Europe’s Digital Omnibus: How Streamlined Regulation Will Transform Compliance As A Service

Compliance as a service is becoming the preferred model for organizations managing rising regulatory demands, especially in sectors like finance and technology in which rules evolve quickly and overlap across jurisdictions. With frameworks such as the GDPR, the AI Act, and cybersecurity regulations expanding, many firms now rely on external partners.

These pressures are more than operational. Under GDPR, serious violations can lead to fines of up to 20 million euros or 4% of an organization’s global turnover, while even less severe breaches may result in penalties of up to 10 million euros or 2%. As similar expectations spread across laws like the Data Act and digital services legislation, the cost and difficulty of staying compliant continue to grow.

To address these challenges, the European Commission introduced the Digital Omnibus in November 2025. Rather than adding new laws, it focuses on aligning existing regulations to remove duplication and improve consistency across areas such as data governance, AI oversight, and digital reporting.

This alignment directly supports the transformation towards compliance as a service model, which depends on unified processes, integrated reporting, and consistent controls across regulatory domains. In this article, we explore how the Digital Omnibus is changing the compliance environment and why it strengthens the case for adopting service-based models.

What Is the Digital Omnibus and Why Was It Introduced?

The Digital Omnibus, published by the European Commission last year, is not a new law but a coordinated update to multiple existing digital regulations. Its goal is to reduce duplication, clarify procedures, and simplify how overlapping laws are applied by businesses and enforced by regulators. 

Rather than introducing additional rules, the Commission is adjusting core frameworks such as the AI Act, GDPR, Data Act, the Digital Services Act, and cybersecurity rules to ensure they operate more consistently.

The package includes three core elements. First, it introduces technical amendments to align the language and scope of key regulations. Second, it simplifies parts of the AI Act to improve legal certainty.

Third, it lays out a broader strategy for improving data use and oversight across the European Union. For businesses operating across borders within the EU, the combined effect is a reduction in compliance difficulty and a more coherent system of obligations.

A significant structural addition is the creation of a new business category called the small mid-cap, or SMC. This refers to companies that are larger than SMEs but not large enough to meet the scale of full enterprise-level obligations. These companies will now be eligible for simplified compliance requirements that were previously restricted to smaller firms.

For organizations already offering or adopting compliance as a service, these reforms create conditions for how services can be delivered consistently across jurisdictions. The Digital Omnibus implements a model where managed compliance functions can be scaled in line with shared regulatory expectations.

Practical Compliance Changes Under the Digital Omnibus

Although the Digital Omnibus is still in its proposal stage, the direction of regulatory change is clear. The European Commission is working toward a more synchronized digital rulebook, with fewer conflicting requirements and greater legal clarity. 

This environment demands that organizations review their current compliance setups and make early operational adjustments to avoid inefficiencies and misalignment with future rules. For businesses using compliance as a service, the implications are straightforward, as service providers must translate legal updates into seamless operational delivery.

1. Mapping Overlapping Obligations

Organizations should begin by identifying where their compliance duties intersect across multiple laws. The Omnibus impacts several major frameworks, including the AI Act, the GDPR, the Data Act, and EU cybersecurity rules. 

These frameworks often require reporting, documentation, and controls that are currently managed in isolated teams or workflows. Businesses can reduce internal difficulty and prepare for a regulatory model that increasingly favors unified monitoring by creating a consolidated view of where obligations overlap. 

This is especially important in areas like data classification, incident handling, and transparency reporting, where similar outputs are often generated separately for each law.

2. Reassessing Compliance Projects and Deadlines

Many firms have planned or initiated updates to policies, documentation, and systems in line with the original timelines of individual laws. For example, transparency obligations under the AI Act were originally due for enforcement in 2026, and cybersecurity reporting processes under NIS2 were being developed in parallel with GDPR obligations.

The Omnibus introduces revised timelines and restructured processes. As a result, firms should review current projects and assess whether those plans are still aligned with the evolving legal framework. Continuing with outdated plans may result in replaceable work or systems that require additional adjustments in the near future.

This review process is particularly relevant for businesses delivering compliance as a service, since clients will expect that reporting, documentation, and compliance logic reflect the most current legal interpretations and implementation schedules.

