15 Oct 2025 Digital Package and Omnibus – Call for evidence

Eurosmart’s Position

While Eurosmart welcomes the Commission’s work on the Digital Omnibus, we note with concern that the current Call for Evidence appears to narrow the initial ambition of this initiative. The Omnibus was originally conceived as a bold and strategic exercise to streamline Europe’s increasingly complex digital regulatory landscape and to remove inconsistencies between key legislative acts. However, its current scope seems limited to administrative simplification, without sufficiently addressing the substantive overlaps already identified by policymakers and stakeholders.

Eurosmart therefore calls for the Digital Omnibus to fully assume its political and strategic role: ensuring coherence across Europe’s digital regulatory landscape, enhancing legal certainty, and enabling innovation grounded in trust, security, and fundamental rights. Beyond necessary administrative simplifications, Eurosmart believes the true objective of the Omnibus should be to strengthen European competitiveness and reinforce confidence in secure digital technologies.

Eurosmart has identified several areas where the Digital Omnibus can deliver real impact by harmonsing requirements from different EU legislative instruments, and more generally ensuring consistency across Europe’s digital regulatory landscape while enabling a necessary risk-based approach.

1. Excessive constraints on QSCD certification imposed by eIDAS
2. Interplay between NISD2 and the CRA
3. Interplay between the CRA and the CSA
4. Harmonization of conformity assessment practices in the CRA, CSA, NISD2, AI Act and eIDAS
5. Harmonisation of vulnerability management.
6. Provide clear legal framework for Common Specifications and technical specifications used to support implementation of legal acts
7. Enhance the CSA to provide mechanisms for risk management over certified products 7
8. Clarification on the implementation of NISD2
9. Making the AI Act Work