Summary statistics
Overlaps: 4 · Conflicts: 2 · Gaps: 2
8 article-level crossrefs catalogued between Data Governance Act and GDPR 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 |
|---|---|---|---|---|
| Data Governance Act Art 7 | GDPR Art 5, Art 24 | overlap | medium | [entity affected: Public sector bodies / Competent bodies] Both regulations require the implementation of technical and organizational measures to ensure data security, privacy, and integrity during p |
| Data Governance Act Art 9 | GDPR Art 12 | overlap | low | [entity affected: Competent public sector bodies / Controllers] Both regulations mandate specific timeframes for responding to requests (data re-use or subject rights) and require notification if the |
| Data Governance Act Art 7 | GDPR Art 7, Art 8 | overlap | medium | [entity affected: Competent bodies / Controllers] Both regulations involve mechanisms for obtaining and verifying consent or permission from data subjects, with GDPR providing the detailed legal stand |
| Data Governance Act Art 13 | GDPR Art 51, Art 62 | overlap | low | [entity affected: Data protection authorities / Competent authorities] Both regulations require cooperation and information exchange between relevant supervisory authorities (including data protection |
| Data Governance Act Art 6 | GDPR Art 12 | conflict | high | [entity affected: Public sector bodies / Controllers] DGA allows fees for data re-use limited to costs, while GDPR generally requires the exercise of data subject rights to be free of charge, creating |
| Data Governance Act Art 4 | GDPR Art 5, Art 6 | conflict | high | [entity affected: Public sector bodies] DGA promotes broad data re-use and limits exclusivity, which may conflict with GDPR's strict purpose limitation and lawfulness requirements if re-use purposes a |
| Data Governance Act Art ? | GDPR Art ? | gap | medium | [entity affected: Data intermediation services providers] Neither regulation explicitly defines the liability of data intermediaries for data quality or accuracy errors in the data they facilitate, le |
| Data Governance Act Art ? | GDPR Art ? | gap | medium | [entity affected: Data altruism organisations] While DGA regulates registration and GDPR regulates processing, there is no clear guidance on how data altruism organizations should handle cross-border |
Conflicts explained
The 2 article-level conflicts between Data Governance Act and GDPR mean a control that satisfies one can pull the wrong way on the other:
- Data Governance Act Art 6 vs GDPR Art 12 — [entity affected: Public sector bodies / Controllers] DGA allows fees for data re-use limited to costs, while GDPR generally requires the exercise of data subject rights to be free of charge, creating potential conflict if re-use involves personal data subject rights.
- Data Governance Act Art 4 vs GDPR Art 5, Art 6 — [entity affected: Public sector bodies] DGA promotes broad data re-use and limits exclusivity, which may conflict with GDPR's strict purpose limitation and lawfulness requirements if re-use purposes are incompatible with original collection purposes.
Which regulation takes precedence
EU law does not lay down a universal precedence rule between Data Governance Act and GDPR. 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 4 overlaps as design opportunities — one control, two regulatory anchors. Treat the 2 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 dsa comparison
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