What’s new in CIPP/E in 2025?
The world of privacy is evolving at a dizzying pace. Legislators across Europe, North America, and the Asia-Pacific are rolling out new rules that not only protect personal data but also shape how companies can share and monetise information. In Europe, the Data Act entered into force in January 2024 and will apply from 12 September 2025, creating a framework for fair access to data and ensuring that data-sharing does not undermine personal data protection. Meanwhile, the EU AI Act is adding layers of governance around artificial intelligence, with prohibitions on certain AI practices already taking effect on 2 February 2025 and more substantive obligations (including compliance frameworks for high‑risk systems) scheduled for August 2026. This wave of regulation signals that privacy professionals must navigate not only traditional data-protection law but also an emerging intersection with AI governance and digital ethics.
Against this backdrop, the International Association of Privacy Professionals (IAPP) has announced sweeping updates to its Certified Information Privacy Professional / Europe (CIPP/E) certification. Beginning 1 September 2025, the exam will assess candidates on new case law, fresh regulatory opinions, and emerging topics like AI compliance and data‑breach management.
Why 2025 is a Landmark Year for Privacy?
A confluence of regulatory forces makes 2025 a watershed year for privacy. The Data Act focuses on granting users greater control over non‑personal and industrial data while ensuring personal data remains protected. At the same time, global trends highlight the rise of national and regional privacy laws. New U.S. state laws, updated regimes in Asia–Pacific and the Middle East, and debates over “pay or consent” business models all point to a world where organisations must grapple with a patchwork of rules. These developments are not just legal footnotes; they reflect fundamental questions about who owns data, how it can be used, and the balance between innovation and individual rights.
Privacy professionals also face the challenge of aligning AI practices with existing data-protection frameworks. The EU AI Act’s early provisions prohibit certain manipulative AI practices and emphasise the need for AI literacy within organisations.
Later provisions will impose detailed documentation and risk‑management requirements for general‑purpose AI models, impacting companies that build or integrate AI systems. For exam candidates, mastering the interplay between GDPR and AI regulations will be critical to answering scenario‑based questions on the 2025 exam.
Exam Structure at a Glance
Before diving into content updates, it’s essential to understand the exam format. Core IAPP exams, including CIPP/E, consist of 90 multiple‑choice questions. Of these, 75 are scored; the remaining 15 are unscored pre‑test items used to evaluate future questions. You will have 150 minutes (2.5 hours) to complete the exam, including an optional 15‑minute break. Importantly, the clock keeps ticking while you agree to the Candidate Statement and Confidentiality Agreement, so be ready to sign promptly on exam day.
What’s New in CIPP/E in 2025?
CIPP/E Domain‑Wise Comparison: Old vs. New
| Old Domains | New Domains | Description |
| Domain 1: Introduction to European Data Protection | Domain 1: Introduction to European Data | This domain remains largely consistent in scope. |
| Domain 2: European Data Protection Law and Regulation | Domain 2: European Data Protection Law and Regulation | This domain was split into three new domains to provide clearer grouping. |
| Domain 3: European Data Processing | This new domain focuses on the principles and concepts of data processing (formerly part of Domain 2). | |
| Domain 4: European Data Protection: Scope and Accountability | This new domain focuses on territorial scope, roles (controller/processor), and accountability measures (formerly part of Domain 2). | |
| Domain 3: Compliance with European Data Protection Law and Regulation | Domain 5: Compliance with European Data Protection Law and Regulation | This domain remains largely consistent in scope (formerly Domain 3). |
One of the most noticeable changes is the reorganisation of the exam domains. Previously, CIPP/E was structured around three broad domains. Starting in September 2025, it moves to five domains: Rights & Principles, Legal Bases & Compliance Requirements, Controller & Processor Obligations, Cross‑Border Data Transfer Mechanisms, and Corporate Application of GDPR.
This restructuring is largely organisational rather than substantive; the number of questions per topic remains the same, and the core concepts have not been de‑emphasised. The goal is to make the content easier to digest and align the exam more closely with how practitioners actually work.
Here is an overview of the new structure:
- Rights and Principles covers fundamental rights such as transparency, purpose limitation, and data‑subject rights.
- Legal Bases and Compliance Requirements examines lawful bases for processing under Article 6, including legitimate interest, consent, and contract.
