Simplification or Deregulation? The Digital Omnibus and the Silent Erosion of B2B Protections in the Digital Single Market

Abstract In November 2025, the European Commission presented the Digital Omnibus Proposal as the legislative core of its broader Digital Package on Simplification – an initiative forming part of a series of Omnibus packages ostensibly aimed at reducing administrative burdens and boosting competitiveness. A crucial but overlooked dimension of the Digital Omnibus is the repeal of the Platform-to-Business (P2B) Regulation (EU) 2019/1150, the first horizontal framework establishing mandatory commercial safeguards for professional users of online intermediation services, on the premise that the Regulation has been absorbed by the Digital Services Act (DSA) and the Digital Markets Act (DMA). Against this backdrop, this article critically examines the normative impact of the Digital Omnibus stemming from the proposed repeal. Through a granular gap analysis, it demonstrates that the post-abrogation legal framework fails to replicate the tailored commercial safeguards provided by the Regulation, creating critical regulatory voids. Furthermore, it argues that framing substantive deregulation – which fundamentally reconfigures core policy objectives of the EU digital acquis – as a mere technical simplification fails to account for the true normative reach of the Digital Omnibus, rendering its impact unclear and exposing platform-dependent business users to severe regulatory uncertainty without the benefit of adequate democratic debate.

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Publication Details

Journal
European Journal of Risk Regulation
Published
2026-09-30
DOI
https://doi.org/10.1017/err.2026.10155
Primary Topic
Diverse Legal and Medical Studies
Type
article
Field-Weighted Citation Impact
0.00
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article

Simplification or Deregulation? The Digital Omnibus and the Silent Erosion of B2B Protections in the Digital Single Market

Guido Smorto
European Journal of Risk Regulation
Diverse Legal and Medical Studies
article

Simplification or Deregulation? The Digital Omnibus and the Silent Erosion of B2B Protections in the Digital Single Market

Guido Smorto
article en

Abstract

Abstract In November 2025, the European Commission presented the Digital Omnibus Proposal as the legislative core of its broader Digital Package on Simplification – an initiative forming part of a series of Omnibus packages ostensibly aimed at reducing administrative burdens and boosting competitiveness. A crucial but overlooked dimension of the Digital Omnibus is the repeal of the Platform-to-Business (P2B) Regulation (EU) 2019/1150, the first horizontal framework establishing mandatory commercial safeguards for professional users of online intermediation services, on the premise that the Regulation has been absorbed by the Digital Services Act (DSA) and the Digital Markets Act (DMA). Against this backdrop, this article critically examines the normative impact of the Digital Omnibus stemming from the proposed repeal. Through a granular gap analysis, it demonstrates that the post-abrogation legal framework fails to replicate the tailored commercial safeguards provided by the Regulation, creating critical regulatory voids. Furthermore, it argues that framing substantive deregulation – which fundamentally reconfigures core policy objectives of the EU digital acquis – as a mere technical simplification fails to account for the true normative reach of the Digital Omnibus, rendering its impact unclear and exposing platform-dependent business users to severe regulatory uncertainty without the benefit of adequate democratic debate.

European Journal of Risk Regulation
University of Palermo (AR), University of Palermo (IT)
Peace, Justice and strong institutions
Openalex Percentile: Top 8%
Diverse Legal and Medical Studies
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Simplification or Deregulation? The Digital Omnibus and the Silent Erosion of B2B Protections in the Digital Single Market — Guido Smorto · European Journal of Risk Regulation (2026) | TGRS Research Map | TGRS