Homo Digitalis publishes its Study on the proposed Digital Omnibus Regulations
On 19 November, the European Commission published two (2) proposed Digital Omnibus Regulations.
The first (Digital Omnibus Regulation Proposal) proposes significant amendments to provisions of well-known legislative instruments that are already in force, such as the General Data Protection Regulation (GDPR – Regulation 2016/679), the Data Protection Regulation for the EU institutions, bodies, offices and agencies (EUDPR – Regulation 2018/1725), the ePrivacy Directive (Directive 2002/58/EC), the Data Act (Regulation 2023/2854), the Single Digital Gateway Regulation (Regulation 2018/1724), the NIS2 Directive (Directive 2022/2555) and the Critical Entities Resilience Directive (Directive 2022/2557).
It also proposes the repeal of other legislative instruments that are currently in force, namely the Regulation on the free flow of non-personal data (Regulation 2018/1807), the Data Governance Act (Regulation 2022/868), the Regulation on platform-to-business relations (P2B – Regulation 2019/1150) and the Open Data Directive (Directive 2019/1024).
The second (Digital Omnibus on AI Regulation Proposal) proposes significant amendments to legislation that is currently partially in force, in particular the Artificial Intelligence Act (AI Act – Regulation 2024/1689), while also introducing additions to legislation that is fully in force, specifically the Regulation establishing common rules in the field of civil aviation (Regulation 2018/1139).
Homo Digitalis, together with the European network of which it is a member, European Digital Rights (EDRi), as well as other civil society organisations, academics and experts, sought throughout 2025 to maintain a substantive and well-documented presence in the relevant legislative preparatory process. In this context, we submitted a series of open letters to the competent bodies of the European Commission in May, September and November, while at the same time setting out our positions and arguments in detail through active participation in the public consultation process in October 2025.
We had already warned that the Digital Omnibus package forms part of a broader wave of deregulation that threatens to weaken critical European rules, portraying fundamental rights as an alleged obstacle to innovation and, in practice, serving the interests of large technology companies. From the outset, we had no confidence that the European Commission would be able to genuinely absorb and process our positions within the framework of the public consultation, because the consultation closed in mid-October and the publication of the final text with the proposed provisions was expected just one month later. It would have been essentially impossible to analyse and incorporate arguments and proposals into the text within such a short timeframe.
By November 2025, it had become clear that the European Commission was never interested in substantive dialogue and exchange of views regarding this legislative initiative. At that point, a leak of certain drafts of the proposed provisions revealed that the Commission had already shaped a draft regulation containing highly problematic provisions, representing the greatest rollback in the protection of human rights in the digital sphere. We then highlighted, through a joint press release, the significant challenges arising from the proposed changes to the GDPR and the ePrivacy Directive. A few days later, the official text was published, concealing new surprises and even greater challenges for our rights and freedoms in the digital environment.
Today, we publish our in-depth study on the package of proposed Digital Omnibus reforms, explaining the challenges that arise for our rights and freedoms.
The text of our study is available here (EL).
The Digital Omnibus reform package is not a technical exercise in codification, but a decisive shift of the European digital acquis towards a regime of reduced safeguards and diminished accountability. If adopted as is, the Union risks losing the strongest tool it possessed internationally: the example that technological progress can coexist with high standards of fundamental rights protection.
This weakening will not be felt through dramatic ruptures, but through a slow and persistent erosion, whereby rights we considered non-negotiable will be transformed into exceptions, and oversight will become a shadow of its former self. The choice facing EU legislators does not concern the “simplification” of legislation, but the very future of the European model of human protection: whether it will remain a pillar of the rule of law or allow itself to be replaced by a logic in which innovation is imposed without counterbalances and privacy becomes negotiable.
The Founding Conference of the Greek Artificial Intelligence Network – GAIN Successfully Concluded
The founding conference of the Cooperation Network for the Protection and Promotion of Human Rights in the Development and Use of Artificial Intelligence Systems in Greece was successfully completed! The provisional title of the network is Greek Artificial Intelligence Network – GAIN.
The network aspires to become a space for collaboration, knowledge exchange, and mutual support, fostering initiatives in awareness-raising, advocacy, and legal assistance — with the central goal of safeguarding Human Rights in the development and use of Artificial Intelligence systems.
