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REGULATORY WATCH BRIEF Low 34 ⚖️ Enforcement Action announced

noyb to file injunction against SCHUFA over shadow database

The planned injunction highlights enforcement of EU data‑protection rights against a major credit reference agency.

ADTP Regulatory Watch · September 10, 2026
ImpactLow 34
Type⚖️ Enforcement Action
Statusannounced not law
JurisdictionEU-DE

What happened

noyb sent a cease-and-desist letter to SCHUFA demanding the removal of its shadow database. SCHUFA's deadline to comply has expired and the agency has rejected the allegations. noyb announced it will now file an injunction and invites interest in a potential class action.

Why it matters for trust and compliance

  • Its status is announced. It is not law yet. Track it, but do not treat it as an obligation.
  • The planned injunction highlights enforcement of EU data‑protection rights against a major credit reference agency.

Who is affected

financial services controller data broker SCHUFA

Recommended actions

  1. Check that privacy notices describe the practices this addresses.
  2. Confirm access, correction, deletion and opt-out requests are handled within the required time.
  3. Revisit retention schedules and data minimisation for the data involved.
  4. Inventory AI or automated decision systems in scope and their assessments.