In our feedback document on the proposed EU Data Act, ACCIS broadly welcomes the EU Data Act as it creates a fairer, more innovative, and more competitive data economy in Europe. We are however unclear as to the stated harmonising objective of the Regulation. The GDPR – that the EU Data Act builds upon – has not [yet] managed to harmonise data processing across the EU.
Furthermore, the proposed Regulation seeks to redefine rules and practices on data access and use in order to foster data (re)use. The draft Act’s declared objective is to ensure fairness in how the value of data is allocated among actors who are active on different levels of the data value chain. Although the rules set out in the proposal are meant to be directly applicable to all sectors and across the EU as minimum standards, we are unclear how these rules will apply specifically to the credit referencing industry – if they apply at all – and would welcome clarifications in that regard.