Editor’s Note: The EU has set a deadline for cross-border GDPR enforcement. On June 16, 2025, Parliament and Council reached a provisional deal that brings binding deadlines, unified complaint standards, early-stage coordination among DPAs, and consistent procedural rights across the bloc. For cybersecurity, information governance, and eDiscovery teams, this is more than process hygiene—it’s operational change. Predictable timelines (including a 15-month cap for complex matters) will tighten incident response and evidence-preservation windows, make data mapping and retention decisions more consequential, and raise the premium on coordinated, cross-border playbooks. Now is the time to validate main-establishment determinations, stress-test regulatory response protocols, align translation and notification workflows, and ensure legal tech stacks can track milestones and manage DPA interactions at pace. While formal adoption is expected later in 2025, proactive preparation will pay dividends as enforcement becomes faster, clearer, and more consistent across the EU.
Content Assessment: EU Agrees on GDPR Cross-Border Enforcement Reform: New Procedural Rules to Streamline Investigations
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Industry News – Data Privacy and Protection Beat
EU Agrees on GDPR Cross-Border Enforcement Reform: New Procedural Rules to Streamline Investigations
ComplexDiscovery Staff
The European Union reached a provisional agreement on June 16 2025, establishing new procedural rules for cross-border data privacy investigations under the General Data Protection Regulation (GDPR). The agreement between the European Parliament and the Council introduces binding deadlines and standardized procedures aimed at addressing documented delays and coordination challenges that have affected cross-border cases since the GDPR’s implementation in 2018.
The reforms, initially proposed by the European Commission in July 2023 (COM(2023) 348 final), establish 15-month deadlines for complex privacy cases and create uniform complaint standards across all 27 EU member states, marking the first substantial revision to GDPR enforcement procedures since the regulation took effect, focusing specifically on improving the mechanics of cross-border cooperation between data protection authorities (DPAs).
Current Enforcement Challenges
Statistical data from Ireland’s Data Protection Commission (DPC) illustrates the concentration of cross-border cases within the current system. According to the DPC’s September 2023 statistical report, 87% of cross-border complaints handled by Ireland relate to just ten data controllers—primarily large technology companies with European headquarters in Dublin. Between May 2018 and September 2023, the Irish DPC completed 79% of cross-border complaints in which it served as the lead supervisory authority.
The one-stop-shop mechanism, designed to simplify GDPR compliance by designating a single lead supervisory authority for organizations operating across multiple EU states, has created bottlenecks when handling high volumes of complaints. Translation requirements, varying national procedural rules, and resource constraints have contributed to processing delays, with some complex investigations extending over multiple years.
European Commission officials, when proposing the procedural reforms in 2023, acknowledged that “inconsistent application by data protection authorities, fragmented national procedures, and limited resources” had created challenges for effective cross-border enforcement. The proposed regulation aims to address these structural issues while maintaining the fundamental privacy protections established by GDPR.
Key Elements of the New Framework
The provisional agreement introduces several mechanisms designed to standardize and accelerate cross-border investigations.
Binding Enforcement Timelines: Complex cases must conclude within 15 months, with simplified cooperation procedures limited to 12 months. The framework includes a single possible extension of up to 12 additional months for the most complex investigations. These deadlines provide predictability for both complainants and organizations under investigation.
Unified Complaint Standards: The regulation establishes consistent admissibility criteria for privacy complaints across all member states. This harmonization addresses current disparities where identical complaints might receive different treatment depending on the filing location, ensuring more equitable access to privacy enforcement mechanisms.
Enhanced Procedural Rights: Both complainants and organizations under investigation are granted guaranteed rights to access preliminary findings and provide comments before final decisions are made. These procedural protections will apply uniformly across all member states, replacing the current patchwork of varying national approaches.
Streamlined Resolution Pathways: Early resolution mechanisms allow supervisory authorities to address straightforward complaints before engaging the full cross-border cooperation procedure. This approach reduces administrative burden while maintaining appropriate rights protections for all parties.
