Want to Judge US-EU Data Privacy Fights? Apply Now
Published Date: 2/23/2026
Notice
Summary
The Department of Commerce is asking for public feedback on a form used to apply as an arbitrator for the Data Privacy Framework, which helps protect personal data shared between the U.S., EU, UK, and Switzerland. This process affects people who want to be on the official list of arbitrators and ensures smooth, fair handling of privacy disputes. Comments are open until April 24, 2026, with no new fees involved.
Analyzed Economic Effects
5 provisions identified: 2 benefits, 3 costs, 0 mixed.
Arbitration Limited to Non‑Monetary Relief
If an EU, UK, or Swiss individual invokes binding arbitration under the Data Privacy Framework, the arbitration panel (one or three arbitrators) can impose only individual-specific non-monetary equitable relief (for example, access, correction, deletion, or return of data). Arbitration decisions are binding, but no damages, costs, fees, or other monetary remedies are available.
Arbitrator Application Eligibility Rules
To apply to be an arbitrator for the Data Privacy Framework, you must be admitted to practice law in the United States and be an expert in U.S. privacy law with expertise in EU or Swiss data protection law (as applicable). Applications must describe your independence, provide three references about your integrity, list relevant education and experience, and be submitted electronically headed with the applicable list name.
Application Time Burden and Deadline
The Department estimates 30 applicants will respond, with an average of 4 hours per application and a total annual burden of 120 hours. The information collection is voluntary, has an estimated total annual cost to the public of $0, and comments on the collection must be received by April 24, 2026.
Arbitrator List Size and Term Length
The Department will maintain an EU-U.S. DPF List of at least 10 arbitrators and a Swiss-U.S. DPF Supplemental List of up to five arbitrators. Arbitrators remain on their list for 3-year terms, renewable by the Department of Commerce with prior notification to the relevant partner authority.
ICDR-AAA to Administer Arbitrations
The International Centre for Dispute Resolution (ICDR), the international division of the American Arbitration Association (AAA), will administer arbitrations under the Data Privacy Framework, manage the arbitral fund, and facilitate arbitrator fee arrangements, including collection and timely payment of arbitrator fees and other expenses.
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Key Dates
Department and Agencies
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Previous / Next Documents
Previous: 2026-03469, Agency Information Collection Activities; Submission to the Office of Management and Budget (OMB) for Review and Approval; Comment Request; Self-Certifications Under the Data Privacy Framework Program
The Department of Commerce is asking for public feedback on a form that U.S. companies use to prove they protect personal data when sharing it with the EU, UK, and Switzerland. This helps keep data safe and supports international business. Comments are open until April 24, 2026, and this process aims to keep paperwork easy and efficient for everyone involved.
Next: 2026-03471, Agency Information Collection Activity: Financial Statement
The VA wants your thoughts on updating their Financial Statement form, which helps check a borrower's money situation for loan reinstatements. If you’re involved with VA loans or financial info, this affects you! You’ve got until April 24, 2026, to share your ideas—no cost, just your feedback to make things smoother and clearer.