3. Preparing for Integrated Frameworks

The Digital Omnibus introduces an underlying expectation that legal frameworks will be applied together rather than separately. From unified incident reporting through ENISA to harmonized data governance requirements, the trend is toward shared logic and common procedures.

This change requires stronger coordination among legal, compliance, information security, and operational teams. Siloed functions that manage laws in isolation may miss key synergies or create friction points that delay regulatory response or reduce audit quality.

Managed compliance providers are already expected to maintain this level of integration. For firms relying on compliance as a service, this means that obligations across AI, data, and security frameworks can be addressed through consistent workflows and shared controls, without needing to rebuild systems each time a rule changes.

Future Enforcement Outlook and Timelines

The upcoming Digital Omnibus regulation represents a foundational change in how digital laws will be enforced across the European Union, moving toward integration and procedural alignment rather than isolated compliance. 

Even though formal adoption is still underway, organizations that understand the transitional expectations and adjust their strategies early will be better positioned to maintain operational stability and regulatory trust.

1. Legislative Status and Planning Window

The Digital Omnibus is currently undergoing consultation through the European Commission’s Digital Fitness Check, with formal negotiations set to continue throughout 2026. 

The final regulation is expected to be adopted by the end of that year, giving businesses a defined window to assess and reconfigure their compliance functions in anticipation of the coming changes.

2. Phased Implementation Starting 2027

The regulation is structured for phased application rather than a single implementation deadline. Transparency obligations under the AI Act will take effect from February 2027. 

Other elements, such as the high-risk AI category and changes to contractual standards under the Data Act, will depend on additional guidance and the rollout of support tools by EU bodies. This structure emphasizes the need for careful planning and timeline tracking within compliance teams and across outsourced compliance services.

3. Pre-Enforcement Expectations from Regulators

Although the regulation has not yet taken legal effect, EU regulatory bodies are already incorporating its themes into supervisory dialogue. National data protection authorities and cybersecurity agencies are beginning to inquire about internal alignment with expected reforms. 

These inquiries focus particularly on transparency, data processing, and coordinated incident reporting. These early engagements should be viewed as signals of enforcement intent and should inform the direction of internal reviews and partner readiness assessments.

4. Centralization of Reporting Through ENISA

A significant procedural development under the Omnibus is the creation of a unified incident reporting entry point to be managed by ENISA. This reform replaces the need for organizations to submit overlapping reports under GDPR, NIS2, and DORA by consolidating them into a streamlined process. 

The result is a raised bar for consistency in incident classification, response coordination, and cross-functional engagement during reporting events.

5. Prioritizing Legal Alignment Across Frameworks

With the Omnibus encouraging integrated application of laws, regulators are expected to change focus from isolated compliance checks to evaluations of how organizations manage interrelated legal obligations. 

Companies will need to demonstrate that their approach to cybersecurity, data protection, AI governance, and data sharing is coherent and strategically aligned, rather than reactive or fragmented across departments or systems.

6. Early Adaptation Strengthens Operational Readiness

Proactive preparation remains the most effective way to avoid rushed adaptations and compliance missteps once enforcement begins. 

Institutions that invest in aligning documentation systems, legal interpretations, and internal processes in advance will experience fewer disruptions and can maintain audit readiness throughout the transition period.

7. Managed Compliance Models Must Evolve in Step

For providers of compliance as a service, this period demands awareness of the regulatory timeline and structured processes for integrating reform into operational workflows. 

Service delivery must remain aligned with new deadlines, evolving reporting formats, and regulator expectations, all while maintaining quality and scalability for clients. Those that fail to make these adjustments risk becoming out of sync with both regulatory frameworks and client obligations.

8. The Impact of the Digital Fitness Check

The Digital Fitness Check remains open through early 2026 and is expected to influence final language within the Omnibus. Companies and service providers participating in the consultation process can shape definitions, procedural safeguards, and exemption criteria. 

Engaging with this process gives compliance as a service providers insight into where future workload may concentrate and where clients will require targeted operational support.

9. Sectoral Overlaps and Compliance Layering

The Omnibus is part of a wider regulatory evolution that includes DORA for financial resilience, MiCA for crypto oversight, and the pending ePrivacy Regulation. Organizations must prepare for multi-regime obligations, ensuring that data protection, cybersecurity, and financial risk teams collaborate to avoid conflicting controls. 

