The recent updates are not shown on the linked page, but at graph.openaire.eu/docs/changel....

Maybe the valid reasons referred to could be specifically listed.

The description of the transparency principle still supports data sharing and an obligation to explain why it is not possible (the mentioned valid reasons), but the new standards could provide clearer guidelines.

'Desirable' is used in connection to both Open Science and FAIR data. To me it feels like change from the previous code and the European code. If you don't take reproducibility into account, you could discuss where to concentrate our efforts to make data Open and FAIR, but is 'wenselijk' clear?

On Open Data: a reference to a specific list of valid reasons to not make data public is still included, but I miss the translation of 'as open as possible, as closed as necessary'. I also feel the word 'wenselijk' (desirable) may leave more room for interpretation than 'gepast' (appropriate).