# European Data Union Strategy

Canonical URL: https://digital-acquis.eu/initiative/european-data-union-strategy

Entry type: initiative

Source edition current through: 17 July 2026 (2026-07-17). This is not a page modification date.

Status: delivered. A delivered initiative is not necessarily legislation in force.

Instrument: Communication
Date as recorded: 19 Nov 2025
Date kind: date
Status note: full date links only to published artifact types
Promised timeline: Planned for 19 November 2025.

## Previous steps

Consultation

## Summary

The strategy will establish a simpler, coherent EU framework for secure, large-scale data sharing between businesses and public administrations to power AI. It will align and streamline existing rules and practices, strengthen cross-border interoperability, and embed robust safeguards for confidentiality, integrity, security and IP. Concretely, it will: promote common technical and semantic standards (e.g. schemas, metadata, APIs); enable trusted data intermediaries and data-pooling mechanisms; expand access via privacy-preserving methods (e.g. anonymisation, synthetic data, secure processing); and clarify fair, transparent licensing for B2B and public-private data use. Closely linked to AI Factories, new Data Labs will federate sectoral datasets and connect to Common European Data Spaces to unlock high-quality training data at scale.

## Sources

- [Official source](<https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52025DC0835>)

## Action items (9; complete published list)

### 1. Action item 490001

Launch first data labs to scale data availability and link to AI ecosystems (Q4 2025). They will also offer trusted pseudonymisation services.

Provenance: source document doc-060, paragraph 1. Digital dimension: yes.

### 2. Action item 490002

Launching the quality data for AI initiative: expanding high-value datasets under the Open Data Directive (Q4 2026); setting up a stakeholder forum with public broadcasters and AI developers (Q2 2026); making 30 million digitised cultural objects available for AI training (Q4 2026); and launching a crowdsourcing initiative for domain-specific data and language data in smaller European languages (Q2 2026).

Provenance: source document doc-060, paragraph 2. Digital dimension: yes.

### 3. Action item 490003

Proposal to consolidate data legislation (Q4 2025)

Provenance: source document doc-060, paragraph 3. Digital dimension: yes.

### 4. Action item 490004

Proposal to update ePrivacy rules on cookies and similar technologies (Q4 2025)

Provenance: source document doc-060, paragraph 4. Digital dimension: yes.

### 5. Action item 490005

Proposal for targeted GDPR adjustments (Q4 2025)

Provenance: source document doc-060, paragraph 5. Digital dimension: yes.

### 6. Action item 490006

Launching a one-click compliance initiative (from Q4 2025 onwards)

Provenance: source document doc-060, paragraph 6. Digital dimension: yes.

### 7. Action item 490007

Rolling out support measures for the implementation of the Data Act (from Q4 2025 onwards)

Provenance: source document doc-060, paragraph 7. Digital dimension: yes.

### 8. Action item 490008

Issuing guidelines to assess fair treatment of EU data abroad (Q2 2026)

Provenance: source document doc-060, paragraph 8. Digital dimension: yes.

### 9. Action item 490009

Creating a toolbox to counter unjustified localisation, exclusion, weak safeguards, and data leakage (Q2 2026) and adopting measures to protect sensitive non-personal data (Q3 2026)

Provenance: source document doc-060, paragraph 9. Digital dimension: yes.

## Referenced entries

- [Data Labs](<https://digital-acquis.eu/initiative/data-labs>) — status: not recorded.

Embedded in the AI Factories ecosystem, Data Labs will federate datasets and link them to the relevant Common European Data Spaces, giving developers a single, trusted entry point to high-value data. They will provide AI developers with large volumes of high-quality data in health, energy and other domains under clear access conditions and governance. Beyond brokerage, they will offer value-added services: dataset cleaning and enrichment; standardised formats; synthetic data; and shared technical building blocks that strengthen interoperability across sectors and borders, with data-pooling compliant with competition rules via trusted intermediaries under the Data Governance Act. The Commission’s Simpl software will lower integration costs and expand participation.

