5 Trends to Watch: 2025 EU Data Privacy & Cybersecurity

1. Full Steam Ahead: The European Union's (EU) Artificial Intelligence (AI) Act in Action - As the EU's landmark AI Act officially takes effect, 2025 will be a year of implementation challenges and enforcement. Companies deploying AI across the EU will likely navigate strict rules on data usage, transparency, and risk management, especially for high-risk AI systems. Privacy regulators are expected to play a key role in monitoring how personal data is used in AI model training, with potential penalties for noncompliance. The interplay between the AI Act and the General Data Protection Regulation (GDPR) may add complexity, particularly for multinational organizations.
   
   
2. Network and Information Security Directive (NIS2) Matures: A New Era of Cybersecurity Regulation - The EU's NIS2 Directive will enter its enforcement phase, expanding cybersecurity obligations for critical infrastructure and key sectors. Companies must adapt to stricter breach notification rules, risk management requirements, and supply-chain security mandates. Regulators are expected to focus on cross-border coordination in response to major incidents, with early cases likely setting important precedents. Organizations will likely face increasing scrutiny of their cybersecurity disclosures and incident response protocols.
   
   
3. The Evolution of Data Transfers: Toward a Unified Framework - After years of turbulence, 2025 may mark a turning point for transatlantic and global data flows. The EU-U.S. Data Privacy Framework will face ongoing reviews by the European Data Protection Board (EDPB) and potential legal challenges, but it offers a clearer path forward. Meanwhile, the EU may continue striking adequacy agreements with key trading partners, setting the stage for a harmonized approach to cross-border data transfers. Companies will need robust mechanisms, such as Standard Contractual Clauses and emerging Transfer Impact Assessments (TIAs), to maintain compliance.
   
   
4. Consumer Rights Expand Under the GDPR's Influence - The GDPR continues to set the global benchmark for privacy laws, and 2025 will see the ripple effect of its influence as EU member states refine their own data protection frameworks. Enhanced consumer rights, such as the right to explanation in algorithmic decision-making and stricter opt-in requirements for data use, are anticipated. Regulators are also likely to target dark patterns and deceptive consent mechanisms, driving companies toward greater transparency in their user interfaces and data practices.
   
   
5. Digital Markets Act Meets GDPR: Privacy in the Platform Economy - The Digital Markets Act (DMA), fully enforceable in 2025, will bring sweeping changes to large online platforms, or "gatekeepers." Interoperability mandates, restrictions on data combination across services, and limits on targeted advertising will intersect with GDPR compliance. The overlap between DMA and GDPR enforcement will challenge platforms to adapt their practices while balancing privacy obligations. This regulatory synergy may reshape data monetization strategies and set a precedent for digital market governance worldwide.

About the Authors

Dr. Viola Bensinger is global co-chair of Greenberg Traurig LLP's Intellectual Property & Technology Practice Group. Carsten Kociok is co-head of Greenberg Traurig's global Fintech Group. And Dr. Philip Radlanski is a local partner in Greenberg Traurig's IP & Technology Practice Group. With more than 260 intellectual property attorneys and patent agents in the United States, Asia, and Europe, Greenberg Traurig provides a broad range of patent, trademark and copyright protection and strategic counseling. Greenberg Traurig was named a "National Tier 1" Law Firm for IP Litigation, Patent Law and Litigation, Copyright Law, Technology Law, Information Technology, and Trademark Law by Best Law Firms® in 2025. In the 2024 report, Greenberg Traurig was named Law Firm of the Year for Information Technology Law. In addition, Greenberg Traurig was named a "Law Firm of the Year" for Trademark Law in the 2020 and 2022 editions of Best Law Firms®. The BTI Consulting Group named Greenberg Traurig's IP Litigation Practice a 'Litigation Standout' in the "BTI Litigation Outlook 2024: Navigating Litigation Spending in the New Unpredictable World."