Here’s a breakdown of the key changes introduced by the two Commission Delegated Regulations you’ve provided:
Commission Delegated Regulation (EU) 2026/327
This regulation amends Delegated Regulation (EU) 2023/333 to improve how multiple identities are detected across EU information systems. The core change is the inclusion of data from the ‘Eurodac’ database in the identity comparison process. Specifically:
- Article 1: Adds a new point to Article 1 of Delegated Regulation (EU) 2023/333, specifying that identity data from Eurodac will now be compared in the multiple-identity detection process.
- Article 2: Updates Annexes I and II of Delegated Regulation (EU) 2023/333 to reflect the inclusion of Eurodac data.
- Annex: Provides specific amendments to the tables in Annexes I and II, detailing which data categories (like names, dates of birth, etc.) from Eurodac will be compared with those in other EU systems like SIS, EES, ETIAS, ECRIS-TCN, and VIS.
In essence, this regulation expands the scope of data used to identify potential multiple identities by incorporating Eurodac data, which includes details like names, nationalities, date and place of birth, and sex.
Commission Delegated Regulation (EU) 2026/326
This regulation amends Delegated Regulation (EU) 2023/332 with a similar objective: to enhance the interoperability of EU information systems for police, judicial cooperation, asylum, and migration by refining the multiple-identity detection process. The key feature is again the inclusion of ‘Eurodac’ data.
- Article 1: Modifies Article 1 of Delegated Regulation (EU) 2023/332 to include identity data from the Eurodac system (Regulation (EU) 2024/1358) in the multiple-identity detection process. This data includes surnames, forenames, names at birth, aliases, nationalities, date of birth, place of birth, and sex.
- Article 2: Amends Annexes I and II of Delegated Regulation (EU) 2023/332, with the specifics detailed in the Annex of the regulation.
- Annex: Provides specific amendments to tables in Annexes I and II, specifying which data categories from various systems (SIS, EES, ETIAS, ECRIS-TCN, VIS, and Eurodac) are to be compared for identity detection.
The core change is expanding the data pool used for creating links between different EU information systems to include Eurodac data. This aims to improve the accuracy of identity checks and combat identity fraud.
Review of each of legal acts published today:
Commission Delegated Regulation (EU) 2026/327 of 3 December 2025 amending Delegated Regulation (EU) 2023/333 supplementing Regulation (EU) 2019/817 of the European Parliament and of the Council as regards determining cases where identity data are considered as same or similar for the purpose of the multiple identity detection
This Commission Delegated Regulation (EU) 2026/327 amends Delegated Regulation (EU) 2023/333, which supplements Regulation (EU) 2019/817. The core objective is to refine the process of detecting multiple identities across EU information systems. This is achieved by specifying the criteria for determining when identity data is considered the same or similar, which is crucial for the interoperability framework between EU information systems.
The regulation consists of three articles and an annex. Article 1 amends Article 1 of Delegated Regulation (EU) 2023/333 by inserting a new point (i) that lists identity data from ‘Eurodac’ to be compared in the multiple-identity detection process. Article 2 amends Annexes I and II of Delegated Regulation (EU) 2023/333, updating tables related to data categories for identity comparison. Article 3 states that the regulation will enter into force twenty days after its publication in the Official Journal of the European Union. The annex provides the specific amendments to Annexes I and II of the original Delegated Regulation, detailing changes to tables that outline data categories such as names, dates of birth, gender, nationality, and place of birth across various EU information systems like SIS, EES, ETIAS, ECRIS-TCN, VIS, and Eurodac. The main change is the inclusion of Eurodac data in the comparison process.
The most important provision of this regulation is the inclusion of ‘Eurodac’ data in the multiple-identity detection process. This means that the identity data stored in Eurodac, which includes surname(s) and forename(s), name(s) at birth and previously used names and any aliases; nationality(ies); date of birth; place of birth and sex, will now be compared with data in other EU information systems. This addition aims to enhance the accuracy and effectiveness of identity checks, helping to identify individuals who may be registered under different identities across various systems.
Commission Delegated Regulation (EU) 2026/326 of 3 December 2025 amending Delegated Regulation (EU) 2023/332 supplementing Regulation (EU) 2019/818 of the European Parliament and of the Council as regards determining cases where identity data are considered as same or similar for the purpose of the multiple identity detection
This Commission Delegated Regulation (EU) 2026/326 amends Delegated Regulation (EU) 2023/332, focusing on the interoperability of EU information systems in the fields of police, judicial cooperation, asylum, and migration. The key aim is to refine the process of detecting multiple identities across different EU databases. This is achieved by specifying how identity data is compared to determine if it should be considered the same or similar, which is crucial for creating links between data in various EU information systems.
The regulation consists of three articles and an annex. Article 1 modifies Article 1 of Delegated Regulation (EU) 2023/332 by inserting a new point (i) that lists specific identity data from the ‘Eurodac’ system (Regulation (EU) 2024/1358) to be included in the multiple-identity detection process. This includes surnames, forenames, names at birth, previously used names, aliases, nationalities, date of birth, place of birth, and sex. Article 2 amends Annexes I and II of Delegated Regulation (EU) 2023/332, with detailed changes outlined in the Annex of this regulation. Article 3 states that the regulation will come into force twenty days after its publication in the Official Journal of the European Union. The annex provides specific amendments to tables in Annexes I and II of the original regulation, detailing which data categories from various systems (SIS, EES, ETIAS, ECRIS-TCN, VIS, and Eurodac) are to be compared for identity detection.
The most important provision of this act is the inclusion of Eurodac data in the multiple-identity detection process. This means that the regulation expands the scope of identity data considered for creating links between different EU information systems, which is essential for accurate identification and combating identity fraud.