jun 2021

Members of the French Publishers Association, in particular legal, scientific, technical and medical publishers obviously rely on the database right, as a complement to Copyright. For instance : - legal databases often comprise raw data, not protected by copyright. However, the use of these data…

Consultation response

Bureau Brussels Consulting, 24 Jun 2021

The European Data Centre Association (EUDCA) represents the European data centre (DC) operator community. The EUDCA is happy to submit feedback on the new rules for the common European data spaces and wants to draw attention to the following key points: • EUDCA members host several customers who…

Consultation response

Science Europe, 25 Jun 2021

Access, interoperability, and the use of high-quality data are cornerstones of research and innovation. Science Europe, therefore, welcomes the initiative of the European Commission, as outlined in the European Strategy for Data from 19 February 2020, to create a single market for data that would…

Consultation response

Stichting Open Future, 25 Jun 2021

The Data Act is an important addition to the Data Governance Act (DGA), that further completes the European Data Strategy. While the DGA provides the framework for data sharing to take place in the first place, the Data Act seems to be designed to provide the economic conditions to foster the…

Austrian Social Insurance demands health data exemptions from Data Act

Dachverband der österreichischen Sozialversicherung, 13 May 2022

The organization calls for clear definitions and exemptions for institutions holding sensitive health data. They also request that technical protection measures for data become mandatory.
This would shield social security institutions from mandatory data sharing requirements for health records.
Private firms and researchers lose guaranteed access to large public health datasets for innovation.

Japanese automakers urge 24-month delay for EU Data Act

Japan Automobile Manufacturers Association, Inc. European Office, 13 May 2022

JAMA seeks to extend the implementation period from 12 to 24 months. They request limiting shared data to what is already accessible to manufacturers. They also want business users to provide appropriate compensation for data access.
A longer timeline and limited data scope would reduce technical costs.
Third-party service providers will face longer delays accessing necessary vehicle data.

Consultation response

MOBIVIA, 12 May 2022

10 May 2022 Joint Statement on Data Act and the need for a sector-specific legislation on access to in-vehicle data By ACA, FFEA, FRANCE ASSUREURS, MOBILIANS, MOBIVIA, SESAM LLD, SNSA & UFE; connected mobility players New services arising from vehicle connectivity will improve peaceful…

Consultation response

Fédération Française du Bâtiment, 25 Jun 2021

La Fédération Française du Bâtiment se réjouit de l’initiative de la Commission européenne visant à instaurer une équité et des règles harmonisées dans l’économie de la donnée. Ainsi, elle soutient le projet d’Acte sur les données qui entend renforcer l’interopérabilité des systèmes et développer…

Consultation response

European Committee for Interoperable Systems, 13 May 2022

The European Committee for Interoperable Systems ("ECIS") is an international, non-profit association of information technology companies founded in 1989 which endeavours to promote a favourable environment for interoperable ICT solutions. For three decades ECIS has actively represented its members…

Consultation response

International Federation of Reproduction Rights Organisations, 13 May 2022

IFRRO, the International Federation of Reproduction Rights Organisations, is the international network of collective management organisations and creators’ and publishers’ associations in the text and image spheres, with over 150 members in 85 countries. Our members represent many millions of…

Internet group eco warns Data Act creates excessive bureaucracy

eco - Verband der Internetwirtschaft, 13 May 2022

The association requests stronger protections for trade secrets and more incentives for data holders. They argue for narrower definitions of government data access and flexible implementation deadlines. They also seek a clearer regulatory distinction between personal and industrial data.
Reducing these requirements would lower compliance costs and protect proprietary business secrets.
Public authorities would find it harder to access private data for non-emergency tasks.

Consultation response

LKQ Europe, 9 May 2022

LKQ Europe, a subsidiary of LKQ Corporation, with its head office in Zug, Switzerland, is the leading distributor of automotive aftermarket parts for cars, commercial vans and industrial vehicles in Europe. It currently employs approximately 26,000 people with a network of more than 1,000 branches…

Consultation response

eco - Verband der Internetwirtschaft, 25 Jun 2021

About eco: With over 1,100 member companies, eco is the largest Internet industry association in Europe. Since 1995 eco has been instrumental in shaping the Internet, fostering new technologies, forming framework conditions, and representing the interests of members in politics and international…

Consultation response

Verband Deutscher Verkehrsunternehmen, 25 Jun 2021

The German transport association (Verband Deutscher Verkehrsunternehmen, VDV) welcomes the Commission’s initiative to increase good governance and fairness in the data economy by fostering in particular business to government (B2G) data sharing. Public transport authorities (PTAs) and public…

German Federal Bar Demands Exemptions to Protect Professional Secrecy

Bundesrechtsanwaltskammer, 13 May 2022

The organization requests specific exemptions for professional secrecy holders to ensure legal confidentiality and independence. They suggest narrower definitions of data holders to prevent unfeasible organizational and legal requirements.
This would allow the legal profession to avoid complex new compliance costs and mandates.
Public authorities lose the ability to access data from legal professionals during exceptional needs.

