The so-called Digital Omnibus, a set of deregulatory measures that ran contrary to the EU’s previous efforts to regulate the digital economy, took many by surprise. We argue that this is due to the lack of attention paid to the digital policies of smaller EU member states, a problem that is shared by both media reporting and academic research.

At the end of 2025, the European Commission published the Digital Omnibus Regulation Proposal that hits the EU’s rights-based model at its heart. It does so by cutting privacy protection safeguards in the GDPR and delaying the introduction of measures against high-risk systems in the AI Act. This signals a change from the regulatory ambitions that had characterised the EU’s approach to digital governance since 2019 – often under the label of digital sovereignty.

Besides its deregulatory edge, the Omnibus has another common denominator. Its presentation and support have been mostly orchestrated by EU representatives from small member states. This is evident from the lineup during the Commission’s press conference on the issue, which included Henna Virkkunen of Finland, Michael McGrath of Ireland, and Valdis Dombrovskis of Estonia. Guided by the Danish Presidency, the Conclusions of the Council of the EU make this clear, too. It was not only the German government that threw its support behind the proposal, but also – and most eagerly – the trio of Sweden, Finland, and Czechia. All these small countries belong to the Digital 9+ coalition (D9+).

To our knowledge, this prominence of small states from Northern and Eastern Europe in the deregulatory push has been largely overlooked in the analysis. Instead, the media talk of big actors and noisy politics, including US pressure on the EU, changes of heart in large Western European states, or a new-born alliance of centre-right and far-right parties in the European Parliament. These are indeed important issues, but they paint only a limited picture.

Mind the small actors

In our recent article, we argue that to understand EU digital politics more fully, we should pay more attention also to the positions of smaller member states. The Digital Omnibus is a case in point. Many of the states that are now at the helm of the deregulatory wave have in fact been sceptical of the EU’s digital legislative push already at the time when it was hailed as a success story in the form of the so-called Brussels effect.

One could easily criticise journalists for being simplistic or impressionistic when reporting on the Omnibus as a result of a power game between big players, such as the US, Germany, or big tech itself. However, academic research on EU digital politics has similar blind spots.

As Julia Rone and our article argue, the majority of academic scholarship has so far focused on explaining how big Western European states and EU institutions pushed for the ambitious digital sovereignty agenda. While doing so, it has confused the French and German positions for a shared EU approach, while the dissenting voices of the small states from across Europe have been pushed out of the scholarly debate.

Enter the D9+ coalition and you will get a fuller picture. This like-minded coalition of mostly Nordic, Benelux, Baltic, and Central European countries formed as a dissenting group in the regulatory discussions leading to the GDPR’s enactment already in the mid-2010s. Their dissent was rooted in a shared self-perception as small and open economies with neither the capacities to match Germany’s regulatory ambitions nor the appetite for pursuing a French-style industrial policy.

As early as 2020, the D9+ capitals therefore called to “strike the right balance” between the trustworthiness and innovation of AI, advocating thus for “soft law” and “voluntary” self-regulation instead of the hard-law approach of the AI Act and similar measures. They have called for avoiding “unnecessary burdens or barriers” for European businesses and EU’s export competitiveness long before this became the official line of the Commission.

A tipping point, not a turning point

With this fuller picture, the Digital Omnibus should not be understood as a turning point, that is a sudden reversal from regulation to deregulation. Rather, it marks a tipping point: a moment when the long-standing defensive posture of small states against the ambitious EU digital regulation has tipped into an openly offensive strategy that now actively pushes for deregulation.

During the momentum of von der Leyen’s first Commission between 2019 and 2024, sceptical small states merely focused on watering down key aspects of the digital sovereignty agenda. For example, Czechia has done so through quiet bureaucratic networks, pushing for exempting small and medium-sized firms from the maximum scope of EU digital regulations.

That momentum waned at the end of 2023, when last-minute objections by France, Germany, and Italy to the then-finalised AI Act risked derailing it entirely. A change of government in Berlin last year was enough to tilt Germany back towards its free-market instincts.

Since the start of 2025, von der Leyen’s second Commission shifted its language to regulatory “simplification”. It thus productively tapped into the reservoir of critiques and appeals that have been produced by the D9+ coalition for years. This in turn created a window of opportunity for the small states to move into an open offensive and start pushing for deregulatory alternatives outright.

Deregulatory offensive?

So, does the Digital Omnibus open the door to a one-sided deregulatory future? Looking back through a more complete picture, one can leave such roller-coaster predictions aside. Just as the regulatory period was full of messy politics that made the process hardly a one-sided policy drive, the deregulatory promise will likely end in incremental steps, deadlocks and messy compromises.

We call for focusing on these small actors as well when studying these conflicts over the future of the EU’s digital sovereignty. While the digital space is likely to become more and more a domain of big-power politics, one might also appreciate how small actors try to creatively shape it despite their size-related disadvantage. Our research revealed a range of such creativity, from aligning with external powers (particularly the US or China) to exert pressure on large European states, to twisting EU regulations in ways that serve domestic agendas, or even foot-dragging during the implementation phase.

Once small states and these specific strategies are put under the spotlight, digital politics will suddenly appear in a different light: one in which the preferences and positions of the big players are not so all-powerful, thus creating interpretative and imaginative space for agency of such smaller actors. This might be true for Czechia vis-à-vis Germany in EU digital politics, just as for the EU vis-à-vis the US state and big tech in global digital politics.