Compliance Briefing — June 23, 2022

Executive briefing: On June 23, 2022, Regulation (EU) 2022/868 — the Data Governance Act (DGA) — took effect. The regulation establishes certification regimes for data intermediaries, harmonizes conditions for reusing public-sector data subject to rights protections, and sets transparency rules for recognized data altruism organizations.

Immediate compliance priorities

Service qualification. Determine whether EU operations provide data intermediation services and require notification, compliance programs, and neutrality safeguards.
Public data reuse. Align licensing processes with DGA requirements for protected public-sector datasets, including confidentiality and intellectual property safeguards.
Altruism governance. Assess interest in registering as a data altruism organization and build mechanisms for consent management and transparency reporting.

Control alignment

Compliance management. Implement internal controls to preserve neutrality, prevent conflicts of interest, and maintain audit trails for data intermediation services.
Contract updates. Update data sharing agreements to reflect DGA obligations around lawful reuse, data security, and user rights.
Oversight. Prepare for supervision by designated competent authorities, including reporting obligations and on-site inspections.

Enablement moves

Coordinate with EU Data Innovation Board guidance to interpret harmonized standards.
Integrate DGA requirements with forthcoming Data Act obligations to streamline EU data strategy compliance.
Engage stakeholders on data altruism participation, including transparency dashboards for contributors.

Sources

Zeph Tech enables EU data teams to operationalize DGA obligations across intermediary services, altruism programs, and public-sector reuse agreements.