The network’s activities aim to go beyond the minimum legal guarantees, drawing guidance from codes of ethics that emphasize morality, transparency, and accountability in the design, implementation, and evaluation of AI technologies.
The event took place on October 7, 2025, hosted at the offices of the Greek Forum of Migrants, where members and observers of the network had the opportunity to discuss, plan, and lay the foundations for an open, collaborative, and socially responsible AI community in Greece.
During the event, Open Lab Athens delivered an educational presentation on the technical characteristics and materialities of machine learning, significantly contributing to the discussion and collective understanding of the related technologies and their limitations.
The initiative is coordinated by the Homo Digitalis team, with the support of the European Artificial Intelligence & Society Fund (EAISF).
You can read the related Press Release (ΕL) here.
Organizations participating in the network’s processes as members or external observers include (in alphabetical order):
Ανοιχτό Εργαστήριο Αθήνα | Open Lab Athens
Διεπιστημονική Εταιρία Έρευνας στην Αιματολογία – ΔΕτΕΑ
Δίκτυο για τα Δικαιώματα του Παιδιού | Network for Children’s Rights
Ε.Κ.ΠΟΙ.ΖΩ.Ένωση Καταναλωτών «Η Ποιότητα της Ζωής» | Consumers’ Association “The Quality of Life” EKPIZO
Ελληνική Ένωση Δικαιωμάτων του Ανθρώπου | Hellenic League for Human Rights
ΕΛΛΗΝΙΚΟ ΣΥΜΒΟΥΛΙΟ ΓΙΑ ΤΟΥΣ ΠΡΟΣΦΥΓΕΣ | GREEK COUNCIL FOR REFUGEES
Ελληνικό Φόρουμ Μεταναστών | Greek Forum of Migrants
Εταιρεία Περιφερειακής Ανάπτυξης και Ψυχικής Υγείας – ΕΠΑΨΥ | Association for Regional Development and Mental Health – EPAPSY
Ένωση Πληροφορικών Ελλάδος
Ινστιτούτο Έρευνας Ρυθμιστικών Πολιτικών – ΙΝΕΡΠ | Institute for Regulatory Policy Research – INERP
Κέντρο ΔΙΟΤΙΜΑ
ΚΥΤΤΑΡΟ ΕΝΑΛΛΑΚΤΙΚΩΝ ΑΝΑΖΗΤΗΣΕΩΝ ΝΕΩΝ – ΚΕΑΝ | CELL OF ALTERNATIVE YOUTH ACTIVITIES
Με Άλλα Μάτια | Me Alla Matia
Οργανισμός Ανοιχτών Τεχνολογιών – ΕΕΛΛΑΚ | Open Technologies Alliance (GFOSS)
ΠΑΡΑΤΗΡΗΤΗΡΙΟ ΑΣΤΥΝΟΜΕΥΣΗΣ copwatch.gr
AMKE REVMA – ROMA EDUCATIONAL VOCATIONAL MAINTAINABLE ASSISTANCE
Athens Network of Collaborating Experts -ANCE
DATAWO
ERGO.Academy
HIAS Greece
Homo Digitalis
I Have Rights
In contACT
inside story.
KnowledgeRights21 (National coordinator for Greece and Cyprus)
OmniaTV (iCase Κοιν.Σ.Επ.)
Reporters United
SolidarityNow
Solomon
VISIBLE MACHINES
Vouliwatch
WHEN Equity Empowerment Change
WWF Greece
Homo Digitalis speaks at the 1st Seminar of the GNCHR Educational Seminar Series on “Artificial Intelligence: Levels of Protection”
With great success and active public participation, on Monday, September 29, 2025, the opening event of the Educational Seminar Series of the Greek National Commission for Human Rights (GNCHR) took place in the event hall of the Athens Bar Association (DSA), under the theme:
“The Next Day of Rights: Artificial Intelligence – Sustainability – Securitization.”
Homo Digitalis had the great honor of contributing with a presentation in the first seminar of the series, titled “Artificial Intelligence: Levels of Protection.”