Source document doc-060, action item 490001:

> Launch first data labs to scale data availability and link to AI ecosystems (Q4 2025). They will also offer trusted pseudonymisation services.

## Citing documents

- [Political Guidelines 2024-29](<https://digital-acquis.eu/strategy/political-guidelines-2024-29>) — status: not recorded.

The Political Guidelines link European competitiveness with industrial renewal, digital innovation and simpler rules for businesses. They propose support for AI, data sharing, biotechnology and strategic investment, alongside cleaner energy, circular production and changes to public procurement. A Union of Skills would connect education, training and recognition of qualifications across borders. The programme also covers hospital cybersecurity, protection against online manipulation and harmful platform design, and measures to improve working conditions. International partnerships and economic security form part of this agenda, while institutional reforms and stronger cooperation on lawmaking are intended to support its implementation.

Source document doc-002, action item 30019:

> This is why we will put forward a Europea Data Union Strategy. This will draw on existing data rules to ensure a simplified, clear and coherent legal framework for businesses and administrations to share data seamlessly and at scale, while respecting high privacy and security standards.

- [Implementation and Simplification](<https://digital-acquis.eu/strategy/implementation-and-simplification>) — status: not recorded.

The communication sets out how the Commission intends to make EU rules easier to implement and less burdensome. It combines implementation strategies and stakeholder dialogues with a continuing review of legislation, practical checks with businesses and stronger assessment of regulatory costs. Simplification packages cover areas including sustainability, investment, smaller companies and digital rules. Digital tools and procedures are intended to make compliance easier across borders. Annual reporting would track implementation and burden reduction, while cooperation with Parliament and Council would support clearer assessment of amendments and more effective lawmaking.

Source document doc-021, action item 200008:

> European Data Union Strategy: Addresses existing data rules to create a simplified and coherent legal framework enabling businesses and administrations to share data seamlessly and at scale, while maintaining privacy and security standards. [2025]

- [AI Continent Action Plan](<https://digital-acquis.eu/strategy/ai-continent-action-plan>) — status: not recorded.

The AI Continent Action Plan combines computing infrastructure, access to data, wider AI use and skills development. It proposes AI Factories and Gigafactories, linked data labs and support for European data spaces, alongside work on cloud infrastructure. Industrial and scientific adoption would be supported through the Apply AI and AI in Science strategies, research funding and innovation hubs. The plan also addresses startup financing, access to markets and the attraction and training of AI talent. An AI Act Service Desk and consultation on regulatory challenges are intended to help organisations understand and meet their obligations.

Source document doc-032, action item 310013:

> Launch a public consultation on the Data Union Strategy in order to better understand industry’s data needs (Q2 2025) before presenting the Data Union Strategy (Communication, Q3 2025);

- [Life Science Strategy](<https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52025DC0525>) — status: delivered.

Source document doc-043, action item 380013:

> The Commission will support activities to develop and populate strategic biodata resources, including non-human biodata, and enable access for European and global users in complement to the European Data Union strategy.

- [Apply AI Strategy](<https://eur-lex.europa.eu/resource.html?uri=cellar:194ae542-a421-11f0-97c8-01aa75ed71a1.0001.02/DOC_1&format=PDF>) — status: delivered.

Source document doc-051, action item 430006:

> support the development of frontier AI model and AI agents adapted to manufacturing. Building on the Data Spaces for Manufacturing24 and the forthcoming Data Union Strategy, the Commission will facilitate data pooling across industrial actors through trusted third parties, to ensure a sufficient volume of training data, while preserving intellectual property and data security and making use, as relevant, of the data labs in AI Factories.

- [EU Defence Industry Transformation Roadmap](<https://defence-industry-space.ec.europa.eu/document/download/513de692-d08c-40cc-80c3-cb6611ace178_en?filename=EU-Defence-Industry-Transformation-Roadmap.pdf>) — status: not recorded.

