COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS on a strengthened public sector interoperability policy Linking public services, supporting public policies and delivering public benefits Towards an ‘Interoperable Europe’
Date: 2022-11-18
Institutions: Directorate-General for Digital Services, European Commission
Subjects: EU policy, European Interoperability Framework, European cooperation, administrative cooperation, digital transformation, digitisation, electronic government, public policy, public sector, public service

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 18.11.2022  COM(2022) 710 final  COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS on a strengthened public sector interoperability policy  Linking public services, supporting public policies and delivering public benefits Towards an ‘Interoperable Europe’ {SWD(2022) 710 final}  
 
 
Table of Contents 

1.  SETTING THE SCENE ..................................................................................................... 2 

2.  DRIVING INTEROPERABLE PUBLIC SECTOR DIGITALISATION.......................... 3 

2.1  What is interoperability… ........................................................................................... 3 

2.2  …and why does improving interoperability matter for the EU? ................................. 4 

3.  CHANGING GEAR ON EU INTEROPERABILITY COOPERATION .......................... 5 

3.1  Building a shared interoperability governance ............................................................ 5 

3.2 

Involving all layers of government .............................................................................. 6 

3.3  Advancing innovation and ‘GovTech’ cooperation .................................................... 7 

3.4  Monitoring impact ....................................................................................................... 8 

4.  MAKING EU POLICIES INTEROPERABLE BY DESIGN AND DIGITAL-READY .. 9 

4.1  Designing EU policies in the digital age ..................................................................... 9 

4.2 

4.3 

Focusing interoperability funding ............................................................................. 11 

Embedding interoperability into EU data and innovation policies ............................ 12 

4.4  Developing international cooperation on public sector interoperability ................... 13 

1 

 
 
 
 
1.  SETTING THE SCENE 

Interoperable  digital  public  services  are  essential  for  successfully  digitalising  the  European 
Union’s single market. There is a lot to be gained by industry and society from making sure 
the  digital  transformation  of  Europe’s  public  sector  is  inclusive,  fair  and  open,  sustainable, 
value-driven  and  interoperable.  The  digital  transformation  of  the  public  sector  creates  very 
considerable  pull  and  push  factors1  for  the  digitalisation  of  European  industry  and  society. 
The  weight  and  potential  of  the  public  sector  for  a  value-driven  “European  way”  of  digital 
transformation  has  been  acknowledged  by  EU  governments2,  and  local  and  regional 
communities3, and confirmed by the EU Digital Compass, identifying the public sector as one 
of four cardinal points signposting the EU’s digital trajectory4. Digital public administrations 
have emerged as a particular focus points of national Recovery and Resilience Plans as well, 
with a combined planned investment of EUR 47 billion5. 

A  stronger  focus  on  public  sector  interoperability  supports  Europe’s  recovery  effort  and 
resilience, effectively connecting public administrations and policies, people and business for 
seamless  service  offers  and  data  flows.  This  includes  making  EU  policies  fit  for  the  digital 
age, ensuring effective policy implementation by digital means and interoperability from the 
policy  design  stage,  in  close  partnership  between  policy  makers  and  ICT  experts.  This  also 
includes building a virtuous innovation cooperation loop for designing and delivering digital 
public services. 
This  communication  accompanies  the  proposal  for  an  ‘Interoperable  Europe  Act’6,  which 
aims at establishing a common interoperability governance and at facilitating the co-creation 
of an ecosystem of interoperability solutions across the EU. Joint development of solutions, as 
well as sharing and reusing proven tools is the fast and cost-effective approach to designing 
digital public services. Strengthened interoperability cooperation is essential for fully tapping 
into  the  public  sector’s  transformation  potential,  avoiding  fragmentation  and  improving 
connectivity and data sharing. By doing this, the proposed policy framework will contribute to 
safeguarding  Europe’s  digital  sovereignty  and  empower  digital  subsidiarity.  Strengthening 
EU  government  interoperability  policy  delivers  on  the  Commission’s  priorities  and  digital 
policy agenda, making Europe’s public sector fit for the digital age7. 

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The public sector represents 53.1% of GDP in 2020, https://ec.europa.eu/eurostat/statistics-
explained/index.php?title=Government_finance_statistics#Government_revenue_and_expenditure 
Such as with ministerial declarations adopted in Tallinn 2017 (https://digital-
strategy.ec.europa.eu/en/news/ministerial-declaration-egovernment-tallinn-declaration), Berlin 2020 
(https://ec.europa.eu/isa2/sites/isa/files/cdr_20201207_eu2020_berlin_declaration_on_digital_society_a
nd_value-based_digital_government_.pdf), Lisbon 2021 (https://www.lisbondeclaration.eu/) and 
Strasbourg 2022(https://www.eupan.eu/2022/04/presidence-francaise-2022-french-presidency-2022/). 
Exemplified by the ‘Living-in-EU’ cooperation, https://living-in.eu/ 
The European way for the Digital Decade, COM(2021) 118 final, 
https://ec.europa.eu/info/strategy/priorities-2019-2024/europe-fit-digital-age/europes-digital-decade-
digital-targets-2030_en 
From https://ec.europa.eu/info/files/recovery-and-resilience-facility-annual-report_en, page 23 
Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 
laying down measures for a high level of public sector interoperability across the Union (Interoperable 
Europe Act), COM(2022)720 final. 
https://ec.europa.eu/info/strategy/priorities-2019-2024/europe-fit-digital-age/shaping-europe-digital-
future_en 

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2.  DRIVING INTEROPERABLE PUBLIC SECTOR DIGITALISATION 

2.1 What is interoperability… 

Public  sector  interoperability  is  what  enables  administrations  to  cooperate  and  make  public 
services  function  across  borders,  across  sectors  and  across  organisational  boundaries.  This 
benefits  people  and  businesses  who  depend  on  these  connected  services8.  It  also  benefits 
communities  and  administrations  themselves,  which  depend  on  trusted  data  from  different 
public or private  sources for  their decisions, and which need to  deliver on policy  objectives 
that are often interconnected across borders and sectors9. Interoperability plays a role within 
and  across  organisations  and  policy  sectors,  in  particular  those  with  a  strong  public  sector 
connection,  such  as  justice  and  home  affairs,  taxation  and  customs,  transport,  environment 
and  agriculture,  or  health,  as  well  as  business  and  industry  regulation.  Interoperability  is  an 
established theme across EU digital and data policies. 

