In recent years, numerous digital laws have been developed in the EU. For many businesses, especially small and medium-sized enterprises (SMEs), this has resulted in a complex regulatory landscape with high obligations and legal uncertainties. The Digital Omnibus provides an opportunity to harmonize rules, refine definitions, and reduce overlapping regulations. To ensure companies benefit, there is a need for practical guidelines, realistic timelines, and coordinated implementation across member states.
The Essentials at a Glance
- Companies face regulatory overload in many areas, particularly small and medium-sized enterprises (SMEs).
- The Digital Omnibus is an opportunity for simplification, coherence, and greater legal certainty.
- Stricter and uniform definitions as well as coordinated reporting obligations are key.
- Practical guidelines and realistic transition periods are vital for implementation.
- Strengthening cyber resilience – avoiding duplicate regulations and inconsistent requirements.
Background
The EU aims to simplify and better align existing digital regulations with a Digital Omnibus. The AI Act, Data Act, DSA, DMA, CRA, DORA, and NIS2 currently overlap partially, leading to fragmentation, redundant requirements, and high documentation and reporting workloads. The DIHK emphasizes that precise definitions, coherent responsibilities, and harmonized reporting processes are necessary to achieve legal certainty and practical compliance. Given the rapid pace of technological development, speedy but realistically designed implementation processes are also essential.
What’s Important for Businesses
- Review and consolidate internal compliance maps: Identify overlaps between the AI Act, Data Act, GDPR, NIS2, CRA, and DORA, and establish modular processes.
- Proactively use SME support: Integrate guidelines, self-assessment tools, and service desks (e.g., the AI Service Desk of the Federal Network Agency) for pragmatic implementation.
- Strengthen data management: Standardize anonymization/pseudonymization, design legally secure data spaces, and separate mixed datasets in accordance with GDPR/Data Act.
DIHK Demands
- Coherent regulation: Unified definitions and clear distinctions between digital acts (AI Act, Data Act, DSA/DMA, CRA, DORA, NIS2), including GDPR integration.
- EU-wide coordination of reporting: A single harmonized reporting platform with aligned deadlines and thresholds, for example, involving ENISA.
- Tiered cyber certifications: Recognized low-threshold certifications for SMEs and clear integration into comprehensive certifications for larger companies.
- Legally secure implementation of the AI Act: Early, practical guidelines and standards; realistic timelines; safe harbor approaches and self-assessments for SMEs.
- Lex-specialis and lead-act principle: Clearly prioritize sectoral rules in case of conflicts and explicitly assign requirements of the AI Act to avoid redundancy.
FAQ
Frequently Asked Questions
What is the Digital Omnibus?
An EU initiative package designed to simplify and better harmonize existing digital regulations, aiming to reduce bureaucracy and increase legal certainty.
Which companies are affected?
Fundamentally all companies in the digital single market – particularly those with data-driven business models, AI usage, or high cybersecurity requirements.
How does the Digital Omnibus impact the GDPR?
The GDPR remains central. The Omnibus is intended to clarify overlaps with other laws and create coherent guidelines, for instance on data quality, data governance, and reporting obligations.
When will changes come into effect?
Timelines primarily depend on the progress of EU negotiations. The German Chamber of Commerce and Industry (DIHK) calls for timely guidelines and transition periods so companies can prepare in a structured manner.
Download
DIHK position paper on the planned simplification package for the digital sector (PDF, 259 KB) (only available in German)
- Relevant in topic:
- Innovation
- Key areas:
-
- Digitalisierung
- Bürokratie
Released 14.10.2025
Modified 12.03.2026
Contact
Jennifer Evers
Director Alternative Dispute Resolution (SGH), Law of the Digital Economy and Legal Tech | In-House Lawyer
Arian Siefert
Director Digital Economy
Jonas Wöll
Director Digital Single Market, EU Transport Policy, Regional Economic Policy