COMMISSION STAFF WORKING DOCUMENT IMPACT ASSESSMENT REPORT Accompanying the document 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)
Date: 2022-11-18
Institutions: Directorate-General for Digital Services, European Commission
Subjects: European Interoperability Framework, administrative cooperation, cross-border cooperation, data processing, digital transformation, electronic government, exchange of information, information system, public sector, public service

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 18.11.2022  SWD(2022) 721 final  COMMISSION STAFF WORKING DOCUMENT  IMPACT ASSESSMENT REPORT  Accompanying the document 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} - {SEC(2022) 720 final} - {SWD(2022) 720 final} - {SWD(2022) 722 final}  
 
 
Table of Contents 

1. 

INTRODUCTION ....................................................................................................... 6 

1.1. Societal context ....................................................................................................... 7 

1.2. Political context ....................................................................................................... 7 

1.3. Legal context ........................................................................................................... 9 

2.  PROBLEM DEFINITION ........................................................................................ 10 

2.1. What is the problem ............................................................................................... 11 

2.2. What are the problem drivers? .............................................................................. 15 

2.2.1.  Inefficient governance of interoperability efforts ........................................... 15 

2.2.2.  Lack of common minimum interoperability specifications, shared solutions, 
standards .................................................................................................................... 17 

2.2.3.  Lack of an ‘interoperability by default’ approach in the design and 
implementation of EU policies .................................................................................. 19 

2.3. How will the problem evolve in the future? .......................................................... 21 

3.  WHY SHOULD THE EU ACT? .............................................................................. 21 

3.1. Legal basis ............................................................................................................. 21 

3.2. Subsidiarity: Necessity of EU action ..................................................................... 23 

3.3. Subsidiarity: Added value of EU action ................................................................ 23 

4.  OBJECTIVES: WHAT IS TO BE ACHIEVED? ..................................................... 24 

4.1. General objective ................................................................................................... 24 

4.2. Specific objectives ................................................................................................. 25 

5.  WHAT ARE THE AVAILABLE POLICY OPTIONS? .......................................... 28 

5.1. What is the baseline from which options are assessed? ........................................ 28 

5.2. Option 1: Non-legislative ...................................................................................... 28 

5.3. Option 2: Legislative initiative - New legal framework for an interoperable EU 

public sector infrastructure and strengthened EU policy coordination .................... 29 

5.4. Option 3: Legislative initiative - New legal framework introducing a common 

European Interoperability Architecture for all public services ................................ 32 

5.5. Options discarded at an early stage ....................................................................... 33 

6.  WHAT ARE THE IMPACTS OF THE POLICY OPTIONS? ................................. 33 

6.1. Impacts of Option 0 - baseline scenario ................................................................ 34 

6.2. Impacts of Option 1: Non-legislative actions ........................................................ 35 

6.3. Impacts of option 2: New legal framework for an interoperable EU public 

sector infrastructure ................................................................................................. 39 

6.4. Impacts of option 3: Legal interoperability requirements for public sector 

bodies ....................................................................................................................... 42 

1 

 
7.  HOW DO THE OPTIONS COMPARE? .................................................................. 44 

7.1  Coherence .............................................................................................................. 46 

7.2  Effectiveness .......................................................................................................... 47 

7.3  Efficiency .............................................................................................................. 48 

7.4  Subsidiarity ............................................................................................................ 50 

7.5  Stakeholder support expected ................................................................................ 51 

8.  PREFERRED OPTION............................................................................................. 51 

9.  HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED? ....... 54 

ANNEXES ........................................................................................................................ 60 

Annex I. Procedural information .................................................................................. 60 

Lead DG: Directorate General for Informatics .......................................................... 60 

Organisation and timing ............................................................................................. 60 

Consultation of the RSB ............................................................................................ 60 

Evidence, sources and quality .................................................................................... 63 

Annex II. Stakeholder consultation .............................................................................. 65 

Summary of the stakeholder strategy ......................................................................... 65 

Summary of the feedback on the Inception impact assessment ................................. 66 

Consultation activities for the EIF evaluation and Impact assessment ...................... 67 

Results: EIF Evaluation ............................................................................................. 70 

Results: Impact Assessment ....................................................................................... 73 

Input of the Expert Group co-design process ............................................................ 81 

