# C_2018081EN.01017601.xml

| 2.3.2018 | EN | Official Journal of the European Union | C 81/176 |
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2.3.2018

EN

Official Journal of the European Union

C 81/176

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Opinion of the European Economic and Social Committee on the ‘Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions on European Interoperability Framework — Implementation Strategy’

(COM(2017) 134 final)

(2018/C 081/24)

| Rapporteur: | Brian CURTIS |
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Rapporteur:

Brian CURTIS

Brian CURTIS

| Consultation | European Commission, 31.5.2017 |
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| Legal basis | Article 304 of the Treaty on the Functioning of the European Union |
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| Section responsible | Transport, Energy, Infrastructure and the Information Society |
| Adopted in section | 2.10.2017 |
| Adopted at plenary | 18.10.2017 |
| Plenary session No | 529 |
| Outcome of vote
  (for/against/abstentions) | 180/2/0 |

Consultation

European Commission, 31.5.2017

Legal basis

Article 304 of the Treaty on the Functioning of the European Union

Section responsible

Transport, Energy, Infrastructure and the Information Society

Adopted in section

2.10.2017

Adopted at plenary

18.10.2017

Plenary session No

529

Outcome of vote

(for/against/abstentions)

180/2/0

1.   Conclusions and recommendations

Conclusions and recommendations

Conclusions

Conclusions

| 1.1. | The digital economy, especially its associated and supporting public service framework, is vital to the smooth and efficient functioning of civil society in the EU. The Committee welcomes the continuous progress and support provided by the European Commission in this further development of the European Interoperability Framework (EIF). |
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1.1.

The digital economy, especially its associated and supporting public service framework, is vital to the smooth and efficient functioning of civil society in the EU. The Committee welcomes the continuous progress and support provided by the European Commission in this further development of the European Interoperability Framework (EIF).

| 1.2. | The Communication indicates further advances in the advisory and cohesive role which DG DIGIT is playing in encouraging Member States and their public administrations at all levels to seamlessly interconnect. |
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1.2.

The Communication indicates further advances in the advisory and cohesive role which DG DIGIT is playing in encouraging Member States and their public administrations at all levels to seamlessly interconnect.

| 1.3. | The Committee nevertheless notes that interoperability capacity varies considerably between and within Member States. The current consensus is that regulation or mandatory governance procedures remain off-limits but this places a greater responsibility on Member States to voluntarily engage in every possible way with the spirit and substance of the EIF and its implementing programmes. Security and privacy continue as one of the 12 principles of the EIF and the EESC notes positively that these principles are elaborated in some detail and are the subject of two clear recommendations in the Interoperability Implementation Plan. By its nature the EIF offers a broad framework within which Member States can exercise their subsidiarity rights but it is undoubtedly the case that public unease about personal data ownership, use and security is widespread and common concerns are shared across Europe. Such issues are linked to the fundamental rights enshrined in the EU Treaties. |
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1.3.

The Committee nevertheless notes that interoperability capacity varies considerably between and within Member States. The current consensus is that regulation or mandatory governance procedures remain off-limits but this places a greater responsibility on Member States to voluntarily engage in every possible way with the spirit and substance of the EIF and its implementing programmes. Security and privacy continue as one of the 12 principles of the EIF and the EESC notes positively that these principles are elaborated in some detail and are the subject of two clear recommendations in the Interoperability Implementation Plan. By its nature the EIF offers a broad framework within which Member States can exercise their subsidiarity rights but it is undoubtedly the case that public unease about personal data ownership, use and security is widespread and common concerns are shared across Europe. Such issues are linked to the fundamental rights enshrined in the EU Treaties.

Recommendations

Recommendations

| 1.4. | The EESC would welcome the full engagement of the Member States and the European Union institutions to implement the EIF. |
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1.4.

The EESC would welcome the full engagement of the Member States and the European Union institutions to implement the EIF.

| 1.5. | Although cyber security does not fall within the competences of this Communication it is clear that reassurances need to be provided in other EU legislative instruments to ensure that greater interoperability and public access does not mean greater vulnerability by penetration from the increasing threat of cyber attack. |
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1.5.

