The rapid expansion of EU digital regulation has strengthened security, privacy, and trust, but it has also created overlapping obligations, inconsistent timelines, and administrative complexity. The Digital Omnibus Package provides a timely opportunity to streamline these rules, ensure greater coherence, and enable businesses to focus resources on resilience and innovation rather than redundant compliance tasks.
The Charter of Trust welcomes the Commission’s initiative to harmonize digital regulations across the EU, aiming to reduce administrative burdens while maintaining high standards of security and privacy. Representing the unified views of its Partners, this paper addresses all key legislation within the scope of the Digital Omnibus and offers comprehensive recommendations. It emphasizes the need for a unified incident reporting system, risk-based notification requirements, and fair compliance processes to minimize regulatory overlap. The Charter calls for clearer liability clauses, global recognition of certifications, and stronger supply chain security.
In data regulation, the Charter advocates ensuring alignment between the rules on data intermediation services under the DGA and B2B data sharing under the Data Act and extending exemptions to mid-cap companies, all while safeguarding trade secrets. For artificial intelligence, the paper recommends a phased approach to new requirements, integrated conformity assessments, harmonized compliance templates, and clear definitions, supported by sector-specific guidance and transparent AI categorization. The Charter also encourages the European Commission to ensure that ePrivacy reform is future-proof, fosters innovation, and reflects the needs of both businesses and consumers. Finally, it recommends robust security standards and cross-border recognition for the EU Business Wallet, with industry involvement in technical standards and integration with data access systems.
Collectively, these measures are designed to foster innovation, resilience, and trust in the EU’s digital landscape, allowing businesses to thrive in a coherent and future-ready regulatory environment.

We are thrilled to announce that we welcome Zscaler as the newest Partner to the Charter of Trust!

Zscaler is a leading cloud enterprise security provider helping global businesses accelerate their digital transformation by becoming more agile, efficient, resilient, and secure.

With Zscaler as a partner in the Charter of Trust, we aim to strengthen global cyber resilience through trust – by fostering actionable collaboration between industry leaders, governments, and public-private platforms. Zscaler brings robust expertise and innovation to the table, making it the ideal partner to drive this mission forward.

“Zscaler is excited to drive meaningful change alongside our new partners, laying a foundation of trust essential for successful digital transformation,” said Sam Curry, Zscaler CISO. “In today’s world, the need for reducing inherent trust and default access has never been greater. To truly stay ahead of ever-evolving threats, we must unite as a coalition of practitioners. Cyber attackers aren’t taking breaks, and with advancements like artificial intelligence, quantum cryptography, and emerging technologies on the horizon, collaboration is the key to securing the future.”

“We are proud to welcome Zscaler to the Charter of Trust. Their focus on cybersecurity innovation and commitment to openness reflect our shared ambition to create a safer, more resilient digital future. Together, we’ll strengthen trust, transparency, and security across the global digital landscape.” highlighted Dr. Summit Chada, Charter of Trust Co-Chair and COO Group Security & Business Lines CISO at Atos.

“With Zscaler as a Partner of the Charter of Trust, we believe that we can strengthen the global commitment to secure digital transformation by combining technological innovation with the Charter of Trust’s collaborative approach to cybersecurity leadership.” Ralf Schneider, Charter of Trust Co-Chair and Senior Fellow and Head of Cybersecurity and NextGenIT Think Tank at Allianz SE, welcomes Zscaler to the Charter of Trust.

We are excited to join forces and work together to advance digital trust and security across industries.

The Charter of Trust welcomes the opportunity to participate in the European Commission’s public consultation on the revision of the Cybersecurity Act. As a coalition united by the goal of strengthening digital trust, we are pleased to share our consolidated response and recommendations.

We support Policy Option 2, which focuses on targeted regulatory measures that address key challenges without creating unnecessary complexity. In this context, we emphasize the need to enhance the role and resources of ENISA, to ensure effective implementation of both current legislation and the European Cybersecurity Certification Framework (ECCF).

Our recommendations aim to improve transparency, collaboration, and efficiency across the EU’s cybersecurity landscape. These include:

- Introducing clear timelines for the development of certification schemes.

- Enhancing stakeholder engagement throughout the process.

- Establishing more structured communication channels between ENISA, the Stakeholder Cybersecurity Certification Group (SCCG), and sectoral ISACs (Information Sharing and Analysis Centers).

We call for a stronger ECCF, one that is transparent, inclusive, and aligned with international standards to foster global interoperability and ease compliance for organizations across borders. Equally critical is the harmonization of certification practices across EU member states and the mutual recognition of certifications to minimize regulatory fragmentation.

The Charter of Trust advocates for technically robust, standards-based certification schemes, with well-defined roles and responsibilities. We also stress the need for clarity on the interplay between voluntary and mandatory certifications, particularly in relation to the upcoming Cyber Resilience Act (CRA).

To streamline compliance and reduce administrative burden, we propose a unified, risk-based incident reporting regime that consolidates requirements under regulations such as NIS2, CRA, GDPR, and DORA. This would not only simplify reporting for organizations but also enhance the EU’s overall cyber resilience. In addition, we recommend incorporating liability protections and grace periods for incident disclosure.

Finally, we urge the Commission to strengthen supply chain security by adopting a risk-based classification approach and establishing baseline cybersecurity requirements for ICT suppliers.

The Charter of Trust remains fully committed to supporting the European Commission in shaping a secure, resilient, and trusted digital future for Europe. We look forward to continued collaboration in building a cybersecurity framework that meets the needs of all stakeholders, today and in the years to come.