Source document doc-062, action item 510006:

> In line with Data Union Strategy, propose the establishment of a trusted, secure, and interoperable data environment with the creation of a European Defence Data Space [by 2028], in close coordination with industry, Member States, and EDA, to facilitate the development of game-changing capabilities for defence such as AI models, digital twins, and predictive maintenance (28). The Commission will launch a reflection process with Member States and industry.

## Current developments

Latest updates from Digital Policy Alert and Global Trade Alert.

- [European Commission Data Union Strategy to streamline data sharing and governance](<https://digitalpolicyalert.org/change/14758-european-commission-data-union-strategy-to-streamline-data-sharing-and-governance>) — Digital Policy Alert; source updated: 2025-11-19; relationship: related context.

## Associated policy priorities

- [AI & Data Capabilities and Deployment](<https://digital-acquis.eu/policy-priority/ai-and-data-capabilities-and-deployment>)

## Broader policy context (shared priority; not a direct citation)

- [Action Plan on Cybersecurity and Artificial Intelligence](<https://digital-acquis.eu/initiative/action-plan-on-cybersecurity-and-artificial-intelligence>) — status: delivered.

The action plan sets out measures to make advanced AI capabilities available for cybersecurity while addressing AI-enabled threats. It covers an EU evaluation capacity for AI models, structured access to advanced capabilities, secure testing, guidance, vulnerability management and training. It also proposes a pilot campaign on critical open-source resilience, an EU Grand Challenge for AI-powered cybersecurity solutions, and use of AI Factories' computing capacity for cyber resilience.

- [AI Act Service Desk](<https://digital-acquis.eu/initiative/ai-act-service-desk>) — status: not recorded.

The Service Desk will be the EU’s single-entry helpdesk and information platform for AI Act compliance. Hosted by the AI Office, it will offer free, tailored guidance for companies and public authorities—especially SMEs—plus interactive self-assessment tools, decision trees, FAQs, templates and practical advice on obligations, risk classification, conformity assessment and documentation. It will also route users to national competent authorities and consolidate standards and best-practice resources so compliance is faster, cheaper and consistent across the Single Market.

- [AI Factories](<https://digital-acquis.eu/initiative/ai-factories>) — status: not recorded.

Open, EU-wide hubs built around EuroHPC supercomputers that bundle AI-optimised compute, data storage, programming support and talent to develop frontier models and applications. Startups, SMEs, researchers and public bodies get streamlined one-stop access to computing time, data labs linked to Common European Data Spaces, and services for testing, validation and skills—cutting training from months to weeks and lowering costs. The first 13 Factories across 17 Member States are networked, with AI Factory Antennas extending reach. EuroHPC will provide a single entry point and procure AI-dedicated systems in 2025/26, tripling Europe’s available AI capacity.

- [AI Factory Antennas](<https://digital-acquis.eu/initiative/ai-factory-antennas>) — status: not recorded.

Antennas will extend Europe’s AI compute to every region by giving Member States without local supercomputers a light-footprint node that offers remote access to the AI-optimised resources of a linked AI Factory in another country. They will plug into EuroHPC’s single entry point and common access policy, enabling streamlined allocation of compute and support services, with tailored fast tracks for startups, SMEs and selected EU projects. Antennas will interconnect with AI Factories, European Digital Innovation Hubs, Testing & Experimentation Facilities, and emerging Data Labs to deliver hands-on training, testing, and data services. All Antennas and Factories will be networked EU-wide for consistent access and support.

- [AI Gigafactories](<https://digital-acquis.eu/initiative/ai-gigafactories>) — status: forthcoming.

AI Gigafactories will give Europe frontier-scale compute to train state-of-the-art models. Each site will exceed 100,000 high-performance processors, be designed for energy and water efficiency and circularity, and be federated with EuroHPC’s AI Factories. Financing will blend public-private partnerships with the InvestAI Facility and an official EuroHPC call in Q4 2025. Facilities will co-locate data, training, safety and evaluation capabilities; provide shared access for startups, researchers and the public sector; and anchor regional skills pipelines. As a pilot for the Competitiveness Coordination Tool, they will crowd-in private capital, spur EU AI-chip design ahead of the 2026 Chips Act review, and secure sovereign AI capacity.

