Data intermediation services must be neutral and register (DGA)

Published by:
Netherlands Enterprise Agency, RVO
Netherlands Enterprise Agency, RVO
Effective date: 24 September 2023

What has changed?

Do you have a data intermediation service, you are a so-called data intermediary? The Data Governance Act (DGA) states that you must register with the regulatory body before you can offer your services. Your services must also be neutral.

As a data intermediary, you offer services that connect data holders and data users for the purpose of sharing data. This is not just about services that only offer the technology to share data. Matchmaking services, such as a data marketplace, are also covered by the DGA.

Registering with the ACM

You must register as a data intermediation service with the Authority Consumer and Market (ACM, in Dutch). After your receive confirmation of your registration, you can offer your services throughout the EU. You can get the label 'data intermediation services provider recognised in the Union' from the regulator. Please note: As the ACM is not yet a formal regulator, you cannot register at this time. You can submit a pre-notification of your registration and application of the EU label to the ACM. You will then be informed when you can register and apply for an EU label.

Neutral data mediation service

Your data mediation service must be neutral:

  • The data you receive must not be used for anything other than sharing it with the data user at the request of the data holder.
  • You cannot offer other (data) services.
  • You must help natural persons exercise their privacy rights under the General Data Protection Regulation (GDPR).

What is the DGA?

The Data Governance Act (DGA) is a European regulation that states rules for governments, companies, and organisations. The DGA aims to ensure greater trust in data sharing.

For whom?

  • Data intermediaries that mediate a commercial relationship between data holders and data users, with the purpose to share data.
  • Data intermediation service providers that were already active before 23 June 2022, have to comply with the DGA’s requirements no later than 24 September 2025. For data intermediary service providers that became active after 23 June 2022 this applies as early as 24 September 2023.


The Digital Governance Act (DGA) has entered into effect on 24 September 2023.

This article is related to:

Questions relating to this article?

Please contact the Netherlands Enterprise Agency, RVO