As per a report by PPC Land, Advocate General Laila Medina delivered her opinion on October 15 in Case C-568/25, Association for Consumer Information (VKI) v Universal Versand GmbH, which the Austrian Supreme Court referred to the Court of Justice of the European Union. Universal Versand, a mail-order company operating in Austria, runs automated credit assessments before offering invoice or instalment payment, with a third-party company assessing new customers. PPC Land quotes the Advocate General as proposing that excluding a customer from payment methods "has legal effect on that customer or at least similarly significantly affects that customer if it is likely to prevent the conclusion of the sales contract," so that Article 22 of the General Data Protection Regulation (GDPR) applies.

On data and burden of proof, PPC Land quotes the opinion as saying a controller "may only collect and use data that is objectively suitable and strictly necessary for achieving the purpose pursued," with the burden of proof on the company. On necessity, the Advocate General proposes that the automation itself, not only the decision, must be necessary, which the company must show on objective factors, including that "no less intrusive alternative is available." An Advocate General's opinion is not binding. The Court of Justice will rule later, and the Austrian court will then apply that ruling to the company's practice.