The European Commission’s Digital Omnibus package (published 19 November, 2025; see here) proposes a number of amendments to inter alia the GDPR, including to Article 22. Recognising the significance of these proposals for the credit information sector, ACCIS engaged with the legislative process by submitting feedback via the European Commission’s portal ahead of the 13 March, 2026 deadline.
Article 22 of the GDPR – which governs automated individual decision-making, including profiling – is of central importance to ACCIS members. Not least, since the landmark ruling in Case C-634-21 of the Court of Justice at the end-of 2023. Any potential future changes to the legal framework governing this activity therefore demands close attention. In that submission, ACCIS put forward a concrete set of proposed amendments to Article 22, reflecting the operational realities of credit information suppliers and the essential role they play in enabling access to credit, while also respecting the horizontal nature of the Regulation.