Governance

data intermediary

Neutral actors facilitating governed data exchange.

How the laws define this

Both sources establish data intermediaries as trusted or neutral entities that facilitate governed data sharing by offering standardized frameworks, technical mediation services, and certification to ensure secure, compliant exchanges between parties. However, they diverge in their specific operational scope and governing legal frameworks. Datenstrategie für Österreich (Data Strategy for Austria) emphasizes cross-sector data reuse, framing intermediaries as neutral actors providing governance functions like access control, monitoring, and clear codes of conduct. In contrast, the National Data Strategy (aligned with the national AI and quantum strategies — 'Accelerating Digital Sovereignty 2030') explicitly focuses on lawful public–private data sharing, tying these designated actors directly to compliance with the EU Data Governance Act and national rules while stressing auditable exchanges and standardized contractual frameworks.

Synthesised from the 2 statutory definitions below. Each one is quoted in full, with its source.

How jurisdictions differ

What is distinctive in each definition, binding law in force first.

Jurisdiction	Instrument	Status	What is distinctive
Austria	Data Strategy for Austria	Adopted	Adds supervision, possible certification, clear codes of conduct, and a vision for enabling cross-sector data reuse.
Luxembourg	National Data Strategy (aligned with the national AI and quantum strategies — 'Accelerating Digital Sovereignty 2030')	Adopted	Specifies compliance with the EU Data Governance Act and national rules, plus standardized contractual frameworks and auditable exchanges.

What it triggers

Austria's Data Strategy for Austria sets out supervised and possibly certified data intermediaries operating under clear codes of conduct to enable cross-sector data reuse.source
Luxembourg's National Data Strategy describes designated trusted actors mediating public-private data sharing with certification paths and technical services.source

Definitions (2)

Neutral actors or services that mediate and facilitate governed data sharing between data holders and data users, offering trust, standardised interfaces, and governance functions (e.g., certification, access control and monitoring). The Strategy envisions supervised and possibly certified data intermediaries operating under clear codes of conduct to enable cross-sector data reuse.

Datenstrategie für Österreich (Data Strategy for Austria)Definition 1 of 2

Designated trusted actors or service providers that mediate and facilitate lawful public–private data sharing in compliance with the EU Data Governance Act and national rules, providing standardized contractual frameworks, certification paths, and technical mediation services to ensure secure, auditable, and compliant data exchanges.

National Data Strategy (aligned with the national AI and quantum strategies — 'Accelerating Digital Sovereignty 2030')Definition 2 of 2

Not to be confused with

data trustee

Data trustee focuses on managing rights, consent, and access, while data intermediary facilitates broader governed exchange with trust and interfaces.

data intermediation service provider

Data intermediation service provider is a recognised entity for data access and reuse, whereas data intermediary encompasses neutral actors or services offering governance functions.

Questions and answers

What supervision do data intermediaries need in Austria?

Austria's Data Strategy for Austria envisions supervised and possibly certified data intermediaries. They operate under clear codes of conduct.

How does Luxembourg ensure compliant data sharing via intermediaries?

Luxembourg's National Data Strategy designates trusted actors compliant with the EU Data Governance Act and national rules. They provide standardized contractual frameworks, certification paths, and technical mediation for secure, auditable exchanges.

What services do data intermediaries provide according to these strategies?

Both strategies describe data intermediaries offering trust, standardised interfaces, governance functions like certification and access control. Luxembourg adds auditable exchanges and technical mediation.