Consolidated GDPR Text Published And Adoption Expected By 14 April

On 6 April 2016, following a review by legal/linguistic experts, the consolidated version of the GDPR text has been published in all official European languages. Further, Council adopted its position on the text on 8 April which paves the way for the EU Parliament to vote on the text next week.

The Revised Text

Compared to the version of the GDPR text issued on 17 December 2015, the updated text contains new numbering as well as linguistic changes. The GDPR now counts 173 Recitals and 99 Articles.


Changes to the text are of purely linguistic (rather than substantive) nature. For example, the term “individuals” has been replaced with “natural persons” and the text now consistently refers to “personal data”  rather than “data”.

Further, the drafting of some provisions (such as Art. 8 which requires parental consent in the case of provision of information society services directly to children) has been clarified – without changing their meaning though. 

You can access an unofficial comparison of the GDPR text issued on 17 December 2015 versus the text issued on 6 April 2016 here.

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Timeline for Expected Votes

Council adopted its position on the GDPR via written procedure on 8 April 2016. Originally, Council was scheduled to vote on the consolidated GDPR text on 21 April 2016 during the next Justice and Home Affairs Council. However, in order to expedite the process, on 4 April, Council issued a note advising that it would adopt its position on the consolidated text via written procedure which is an extraordinary procedure not involving a public deliberation.

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The EU Parliament is expected to vote on, and adopt, the text as early as 14 April 2016 during its next plenary session. Once adopted by the EU Parliament, the text will be published in the Official Journal of the EU which publication will set off the two-year transition period following which organzations will be required to comply with the GDPR. It looks like no time will be wasted before the GDPR will enter into force!

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