Data Strategy Briefing — September 24, 2025
The European Commission must deliver its first Data Governance Act evaluation by 24 September 2025, so data leaders should prepare evidence packs that show how neutrality, access, and sanction frameworks are operating ahead of the report and potential legislative proposals.
Executive briefing: Article 35 of the Data Governance Act (DGA) requires the Commission to submit an evaluation of the Regulation to the European Parliament, the Council, and advisory committees by 24 September 2025. The review will scrutinise how data intermediation services, re-use authorisations, and penalty regimes are functioning, making it critical to surface operational proof points before policymakers consider follow-up legislation.
Key governance checkpoints
- Neutrality evidence. Assemble documentation showing how Article 12 neutrality safeguards, separation of duties, and accounting controls are being enforced across your data intermediation portfolio.
- Public-sector re-use dashboards. Ensure Article 5 request tracking demonstrates timely handling of protected public-sector data re-use and highlights any disputes escalated to competent bodies.
- Penalty oversight. Confirm Article 34–35 sanction frameworks have governance owners and that reporting lines into national authorities are documented.
Operational priorities
- Stakeholder engagement. Brief public policy and regulatory affairs teams on likely evaluation themes so they can contribute case studies to Commission consultations.
- Gap remediation. Use evaluation criteria to stress-test whether data altruism consent mechanisms and metadata disclosures align with DGA expectations.
- Scenario planning. Model how possible legislative amendments—such as tighter certification or reporting obligations—would impact service design and staffing.
Enablement moves
- Run executive table-top exercises that walk through the Commission’s assessment questions and identify the evidence each function can supply.
- Update board reporting templates to reference the evaluation timeline and any anticipated follow-up proposals or delegated acts.
Sources
Zeph Tech prepares DGA evaluation evidence packs, neutrality control attestations, and legislative scenario briefings for multinational data teams.
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