Saatja: Stina Avvo - JUSTDIGI </O=EXCHANGELABS/OU=EXCHANGE ADMINISTRATIVE GROUP (FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=CEB7B834D3614CB8B327DC919CC43C3B-9B248276-23>
Saaja:
[email protected]
Teema: RE: Request for Guidance on Notification Procedure for Data Intermediary Status under Regulation (EU) 2022/868
Dear Ms Daria Titova
We thank you for your inquiry!
At present, we are preparing the national implementing legislation for the Data Governance Act (DGA, Regulation (EU) 2022/868), <http://data.europa.eu/eli/reg/2022/868/oj> which will establish and designate the competent authorities at the national level, their necessary competences and the expected processes. In Estonia, notifications are preferably submitted through digital channels. The national legislation is planned to enter into force in the end of this year.
While drafting the legislation and following consultations, the Data Protection Inspectorate has been proposed as the competent authority for the supervision of data intermediation service providers. As the conferral of DGA related competences to the Data Protection Inspectorate requires a national implementing law, no interim steps can be foreseen at this stage.
In the summer, we will launch a consultation on the national implementing legislation, inviting feedback from stakeholders, including businesses. Corresponding consultation information will be available on our website: www.justdigi.ee <http://www.justdigi.ee> .
The DGA does not establish a mandatory form notification for businesses. The requirements for notification by data intermediation services providers can be found in DGA art 11. The article 11 paragraph 6 states the information that must be on the notification:
a. the name of the data intermediation services provider;
b. the data intermediation services provider’s legal status, form, ownership structure, relevant subsidiaries and, where the data intermediation services provider is registered in a trade or other similar public national register, registration number;
c. the address of the data intermediation services provider’s main establishment in the Union, if any, and, where applicable, of any secondary branch in another Member State or that of the legal representative;
d. a public website where complete and up-to-date information on the data intermediation services provider and the activities can be found, including as a minimum the information referred to in points (a), (b), (c) and (f);
e. the data intermediation services provider’s contact persons and contact details;
f. a description of the data intermediation service the data intermediation services provider intends to provide, and an indication of the categories listed in DGA article 10 under which such data intermediation service falls;
g. the estimated date for starting the activity, if different from the date of the notification.
Nevertheless, Member States will notify the Commission as and when data intermediation organisations are registered. Member States notify the Commission by electronic means. The suggested voluntary form for Member State level can be found on this website: https://digital-strategy.ec.europa.eu/en/library/notification-form-member-states-recognised-data-intermediation-services.
The helping materials and guidance published by the Commission can be found on the following websites:
* General information hub: https://digital-strategy.ec.europa.eu/en/policies/data-governance-act;
* Guidance document: https://digital-strategy.ec.europa.eu/en/library/new-practical-guide-data-governance-act.
We sincerely regret any inconvenience that may have arisen. Should you require any additional clarifications regarding the DGA or its national implementing legislation, we would be pleased to provide further assistance.
Yours sincerely,
Stina Avvo
Chief Legal Officer (IT law)
Ministry of Justice and Digital Affairs
+37258851218
From: Daria Titova <
[email protected]>
Sent: Tuesday, July 1, 2025 12:02 PM
To: info - MKM <
[email protected]>
Subject: [SUSPECTED SPAM] Request for Guidance on Notification Procedure for Data Intermediary Status under Regulation (EU) 2022/868
Tähelepanu! Tegemist on välisvõrgust saabunud kirjaga.
Tundmatu saatja korral palume linke ja faile mitte avada.
Dear Sir or Madam,
I am writing on behalf of MyGaru OÜ, a company legally registered in Estonia. We are currently preparing to operate as a provider of data intermediation services in accordance with Article 11(1) of Regulation (EU) 2022/868 (Data Governance Act).
We respectfully request your guidance on the following matters:
1. Which competent authority in Estonia is currently responsible for receiving notifications from entities seeking recognition as a data intermediary?
2. If the designation process in Estonia is not yet finalised, are there any interim steps or preparatory actions that companies should undertake in the meantime?
3. Are there any standard templates, forms, or procedural instructions published by the European Commission to support companies in submitting notifications under the DGA?
4. Once a competent authority is designated, what is the expected process for submitting the notification (e.g. electronic platform, postal delivery, direct communication)?
We are committed to full compliance with the DGA and look forward to your support in clarifying the applicable procedure for notification.
Thank you for your time and assistance.
Sincerely,
MyGaru OÜ