Allied For Startups' Preliminary Remarks on the Commission’s Digital Omnibus Proposals

On 19 November, the European Commission presented the Digital Omnibus package, aimed at simplifying existing rules on data, cybersecurity, and AI.

Allied For Startups welcomes these proposals, which represent an important shift towards clearer and smarter rules for Europe’s digital economy. A coherent framework is essential to strengthen the Single Market and enable startups and scaleups to start, scale, and remain in Europe.

We particularly welcome three elements:

• Consolidating data rules in a single Data Act by bringing together the Free Flow of Non-Personal Data Regulation, the Data Governance Act and parts of the Open Data Directive. This can reduce fragmentation and give founders a more predictable framework for accessing and using data.
• Simplifying consent and tackling cookie fatigue by moving device-level rules fully into the GDPR, clarifying when consent is required and enabling machine-readable user preferences. This can reduce compliance burdens and improve user experience.
• Streamlining incident reporting and easing AI Act implementation through a “report once, share many” system and more realistic timelines and obligations for high-risk AI systems. Extending simplified regimes to small mid-caps and shifting obligations to when standards are available are important improvements.

However, important gaps remain. Startups still do not appear as a distinct regulatory category, despite facing unique growth and resource constraints. The new consent architecture risks giving browsers and intermediaries gatekeeping power. Key concerns around cloud switching, termination rights and long-term contracts remain unresolved. And the package does not address our call for a pause on new digital rules until existing ones are implemented and harmonised.

Allied for Startups will work with EU institutions to ensure this package leads to real simplification. In the coming months we will push for a stronger startup perspective in negotiations, provide concrete use cases to shape implementing acts and standards, and feed evidence into the Digital Fitness Check.

The Omnibus package can mark a real turning point – but only if simplification becomes the guiding principle, allowing startups to start, scale and stay in Europe.