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Explainer

DGA data intermediation: notification and neutrality for data intermediaries

Adopted 2026-06-28 ยท ≈ 1 min read ยท Dirk Baaijen

Anyone acting as a data intermediary connecting data providers and users falls under the Data Governance Act's notification regime and must guarantee neutrality: not using the intermediated data for their own purposes, with structural separation from other services.

Short answer: If you act as an intermediary connecting data providers with data users โ€” a data marketplace, data-space platform or intermediation service โ€” you fall under the DGA's notification regime. You notify the competent authority and meet strict neutrality requirements.

What is a data intermediation service?

It concerns services that establish a commercial relationship for data sharing between an undetermined number of data providers and users โ€” including services that help individuals make their data available. It does not concern services that obtain data to make their own products; the intermediating, neutral role is decisive.

Notification and neutrality

Before offering the service, you submit a notification. Neutrality then applies: you may not use the intermediated data for your own purposes, you keep the data intermediation service structurally separate from your other services, and your fees and terms must not unfairly affect sharing. This creates trust that the intermediary does not compete with its users' data.

Why it matters

These neutral intermediaries are the engine under secure data spaces and chain data sharing: they let parties share data without losing control. If you build or consider such a role โ€” for example in a mobility data space โ€” assess early whether you fall under this regime.

Lees ook: Data Governance Act guide and European data spaces.

Sources

  1. https://eur-lex.europa.eu/eli/reg/2022/868/oj
    Regulation (EU) 2022/868 (DGA), Chapter III โ€” providers of data intermediation services: notification and conditions.
  2. https://digital-strategy.ec.europa.eu/en/policies/data-governance-act
    European Commission โ€” data intermediation services under the DGA.

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Dirk Baaijen

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Compiled and maintained by YRproject โ€” programme and project direction at the intersection of digital transformation, AI and regulation. Every factual claim is traceable to its primary source. YRproject is led by Dirk Baaijen About & method โ†’

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