Public  services  are  delivered  and  used  at  different  levels,  foremost  locally,  but  also  at 
regional,  national  and  European  levels.  They  rarely  function  in  isolation,  as  the  access  to 
registers established at different levels  or sectors is necessary in order to exchange data and 
deliver the required service to the end-users. Much of this data is located outside the context 
of a given policy area, a specific public administration and, increasingly, beyond borders. This 
means public services across Europe represent an emerging ‘network of networks’ of largely 
sovereign  actors  at  all  levels  of  government,  each  with  their  own  legal  framework  and 
mandates, yet all interconnected. In analogy to the established Trans-European Transport and 
Energy Networks10, public services are forming their own Trans-European network, founded 
on interoperability. 

Interoperability  is  sometimes  seen  as  a  purely  technical  matter.  However,  considering  the 
technical aspects alone is not sufficient for effectively linking administrations, data flows and 
services. It is necessary to ensure technical connection capacity and semantic understanding 
for  the  exchange  and  processing  of  the  data  concerned,  and  to  establish  the  required 
organisational and legal context, for instance in relation to rights to access, exchange or reuse 
of  data.  For  coordination  and  coherence,  interoperability  also  requires  an  integrated 
governance approach. These basic conditions – or ‘layers’ – of interoperability are set out in 
the  European  Interoperability  Framework  (EIF),  a  conceptual  model  developed  by  digital 
public  sector  practitioners  from  across  Europe  in  2004  and  updated  twice  since11.  Over  this 
period, in sync with an increasingly connected world, interoperability emerged as an essential 
aspect of the digital transformation of administrations and services. 

The EIF is now the commonly accepted policy framework for interoperability in the EU, and 
beyond12. Given its specific mission  to  serve  the common public cause,  this interoperability 
foundation needs to be transparent, inclusive, fair and secure, and firmly based on EU values. 

8  

9  

10  

11  

12  

For instance https://nordicsmartgovernment.org/, an initiative of five Nordic countries to establish cross 
border and cross sector interoperable public services. 
An example of such multi-faceted policies is the case of smart cities for which energy , environmental, 
transport, water, waste and digital considerations have to be taken together, https://ec.europa.eu/info/eu-
regional-and-urban-development/topics/cities-and-urban-development/city-initiatives/smart-cities_en 
Articles 170 to 172 of the Treaty on the Functioning of the European Union (TFEU) set out the EU’s 
competence to establish and develop trans-European networks and to promote the interconnection and 
interoperability of national networks. This increasingly involves combining ‘hardware’ and ‘software’ 
and connecting ‘sovereign’ systems in a common network of energy, transport and digital networks. 
https://joinup.ec.europa.eu/collection/nifo-national-interoperability-framework-observatory/european-
interoperability-framework 
https://joinup.ec.europa.eu/collection/nifo-national-interoperability-framework-observatory/national-
interoperability-initiatives.  

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Interoperability is what enables public sector actors to connect, cooperate and exchange data 
while safeguarding sovereignty and subsidiarity13. 

2.2 …and why does improving interoperability matter for the EU? 

Improvements in public sector performance thanks to full implementation of interoperability 
at  all  levels  of  administration  could  lead  to  an  estimated  increase  of  0.4%  in  EU  GDP. 
Individuals could save up to 24 million hours a year, or EUR 543 million. Businesses could 
save 30 billion hours or EUR 568 billion a year14. The estimated annual cost savings credited 
to  cross-border  interoperability  range  between  EUR  5.5  and  6.3  million  for  citizens,  and 
between EUR 5.7 and 19.2 billion for businesses.  

Case  studies  also  show  that  interoperability  has  a  positive  effect  on  other  public  values, 
beyond  efficiency  gains15.  For  example,  pro-active  public  services  or  multilingual  semantic 
support improve access to and inclusiveness in public services, increasing public trust16. 

Interoperability  is  vital  in  times  of  crisis,  as  Covid-19  has  shown.  Not  only  was 
interoperability necessary  for the creation of  digital Covid-19 certificates that are  accessible 
EU-wide,  but  also  for  the  real-time  sharing  of  data  on  available  beds  in  intensive  care  in 
hospitals17.  Interoperability  helps  the  State  to  be  more  agile  and  ensure  access  to  real-time 
information  across  sectors  and  administrative  levels;  it  helps  assess  policy  performance  and 
gives incentives to constantly innovate, share efforts and bridge gaps across policy areas. 

However, the current policy framework of non-binding interoperability cooperation is not fit 
for making the most of these estimated gains. While digital government and data experts have 
developed  –  with  remarkable  commitment  –  a  wide-ranging  common  EU  interoperability 
acquis18 of cooperation practices, concepts, reusable solutions,  open specifications and tools 
that  support  national  reform  efforts19  and  established  EU  policies20,  recent  evaluations  have 
exposed major limitations of this entirely voluntary approach to cooperation. 

