The European Commission’s plan with the Digital Omnibus package on incident reporting, which introduces a single-entry point for notifying incidents across GDPR, NIS2, DORA, eIDAS and other EU regimes, aims to simplify compliance but may instead create new operational complexity.

The proposal sits at the centre of the Digital Omnibus package and is intended to streamline the way organisations communicate serious events to regulators. Yet when examined closely, the practical consequences reveal a series of challenges that could outweigh the anticipated benefits.

Different regulatory regimes cannot be reduced to a single model

Each EU incident reporting regime was developed independently, with its own terminology, thresholds, timelines and evidentiary requirements. A GDPR data breach, for example, follows a logic that does not align with a NIS2 “significant incident,” and both differ substantially from operational resilience events regulated under DORA.

A universal template risks being either overly generic or misleadingly detailed. Companies may find themselves omitting key information needed by specific authorities or, conversely, providing unnecessary details simply to ensure they meet the strictest standard. This is one of the inherent weaknesses of digital omnibus incident reporting as currently conceived.

Language requirements remain a practical barrier

A single EU platform cannot resolve national language obligations. Today, many authorities still require:

• submissions in local languages,

• translated annexes or forensic analyses, and

• clarifications written in national terminology.

Even if the unified interface accepts English, regulators may still demand local-language documents. This could lead to duplicate filings or translation-heavy workflows that undermine the idea of simplification.

Some national authorities already operate efficient systems

Several countries have invested in advanced, automated reporting tools. Italy’s Garante, for instance, has developed a highly functional platform for personal data breach notifications. If organisations must now complete a broad EU-level form and then supplement it because national authorities require more context, the process grows longer and more burdensome.

In such cases, the digital omnibus incident reporting system risks adding layers of work rather than removing them.

Follow-up questions could slow down time-sensitive assessments

Incident reporting is time-critical. Authorities need detailed, accurate information as quickly as possible. A one-size-fits-all form may not provide the granularity needed for initial assessment, prompting multiple rounds of follow-up questions. That slows down the overall response process at the exact moment when speed is essential.

A more realistic solution: harmonise within each regulatory field

Rather than merging all regimes into a single structure, a more effective approach would involve:

• harmonised GDPR breach notification forms,

• consistent NIS2 templates, and

• alignment within DORA’s operational resilience rules.

This preserves clarity and respects the distinct design of each regulatory regime, while still delivering meaningful simplification.

My experience overseeing multijurisdictional incident reporting across dozens of countries demonstrates that harmonisation works only when it respects the internal mechanics of each legal framework. Forced unification tends to create ambiguity and administrative backlogs.

Final Thoughts

The Digital Omnibus package has noble ambitions: less fragmentation, more consistency, and a smoother compliance experience. But ambition must be matched with operational realism.

Unless carefully redesigned, the digital omnibus incident reporting system may create increased workloads, slower assessments and more uncertainty for organisations already navigating a dense regulatory landscape.

True simplification begins with precision—ensuring that each field, each authority and each legal framework receives exactly the information it needs, no more and no less.

On a similar topic, you can read the article “CJEU clarifies that a data breach does not presuppose inadequate technical privacy measures“.