ETD

• Artificial Intelligence
• Competitiveness
• Data Protection
• Digital Rights
• EU Law
• Simplification

The European Union’s Digital Omnibus, proposed by the European Commission (EC) in November 2025, presents itself as a simplification of an increasingly complex digital rulebook. Framed as a response to competitiveness pressures and administrative burden on businesses, the reform has nonetheless drawn sustained criticism from data protection authorities, civil society organisations and, privacy advocates, who argue that several of its core provisions amount to a substantive rollback of fundamental rights protections rather than a technical simplification.
This thesis asks to what extent the Digital Omnibus functions as a “Trojan Horse”: a reform that, presented as a competitiveness-enhancing simplification, in fact erodes the fundamental rights architecture developed under EU digital constitutionalism. Adopting a doctrinal and policy-analytical methodology, combining Charter of Fundamental Rights analysis, CJEU case law, and empirical evidence from regulators and practitioners, the thesis identifies which specific provisions pose the greatest risk to individuals’ rights and which create unexpected costs or legal uncertainty for businesses, testing the Commission’s own claim that simplification benefits both. The analysis suggests that the reform largely fails on its own terms: it weakens key rights protections while delivering limited genuine relief to the businesses it claims to serve, exposing a false dichotomy between rights protection and market competitiveness at the heart of the EU’s current simplification agenda.