When GDPR came into force in 2018, it brought welcome clarity to a fragmented European privacy landscape. But it also dropped a regulatory boulder on the shoulders of SMEs. Uniform standards? Excellent. Uniform obligations? Not so much.
Six years later, that rigidity is beginning to crack, for the better. Lawmakers are quietly dialing back the bureaucracy, especially for small businesses. Not to lower the bar, but to aim it correctly. And that shift changes the game, if you’re paying attention.
The Compliance Register: Finally, Some Sanity
The first real signal came with a proposed amendments to Article 30(5) GDPR. Under the revised threshold, companies with fewer than 750 employees will no longer be required to maintain a full Record of Processing Activities (ROPA), unless they deal with high-risk data (think medical records, biometrics, or data on children), However, it's only the likelihood of a high risk under the DPIA rules that will trigger the exclusion.
This is not a deregulation move. It’s triage.
If your data operations are routine and low-risk, the law is finally acknowledging that you shouldn’t waste hours on templates nobody reads. But if you’re touching sensitive categories, even in small volumes, the rules haven’t budged an inch. You still need full documentation, technical measures, and internal accountability.
This isn’t about doing less. It’s about doing the right compliance, not all the compliance.
Denmark Is Quietly Leading the Way
While Brussels is famous for ambiguity, Copenhagen has taken a bolder route: clear guidance over creative guessing.
The Danish Data Protection Authority launched a simplified GDPR toolkit for SMEs, including ready-to-use templates, a DPIA wizard, and real-time support. The model is pragmatic, scalable, and refreshingly unpatronizing. And now it’s being looked at as a blueprint for a European SME GDPR Toolbox.
The goal isn’t to dilute protection. It’s to eliminate amateurism by giving businesses clear guardrails. Stop punishing companies for not being clairvoyant, and start helping them make legally sound, risk-adjusted decisions.
It’s about time.
This Was Never About You, But You Benefit Anyway
Let’s be honest: GDPR was never meant to protect you from regulation. It was meant to protect Europe from them, U.S. tech monopolies, surveillance capitalism, and unchecked data extraction. That’s why the framework is so heavy.
But for years, that weight was applied indiscriminately. A freelancer with a client list had to jump through the same hoops as a social media platform mining user behaviour at scale.
These new adjustments are a course correction, not a retreat. They preserve the spirit of GDPR, data dignity and European autonomy, while acknowledging that not every bakery needs a privacy officer.
If you’re in the low-risk category, consider this your window to get smarter, not lazier.
Don’t Mistake Relief for Immunity
Here’s the trap: many SMEs will see this reduced burden as a green light to relax across the board.
Don’t.
This is not a shift in liability, only in expectations. Regulators still hold you accountable for protecting personal data. Clients still want reassurance that you’re not flying blind. And once you scale, raise funds, enter partnerships, move cross-border, the light-touch regime disappears. Instantly.
You’ll be audited on governance, not goodwill.
So treat this moment not as a loophole, but as an architectural reset. Drop the vanity paperwork. Invest in the core: data mapping, access controls, breach protocols, and consent logic.
What Smart Companies Should Do Now
If you’re serious about turning these changes into strategic advantage, start here:
- Don’t self-diagnose. Just because you’re small doesn’t mean you’re exempt. Review whether your data qualifies as “high risk” under Articles 9 and 10. Pay attention to automated decision-making, profiling, or tracking.
- Use the new tools, but don’t game them. Adopt official templates, simplified DPIAs, and updated compliance registers. But remember: templates are only as good as the logic behind them.
- Think like a future partner. Even if regulators are easing off, your future clients and investors aren’t. Build a system you’d be proud to show in a due diligence process. One that proves you know what data you hold, and how you protect it.
The Opportunity, If You’re Ready
This shift is a legal and ethical opportunity. A rare moment to strip back the administrative deadwood and build a leaner, smarter GDPR posture.
Ignore the hype that says compliance is softening. It isn’t. It’s sharpening its focus. And if you’re paying attention, you can use that to your advantage.
This is what strategy looks like in compliance: Not waiting to be told what to do. But knowing what matters, and doing it better than expected.
Head of Compliance and Legal Department
Francesco Cattaneo is Head of Legal & Compliance at XTROVERSO™. A qualified Italian lawyer and CIPP/E-certified privacy expert, he bridges civil law, digital regulation, and strategic governance. His writing challenges the false divide between law and innovation, showing how clear rules, when well-crafted, are not limits but instruments of freedom, protection, and long-term design.