Answer to request

ERAELU KAITSE JA RIIGI LÄBIPAISTVUSE EEST

Tatari tn 39 / 10134 Tallinn / 627 4135 / [email protected] / www.aki.ee

Registrikood 70004235

Daria Titova

MyGaru OÜ

[email protected]

Yours: 21.01.2026 nr Ours: 30.01.2026 nr 2.2-9/26/2205-4

Answer to request Estonian Data Protection Inspectorate (EDPI) has received your inquiry regarding the procedure for notifying the Estonian competent authority in accordance with Article 11 of the Regulation (EU) 2022/868 on European Data Governance, with the intention of obtaining recognition as a data intermediary. We appreciate your proactive engagement with the requirements set out in the DGA. At present, we would like to inform you that the competent authority to receive notifications under the Article 11 has still not yet been designated, as there is no national implementation legislation. Consequently, it is not currently possible to provide definitive answers to your specific questions regarding the notification procedure. EDPI turns your attention to the Proposal for a regulation of the European Parliament and of the Council amending Regulations (EU) 2016/679, (EU) 2018/1724, (EU) 2018/1725, (EU) 2023/2854 and Directives 2002/58/EC, (EU) 2022/2555 and (EU) 2022/2557 as regards the simplification of the digital legislative framework, and repealing Regulations (EU) 2018/1807, (EU) 2019/1150, (EU) 2022/868, and Directive (EU) 2019/1024 (Digital Omnibus). In the Digital Omnibus proposal, European Commission has proposed to repeal the Regulation 2022/868 (DGA) and according to the proposal, its provisions related to data intermediate service providers will be incorporated into the Data Act through an amendment in a simplified form. The outcome of the Digital Omnibus proposal is yet unknown. Should you have any additional questions within the remit of the EDPI, we remain at your disposal. Respectfully (signed digitally)

Kirsika Nigul

Advisor of European Cooperation and Law

authorized by Director General