Allied For Startups’ Position on the European Data Union Strategy

Allied For Startups welcomes the opportunity to contribute to the development of the Data Union Strategy. Startups emerge by responding to real consumer needs, creating solutions that ultimately benefit European societies and economies. Central to their growth and innovation is access to data, not only within Europe but also beyond its borders. Particularly, public data plays a crucial role in enabling startups to develop products and services that address pressing challenges. A Data Union Strategy that truly reflects the realities and needs of startups will be a key driver of Europe’s economic and technological progress.

What is the European Data Union Strategy ?

The Data Union Strategy is an upcoming Commission communication building on the 2020 Data Strategy, which aimed to create an internal market where data flows freely. It is also a core element of the AI Continent Action Plan, designed to unlock the full potential of AI. Its main objective is to remove key barriers such as fragmented regulation, limited access to data, talent, compute, and capital, along with rising legal uncertainty and administrative burdens. It also seeks to address risks tied to international data transfers and geopolitical dependencies that threaten the EU’s long-term AI competitiveness.

To achieve this, the Strategy will focus on three pillars: first, boosting investment in data technologies and improving data access, especially for generative AI and startups, through funding and voluntary sharing tools; second, simplifying the regulatory landscape by streamlining rules, reducing administrative burdens, and enabling automated digital compliance; and third, developing an International Data Strategy to protect EU data flows, promote imports, and support global cooperation and rule-making for cross-border sharing.

What AFS proposes

Startups rely on access to data to build, train, and scale innovative products, especially in AI. Yet today, fragmented rules, limited data availability, and complex compliance obligations are holding them back. We believe the Data Union Strategy must focus on:

• Regulatory simplification and coherence: Streamlining overlapping rules, aligning definitions, and harmonising enforcement to create a predictable framework for data use across the EU.
• Data access and investment: Scaling up access to high-quality public and private datasets, accelerating the rollout of interoperable data spaces, and supporting voluntary data sharing through tools like one-stop shops.
• Global data flows: Enhancing legal clarity around international transfers and ensuring European startups can access global data on equal terms with international competitors.
• Open public data reuse: Avoiding restrictions based on company size or legal form and ensuring public sector data remains open, interoperable, and accessible to startups of all stages.

Startups need a data framework that enables, not inhibits, innovation. The Data Union Strategy should deliver more usable data, fewer barriers, and a simplified path to growth.