This document is offered as an expert contribution to ongoing discussions about the data aspects of the Digital Omnibus. Drawn from my experience in digital policy, technology strategy, and digital business, I find that the Commission's current Omnibus proposal contains a small number of provisions that achieve genuine simplification and strengthen the reliability of the regulatory environment, alongside a larger number of provisions that, however well-intentioned, would produce outcomes contrary to the legislative aims set out in the Commission's own framing. My purpose is to provide the framework and background information necessary for trilogue interlocutors to identify which provisions can be retained, which can be improved, and which should be reconsidered, so that the final Omnibus achieves the impact that its proponents seek.

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