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Praxikon

Legislation in motion

Proposal: definition of scientific research, purpose limitation and information duty for research (Article 4(38), 5(1)(b) and 13(5) GDPR)

Date
Status
under negotiation
Body
Europese Commissie
Reference
COM(2025) 837 final, artikel 3, punten 1(b), 2 en 6; 2025/0360 (COD); ST 15698/25

What it is about

The proposal adds a definition of scientific research. It includes research that supports innovation and research that also furthers a commercial interest. Further processing for archiving in the public interest, scientific or historical research or statistics would, in accordance with Article 89(1), be considered compatible with the initial purposes, independent of the conditions of Article 6(4). For research, controllers need not inform data subjects where that is impossible, would involve disproportionate effort, or would render impossible or seriously impair the research. They must then take appropriate measures, including making the information publicly available. The EDPB and EDPS welcome these parts and suggest improvements. As of 15 September 2026 the proposal is still under negotiation; neither Parliament nor the Council has adopted a position.

What this means in practice

If adopted, reuse of data for research would no longer require a separate compatibility assessment, although the Article 89(1) safeguards would still apply. You could then replace individual information with appropriate measures such as public information. The broad definition would bring commercial research and development more readily within research under the GDPR. For now the current GDPR applies unchanged.

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.

Connections

What connects to this development

The counterpart in the other law

Case law8 of 16

Guidelines8 of 16

Enforcement and fines8 of 13

Legislation in motion6 of 17