Consultation response

Cigref, 13 May 2022

Beltug, Cigref, CIO Platform Nederland and Voice-e.v. jointly support the Commission’s ambition to ensure fairness in how the value of data is allocated among actors who are active on different levels of the data value chain. Data is not only a core component of the digital economy, but also a…

Consultation response

Center for Data Innovation, 13 May 2022

On behalf of the Center for Data Innovation (Transparency Register #: 367682319221-26), we are pleased to submit this feedback on the European Commission’s adopted proposal for the Data Act. The Data Act contains fundamental pitfalls and needs significant modification so as to not harm the European…

Consultation response

Cigref, 25 Jun 2021

Cigref welcomes the Commission’s objective to ensuring fairness in how the value from using data is shared among businesses, consumers, and accountable public bodies. We welcome a harmonized European approach with effectiveness, fairness, proportionality as guiding principles. This data strategy is…

Consultation response

TomTom International bv, 13 May 2022

As Europe’s leading independent location technology specialist, TomTom appreciates the opportunity to provide feedback on the Commission’s proposal for the Data Act. Overall, TomTom supports many of the components of the Data Act. However, we would like to seek clarification on some issues and…

Consultation response

European Materials Handling Federation, 13 May 2022

FEM welcomes the European Commission’s proposal to foster the EU data economy. The transition of the EU to a data-driven economy will generate a considerably positive impact on the future growth and competitiveness of European industries. Materials handling equipment in operation has already become…

Consultation response

Local Government Denmark, 13 May 2022

Kommissionen har inviteret til åben høring vedrørende udspillet til datafor-ordning. KL sender hermed sit bidrag og takker for muligheden for at indsende bemærkninger. KL er interesseorganisation for de 98 danske kommunalbestyrelser og arbejder for, at kommunerne har de bedst mulige rammer til at…

French construction industry demands clearer definitions in EU Data Act

Fédération Nationale des Travaux Publics, 9 May 2022

The federation calls for precise definitions of non-personal data and connected objects to avoid legal uncertainty. They argue data sharing should rely on contracts where firms choose partners and maintain trade secrets.
Tighter legal definitions would help these companies protect their proprietary information and profits.
Public agencies lose flexibility because they would be prohibited from reusing shared business data.

Consultation response

MAIF, 26 Apr 2022

On 23 February 2022, the European Commission presented its proposal for a regulation establishing harmonised rules for fair access and use of data, known as the Data Act, which MAIF warmly welcomes. Since 2020, MAIF has been working on the development of a European Personal Information Management…

Consultation response

Fédération Nationale des Travaux Publics, 24 Jun 2021

La fédération nationale des travaux publics (FNTP) salue l'initiative de la Commission d'établir un Acte législatif sur les données. Une action forte de l'Union européenne sur les données est absolument nécessaire. En effet, les données produites par les entreprises du secteur de la construction,…

Consultation response

MAIF, 24 Jun 2021

MAIF welcomes the will of the Commission to publish, by the end of the year, a Data Act to increase access to and further use of data. In this contribution, MAIF shares several key points raised in the inception impact assessment published on 28th May 2021. The Data Act must build the basis for a…

Consultation response

Koninklijke Nederlandse Toeristenbond ANWB, 13 May 2022

see attached file

Austrian motoring club urges sector-specific EU car data rules

Österreichischer Automobil-, Motorrad- und Touring Club, 13 May 2022

The club demands a sector-specific instrument for automotive data. They argue general consumer electronics rules are unsuitable for vehicle data sovereignty.
Standardized access would reduce the high investment costs required for multi-brand workshops.
Vehicle manufacturers would lose their monopoly over determining how automotive data is used.

Consultation response

Deutscher Juristinnenbund e.V., 10 May 2022

Der Deutsche Juristinnenbund e.V. (djb) nimmt zum aktuellen Entwurf der EU-Verordnung über harmonisierte Vorschriften für einen fairen Datenzugang und eine faire Datennutzung (Datengesetz) wie folgt Stellung - siehe angehängte Stellungnahme des djb - st22-07_EU-DataAct.pdf

Consultation response

European Chemical Society, 25 Jun 2021

The European Chemical Society (EuChemS), an international organisation comprising 50 member societies from Europe and beyond and having had a representative on the EC’s High Level Expert Group Open Science Policy Platform (OSPP) 2016-2020 welcomes the Commission’s initiative to clarify and…

Consultation response

Data, AI and Robotics (DAIRO) AISBL, 12 May 2022

The Big Data Value Association (BDVA) is a European industry-driven research and innovation community on Big Data, Data Value, and Industrial AI. BDVA is also a unique platform for pre-competitive collaboration between industry and research, combining a research-oriented and experimental approach…

French auto federation demands fair vehicle data access

Fédération Nationale de l'Automobile, 12 May 2022

The FNA requests automatic, real-time access to vehicle technical and usage data without complex consent processes. They seek a requirement for manufacturers to provide this information in usable formats at minimal cost.
This ensures independent repairers can compete fairly and fulfill their legal diagnostic obligations to customers.
Car manufacturers lose the ability to capture the aftermarket through digital locking practices.