Compliance as a service models are well-suited to absorb this difficulty into unified reporting and controls, particularly when services are structured to support layered regulation.

10 Cost Efficiency Through Standard Support Tools

To reduce implementation burdens, the Omnibus proposes releasing official contractual templates, guidance documents, and a legal helpdesk for the Data Act. These tools, while still in development, will help organizations avoid unnecessary legal expenditure and standardize contract language across borders. 

Compliance as a service providers should prepare to incorporate these tools into client operations to minimize manual interpretation and align delivery with regulator-validated templates.

How Lucinity Supports Operational Compliance with the Digital Omnibus and GDPR

The Digital Omnibus and updated GDPR enforcement trends call for stronger internal alignment, documented transparency, and scalable oversight. Lucinity offers a suite of tools specifically designed to meet these expectations, helping financial institutions manage obligations without duplicating effort or exposing gaps. 

These features are particularly valuable in the context of compliance as a service, where operational execution must be aligned with cross-framework consistency and real-time adaptability.

1. Case Management: Lucinity’s case management platform enables compliance teams to manage and monitor tasks across regulations such as GDPR, the AI Act, and cybersecurity laws, all within a single, configurable workspace. This is especially aligned with the Digital Omnibus’s push for procedural integration and centralized oversight. 

The system ensures consistency while reducing manual fragmentation by linking internal investigations, audit trails, and regulatory responses together. Institutions can track regulatory processes end-to-end, improving response times and supporting documentation readiness for cross-framework audits.

2. Human AI: Human AI is Lucinity’s approach to keeping humans involved in all major compliance decisions. While automation improves scale and speed, Human AI ensures accountability and judgment stay central, particularly important in light of the Digital Omnibus, which favors proportional, explainable systems over rigid rule-checking. 

Human AI enables review points, escalation paths, and contextual inputs within every workflow, helping institutions demonstrate operational control and decision-making integrity across GDPR, AI, and incident management protocols.

4. Regulatory Reporting: With the Digital Omnibus positioning ENISA as the central reporting channel for cybersecurity and data incidents, financial institutions need tools that simplify regulatory submission across overlapping frameworks. 

Lucinity’s regulatory reporting workflows support the collection, preparation, and centralized handling of reports under GDPR, DORA, and evolving EU cybersecurity laws. This helps institutions reduce manual errors while maintaining clear oversight of their reporting obligations across regimes.

Final Thoughts

With the Digital Omnibus laying the groundwork for regulatory alignment across the EU, financial institutions must reassess how they approach compliance delivery. Regulatory deadlines may be staggered, but expectations are already changing. Institutions that prepare early and adopt structured, scalable models like compliance as a service will be better equipped to manage the transition. At the same time, choosing the right partners and tools will make a meaningful difference in how efficiently and confidently compliance is maintained.

1. The Omnibus promotes legal coherence, requiring organizations to align obligations under the AI Act, GDPR, and cybersecurity rules within shared governance processes.
2. Although some requirements take effect in 2027 or later, regulators are already evaluating institutional readiness, especially regarding reporting and documentation structures.
3. From explainable AI and Human AI to unified case management and regulatory reporting, Lucinity’s platform helps financial institutions meet Omnibus expectations through structured, transparent compliance.
4. Providers are now expected to manage cross-framework obligations, track reform timelines, and deliver repeatable audit readiness as part of their operational offering.

Visit Lucinity to explore how their configurable compliance solutions align with the EU’s digital reform priorities.

FAQs

1. What is the role of compliance as a service in meeting Digital Omnibus obligations?
Compliance as a service helps institutions align workflows, reporting, and documentation across frameworks like the AI Act, GDPR, and cybersecurity rules, as required by the Omnibus.

2. Does compliance as a service cover the GDPR’s new reporting and consent rules?
Yes. A strong service model includes updates for GDPR amendments, such as centralized breach reporting and simplified cookie consent requirements.

3. How does Lucinity support compliance as a service under EU regulations?
Lucinity offers case management, Explainable AI, Human AI, and regulatory reporting tools that help firms meet integrated requirements under the Digital Omnibus and GDPR.

4. Is compliance as a service relevant for medium-sized firms under the Omnibus?
Yes. The Digital Omnibus introduces a new SMC category, and service models can help these firms access simplified compliance support without internal overhead.