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.

Admissibility – Limitation period

Article(s) involved (national, EU, or other): Article 77


Some complaints are rejected because of a limitation period / statute of limitation. For example, a time limit for introducing the complaint is envisaged in AT and SK law.

Ideal Solution

The matter should be harmonised (e.g. one year as from the day the data subject became aware of the violation). 

Proposed Solution

Concept 2 would allow to ensure that the national law of the filing SA is relevant for any rules on the admissability of the law and other SAs may not review the admissability.

Reference to EDPB documents / table:

EDPB wishlist, page 7

National Issues

National Issues