Suggested Amendments to the Digital Omnibus: Europe

Video Games Europe has formally submitted a series of proposed amendments to the European Union’s Digital Omnibus, a legislative framework aimed at streamlining data protection and digital governance. The primary objective of these suggestions is to clarify and refine regulatory requirements for the video game industry, specifically concerning the intersection of artificial intelligence development, data privacy, and administrative compliance. By advocating for these adjustments, the organization seeks to ensure that the evolving digital landscape remains conducive to innovation while maintaining robust protections for European consumers.

The proposed amendments focus on several critical areas of the General Data Protection Regulation (GDPR) and related digital policies. Key areas of concern include the parameters for scientific research, the handling of special categories of personal data during the development and operation of AI systems, and the practical limitations regarding data subject access requests. Furthermore, the submission addresses technical operational requirements, such as data breach notification protocols, data protection impact assessments, and the integration of cookie regulations into broader data protection frameworks.

The scope of these recommendations is pan-European, reflecting the industry's need for a harmonized regulatory environment across the continent. By targeting specific articles—such as Article 33 regarding data breaches and Article 88a concerning cookie rules—the industry body aims to reduce legal ambiguity for developers and publishers. These suggestions represent a strategic effort to align legislative mandates with the technical realities of modern game development, ensuring that data management practices remain both compliant and operationally feasible within the European digital market.