Simplification or Deregulation? The Digital Omnibus and the Silent Erosion of B2B Protections in the Digital Single Market

Abstract

In November 2025, the European Commission presented the Digital Omnibus Proposal as the legislative core of its broader Digital Package on Simplification – an initiative forming part of a series of Omnibus packages ostensibly aimed at reducing administrative burdens and boosting competitiveness. A crucial but overlooked dimension of the Digital Omnibus is the repeal of the Platform-to-Business (P2B) Regulation (EU) 2019/1150, the first horizontal framework establishing mandatory commercial safeguards for professional users of online intermediation services, on the premise that the Regulation has been absorbed by the Digital Services Act (DSA) and the Digital Markets Act (DMA). Against this backdrop, this article critically examines the normative impact of the Digital Omnibus stemming from the proposed repeal. Through a granular gap analysis, it demonstrates that the post-abrogation legal framework fails to replicate the tailored commercial safeguards provided by the Regulation, creating critical regulatory voids. Furthermore, it argues that framing substantive deregulation – which fundamentally reconfigures core policy objectives of the EU digital acquis – as a mere technical simplification fails to account for the true normative reach of the Digital Omnibus, rendering its impact unclear and exposing platform-dependent business users to severe regulatory uncertainty without the benefit of adequate democratic debate.