SIIA Comments on the EU Digital Fitness Check and Digital Omnibus for AI, Data, and Cybersecurity

The Software & Information Industry Association (SIIA) submitted comments to the European Commission's Digital Fitness Check and related Digital Omnibus initiatives addressing privacy, AI, cybersecurity, and data governance rules. The submission highlights how overlapping EU digital regulations-including the GDPR, AI Act, Data Act, and cybersecurity frameworks-can create duplication, inconsistent terminology, and fragmented compliance obligations for software, cloud, and AI developers. SIIA recommends targeted reforms to reduce administrative burden while preserving strong protections for individuals and resilient digital infrastructure. Key proposals include clarifying lawful bases for AI development, enabling interoperable consent and opt-out signals, harmonizing cybersecurity incident reporting, aligning digital identity rules with existing standards, simplifying data sharing and interoperability frameworks, and ensuring proportional implementation of the AI Act. These changes aim to improve legal certainty, streamline compliance, and support innovation across the EU's digital economy.

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