Although cyber security does not fall within the competences of this Communication it is clear that reassurances need to be provided in other EU legislative instruments to ensure that greater interoperability and public access does not mean greater vulnerability by penetration from the increasing threat of cyber attack.

| 1.6. | Another shared concern is how to support those unable to engage, for various reasons, with the rapidly expanding and pervasive world of digital services. The EESC urges Member States to embrace the EIF recommendations related to user-centricity, in particular the one that calls for a multi-channel delivery, physical and digital, of digital public services. |
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1.6.

Another shared concern is how to support those unable to engage, for various reasons, with the rapidly expanding and pervasive world of digital services. The EESC urges Member States to embrace the EIF recommendations related to user-centricity, in particular the one that calls for a multi-channel delivery, physical and digital, of digital public services.

| 1.7. | The EESC has some concern that the action points do not define goals and appear to be a shared responsibility between Member States and the Commission. A statement of clearer responsibilities and an indication of priorities would assist the allocation of resources. |
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1.7.

The EESC has some concern that the action points do not define goals and appear to be a shared responsibility between Member States and the Commission. A statement of clearer responsibilities and an indication of priorities would assist the allocation of resources.

| 1.8. | Greater clarity is needed on how the requirement for a focus on the needs of business and the citizen (user-centric services) can be implemented. |
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1.8.

Greater clarity is needed on how the requirement for a focus on the needs of business and the citizen (user-centric services) can be implemented.

| 1.9. | The Committee recommends that citizens and business events and related procedures, included in the Commission’s adopted proposal COM(2017) 256 Annex II, are given priority when it comes to measuring EIF’s implementation level. |
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1.9.

The Committee recommends that citizens and business events and related procedures, included in the Commission’s adopted proposal COM(2017) 256 Annex II, are given priority when it comes to measuring EIF’s implementation level.

| 1.10. | The Committee notes that the active work of the National Interoperability Framework Observatory (NIFO) is providing a sound basis for future recommendations. This could be the basis for a possible statutory instrument in two to three years’ time which could resolve outstanding issues. |
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1.10.

The Committee notes that the active work of the National Interoperability Framework Observatory (NIFO) is providing a sound basis for future recommendations. This could be the basis for a possible statutory instrument in two to three years’ time which could resolve outstanding issues.

2.   Introduction

Introduction

| 2.1. | The completion of the Digital Single Market (DSM) is one of the European Commission’s 10 political priorities and could contribute EUR 415 billion per year to Europe’s economy, create jobs and transform public services. The need for public administrations to collaborate digitally is a vital element of the DSM. The public sector accounts for more than 25 % of total employment and represents a fifth of the EU’s GDP through public procurement. The growth of student exchange, tourism, migration, cross-border business development and online shopping all reinforce the need for interoperability in many areas. |
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2.1.

The completion of the Digital Single Market (DSM) is one of the European Commission’s 10 political priorities and could contribute EUR 415 billion per year to Europe’s economy, create jobs and transform public services. The need for public administrations to collaborate digitally is a vital element of the DSM. The public sector accounts for more than 25 % of total employment and represents a fifth of the EU’s GDP through public procurement. The growth of student exchange, tourism, migration, cross-border business development and online shopping all reinforce the need for interoperability in many areas.

| 2.2. | The European Interoperability Framework (EIF) was first adopted in 2010. It gave specific guidance to public administrations on how to establish interoperable public services through recommendations based on underlying interoperability principles and conceptual models. |
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2.2.

The European Interoperability Framework (EIF) was first adopted in 2010. It gave specific guidance to public administrations on how to establish interoperable public services through recommendations based on underlying interoperability principles and conceptual models.

| 2.3. | The Interoperability Solutions for European Public Administrations (ISA) programme (2010-2015), and its successor the ISA2 programme (2016-2020), are the main instruments through which the EIF of 2010 has been implemented. |
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2.3.

The Interoperability Solutions for European Public Administrations (ISA) programme (2010-2015), and its successor the ISA2 programme (2016-2020), are the main instruments through which the EIF of 2010 has been implemented.

