Will the EU's digital simplification plans end up complicating things?

Simplification will continue to be a major topic in the EU's 2026 digital agenda. The idea to simplify the EU's digital laws framework directly followed the last European Commission's term — often referred to as the EU's digital legislative tsunami era — which introduced laws such as the Data Act, Data Governance Act, Digital Services Act, Digital Markets Act, European Health Data Space, NIS2, Digital Operations Resilience Act, Cyber Resilience Act and Artificial Intelligence Act. Practitioners' calls for greater consistency and clearer regulatory interplay were met by another wave from the current Commission — this time focused on simplification efforts.  

Specific simplification initiatives kicked off last year with the Omnibus IV introducing changes to the current record-keeping requirements under the EU General Data Protection Regulation and the highly anticipated Digital Omnibus, proposing targeted amendments to several EU data and cybersecurity laws as well as the EU AI Act.  

The omnibuses are not the only projects aimed at improving the EU's digital rulebook. Since November 2025 and through 11 March this year, the Commission has been running a Digital Fitness Check to evaluate the effectiveness of the EU's digital laws. Although no legislative initiatives are promised at this point, the Digital Fitness Check will analyze the interplays and coherence between different pieces of legislation, including sectoral laws, and determine whether and where further simplification action is needed.  

Plans to revise the EU's digital rules do not stop here. A reviewed Cybersecurity Act proposal released in January that includes targeted amendments to NIS2 — a law also included in the Digital Omnibus proposal — as well as possible data transfer limits. The first DMA review is coming this May. The Digital Fairness Act, another legislative project, is expected to be proposed before the end of this year. It plans to address remaining legislative gaps when it comes to consumer protection online as well as simplify and clarify certain obligations for businesses.  

The plan is to make the EU's digital rulebook clearer and less burdensome, but there is a risk of complicating things further. With so many simplification plans, most of 2026 will be a guessing game on which laws will end up being changed and how. For practitioners, this means untangling different simplification projects and determining which ones will necessitate operational changes to their organization's digital governance programs. 

Laura Pliauškaitė is the European Operations Coordinator at IAPP.