COMMISSION STAFF WORKING DOCUMENT Revision of the European Interoperability Framework - Analysis Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions European Interoperability Framework – Implementation Strategy
Date: 2017-03-23
Institutions: Directorate-General for Digital Services, European Commission
Subjects: EU programme, administrative cooperation, cooperation policy, digital technology, electronic government, exchange of information, information technology applications, public authorities, single market

EN 

   EN 

   EUROPEAN COMMISSION  Brussels, 23.3.2017  SWD(2017) 112 final   COMMISSION STAFF WORKING DOCUMENT Revision of the European Interoperability Framework - Analysis Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions European Interoperability Framework – Implementation Strategy {COM(2017) 134 final} {SWD(2017) 113 final}  
 
 
Contents 

1 

2 

2.1 

2.2 

2.3 

3 

4 

Background and policy context .................................................................................... 3 

Problems, causes and benefits ...................................................................................... 6 

Problems ................................................................................................................................... 6 

Underlying causes and consequences ....................................................................................... 9 

Benefits of interoperability ..................................................................................................... 11 

Key insights from the consultation process ............................................................... 13 

Conclusion ................................................................................................................. 19 

TABLE OF FIGURES 

Figure 1 Average NIF implementation level in 2015 .............................................................................. 7 
Figure 2 Estimated costs for implementing the EIF recommendations ................................................. 15 
Figure 3 EIF Recommendations’ implementation complexity.............................................................. 16 
Figure 4 Estimated benefits for implementing the EIF recommendations ............................................ 17 
Figure 5 EIF areas of contribution ........................................................................................................ 18 

2 

 
 
 
 
 
BACKGROUND AND POLICY CONTEXT 

1 
The European public sector plays a key role in the Digital Single Market (DSM) strategy.1 It 
ensures that: 

  citizens  across  the  EU  have  at  their  disposal  fully  automated  end-to-end  digital 
services, enabling them to request certificates, declare taxes, register as a resident, take 
up a job, have professional qualifications recognised, enrol children at school, register 
a car, etc.; 

  businesses  operating  across  the  EU  also  have  at  their  disposal  end-to-end  digital 
services, enabling them to register as a legal entity, start a new business, declare taxes, 
participate in public procurements, etc.; 

  data  owned  by  public  administrations,  e.g.  population,  company,  environmental, 
financial,  transport,  health,  etc.,  can  be  efficiently  collected,  reused,  analysed, 
aggregated and published as open data whenever possible. 

For  the  above  to  happen,  public  administrations,  citizens  and  businesses  should  be  able  to 
interact between each other so that: 

i. 

existing public services can be easily identified, reached and used;  

ii.  when new services are built they become linked with other services and they fully or 
partly reuse other similar existing services as much as possible. It is the equivalent of 
building roads to link isolated cities so that people can move, work and do business. 

This  concept  of  digital  interaction  between  concerned  stakeholders  with  the  purpose  of 
exchanging information towards mutually beneficial goals is called ‘interoperability’. 

An  (already  implemented)  example  of  this  is  a  request  from  a  citizen  working  abroad  for 
recognition of her/his professional qualifications. Having interoperability in place implies that 
the  citizen  could  simply  submit  the  request  to  the  responsible  authority  in  the  country  of 
residence. This authority in turn uses a dedicated multilingual IT system2 to get in touch with 
the  authority  of  the  requestor’s  home  country  and  ask  for  the  certificate’s  validation. 
Everything  is  done  through  an  automated  exchange  of  information  between  the  relevant 
authorities  of  both  countries,  without  the  citizen’s  involvement.  Interoperability  makes  it 
feasible for different existing authorities to work together across countries, through the use of 
an  IT  system,  multilingualism,  a  common  specification  for  the  structure  of  the  exchange 
information, etc. 

Similar interoperable information systems and services should be put in place. This involves 
ensuring that:  

1  COM(2015)  192  final,  Communication  from  the  Commission  to  the  European  Parliament,  the  Council,  the 
European Economic and Social Committee and the Committee of the Regions - A Digital Single Market Strategy 
for Europe, Brussels, 06.05.2015. 
2 Internal Market Information system (IMI). 

3 

 
 
                                                            
i. 

ii. 

iii. 

iv. 

at national and European levels, there are portals that include complete catalogues of 
the available public services;  

those  services  are,  to  a  reasonable  extent,  multilingual  and  linked  with  national 
registries (land, population, insolvency, business, etc.);  

trust is in place so that citizens and businesses agree to submit their data and can track 
how it is used; 

automation  is  sufficient  to  allow  for  once-only  submission  of  personal  information 
while minimising manual input. 

Interoperability  is  a  universal  requirement  for  a  variety  of  EU  policies,  such  as  the  single 
market,  environment,  home  affairs  and  justice,  health,  customs,  taxation,  regional  policy, 
research  and  innovation,  public  procurement,  etc.  In  all  these  policies  the  need  to  ensure 
linkage and exchange of information between Member States’ public administrations, citizens 
and  businesses  is  indeed  embedded  in  the  corresponding  legislation  and  implementing 
instruments. 

