Tracker record · EU/U.S. · Commission implementing decision

EU-U.S. Data Privacy Framework and current litigation

Industry: All industries · Track: Compliance, Litigation and Enforcement

The EU-U.S. Data Privacy Framework adequacy decision for transatlantic transfers. Compliance track: U.S. organizations certify through the Department of Commerce program and recertify annually. The adequacy decision operates unless and until withdrawn or annulled; Latombe appealed on October 31, 2025 (Case C-703/25 P). The Court's case listing identifies the appeal as pending. An appeal does not itself suspend the adequacy decision.

Status

Legal status
In effect; adequacy decision operative; appeal C-703/25 P pending (Adopted July 10, 2023; upheld by the General Court in Latombe (T-553/23) on September 3, 2025; appeal C-703/25 P filed October 31, 2025; the Court's case listing identifies the appeal as pending. The adequacy decision remains operative while the appeal is pending; it ceases only if the Commission withdraws or amends it or the Court of Justice annuls it.)
Allegation or finding
Finding or order
Applicability
U.S. organizations self-certifying under the Framework
Enforceability
Binding per its terms
Procedural posture
Legal challenge pending (appeal C-703/25 P, filed October 31, 2025); Framework remains operative
Law checked through
October 13, 2026
Citation
Commission Implementing Decision (EU) 2023/1795
Source
Commission Implementing Decision (EU) 2023/1795; Latombe v. Commission, T-553/23 (September 3, 2025); appeal C-703/25 P

Related guides

Related topics