Brussels, 9 July 2025 - The European Data Protection Board (EDPB) and European Data Protection Supervisor (EDPS) issued today a Joint Opinion on the European Commission’s Proposal for a Regulation amending certain regulations, including the GDPR.

The Proposal, part of the fourth simplification Omnibus, aims to simplify EU rules and reduce administrative burden, extending certain mitigating measures available for small and medium sized enterprises (SMEs) to small mid-cap enterprises (SMCs), and includes further simplification measures. 

The Proposal aims to modify Art.30 (5) GDPR, providing a derogation to the obligation to keep a record of data processing operations. Currently, this derogation only applies to enterprises and organisation under 250 employees, except in certain cases. Under the Proposal, the derogation would apply to an enterprise or organisation employing fewer than 750 people, unless the processing operation carried out is likely to result in a high risk to individuals’ rights and freedoms, within the meaning of Art.35 GDPR.

In addition, the Proposal introduces a definition of SME and SMC in Art.4 GDPR and extends the scope of Art.40 (1) and 42 (1) GDPR to the SMCs, which refer to codes of conduct and certification. These tools are currently designed to help enterprises and organisations demonstrate compliance with the GDPR focusing on the specific needs of SMEs.

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