Quarterly Privacy Law Update | Q2 2025

EU

EU Proposes Reduction of GDPR Record-Keeping Requirements

The European Commission has proposed simplifying GDPR record-keeping obligations as part of its broader regulatory streamlining efforts, aiming to reduce administrative burdens for businesses. The proposal would revise Article 30(5) GDPR, which offers an exemption from keeping a record of processing activities ("ROPA"). The exemption would be extended from organizations with fewer than 250 employees to those with fewer than 750 employees. Article 30(5) also includes exceptions to the exemption, which will also be revised such that only high-risk processing would require such SMEs to maintain a ROPA.

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