Table of Contents

Overview

This report covers Parliamentary Questions (PQs) and Commission replies published between 3 and 9  November 2025. The exchanges highlight the initial implementation and enforcement phases of the EU’s core digital legislative files. Key policy areas under scrutiny include the enforcement of the Digital Services Act (DSA), particularly concerning content moderation appeals and the protection of minors, the practical application of the AI Act’s provisions on safety and copyright, and the scope of the General Data Protection Regulation (GDPR) in emerging sectors like genetic testing. The Commission consistently positions itself as an enforcer of these established frameworks, emphasising their sufficiency and balance while clarifying the division of responsibilities with national authorities. These developments offer crucial insights for digital-policy professionals into the EU’s emerging enforcement priorities and the practical interpretation of its new digital rulebook.

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Core Legislative Frameworks (AI Act, DSA, DMA, Data Act, Cyber Resilience, NIS2)

DSA Enforcement & Online Safety

❗ Commission Confirms Preliminary Finding of Meta Breach on User Appeals

In a 7 November 2025 response, Executive Vice-President Virkkunen addressed a question regarding a specific Facebook page termination. The Commission stated it has no direct competence in individual content moderation decisions but confirmed its preliminary finding from 24 October 2025 that Meta breached its Digital Services Act (DSA) obligations. The reply to question P-003989/2025 highlights that Meta’s appeal mechanism for both Facebook and Instagram appears insufficient, as it does not allow users to provide explanations or evidence. The Commission reiterated that under the DSA, Very Large Online Platforms (VLOPs) must assess and mitigate systemic risks to civic discourse and that it remains in regulatory dialogue to ensure compliance.

❗ DSA Provides Framework to Tackle Image-Based Sexual Abuse Online

The Commission is committed to tackling gender-based violence, as stated in its 6 November 2025 reply to question E-003551/2025. Executive Vice-President Virkkunen explained that the Digital Services Act (DSA) establishes that illegal offline content, including image-based sexual abuse (IBSA), is also illegal online. The DSA mandates notice-and-action mechanisms for illegal content and requires VLOPs to conduct risk assessments for systemic risks like IBSA. The response also noted that non-VLOP platforms fall under the remit of national Digital Services Coordinators and pointed to the 2024 Directive on combating violence against women as another key instrument.

❗ Commission Clarifies DSA Obligations for E-Commerce Platforms

In a reply dated 4 November 2025, the Commission clarified the obligations of online platforms under the new Packaging and Packaging Waste Regulation (PPWR). Answering question E-003267/25, Commissioner Roswall stated that while online platforms do not have the same obligations as manufacturers or importers, the Digital Services Act (DSA) applies to all intermediary services offered in the EU. Under the PPWR, online platforms must obtain confirmation of extended producer responsibility (EPR) registration from producers selling via their services. The Commission noted that enforcement is primarily a task for Member State authorities.

❗ Safeguards in Child Sexual Abuse Regulation Proposal Defended by Commission

Responding on 6 November 2025 to concerns about the proposal to prevent and combat child sexual abuse, Commissioner Brunner asserted that the measure is based on a thorough impact assessment. The reply to question E-003690/25 states that the proposed detection orders are targeted and issued by judicial or independent authorities, balancing all fundamental rights. The Commission emphasised that the proposal includes necessary safeguards and that it will continue to support the co-legislators in ensuring a fair balance is struck in the final text.

❓ MEPs Probe Commission Stance on Online Recruitment of Minors for Crime

In question E-004256/2025, submitted on 29 October 2025, MEPs from the PfE group asked the Commission about the online recruitment of minors to commit crimes. The question seeks details on demographic data collected by Europol, whether the Commission views these minors as victims or perpetrators, and its position on recruitment for politically motivated violence. A response from the Commission is pending.

AI Act & Copyright

❗ Commission Affirms Existing Copyright Law as Sound Basis for AI Training

Executive Vice-President Virkkunen, in a 5 November 2025 response, reaffirmed the Commission’s position on AI model training and copyright. Answering question E-003582/25, the Commission stated that legislators consider the text and data mining (TDM) exception in Article 4 of the Copyright Directive (2019/790) to be relevant for AI training. The reply highlights that the recently endorsed General-Purpose AI (GPAI) Code of Practice requires respect for rights reservations under this article. The Commission considers the current EU copyright acquis well-balanced and suitable for new technologies, noting the TDM exceptions will be assessed in the upcoming review of the Directive.

❓ MEPs Question Human Oversight in AI-Driven Copyright Enforcement

A group of MEPs from the PfE group submitted question E-004239/2025 on 29 October 2025 regarding the use of AI to detect and remove content that infringes copyright. The MEPs ask if the Commission plans to regulate AI by requiring human oversight before content removal and what safeguards will prevent its misuse for censoring political opinions. A Commission response is pending.

❓ MEP Pushes for EU-Wide Recognition of E-Lending Rights for Libraries

In question E-004258/2025 submitted on 29 October 2025, Barry Andrews (Renew) highlighted the financial challenges European libraries face in accessing e-books due to high licensing costs and restrictive publisher practices. Citing a 2016 CJEU judgment, the question asks if the Commission will act to facilitate EU-wide recognition of e-lending rights in EU copyright law to protect libraries from unfair costs. A response is awaited.

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AI Ethics, Safety & Fundamental Rights

❗ AI Act and DSA Address Risks of Emotional Dependence on Chatbots

The Commission acknowledges the potential for users to develop emotional dependence on AI systems, as detailed in a 7 November 2025 reply from Executive Vice-President Virkkunen. The response to question E-003674/25 outlines how the AI Act prohibits manipulative or deceptive AI systems that cause significant harm and imposes transparency obligations. It also notes that if a chatbot is part of a VLOP service, the DSA requires providers to assess and mitigate systemic risks, including those to mental well-being. The Commission also referenced its active involvement in the Council of Europe’s Convention on Artificial Intelligence to ensure consistency with the AI Act.

