Position Paper

Ensuring Clarity and Flexibility in the EU Data Act

The sharing and use of data continues to increase in importance for many sectors across the economy, the travel and tourism sector making no exception. eu travel tech’s members, as prominent digital intermediaries of travel services, fully support the Data Act’s ambition to facilitate access to and further the (re-) use of data. Particularly as regards B2B and B2C interactions on data sharing, a harmonized framework at the EU level can go a long way to creating much-needed legal clarity on the rights of obligations of both data holders and data recipients.

In the paper below, eu travel tech sets out its views on the EU Data Act proposal currently under discussion in the European Parliament and Council of the EU.

Key recommdations:

  • Safeguard possibility for sectoral legislation to use Data Act as basis and derogate from it, where required.
    • Ensure flexibility for sectoral legislation particularly in derogating from compensation provisions and non-binding dispute settlement.
  • Introduce significantly more clarity on B2G data sharing obligations by providing guidance, more well-defined terms and stronger proportionality checks.
    • Facilitate compliance by extending timelines and introducing rules to prevent abuse and disproportionate requests.
    • Ensure legislative coherence by clearly defining relationship between the Data Act and sectoral B2G data sharing obligations.