20 January 2026

In late November 2025, the European Commission released the Data Union Strategy (DUS), which focused, primarily, on “unlocking data for AI”. The strategy identifies three priority areas for action based on:

• Scaling up access to data for AI to ensure our businesses have access to high-quality data needed for innovation
• Streamlining data rules to give legal certainty to businesses and reduce compliance costs
• Safeguarding the EU’s data sovereignty to strengthen our global position on international data flows

DUS places artificial intelligence at the forefront of Europe’s data future. The “EU needs large volumes of high-quality data to compete and drive innovation,” it notes. Without large pools of high-quality data, the EU cannot build strong AI models. We strongly agree on the necessity of a large pool of trusted data in a common space, but the DUS lacks the adequate guidance to ensure incentivisation and compensation policies to facilitate the creation of these large pools of data.

Simplification of the regulatory landscape
As a whole, the DUS offers not only a focus on AI, but also a proposed omnibus/simplification of the data regulatory landscape into a single data framework. The essential features of the Data Act will remain unchanged, but business-to-government data sharing may be “limited to emergencies” – the exact nature of such an emergency is unclear. There is also a proposed “innovation-friendly privacy framework” which would still simplify information obligations and breach notifications to authorities.

Creation of data labs as data pooling services and connection to AI developers
The DUS will launch data labs to scale up data availability and create links between data spaces and AI ecosystems – using both private and public resources to data available to companies and researchers. The labs will use the data sharing mechanisms of the common European data spaces to link data spaces and AI developers. They will also serve as “specialised service facilities” for data pooling, curation, pseudonymisation, and anonymization, as well as regulatory guidance on applying the Data Act’s data access provisions and managing trade secret protection.

What is missing: data incentivisation/compensation
The DUS does not detail in any tangible way how to incentivise data sharing. The DUS notes that the Commission will “announce work” on a support package for the Data Act, including “guidance on compensation”. EUREC has previously advocated for auctions using non-price criteria as a simple and effective method of incorporating data-friendly initiatives, such as in our input to the public consultation on the Data Union Strategy. The DUS does not reference auctions or non-price criteria in any capacity as a means for governments to incentivize the sharing of RES plant operational data, but there is still a chance that the imminent AI and Digitalisation for Energy Roadmap will.