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| 2.4. | Since 2010, European policies and initiatives impacting the public sector have either evolved, such as the revised Directive on the reuse of public sector information, the eIDAS regulation (1) and the eGovernment Action plan 2016-2020, or are currently under preparation, such as the Single Digital Gateway and the Free Flow of (non-personal) Data across borders. |
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2.4.

Since 2010, European policies and initiatives impacting the public sector have either evolved, such as the revised Directive on the reuse of public sector information, the eIDAS regulation (1) and the eGovernment Action plan 2016-2020, or are currently under preparation, such as the Single Digital Gateway and the Free Flow of (non-personal) Data across borders.

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| 2.5. | Information technology is a fast-moving field in areas such as open data and cloud computing. |
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2.5.

Information technology is a fast-moving field in areas such as open data and cloud computing.

| 2.6. | The above policy and technology related points together with the need to review the EIF’s effectiveness resulted in a stakeholder consultation in 2016 which analysed needs and problems faced by stakeholders with regards to interoperability and the implementation of the EIF, identified impacts which might arise from expected revisions, and collected feedback on added value. |
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2.6.

The above policy and technology related points together with the need to review the EIF’s effectiveness resulted in a stakeholder consultation in 2016 which analysed needs and problems faced by stakeholders with regards to interoperability and the implementation of the EIF, identified impacts which might arise from expected revisions, and collected feedback on added value.

| 2.7. | As a result the new framework puts more emphasis on how interoperability principles and models should apply in practice and clarifies the centrality of the EIF in linking national and domain-specific frameworks. The number of recommendations has increased from 25 to 47 in a way that the updated and newly introduced interoperability recommendations are made more specific to facilitate their implementation, with a stronger focus on openness and information management, data portability, interoperability governance, and integrated service delivery. |
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2.7.

As a result the new framework puts more emphasis on how interoperability principles and models should apply in practice and clarifies the centrality of the EIF in linking national and domain-specific frameworks. The number of recommendations has increased from 25 to 47 in a way that the updated and newly introduced interoperability recommendations are made more specific to facilitate their implementation, with a stronger focus on openness and information management, data portability, interoperability governance, and integrated service delivery.

3.   Gist of the Commission Communication

Gist of the Commission Communication

| 3.1. | The Communication offers a general overview, review and analysis of progress to date and priorities for the future. Annex I of the Communication sets out 22 actions across five focus areas. This is supported by Annex II which sets out the principles of the new EIF and details of the 47 recommendations. The aim is to provide seamless services and data flows for European public administrations through adherence to the generic framework of the EIF, which is based on the EIF Conceptual Model. |
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3.1.

The Communication offers a general overview, review and analysis of progress to date and priorities for the future. Annex I of the Communication sets out 22 actions across five focus areas. This is supported by Annex II which sets out the principles of the new EIF and details of the 47 recommendations. The aim is to provide seamless services and data flows for European public administrations through adherence to the generic framework of the EIF, which is based on the EIF Conceptual Model.

| 3.2. | For people to be free to work and relocate and for businesses to enjoy the benefits of unhindered trade and capital flows across all Member States, the implementation of efficient digital public services is vital. Member States are modernising their public administrations by introducing widespread digitalisation but, to avoid the risk of creating isolated digital environments and consequently electronic barriers to the four freedoms, interoperability is essential. |
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3.2.

For people to be free to work and relocate and for businesses to enjoy the benefits of unhindered trade and capital flows across all Member States, the implementation of efficient digital public services is vital. Member States are modernising their public administrations by introducing widespread digitalisation but, to avoid the risk of creating isolated digital environments and consequently electronic barriers to the four freedoms, interoperability is essential.

| 3.3. | The framework proposes that good interoperability requires actual and potential barriers to be addressed in legal issues, organisational aspects, data/semantic concerns and technical challenges. The implementation and review of the ISA and ISA2 programmes have gone a long way towards identifying and dealing with these aspects but there remains much to do. |
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3.3.