Digital aspects, including data access and sharing aspects, are all too often addressed too late 
in  the  policymaking  process.  Interoperability  considerations  are  not  ‘wired  into’  public 
services.  This  means  high  implementation  risks  and  costs,  missed  opportunities,  and,  in  the 
worst  case,  an  undermining  of  large  scale  digitalisation-dependent  policies21.  Public 

13  
14  

15  

16  

17  
18  

19  

20  

21  

As stressed in the Berlin Declaration referred to above. 
Study from the Commission’s Joint Research Centre, 
https://publications.jrc.ec.europa.eu/repository/handle/JRC127330 
The DIGI4FED project is an example for this: https://www.uantwerpen.be/en/research-
groups/govtrust/research/projects/digi4fed/ 
For example the Automatic Social Energy Tariff in Portugal, which won a United Nations award 
(https://eportugal.gov.pt/en/noticias/tarifa-social-de-energia-automatica-premiada-pela-onu), or 
eTranslation tools used for the Conference on the Future of Europe portal, available to public 
administrations (https://ec.europa.eu/info/resources-partners/machine-translation-public-
administrations-etranslation_en). 
See https://www.sciencedirect.com/science/article/pii/S2468042722000033 
Including assets developed in cooperation with EU countries and with financial support from the former 
ISA² and CEF-Telecom programmes, see https://joinup.ec.europa.eu/ 
Such as the Spanish national interoperability law and practice, see 
https://www.boe.es/buscar/act.php?id=BOE-A-2010-1331 and 
https://www.boe.es/biblioteca_juridica/index.php?tipo=C 
Some important EU policies started as and/or were supported by interoperability projects, e.g. the 
eIDAS regulation (https://digital-strategy.ec.europa.eu/en/policies/eidas-regulation) or the EU 
Blockchain Service Infrastructure (https://ec.europa.eu/cefdigital/wiki/display/CEFDIGITAL/ebsi). 
Addressing digital and interoperability aspects early on during policy design offers particular benefits, 
as pointed out in the ICT Impact Assessment guidelines produced by the Commission in 2018 
(https://ec.europa.eu/isa2/sites/isa/files/ict_impact_assessment_guidelines.pdf) and specified in the 

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administrations can only be interoperable if the right assessments and choices are made early 
on in the policy design phase. Not acting to improve interoperability could make the EU miss 
the opportunity to considerably reduce administrative burden. This would lower the resilience 
of public administrations, limit their capacity to innovate and, in the worst case, make them 
unable to  act  in  times of crisis22. Cooperation of public administrations  across borders must 
become as natural and seamless as trains crossing borders, or energy flows between national 
networks. The response to Covid-19 only highlighted the importance of stable digital public 
sector interaction across borders and across sectors. 

increasingly  vocal  about 

In this context, and with digital transformation gaining momentum, EU ministers responsible 
for  public  sector  transformation  and  Member  State  chief  information  officers  (CIOs)  have 
become 
interoperability 
cooperation. They call for a stable organisational structure, for generalising the application of 
the EIF, for designating commonly accepted and open specifications and solutions ready for 
reuse. They also call for an ‘interoperability by design’ approach and for better coordinating 
experimentation  and  innovation  in  the  public  sector,  including  cooperation  with  the  private 
sector  (‘GovTech23).  The  Commission’s  proposal  for  a  strengthened  EU  public  sector 
interoperability policy responds to these needs. 

to  strengthen  European 

the  need 

3.  CHANGING GEAR ON EU INTEROPERABILITY COOPERATION 

3.1 Building a shared interoperability governance 

The  proposed  Interoperable  Europe  Act  focuses  on  building  a  structured,  transparent  and 
inclusive cooperation framework, providing for the adaptability and innovation capacity that 
the public sector needs in a dynamic technical, societal and political context. Interoperability 
cannot  be  achieved  from  the  top  down  by  a  single  entity,  nor  can  it  be  achieved  from  the 
bottom up by individual actors: it  requires effective cooperation between policy-makers and 
policy  implementers  across  all  levels  of  government  and  across  sectors.  It  also  requires  an 
open  but  stable  and  integrated  governance  framework.  One  that  ensures  subsidiarity  by 
establishing effective co-ownership. One that is sustainable for the future because something 
designed to be interoperable becomes less quickly outdated. One that turns the public sector’s 
transformation potential into reality and safeguards public values. The proposed Interoperable 
Europe Act seeks to provide this cooperation framework. It provides for the establishment of 
an Interoperable Europe Board to steer the common interoperability effort, bringing together 
Member State  central  digital transformation authorities  and EU  Institutions.  It  also  provides 
for an open Interoperable Europe Community of experts, practitioners and interested parties to 
ensure transparency and link to grassroots practice. 

Interoperability  is  a  moving  target  because  of  the  fast  pace  of  technology  development  and 
ever evolving policy needs. It requires a dedicated, innovation-friendly and open legal setup 
that  avoids  regulatory  and  technological  lock-ins.  Other  options,  such  as  enshrining  the 
technologies  used  today  in  law,  would  risk  undermining  future  innovation  and  limit  the 

22  

23  

recommendations from the members of the Commission expert group on interoperability of public 
services (https://joinup.ec.europa.eu/collection/interoperable-europe/news/official-expert-
recommendations-new-interoperability-policy). 
For example, the lack of data consistency hampered the EU’s capacity to respond cooperatively early 
on in the COVID-19 crisis, as found by Renda, A., and Castro, R. (2020) in ‘Towards stronger EU 
governance of health threats after the COVID-19 pandemic’, European Journal of Risk Regulation, 
11(2), pp 273-282. 
See ‘GovTech Practices in the EU’ (https://publications.jrc.ec.europa.eu/repository/handle/JRC128247) 
or ‘Exploring Digital Government Transformation in the EU - Understanding public sector innovation 
in a data-driven society’ (https://publications.jrc.ec.europa.eu/repository/handle/JRC121548) 

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capacity of administrations to adapt to changing needs and new technologies. Interoperability 
policymaking  and  regulation  in  themselves  need  to  be  innovative  and  digital-ready24.  The 
proposed  Interoperable  Europe Act  seeks to  provide such built-in  innovation  framework for 
the public sector. 

The EIF is the reference instrument for public sector interoperability implementation. In order 
to ensure it stays relevant, it needs to be regularly reviewed and updated. It also needs further 
development of implementation recommendations and support25, for instance, to support the 
upcoming EU sectoral data spaces26, in close coordination with the European Data Innovation 
Board and the requirements of the upcoming Data Act27. The proposed Interoperable Europe 
Act  provides  for  such  regular  updating,  in  line  with  innovation-friendly  and  digital-ready 
regulation.  

