Invest Europe

Response to the European Commission consultation on Simplification: digital package and omnibus – DORA comments

Positions & consultation responses

13 Mar 2026

The Digital Omnibus proposals on DORA, such as the single EU incident‑reporting entry point, are a positive and pragmatic step towards a more coherent, efficient and proportionate digital resilience framework in the EU.

However, broader adjustments are still needed to ensure that DORA is workable for private capital managers and does not undermine the EU’s ambition to boost private investment, innovation and growth. In particular, DORA must better recognise the specific characteristics of long‑term, closed‑ended equity funds and avoid imposing on them ICT regimes designed for very different business models.