Position paper – Proposal for a Digital Omnibus

Vehicle manufacturers have become an integral part of the digital economy, with modern vehicles serving as platforms for advanced technologies, connectivity, and data-driven services.

Vehicles today are not only transport solutions but also reference points for the development and implementation of new digital technologies and innovative business models. This central role positions the automotive sector at the forefront of technological progress and digital transformation in Europe.

At the same time, vehicle manufacturers are required to comply with a complex and rapidly evolving EU digital legal framework. The fragmentation, overlap, and administrative burden of these requirements pose significant challenges, diverting resources from innovation and potentially undermining competitiveness. Navigating such a multifaceted regulatory environment is particularly demanding for companies that operate across multiple member states and digital domains.

For these reasons, the European Automobile Manufacturers' Association (ACEA) welcomes the European Commission's objective to simplify and streamline the EU digital legal framework through a Digital Omnibus package. We see this initiative as an opportunity to foster a more coherent, business-friendly regulatory environment. However, we believe that the Commission's proposal for a Digital Omnibus does not go far enough and misses a real opportunity to table measures that could have a significant positive impact for the industry.

In this context, ACEA has a number of proposals to put forward on key areas considered by the Commission which we believe can help drive the changes needed to enhance competitiveness, support innovation, and ensure Europe remains a global leader in the automotive sector.

1. Data acquis
   The auto industry supports simplifying data-sharing rules and limiting public-sector access to private data, but several Commission proposals require adjustment to avoid legal uncertainty, and further simplification is needed to reduce disproportionate burdens. ACEA calls for streamlined obligations, clearer rules on non-personal data use and international transfers, rejection of duplicative provisions, and a more balanced governance framework including industry representation.
2. Data protection and privacy
   ACEA backs objectives of the Commission's targeted GDPR amendments, but further changes are needed to better balance data protection with innovation, including clearer rules for research, special-category data use, device-level data access, and pseudonymisation. Auto makers recommend more proportionate enforcement, streamlined obligations, broader legal bases for IoT and vehicle data processing, and safeguards that ensure legal certainty, technological neutrality, and practical operability.
3. Cybersecurity
   Vehicle manufacturers endorse the Commission's plan for a single reporting channel for cybersecurity incidents, but deeper harmonisation is essential to eliminate fragmented national requirements, standardise reporting criteria, and reduce unnecessary administrative burdens. ACEA also advocates a risk-based approach to NIS 2 obligations, focusing requirements on systems tied to critical activities, exempting small entities.

Key adjustments are needed for Artificial Intelligence (AI)

Artificial intelligence is increasingly central to vehicle development, manufacturing, and mobility services. ACEA therefore welcomes the Commission's Digital Omnibus for AI, particularly the proposed extensions to implementation timelines. However, several gaps risk creating uncertainty and disproportionate compliance burdens.

To ensure workable implementation of the AI Act, ACEA calls for clarity on application dates, alignment of biometric-data definitions with the GDPR, a genuinely risk-based approach to emotion-recognition systems, and avoidance of premature sector-specific rules before harmonised standards are available. Additional improvements include guidance on copyright obligations, proportionate treatment of open-source AI, and measures to ease intra-group compliance.

In addition to our position paper on a proposal for a Digital Omnibus, a full overview of ACEA's recommendations on AI is available in the downloadable position paper below.

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