3.2 Involving all layers of government 

A  strengthened  EU  interoperability  governance  co-owned  by  Member  States  and  the  EU 
offers  a  much-needed  improved  policy  and  support  framework  for  EU  public  sector  reform 
objectives28. This effort needs to be collective, spanning all levels of government, in order to 
maintain and update the rich interoperability acquis of concepts, guidelines, specifications and 
reusable assets. 

Adequate involvement and representation of regional and local communities is a prerequisite, 
not only because they constitute the ‘first and last mile’ of public service delivery, but also in 
order to be able to tap into the considerable innovation capacity of cities and regions29. Here, 
public-private innovation and service cooperation play an important role. Movements such as 
‘Living-in-EU’,  as  well  as  extended  project  cooperation  such  as  ‘Open  and  Agile  Smart 
Cities’30,  show  that  there  is  a  strong  demand  for  cooperation  around  interoperability  and 
readiness  to  engage  from  regional  and  local  levels.  The  variety  and  expertise  of  locally 
developed  interoperability  solutions  is  an  important  asset  and  should  be  systematically 
contributing  to  catalogues  of  recognised  and  commonly  available  interoperability  resources. 
This 
include 
representatives from rural and urban local and regional authorities and societal groups on the 
future Interoperable Europe Board and why experts from all levels of government are actively 
encouraged to contribute to the work of the future Interoperable Europe Community. 

interoperability  governance  should 

the  proposed  future  EU 

is  why 

24  

25  
26  

27  
28  

29  

30  

A policy (or legal act) is digital-ready if it enables smooth and digital-by-default policy implementation 
and is conducive to digital transformation through the best use of technologies and data 
(https://joinup.ec.europa.eu/collection/better-legislation-smoother-implementation/digital-ready-
policymaking). See also the European Commission’s Better Regulation Tool #28 on digital-ready 
policymaking (https://ec.europa.eu/info/files/chapter-3-identifying-impacts-evaluations-fitness-checks-
and-impact-assessments_en). 
https://joinup.ec.europa.eu/collection/national-interoperability-framework-observatory/eif-toolbox. 
The Commission already adopted the first proposal for a sectoral data space, the proposed Regulation 
for the European Health Data Space, https://ec.europa.eu/commission/presscorner/detail/en/ip_22_2711 
https://ec.europa.eu/commission/presscorner/detail/en/ip_22_1113 
European Public Administration Network (https://www.eupan.eu/), or the Commission Expert Group on 
Public Administration and Governance (https://ec.europa.eu/reform-support/public-administration-and-
governance-policy-making/expert-group-public-administration-and-governance_en). 
Smart Cities marketplace (https://smart-cities-marketplace.ec.europa.eu/projects-and-sites). Examples 
of local activities include: AI for the detection of cardiac arrests 
(https://cordis.europa.eu/article/id/421437-artificial-intelligence-detects-cardiac-arrest-in-emergency-
calls); managing capacity in public spaces (Fuengirola https://www.themayor.eu/en/a/view/fuengirola-
digitized-its-beach-control-and-got-an-award-for-it-8098); AI for Local Digital Twins (DUET 
https://www.digitalurbantwins.com/, LEAD (https://www.leadproject.eu/), SHPERE (https://sphere-
project.eu/). 
https://oascities.org/minimal-interoperability-mechanisms/ 

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To cater specifically for local and regional conditions, the Commission, in close cooperation 
with private and public stakeholders, has developed a ‘European Interoperability Framework 
for  Smart  Cities  and  Communities’  (EIF4SCC)  fully  aligned  with  the  EIF.  Following 
extensive public discussion and consultation, this specialisation of the EIF is presented in the 
staff  working  document  accompanying  this  communication31.  The  Commission  encourages 
experts and practitioners from other policy areas to follow this example of adapting the EIF to 
specific  and/or  sectoral  use  cases.  The  future  Interoperability  governance  will  be  given  the 
task  of  assessing  the alignment  of  the  specialised  interoperability  frameworks  with  the  EIF. 
For  instance,  a  specialisation  of  the  EIF  has  been  developed  in  the  past  for  digital  health 
purposes32.  Traditionally,  interoperability  also  plays  an  important  role  in  environmental 
policy33, justice and home affairs34 or transport35. 

3.3 Advancing innovation and ‘GovTech’ cooperation 

Avoiding falling behind in technology integration is a constant challenge for the public sector. 
While  often  criticised  for  technology  risk  aversion,  public  authorities,  in  their  unique  role 
serving  the  common  cause,  need  to  demonstrate  a  particular  duty  of  care  as  regards 
technology adoption and lawful, fair and trustworthy technology use. Yet, new technologies 
have the potential to make public services more accessible, more inclusive and more efficient 
than ever. Ensuring continuous digital innovation for the public sector is as challenging as it is 
important. 

Across  Europe  there  are  already  several  hundreds  of  activities  testing  and  piloting  digital 
technologies in the public sector; learning about the benefits and risks of these technologies is 
essential.  The  Commission  is  setting  up  an  Innovative  Public  Services  Observatory36  to 
analyse  trends  and  identify  good  and  bad  practices,  to  inform  the  adoption  of  emerging 
technologies  and  to  ensure  interoperability  by  design.  The  observatory  will  assess  how 
technologies  such  as  Artificial  Intelligence  are  transforming  public  sector  processes  and 
governance  structures.  This  will  help  EU  as  well  as  national  and  local  authorities  to  take 
informed decisions about implementing emerging technologies. 

Europe is full of thriving regional ecosystems of innovative small technology companies and 
start-ups37, supported, amongst other, by a network of Digital  Innovation Hubs38 and by the 
European  Innovation  Council39.  Openly  available,  reusable  and  recognised  interoperability 
resources are important assets for small innovative companies and civil society initiatives to 
engage with the public sector. 

