July 13, 2026

A Single Standard for Anonymisation: Article 6(11) DMA, the GDPR, and the Expectations of Europeans

As the EU’s digital rulebook matures, a recurring challenge is ensuring that its instruments are read as a coherent whole. Where the same concept appears in more than one regulation, it should, so far as the law allows, carry the same meaning.

Anonymisation under the Digital Markets Act is a timely case in point. Article 6(11) DMA requires that search data made available to competing providers be anonymised where it constitutes personal data. What “anonymised” requires in practice is currently being considered in parallel across several workstreams — the implementation of the DMA, the evolving GDPR standard following the Court of Justice’s judgment in SRB and the EDPB’s new draft guidance, and the Digital Omnibus. The Commission, the EDPB, national data protection authorities and the co-legislators each hold part of the same concept.

In this paper, CIPL sets out why that concept is best given a single, GDPR-consistent meaning applied consistently across the digital acquis.

CIPL supports the objective of Article 6(11) — greater contestability in the search market — and the data sharing it mandates. The question the paper takes up is not whether search data should be shared, but the standard on which it is anonymised before it is. A bespoke, DMA-specific reading of “anonymised” — one calibrated to the internal market and another to fundamental rights — would fragment a core concept, introduce legal uncertainty, and sit uneasily with the EU’s own objective of simplifying the digital acquis.

Throughout, CIPL keeps the end user in view. The paper draws on a six-market survey of 3,000+ Europeans with the European Public Policy Partnership: 66% expect their searches to stay confidential, 71% are unaware of the sharing obligation, and half think anonymised data could be re-identified. As these questions are resolved, there is real value in bringing users on the journey.