This paper is a response to the public consultation regarding the Digital Omnibus Proposal (DOP) by the European Commission. The DOP introduces amongst others two important changes that directly impact archiving by a state archive. First, the DOP merges the Open Data Directive (ODD), the Data Act (DA) and the Data Governance Act (DGA) into one data law. Second, the DOP introduces changes to the General Data Protection Regulation (GDPR), NIS2 Directive, CER Directive, the Regulation on the single digital gateway, EU Data Protection Regulation and the ePrivacy Directive, and annuls the Regulations 2018/1807 and 2019/1150. This position focuses on these two changes and proposes concrete improvements to better align the planned legislative reform with the essential state activity of public archiving. Without such amendments, we see a risk that the role public archiving plays for democratic accountability is (further) undermined.The Belgian State Archives propose the following changes to the Digital Omnibus Proposal in order to better enable the crucial functioning of archival institutions: (a) reconsider the merging of the Open Data Directive, the Data Governance Act and the Data Act; (b) clarifying the legal regime for documents; (c) defining and recentring the archives.