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 -deadline for the consistency procedure

Article(s) involved (national, EU, or other): Article 65 + Rules of Procedure EDPB


There is currently no deadline to start an Article 65 procedure once the file has been sent to the EDPB.

Ideal Solution

The procedural regulation should override the EDPB Rules of Procedure and state a clear deadline for the EDPB to start the consistency procedure under article 65

Proposed Solution

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

Reference to specific noyb cases:

See example of Google complaint from Issue 28.

National Issues

National Issues