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Asociación Española de Economia Digital

Adigital

Adigital is the leading Spanish association representing companies in the digital economy sector.

Lobbying Activity

Adigital urges EU to maintain current audiovisual media rules

19 Dec 2025
Topic — The Commission is evaluating if the Audiovisual Media Services Directive remains fit for purpose.
Message — Adigital argues current rules remain fit for purpose alongside the DSA. They caution against increasing content quotas or tightening European work definitions. They favor harmonized guidance over new legislative requirements.12
Why — Maintaining current rules prevents higher operational costs and increased regulatory complexity.34
Impact — Consumers lose variety as the current system already reduces choice.5
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Spanish tech group Adigital urges openness in Quantum Act

15 Dec 2025
Topic — This consultation seeks views on accelerating the development and industrial deployment of quantum technologies.
Message — Adigital wants the EU to prioritize software development and real-world industrial applications. They advocate for a model that promotes international cooperation rather than restrictive trade policies. They also call for better access to specialized research facilities across all member states.123
Why — This would prevent domestic companies from losing access to essential global innovation networks.45
Impact — Tech startups and scale-ups may suffer under heavy administrative and reporting burdens.67
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Spanish digital association urges flexibility in cyber reporting rules

12 Nov 2025
Topic — The European Commission is defining rules for delaying notifications of cyber vulnerabilities.
Message — The association requests more transparency for manufacturers when notification delays are invoked. They argue that the current criteria for delaying information sharing are too restrictive. They also recommend using a reasonable timeframe rather than a strict 72-hour limit for complex cases.123
Why — The group would avoid premature disclosure of vulnerabilities, reducing potential exploitation risks.4
Impact — National authorities in other countries might face delays receiving vital security alerts.5
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Adigital warns new EU rules risk duplicating existing laws

23 Oct 2025
Topic — This consultation seeks to address gaps in consumer protection online through new legislation.
Message — Adigital requests strengthening enforcement of existing laws instead of creating ones. They also advocate for a regulatory pause to allow for compliance.12
Why — This would reduce compliance costs and eliminate redundant regulatory requirements for businesses.3
Impact — Consumer groups lose new protections against dark patterns and addictive digital designs.4
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Response to Digital package – digital omnibus

24 Sept 2025

Adigital, the Spanish Association of the Digital Economy, appreciates the opportunity to provide feedback. The attached file includes "The Spanish Business Proposal for Regulatory Simplification in the European Unions Digital Agenda". In this exercise, the first of its kind in Spain, we set out 13 legislative areas with technical, concrete, and feasible proposals to accompany and support European efforts on simplification. In particular, chapter 5 includes a series of proposals for regulatory simplification by regulation or sectoral case, including: (i) Data Protection, Privacy and GDPR; (ii) Cybersecurity; and (iii) AI Act. Besides, chapter 6 includes a series of general recommendations in the digital field, suggesting the implementation of Enforcement Technology and RegTech to facilitate both regulatory implementation and the regulatory simplification efforts of the European Commission.
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Spanish digital group Adigital urges EU to simplify consumer rules

29 Jul 2025
Topic — The EU is defining consumer policy priorities and enforcement actions for 2025-2030.
Message — Adigital requests a simpler regulatory approach to reduce red tape for smaller businesses. They advocate for flexible rules that adapt to new digital models and ensure all market players follow the same standards.123
Why — Simplifying regulations would lower operational costs and help Spanish tech firms expand across European borders.4
Impact — Large global platforms may face increased compliance burdens to match the standards of smaller competitors.5
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Adigital urges EU to avoid overregulation in digital networks

10 Jul 2025
Topic — The Commission is seeking input on infrastructure needs for cloud and AI connectivity transitions.
Message — Adigital requests that the Commission avoids new rules and gives companies time to adapt. They believe legislation should be based on evidence rather than creating unnecessary regulatory layers.12
Why — This approach prevents systemic risks and keeps costs lower for Spain's digital ecosystem.3
Impact — Extending obligations would harm European media, education, and e-commerce companies relying on CDNs.4
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Adigital urges pragmatic and innovation-enabling Cloud and AI Act

2 Jul 2025
Topic — The EU's consultation on expanding sustainable cloud and artificial intelligence infrastructure.
Message — Adigital requests fast-track permitting for data centers and better grid access. They advocate for international partnerships and fair competition to avoid regulatory duplication.12
Why — Streamlined procedures and international cooperation would reduce compliance costs and bureaucratic hurdles.34
Impact — Proponents of strict domestic-only cloud services may see their protectionist goals sidelined.5
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Spanish digital association urges EU to prioritize existing certification schemes

19 Jun 2025
Topic — The European Commission is revising the EU Cybersecurity Act's certification framework.
Message — Adigital requests strengthening ENISA's resources to prioritize current mandates before expanding the framework. They advocate for voluntary certification and deeper cooperation with the private sector.12
Why — This would provide regulatory certainty and reduce costs for digital businesses.34
Impact — Centralized EU authorities lose direct visibility if reporting is handled through national entry points.5
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Adigital urges EU to streamline AI rules and delay enforcement

