General Court of the European Union Rejects the Action for Annulment Concerning the EU-US Data Transfer Framework

The action for annulment brought against the decision adopted by the European Commission on 10 July 2023 establishing a new personal data transfer framework between the European Union and the United States is rejected by the General Court of the European Union (“the Court”) on 3 September 2025.

The judgment highlights the following points:

• In the past, the Court of Justice of the European Union annulled two previous adequacy decisions concerning the United States in the Schrems I and Schrems II judgments, on the grounds that they did not ensure a level of protection of fundamental rights and freedoms essentially equivalent to that guaranteed under EU law.
• It is confirmed that, at the time of the adoption of the contested decision, the United States ensured an adequate level of protection for personal data transferred from the European Union.
• It is established that the Data Protection Review Court (DPRC) operates with safeguards guaranteeing the independence of its judges, who may be dismissed only for just cause. It is further stated that the Commission continuously monitors the implementation of the framework and may, if necessary, amend or suspend the scope of the decision.
• It is held that United States law meets the Schrems II standards and ensures a level of protection essentially equivalent to that guaranteed by EU law; all claims are dismissed and the action is closed in its entirety.

You can access the full text of the judgment here.

Kind regards,

Zumbul Attorneys-at-Law

info@zumbul.av.tr

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