Opening remarks were delivered by Marinetta Gounari–Chatzisarantou, Vice President of the Athens Bar Association, while the event was moderated by Giannis Ioannidis, First Vice President of the GNCHR.
Speakers at the seminar included, in order:
Sofia Kastranta, Senior Legal Advisor, Special Legal Service of the Ministry of Foreign Affairs
Dr. Efrosini Siougle, Expert Scientist in Informatics, Head of the Advisory and Compliance Mechanisms Department of the Hellenic Data Protection Authority
Eleftherios Chelioudakis, LL.M, M.Sc, Lawyer and Executive Director of Homo Digitalis
Dr. Christos Tsevas, Expert Scientist of the GNCHR
We warmly thank the Greek National Commission for Human Rights for the kind invitation to participate!
You can watch the full event here.
The second seminar will take place at the Athens Bar Association on Monday, October 13, from 17:00 to 19:00, on the topic: “Artificial Intelligence: Rights.”
Find more information here.
We submit an Open Letter to the Prime Minister, calling on the Hellenic Republic to reject the Danish Presidency’s text on the CSA.
Homo Digitalis today submitted an Open Letter to the Prime Minister of the Hellenic Republic, Kyriakos Mitsotakis, regarding the proposed Regulation on Child Sexual Abuse Material (CSA Regulation).
In our letter — which we have also shared with the Minister of Justice and the Minister for Citizen Protection — we call on the Hellenic Republic to reject the Danish Presidency’s text in the upcoming vote at the EU Justice and Home Affairs Council on October 14, 2025.
The objective of the Regulation — to curb the distribution of child sexual abuse material — is right and necessary. However, the text proposed by the Danish Presidency would achieve the opposite effect, undermining security and trust in the digital space.
Specifically, 787 leading experts in communication security and encryption — including professors from top academic institutions in Greece — have emphasized that:
The technology for detecting child sexual abuse material is inaccurate and ineffective.
Mandatory scanning undermines end-to-end encryption and opens the door to mass surveillance.
The proposed technical measures can be easily bypassed by malicious users and threaten anonymity and freedom of information.
Real child protection comes through education and support for victims, not through mass monitoring.
On October 14, Greece’s position must be guided by knowledge, technical expertise, and the fundamental principles and values upheld by the EU Charter of Fundamental Rights and the Constitution of Greece.
You can read the full text of our open letter here.
You can also read a related article recently published on our website by our member Stergios Konstantinou here.
Learn more about Homo Digitalis’s work on this issue, including past meetings between our members — Haris Kyritsis, Haris Daftsios, Niki Georgakopoulou, Giorgos Sarris, and Angelina Barla — and Greek Members of the European Parliament, in cooperation with European Digital Rights (EDRi), here.
Homo Digitalis Participates in the European Commission’s Meeting on the Protection of Minors Online under the DSA Framework
The Directorate-General for Communications Networks, Content and Technology (DG CONNECT) of the European Commission visited the offices of the Representation of the European Commission in Athens, holding a series of discussions within the framework of the Digital Services Act (DSA) with various stakeholders and interested parties.
On Tuesday, September 30, a meeting was held on the topic of “Protection of Minors,” aiming to exchange views while taking into account the Commission’s recent Guidelines on Article 28 of the DSA and the need to strengthen the protection of minors online.
Homo Digitalis had the honor to participate in the discussion alongside representatives from independent authorities (EETT, Hellenic Data Protection Authority, National Council for Radio and Television), as well as representatives from the Ministry of Digital Governance, the academic community, and other organizations.
We warmly thank Ilektra Makraki, representative of the European Commission Representation in Greece for the DSA, for the invitation and inclusion. Homo Digitalis was represented at the meeting by its Co-founder and Executive Director, Eleftherios Chelioudakis.
The 10th Open Call for Funding of NGI TALER is here!
A short intro about NGI TALER
The NGI TALER project is funded as a pilot under the NGI initiative within the European Commission’s Horizon Europe research funding program. It is operated by a consortium of 11 partners from 8 European countries (Belgium, France, Germany, Greece, Hungary, Luxembourg, Switzerland and The Netherlands) with the mandate to roll out an innovative, best-in-class electronic payment system that benefits everyone: end-consumers, merchants, banks, financial authorities, auditors and anti-corruption researchers! The project builds upon the strong foundations of GNU Taler — the privacy-preserving digital payment system developed by the GNU community and Taler Systems SA with support from the NGI initiative. Read more on NGI TALER’s website, here.
