EDPB Data Protection Brief

Headline

EDPB updates One-Stop-Shop case digest cataloguing DPA enforcement patterns on erasure and objection rights

Executive Summary

The European Data Protection Board published an updated case digest on June 25, 2026, consolidating One-Stop-Shop decisions on the right to object and right to erasure under GDPR Article 60. The digest identifies the most frequent infringements and corrective measures issued across hundreds of new OSS decisions adopted since the original publication.

Bottom Line

The updated digest consolidates hundreds of OSS enforcement decisions into a shared DPA reference on internal process failures, direct marketing objections, and account erasure handling. Organisations subject to GDPR face a supervisory environment where DPAs across the EU now draw from a common, expanded enforcement baseline when assessing corrective measures. The digest's identification of most-frequent infringements means the documented failure patterns carry practical weight as a de facto enforcement standard across lead and concerned supervisory authorities.

Key Regulatory Signals

• Internal Process Scrutiny Is the Primary Enforcement Focus: DPAs assess whether organisations have implemented adequate internal workflows to handle erasure and objection requests, not merely whether individual requests were fulfilled. Organisations without documented, auditable request-handling processes carry documented exposure under the consolidated enforcement record.
• Direct Marketing Objections Remain a High-Frequency Enforcement Area: The digest specifically identifies objections to direct marketing as a recurring case category. Organisations running email, profiling, or behavioural advertising programmes face the highest volume of DPA scrutiny in this thematic area.
• Account and Profile Deletion Requests Generate Repeat Findings: Erasure of user accounts and online data profiles is a named enforcement pattern. Platforms and data-driven services that retain residual data after a deletion request, or that delay fulfilment, appear repeatedly in the underlying OSS decision record.
• Corrective Measure Inventory Now Reflects Hundreds of Additional Decisions: The update incorporates hundreds of OSS decisions adopted after the original digest. The aggregate corrective measure data now reflects a materially larger enforcement sample, giving DPAs a shared reference baseline for calibrating future corrective action.
• Cross-DPA Coordination Tool With Direct Enforcement Utility: The digest is produced under the Support Pool of Experts programme, part of the EDPB 2024-2027 Strategy. Its function is to harmonise supervisory analysis across EU national DPAs, meaning enforcement posture documented here is likely to be applied consistently across multiple jurisdictions rather than remaining confined to a single lead supervisory authority.

Regulatory Delta

- The original case digest established the thematic framework; this update reflects a materially expanded OSS decision base. The expansion represents greater enforcement data, not a change in legal theory.

- The digest now functions as a calibration reference across data protection authorities, meaning the corrective measure patterns documented here carry practical weight beyond the individual decisions that generated them.

- The update aligns with the EDPB 2024-2027 Strategy's explicit capacity-building objective, placing this release within a multi-year programme of supervisory harmonisation across EU national DPAs.

Materiality Classification

MEDIUM — A guidance and enforcement-pattern digest, not a binding decision or final rule. The consolidated infringement catalogue and corrective measure inventory carry directional enforcement weight across EU DPAs, requiring assessment against internal data subject rights processes by organisations with EU data processing operations.

Intelligence Outlook

Monitor the EDPB for further thematic case digest updates under the Support Pool of Experts programme and for any binding guidelines or recommendations that codify the enforcement patterns identified in this digest.