The framework proposes that good interoperability requires actual and potential barriers to be addressed in legal issues, organisational aspects, data/semantic concerns and technical challenges. The implementation and review of the ISA and ISA2 programmes have gone a long way towards identifying and dealing with these aspects but there remains much to do.

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| 3.4. | The latest data available assesses the alignment of national interoperability frameworks with the EIF at 76 % but national interoperability framework implementation in specific national projects was 56 % in 2016 (2), which shows that there are still difficulties with the practical implementation of the current recommendations. It is therefore clear that further specific guidance is required and this is set out in Annex II. |
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3.4.

The latest data available assesses the alignment of national interoperability frameworks with the EIF at 76 % but national interoperability framework implementation in specific national projects was 56 % in 2016 (2), which shows that there are still difficulties with the practical implementation of the current recommendations. It is therefore clear that further specific guidance is required and this is set out in Annex II.

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| 3.5. | The 12 principles remain practically the same as in the previous EIF but reflect recent policy and technical development. Grouped into four categories they are: | Setting the context for EU actions on interoperability







  1: | Subsidiarity and proportionality |
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3.5.

The 12 principles remain practically the same as in the previous EIF but reflect recent policy and technical development. Grouped into four categories they are:

Setting the context for EU actions on interoperability

Setting the context for EU actions on interoperability

1:

Subsidiarity and proportionality

Core interoperability

Core interoperability

| 2: | Openness |
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2:

Openness

| 3: | Transparency |
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3:

Transparency

| 4: | Reusability |
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4:

Reusability

| 5: | Technological neutrality and data portability |
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5:

Technological neutrality and data portability

Generic user needs and expectations

Generic user needs and expectations

| 6: | User-centricity |
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6:

User-centricity

| 7: | Inclusion and accessibility |
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7:

Inclusion and accessibility

| 8: | Security and privacy |
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8:

Security and privacy

| 9: | Multilingualism |
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9:

Multilingualism

Cooperation among public administrations

Cooperation among public administrations

| 10: | Administrative simplification |
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10:

Administrative simplification

| 11: | Preservation of information |
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11:

Preservation of information

| 12: | Assessment of effectiveness and efficiency. |
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12:

Assessment of effectiveness and efficiency.

| 3.6. | The Communication calls upon public administrations to improve their national governance of interoperability activities, use common operational models to develop better digital public services and include the needs of citizens and businesses from other EU Member States, manage data they own in common semantic and syntactic formats to make it easier to publish it on portals, and to aggregate, share and reuse it. |
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3.6.

The Communication calls upon public administrations to improve their national governance of interoperability activities, use common operational models to develop better digital public services and include the needs of citizens and businesses from other EU Member States, manage data they own in common semantic and syntactic formats to make it easier to publish it on portals, and to aggregate, share and reuse it.

| 3.7. | The Communication presents a consolidated EIF conceptual model based on the synthesis of an interoperability model and a model on integrated public services. This is applicable to all digital public services, with special focus on governance aspects. The exegesis of both the principles and the models is illustrated with 47 specific recommendations. The accompanying Interoperability Action Plan provides further specific implementation suggestions. These add clarity to the conceptual model and also address specific operational issues that were raised in the 2016 consultation. |
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3.7.

The Communication presents a consolidated EIF conceptual model based on the synthesis of an interoperability model and a model on integrated public services. This is applicable to all digital public services, with special focus on governance aspects. The exegesis of both the principles and the models is illustrated with 47 specific recommendations. The accompanying Interoperability Action Plan provides further specific implementation suggestions. These add clarity to the conceptual model and also address specific operational issues that were raised in the 2016 consultation.

| 3.8. | For example, the common problem of legacy systems designed to solve local and domain-specific issues has created fragmented ICT islands. One of the recommendation that addresses this is ‘The use of open specifications, where available, to ensure technical interoperability when establishing European public services’ (Recommendation 33). The Action Plan supports this by elaborating seven action areas (12-18) suggesting specific measures. |
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3.8.

