Position Paper
11 August 2026

EUROBAT feedback on the draft Implementing Act on Article 77(9) of Regulation (EU) 2023/1542

EUROBAT supports the objective of the Commission’s draft implementing act under Article 77(9) of Regulation (EU) 2023/1542, but the access framework must remain proportionate, purpose-limited and protective of commercially sensitive information. Access should be based on a clear and verified need, without turning restricted data into de facto public information, and any access by public authorities should be limited to what is necessary for enforcement and subject to strict confidentiality safeguards.

View the full feedback here.