Formal Comments

We issue formal comments as part of our role as advisor on all matters relating to the procesing of personal data.

Similar to our Opinions, our Formal Comments are issued in response to a request from the European Commission under Article 42(1) of Regulation (EU) 2018/1725 and address the data protection implications of a legislative proposal or a draft implementing or delegated act. Our Formal comments are usually shorter and more technical, or only address certain aspects of a proposal.

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Nov

2025

Formal Comments

EDPS Formal Comments on the Draft Commission Implementing Regulation laying down implementing technical standards for Regulation (EU) 2023/2631 on standard forms, templates and procedures for notifying material changes in information for External Reviewer

EDPS Formal comments on the draft Commission Implementing Regulation laying down implementing technical standards for the application of Regulation (EU) 2023/2631 with regard to the standard forms, templates and procedures for the notification of material changes in the information provided for registration as an external reviewer

Available languages: English

Topics

Supervision by EDPS

Accountability

Transparency

Nov

2025

Formal Comments

EDPS Formal comments on the draft Commission Implementing Regulation on the application of the principles for verification of declared embedded emissions pursuant to Regulation (EU) 2023/956

Available languages: English

Topics

Accountability

Transparency

Security

Nov

2025

Formal Comments

EDPS Formal comments on the draft Commission Delegated Regulation supplementing Regulation (EU) 2023/956 on conditions for granting, controlling, and withdrawing verifier accreditation, and on mutual recognition and peer evaluation of accreditation bodies

EDPS Formal comments on the draft Commission Delegated Regulation supplementing Regulation (EU) 2023/956 by specifying the conditions for granting accreditation to verifiers, for the control and oversight of accredited verifiers, for the withdrawal of accreditation and for mutual recognition and peer evaluation of accreditation bodies

Available languages: English

Topics

Accountability

Oct

2025

Formal Comments

EDPS Formal comments on the draft Implementing Regulation laying down rules for the application of Regulation (EU) No 910/2014 as regards requirements for qualified trust service providers providing qualified trust services.

EDPS Formal comments on the draft Implementing Regulation laying down rules for the application of Regulation (EU) No 910/2014 as regards requirements for qualified trust service providers providing qualified trust services.

Available languages: English

Topics

Internal Market

Security

Oct

2025

Formal Comments

EDPS Formal comments on the draft Implementing Regulation laying down rules for the application of Regulation (EU) No 910/2014 as regards reference standards for qualified certificates for website authentication.

EDPS Formal comments on the draft Implementing Regulation laying down rules for the application of Regulation (EU) No 910/2014 as regards reference standards for qualified certificates for website authentication.

Available languages: English

Topics

Internal Market

Security

Cybersecurity

Access to documents
Administrative and Human Resources
AI Supervision by EDPS
Article 7 - right to private life
Binding Corporate Rules
Biometrics
Money laundering
C-ITS
Case Management System
ECHR
CJEU
Communication
Computer Forensics
Council of Europe
Data retention
COVID-19
Data Breach
Right of Information
EU Passengers Name Record
Europol
Finance
IT at Work
IT
Tracking
Management of the EDPS
mHealth
PETs
Physical Security
Public Events
Regulation 2018/1725
Safe Harbour
SIS
SIS SCG
Staff Committee
Supervision by EDPS
Surveys
Article 8 - right to data protection
Right of Access
Blockchain
Encryption
Standard Contractual Clauses
Clinical Trials
Convention 108
Tax cooperation
ECtHR
Cybersecurity
Investigations
eCall
ECRIS
PNR
OECD
Profiling
VIS
VIS SCG
Adequacy Decision
Anti-fraud
Cloud Computing
EDPB - 29WP
Cybercrime Convention
Counter-terrorism
Drones
Right to Rectification
Eurodac
Eurodac SCG
Tax evasion
Privacy Shield
Mobile Devices & Apps
CIS
CIS SCG
Umbrella Agreement
Right to Erasure
Financial markets
United Nations
Recruitment
IMI
Open Data
Right to Restriction of Processing
Staff Evaluation
IMI SCG
TTIP
Working Conditions
Smart Meters
Data Portability
EES
Procurements, Grants, Experts
Right to Object
Social Networks
Automated Individual Decision-Making
Health Data in the Workplace
Anti-harassment
Data Protection Officer
Conflicts of Interest
Security & Access to Premises
Net Neutrality
Encryption
Artificial Intelligence
Ethics
Robotics
Charter of Fundamental Rights
General Data Protection Regulation
Police Directive
ePrivacy Directive
Regulation 45/2001
Rights of the Individual
Necessity & Proportionality
Privacy by Design
Interoperability
Privacy by Default
Accountability
International Agreements
International Standards
International Cooperation
Case-law and litigation
Transfers of data
Supervision coordination
Large-Scale IT Systems
Information Security
Digital Clearinghouse 2.0
Internet of Things
Personal Information Management System
IPEN
eGovernment
Borders, Asylum, Migration
Common Foreign and Security Policy
Competition
Consumers
Finance & Economy
Health
Internal Market
Digital Single Market
Judicial Cooperation
Police Cooperation
Electronic Communications, Information Society
Research & Science
Transport
Privacy in the EU Institutions
Transparency
Whistleblowing
Surveillance
Security
Technologies

