Commission Work Programme 2026: On Track, but to Where?

29 October 2025

Blog post by Stephen Wyber

The European Commission has published its Work Programme for 2026, setting out 38 new initiatives around six themes—combining both proposed laws and non-legislative initiatives. This confirms that the plans previously announced are on track, but there are still plenty of details to fill in. This article looks at what the Commission Work Programme 2026 could mean for researchers, educators, readers and the libraries that serve them.

Key takeaways for libraries, researchers and educators

  • The ERA Act, the European Innovation Act, and the Digital Fairness Act have high relevance for these sectors
  • Opportunities to address contractual barriers that limit library users’ rights
  • Open questions around ambition, timing, and stakeholder dialogue across research and education
  • Gaps in copyright and culture that merit a fuller review of the acquis

Enabling Research and Innovation

From a Knowledge Rights 21 (KR21) perspective, the most noteworthy issues are the ones already included in the Competitiveness Compass earlier this year. 

The European Research Area (ERA) Act, which is described as the main means of ‘unleashing the fifth freedom’ (the freedom of movement of knowledge), is likely to be presented in September 2026. A public consultation is already underway (see our summary), alongside a study into the economic impacts of introducing a Secondary Publication Right and other reforms. 

Also relevant to KR21 is the European Innovation Act, expected earlier than the ERA Act and likely to focus more on the needs and interests of innovative companies. Here, there is a real opportunity to improve the conditions for research-industry collaborations. However, it will be vital to avoid misalignments, or giving more favourable conditions to business than to libraries and research institutions. Connected to this is a proposal for a special legal regime for innovative firms—a 28th regime. 

Taking Account of the Needs of Libraries and Library Users: Digital Fairness & Better Regulation

We will also follow the Digital Fairness Act closely. With the public consultation now closed (we are grateful to all libraries and library allies who responded), this is an opportunity to highlight how digital contracts are not working for libraries and their users. 

With researchers, teachers, learners, and readers depending on libraries to be able to enjoy their rights of access to research, education, and culture, unfair contract terms offered to these institutions have a direct impact on individuals. 
Another opportunity comes with the proposed communication on better regulation planned for the first half of the year. The Work Programme underlines that this will focus on simplification and proportionality, pushing back on the idea of regulating for the sake of it. For researchers, educators, readers, and the libraries that support them, a powerful step would be to ensure that any new communication underlines the need to consider how any proposed rules or reforms affect them, as well as the wider fifth freedom.

Digital Education and Skills: 2030 Roadmap, Plus a Citizen’s Omnibus

Finally, the Commission also commits to a 2030 Roadmap on the Future of Digital Education and Skills. While education remains a national competence (and so this is a non-legislative initiative), it does offer the opportunity to highlight challenges to libraries’ ability to support digital learning in communities, as well as distance learning. 

A proposed ‘Citizens Omnibus’ could also provide an opportunity to promote the rights to research, education and culture. However,  no further details are available at this stage.

Low Visibility? Gaps and Uncertainties

The Citizen’s Omnibus is not the only area where the Work Programme is either light on detail, or fully silent. While many pieces of law are name-checked, the level of ambition remains unclear. As underlined, for example, in our analysis of the current consultation on the ERA Act, what is likely to be included is still unclear. 

Meanwhile, while work is ongoing on a review of the Directive on Copyright in the Digital Single Market, this is not on the list of legislation to be reviewed in the Work Programme. It does at least get a mention in Executive Vice President Virkkunen’s 2025 progress report on simplification, but this falls short of the comprehensive review of the EU’s wider acquis on copyright that would arguably be needed to ensure that laws are working for research, education, and cultural rights. Culture is also largely absent, despite ongoing work on the Cultural Compass. 

There is also limited information about planned dialogues with stakeholders. To date, the only one touching on the research sector has been a review of the processes around the Horizon Europe programme. The education sector, in the meantime, has been invited to reflect on the European Education Area. However, there has been no effort to look at how laws in other areas affect research and education. It is also not certain that the Commission will be able to advance its agenda smoothly, as shown by the recent rejection by the Parliament of a position on a legislative package on sustainability.

What KR21 Will Watch Next

In short, there are genuine openings that could make life easier for researchers, educators, readers, and the libraries that serve them—but still plenty to clarify. KR21 will continue to gather evidence, share experiences and champion reforms that enable the free movement of knowledge.


29 October 2025

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