Subject: FW: Digital Omnibus / GDPR
From: "Justiits- ja Digiministeerium" <[email-masked]>
To: "Justiits- ja Digiministeerium" <[email-masked]>
Date: Thu, 18 Dec 2025 11:19:21 +0200

From: Vitnija Saldava <[email-masked]>
Sent: Wednesday, December 17, 2025 10:49 AM
To: Kristi Värk - JUSTDIGI <[email-masked]>
Cc: Tatjana Lukoseviciene <[email-masked]>
Subject: Re: Digital Omnibus / GDPR

Tähelepanu! Tegemist on välisvõrgust saabunud kirjaga.
Tundmatu saatja korral palume linke ja faile mitte avada.

Hello Kristi,

Hope you are doing well. Following up on the conversation we started in 
spring, I am writing to share with you our perspective on the Digital 
Omnibus (attached), and ask if you may be available for a short call, still 
this year? Perhaps there is a good time on Friday (19th)?

It is clear that despite clear mandates from industry leaders and heads of 
state, the European Commission’s Omnibus proposal fails to address Europe’s 
growing competitiveness gap – it only offers limited adjustments that do not 
match the scale or urgency of the challenge.

On the AI Act, the Omnibus report does not provide the regulatory certainty 
or competitive edge Europe needs. Modest improvements, such as expanded 
legal bases for bias mitigation, more centralized enforcement, and 
transitional periods, leave core problems intact: disproportionate 
compliance burdens, legal uncertainty, fragmented timelines, and most 
fundamentally an innovation-averse framework.

Similarly, for the GDPR and ePrivacy, clarifying legitimate interests for AI 
development and concepts of personal data and anonymisation in line with 
CJEU case law are positive but insufficient. The proposal misses the 
opportunity to firmly embed risk-based proportionality and a clear mandate 
for regulators to consider innovation and economic impact - reforms that are 
essential to enable responsible AI development and safeguard Europe’s 
competitiveness.

Kind regards,

Vitnija Saldava

Regional Public Policy Lead

Meta <http://www.meta.com/>