Improved Coordination Requirements: Lead supervisory authorities must share summaries of key issues early in investigations, enabling other national authorities to provide input and align their positions. This mandatory early liaison aims to reduce conflicts between DPAs that have contributed to case delays.
Implications for Organizations and Legal Teams
Organizations with European operations should begin preparing for more structured interactions with supervisory authorities. The standardized timelines and procedures will require companies to establish clear protocols for responding to investigation notices and preliminary findings within defined periods.
For eDiscovery and information governance professionals, the reforms may increase the importance of maintaining robust data mapping and retention policies. The streamlined procedures could lead to more frequent enforcement actions as administrative barriers to investigation decrease. Organizations should review their main establishment determinations under GDPR, as this designation continues to determine which DPA serves as the lead supervisory authority.
Legal technology providers may need to adapt their compliance tools to accommodate the new procedural requirements, particularly those related to timeline management and cross-border coordination. The enhanced procedural rights create opportunities for more systematic approaches to managing regulatory interactions across multiple jurisdictions.
Implementation and Next Steps
The provisional agreement requires formal adoption by both the European Parliament and Council. Based on standard EU legislative procedures following provisional agreements, formal adoption is expected in late 2025. Once adopted, the regulation becomes directly applicable across the EU without requiring national implementation measures.
The European Parliament’s Legislative Train Schedule indicates the file remains under active consideration, with the regulation designed to complement rather than replace existing GDPR provisions. The focus on procedural harmonization preserves the substantive privacy protections while addressing the mechanical aspects of cross-border enforcement.
Privacy professionals and organizations should monitor the final text publication for specific procedural details not included in the provisional agreement announcements. Key areas to watch include the precise criteria for complaint admissibility, specific requirements for early liaison between authorities, and detailed provisions for the early resolution mechanisms.
Context and Perspectives
The reforms respond to extensive documented criticism of current enforcement mechanisms from multiple stakeholders. Academic analyses, including studies published by the Center for Strategic and International Studies, have highlighted coordination challenges between DPAs. Privacy advocacy groups, while welcoming standardization efforts, have expressed concerns about whether the reforms go far enough to address enforcement gaps.
Industry representatives have generally supported the push for greater procedural clarity and predictable timelines. Law firms advising multinational clients note that the current system’s unpredictability creates compliance challenges, particularly for organizations operating across multiple member states.
Some data protection authorities have emphasized that resource constraints, rather than procedural rules alone, contribute to enforcement delays. The reforms do not directly address funding or staffing issues, which vary significantly across member states.
Looking Ahead
These procedural reforms represent a significant evolution in European privacy enforcement infrastructure. By establishing binding deadlines and harmonized procedures, the regulation aims to deliver more consistent and timely resolution of cross-border privacy complaints while maintaining strong data protection standards.
For the eDiscovery and legal technology community, the reforms signal a maturing of the GDPR enforcement ecosystem. Organizations should view the standardization as an opportunity to develop more systematic approaches to privacy compliance and regulatory engagement. The enhanced predictability may facilitate better risk assessment and resource allocation for cross-border data governance programs.
As the regulation moves toward formal adoption, stakeholders should engage with the implementation process to ensure the new procedures deliver their intended benefits while avoiding unintended consequences. The success of these reforms will ultimately depend on the effective implementation by data protection authorities and the thoughtful adaptation by organizations subject to GDPR requirements.
News Sources
- Enhancing GDPR Enforcement: The EU’s New Procedural Regulation for Cross‑Border Cases (Caldwell Law)
- EU lawmakers announce deal on cross-border GDPR enforcement procedures (International Association of Privacy Professionals)
- EU reaches agreement to streamline cross-border GDPR enforcement (Baker McKenzie)
- EU Finalizes GDPR Procedural Regulation to Improve Cross-Border Enforcement (Federation of Business Information Services)
- 3 Years Later: An Analysis of GDPR Enforcement (Center for Strategic and International Studies)
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Source: ComplexDiscovery OÜ






