Annex III. Who is affected and how? ........................................................................... 85 

Citizens ...................................................................................................................... 85 

Businesses and SMEs ................................................................................................ 85 

Public sector authorities ............................................................................................. 86 

Annex IV. Methodology ............................................................................................... 86 

Overview of information and data sources ................................................................ 86 

Primary data ............................................................................................................... 87 

Secondary data ........................................................................................................... 90 

Data validation ........................................................................................................... 91 

Methods ...................................................................................................................... 92 

Main limitations ......................................................................................................... 98 

Annex V. Recommendations of the Expert group on interoperability of public 

services ..................................................................................................................... 98 

Introduction ................................................................................................................ 98 

Purpose and scope of these policy recommendations ................................................ 99 

2 

 
We share a common vision for the next interoperability policy .............................. 100 

Chapter I: Reinforce the European cooperation on interoperability ........................ 100 

Chapter II: Make the most of interoperability for better EU policies ...................... 102 

Chapter III: Upgrade the current EU interoperable solutions offering .................... 105 

Annex VI Political and policy context ....................................................................... 106 

History of Interoperability Policy ............................................................................ 110 

3 

 
 
 
 
Glossary 

Acronym 

Meaning 

AI 

CEF 

CEMR 

CEPS 

CIO(s) 

Artificial Intelligence 

Connecting Europe Facility 

Council of European Municipalities and Regions 

Centre for European Policy Studies 

Chief Information Officer(s) 

COVID-19 

Coronavirus disease 

CPSV 

DESI 

DG 

Core Public Services Vocabulary 

Digital Economy and Society Index 

Directorate-General 

DG DIGIT 

Directorate-General for Informatics 

DIF 

Domain-specific interoperability framework 

DIGIT.D2 

Directorate-General for Informatics, Directorate D Digital Services, Unit 
D2 Interoperability 

DSM 

EC 

EDIH 

EEA 

eID 

EIF 

Digital Single Market 

European Commission 

European Digital Innovation Hubs 

European Economic Area 

Electronic identification 

European Interoperability Framework 

EIF4SCC 

European Interoperability Framework for Smart Cities and Communities 

EIRA 

European Interoperability Reference Architecture 

EIS 

EQ 

EU 

European Interoperability Strategy 

Evaluation question 

European Union 

GDPR 

General Data Protection Regulation 

4 

 
HORIZON 2020  The EU funding programme for research and innovation (2014 - 2020) 

HORIZON 
Europe 

EU’s key funding programme for research and innovation (2021 to 2027) 

ICT 

Information communication technology 

IMAPS 

Interoperability Maturity Assessment of a Public Service 

ISA²  

Programme on interoperability solutions and common frameworks for 
European public administrations, businesses and citizens 

LORDI 

Local and Regional Digital Indicators Framework 

NGOs 

MIMs 

NIFs 

NIFO 

OECD 

OSLO 

Non-governmental organisations 

Minimal Interoperability Mechanisms 

National Interoperability Frameworks 

National Interoperability Framework Observatory 

Organisation for Economic Co-operation and Development 

Open Standards for Linked Organisations 

PSI Directive 

Directive on the Reuse of Public Sector Information (subsequently revised 
and renamed as the Open Data Directive 2019) 

ROI 

RFS 

SDG 

SMEs 

SRSP 

TSI  

UN  

Return on Investment 

Request for Services DIGIT/1/2020 

Single Digital Gateway 

Small and medium-sized enterprises 

Structural Reform Support Programme 

Technical Support Instrument  

United Nations  

5 

 
 
 
1.  1.  INTRODUCTION 

This  Impact  Assessment  accompanies  the  legislative  proposal  for  an  Interoperable  Europe 
Act.  The  initiative  aims  to  address  the  issues  and  capitalise  on  the  opportunities  arising 
from  the ever-increasing digital  transformation of the public sector in  Europe.  It  focuses on 
interoperability,  which  is  a  cross-cutting  enabling  factor  and  a  key  precondition  for  digital 
transformation to work across borders and sectors. 

In addition, in the context of the European Strategy for Data, it will contribute to unleash the 
potential of the new existing and proposed instruments (namely the Data Governance Act and 
the  proposal  for  Data  Act)  by  facilitating  their  implementation  through  the  setup  of  an 
interoperability governance and an ecosystem of interoperability resources. 

