Summary
- noyb assessed more than 1,000 proposed amendments tabled by MEPs.
- The work concerns the proposed Digital Omnibus reforms to GDPR and ePrivacy rules.
- The ratings reflect noyb’s interpretation; parliamentary voting and final legislative text remain unresolved.
European privacy organisation noyb has reviewed more than 1,000 amendments proposed by members of the European Parliament to EU data protection legislation, publishing a searchable ranking of politicians according to its assessment of how their changes would affect privacy protections. The analysis, released on 12 October, concerns proposed revisions to the General Data Protection Regulation and ePrivacy rules through the Digital Omnibus package.
The organisation evaluated amendments as strengthening or weakening the protections it considers important. It then grouped results by individual MEP and parliamentary affiliation. The scores are a civil society assessment of legislative proposals, not a formal parliamentary judgment on whether an amendment complies with EU law or what effect it would ultimately have.
Digital Omnibus reforms are being discussed partly in the context of simplifying requirements for organisations handling personal data. Supporters of simplification argue that some existing provisions impose uncertainty or unnecessary administrative effort, while privacy advocates warn that changes to definitions, consent requirements, and legal bases can alter protections for individuals and the responsibilities of businesses processing their information.
noyb argues that significant numbers of the proposals would reduce existing safeguards. In its evaluation, members of the European People’s Party received particularly negative aggregate scores, while some other groups fared better. Such comparisons depend on the organisation’s scoring criteria and how it interprets each amendment. They should not be conflated with the final position of a political group or a recorded vote on legislation.
Proposed changes and operational consequences
The eventual wording of GDPR and ePrivacy provisions may change how businesses gather, use, retain, and share customer information with technology suppliers. Questions around tracking technologies, valid consent, the status of personal data, and processing for AI development have legal consequences that extend well beyond digital advertising businesses.
An amendment can appear technical while changing which activities require consent or how an organisation must assess the legal basis for processing. Conversely, a genuinely clarifying provision can reduce inconsistent interpretation without necessarily reducing substantive protections. Evaluating the difference demands attention to the full draft text, existing case law, and any accompanying safeguards, rather than an amendment’s stated objective alone.
Privacy advocates can identify legal consequences within dense legislative proposals, although their assessments reflect their stated policy positions. noyb has published the ranking to make legislators’ proposals more visible to citizens. Its methodology and chosen labels should be considered when interpreting numerical results or comparing individuals who have submitted different numbers of amendments.
The European Parliament has not adopted the final Digital Omnibus text on the basis of this publication. Committee consideration, negotiations with member states, and any subsequent institutional agreement can change or remove proposed provisions. An amendment tabled in a legislative process is neither an enforceable requirement nor a reliable indication that an organisation’s existing compliance obligations have already changed.
Nor can the campaign rankings substitute for examining how changes interact with the separate responsibilities of data controllers, processors, and recipients of shared data. The enforcement decision in Norway involving advertising intermediary Xandr, announced on the same day, illustrates how existing GDPR provisions can impose obligations across multiple participants in a processing operation.
The ranking can also serve as an inventory of contested provisions independently of whether its scoring system is accepted. Individual amendments can be withdrawn, combined, revised, or rejected before an agreed legislative text exists. Organisations therefore need to distinguish a proposal from an enacted obligation when considering future changes to privacy practices. A score assigned by an advocacy organisation cannot substitute for the official wording and procedural status of the underlying amendment.
noyb’s published rankings provide a searchable account of its objections to individual proposals in the EU’s Digital Omnibus debate. Its publicly available database can be checked against proposed amendment text, while the legislative institutions retain responsibility for determining what, if anything, becomes law.
