Why the EU wants to unlock data sharing
Data is one of the most valuable assets a business holds, yet much of it sits unused because organisations do not trust how it will be handled once shared. The EU Data Governance Act (DGA), Regulation (EU) 2022/868, aims to change that. Applicable since 24 September 2023, it creates trusted channels for sharing data – between businesses, with the public sector, and for the common good – while keeping control firmly with the people and organisations the data belongs to. It is a cornerstone of the EU’s wider data strategy, sitting alongside the Data Act and the GDPR.
Trusted data intermediation services
The DGA introduces a regulated category of data intermediation services – neutral middlemen that connect those who hold data with those who want to use it. To keep them trustworthy, the Regulation requires strict neutrality: an intermediary may not use the data it brokers for its own purposes, and its intermediation activity must be structurally separate from any other services it offers. Providers must notify the competent national authority, after which they can operate across the EU.
Data altruism for the public good
The Act also builds a framework for data altruism – the voluntary sharing of data for objectives of general interest such as scientific research, public health or tackling climate change, without seeking a profit. Organisations can register as recognised data-altruism organisations and must then meet transparency and safeguarding requirements, giving individuals and companies confidence that their data will be used only for the stated public-interest purpose.
Re-use of public-sector data
A further pillar makes it easier to re-use certain protected data held by public bodies – for example data covered by confidentiality or third-party rights – under conditions that preserve that protection. This opens up valuable public datasets for innovation while respecting privacy and commercial confidentiality.
Practical example
A Swedish health-tech company wants to combine datasets from several hospitals to train a diagnostic tool. Rather than negotiating bespoke, inconsistent arrangements with each provider, it can work through a notified data intermediation service, or rely on a registered data-altruism organisation to gather consented data for research. The DGA gives all parties a clear, trusted structure – and the company a defensible basis for how the data was obtained.
Common mistakes companies make
The most common misunderstanding is treating the DGA as a replacement for the GDPR – it is not. Where personal data is involved, the GDPR still applies in full, and the DGA sits on top of it. Another mistake is assuming that acting as a data broker is unregulated; if your business connects data holders with users, you may fall within the data-intermediation regime and its neutrality and notification duties. A third is overlooking that the rules on data altruism only give you the recognised status – and its trust benefits – if you actually register.
Recommended actions
Assess whether any part of your business connects data holders and data users in a way that qualifies as data intermediation, and if so, prepare to notify the competent authority. If you handle data for research or other public-interest goals, consider the data-altruism framework. Where you rely on public-sector data, check the re-use conditions. And in every case, run your DGA analysis alongside – never instead of – your GDPR obligations.
Frequently asked questions
Is the DGA already in force?
Yes. The Data Governance Act has applied since 24 September 2023 across the EU.
Does the DGA replace the GDPR?
No. Where personal data is shared, the GDPR continues to apply fully; the DGA adds a governance layer for trusted sharing.
Do we need to register to share data for research?
You can share data without registering, but only registered data-altruism organisations may use the recognised status and the trust it conveys.
Conclusion
The Data Governance Act turns data sharing from an ad-hoc, high-risk exercise into a structured, trusted process – provided businesses understand where they fit within it. Whether you broker data, share it for the public good or re-use public datasets, the DGA sets the ground rules, always alongside the GDPR. Lawgent helps companies navigate the EU data framework and build compliant data-sharing arrangements. Contact us to put your data strategy on a sound legal footing.
