It goes without saying that there will be many big hurdles when negotiating an extensive legal act such as this one. We will look into those in a later update.

As for the question of when the Regulation will be adopted, it is now certain that it will be just before New Year at the earliest. The Regulation is not on the agenda of the Council meeting of the European ministers of justice and home affairs that will take place next week. However, this does not mean that the negotiations will not be concluded before 2016. It will be possible to put the matter on the agenda of another Council meeting later on in December.

However, we doubt that it will be possible as many central issues are still outstanding. But a so-called big bang culmination of difficult negotiations where all outstanding issues are dealt with together is not uncommon in the EU. The answer to whether such solution is desirable by the businesses and authorities that have to live with the effects of the bang is easy; no, definitely not.

Regardless of the outcome of the negotiations, the Data Protection Day 2016 on 28 January 2016 hosted by Plesner, the Confederation of Danish Industry and the Danish Council for Digital Security will be dedicated to the Regulation and its consequences.

Click here to read the programme and to register for the event.