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The Data Governance Act

The European Data Governance Act (DGA) is a game-changer for the EU’s data-driven economy. Malta, a champion of digital innovation, is taking a leading role in implementing this framework. This page explores Data Intermediation Services, Data Altruism Organisations, and the role of the Malta Digital Innovation Authority (MDIA) in this landscape.

DGA sets a common framework for data governance, including conditions for reusing public sector data, a framework for data intermediation services, voluntary registration for data altruism entities, and the establishment of a European Data Innovation Board.

The Act establishes clear rules and mechanisms for data intermediation and altruistic data sharing, ensuring responsible data practices and building user confidence. Data intermediation services must notify the Competent Authority of their services, while Data Altruism Organizations can register themselves as such. Notifications and Registrations are to be submitted to the MDIA if the head office or the legal representative is in Malta. Once registered or notified, and compliant with DGA requirements, these entities can use an EU label in their communications that demonstrate their adherence to the requirements and will be supervised by the MDIA.

Data Intermediation Services

Data Intermediation Services are neutral third parties that act as connectors, facilitating data exchange between data holders (organizations possessing data) and data users (those seeking to utilize the data). They offer services, including data marketplaces and sharing pools, to enable efficient and controlled data transactions. By doing so, these entities will improve the efficiency of data exchange in Europe while they can potentially benefit from a thriving data market, generating revenue and gaining access to market partnerships and collaborations in Europe.

Data Intermediation Services subject to the notification procedure

Data Altruism Organisations

Data Altruism Organizations promote the voluntary sharing of data, contributing to advancements in research, policymaking, and other areas of societal benefit. By registering with MDIA, an organisation can be granted the right to call itself a recognised data altruism organisation and use a common logo.

Requirements for recognition as a Data Altruism Organisation

European Data Innovation Board

The MDIA is involved in the European Data Innovation Board, which the EU Commission established. The board’s objective is to facilitate the sharing of best practices, in particular on data intermediation, data altruism, and the use of public data that cannot be made available as open data, as well as on the prioritisation of cross-sectoral interoperability standards.

Expression of Intent

The MDIA will soon begin accepting registrations and notifications. Malta boasts a robust tech ecosystem, offering several compelling advantages for organizations seeking to register under DGA. These include access to guidance, seamless cooperation with Malta’s European Digital Innovation Hub and a track record of recognizing and supporting organisations in the digital innovation field. Moreover, organizations can benefit from a vibrant tech community that offers potential partnerships, collaborations, and knowledge exchange. Organizations can already access authority support on the topic by sending an email to

Data Intermediation Services subject to the notification procedure

The Data Intermediation Services subject to the notification procedure are:

  1. Intermediation services between data holders and potential data users, including making available the technical or other means to enable such services; those services may include bilateral or multilateral exchanges of data or the creation of platforms or databases enabling the exchange or joint use of data, as well as the establishment of other specific infrastructure for the interconnection of data holders with data users;
  2. Intermediation services between data subjects that seek to make their personal data available or natural persons that seek to make non-personal data available, and potential data users, including making available the technical or other means to enable such services and enabling the exercise of the data subjects’ rights provided in Regulation (EU) 2016/679;
  3. Services of data cooperatives.
Requirements for recognition as a Data Altruism Organisation

In order to qualify for registration in the public register of recognised data altruism organisations, an entity must:

  • carry out data altruism activities
  • be a legal person established pursuant to national law
  • operate on a not-for-profit basis and be legally independent from any entity that operates on a for-profit basis
  • carry out its data altruism activities through a structure that is functionally separate from its other activities
  • comply with the European Commission’s rulebook.