- [AI Pact](<https://digital-acquis.eu/initiative/ai-pact>) — status: forthcoming.

The AI Pact is a voluntary preparatory framework for organisations ahead of the AI Act's implementation. Its first pillar convenes stakeholders to exchange experience, best practices and information through the AI Office. Its second invites providers and deployers to publish pledges covering actions and timelines, including governance, mapping likely high-risk systems, and staff awareness and literacy. Pledges are not legally binding and impose no legal obligations.

- [Apply AI Alliance](<https://digital-acquis.eu/initiative/apply-ai-alliance>) — status: not recorded.

Apply AI Alliance is the strategy's main coordination forum, bringing together AI providers, industry leaders, academia and the public sector so policy action reflects real-world needs. The wider Apply AI Strategy seeks to increase AI adoption and innovation, particularly among SMEs, support an 'AI first' approach, and promote a 'buy European' approach in the public sector. Its sectoral measures cover 10 key industries and public services, alongside support through Experience Centres for AI, AI Factories, testing facilities and regulatory sandboxes.

- [Common European Data Spaces](<https://digital-acquis.eu/initiative/common-european-data-spaces>) — status: not recorded.

Will provide trusted, interoperable environments for cross-sector and cross-border data use, turning today’s fragmented datasets into high-value shared resources for businesses and public administrations. Linked tightly to Data Labs, they will offer services such as dataset cleaning and enrichment, standardised formats, synthetic data, shared technical building blocks, and cross-space interoperability to accelerate AI development and deployment. Antitrust-compliant data pooling will be enabled via trusted data intermediaries and governance under the EU data framework, lowering barriers for SMEs while protecting confidentiality and security. A common software layer (e.g. SIMPL) will simplify access and reuse across spaces, strengthening Europe’s AI ecosystem and data economy.

- [Digital Europe Programme 2025-2027](<https://digital-acquis.eu/initiative/digital-europe-programme-2025-2027>) — status: not recorded.

Digital Europe funds projects that move digital technology from research towards market deployment, with a focus on supercomputing, artificial intelligence, cybersecurity, semiconductors, advanced digital skills and wider use of digital technologies. The programme supports the EU's green and digital objectives, resilience and digital sovereignty. It is intended to benefit citizens and businesses, particularly small and medium-sized enterprises, through direct and indirect management.

- [Digital Omnibus on AI](<https://digital-acquis.eu/initiative/digital-omnibus-on-ai>) — status: in progress.

The Digital Omnibus on AI proposes changes to simplify implementation of the AI Act while maintaining protections for health, safety and fundamental rights. It responds to delayed standards, guidance and national authorities that could raise compliance costs for high-risk AI systems. The proposal would link the application of certain high-risk obligations to the availability of measures that support compliance, and would also amend EU aviation-safety rules.

- [Digital Omnibus on Data](<https://digital-acquis.eu/initiative/digital-omnibus-on-data>) — status: in progress.

The Commission will table a simplification package to cut compliance costs in the digital acquis while preserving protections. It will rationalise data rules (i.e. DGA, Free Flow of Non-Personal Data, Open Data), modernise cookie/tracking provisions to curb consent fatigue, and streamline overlapping cybersecurity incident reporting, with targeted adjustments to ensure predictable application of the AI Act. It will also clarify obligations under the European Digital Identity framework and align with the forthcoming Business Wallet, applying ‘one-in, one-out’. A Digital Fitness Check will assess cumulative effects and cross-border fragmentation.

- [European AI Observatory](<https://digital-acquis.eu/initiative/european-ai-observatory>) — status: not recorded.

The European AI Observatory is one of the governance measures in the Commission's Apply AI Strategy, adopted on 8 October 2025. The Commission says it will set up an AI Observatory to provide indicators to assess the impact of AI in the sectors covered by the strategy and in future sectors, to monitor developments and trends, and to follow the changes AI may bring to the labour market. The Observatory will also support the organisation of sectoral discussions and will be used for political analysis and decision making, as well as for informing the AI community and the broader public about recent developments in the field. The Commission adds that, based on the monitoring activities, it will make a proposal, in the context of the Digital Decade, for a public and private AI investment target.