In  response  to  the  need  for  interoperability,  the  Commission  has  launched  a  series  of 
initiatives,  that  resulted  inter-alia,  in  the  programme  on  interoperability  solutions  and 
common frameworks for European public administrations, businesses and citizens ISA²,3 the 
Connecting  Europe  Facility4  (CEF),  the  INSPIRE5  Directive.  The  2010  Communication 
‘Towards interoperability for European public services’6 set out recommendations to support 
the  implementation  of  interoperability  at  national  and  EU  levels.  The  Communication 
included:  

  a  European  Interoperability  Framework7  (EIF)  which  has  been  embraced  by  the 
Member States and is being used as a paradigm for their own national interoperability 
frameworks (NIFs) and strategies;  

  a European Interoperability Strategy8 (EIS) to set out interoperability priorities. 

In the DSM strategy, the Commission announced its intention to revise and extend the EIF9 in 
order to: 

3 Decision (EU) 2015/2240 of the European Parliament and of the Council of 25 November 2015 establishing a 
programme  on  interoperability  solutions  and  common  frameworks  for  European  public  administrations, 
businesses and citizens (the ISA2 programme) as a means for modernising the public sector. 
4 Regulation (EU) No 283/2014 of the European Parliament and of the Council of 11 March 2014 on guidelines 
for  trans-European  networks  in  the  area  of  telecommunications  infrastructure  and  repealing  Decision  No 
1336/97/EC. 
5  Directive  2007/2/EC  of  the  European  Parliament  and  of  the  Council  of  14  March  2007  establishing  an 
Infrastructure for Spatial Information in the European Community, INSPIRE OJ L 108, 25.4.2007, p. 1. 
6  COM(2010)  744  final,  Communication  from  the  Commission  to  the  European  Parliament,  the  Council,  the 
European  Economic  and  Social  Committee  and  the  Committee  of  Regions  Towards  interoperability  for 
European public services, Brussels, 16.12.2010. 
7 COM(2010) 744 final: Annex 2. 
8 COM(2010) 744 final: Annex 1. 
9  Page  16  of  the  Communication:  ‘The  Commission  will  revise  and  extend  the  European  Interoperability 
Framework’. 

4 

 
 
                                                            
i. 

align with recent policy developments such as the DSM and actions included in it such 
as  the  single  digital  gateway,  the  eIDAS  Regulation,10  the  revised  Directive  on  the 
reuse of public sector information,11 and the European cloud initiative;12  

ii. 

align with emerging technological trends, such as cloud computing, big and open data;  

iii. 

iv. 

take  into  account  the  lessons  learned  from  the  implementation  of  the  current  EIF 
version by national public administrations;  

focus  on  the  implementation  of  the  EIF  through  addressing  more  specific 
recommendations. 

Interoperability is also recognised as a booster for the delivery of eGovernment services in the 
EU  eGovernment  action  plan  2016-202013  and  the  revision  of  the  EIF  is  one  of  the  listed 
actions.14  

The  updated  EIF  recommendations,  annexed  to  the  Communication  which  this  document 
accompanies, were increased from 25 in the existing EIF to 47 and consist of two types: 

1.  the existing ones that will be kept unchanged, 

2.  recommendations  that  are  genuinely  new  or  substantially  amended  to  better  clarify 

them.15 Main areas having undergone changes include: 

  open data: promoting open government data by default, of high quality, machine-

readable and made available with clear usage licences; 

 

information  management:  advising  administrations  to  treat  information  as  a 
valuable corporate asset and submit information ‘once-only’; 

  data portability, which together with the above two points contributes to enabling 

seamless flows of data between concerned public services; 

 

legal interoperability:  promoting  the  notion  of  ‘interoperability  checks’  to  enable 
the identification of interoperability barriers in new and existing legislation; 

  service  catalogues,  which  are  linked  with  the  single  points  of  contact  in  the 

Services Directive and with the single digital gateway; 

  base registries accessibility, as an enabler of the ‘once-only’ principle. 

10 Regulation (EU) No 910/2014 of the European Parliament and of the Council of 23 July 2014 on electronic 
identification  and  trust  services  for  electronic  transactions  in  the  internal  market  and  repealing  Directive 
1999/93/EC. 
11 2003/98/EC, revised by Directive 2013/37/EU. 
12  COM/2016/0178  final,  Communication  from  the  Commission  to  the  European  Parliament,  the  Council,  the 
European  Economic  and  Social  Committee  and  the  Committee  of  the  Regions  -  European  Cloud  Initiative  - 
Building a competitive data and knowledge economy in Europe. 
13  COM(2016)  179  final,  Communication  from  the  Commission  to  the  European  Parliament,  the  Council,  the 
European  Economic  and  Social  Committee  and  the  Committee  of  the  Regions  -  EU  eGovernment  action  plan 
2016-2020. 
14  COM(2016)  179  final,  page  6:  ‘The  Commission  will  present  a  revised  version  of  the  European 
Interoperability Framework (EIF) and support its take-up by national administrations for the period 2016-2019’. 
15 i.e. in the proposed EIF all 12 principles are linked with a total of 19 recommendations, as opposed to the 
existing EIF where the same 12 principles were served only by eight recommendations. 

