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Legislation in motion

Proposal: EU-wide DPIA lists, template and methodology (Articles 35, 57, 64 and 70 GDPR)

Date
Status
proposal
Body
Europese Commissie
Reference
COM(2025) 837 final, artikel 3, punten 9 en 11 tot 14 (wijziging artikel 35, 57, 64 en 70 AVG); ST 15698/25; 2025/0360 (COD)

What it is about

National lists of processing operations requiring or not requiring a DPIA would be replaced by EU-wide lists. Within nine months of the amending regulation becoming applicable, the EDPB would propose the lists, a common template and a methodology. The Commission would adopt them by implementing act and review them at least every three years. Existing national lists, such as the Dutch AP list, remain valid until the implementing act is adopted. The power of national authorities to set lists (Article 57(1)(k)) and the related consistency procedure (Article 64(1)(a)) are removed.

What this means in practice

If adopted, you would work with the same DPIA list and template in every Member State, simplifying work for cross-border organisations. Until the implementing act exists, the Dutch AP list remains authoritative. You may later need to align your own DPIA methodology with the EU template.

The GDPR articles concerned

Source: Raad van de EU, register (COM(2025) 837 final als ST 15698/25)checked on 15 September 2026

Summary and practical reading by Praxikon. Not legal advice; the source prevails.

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Guidelines8 of 11

Legislation in motion6 of 17