31  
32  

33  
34  

35  
36  
37  

38  
39  

SWD(2022)710 final. 
See the European eHealth Interoperability Framework (https://op.europa.eu/en/publication-detail/-
/publication/7e8e2f60-6f87-4be8-9125-477e212e3a74) and (https://eufordigital.eu/wp-
content/uploads/2021/03/Common-Guidelines-for-eHealth-Harmonisation-and-Interoperability.pdf). 
The Commission has since proposed establishing a dedicated European Health Data Space 
(https://health.ec.europa.eu/ehealth-digital-health-and-care/european-health-data-space_en). 
Such as https://inspire.ec.europa.eu/inspire-directive/2 
Such as https://e-justice.europa.eu/home?plang=en&action=home and https://ec.europa.eu/home-
affairs/policies/schengen-borders-and-visa_en 
Such as https://transport.ec.europa.eu/transport-themes/intelligent-transport-systems_en 
https://joinup.ec.europa.eu/collection/innovative-public-services 
As for instance here: https://atomico.com/insights/launching-the-7th-annual-state-of-european-tech-
report 
https://digital-strategy.ec.europa.eu/en/activities/edihs 
https://eic.ec.europa.eu/index_en and the Horizon Europe Programme 

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Public-private  ‘GovTech’  or  ‘CivicTech’  cooperation40  stimulates  public  sector  innovation, 
supports  Europe’s  technological  sovereignty  and  opens  pathways  to  public  procurement. 
Gaining access to public procurement is a core concern for smaller companies, to be able to 
scale  up  and  gain  recognition  and  stable  operating  income41.  Supporting  GovTech  is  a 
dedicated  strand  of  both  the  Digital  Europe  Programme  and  the  proposed  Interoperable 
Europe  Act,  fully  aligned  with  the  EU  innovation  support  framework.  Industry  will  have  a 
link  to  the  future  Interoperable  Europe  Board  via  the  European  Economic  and  Social 
Committee and is invited to join the future Interoperable Europe Community. 

3.4 Monitoring impact 

The  impact  assessment  for  a  future  interoperability  policy  has  exposed  the  difficulties  of 
collecting data and estimating the cost and benefits of interoperability as an activity that is not 
in itself the end purpose but an important support instrument for public sector digitalisation. It 
is  however  useful  to  measure  interoperability  maturity  in  order  to  guide  investments  and 
gauge progress.  A multitude of reporting and monitoring tools exist for digital  government, 
depending on specific user, sector or geographic focus42. These tools are not always aligned 
or  sufficiently  connected,  and  the  results  are  rarely  presented  in  an  easy-to-use  machine-
readable  format.  They  also  may  impose  a  considerable  burden  on  administrations  as  the 
Commission expert group on interoperability of public services has pointed out43. 

For these reasons it is important to develop transparent and reusable, digital-ready reporting 
and  monitoring  tools,  to  help  reach  the  Digital  Decade  targets.  Existing  monitoring  formats 
should  be  integrated  into  a  ‘once-only’  logic,  reusing  data  and  surveys  where  possible  and 
making the results openly available in machine-readable formats. This is in itself an aspect of 
digital-ready policymaking, with tools and concepts reusable, integrated and transferrable, for 
the benefit of practitioners and policymakers. 

The Commission proposal for an Interoperable Europe Act: 

- 

establishes  a  structured  EU  cooperation  on  interoperability  and  co-ownership  with 
Member  States  of  the  EU  interoperability  acquis  by  creating  the  Interoperable  Europe 
Board  composed  of  digital  government  practitioners  representing  Member  States;  it 
creates  the  Interoperable  Europe  Community  as  an  open  forum  of  professionals  and 
interested parties advising on interoperability and public sector innovation; 

-  mandates  the  Interoperable  Europe  Board  to  develop  the  EIF  and  ensure  its  future 

- 

40  

41  
42  

43  

evolution; 
introduces  in  a  proportionate  manner  a  mandatory  interoperability  assessment  for  any 
change to, or introduction of, an information system or system component of cross-border 
relevance that enables public services to be delivered or managed electronically; 

Both terms refer to public-private cooperation on technologies for the public sector. Where GovTech 
usually involves technology startups and SMEs, for instance piloting AI use, CivicTech usually 
involves civil society organisations, for instance promoting technology based citizen engagement. 
See the EU SME strategy, https://ec.europa.eu/growth/smes/sme-strategy_en 
Such as DESI (https://digital-strategy.ec.europa.eu/en/policies/desi), or the LORDI project (Local and 
Regional Digital Indicators: https://living-in.eu/groups/commitments/monitoring-measuring). Also the 
OECD (https://goingdigital.oecd.org/indicator/58), the United Nations 
(https://publicadministration.un.org/egovkb/en-us/Reports/UN-E-Government-Survey-2020) and the 
World Bank (https://www.worldbank.org/en/events/2021/09/16/govtech-maturity-index-the-state-of-
digital-transformation-in-the-public-
sector#:~:text=The%20World%20Bank%20has%20developed,citizen%20engagement%2C%20and%20
GovTech%20enablers) also run relevant monitoring projects. 
Recommendation 16 at https://ec.europa.eu/transparency/expert-groups-
register/core/api/front/expertGroupAddtitionalInfo/43164/download 

8 

 
                                                           
- 

- 

introduces  catalogues  of  recognised  interoperability  assets  that  can  be  reused  by 
administrations and in policymaking, such as digital tools, specifications or solutions; and 
strengthens  interoperability  support  for  digital-ready  EU  policies  and  for  common 
GovTech innovation projects. 

The Commission will: 

- 

- 

- 

- 

adopt a renewed EIF, based on a proposal by the future Interoperable Europe Board. The 
new EIF will focus on concrete implementation recommendations, including for EU data 
spaces, in close coordination with the European Data Innovation Board; 
support the development of sectoral interoperability specialisations aligned with the EIF, 
such  as  the  EIF  for  smart  cities  and  communities  (EIF4SCC)  published  alongside  this 
communication; 
ensure  close  interaction  of  its  GovTech  cooperation  and  support  activities  with  EU 
innovation instruments such as Digital Innovation Hubs (DIHs), the European Innovation 
Council and Ecosystems (EIC and EIE) and the European Institute of Technology (EIT); 
and 
ensure reporting and monitoring on interoperability is fully aligned with  and, as needed, 
integrated into relevant EU policy monitoring tracks (especially the Digital Economy and 
Society Index DESI, the Digital Decade process, monitoring of the Berlin Declaration and 
of national Recovery and Resilience Plans). 

