Digital Omnibus Report V3: Analysis of Select GDPR and ePrivacy Proposals by the Commission

GDPR Policy On 19 November 2025, the European Commission published its proposal for the "Digital Omnibus", subsequently sparking significant criticism and opposition. noyb conducted a thorough analysis of all the changes relevant to the GDPR and the ePrivacy Directive, which we firstly published a few days after the proposal was issued by the European Commission. The comprehensive report provides a comparison of the existing law with the Commission's proposal and compiles all our insights. The report also discusses relevant case law and the impact on data subjects, authorities and controllers, providing real-life examples of potential consequences. This new version, published on 24 February 2026, supplements our detailed legal analysis (version 1) and recommendations (version 2) with comments on the joint EDPB/EDPS opinion on the data part of the Digital Omnibus published on 11 February 2026. Download the report! Background. The EU Commission has published its Digital Omnibus proposal