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The  implementation  of  the  revised  EIF  at  national  level  should  always  be  guided  by  the 
proportionality  principle  (1st  principle  and  recommendation  of  the  EIF)  that  gives  sufficient 
freedom to  Member States  administrations to tailor their interoperability activities in such  a 
way  that  national  particularities  are  respected,  i.e.  level  of  administration  or  type  of  public 
service where the EIF should apply.  

As  with  the  original  EIF,  the  Communication  provides  organisational,  financial  and 
operational directions and an interoperability action plan (Annex 1 of the Communication) to 
implement the revised EIF recommendations. 

2 

2.1 

PROBLEMS, CAUSES AND BENEFITS 

Problems 

Fragmented delivery of digital public services in the EU 

Public  administrations  at  national  level  establish  their  own  operational  models  and  develop 
their  own  business-specific  information  systems  and  networks,  without  always  interacting 
with  other  public  administrations.  They  also  deliver  public  services  to  their  citizens  and 
businesses, mainly within the area of their responsibility and not always using digital means. 
This delivery focuses on national needs, often ignoring those of citizens and businesses from 
other Member States. 

The  above  are  chronic  issues.  The  adoption  by  the  Commission  of  the  EIF  in  2010  was  a 
substantial  effort  to  give  guidance  to  the  Member  States  on  how  to  organise  their  national 
interoperability  activities.  Since  then,  the  Commission  has  been  monitoring  the  extent  to 
which  the  EIF  has  been  taken  into  account  for the  national  interoperability  frameworks  and 
digital strategies, by measuring two indicators:  

i. 

ii. 

the level of alignment between the EIF and NIFs, namely the degree of taking the EIF 
into account when preparing national frameworks or policies;16  

the level of NIF implementation, namely the amount of projects completed following 
the recommendations of  the NIF.17  

In  2014  a  very  good  level  of  72 %  alignment  was  reached,  while  the  NIF  implementation 
stood lower at 28.4 % for the 19 countries included in the ‘State of Play of Interoperability in 
Europe - Report 201418’.  

16 Different Member States have different ways of dealing with interoperability at high level: some introduce it 
in law, some in specific national interoperability frameworks, some in their digital strategies, and others use a 
collection of different documents and references. A NIF could be any or a combination of the above. 
17 As examples: the Netherlands implements the reusability principle with legislation on the use of the generic 
digital infrastructure (GDI) reusable building blocks (set of standards, products and services) by all governments, 
public organisations and even private parties; Luxembourg implements organisational interoperability by putting 
in place a Business Process Management Office (BPMO). 
18 http://ec.europa.eu/isa/documents/publications/2014-report-on-state-of-play-of-interoperability.pdf. 

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In  2015,  18  assessed  countries  scored  better  in  terms  of  implementation,  i.e.  45 %,  as 
presented  in  the  ‘NIFs  Implementation  and  Monitoring  State  of  Play  201519’,  with  10 
countries scoring over 50 %, and four of them scoring over 80 %, as depicted in Figure 1. 

 However there is a noticeable gap between countries, with Spain hitting 97.8 % and Hungary 
only  3.3 %. It is  worth mentioning that  the average level of implementation  increased  year-
over-year by 17 % compared to 2014. 

Figure 1 Average NIF implementation level in 2015 

Source: NIFs Implementation and Monitoring State of Play Report 2015. 

The  wide  divergence  in  the  scores  reflects  the  different  maturity  levels  of  the  NIFs  in  the 
analysed  countries.  This  is  due  to  the  fact  that  some  countries  have  only  recently  started  to 
work on interoperability and on establishing a NIF, while in other cases those activities date 
back several years. 

In 2012, more than 13.6 million EU citizens lived and worked in a Member State other than 
theirs.20  All  these  people  have  to  register  for  a  pension,  declare  taxes,  receive  a  birth 
certificate,  enrol  in  a  school,  request  an  ID  card,  etc.  Companies  doing  businesses  cross-
border also need to interact online with public administrations to register a new legal entity, 
consult business registries, pay taxes, participate in public procurements, etc. 

Despite  the  fact  that  public  administrations  of  Member  States  continue  to  digitise  their 
services and improve their interactions, the fragmented delivery of digital public services still 
exists.  Services  are  often  developed  in  isolation  or  with  limited  interaction  with  each  other, 
and data is not  always efficiently shared. Therefore governance of interoperability activities 
may  need  to  be  further  improved.  Fully  linked  (end-to-end)  cross-border  digital  public 
services barely exist in Europe, as remaining digital fragmentation at national level prevents 

19  https://joinup.ec.europa.eu/sites/default/files/2015_report_implementation_monitoring_final.pdf.  Figures  for 
2015 on alignment are not available, and therefore cannot be reported. 
20 EU citizenship statistics on cross-border activities provided by Eurostat. 