4.  MAKING EU POLICIES INTEROPERABLE BY DESIGN AND DIGITAL-READY 

4.1 Designing EU policies in the digital age 

Digital aspects in general, and interoperability specifically, have traditionally been delegated 
to technical  experts and  addressed only  downstream, late in, or even after conclusion of  the 
policymaking  process.  This  carries  high  policy  implementation  risks  and  costs  from 
unintended  barriers  and  limitations.  To  overcome  this,  it  is  necessary  to  adopt  a  systemic 
interoperability-by-design approach to policy making. 

The policy making and implementation cycle is increasingly data-driven and digital, ranging 
from  foresight  and  impact  assessment44, to  data collection and monitoring45, to  services and 
tools46. EU policies contain more and more digital aspects47. With policy objectives, data sets 
and digital solutions closely inter-connected, EU policy making and implementation can only 
be  effective  and  efficient  if  supported  by  a  partnership  between  policy  makers  and  ICT 

44  

45  

46  

47  

For instance https://ec.europa.eu/info/law/law-making-process/planning-and-proposing-law/better-
regulation-why-and-how/better-regulation-guidelines-and-toolbox_en 
For instance reporting on sustainability information has gained prominence, see Regulation (EU) 
2019/2088 of the European Parliament and of the Council of 27 November 2019 on 
sustainability‐related disclosures in the financial services sector, which entered into force in 2021. 
For instance Regulation (EU) 2021/953 on a framework for the issuance, verification and acceptance of 
interoperable COVID-19 vaccination, test and recovery certificates (EU Digital COVID-19 Certificate) 
to facilitate free movement during the COVID-19 pandemic: https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32021R0953. In maritime surveillance policy new tools such as 
Copernicus Maritime Services or Remote Electronic Monitoring (REM) are being used. 
https://www.efca.europa.eu/en/content/new-technologies-maritime-surveillance, https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32021R0953 
Of the 284 legislative initiatives presented by the Commission between March 2020 and June 2021, 
47% referred to digital elements and 67% to data in their roadmap or at the inception impact assessment 
stage (https://joinup.ec.europa.eu/collection/better-legislation-smoother-implementation); Digital-ready 
policymaking boosted by COVID-19 (https://joinup.ec.europa.eu/collection/better-legislation-smoother-
implementation/news/digital-ready-policymaking-boosted-covid-19). 

9 

 
                                                           
experts.  This  partnership  needs  to  start  as  early  as  possible  in  the  policy  formulation  and 
development process. 
The Commission’s own Digital Strategy48 and Better Regulation agenda49 firmly incorporate 
digital thinking into the EU policy cycle, promoting the ‘digital-by-default’ principle in policy 
development. Digital  and interoperability  aspects  need to  be considered  at all stages:  policy 
design, stakeholder consultations, impact assessments, policy implementation, monitoring and 
evaluation. 

The aim of ‘digital checks’ as a dedicated, if evolving, component of the Commission’s Better 
Regulation Toolbox50, is to help policymakers identify and address the relevant digital aspects 
of  a  policy  early  on.  Checks  must  go  hand  in  hand  with  structural  expert  advice,  e.g.  on 
system architecture, data and cloud technologies and privacy and cybersecurity. Reuse of data 
from authoritative sources, reuse of existing solutions and uptake of innovative technologies 
will make implementation simpler and more resource-efficient, while paving the way for the 
use  of  data  analytics,  secure  and  safe  data  flows  and  Artificial  Intelligence  and  emerging 
technologies.  This  practice  has  proven  its  potential  for  simplification  and  reducing 
administrative burden51. 

For  legislative  proposals,  there  will  be  a  greater  focus  on  interoperability,  systematically 
assessing conformity with the EIF (and, if relevant any of its specialisations) and identifying 
the  scope  for  reuse  of  interoperable  systems,  concepts  and  components.  This  enables  the 
Commission  and  Member  States  to  structure  data  collection  and  monitoring  practices  and 
prevent development of duplicated and conflicting systems, vendor lock-in and unsustainable 
ICT  practices.  The  structured  cooperation  of  public  administrations  across  EU  countries 
proposed  under  the  Interoperable  Europe  Act,  will  yield  advice  on  EU  policies  with  high 
impacts  on  the  digital  infrastructure  of  Member  States  and  enable  timely implementation  of 
EU policies. 

Digital-ready  and  interoperability-by-design  policymaking  will  support  the  emergence  of 
genuinely  trans-European  digital services  for  people,  businesses  and  public  policy,  relevant 
for  the  Digital  Single  Market.  It  will  increase  cross-border  trust,  as  demonstrated  by,  for 
example,  the  EU  Digital  Covid-19  certificates,  secure  digital  identity52,  the  Internal  Market 

48  

49  

50  

51  

52  

https://ec.europa.eu/info/news/commission-adopts-new-digital-strategy-address-transformation-
opportunities-post-pandemic-world-2022-jun-30_en 
COM(2021) 219 Better Regulation: Joining forces to make better laws 
(https://ec.europa.eu/info/law/law-making-process/planning-and-proposing-law/better-regulation-why-
and-how_en) and SWD(2021) 305 Better Regulation Guidelines 
(https://ec.europa.eu/info/sites/default/files/better_regulation_joining_forces_to_make_better_laws_en_
0.pdf and https://ec.europa.eu/info/sites/default/files/swd2021_305_en.pdf) 
‘Have I considered…’ check lists in Tool #28 on digital-ready policymaking of the Better Regulation 
Toolbox: https://ec.europa.eu/info/law/law-making-process/planning-and-proposing-law/better-
regulation-why-and-how/better-regulation-guidelines-and-toolbox/better-regulation-toolbox-0_en and 
https://ec.europa.eu/info/law/law-making-process/planning-and-proposing-law/better-regulation-why-
and-how/better-regulation-guidelines-and-toolbox_en 
For instance in Denmark (https://en.digst.dk/digital-governance/digital-ready-legislation/guidances-and-
tools/) or in the healthcare sector where interoperability considerations support policy design 
(https://ec.europa.eu/health/blood-tissues-cells-and-organs/overview/revision-eu-legislation-blood-
tissues-and-cells_en). 
https://digital-strategy.ec.europa.eu/en/policies/eidas-regulation 

10 

 
                                                           
Information  System  (IMI)53  and  a  growing  number  of  cross-border  services  enabled  by  the 
Digital Single Gateway54. 

