Moderate
Guidance
In effect
France · Sep 10, 2026 · effective Sep 1, 2026
CNIL guidance on data‑protection obligations under the electronic invoicing reform effective 1 Sept 2026
The CNIL explains the data‑protection implications of the French electronic invoicing reform that entered into force on 1 Sept 2026. It details which personal data may be processed, the roles of issuers, receivers and certified platforms…
CNIL · réforme relative à la facturation électronique
Low
Enforcement
Announced
Germany · Sep 10, 2026
noyb to file injunction against SCHUFA over shadow database
noyb sent a cease-and-desist letter to SCHUFA demanding the removal of its shadow database. SCHUFA's deadline to comply has expired and the agency has rejected the allegations. noyb announced it will now file an injunction and invites…
Moderate
Lawsuit filed
Filed
United States (federal) · Sep 8, 2026
EFF releases 1,000 pages of CMS records on AI-driven Medicare WISeR prior‑authorization program
EFF obtained about 1,000 pages of CMS documents through its FOIA lawsuit filed in March, revealing delays, denials, and financial incentives in the WISeR AI model. The records show requests sometimes waited up to 83 days and vendors denied…
Centers for Medicare & Medicaid Services (CMS)
High
Amendment
Signed
Delaware · Sep 3, 2026 · effective Jan 1, 2027
Delaware Governor signs HB 380, amending the DPDPA effective Jan 1 2027
Governor Meyer signed HB 380 on September 2, amending the Delaware Personal Data Privacy Act. The amendment expands the definition of sensitive data, lowers applicability thresholds, adds new contractual and due‑diligence requirements for…
CFPB · Fair Credit Reporting Act
Moderate
Proposed regulation
Announced
France · Sep 3, 2026
CNIL agenda includes review of draft decrees on automated personal data processing and authorizations for health data studies
The CNIL plenary session agenda for 3 September 2026 lists examinations of draft deliberations on a decree modifying decree n° 2023‑935 for the SISPoPP system, a draft decree on the API‑PNR France system, and authorizations for RCTs, IQVIA…
Commission nationale de l'informatique et des libertés (CNIL) · General Data Protection Regulation
Low
Enforcement
Announced
Germany · Aug 26, 2026 · effective Aug 26, 2026
noyb sends cease‑and‑desist letter to SCHUFA over alleged ‘shadow database’ GDPR violations
In July 2026, the NGO noyb issued a cease‑and‑desist letter to German credit agency SCHUFA demanding it stop storing data beyond retention periods and provide full historical data under Article 15 GDPR. The organization warned it will seek…
EDPB · General Data Protection Regulation
Low
Enforcement
Announced
United States (federal) · Aug 19, 2026
Tech firms privately resist ICE subpoenas seeking user data
ICE has sent hundreds of subpoenas to large technology companies for subscriber information. Meta and Reddit have privately pushed back, questioning statutory authority and objecting to requests tied to protected activity. In some cases…
U.S. Immigration and Customs Enforcement · 19 U.S.C. §1509
Low
Court ruling
Decided
United States (federal) · Aug 4, 2026
Ninth Circuit rules Perplexity AI’s Comet browser not liable under CFAA
The Ninth Circuit Court of Appeals held that Perplexity AI’s Comet browser does not violate the Computer Fraud and Abuse Act because the tool itself does not access Amazon’s servers; users do. The court rejected Amazon’s claim that…
Computer Fraud and Abuse Act
Low
Enforcement
Filed
Austria · May 5, 2026
LinkedIn blocks GDPR access to profile visitor data behind paywall, noyb files complaint in Austria
LinkedIn requires users to pay to view who has visited their profile, despite the data being personal under the GDPR. noyb argues the data must be provided free of charge under Article 15 and has lodged a complaint with the Austrian Data…
Austrian Data Protection Authority · General Data Protection Regulation
Moderate
Proposed regulation
Proposed
European Union · Apr 16, 2026
EU Digital Omnibus proposal aims to limit GDPR right of access amid 83.5% non‑compliance
The European Commission’s Digital Omnibus proposal would restrict the GDPR right of access to “data protection purposes”, citing alleged abuse. NOYB’s analysis shows that 83.5% of access requests were not properly answered, with only 16.5%…
European Commission · General Data Protection Regulation