7 

 
 
 
                                                            
their  implementation  at  European  level.  Cross-border  services  have  to  liaise  with  different 
national  public  services,  information  systems,  data  repositories  and  networks  which  if 
isolated, not fully digitised or difficult to access create barriers in the implementation of the 
DSM. 

The EU-28 Digital Economy and Society Index (DESI) weighted score for eGovernment21 in 
2016,  stands  only  at  55.4 %.  The  degree  to  which  public  services  are  delivered  by  digital 
means varies between the Member States. The DESI for digital public services shows that in 
2015  there  was  a  significant  gap  between  the  high-scorer  Estonia  (86.6 %)  and  Bulgaria, 
which  scored  the  lowest  (33 %).  Likewise,  when  it  comes  to  cross-border  services,  the 
eGovernment benchmark insight report indicator for cross-border mobility shows a weighted 
average  performance  of  only  48 %  in  201422  and  the  single  market  scoreboard  report  for 
201423 (in the context of the points of single contact under the Services Directive) recognises 
that cross-border accessibility is still the highest barrier for cross-border trade. 

The  relationship  between  interoperability  and  digital  public  services  is  proven  by  the 
observation that countries scoring well in digital services scoreboards (DESI, eGovernment, 
single market) similarly occupy a high position in the interoperability scoreboard. 

As shown above, the current landscape shows a digital fragmentation at national level. This 
means  that  national  digital  public  services  are  far  from  becoming  end-to-end.  This  in  turn 
results  in  even  deeper  digital  fragmentation  at  EU  level,  as  identified  in  the  DSM  and 
measured in the digital and single market scoreboards. 

Fragmentation in the organisation and format of public data in the EU   

Public  administrations  have  to  manage  and  host  large  amounts  of  data  generated  by 
themselves  as  well  as  from  various  organisations  working  with  or  on  behalf  of  the  public 
sector, i.e. academia, research institutes, NGOs, etc. There can be different kinds of data such 
as:  citizens’  and  businesses’  identification  records;  transport  data  related  to  parking  places, 
events  and  planned  road  works,  location  of  cameras;  financial  data  on  taxation,  allowances 
and  payments;  environmental/meteorological  data  related  to  weather,  floods,  pollution, 
geospatial  maps  and  photos;  health  data  related  to  diseases,  statistics  on  use  of  alcohol, 
smoking. There is a wide-spread use of different kinds of data in different formats (pure text, 
in  databases,  images,  videos,  etc.)  and  different  security  and  confidentiality  requirements  in 
relation  to  its  use,  and  methods  to  govern  and  organise  it.  This  data  is  used  by  public 
administrations to fulfil their administrative obligations. Often this data is not covered by any 

21 It comprises, number of users, pre-filled forms, online service completion and open data. 
22  It  includes  four  indicators  in  2014:  user  centricity,  transparent  government,  cross-border  mobility  and  key 
enablers for eGovernment. Data collection was based on mystery shopping and 27000 user surveys for the EU-
28+.  Each  of  the  indicators  is  further  broken  down  in  sub-indicators  and  receives  an  overall  score  from  0 % 
(weakest performance) to 100 % (best possible performance). 
23 
psc_en.pdf . 

http://ec.europa.eu/internal_market/scoreboard/_docs/2015/09/points-of-single-contact/2015-09-scoreboard-

8 

 
 
                                                            
specific  legal  regime  requiring  their  confidentiality  and  can  therefore  be  made  publicly 
available.  The  value  of  public  open  data  is  well-known.  It  can  be  reused  by  different 
administrations  within  the  public  sector  to  improve  the  quality  of  public  services,  by 
businesses  for  commercial  purposes,  thus  contributing  to  innovation  and  to  the  digital 
economy, and by citizens to increase their awareness about political and social life. 

Today  public  administrations  digitise,  exchange  and  often  publish  their  data  on  portals,  as 
open data. However when doing so they create many different poles of data often in different 
formats. This makes it difficult to aggregate, share and reuse the data. It means that there is 
scope for further improvement in order to have data and metadata in a syntactic and semantic 
shape  that  can  be  easily  federated,  aggregated,  retrieved  and  searched.  There  is  a  need  for 
interoperability  between  the  different  sets  of  data  (datasets),  met  through  developing 
specifications and standards, software tools, as well as proposing methods for governing the 
collection, interconnection, use and update of this data. 

Today public data comes in different formats, which does not allow it to be fully exploited. 