Consultation response

Wirtschaftsverband der deutschen Kautschukindustrie e.V., 12 May 2022

wdk - German Rubber Manufacturers Association welcomes the publication of the Data Act proposal. The position is attached.

Consultation response

Weizenbaum-Institut e.V., 12 May 2022

The Weizenbaum Institute for the Networked Society in Berlin congratulates the European Commission for approaching an important milestone in the implementation of the data strategy announced two years ago. The Data Act legislative proposal includes a package of measures that are expected make more…

Spanish digital association warns Data Act risks damaging competition

Asociación Española de Economia Digital, 10 May 2022

Adigital requests that definitions for data holders be clarified and recommends a longer period for companies to implement the regulation. They also seek stronger protections for trade secrets when sharing data with public sector bodies.
A longer timeline and clearer rules would provide companies with much-needed legal certainty.
Cloud providers and non-EU firms may face discrimination due to data localization and standards.

Consultation response

EuroGeographics, 24 Jun 2021

EuroGeographics is an independent international not-for-profit organisation representing Europe’s National Mapping, Cadastral and Land Registration Authorities, responsible for a large set of public sector datasets including high value geospatial datasets that are defined in the Open data and PSI…

Consultation response

BlackBerry Limited, 23 Jun 2021

BlackBerry, the global cybersecurity software and services company, welcomes the opportunity to provide input to the EC roadmap on the EU Data Act. We support efforts put by public authorities to promote data sharing and access, and welcome the Commission’s interest in the field. The ability to…

Consultation response

Sdružení pro internetový rozvoj, 13 May 2022

As an umbrella association of Czech online publishers, TVs, technological companies, advertisement agencies and e-commerce players, we welcome the intention of the European Commission to propose a new regulation aiming to introduce a fair and effective tool for exchange of IoT data. Unfortunately,…

Consultation response

SCALEWAY, 13 May 2022

As a leading alternative European cloud service provider, Scaleway is welcoming very positively the Data Act proposal published by the European Commission. We share the objective of the European Commission to remove commercial /financial, technical, contractual obstacles that still prevent…

Consultation response

Rat für Informationsinfrastrukturen, 12 May 2022

The German Council for Scientific Information Infrastructures (RfII) was established by the Joint Science Conference (GWK) of the Federal Republic of Germany to provide advice on the enhancement of scientific information infrastructures and related topics of the digital turn in science and…

Consultation response

Bundesverband Medizintechnologie e.V., 12 May 2022

Rückmeldung im Rahmen der Konsultation zum Vorschlag für eine Verordnung über harmonisierte Vorschriften für einen fairen Datenzugang und eine faire Datennutzung (Datengesetz) Da der am 23.02.2022 von der EU-Kommission veröffentlichte Vorschlag für ein Datengesetz in der aktuellen Fassung…

Consultation response

Open-Xchange AG, 11 May 2022

Open-Xchange would like to thank for the opportunity to provide comments on the Commission’s proposed text for the new Data Act. We generally support the Commission’s objectives and the current proposal, but we would like to address the issue of data sharing obligations for software and hardware…

Consultation response

Federation of European Business Information Services, 11 May 2022

Please find attached FEBIS ' comments on the Data Act proposal. FEBIS stands for Federation of Business Information Services, the specialized and recognized industry body of providers of global B2B business intelligence services for managing trade risks. Today´s 140 plus members of our federation…

Consultation response

Centro Español de Derechos Reprográficos EGDPI, 25 Jun 2021

Estas son las contribuciones del CENTRO ESPAÑOL DE DERECHOS REPROGRÁFICOS EGDPI (CEDRO) a la hoja de ruta sobre la futura “Ley de datos” y modificación de las normas sobre la protección jurídica de las bases de datos. CEDRO es una entidad de gestión de derechos de Propiedad Intelectual establecida…

Consultation response

Software & Information Industry Association, 13 May 2022

SIIA appreciates the opportunity to provide feedback on the proposed Data Act. SIIA represents over 450 companies reflecting the breadth of the data-driven economy, many of which are based in the EU and most of which do business in the EU. Summary. SIIA supports the objectives of the Act to unlock…

Consultation response

BOVAG, 13 May 2022

See attachment for our feedback.

