GDPR reform on the horizon - anticipated changes under the EU Digital Omnibus proposal

The European Union is considering targeted amendments to GDPR as part of a broader digital regulatory reform, commonly referred to as the Digital Omnibus initiative. The European Commission presented the relevant legislative proposal in November 2025, with the aim of modernising and simplifying data protection rules that have been in force since 2018, while reducing administrative burdens and adapting the framework to technological and economic developments.

One of the key proposed changes concerns the concept of personal data, shifting towards a more contextual approach whereby information would qualify as personal data only if it can realistically be linked to an identifiable individual. This could narrow the scope of data falling under the GDPR in certain use cases, such as scientific research or data-intensive technological environments. In parallel, the proposal envisages simplifying transparency obligations under Articles 13 and 14 for low-risk processing activities.

The amendments also seek to provide greater flexibility for innovation-driven processing activities. In particular, they contemplate broader reliance on legitimate interest as a lawful basis for scientific research and certain artificial intelligence applications, subject to appropriate safeguards. Adjustments to the treatment of special categories of data are likewise under discussion, reflecting the growing relevance of AI training and automated data analysis.

While the Commission presents these reforms as measures to enhance legal clarity and competitiveness, they have triggered debate among stakeholders. Critics caution that easing certain obligations may weaken data subject protections, whereas supporters emphasise the need for a more proportionate, risk-based regulatory framework. The proposal is currently subject to the ordinary legislative procedure, and its final content will depend on negotiations between the European Parliament and the Council, with potential application envisaged from 2026 onward.