In the past years we have identified more than 60 procedural issues that we have experienced first-hand in daily operations. We have summarized them on the page below. Many of these issues are symptoms of an underlying procedural problem.

Effective procedure – OSS – no deadline to transfer a complaint to the LSA

Article(s) involved (national, EU, or other): Article 56(3) GDPR


The lack of deadline for an SA to transfer the complaint to the LSA is slowing down the procedure.

Ideal Solution

The text should provide for such a deadline. The decision whether or not to transfer a case to the LSA should be taken together with the decision on the admissibility of the complaint and the competence of the SA, i.e. within 3 months from the day of receipt of the complaint.

Proposed Solution

Concepts 9, 10, 14 and 16 should solve these issues.

Reference to specific noyb cases:

See AT case against Netflix where the SA did not send the procedure to the LSA for 2 years.

Reference to EDPB documents/table:



National Issues

National Issues