Governance

data intermediation services

Neutral third-party services that facilitate data exchange without exploiting it.

How the laws define this

Both frameworks agree that data intermediation services involve facilitating the sharing or exchange of data between multiple parties under mandatory official notification and oversight requirements. Providers in both contexts must register their activities with a competent authority or Ministry and adhere to regulatory governance standards. They diverge, however, on provider restrictions and operational scope. The Draft Act on Data Management (Projekt ustawy o zarządzaniu danymi) defines these offerings strictly as neutral third-party services that must act impartially and are prohibited from exploiting shared data for their own purposes. In contrast, Law 5188/2025: Measures for the implementation of the Data Governance Act and the National Strategy for public sector data limits providers to legal persons and broadens the functional scope to include data pooling among data subjects, data holders, and third parties, explicitly using the definition to establish which commercial actors face government supervision and legal sanctions.

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
Greece	Law 5188/2025: Measures for the implementation of the Data Governance Act and the National Strategy for public sector data	In Force	Specifies that only legal persons can provide the services, requires notification to the Ministry, mandates governance safeguards, and subjects providers to oversight and sanctions.
Poland	Draft Act on Data Management	In Force	Explicitly requires providers to register with the competent authority and comply with neutrality and reporting obligations.

What it triggers

In Greece, under Law 5188/2025, providers must notify their activity to the Ministry, meet governance safeguards, and may be subject to oversight and sanctions.source
In Poland, under the Draft Act on Data Management, providers must notify or register with the competent authority and comply with neutrality and reporting obligations.source

Definitions (2)

Neutral third‑party offerings that facilitate the exchange or sharing of data between providers and recipients while acting impartially and not exploiting the data for their own purposes; providers of such services must notify/register with the competent authority and comply with neutrality and reporting obligations.

Draft Act on Data Management (Projekt ustawy o zarządzaniu danymi)Definition 1 of 2

Services provided by legal persons that facilitate the sharing, exchange or pooling of data between data subjects, data holders and third parties, operating under notification and supervisory requirements established by the Ministry; providers must notify their activity, meet governance safeguards, and may be subject to oversight and sanctions under the law. The definition frames which commercial or intermediary actors fall within the registration/notification regime.

Law 5188/2025: Measures for the implementation of the Data Governance Act and the National Strategy for public sector dataDefinition 2 of 2

Not to be confused with

data intermediary

Data intermediary is a general term for neutral actors facilitating governed data exchange, while data intermediation services refer to specific regulated offerings with notification requirements.

data intermediation service provider

Data intermediation service provider denotes a recognised entity facilitating data access and reuse, whereas the term covers the services themselves subject to registration and oversight.

Intermediary

Intermediary broadly means any entity handling electronic records for others, unlike data intermediation services which are neutral third-party data exchange facilitators with strict non-exploitation rules.

Questions and answers

What obligations apply to data intermediation services in Greece?

Providers must notify their activity to the Ministry, meet governance safeguards, and may be subject to oversight and sanctions under Law 5188/2025. This frames which commercial or intermediary actors fall within the registration regime.

What are the requirements for data intermediation services in Poland?

Providers must notify or register with the competent authority and comply with neutrality and reporting obligations under the Draft Act on Data Management.

How do data intermediation services differ from general intermediaries?

Data intermediation services are neutral third-party offerings that facilitate data exchange without exploiting it and require registration, unlike general intermediaries that simply handle electronic records.