The Data Governance Act and data intermediation, explained
The Data Governance Act is the quieter sibling of the Data Act, but it matters for anyone sourcing or sharing data in Europe. This guide explains what it does, the new role of data intermediaries, and what it means in practice.
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What the Data Governance Act is
The Data Governance Act (Regulation (EU) 2022/868) is part of the European data strategy. It sets rules to increase trust in data sharing: governing data intermediation services, enabling the re-use of certain protected public-sector data, and creating a framework for data altruism.
Data intermediation services
The Act introduces a regime for data intermediaries, neutral parties that facilitate sharing between data holders and users. Intermediaries must meet conditions designed to ensure they act in the interests of participants rather than exploiting the data themselves.
Public-sector data re-use
It creates mechanisms for re-using protected public-sector data (for example, data subject to confidentiality or third-party rights) under controlled conditions, complementing the Open Data Directive.
Data altruism
The Act establishes a framework for organisations that collect data for altruistic purposes, with a recognised status and safeguards.
How it relates to the Data Act
The Data Governance Act sets the trust and intermediation framework; the Data Act creates concrete access rights. Together they shape how data can be shared and re-used across the EU.
What it means for buyers
For organisations sourcing data, the Act expands trusted routes to data and clarifies the role of intermediaries. It reinforces the value of working with parties that provide transparent, well-governed access, with the documentation buyers need.
Data intermediaries in practice
The Act’s intermediary regime is designed to create trusted middlemen who connect data holders and users without exploiting the data themselves. Recognised intermediation services must meet neutrality conditions, they cannot use the data they broker for their own ends, must keep it separate, and must act in participants’ interests. For buyers, this matters because it formalises a trustworthy route to data that sits between fully open data and bilateral deals, and it reinforces the value of working with parties that provide transparent, well-governed access.
How it fits the wider framework
The Data Governance Act provides the trust and intermediation layer; the Data Act creates concrete access rights; the GDPR governs personal data throughout; and common data spaces apply these rules within sectors. Seen together, they are not overlapping burdens but a stack: governance, access, protection and sectoral implementation. Sourcing that is documented and standards-aligned travels well across all of them.
- The Data Governance Act (Regulation (EU) 2022/868) builds trust in data sharing.
- It governs data intermediaries, public-sector data re-use and data altruism.
- It complements, and does not replace, the Data Act and GDPR.
- It expands trusted, well-governed routes to data for buyers.
Sources & further reading
- EUR-Lex: Regulation (EU) 2022/868 (Data Governance Act).
- European Commission: Data Governance Act explained.
- EUR-Lex: Regulation (EU) 2023/2854 (Data Act).
- EUR-Lex: Directive (EU) 2019/1024 (Open Data Directive).
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