by Gareth Kristensen, Prudence Buckland, Jan-Frederik Keustermans, and Hakki Can Yildiz
Left to right: Gareth Kristensen, Prudence Buckland, Jan-Frederik Keustermans, and Hakki Can Yildiz (photos courtesy of Cleary Gottlieb Steen & Hamilton LLP)
Background
On 19 November 2025, the European Commission presented its much-anticipated Digital “Omnibus” package[1] intended to ease the administrative and compliance burden facing European businesses. Executive Vice-President of the Commission Henna Virkkunen stated that “[f]rom factories to start-ups, the digital package is the EU’s answer to calls to reduce burdens on our businesses.”[2]