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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Mar

2026

Formal Comments

EDPS Formal comments on the draft Commission Implementing Decision on adopting measures accessing, amending, erasing and advance erasing of data in the ETIAS Central System

EDPS Formal comments on the draft Commission Implementing Decision on adopting measures for the application of Regulation (EU) 2018/1240 as regards accessing, amending, erasing and advance erasing of data in the ETIAS Central System and repealing Commission Implementing Decision (EU) 2021/1028.

Available languages: English

Topics

Borders, Asylum, Migration

Surveillance

Mar

2026

Formal Comments

EDPS Formal comments on the draft Commission Implementing Regulation specifying the functionalities of the systems prohibiting products made with forced labour

EDPS Formal comments on the draft Commission Implementing Regulation specifying the details & functionalities of the systems prohibiting products made with forced labour on the Union market.

Available languages: English

Topics

Internal Market

Mar

2026

Formal Comments

EDPS Formal comments on the draft Commission Implementing Regulation in regards to operation and supervision of AI regulatory sandboxes

EDPS Formal comments on the draft Commission Implementing Regulation laying down rules for the application of Regulation (EU) 2024/1689 as regards the establishment, development, implementation, operation and supervision of AI regulatory sandboxes.

Available languages: English

Topics

AI Supervision by EDPS

Feb

2026

Formal Comments

EDPS Formal Comments on Draft Delegated Regulation on Access to Vehicle Data

EDPS Formal comments on draft Commission Delegated Regulation amending Regulation (EU) 2018/858 as regards the standardised access to vehicle on-board diagnostics information and repair and maintenance information, and the requirements and procedures for secure access to on-board diagnostic information.

Available languages: English

Topics

Information Security

Feb

2026

Formal Comments

EDPS formal comments on the draft Commission Implementing Regulation establishing implementing technical standards for applying Regulation (EU) No 596/2014 on the format of insider lists, repealing Commission Implementing Regulation (EU) 2022/1210

EDPS Formal comments on the draft Commission Implementing Regulation laying down implementing technical standards for the application of Regulation (EU) No 596/2014 with regard to the format of insider lists, and repealing Commission Implementing Regulation (EU) 2022/1210.

Available languages: English

Topics

Internal Market

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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
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Investigations
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ECRIS
PNR
OECD
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VIS
VIS SCG
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EDPB - 29WP
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Eurodac
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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
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TTIP
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Right to Object
Social Networks
Automated Individual Decision-Making
Health Data in the Workplace
Anti-harassment
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Encryption
Artificial Intelligence
Ethics
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Charter of Fundamental Rights
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ePrivacy Directive
Regulation 45/2001
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Necessity & Proportionality
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International Agreements
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Common Foreign and Security Policy
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Technologies

Agency for the Cooperation of Energy Regulators (ACER)
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Community Plant Variety Office (CPVO)
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eu-LISA
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European Central Bank (ECB)
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