The EDPB has launched a public consultation on Recommendations 1/2026, focused on the approval process and required elements for Processor Binding Corporate Rules (BCR-P) under Article 47 GDPR. The consultation opened on 19 January 2026 and runs until 2 March 2026.
BCRs are a recognised transfer mechanism for multinational groups, allowing internal transfers of personal data across borders where appropriate safeguards and enforceable rights are established. Processor BCRs are particularly relevant to global service providers and outsourcing groups that process personal data on behalf of controllers in multiple jurisdictions. The EDPB’s consultation signals continued regulatory attention on transfer governance — not just on the legal paperwork, but on the operational reality of how protections are implemented and maintained.
The timing matters. Since Schrems II, transfer compliance has been shaped by the need to demonstrate “essentially equivalent” protection, and organisations have increasingly leaned on SCCs with supplementary measures. BCRs remain attractive for certain group structures because they provide a durable internal framework, but they are complex to prepare, approve, and maintain. The EDPB’s work here aims to tighten clarity and alignment on what an approvable BCR-P looks like and how authorities should assess applications.
For organisations considering BCRs, the consultation is an opportunity to anticipate where regulators will focus: governance and accountability, audit and monitoring obligations, complaint handling, enforceability, training, and practical commitments around onward transfers and third-country access risks.
Acompli perspective: Transfer compliance tends to fail when it is treated as a legal project rather than a repeatable operational programme. Whether you use SCCs, BCRs, or a mix, the credible posture is the same: defined ownership, documented assessments, technical controls, and a living record of decisions. Tools that keep transfer assessments and vendor transfer maps current are increasingly valuable as regulators scrutinise not only the mechanism, but the evidence behind it.