POSITION | DIGITAL POLICY | EU SIMPLIFICATION
Simplifying the EU’s Digital Rulebook Proposals for the EU Commission’s Digital Simplification Package.
15 July 2025 Executive Summary Europe’s competitiveness is under severe pressure, as the Draghi and Letta reports stressed recently. The EU has fallen behind the USA and China in terms of growth, productivity and innovative strength. Europe is at risk of being left behind in key technologies, such as artificial intelligence. The dictum “the US innovates, the EU regulates” becomes increasingly true: The EU has adopted a comprehensive regulatory framework in the digital sector – including the Artificial Intelligence Act (AI Act), the Data Act, the Chips Act, the NIS2 Directive, the Cyber Resilience Act (CRA), the Digital Services Act (DSA), the Gigabit Infrastructure Act (GIA), the Data Governance Act (DGA) and the Digital Markets Act (DMA). This regulatory framework has negative implications for companies’ internal processes and the development of digital business models. Due to this sheer volume of digital regulatory acts, companies are confronted with an unprecedented amount of additional work that binds monetary and human resources that could otherwise be used to strengthen research, development and innovation to stay internationally competitive. Furthermore, they have to adapt their internal processes and hire specialised staff, which presents companies with additional challenges in the context of the acute shortage of skilled workers. Therefore, German industry highly appreciates the European Commission’s announcement of an ample simplification package for digital regulation. Policy recommendations at a glance German industry urges the European Commission to include the following aspects in the digital package in order to reduce the regulatory burden, cut red-tape and reporting obligations, and thereby, to boost Europe’s competitiveness by reaping the full potential of the digital transformation. To this end, we propose the following three overarching measures: ▪
Reduce reporting obligations: In several digital acts, the European co-legislators have included extensive reporting obligations. To reduce the overall regulatory burden and to free resources for research and innovation as well as the adoption of new business models, the reporting obligations must be streamlined and simplified.
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Withdraw legislative act: Since the CRA provides for harmonised and mandatory cybersecurity requirements for all products with digital elements the CSA’s schemes are obsolete for such products, henceforth, the scheme-related Articles should be withdrawn.
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Align timelines and ensure availability of standards: The European co-legislators have implemented a vast set of regulatory acts. While these acts are highly interdependent, their
Steven Heckler | Digitalisation and Innovation | T: +49 30 2028-1523 | s.heckler@bdi.eu | www.bdi.eu