Data & Technology For Compliance Alliance
DT4C Alliance
The DT4C Alliance is the EU's leading advocacy organisation for data and technology service providers companies, championing innovation and transparency in financial crime prevention.
ID: 375561349058-23
Lobbying Activity
Response to Digital package – digital omnibus
14 Oct 2025
The DT4C Alliance welcomes the European Commissions Digital Omnibus as a timely instrument to simplify the EUs digital rulebook and deliver the Draghi Reports burden-reduction goals and the Competitiveness Compass targets. Europes digital competitiveness depends on clear, coherent rules that enable innovation while preserving high standards of trust, safety and fairness. Today, overlapping frameworks across data, cybersecurity and AI have created fragmentation, legal uncertainty and rising compliance costs. The Digital Omnibus is therefore a practical chance to streamline the acquis, remove duplication, and ensure consistent application across Member States ensuring businesses can invest and scale with confidence. In line with this, our recommendations follow four guiding principles: Effectiveness & consistency: Anchor obligations to intended outcomes rather than rigid processes. Eliminate conflicting or duplicative requirements without sacrificing legal clarity. Provide reading keys where different regimes converge on the same risk/outcome (e.g., aligning interpretations of legitimate interest across AML/GDPR contexts), and ensure mitigations are applied consistently across Member States. No unnecessary layering: Avoid stacking horizontal rules on top of robust sectoral frameworks. Where comprehensive sector regimes exist (e.g., DORA in financial services), exclude those sectors from additional horizontal instruments (e.g., NIS2, CRA) to prevent overlap and patchwork implementation that deters investment. Legal clarity & harmonisation: Practical consideration of the most appropriate legislative instrument to deliver consistent application in practice; greater transparency around Member State transposition of Directives; where Directives are used, support broad main-establishment rules. Expand lex specialis for sector files; curb gold-plating and overlaps via guidance on data needs and sectoral impacts; and extend one-stop-shop or mutual recognition for auditing, conformity, registration, reporting and enforcement. Remove zombie national provisions when EU rules are repealed or updated. Global alignment: Coordinate with widely used international norms and best practices to facilitate cross-border operations and reduce duplicative compliance for EU firms. More specifically, the Digital Omnibus is firstly a timely opportunity to make the GDPR deliver expected outcomes and risk-mitigation impactenabling responsible data use while preserving high standards of protection. We also recognise the potential of the forthcoming EU Business Wallet to support trusted identification and secure data exchange across the EU. Regulatory coherence is equally essential in AI and cybersecurity frameworks to ensure consistent, innovation-friendly rules that reinforce trust and resilience across the single market.
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