‘Right to be forgotten’ not yet fully implemented across Europe

'Right to be forgotten' not yet fully implemented across Europe

The “right to be forgotten” has not been fully realised, according to a new report on a Europe-wide enforcement campaign.

Ireland’s Data Protection Commission (DPC) was among the EU data protection bodies which took part in enforcement actions under the European Data Protection Board’s (EDPB) coordinated enforcement framework (CEF) in 2025.

The CEF exercise in 2025 involved 32 data protection authorities across Europe, with nine initiating new formal investigations or continuing ongoing ones, while 32 carried out a fact-finding exercise.

A total of 764 controllers across Europe responded to the action, ranging from small and medium-sized enterprises (SMEs) to big companies active in many different industries and fields, as well as various types of public entities.

A new report summarises the outcome of the coordinated national actions and lists issues observed for some controllers as well as recommendations to help them implement the right to erasure, or “right to be forgotten”, under Article 17 GDPR.

Graham Doyle, deputy commissioner at the DPC, said: “The DPC is proud to have been involved in the work conducted under the coordinated enforcement framework since its establishment in October 2020.

“We very much welcome the publication of the 2025 report, which details actions taken by the DPC, and colleague Supervisory Authorities across the EU/EEA, in 2025 under the CEF.”

For 2026, the CEF will focus on the obligations of transparency and information under the GDPR.

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