What is this funding call about?
Part of the budget of NGI TALER is reserved for open calls to fund additional free software efforts that are aligned with the topics and approach of NGI TALER. We invite your contributions to help reshape the state of play of digital payment systems, and to help create an open, trustworthy and reliable internet for all! You can contribute exciting new capabilities to GNU Taler itself, build auxiliary tools or work on user experience, but you could also be developing integrations into FOSS applications and open standards, or work on improvements to infrastructure components like merchant back-ends. See more info about the wide range of activities that qualify for financial support and the eligibility criteria here.
How to apply?
The open call is open since 01/10/2025 and the deadline to submit your application is December 1st, 2025, 12:00 CET! You can apply only with proposals between 5.000 and 50.000 euro (60.000 euro is the cumulative absolute hard limit for any applicant for the program). To apply you need to fill in a specific form! From our end we will provide a transparent and efficient selection process. More info in the links below:
We submitted our views to the European Commission’s public consultation on the assessment of the impact of the Digital Markets Act (DMA)
On September 23, Homo Digitalis submitted its views to the European Commission’s Public Consultation as part of the report it is preparing on the assessment of the impact of Regulation (EU) 2022/1925 on Digital Markets (Digital Markets Act – DMA).
The real impact of the DMA depends on the Commission’s determination to enforce it, honoring both the letter and the spirit of the regulation — namely, to create open and competitive digital markets, strengthen competition, and protect users’ rights.
You can read our full submission here.
For more information about the public consultation, click here.
We spoke to NEWS247 about the data breach incident involving the Italian company doValue.
Homo Digitalis gave statements to journalist Eftychia Soufleri and NEWS247.gr regarding the hacking of the Italian company doValue, one of the largest loan management companies in Europe.
16 terabytes of personal data — that’s how much hackers claim to have stolen from the company’s systems, even posting an ad on the dark web to sell them. Our Co-founder and Executive Director, Eleftherios Chelioudakis, represented us by giving statements on the matter.
Find out more about here the sensitive personal data collected by debt collection companies, how much such data is worth on the dark web, and what the obligations of the doValue Group and its subsidiaries, including the Greek subsidiary doValue Greece, are — in case the hack also affected their systems, if the hackers’ claims prove true.
We would like to thank the journalist for including our statements in her article.
We submitted a FOIA before the Greek Ministry of Education for its Memorandum of Cooperation with OpenAI
At Homo Digitalis, we support the innovations brought by new technologies and believe that they can significantly contribute to the improvement of our society, provided that their use complies with the applicable legal framework and aims to promote and protect our rights and freedoms. We envision a better world, where the adoption of technological solutions is the result of critical thinking as well as informed and balanced decision-making.
In this light, we were concerned by the signing, on Friday, September 5, of the “OpenAI for Greece” Memorandum of Cooperation by the Ministry of Education, Religious Affairs and Sports with OpenAI and other stakeholders, for the pilot use of the ChatGPT Edu tool by teachers and students in 20 high schools across the country.
How will teachers and students feel when asked to use tools provided by a company such as OpenAI, which has already been fined €15 million for violations of data protection legislation in Italy and is currently under investigation for possible violations in other countries, such as Austria?
And on what grounds are Artificial Intelligence systems based on proprietary software from US tech giants being prioritized over equivalent tools that could be developed with free and open-source software by research centers and institutions in Greece? Such a choice disregards the European Union’s strategy to strengthen openness, transparency, and technological sovereignty, and, in the case of widespread adoption, will inevitably lead to the dependency of our education system on proprietary software and foreign companies.
In light of the above, today we submitted (protocol number 108260/8/92025) before the Ministry of Education, Religious Affairs and Sports a request for access to documents and information, in which we set out our concerns in detail and request access both to the Memorandum of Cooperation and to other related legal deliverables that should have been drawn up regarding the obligations arising from Law 4624/2019 and Law 4961/2022.
You can see our request here (EL).