Agency for the Cooperation of Energy Regulators (ACER)
Body of European Regulators for Electronic Communications (BEREC)
Clean Sky Joint Undertaking (CSJU)
Committee of the Regions (CoR)
Community Plant Variety Office (CPVO)
Consumers, Health and Food Executive Agency (CHAFEA)
Council of the European Union
Court of Justice of the European Union (CJEU)
ECSEL Joint Undertaking (ECSEL)
eu-LISA
European Agency for Safety and Health at Work (EU-OSHA)
European Anti-Fraud Office (OLAF)
European Asylum Support Office (EASO)
European Aviation Safety Agency (EASA)
European Banking Authority (EBA)
European Border and Coast Guard Agency (FRONTEX)
European Central Bank (ECB)
European Centre for Desease Prevention and Control (ECDC)
European Centre for the Development of Vocational Training (Cedefop)
European Chemicals Agency (ECHA)
European Climate, Infrastructure and Environment Executive Agency (CINEA)
European Commission
European Court of Auditors (ECA)
European Data Protection Board (EDPB)
European Data Protection Supervisor (EDPS)
European Defence Agency (EDA)
European Economic and Social Committee (EESC)
European Education and Culture Executive Agency (EACEA)
European Environment Agency (EEA)
European External Action Service (EEAS)
European Fisheries Control Agency (EFCA)
European Food Safety Authority (EFSA)
European Foundation for the Improvement of Living and Working Conditions (Eurofound)
European GNSS Agency (GSA)
European Health and Digital Executive Agency (HaDEA)
European Innovation Council and SMEs Executive Agency (EISMEA)
European Institute for Gender Equality (EIGE)
European Institute of Innovation and Technology (EIT)
European Insurance and Occupations Pensions Authority (EIOPA)
European Investment Bank (EIB)
European Investment Fund (EIF)
European Labour Authority (ELA)
European Maritime Safety Agency (EMSA)
European Medicines Agency (EMA)
European Ombudsman (Ombudsman)
European Parliament
European Personnel Selection Office (EPSO)
European Police College (CEPOL)
European Police Office (EUROPOL)
European Public Prosecutor's Office (EPPO)
European Research Council Executive Agency (ERCEA)
European Research Executive Agency (REA)
European Securities and Markets Authority (ESMA)
European Systemic Risk Board (ESRB)
European Training Foundation (ETF)
European Union Agency for Fundamental Rights (FRA)
European Union Agency for Network and Information Security (ENISA)
European Union Agency for Railways (ERA)
European Union Drugs Agency
European Union Institute for Security Studies (EUISS)
European Union Intellectual Property Office (EUIPO)
European Union Satellite Centre (EUSC)
Fuel Cells & Hydrogen Joint Undertaking (FCHJU)
Fusion for Energy (F4E)
Innovative Medicines Initiative Joint Undertaking (IMI JU)
Joint Research Centre (JRC)
Office for Harmonisation in the Internal Market (OHIM)
Other
SESAR Joint Undertaking (SESAR JU)
Single Resolution Board (SRB)
The European Union's Judicial Cooperation Unit (EUROJUST)
Translation Centre for the Bodies of the European Union (CdT)