LegalVideo Games Europe
Digital Omnibus: Digital Package for Simplification
1 Oct 20256 pages~14 min full read
The European video-games sector, valued at €26.8 billion and supporting 116,000 jobs, faces declining global competitiveness due to overlapping and burdensome EU digital regulations.
See it on page 6OECD research indicates that full data localisation policies could reduce global GDP by 4.5% and decrease exports by 8.5%, highlighting the economic risks of fragmented digital rules.
See it on page 2The industry is advocating for a 'Digital Omnibus' to streamline compliance, specifically requesting a grace period for the Data Act to account for long console development cycles.
See it on page 3Regulatory reforms should include harmonizing GDPR enforcement across EU Member States and implementing measures to curb abusive data-subject requests.
See it on page 4The Cyber Resilience Act requires more precise definitions of 'substantial modification' and practical guidance regarding CE marking for software distributed through app stores.
See it on page 5The ePrivacy framework must be modernized while ensuring game providers retain the ability to process communications for essential safety, anti-harassment, and anti-cheating measures.
See it on page 4The AI Act should be applied with proportionality, acknowledging that the vast majority of video-game applications present low risk to consumers.
See it on page 5The paper argues that the European Union’s expanding digital regulatory landscape is creating overlapping and burdensome compliance requirements for the video‑games sector, threatening its global competitiveness. It calls for a coordinated “Digital Omnibus” that streamlines rules while preserving consumer protection, emphasizing that simplification must translate into tangible reductions in administrative and legal costs for companies.
Key recommendations focus on six regulatory areas. First, greater legal certainty is needed for cross‑border data transfers, with clearer guidance on the use of Standard Contractual Clauses and the impact of their termination. Second, the rollout of the Data Act should include a grace period to accommodate long‑development cycles of consoles and to avoid data‑leak risks. Third, modest adjustments to the GDPR are urged to harmonise enforcement across Member States and to curb abusive data‑subject requests. Fourth, the ePrivacy framework should be modernised but retain the ability of game providers to process communications for safety, harassment prevention and cheating detection. Fifth, the Cyber Resilience Act requires precise definitions of “substantial modification” and practical guidance on CE marking for software distributed via app stores, with a shorter security‑update horizon for consoles. Sixth, the AI Act should be applied proportionately, recognising the low‑risk nature of most video‑games.
The scope covers the EU digital market in 2025, targeting video‑game developers, publishers and platform operators. The position draws on industry data—Europe’s video‑games market is valued at €26.8 billion, supports 116 000 jobs, and reaches 54 % of Europeans—and on an OECD study estimating that full data localisation would cut global GDP by 4.5 % and reduce exports by 8.5 %. No primary survey is cited; the analysis is based on sector observations and existing economic research. The overall thrust is to achieve regulatory coherence that safeguards users while enabling the European video‑games industry to thrive internationally.