3 Jun 2025
Topic — The initiative aims to boost industrial AI uses and improve public services' delivery.
Message — Adigital requests excluding low-risk systems to streamline compliance and reduce regulatory burdens. They also support delaying implementation until six months after relevant standards are available.12
Why — This would reduce compliance costs and give Spanish digital businesses more certainty.34
Impact — Workers may lose enhanced protections if HR software is excluded from the AI Act.5
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Meeting with Felix Fernandez-Shaw (Director Directorate-General for International Partnerships) and

1 Apr 2025 · Plenary Feedback round on previously held GGIA Working Group sessions of 9 different thematical groups regarding Latin America and the Caribbean (LAC).

Response to EU Start-up and Scale-up Strategy

17 Mar 2025

We welcome the opportunity to respond to this consultation. This document is the result of an open process of collaboration, input of ideas and advice from a variety of individuals and organizations interested in promoting the startup growth and development in Spain and the European Union. We have worked for a long period of contrast and feedback sessions with representatives from the abovementioned organizations, Ministries from the Government of Spain, as well as a filtered list of founders, scaleups and companies. The views and opinions expressed in this document do not necessarily reflect the views or positions of any entities they represent. Our goal is to provide a response to this consultation with a "country-agenda perspective" from Spain in order to support the European Union's goals related to competitiveness for this new mandate and, concretely, the upcoming Startup and Scaleup Strategy. We share this 11-page document (attached) with specific policy proposals in five (5) main policy areas: funding; economic drivers for competitiveness; governance and coordination; metrics and methodology; and international dimension and impact. Adigital is the Spanish Association for the Digital Economy. Endeavor is the leading global community of, for and by high-impact entrepreneurship. EsTech, created by Adigital, is the platform for high-growth companies with a technological base in Spain. SpainCap is the national association of Venture Capital and Private Equity. StartupVLC and Tech Barcelona are the startup regional clusters promoting the ecosystem development in Valencia and Barcelona respectively.
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Adigital urges EU to keep cross-border delivery voluntary

11 Mar 2025
Topic — The European Commission is evaluating the effectiveness of the current Geo-blocking Regulation.
Message — The organization recommends that the regulation should not oblige e-retailers to offer delivery across borders. They argue that companies must preserve their freedom to decide in what markets they remain active. Additionally, retailers should be able to take into account geographical differences in their pricing strategy.123
Why — This flexibility allows retailers to avoid high logistical costs and maintain their competitiveness.4
Impact — Consumers lose out on equal access to the full range of European products.5
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Meeting with Werner Stengg (Cabinet of Executive Vice-President Henna Virkkunen)

10 Mar 2025 · EU digital policy

Adigital Calls for Harmonized EU Minor Protection Rules

30 Sept 2024
Topic — EU consultation on safety guidelines for online platforms accessible to minors.
Message — Adigital requests harmonized EU-wide standards to avoid regulatory overlaps and legal uncertainty. They advocate for flexible, risk-based measures rather than a rigid one-size-fits-all approach.123
Why — Unified rules would reduce technical burdens and prevent costly market fragmentation.4
Impact — Minors might lose access to helpful information under overly prescriptive regulations.5
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Adigital urges less interventionist EU digital infrastructure policies

13 Jun 2024
Topic — Commission consultation on scenarios for mastering Europe's future digital infrastructure and connectivity needs.
Message — Adigital urges for a less interventionist environment that avoids extending existing obligations. They support maintaining an open internet while adopting a technology-neutral approach for connectivity.123
Why — This would reduce compliance burdens and provide a more stable environment for investment.45
Impact — Smaller national players may face displacement as the EU encourages market consolidation.6
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Adigital warns new travel rules burden digital tour organizers

8 Mar 2024
Topic — Review of EU rules protecting travellers in packages and linked arrangements.
Message — Adigital calls for a balance between consumer rights and sustainable business operations. They oppose prepayment limits and the expanded package definition, arguing these increase administrative burdens. They also demand alignment with air passenger regulations.123
Why — This would reduce their administrative costs and maintain necessary business liquidity.45
Impact — Consumers face higher prices as smaller organizers struggle with new entry barriers.67
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Response to Report on the application of the General Data Protection Regulation