- Controller and Processor Obligations focuses on duties under Articles 24–30, including accountability, record‑keeping, and vendor management.
- Cross‑Border Data Transfer Mechanisms explores mechanisms like adequacy decisions, Standard Contractual Clauses (SCCs), and Binding Corporate Rules (BCRs), as well as the one‑stop shop.
- Corporate Application of GDPR deals with practical implementation in areas like employee data, marketing, HR records, and product development.
New EDPB Opinions and Regulatory Guidance
Beyond restructuring, the exam will test new guidance from the European Data Protection Board (EDPB). Opinion 22/2024 clarifies the roles and liabilities in chains of controllers, processors and sub‑processors. It emphasises that processors must vet their sub‑processors, maintain documentation, and alert controllers to changes. Controllers remain accountable for ensuring downstream processors comply with the GDPR; liability does not simply cascade down the chain. Candidates will need to know when joint controller arrangements apply and how risk and responsibility are distributed. The opinion also urges enhanced cooperation during data protection impact assessments (DPIAs) and incident response, meaning privacy teams must coordinate across suppliers and affiliates.
Opinion 04/2024 deals with the main establishment for companies operating in multiple EU member states. It clarifies that the one‑stop shop applies only when a controller’s main establishment has the power to make decisions about processing operations.
The exam also incorporates Guidelines 1/2024 on legitimate interest as a legal basis. Candidates should be prepared to apply the three‑part test: (1) the interest pursued must be lawful and clearly articulated; (2) processing must be strictly necessary; and (3) the interests or rights of data subjects must not override the controller’s interest. Expect hypothetical scenarios where you must determine whether legitimate interest supports data processing in contexts like fraud prevention, behavioural advertising, or employee monitoring.
AI and GDPR: Integrating Data Ethics
CIPP/E 2025 acknowledges that AI is no longer a niche concern but a core component of data‑driven organizations. The updated body of knowledge introduces content on GDPR compliance for AI systems, stressing the principles of fairness, transparency, data minimisation, and accountability. Candidates should understand how to conduct DPIAs for AI models, build explainability into system design, and establish human oversight to mitigate algorithmic bias. The exam may reference AI frameworks like the OECD AI Principles and the NIST AI Risk Management Framework, which emphasise trustworthy AI and risk-based approaches to design.
Breach Notification and Incident Response
Data breaches have become headline news, and the GDPR’s stringent notification requirements are central to compliance. The updated exam amplifies coverage of Articles 33 and 34, which govern breach notification and communication to individuals. Candidates must distinguish between general security incidents and notifiable breaches. The exam will test how to evaluate the risk to individuals, including whether compromised data could lead to financial loss, identity theft, or discrimination. The updated material also emphasises incident response planning and breach documentation.
Additional Topics: Data Act, Privacy & Security Incidents, and More
The 2025–26 body of knowledge introduces several new sub‑topics beyond those discussed above. Candidates should be aware of the European Data Act, which, while focused on non‑personal data, includes provisions on data sharing and user rights that intersect with GDPR obligations. Other additions include the intersection of privacy and security, such as ensuring that cybersecurity measures align with privacy principles and do not lead to excessive monitoring or data collection.
The exam also devotes more attention to privacy and security incidents, such as understanding differences between data breaches and other security incidents, developing incident‑response templates, and learning cross‑border coordination.
CIPP/E Training with InfosecTrain
The 2025 CIPP/E updates underscore how privacy law now intertwines data protection fundamentals with AI governance and cross-border data sharing. Mastering the new five-domain structure, updated EDPB opinions, and AI-specific compliance guidelines is essential for navigating an exam comprising 90 scenario-based questions in just 2.5 hours.
InfosecTrain’s CIPP/E training aligns perfectly with these changes. As an official IAPP partner, our program covers the revised body of knowledge, including rights and principles, new lawful-basis guidance, cross-border transfers, and practical breach-response drills, while simulating the updated exam format through case-study-driven lessons and practice tests. If you want to confidently tackle the latest CIPPE exam and apply your knowledge in real‑world situations, enroll in InfosecTrain’s CIPP/E training today and turn these updates into your competitive advantage.
TRAINING CALENDAR of Upcoming Batches For CIPP/E
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