JBCE Position Paper on the Proposal for a Digital Package on Simplification
On 10 October 2025, JBCE submitted its position paper on the European Commission's proposal for a Digital Package on Simplification.
JBCE sets out several proposals to simplify compliance, reduce overlapping obligations, and ensure alignment with the General Data Protection Regulation (GDPR) and international standards in order to enhance Europe’s competitiveness and innovation capacity.
- Data legislation (mainly Data Act): JBCE advocates for clearer protections for trade secrets, proportional obligations, and harmonised compensation rules to avoid excessive burdens on data holders.
- Cybersecurity: JBCE recommends unified reporting templates, realistic timelines aligned with GDPR standards, and regulatory coherence across Cyber Resilience Act, NIS2, and sector-specific rules to prevent duplication.
- Artificial Intelligence Act: JBCE advocates for a phased implementation, simplified documentation requirements, and clearer definitions - particularly of “high-risk” and “substantial modification” - to reduce legal uncertainty while fostering innovation.
These measures will contribute to greater legal clarity, lower compliance costs, and position the EU as a global leader in secure, interoperable, and innovation-friendly digital ecosystems.
JBCE also underscores the strategic importance of EU–Japan cooperation in developing interoperable standards and promoting the exchange of best practices. We strongly hope that such collaboration will be further advanced through structured policy dialogues, notably the EU–Japan Digital Partnership, thereby contributing to the prosperity of both regions and the strengthening of global digital governance.
For more information, please contact info@jbce.org