December 4, 2025

CIPL Response to the European Commission and the European Data Protection Board Public Consultation on the Draft Joint Guidelines on the Interplay between the GDPR and the DMA

CIPL welcomes the opportunity to comment on the joint draft Guidelines of the European Commission and the European Data Protection Board (EDPB) on the Interplay between the Digital Markets Act (DMA) and the General Data Protection Regulation (GDPR).

CIPL appreciates the cooperative nature of these draft Guidelines and the collaboration of the European Commission and the EDPB in providing guidance on the areas of overlap and tension between the DMA and the GDPR. While the DMA applies “without prejudice to the rules resulting from other acts of Union law regulating certain aspects of the provision of services covered by this Regulation”, we support the EC and the EDPB in their objective to provide guidance for coherent and consistent interpretation on the interplay between both laws, where personal data is involved. This is crucial to ensure legal certainty for organisations and clear, harmonised protection for users’ rights across the EU digital landscape.

CIPL notes, however, that in several key areas, the draft Guidelines introduce interpretations that go beyond the DMA’s legal text, potentially undermine GDPR protections, or create practical implementation challenges, while guidance is missing in some areas.

Our response to this consultation offers several detailed observations and recommendations.