For example, the common problem of legacy systems designed to solve local and domain-specific issues has created fragmented ICT islands. One of the recommendation that addresses this is ‘The use of open specifications, where available, to ensure technical interoperability when establishing European public services’ (Recommendation 33). The Action Plan supports this by elaborating seven action areas (12-18) suggesting specific measures.

4.   General comments

General comments

| 4.1. | The Committee welcomes the further development of the EIF and notes that it is likely that in October 2017 under the Estonian Presidency, there will be a ministerial declaration on eGovernment committing, among other things, to EIF implementation. The EESC recognises the importance of the digital economy to civil society in the EU and through its opinions in recent years has offered constructive views on the Digital Agenda and its successor programme, the DSM (3). |
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4.1.

The Committee welcomes the further development of the EIF and notes that it is likely that in October 2017 under the Estonian Presidency, there will be a ministerial declaration on eGovernment committing, among other things, to EIF implementation. The EESC recognises the importance of the digital economy to civil society in the EU and through its opinions in recent years has offered constructive views on the Digital Agenda and its successor programme, the DSM (3).

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| 4.2. | During the last decade eGovernment Action Plans (4) have been effective political instruments in advancing the modernisation of public administrations across the EU. They have been supporting coordination and collaboration between Member States and the Commission and have led to joint actions on eGovernment of which the EIF is a vital part. |
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4.2.

During the last decade eGovernment Action Plans (4) have been effective political instruments in advancing the modernisation of public administrations across the EU. They have been supporting coordination and collaboration between Member States and the Commission and have led to joint actions on eGovernment of which the EIF is a vital part.

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| 4.3. | The Implementation Strategy for the new European Interoperability Framework reflects many of the recommendations made in previous Committee opinions and emphasises the growing need for urgent and coherent action by public administrations across the EU. Some earlier reservations from Member States about the EIF have now largely been resolved and although there is still some way to go the main difficulties in implementation revolve around resources and legacy issues rather than matters of principle. |
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4.3.

The Implementation Strategy for the new European Interoperability Framework reflects many of the recommendations made in previous Committee opinions and emphasises the growing need for urgent and coherent action by public administrations across the EU. Some earlier reservations from Member States about the EIF have now largely been resolved and although there is still some way to go the main difficulties in implementation revolve around resources and legacy issues rather than matters of principle.

| 4.4. | In our previous opinion on ‘Interoperability as a means for modernising the public sector’ (5) we noted that citizens were increasingly aware of, and concerned by, public administrations’ collection and usage of personal data or data collected more broadly. They are also aware that greater interoperability has implications for how data can be shared and used. This awareness is now at an even greater level and so it is encouraging to see that the issues of security and privacy have been noted and recommendations (Numbers 46-47) made to prioritise action. |
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4.4.

In our previous opinion on ‘Interoperability as a means for modernising the public sector’ (5) we noted that citizens were increasingly aware of, and concerned by, public administrations’ collection and usage of personal data or data collected more broadly. They are also aware that greater interoperability has implications for how data can be shared and used. This awareness is now at an even greater level and so it is encouraging to see that the issues of security and privacy have been noted and recommendations (Numbers 46-47) made to prioritise action.

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| 4.5. | In a fast-moving field such as ICT it is often the case that technical and market developments outpace policy thinking and the legal and regulatory mandate and monitoring capacity. Therefore the Committee fully concurs with the regular review and adjustment approach by the Commission represented in this proposal. In this respect NIFO provides a vital service to the involved stakeholders. Through the NIFO much practical and technical detail supplements the conceptual and legal frameworks. For example, 32 recently updated online factsheets consolidate the latest information about the national interoperability status of participating countries (6). |
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4.5.

In a fast-moving field such as ICT it is often the case that technical and market developments outpace policy thinking and the legal and regulatory mandate and monitoring capacity. Therefore the Committee fully concurs with the regular review and adjustment approach by the Commission represented in this proposal. In this respect NIFO provides a vital service to the involved stakeholders. Through the NIFO much practical and technical detail supplements the conceptual and legal frameworks. For example, 32 recently updated online factsheets consolidate the latest information about the national interoperability status of participating countries (6).