❓ MEPs Raise Alarm Over Proposed ‘European Democracy Shield’

In two related questions, E-004272/2025 and E-004274/2025, submitted on 30 October 2025, Mathilde Androuët (PfE) questioned the Commission about a report recommending a ‘European Democracy Shield’. The report suggests creating a centralised mechanism to monitor the European information space. The MEP asks if the Commission supports these proposals and how it would ensure such a shield does not become an instrument of censorship or electoral interference. The Commission’s reply is pending.

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Data, Cloud & Digital Infrastructure

❗ GDPR Applies to Recreational Genetic Testing Services

On 7 November 2025, Commissioner McGrath clarified that companies offering recreational genetic testing services in the EU are bound by the General Data Protection Regulation (GDPR). The answer to question E-003662/25 specifies that processing genetic data, a special category of personal data, requires a valid legal basis and must meet conditions under Article 9(2) of the GDPR. The Commission stressed that monitoring and enforcement of the GDPR fall within the competence of national data protection authorities (DPAs).

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Sectoral Policy & Regulation

❗ Commission Funds AI in Healthcare to Address Staff Shortages

In a 7 November 2025 reply, Executive Vice-President Mînzatu highlighted the EU4Health programme’s role in promoting the upskilling of health professionals for digital transformation. The response to question P-004116/25 notes that the Commission funds projects like COMPASS-AI to advance the safe use of AI in healthcare, particularly to alleviate staff shortages in remote areas. This initiative is part of the Commission’s ‘Apply AI Strategy’ and includes plans for European AI-powered advanced screening centres.

❗ European Health Data Space to Support Research Data Harmonisation

Commissioner Zaharieva, on 6 November 2025, pointed to the European Health Data Space (EHDS) as a key initiative for medical research. Answering question E-003626/25 on Myalgic encephalomyelitis/chronic fatigue syndrome (ME/CFS), the Commission stated that the EHDS aims to improve health data exchange and access for research, which could eventually provide a framework for harmonising data on different disorders, including ME/CFS.

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Research, Innovation & Industrial Policy

❓ MEPs Voice Concerns Over Future of International R&I Cooperation

Question E-004265/2025, submitted on 30 October 2025, raises concerns about the future of the EU’s framework programme for research and innovation. Sofie Eriksson (S&D) asks how the Commission will ensure that including defence research in the next programme (successor to Horizon Europe) will not increase costs, complicate processes, or weaken crucial cooperation with partner countries like the UK, Canada, and Japan. A response is pending.

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International & Geopolitical Dimension

❗ Commission Details EU-US Cooperation on Technical Standards

On 7 November 2025, Mr Šefčovič provided an update on the EU-US political agreement on tariffs and trade. The reply to question E-003505/25 notes that the EU and US have agreed to enhance technical cooperation between their respective standards development organisations. The goal is to identify and develop common standards for the transatlantic marketplace in key sectors. The Commission is assessing US standards for vehicle safety and emissions, noting that while some areas are comparable, others follow different approaches.

❓ MEP Questions Commission’s Efforts to Prevent AI in Nuclear Warning Systems

Günther Sidl (S&D) submitted question E-004224/2025 on 27 October 2025, expressing expert concerns about the potential use of AI in nuclear early warning and decision-making systems. The question asks what specific efforts the Commission is making at an international level to prevent this and whether it is supporting research into the associated risks. The Commission has yet to respond.

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Peripheral & Contextual Issues

❗ Commission Comments on Rail Sector’s Digital Ticketing Standard

In a 7 November 2025 reply concerning the rail sector’s Open Sales and Distribution Model (OSDM), Commissioner Tzitzikostas clarified its status. The answer to question E-003405/25 explains that OSDM is a sector-led initiative. The European Union Agency for Railways (ERA) has adapted and integrated parts of OSDM into its technical documents, which the Commission intends to reference in a future implementing act. The Commission noted it does not monitor OSDM’s implementation directly as it was not developed to support EU legislation, and pointed to an ERA report outlining potential risks regarding passenger rights.

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Convergence & Analysis

The Commission’s replies from this period suggest a clear focus on the implementation and consolidation of its landmark digital legislative files. A cross-cutting theme is the emphasis on the sufficiency of existing frameworks. When questioned on emerging challenges, such as the risks of AI chatbots (E-003674/25) or the legal basis for AI training (E-003582/25), the Commission consistently points to specific provisions within the AI Act, DSA, and copyright law, framing them as adequate and well-balanced. This indicates a strategic posture aimed at building confidence in the new rulebook rather than signalling further legislative overhauls.

Furthermore, the Commission carefully delineates its enforcement competencies from those of national authorities. In its responses concerning DSA enforcement on Meta (P-003989/25) and the application of GDPR to genetic data (E-003662/25), it clarifies that its role is to address systemic issues and act as guardian of the Treaties, while specific cases and day-to-day enforcement fall to national bodies like Digital Services Coordinators and Data Protection Authorities. This reinforces the principle of subsidiarity and highlights the critical role national agencies will play in the digital single market.

Finally, the Commission’s answers reveal a strategy of leveraging non-legislative tools, such as funding programmes and international cooperation, to advance policy goals. The use of EU4Health to promote AI in healthcare (P-004116/25) and the pursuit of transatlantic technical standards with the US (E-003505/25) illustrate a pragmatic approach to fostering innovation and strengthening the EU’s strategic position. Overall, the material reveals an institution shifting from rule-making to rule-implementation, focused on demonstrating the effectiveness and coherence of its digital policy architecture.

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