While the Commission has committed itself to digital-ready policymaking and will ensure its 
application to policy initiatives and legislative proposals, this is only the start. To make EU 
legislation  fully  digital-ready  and  interoperable-by-design,  it  is  important  to  seek,  and 
eventually  ensure,  a  shared  understanding  between  the  co-legislators,  in  full  respect  of  the 
roles  of  each  Institution.  The  common  EU  interoperability  governance  under  the  proposed 
Interoperable  Europe  Act  is  an  essential  instrument  for  helping  this  shared  understanding 
emerge. 

4.2 Focusing interoperability funding 

EU programmes provide dedicated funding for research, development and maintenance of EU 
public  sector  interoperability  resources,  such  as  interoperability  assessment  tools,  semantic 
vocabularies,  GovTech  or  reusable  building  blocks  for  data  exchange  and  electronic 
identity55. It is important that Member States IT and policy practitioners – the ultimate users 
of  these  resources  and  implementers  of  policies  –  advise  on  the  priorities  for  EU  funding 
addressing interoperability. The future Interoperable Europe Board will be tasked with giving 
advice  on  any  policy  implementation  or  innovation  support  measures  deemed  necessary,  as 
envisaged in the proposed Interoperable Europe Act. 

EU  funding  for  interoperability  also  supports  implementation  of  EU  policies  relevant  for 
digital  government, such as the Single Digital Gateway, the EU eID wallet or  Local Digital 
Twins56. With the Structural Funds57, the Recovery and Resilience Facility58, the Connecting 
Europe  Facility59,  and  the  Technical  Support  Instrument  (TSI)60,  the  EU  supports  public 
sector  modernisation  investments  in  the  Member  States.  The  EU  public  administration 
network is developing an ambitious modernisation agenda61. The Digital Decade proposal and 
the TSI make provision for multi-country projects supporting digital transformation, including 
European  Digital  Infrastructure  Consortium  (EDIC)62.  Such  modernisation  and  reform 
support  strands  should  ensure  early-stage  coordination  and  take  interoperability  needs  into 
account, for instance through regular exchange with and advice from the practitioners on the 
future Interoperable Europe Community. 

53  

54  

55  

56  
57  

58  

59  
60  

61  

62  

The IMI allows public authorities to exchange information, supporting the free movement of services 
and persons in the Single Market 
Regulation (EU) 2018/1724 establishing a single digital gateway to provide access to information, to 
procedures and to assistance and problem-solving services (https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=uriserv:OJ.L_.2018.295.01.0001.01.ENG&toc=OJ:L:2018:295:TOC) 
In particular the Digital Europe Programme (DEP), integrating earlier funding resources from the 
former ISA² and CEF Telecom programmes 
(https://ec.europa.eu/cefdigital/wiki/display/CEFDIGITAL/2018/11/08/Meet+the+new+CEF+Building
+Blocks), and Horizon Europe. 
Supported by the DEP (https://digital-strategy.ec.europa.eu/en/activities/work-programmes-digital). 
https://ec.europa.eu/info/funding-tenders/funding-opportunities/funding-programmes/overview-
funding-programmes/european-structural-and-investment-funds_en 
https://ec.europa.eu/info/business-economy-euro/recovery-coronavirus/recovery-and-resilience-
facility_en 
https://hadea.ec.europa.eu/programmes/connecting-europe-facility_en 
https://ec.europa.eu/info/funding-tenders/find-funding/eu-funding-programmes/technical-support-
instrument/technical-support-instrument-tsi_en 
Including the Strasbourg Declaration adopted in 2022 and the EUPAN 2022-2025 strategy, see at 
https://www.eupan.eu/ 
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52021PC0574 

11 

 
                                                           
4.3 Embedding interoperability into EU data and innovation policies 

Interoperability policy is a necessary complement to the emerging EU data and digital policy 
landscape. It builds on and completes legislation on data availability and data exchange, from 
a  public  sector  angle63.  It  supports  central  common  tools  like  ‘data.europa.eu’,  the  official 
portal  for  European  data64.  It  can  provide  the  semantic  expertise  needed  for  building  data 
spaces and EU cloud policy. Accordingly, and for the strengthened EU interoperability policy 
to be fully effective, a close interaction with relevant operational and regulatory digital policy 
structures needs to be  guaranteed, in  particular  with  the European Data  Innovation Board65. 
The  2030  Digital  Compass,  the  EU’s  digital  policy  reference  framework,  recognises  digital 
government  as  one  of  its  core  vectors  and  the  strengthened  EU  interoperability  policy  is 
designed to support the concomitant Digital Decade process66. 

