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.

Added value of EDPB guidance documents (e.g. procedural guidelines) is unclear

Article(s) involved (national, EU, or other): Article 70(1) GDPR.


Many statements within procedural guidelines are formulated in weak terminology often vaguely prescribing the required action of SAs. This is a result of the lack of unanimity among EDPB members: the text is always a compromise. 

Ideal Solution

Many statements from the EDPB’s procedural and internal guidance documents will have to be clarified before allowing their adoption within a procedural regulation. SAs can increase the authoritative character of guidelines by referring to it in their final binding decisions and publishing guidance on its website (creating legitimate expectations).  

Proposed Solution

This is addressed by the Regulation overall.

Reference to specific noyb cases:

See the Meta case where the DCP wrote that it was bound by the EDPB guidelines.

National Issues

National Issues