2.2 

Underlying causes and consequences 

Incoherent governance of actions to implement interoperability 

Public services operate in  a complex environment,  involving different legislations, levels of 
administration,  information  systems  and  specifications.  For  interoperability  to  apply  there 
needs  to  be  a  common  vision  and  shared  objectives.  A  common  set  of  priorities  should  be 
identified, including agreed implementation timeframes. Interoperability initiatives should be 
monitored and reported to appointed responsible authorities that have the power to decide and 
put the necessary measures in place. 

At EU level, efforts have been made through the existing EIS and initiatives such as the ISA² 
programme  (and  its  predecessors)  to  bring  relevant  stakeholders  together  to  identify  and 
discuss interoperability needs and priorities. The interoperability landscape has been drawn to 
a  certain  extent  and  targeted  actions  have  been  taken.  However  more  intense  governance, 
coordination  and  monitoring  at  national  and  EU  levels  are  needed  to  encourage  different 
public administrations to work together and establish a more comprehensive overview of the 
interoperability environment. 

Cross-organisation barriers 

Public administrations often tend to work in relative isolation, without fully considering well 
in  advance  the  need  to  be  part  of  a  wider  organisational  environment.  They  sometimes  put 
more  emphasis  on  their  own  individual  needs,  often  ignoring  the  future  potential  of  being 
interconnected  or  reusing  data  from  other  sources.  The  costs  and  benefits  of  implementing 
interoperability are not always well explored and communicated. Therefore interoperability is 
not always considered a worthwhile investment. Moreover, organisational complexity is often 

9 

 
 
of  such  magnitude  that  harmonisation  of  processes,  a  pre-requisite  for  interoperability,  is 
difficult to achieve. 

The  situation  becomes  more  adverse  when  it  concerns  cross-border  services  and  data,  as 
targeted  consultation  results  demonstrate  that  more  emphasis  and  priority  is  given  by  the 
Member States to the national dimension rather than to the European one. 

Resources constraints in relation to interoperability 

Resource  shortage  (financial  and  human)  has  been  highlighted  in  the  consultation  as  one  of 
the  main  reasons  impeding  the  implementation  of  interoperability  nationally  and  in  the  EU. 
Member  State  administrations  allocate  a  large  part  of  their  resources  on  operating  and 
maintaining their legacy systems. When it comes to new developments, there are currently no 
mechanisms  in  place  to  systematically  assess  the  possibility  of  reusing  existing  common 
services,  solutions  and  specifications.  This  can  lead  to  a  duplication  of  effort  as  new,  non-
interoperable systems are developed at national and EU levels. This is not cost efficient and 
hampers the effective delivery of digital public services across the EU. 

Scarcity of tools to enable interoperability in the delivery of public services 

There is scope for numerous improvements in the delivery of digital public services across the 
EU. The use of e-Identification and e-Signature should be generalised. Sources of information 
for any kind of data, i.e. population, businesses, vehicles, geospatial, environmental, judicial, 
etc., should be accessible and information should be structured in a form that can flow easily 
between  the  various  channels,  i.e.  using  common  standards  and  specifications.  This 
information should then be presented in a unified way to the end-users, i.e. through one-stop-
shop  portals.  Services  are  not  as  user-centric  as  they  should  and  could  be.  Putting  more 
emphasis  on  security  and  the  protection  of  privacy  and  confidentiality  would  create  trust, 
which, in turn, would increase services’ uptake. 

The  following  measures  could  alleviate  the  observed  digital  fragmentation  and  create  an 
environment where national and cross-border digital services can become a reality: 

 

there is a need to put in place interoperable IT systems, software tools, standards and 
specifications, and methodologies to guarantee that information  is easily transferable 
and is submitted only once;  

  base registries need to be connected to and should be easily accessible;  

  public services should be easily identifiable in catalogues and be presented in a user-

friendly way.  

10 

 
 
 
 
Legal issues in relation to interoperability 

there  are 

in  national 

legislation  preventing 

interoperability  obstacles 

Today, 
the 
implementation of cross-border public services, i.e. differences in dealing with data protection 
issues,  lack  of  legal  equivalence  between  digital  and  paper  processes,  national  legislation 
imposing  the  use  of  specific  standards  or  technologies,  etc.  Also  in  EU  legislation, 
interoperability is considered only for policy-specific instruments, which can result in a lack 
of engagement from stakeholders. Moreover, legislation might create interoperability barriers, 
e.g.  when  it  imposes  unjustified  restrictions  for  storage  of  data.  Also,  often  different 
legislations  lay  down  similar  requirements  in  different  ways,  imposing  the  use  of  policy-
specific  digital  services.  This  increases  digital  fragmentation  and  raises  a  clear  need  for 
interoperability  at  legal  level,  as  was  stated  by  the  contributors  to  the  consultation.  Even  in 
cases of binding instruments, such as the INSPIRE Directive, several Member States reported 
obstacles in sharing spatial data due to inconsistent national policies for data management. 

