Art. 46 DPO – Transitional provisions

Statutory textStatus: 1 December 2025

¹ In the case of automated processing of personal data that was planned or started before the amendment of 29 October 2025 came into force, the assessment of the need for logging under Article 4 paragraph 2 must be carried out by 31 December 2026. If logging proves to be necessary, it must be implemented by 31 December 2029. The foregoing does not apply to the automated processing of sensitive personal data, profiling and automated data processing that falls within the scope of Directive (EU) 2016/680.

² Article 8 paragraph 5 does not apply to assessments carried out before this Ordinance comes into force.

³ Article 31 does not apply to planned automated processing activities in respect of which the decision to develop or approve the project has already been taken when this Ordinance comes into force.

Source: Version on FedlexThis translation is not an official version. Only the German, French and Italian versions are legally binding.

In brief

For automated processing by federal bodies that was planned or started before the amendment of 29 October 2025, the assessment of the need for logging under Art. 4 para. 2 DPO must be carried out by 31 December 2026, and any necessary logging must be implemented by 31 December 2029. This transitional period does not apply to the processing of sensitive personal data, profiling or processing within the scope of Directive (EU) 2016/680. Further transitional rules concern Art. 8 para. 5 and Art. 31 DPO.

Transitional provisions

In brief

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