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ARTICLE · 27 NOVEMBER 2025

The EU "Digital Omnibus" Proposal: A Strategic Pivot For AI And Data Compliance

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On November 19, 2025, the European Commission published a package of legislative proposals known as the "Digital Omnibus." Designed to introduce flexibility into the EU's digital regulatory framework...

European UnionPrivacy

On November 19, 2025, the European Commission published a package of legislative proposals known as the "Digital Omnibus." Designed to introduce flexibility into the EU's digital regulatory framework, the proposal aims to simplify the General Data Protection Regulation (GDPR), the AI Act, and the Data Act to encourage innovation and reduce administrative burdens.

While the proposal introduces several changes, the most immediate operational impact for businesses is a significant restructuring of the compliance timeline for high-risk AI systems and new clarity regarding data processing for AI models.

Recalibrating the High-Risk AI Timeline

The Digital Omnibus proposes delaying the application of rules for high-risk AI systems. Under the current AI Act, obligations for high-risk systems listed in Annex III were set to apply from August 2, 2026. The proposal replaces this fixed date with a conditional timeline dependent on the availability of harmonized

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