Digital Omnibus and e-Privacy: the right simplification in the right place

The Confederation of Swedish Enterprise welcomes the European Commission’s work to simplify the digital regulatory framework. In our position paper on the Digital Omnibus package, we propose how the e-privacy rules can be made more technology-neutral and risk-based—thereby reducing “cookie fatigue” without compromising the protection of individuals’ privacy.

Why it is needed
Today’s consent flows are often burdensome for users and complicated for businesses. A purpose- and risk-based model would mean less banner fatigue where risks are low—and clear consent where risks are higher. At the same time, it avoids cementing solutions that benefit only a small number of intermediaries in the ecosystem.

The way forward
We propose that the first Digital Omnibus should quickly deliver targeted adjustments (such as 88a(3)) to provide immediate simplification. More structural issues—for example machine-readable consent signals—should be addressed together within the Digital Fitness Check to ensure a coherent and future-proof regulatory framework.