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GDPR

EU-US DPF Latest Developments Tracker

by Streamlex 6 March 2025

A continuously updated tracker summarizing the latest developments, including positions of the data protection authorities and EU institutions, on the future of the EU-US Data Privacy Framework (DPF) and any related regulatory challenges. Includes key takeaways for companies and direct links to official statements.


Backround

The EU-US Data Privacy Framework (EU-US DPF), adopted by the European Commission in July 2023, was long awaited by many EU businesses. It allows the EU companies to transfer personal data to US companies certified under EU-US DPF without requiring additional safeguards.  

Issue

However, the EU-US DPF is coming under increased scrutiny primarily due to the political developments in the US (read more about the reasons for concern here and here), raising challenges about its long-term stability. Recent statements from the Nordic DPAs signal uncertainty over the longevity of the adequacy decision. If the decision is overturned, companies relying on it for data transfers may need to find alternative mechanisms.

EU-US DPF Latest Developments Tracker

Jurisdiction

Date

Institution

Development

TL;DR

Analysis

EU

1 April 2025 (coming up)

Court of Justice of the EU (CJEU)

CJEU hearing in the case T-553/23 Latombe v Commission

Mr Latombe seeks annulment of the EU-US DPF alleging infringements of the Charter and GDPR. Mr Latombe's application for an interim relief was dismissed by the Court in 2023.

Sweden

5 March 2025

Swedish DPA

Transfer of personal data to the USA, what applies?

The US adequacy decision is still in effect. However, it may be revoked or annulled by the Commission or CJEU if data protection is deemed inadequate. Companies must stay informed about US adequacy decision updates and be prepared to find alternative data transfer mechanisms if it is revoked.

Norway

26 February 2026

Norwegian DPA

Information about transfers to the United States

The EU-US DPF is still in effect, but the companies should prepare an exit strategy in case the adequacy decision is revoked, as there may be no transition period.

Norwegian DPA Signals Uncertainty Over EU-US Data Transfers

EU

5 February 2026

Member of the European Parliament Raquel García Hermida-Van Der Walle (Renew)

Parliamentary inquiry on the consequences of the Trump administration for data protection and privacy

MEP questioned the European Commission on U.S. data privacy policies, specifically PCLOB’s independence. She asked if the Commission would consider suspending the EU-US DPF until the board is fully independent.

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