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 for triggering Article 65 procedure

Article(s) involved (national, EU, or other): Article 60(4) + 65 GDPR


There is no deadline to trigger an Article 65 procedure if no consensus can be reached.

Ideal Solution

The text should provide such a deadline.

Proposed Solution

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

Reference to specific noyb cases:

See Irish cases against Meta where the DPC waited without reason before sending the case to the EDPB. See also CNIL case against Google where the CNIL and DPC waited before asking the EDPB to take a position on who is the competent authority, and then withdrew their application to the EDPB. The case is still pending and noyb is still waiting to be informed about who is the competent authority.

National Issues

National Issues