The digital fitness check is the second stage of the Commission’s plan to simplify the EU’s digital rules, following the adjustments proposed under the Digital Omnibus. Its aim is to ensure that the EU’s digital rules are effective, proportionate and fit for the future, and how effectively they support the EU’s competitiveness, values and fundamental rights. There was an open public consultation from 19 November 2025 – 11 March 2026, with questions on the interplay between the different rules and their cumulative impact on businesses.
In its response to the consultation, ACCIS relayed that at a general level credit information suppliers operate at the intersection of many digital laws — the GDPR, the EU AI Act, and the revised Consumer Credit Directive. The result is a legal maze for credit scoring. The Digital Fitness Check provides an opportunity to correct for the lack of legal clarity around third-party credit scoring activities.
ACCIS now looks forward to the 19th of November and making further contributions to simplifying the Digital Policy acquis, especially via the Digital Fitness Check.