Consultation response

ACM EUROPE, 13 May 2022

SECOND FILING: REPLACES ORIGINAL CORRUPTED AND UNREADABLE PDF COMMENTS ATTACHED The Association for Computing Machinery (ACM) is the world’s largest and longest established professional society of individuals involved in all aspects of computing. It annually bestows the ACM A.M. Turing Award,…

Consultation response

Conseil National des Professions de l'Automobile, 13 May 2022

Technological advances are leading to a transformation in users' practices, leading them to reconsider their expectations in terms of safety, respect for the environment, inter-modality of means of transport, but also, and above all, of services. Consequently, the downstream automotive sector,…

FEDENE demands trade secret safeguards in EU Data Act

Fédération des services énergie environnement, 13 May 2022

FEDENE requests a clear distinction between raw data and proprietary processed knowledge. They argue trade secrets and algorithms must remain private. They also seek an extension to the proposed twelve-month implementation timeline.
Safeguarding proprietary knowledge maintains their competitive advantage while avoiding expensive data-sharing requirements.
Public institutions and competitors lose access to valuable technical insights and processed analytical datasets.

Consultation response

Fédération des Industries des Equipements pour Véhicules, 13 May 2022

FIEV welcomes the initiative of the European Commission to propose a regulation helping automotive suppliers to have a fair, reasonable and non-discriminatory access to the data produced by mobility systems and their environment, fostering innovation and providing customers with added value…

Consultation response

Syndicat des Entreprises des Services Automobiles en LLD et des Mobilités, 13 May 2022

This is a joint Statement on Data Act and the need for a sector-specific legislation on access to in-vehicle data By ACA, FFEA, FRANCE ASSUREURS, MOBILIANS, MOBIVIA, SESAM LLD, SNSA & UFE; connected mobility players New services arising from vehicle connectivity will improve peaceful driving,…

Consultation response

Gesamtverband Autoteile-Handel e.V., 13 May 2022

Der Gesamtverband Autoteile-Handel (GVA) e.V. begrüßt die Grundsätze und Ziele des Data Act, insbesondere im Hinblick auf die Regulierung des B2B-Datenaustauschs. Als Branchenvertreter des freien Kfz-Teile- und -Servicemarktes teilen wir die Einschätzung, dass gegenwärtig ein Hersteller die…

Consultation response

Fédération Française de l'Expertise Automobile, 13 May 2022

10 May 2022 Joint Statement on Data Act and the need for a sector-specific legislation on access to in-vehicle data By ACA, FFEA, FRANCE ASSUREURS, MOBILIANS, MOBIVIA, SESAM LLD, SNSA & UFE; connected mobility players New services arising from vehicle connectivity will improve peaceful…

Consultation response

Fundacja Moje Państwo, 13 May 2022

Please find attached the feedback of Moje Państwo Foundation to the European Commission’s proposed Data Act.

Consultation response

Software AG, 12 May 2022

With its draft Data Act (Data Act-E), the EU Commission has presented far-reaching regulations for the access and use of non-personal data in the EU. In our view, the Data Act as a horizontal regulation - if done right - offers the opportunity to shape an open and democratic data economy guided by…

Consultation response

Chronos Consulting, s.r.o., 6 Apr 2022

We welcome the limitation of the scope of the Regulation to holders and recipients of data collected through IoT devices, manufacturers of IoT devices, the public sector and data processing service providers. However, the scope is still not clearly defined. It therefore allows for interpretations…

Consultation response

BOVAG, 25 Jun 2021

BOVAG supports the feedback of CECRA in full. And BOVAG also welcomes and appreciate the Commissions plan’s of complementary initiatives for sectoral data spaces or data access & use in specific sectors or markets (incl. in-vehicle data).

Consultation response

IP FEDERATION, 25 Jun 2021

IP Federation’s response to the European Commission’s Inception Impact Assessment on the Data Act and amended rules on the legal protection of databases. Founded in 1920 in the UK, the IP Federation represents IP intensive companies who are extensively involved in business activity in Europe and…

Consultation response

Global Institute for Structure relevance, Anonymity and Decentralisation i.G., 25 Jun 2021

GISAD begrüßt die Initiative der Europäischen Kommission, den Austausch der Daten im Sinne einer Einhaltung des Urheberrechts, der Souveränität der Bürger und der optimalen Verwertung durch die Wirtschaft gesetzlich zu regeln. Jedoch schon an der EU Stellungnahme zur Folgenabschätzung zu dieser…

Consultation response

, 25 Jun 2021

Siehe Anhang!

Consultation response

Asociación Nacional de Vendedores y Reparadores de Vehículos a Motor, Recambios, Accesorios y Afines, 24 Jun 2021

Please find attached the contribution of GANVAM to the roadmap.