2.3 

Benefits of interoperability 

Interoperability  is  the  underlying  condition  for  the  efficient  attainment  of  numerous  high-
impact principles and services. For example:  

 

 

the once-only submission of information is expected to produce net savings of about 
EUR 5 billion per year at EU level by 2017;24  

it  has  been  evaluated  that  putting  in  place  e-procurements  could  result  in  annual 
savings of EUR 100 - 400 billion per year;25  

 

implementing e-invoicing can generate savings of up to EUR 2.3 billion26 per year;  

  overall economic gains from opening up the open public data resource could amount 

to EUR 40 billion a year in the EU.27  

For public administrations 

Public administrations can gain in efficiency and effectiveness after establishing interoperable 
European  public  services  and  will  be  more  aware  of  the  risks  and  costs  of  creating  new 
electronic  barriers  if  they  opt  for  public  services  solutions  that  are  not  interoperable  at  EU 
level. Public administrations should coordinate with the Commission and jointly identify the 
top-priority interoperability  actions.  They  should  then  contribute,  through  their  participation 

24 European Commission, Study on eGovernment and the Reduction of Administrative Burden, 2014. 
25  COM(2012)  179  final,  Communication  from  the  Commission  to  the  European  Parliament,  the  Council,  the 
European  Economic  and  Social  Committee  and  the  Committee  of  the  Regions,  A  strategy  for  e-procurement, 
Brussels, 20.4.2012. 
26  COM(2013)  453  final,  Communication  from  the  Commission  to  the  European  Parliament,  the  Council,  the 
European  Economic  and  Social  Committee  and  the  Committee  of  the  Regions,  End-to-end  e-procurement  to 
modernise public administration, Brussels, 26.6.2013. 
27COM(2015) 192 final, Communication from the Commission to the European Parliament, the Council, the 
European Economic and Social Committee and the Committee of the Regions, A Digital Single Market Strategy 
for Europe 

11 

 
 
                                                            
in various programmes,  i.e. ISA², CEF, to the development of key interoperability solutions 
and  embrace  (reuse  and  operate)  them  at  national  level.  Interoperability  requires  an  initial 
investment.  However  this  could  be  beneficial,  due  to  better  quality  of  public  services,  less 
effort  and  shorter  delivery  time.  The  exact  benefits  cannot  be  monetised  due  to  the  diverse 
effects that improved interoperability might have across society. For instance, a study28 shows 
that interoperability could produce benefits to governments by saving time when citizens and 
businesses  interact  with  the  public  sector,  which  in  turn  results  in  more  productivity  that 
boosts GDP. 

For citizens 

Citizens can benefit from better European digital public services in their daily lives when they 
want  to  extend  their  work  or  leisure  activities  outside  of  their  home  countries.  ‘Better 
services’ means: 

  services and information being easily identifiable, available, well updated, and easily 

understandable; 

 

requests being traceable so that progress can be noted; 

  workflows being fully automated and off-line steps becoming very limited;  

  personal data being handled in accordance with the applicable legal framework; 

 

less time is required for a request to be processed, meaning that working time is not 
spent in queues or unnecessary dealings with the public authorities. 

The young generation is digitally educated and their expectations in terms of quality are high, 
together  with  their  willingness  to  take  part  in  social  dialogues/consultations,  supporting 
decision-making processes through digital means. Improved interoperability will contribute to 
creating  an  environment  of  transparency  within  the  public  sector,  which  in  turn  will 
encourage citizens’ active involvement and participation. 

For businesses 

Likewise, interoperable European public services can help businesses by: 

  enabling and facilitating their access to public services nationally;  

 

limiting administrative burden and facilitating cross-border expansion of their business 
activities in the EU;  

  saving on effort and time when fulfilling their reporting obligations and other official 

duties (tax declaration, VAT, etc.); 

 

reusing public open data to deliver innovative solutions.  

28 The Economic Impact of Interoperability, Lorenzo Madrid, July 2012. 

12 

 
 
                                                            
Businesses can also benefit from interoperability solutions developed by the Commission for 
public  administrations,  as  these  are  open  and  free  to  be  shared  and  reused.  Moreover, 
interoperability is not only beneficial for businesses when it applies to their dealings with the 
public sector but also when it becomes a general market practice. For example, a study on the 
financial  benefits  of  interoperability  in  the  electric  power  industry29  found  that  it  results  in 
lower cost per transaction, increased operational efficiency and lower design, installation, and 
maintenance costs. 

3 

KEY INSIGHTS FROM THE CONSULTATION PROCESS 

Following  the  adoption  of  the  current  EIF  in  2010,  the  Commission  has  been  supporting  - 
through  initiatives  such  as  the  ISA  programme  -  interoperability  actions30  that  contribute  to 
the  implementation  of  various  EIF  recommendations  and  monitoring  the  state  of  play  of 
interoperability  in  the  Member  States  through  setting  up  mechanisms  such  as  the  NIF 
observatory - NIFO.31 To complete this picture, the Commission has launched a consultation 
process which included: 

  A 12 week (from 6.4.2016 to 29.6.2016) open public consultation translated in three 
languages32 during which feedback was received from 113 citizens, 17 businesses and 
private  organisations,33  31  public  administrations,  and  18  research  centres,  academic 
institutions, standardisation organisations and businesses supplying services; 

  A  targeted  consultation  with  the  ISA  Committee/coordination  group  members 
nominated  by  EU  Member  States  and  EEA  countries  (14  answers),  with  12  EU 
institutions/agencies,34 and an internal one across Commission departments. 

