The Polish data protection authority (UODO) conducted study visits in Finland and Hungary to exchange on the implementation of the Data Governance Act (DGA), as part of a project co-financed by the European Commission.

During the visit to Finland, the Polish delegation met with the Finnish Transport and Communications Agency (Traficom), the competent authority for the DGA. Finland was the first country to adopt national legislation in January 2024, covering both the DGA and the Data Act. The governance structure is decentralized, with close cooperation between several institutions. Traficom can issue warnings, reprimands, and, in case of non-correction, fines ranging from €1,000 to €100,000, an amount considered appropriate for young data intermediation companies. The Data Protection Ombudsman, whose powers derive from the GDPR, collaborates with Traficom. The first data intermediation organization was registered in January 2024, followed by the first non-European organization in June 2024.

In Hungary, the national legislation came into force on 1 March 2024, and the National Authority for Data Protection and Freedom of Information (NAIH) created a dedicated department. The Hungarian model relies on two pillars, the National Public Data Portal and the Data Catalogue, accessible via a single information point, as well as a network of Chief Data Officers (CDO) within public institutions. The National Data Protection Agency (NAVÜ) acts as the central coordinator, providing support services such as anonymization. To date, only one data intermediation organization is registered and no data altruism organization, due to requirements considered too restrictive. Feedback indicates that the data market is still too immature to ensure the economic viability of these models.