Response to the Public Consultation on the EDPB Guidelines 02/2026 on Anonymisation

This publication provides a response to the public consultation of the European Data Protection Board (EDPB) on the draft Guidelines 02/2026 on Anonymisation, Version 1.0, which were adopted on 07 July 2026. The response was submitted to the EDPB on 29 October 2026. The response was co-authored by a multi-institution, multi-disciplinary group of German-based academic researchers which specialize in cybersecurity and privacy enhancing systems, data protection law, AI regulation and research data management. With reference to the Guidelines, the response focuses on key areas. These include a framework for assessing the risk of anonymised data, definitions of terminology used within the Guidelines, the criteria for the technical analysis of anonymisation, as well as the interplay between the Guidelines and scientific research data. Within these areas, specific issues are addressed, from which the co-authors derive concrete recommendations for the EDPB and the Guidelines. These issues include, amongst others, the assessment of the risk of identification, the construction of a chain of entities for the means reasonably likely to be used, a broadening of the scope of the definition for given data, the unclear ‘treat them differently’ element of identification, the use of ‘No Inference’ as the primary criterion for the technical analysis, and the recognition of established practices for anonymisation in scientific research.