- [Experience Centres for AI (EDIHs)](<https://digital-acquis.eu/initiative/experience-centres-for-ai-edihs>) — status: not recorded.

The network of European Digital Innovation Hubs will be transformed into AI Experience Centres, covering 85 % of European regions and fully integrated with the AI Factories ecosystem. These centres will provide companies and public administrations with hands-on access to computing power, high-quality data, testing and experimentation environments, regulatory sandboxes, and tailored training. By linking AI deployment directly to Europe’s supercomputing and data infrastructure, the Experience Centres will accelerate the uptake of AI across sectors, foster innovation in strategic industries, and ensure that European businesses can test, scale, and adopt AI solutions under trusted conditions

- [Frontier AI Initiative](<https://digital-acquis.eu/initiative/frontier-ai-initiative>) — status: not recorded.

The Frontier AI Initiative is announced in the Commission's Apply AI Strategy, adopted on 8 October 2025, in the section on supporting AI as a production factor. The Commission says it will launch and coordinate a Frontier AI Initiative to accelerate progress in frontier AI capabilities in Europe by bringing together Europe's leading industrial and academic actors and supporting strategic efforts. The initiative will focus on unlocking advanced capabilities through cutting-edge AI architectures and high-quality data, using the computing capacity offered by the AI Factories and Gigafactories. Alongside it, the Commission says it will launch major EU-wide competitions to develop open frontier AI models, and that these projects will receive free access to EuroHPC supercomputers. The strategy does not give the initiative a dedicated budget or name the body that will administer it.

- [GenAI4EU](<https://digital-acquis.eu/initiative/genai4eu>) — status: not recorded.

Will scale Europe’s generative-AI capacity through targeted R&I and deployment across sectors. Around €700 million in Horizon Europe and Digital Europe calls will fund advanced models and solutions (e.g. to optimise manufacturing lines, improve robot autonomy and human-robot collaboration, strengthen cyber-defence, and enhance medical imaging) while up to four public-sector pilots will accelerate adoption by improving decision-making, streamlining processes, and making services more accessible. Building on the AI Innovation Package and the AI Continent Action Plan, the calls in Q1 2026 will prioritise high-impact uses and innovation procurement to crowd-in private investment and translate research outputs into market-ready solutions.

- [InvestAI](<https://digital-acquis.eu/initiative/investai>) — status: not recorded.

The program will mobilise €200 billion to scale Europe’s AI capacity through a layered public-private fund that de-risks private capital with the EU budget and national co-financing. It will finance four AI gigafactories each with around 100,000 latest-generation AI chips, creating the world’s largest PPP for trustworthy AI and giving startups and industry broad access to compute. Initial EU contributions will come from Digital Europe, Horizon Europe and InvestEU, with cohesion funding from Member States. InvestAI complements the €10 billion AI Factories programme and serves as a pilot for strategic-technology financing under the Competitiveness Compass.

- [Special Envoy for Industrial AI](<https://digital-acquis.eu/initiative/special-envoy-for-industrial-ai>) — status: not recorded.

On 3 June 2026 the Commission appointed Jim Hagemann Snabe as Special Envoy for Industrial Artificial Intelligence. The Commission says he will advise President Ursula von der Leyen and Executive Vice-President Henna Virkkunen on industrial AI. His advisory role covers the entire industrial AI ecosystem, with a particular focus on AI infrastructure, including data centres, high-performance computing and the semiconductor supply chains, together with foundational AI technologies such as large language models, generative AI and cloud services, and AI applications across industrial sectors. The Special Envoy is to deliver a report on industrial AI that the Commission describes as evidence-based and forward-looking, with actionable recommendations aimed at strengthening Europe's digital sovereignty. Mr Hagemann Snabe holds the status of a non-remunerated Special Adviser until 31 March 2027 and will suspend his membership of the Google Cloud advisory board and the C3.ai board during the mandate.

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