In response to the EC’s Call for Evidence, we underscore the importance of recognising a broader community of actors that depend on access to and reuse of public sector data, such as the research community.
Universities play a strategic role in driving research excellence by sharing, accessing, and providing data. To fully harness this potential, the rights and obligations outlined in the Data Governance Act (DGA) and the Open Data Directive (ODD) need to be clarified. Without such clarity, regulatory ambiguity may arise, potentially hindering their ability to engage in research and open science.
The scopes of the DGA and ODD include bodies under public supervision, which often include universities. It is worth noting that data held by cultural establishments under the DGA, such as libraries, are excluded from the scope of the DGA, which creates uncertainties for universities, as many of them also have libraries under their governance structure. Additionally, in the case of the ODD, the definition of “publicly funded” research data remains vague, particularly in the context of public-private partnerships, and requires further clarification.
By overlooking the research community in its simplification efforts, the Commission risks marginalising a key stakeholder essential to enabling data availability, fostering trust-based sharing, and safeguarding Europe’s scientific leadership.
Finally, we urge the Commission to ensure that any revisions to the digital acquis under the Digital Omnibus are closely aligned with the forthcoming ERA Act and the ERA Policy Agenda 2025–2027. Such alignment is vital to advancing open science, improving research data management, and upholding the FAIR data principles.
In Europe, universities are at the heart of the continent’s digital ecosystem, especially compared to our major competitors that have far stronger private investment in digital research, innovation and application. It is critical that, as it strives towards a holistic strategy on data governance, the Commission is fully cognisant of the importance of the public R&I community and its role in generating and using data. Hence, we must insist on universities being fully recognised in the proposed revisions of the data acquis under the Digital Omnibus.
Jan Palmowski, Secretary-General of The Guild