8 Feb 2024

Adigital Contribution COMMISSION 2024 REPORT ON THE APPLICATION OF THE GDPR European Commission Open Feedback Period The General Data Protection Regulation (GDPR) is the main piece of EU legislation guaranteeing the fundamental right to data protection. The GDPR entered into application on 25 May 2018, repealing and replacing Directive 95/46/EC. It sets out the rights of individuals and imposes obligations on organisations and businesses that process the personal data of people in the EU, with a two-fold objective: (i) to protect fundamental rights and freedoms of natural persons and in particular their right to the protection of personal data; and (ii) to allow the free flow of personal data and the development of the digital economy across the internal market. In line with Article 97 GDPR, the Commission must examine, in particular, the application and functioning of Chapter V, on the transfer of personal data to third countries or international organisations with particular regard to decisions adopted pursuant to Article 45(3) of this Regulation and decisions adopted on the basis of Article 25(6) of Directive 95/46/EC; and Chapter VII, on cooperation and consistency. The first report on the evaluation and review of the GDPR was adopted in 2020. The next report is expected to be adopted by mid-2024. Adigital welcomes the opportunity to provide feedback to this initiative, which will report on how the rules have been applied, 6 years after their entry into application. The attached document presents Adigitals inputs to the European Commissions open feedback period, answering the questions that the Commission posed to its GDPR Multistakeholder Group in September 2023.
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Adigital calls for unified financial data sharing framework

31 Oct 2023
Topic — The consultation covers a framework to expand financial data sharing access.
Message — Adigital suggests merging financial data rules into one framework to simplify operations. They argue that companies should only share raw data, not processed insights. They also seek legal immunity for data holders when third parties misuse data.123
Why — This would lower compliance costs and reduce legal liability for data misuse.45
Impact — Third-party service providers lose access to valuable processed consumer insights.6
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Response to Payment services – revision of EU rules (Directive)

31 Oct 2023

Adigital welcomes the opportunity to provide feedback to the EU Commissions proposal on Financial Data Access and revision of the Payments Services Directive (PSD2). We are aligned with the goals of building off of prior legislative work to: (i) create an even more competitive and innovative payments' ecosystem in Europe; (ii) increase payment speeds and lower payment costs for European customers; (iii) enhance payment choice; and (iv) harmonize national legislation via the Payments Services Regulation. The following document presents the inputs from Adigital to the Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on payment services and electronic money services in the Internal Market amending Directive 98/26/EC and repealing Directives 2015/2366/EU and 2009/110/EC open feedback period.
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Response to Payment services – revision of EU rules (new Regulation)

31 Oct 2023

The European Commission presented a Payments Package to bring payments and the wider financial sector into the digital age, including a proposal for a Payment Services Regulation (PSR). Adigital welcomes the opportunity to provide feedback to the EU Commissions proposal on Financial Data Access and revision of the Payments Services Directive (PSD2). We are aligned with the goals of building on prior legislative work to: (i) create an even more competitive and innovative payments' ecosystem in Europe; (ii) increase payment speeds and lower payment costs for European customers; (iii) enhance payment choice; and (iv) harmonize national legislation via the Payments Services Regulation. The following document presents the inputs from Adigital to the Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on payment services in the internal market and amending Regulation (EU) No 1093/2010 open feedback period.
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Response to Virtual worlds, such as metaverse

27 Apr 2023

Adigital, the Spanish Association for the Digital Economy, representing more than 530 associated companies, has the mission of promoting the growth of the digital economy through sustainable and human-centered digitalization, boosting the economy through technology as a lever of progress, and firmly supporting new business models and disruptive technologies as a growth engine. In this day and age, given the rapid development of virtual worlds and immersive technologies, such as the metaverses, Adigital strongly supports the creation of interoperable, open, and inclusive virtual worlds, as well as promoting the development of immersive technologies and the virtual worlds as a thriving economic sector in the European Union. Please, find attached Adigital's position paper on the European Commission's call for evidence on virtual worlds.
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Adigital warns against rigid deadlines in GDPR enforcement reforms

24 Mar 2023
Topic — The initiative aims to streamline cooperation between national authorities enforcing data protection rules.
Message — The group opposes arbitrary and fixed deadlines for investigations, arguing they undermine fair and reasoned outcomes. They insist that the right to be heard must cover both factual and legal elements, specifically before the European Data Protection Board. They also demand strict confidentiality rules and sanctions to prevent information leaks by complainants.123
Why — Maintaining current procedural safeguards would protect companies from rushed enforcement and high administrative fines.45
Impact — Privacy activists and complainants would face restricted access to investigation files and potential legal sanctions.67
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Response to Review of EU rules on payment services

21 Jul 2022

The European Comission has launched and initiative that will report on the application and impact of EU rules on payment services, as required by the review clause of the Second Payment Services Directive. The review will pay attention to whether the Directive is still fit for purpose given the emergence of new payment services and risks. In this sense, it has launched a call for evidence in order to gather information to follow its assessments. Please find attached Adigital's feedback on this consultation.
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Spanish digital association warns Data Act risks damaging competition

10 May 2022
Topic — A proposal to establish harmonized rules for fair access and data use.
Message — 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.123
Why — A longer timeline and clearer rules would provide companies with much-needed legal certainty.45
Impact — Cloud providers and non-EU firms may face discrimination due to data localization and standards.67
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