Data Governance

Service Overview

Are you a non-EU data intermediation service provider or recognised data altruism organisation offering services in the European Union?

The EU Data Governance Act (DGA) — Regulation (EU) 2022/1724, applicable since 24 September 2023 — establishes a representative framework for two distinct types of organisation that operate trust-based data infrastructure in the Union: data intermediation service providers (DISPs), which create the technical and legal conditions for data sharing between data holders and data users; and recognised data altruism organisations (RDAOs), not-for-profit entities that collect data made available by individuals or organisations for objectives of general interest. Both categories, when established outside the EU, are required to designate an EU-established legal representative — DISPs under Article 11(3) DGA, RDAOs under Article 19(3) DGA.

The Digital Omnibus for Data — proposed Commission Regulation COM(2025) 837 — will integrate the DGA's representative requirements into the broader Data Act framework once enacted, anticipated 2027 or 2028. The DGA remains in force in the interim, and the master representative services agreement is structured so that mandates flow through to the superseding instrument without requiring a contract amendment.