When analysing consultation feedback the following issues were taken into account: 

 

Implementation costs;35 

29 Financial benefits of interoperability - How interoperability in the Electric Power Industry will benefit 
stakeholders financially, GridWise Architecture Council, September 2009. 
30 http://ec.europa.eu/isa/actions/index_en.htm . 
31 https://joinup.ec.europa.eu/community/nifo/home . 
32 The open public consultation was available in three languages: French, English and German. 
33 4 of those were at the time of the consultation not included in the transparency register and their answers were 
treated separately. 
34 For the purpose of this report ‘EU institutions/agencies’ refer to the following 12 entities: the European Centre 
for the Development of Vocational Training (Cedefop), the European Banking Authority (EBA), the European 
Monitoring Centre for Drugs and Drug Addiction (EMCDDA), the European Court of Justice (CJEU), the 
European Maritime Safety Agency (EMSA), the European Training Foundation (ETF), the European Food 
Safety Authority (EFSA), the European Parliament, Eurojust, Frontex, the European Railway Agency (ERA) and 
Europol. 
35 It is the expected magnitude of the costs for European institutions/agencies and Member States to implement 
each policy option. Monetisation was not possible as financial data would neither be of sufficient quality nor 
reflect reality due to the high level of uncertainties and assumptions required. Considering that direct and indirect 
costs for businesses and citizens are minimal, they are excluded from this assessment. In fact, businesses and 
citizens are not expected to face any direct costs (i.e. hassle costs, substantive compliance costs, administrative 
burdens) following the implementation of the policy options. On the contrary, the Communication is expected to 
13 

 
 
                                                            
 

Implementation complexity;36 

  Direct benefits.37 

Besides analysing  specific recommendations, the targeted consultation has  also revealed the 
need to update the interoperability models proposed by the EIF, in particular: 

 

the interoperability 4-layer model from the previous EIF has been enhanced with 
two additions: 
o  ‘interoperability  governance’  which  lays  down  interoperability  frameworks, 
organisational  structures,  roles  and  responsibilities,  policies,  agreements  and 
other aspects necessary for ensuring and monitoring interoperability at national 
and EU levels; 

o  ‘integrated  public  service  governance’  which  ensures  the  collaboration  of 
several  organisations  for  the  seamless  delivery,  implementation  and  reuse  of 
public services and data. 

  The conceptual model for integrated public services has been updated to promote a 

set of key interoperability ideas listed below: 
o  ‘integrated  service’  delivery  based  on  a  ‘coordination  function’  to  remove 

complexity for the end-user; 

o  ‘no  wrong  door’  service  delivery  policy,  to  provide  multiple  channels  for 
service  delivery,  while  securing  availability  and  priority  on  digital  channels 
(digital-by-default); 

o  reuse of data and services to decrease costs and increase interoperability; 
o  catalogues describing reusable services and other assets to increase their usage; 
o 
o  security and privacy. 

integrated public service governance (as explained above); 

The full details of the open public consultation can be found in a factual summary which is 
available online.38  

benefit them and reduce their current administrative burden. In addition, there are no regulatory charges, such as 
taxes and levies, to be introduced by any policy option. The assessment focused on costs related to the necessary 
investments and expenses incurred by the Member States’ administrations to comply with the revised EIF, 
comprising all activities required to administer, communicate, promote and monitor the EIF requirements. As for 
monitoring the alignment and implementation of the EIF across the different Member States, the Commission 
will rely on existing mechanisms established by the ISA programme for the period 2010-2015 and carried on by 
the ISA² programme for the period 2016-2020. No major incremental costs are therefore expected, compared to 
the current situation (‘business as usual’). 
36 It means the extent to which it is feasible and complex for Member States to implement the EIF 
recommendations. 
37 It means the extent to which a policy option contributes to the ‘improvement of market efficiency’ (e.g. cost 
savings, time savings, better data quality, higher satisfaction rates from citizens and businesses). This was 
assessed by measuring the level of importance that stakeholders give to each EIF recommendation. 
38 http://ec.europa.eu/isa/consultations/results/result_impact-assessment-for-the-revision-of-the-eis-eifl_en.htm. 
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A synopsis report, explaining briefly how the results of all consultations have been taken into 
account  in  the  Communication,  is  available  in  a  separate  staff  working  document, 
SWD(2017)113. 

Costs 

Implementing  the  updated  EIF  recommendations  implies  costs  for  Member  States  and 
European institutions/agencies. 