Moderate
Fine
In effect
France · Mar 13, 2026
French court upholds €40M GDPR fine against Criteo
The French Data Protection Authority (CNIL) fined Criteo €40 million for GDPR violations, including lack of valid consent, transparency, and failures to honor erasure and access rights. In March 2026, the Conseil d’État rejected Criteo’s…
CNIL · General Data Protection Regulation
Moderate
Proposed regulation
Published
European Union · Mar 5, 2026
EU Commission's Digital Omnibus proposal to limit GDPR Right of Access faces criticism from DPOs
The European Commission has published a Digital Omnibus proposal that would narrow the definition of personal data, restrict the Right of Access and allow broader AI training. A survey by noyb shows data protection officers consider the…
European Commission · General Data Protection Regulation
Moderate
Proposed regulation
Proposed
European Union · Feb 24, 2026
EU Commission proposes Digital Omnibus to amend GDPR and ePrivacy Directive
The European Commission published its Digital Omnibus proposal on 19 November 2025, aiming to amend the GDPR and the ePrivacy Directive. noyb’s analysis warns that the proposed changes could conflict with the EU Charter of Fundamental…
European Commission · ePrivacy Directive
Moderate
Guidance
Published
European Union · Feb 11, 2026
EU DPAs reject key proposals in Digital Omnibus GDPR changes
The European Data Protection Board and the European Data Protection Supervisor issued a joint opinion rejecting the Commission's proposal to narrow the definition of personal data and to restrict the right of access. They also raised…
European Data Protection Board (EDPB) and European Data Protection Supervisor (EDPS) · ePrivacy Directive
Moderate
Lawsuit filed
Filed
European Union · Jan 28, 2026
noyb debunks 5 GDPR misconceptions on Data Protection Day
The article clarifies that the GDPR does not mandate cookie banners, that DPAs rarely impose fines, and that companies must obtain explicit consent for tracking. It also explains the limited scope of the right of access and counters claims…
EDPB · General Data Protection Regulation
Low
Lawsuit filed
Filed
Germany · Jan 28, 2026
noyb files lawsuit against Hamburg DPA over Pay or Okay case involving SPIEGEL
In 2024, privacy advocacy group noyb sued the Hamburg Data Protection Authority concerning a Pay or Okay implementation dispute with the German news magazine SPIEGEL. The case highlights concerns about DPA impartiality and enforcement…
Hamburg Data Protection Authority · General Data Protection Regulation
Moderate
Court ruling
Decided
Austria · Dec 18, 2025 · deadline Dec 31, 2025
Austrian Supreme Court orders Meta to give users full data access within 14 days
The Austrian Supreme Court ruled that Meta must provide a complete copy of all personal data to any user request within 14 days, including source, recipient and purpose information. The court also required Meta to obtain explicit opt‑in…
EDPB · General Data Protection Regulation
Low
Enforcement
Filed
Austria · Dec 17, 2025
noyb files complaints against TikTok, AppsFlyer and Grindr with Austrian DSB over unlawful tracking
noyb has lodged two complaints with Austria's data protection authority alleging that TikTok tracks users across other apps and fails to provide a complete copy of personal data. The complaints also target AppsFlyer and Grindr for sharing…
Austrian Data Protection Authority (DSB) · General Data Protection Regulation
Moderate
Proposed regulation
Proposed
European Union · Nov 22, 2025
EU Commission proposes Digital Omnibus package with new personal data definition and research exemption
The European Commission has released the Digital Omnibus proposal, introducing a narrower definition of personal data (Art. 4(1)), a broader research exemption (Arts. 4(38), 5(1)(b), 13, 89), and new AI‑related rules (Arts. 9(2)(k), 9(5)…
European Commission · General Data Protection Regulation
Moderate
Proposed regulation
Proposed
European Union · Nov 11, 2025
Open letter warns EU Commission's Digital Omnibus draft could deregulate GDPR
Noyb, EDRi and the Irish Council for Civil Liberties sent an open letter to the European Commission criticizing a draft Digital Omnibus that would amend core GDPR provisions. The draft proposes redefining personal data, weakening data…
European Commission · General Data Protection Regulation