By  default,  EU  interoperability  assets  are  available  as  open  specifications  or  open  source 
software67. They need to be open in order to be readily reusable by public administrations at 
all  levels,  that  create  interoperable  systems  and  services,  and  by  private  sector  and  industry 
partners working  with  these  administrations. While open source is  not the only  approach to 
creating  interoperability,  EU  funded  projects  for  public  services  should  be  open  source  by 
default.  This  is  why  the  proposed  Interoperable  Europe  Act  provides  for  access  to  reusable 
solutions, including code, where appropriate and possible. The Commission itself makes code 
available  as  open  source  and  contributes  to  open  source  projects68.  A  dedicated  European 
Public  License  (EUPL)  is  available  in  all  official  EU  languages  with  a  licensing  assistant 
providing online legal support69. With Open Source Programme Offices (OSPOs) or their like 
being  set  up  across  Member  State  administrations,  the  Interoperable  Europe  Board  and 
Interoperable Europe Community will be supporting best practice exchanges and help identify 
reusable solutions and development needs70. 
Close  interaction  with  standardisation  fora  and  activities71  is  particularly  important  for  the 
evolution  of  the  European  interoperability  acquis  and  for  ensuring  an  open,  inclusive  and 
value-driven  digital  transformation.  As  the  EU  is  implementing  its  renewed  standardisation 
policy  framework72,  related  public  sector  interoperability  considerations  will  systematically 
be  addressed  by  the  future  Interoperable  Europe  Board.  This  includes  contributing  to 
standardisation  ‘urgency  areas’  in  the  public  sector  and  supporting  the  EU’s  role  in 
developing standards for public services. 
The Commission’s  recently published  Innovation Agenda73 underlines the  beneficial role of 
the  public  sector,  not  only  as  regulator  but  also  as  procurer  and  experimentation  partner,  in 
the  potential  of 
strengthening 

innovation  capacity.  The  Agenda  stresses 

the  EU’ 

63  

64  
65  
66  

67  
68  
69  
70  
71  

72  
73  

Such as the Open Data Directive (https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32019L1024), the Data Governance Act 
(https://ec.europa.eu/commission/presscorner/detail/en/IP_21_6428) and the Data Act, in particular its 
chapter VIII (https://ec.europa.eu/commission/presscorner/detail/en/ip_22_1113) 
https://data.europa.eu/en 
Established with the Data Governance Act. 
https://digital-strategy.ec.europa.eu/en/library/proposal-decision-establishing-2030-policy-programme-
path-digital-decade 
Via the Joinup portal, in particular https://joinup.ec.europa.eu/collection/open-source-observatory-osor  
See https://ec.europa.eu/info/departments/informatics/open-source-software-strategy_en 
Joinup Licensing Assistant at https://joinup.ec.europa.eu/collection/eupl 
The Commission has established its own OSPO (https://joinup.ec.europa.eu/collection/ec-ospo). 
For example the Multi-Stakeholder platform for ICT standardisation 
(https://ec.europa.eu/growth/single-market/european-standards/ict-standardisation_en). 
See https://ec.europa.eu/docsroom/documents/48598 
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52022DC0332 

12 

 
                                                           
interoperability  and  encourages  exploring  public  sector  experimentation  in  controlled 
environments (sandboxes) and GovTech cooperation. 

4.4 Developing international cooperation on public sector interoperability 

EU interoperability policy is traditionally open to cooperation with international partners, in 
particular in the EU neighbourhood, and with international organisations. Interoperability by 
its very nature is borderless and EU interoperability resources are available openly for reuse 
worldwide. This is in particular the case of the EIF, referenced internationally74. In order to 
further develop  values-based international  cooperation in  digital  government, it is  important 
to  maintain  and  develop  the  existing  interoperability  cooperation  with  international 
organisations  such  as  the  OECD,  the  UN  and  the  World  Bank,  as  well  as  with  like-minded 
global partners75. 

Of particular importance is  deepening the  existing  cooperation with  the  EU neighbourhood; 
Montenegro,  North  Macedonia  and  Ukraine  are  longstanding  partners  in  developing  EU 
interoperability  cooperation  and  other  countries  signalled  strong  interest  in  joining  this 
common effort. Digital transformation of the administration is of high priority for the partners 
in  the  enlargement  and  neighbourhood  context  and  the  Commission  encourages  achieving 
high  degrees  of  interoperability  in  line  with  EU  standards.  Deepening  cooperation  supports 
pre-accession  and  economic  partnership  integration  and  should  therefore  be  a  structural 
component  in  the  EU’s  neighbourhood  policy  instruments76.  Developing  international 
cooperation is not a one-way street. It will, at the same time allow the EU to learn from and 
with  its  partners,  and  benefit  from  their  often  very  advanced  solutions,  expertise  and 
experience. 

The Commission: 

-  will incorporate digital aspects into the different stages of policy definition, development, 

adoption and implementation, as set out in its Digital Strategy; 

-  will ensure the EIF is applied in its operational and policymaking practice and seek timely 
feedback  from  Member  States  on  the  potential  implementation  challenges  of  policy 
proposals with significant digital and interoperable aspects; 

-  urges  the  co-legislators  to  endorse  digital-ready  policymaking  principles  and  ensure 
sufficient attention is paid to digital aspects at the different stages of the EU policy cycle; 
-  will ensure common interoperability resources (tools, specifications, solutions) are reused 
and  referenced  in  funding  instruments,  in  particular  for  public  sector  transformation 
(including  in  TSI,  structural  funds,  neighbourhood  and  pre-accession  support,  and  the 
RRF); 

-  will  ensure  a  close  link  of  the  interoperability  governance  with  existing  data, 
standardisation  and  sectoral  governance  mechanisms,  in  particular  the  European  Data 
Innovation Board and public sector modernisation initiatives; 

74  

75  

76  

https://joinup.ec.europa.eu/collection/nifo-national-interoperability-framework-observatory/eif-
monitoring and https://joinup.ec.europa.eu/collection/nifo-national-interoperability-framework-
observatory/digital-public-administration-factsheets-2021 
For instance with Uruguay (https://ec.europa.eu/isa2/news/european-commission-reinforces-
cooperation-uruguay-interoperability_en/) and Ukraine (https://eufordigital.eu/countries/ukraine/). 
A Commission supported assessment framework developed with the OECD’s Support for Improvement 
in Government and Management (SIGMA) programme is used for monitoring progress of public 
administration reform, and refers to ‘interoperability’ (Principles of Public Administration: 
https://sigmaweb.org/publications/Principles-of-Public-Administration-2017-edition-ENG.pdf)  

13 

 
                                                           
-  will  ensure  that  the  future  Interoperable  Europe  Board  is  involved  in  designing 
interoperability activities funded under the dedicated interoperability section of the Digital 
Europe Programme; and 

-  will  deepen  international  cooperation  on  interoperability,  in  particular  as  part  of  its 

neighbourhood policy and with international organisations. 

14