In our position paper, we reaffirm the essential role of universities and other research performing organisations within the wider stakeholder ecosystem to ensure access to data and foster a truly collaborative environment.
We call for a sustained and structured collaboration between the European institutions and the research community throughout the inter-institutional negotiations and the implementation of the Digital Omnibus. Such engagement will be imperative to the creation of a successful Data Union.
Below, we outline our key recommendations:
Governance and positioning of data labs
The proposed data labs are a central operational innovation in the Data Union Strategy. However, their mandates may overlap with existing initiatives, such as the European Health Data Space Regulation (EHDS), European High Performance Computing Joint Undertaking (EuroHPC JU) and the European Open Science Cloud (EOSC). Alignment is essential, and that for each an enhanced and clear access pathway in the broader research and innovation ecosystem is maintained.
Legal coherence and streamlining under the Digital Omnibus
We broadly welcome the consolidation of the Data Governance Act, the Open Data Directive, and the Free Flow of Non-Personal Data Regulation into the Data Act. Nonetheless, ensuring legal coherence remains critical to prevent further fragmentation, particularly considering the forthcoming European Research Area Act. This alignment must take the specific needs of universities and public research organisations into account.
Strategic data assets and role of research infrastructures
The Strategy acknowledges the importance of public sector, scientific, cultural, and linguistic data, and positively highlights the European Open Science Cloud and RAISE. However, the process for expert-driven priority setting, as well as the criteria for their selection, remains undefined. Involving experts recognised by the wider research community is crucial for transparency and ensuring that research needs are accurately represented in the prioritisation process.
Data sovereignty and international research cooperation
The EU’s international approach to international data governance must safeguard strategic interests without creating barriers which could hinder scientific cooperation or limit access to global datasets. It must advance partnerships worldwide, including through the EU-Africa Global Gateway Investment Package.
Europe’s Data Union must work for the full data ecosystem. Universities and research-performing organisations should be recognised as both core users and providers of high-quality data, and therefore their role must be reflected in the operational design of new instruments such as data labs. The Guild supports the Commission’s ambition to scale access to data, but clarity on governance, legal alignment, and interoperability is essential to achieve simplification for all actors in the data ecosystem. A future-proof framework must embed research interests across the Digital Omnibus, the forthcoming ERA Act, and in the ongoing implementation of the sectoral legislation, such as the European Health Data Space Regulation, to ensure that scientific excellence, academic freedom, and international collaboration remain central to Europe’s digital transformation.
Secretary-General, Jan Palmowski