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5.   Specific comments

Specific comments

| 5.1. | The EIF conceptual model for public services covers the design, planning, development, operation and maintenance of integrated public services at all governmental levels from local to EU level. The principles set out here guide decision-making on establishing interoperable European public services with practical tools in the form of a set of actionable items contained in the Interoperability Action Plan. However, the 22 action points do not define goals and appear to be a shared responsibility between Member States and the Commission. This is not a recipe for decisive action and demands greater clarity. It is also the case that some indication of priority might assist in determining how resources are used, especially as such resources are likely to be limited. |
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5.1.

The EIF conceptual model for public services covers the design, planning, development, operation and maintenance of integrated public services at all governmental levels from local to EU level. The principles set out here guide decision-making on establishing interoperable European public services with practical tools in the form of a set of actionable items contained in the Interoperability Action Plan. However, the 22 action points do not define goals and appear to be a shared responsibility between Member States and the Commission. This is not a recipe for decisive action and demands greater clarity. It is also the case that some indication of priority might assist in determining how resources are used, especially as such resources are likely to be limited.

| 5.2. | The Communication and its supporting documents emphasise the requirement for user-centric services but some greater clarity on how these could be achieved would be welcome. It is proposed that the ISA2 programme include an action which will elaborate on this matter, i.e. through developing a framework and guidelines on how to implement user-centricity in practise. |
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5.2.

The Communication and its supporting documents emphasise the requirement for user-centric services but some greater clarity on how these could be achieved would be welcome. It is proposed that the ISA2 programme include an action which will elaborate on this matter, i.e. through developing a framework and guidelines on how to implement user-centricity in practise.

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| 5.3. | The EIF contains a definition of the public services in its scope. These are almost any kind of cross border public services, which may result in difficulty in assessing and monitoring EIF implementation accurately by the NIFO. The Committee recommends that citizens and business events and related procedures, included in the Commission’s adopted proposal COM(2017) 256 Annex II, are given priority when it comes to measuring EIF’s implementation level. |
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5.3.

The EIF contains a definition of the public services in its scope. These are almost any kind of cross border public services, which may result in difficulty in assessing and monitoring EIF implementation accurately by the NIFO. The Committee recommends that citizens and business events and related procedures, included in the Commission’s adopted proposal COM(2017) 256 Annex II, are given priority when it comes to measuring EIF’s implementation level.

| 5.4. | The principle of subsidiarity has been applied relatively effectively in this area up to the present time. This Communication marks a further step in the encouragement of interoperability but there is still some way to go. The Committee suggests that the active work of NIFO is providing a sound basis for future recommendations and will provide the basis for a possible statutory instrument in two to three years’ time which could resolve outstanding issues. |
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5.4.

The principle of subsidiarity has been applied relatively effectively in this area up to the present time. This Communication marks a further step in the encouragement of interoperability but there is still some way to go. The Committee suggests that the active work of NIFO is providing a sound basis for future recommendations and will provide the basis for a possible statutory instrument in two to three years’ time which could resolve outstanding issues.

Brussels, 18 October 2017.

The President of the European Economic and Social Committee

Georges DASSIS

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(1)  The Regulation (EU) No 910/2014 (OJ L 257, 28.8.2014, p. 73) on electronic identification and trust services for electronic transactions in the internal market provides a predictable regulatory environment to enable secure and seamless electronic interactions between businesses, citizens and public authorities.

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(2)  https://ec.europa.eu/isa2/sites/isa/files/docs/publications/report_2016_rev9_single_pages.pdf

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(3)  OJ C 12, 15.1.2015, p. 99; OJ C 487, 28.12.2016, p. 92; OJ C 487, 28.12.2016, p. 99; OJ C 218, 11.9.2009, p. 36.

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(4)  i2010 eGovernment Action Plan 2006-2010 and eGovernment Action Plan 2011-2015.

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(5)  OJ C 12, 15.1.2015, p. 99.

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(6)  https://joinup.ec.europa.eu/community/nifo/og_page/nifo-factsheets

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