As  mentioned  earlier  in  this  section,  it  was  not  possible  to  request  information  concerning 
monetisation  to  the  respondents  during  this  exercise.  Instead,  respondents  were  asked  to 
assess the costs of implementing each EIF recommendation, from 1 (least costly) to 5 (most 
costly).  Administrative  simplification  and  once-only  submission,  security  and  privacy, 
organisational interoperability and information interoperability received the highest scores in 
this assessment. 

Figure 2 Estimated costs for implementing the EIF recommendations 

Source: results from the open public consultation with public administrations, and the targeted consultation with 
EU institutions/agencies. 

Notes: the data is related to the responses to the question on the overall level of implementation costs of each of 
the EIF recommendations in each target organisation. 

In  addition  to  assessing  the  costs  of  implementing  the  recommendations,  the  level  of 
complexity  or  implementation  feasibility  was  also  assessed  among  the  target  groups. 
Respondents were asked to assess the level of complexity from 1 (very easy to implement) to 
5  (very  complex 
implement).  The  most  complex  recommendations  for  public 
administrations  were  information  interoperability,  legal  interoperability,  governance  and 
once-only submission. 

to 

15 

 
 
Figure 3 EIF Recommendations’ implementation complexity 

Source: results from the open public consultation with public administrations, and the targeted consultation with 
EU institutions/agencies. 

Notes: the data is related to the responses to the question on the overall level of complexity to implement each of 
the EIF recommendations in each target organisation. 

Benefits 

While implementation of the new EIF recommendations could involve costs and complexities 
for the target groups, it will also generate benefits. Overall, the large majority of each target 
group  agreed  that  citizens  and  businesses  will  benefit  from  the  EIF  revision.  Not  a  single 
participant  disagreed  or  partially  disagreed  with  the  statement  that  implementing  the  EIF 
recommendations would contribute to reducing administrative burden. 

More  specifically,  respondents  were  asked  to  assess  the  level  of  importance  of  each  EIF 
recommendation  with  regard  to  the  benefits  they  may  generate  in  the  context  of 
interoperability  at  EU  level  in  spite  of  the  potential  complexity  of  implementing  any 
individual  one,  from  1  (not  important  at  all)  to  5  (very  important).  Public  administrations 
rated  all  recommendations  above  4,  giving  the  highest  marks  to  security  and  privacy, 
effectiveness and efficiency, once-only submission and administrative simplification and data 
transferability. 

16 

 
 
 
Figure 4 Estimated benefits for implementing the EIF recommendations 

Source: results from the open public consultation with public administrations, and the targeted consultation with 
EU institutions/agencies. 

Notes:  the  data  is  related  to  the  responses  to  the  question  on  the  overall  level  of  importance  of  each  EIF 
recommendation with regard to the benefits they may generate in the context of interoperability at EU level in 
spite of the potential complexity of implementing any individual one, in each target organisation. 

The results show that recommendations receiving high scores in terms of cost and complexity 
to implement are also identified as offering higher expected benefits. This is the case of once-
only  submission,  administrative  simplification,  security  and  privacy  and  information 
interoperability. 

Most Member States have already started to implement solutions in the areas covered by the 
proposed recommendations including new or substantially modified ones. Consultation results 
confirm that common recommendations can be an important source of cost and time savings 
for Member States’ public administrations. 

17 

 
 
 
Figure 5 EIF areas of contribution 

Source: results from the open public consultation with public administrations, academia/research/standardisation 
organisations, business and private organisations and the targeted consultation with EU institutions/agencies. 

Notes: the data is related to the responses to the question on the main areas of contribution of the EIF. 

Priorities 

All  stakeholder  groups  (Member  States,  other  EU  institutions/agencies,  businesses  and 
the  vision  on 
academia/research/standardisation  organisations) 
interoperability as stated in the Communication text, as well as with the priorities structured 
around five main focus areas:  

largely  agreed  with 

  governance/coordination/sharing of interoperability initiatives;  

  organisational interoperability;  

  stakeholders’ engagement and awareness raising;  

  key interoperability enablers;  

  supporting instruments for interoperability.  

All  of  these  are  further  detailed  in  an  interoperability  action  plan  annexed  to  the 
Communication. 

18 

 
 
 
4 

CONCLUSION 

Despite  the  relatively  good  level  of  alignment  between  the  existing  EIF  and  NIFs,  the  low 
level of implementation of NIFs at national level has revealed a diverse level of maturity in 
relation to interoperability among Member States.  

New  policies,  technological  evolution  and  lessons  learned  from  past  experience  require  the 
emergence  of  a  new  EIF  to  help  Member  States  deal  with  interoperability  challenges  when 
interoperability 
putting 
recommendations implemented by the Member States will increase quality while minimising 
the cost of EU-wide solutions.  

in  place  modern  digital  public  services.  Having  common 

The implementation of the EIF will be supported mainly by the ISA² programme and through 
actions included in an interoperability action plan.  

19