Summary statistics
Overlaps: 2 · Conflicts: 0 · Gaps: 2
4 article-level crossrefs catalogued between Data Governance Act and DSA from the Fontvera EU regulatory corpus. Article numbers are verbatim from the underlying obligation_crossrefs table; descriptions are extracted, not paraphrased.
All crossrefs between these regulations
| Article (A) | Article (B) | Type | Severity | Description |
|---|---|---|---|---|
| DSA Art 13 | Data Governance Act Art 11 | overlap | low | [entity affected: provider of intermediary services / data intermediation services provider] Both regulations require non-EU established service providers to designate a legal representative in the Un |
| DSA Art 11 | Data Governance Act Art 11 | overlap | low | [entity affected: provider of intermediary services / data intermediation services provider] Both regulations require service providers to designate a single point of contact or provide specific conta |
| DSA Art ? | Data Governance Act Art ? | gap | medium | [entity affected: data intermediation services provider] Data intermediaries facilitating access to public sector data may handle personal data, creating a compliance risk regarding GDPR alignment tha |
| DSA Art ? | Data Governance Act Art ? | gap | medium | [entity affected: online platforms] Online platforms using data altruism organizations for content moderation or training AI models face unclear liability boundaries between DSA content responsibility |
Overlaps explained
No conflict-type crossrefs were catalogued for this pair, but the 2 overlaps below mean a single control can be designed to satisfy both regulations at once. Plan the controls jointly to avoid duplicate effort:
- DSA Art 13 vs Data Governance Act Art 11 (low severity) — [entity affected: provider of intermediary services / data intermediation services provider] Both regulations require non-EU established service providers to designate a legal representative in the Union to act as a point of contact for authorities and compliance matters.
- DSA Art 11 vs Data Governance Act Art 11 (low severity) — [entity affected: provider of intermediary services / data intermediation services provider] Both regulations require service providers to designate a single point of contact or provide specific contact details to facilitate communication with authorities and users.
Which regulation takes precedence
EU law does not lay down a universal precedence rule between Data Governance Act and DSA. In practice three resolution approaches apply: lex specialis (the more specific provision wins when both purport to govern the same conduct); regulator guidance (EDPB, EBA, ESMA and the AI Office have all issued joint readings on overlapping articles — check the most recent applicable opinion); and document the choice (when the regulations leave the call to the controller, the audit defence is your written reasoning, not the regulator's silence). Where the corpus surfaces a conflict rather than an overlap, treat that as an escalation path to legal — not a control-design question.
What this means for your compliance team
Treat the 2 overlaps as design opportunities — one control, two regulatory anchors. Treat the 0 conflicts as escalation paths to legal: the regulations themselves don't resolve them, you do, and you document the reasoning. The 2 gaps point at scenarios where one regulation is silent while the other speaks — assume the regulator who has the explicit rule will win.
Related Fontvera pages
- data governance act article 5 member state
- data governance act vs dma comparison
- data governance act vs dora comparison
- data governance act vs eprivacy comparison
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