Interoperability  is  the  ability  of  systems  and  organisations  to  cooperate,  share  information 
and  knowledge  across  functional,  sectorial  and  physical  borders.  It  goes  beyond  technical 
means; it needs agreements between different organisations, agreed data descriptions, laws 
that  allow  for  those  data  exchanges  and  a  culture  of  cooperation1.  Moving  beyond  its 
technical  aspects,  it  expresses  a  powerful  concept:  interoperability  enables  to  have  solid 
common digital foundations on which it is possible to build better digital services. 

Digitisation is reshaping all aspects of society, including the way public administrations work 
with  one  another  and  how  public  services  are  delivered  to  citizens,  business,  and  to  one 
another  across  borders  and  sectors.  In  the  same  way,  EU  citizens’  and  businesses’ 
expectations  of  their  governments  are  shifting.  When  travelling,  submitting  their  tax 
declarations,  accessing  healthcare  services,  enrolling  in  a  foreign  university,  setting  up  a 
business in another EU country, citizens and businesses want the same user-friendly, secure, 
seamless experience from their public services as from any other digital service. The role of 
interoperability in enabling the achievement of public values should not to be underestimated. 

The aim of strengthening interoperability in this area is to ensure digital public services work 
across  borders  for  all  in  Europe,  by  fostering  a  coherent,  human-centric  approach  to 
interoperability  built  in  by  design  from  policymaking  to  policy  implementation  all  over 
Europe, establishing a clear governance and an ecosystem of solutions and specifications. 

Interoperability  is  fundamental  in  making  this  a  reality.  A  human-centric  approach  is  what 
allows,  for  instance,  a  Swedish  citizen  to  have  her  academic  title  -  acquired  in  Germany  - 
automatically recognised and valid in Italy, where she can work, and then retire  - in Spain - 
where  she  enjoys  her  pension  benefits  and  health  coverage.  Along  the  same  lines,  without 
interoperability  across  all  Member  States  of  the  European  Digital  COVID  certificates,  we 
would  not  have  been  able  to  re-open  so  fast  safe  travel  across  borders  in  Europe2. 
Interoperability  determines  the  effectiveness  of  the  emerging  –  virtual  and  physical  –  data 
infrastructures across Europe3. 

Regulating  public  sector  interoperability  is  also  a  fundamental  prerequisite  for  enhancing 
and  completing  the  Digital  Single  Market.  This  initiative  aims  to  focus  on  improving  the 
digital  infrastructure4  supporting  interoperability  cross-borders  in  Europe  in  line  with  the 
European Strategy for Data. 

In summary, the proposed Interoperable Europe Act would focus on the following areas: 

1  

2  
3  
4  

The  four  core  layers  of  the  European  Interoperability  Framework:  legal,  organisational,  semantic  and 
technical. 
EU Digital COVID Certificate | European Commission (europa.eu). 
For example, transport networks, energy, justice and home affairs, health. 
Digital  public  service  infrastructure  is  understood  in  very  broad  terms  and  underlines  legal, 
organisational, semantic, technical requirements. 

6 

 
                                                           
  Ensure a coherent, human-centric EU approach to interoperability from policymaking 

to policy implementation; 

  Establish  an 

interoperability  governance  structure  designed 

to  enable  public 
administrations  from  all  levels  and  sectors  as  well  as  private  stakeholders  to  work 
together  —  with  a  clear  mandate  to  agree  on  shared  interoperability  solutions  (e.g. 
frameworks, specifications, applications, or guidelines); and, 

  Co-create  an  ecosystem  of  interoperability  solutions  (open  standards,  data  and 
services) for the EU’s public sector, so that public administrations at all levels in the 
EU  and  other  stakeholders  can  contribute  to  and  re-use  such  solutions,  innovate 
together and create public value. 

1.1. 

1.1. 

Societal context 

Member  States  and  the  European  Union  have  been  working  for  more  than  two  decades5  to 
support  the  modernisation  of  administrations  through  digital  transformation  and  foster  the 
deep interconnections needed for a truly European digital space. The European Commission 
in  particular  has  had  five  dedicated  financing  programmes  to  support  the  development  of 
interoperability  (including  the  ISA  and  ISA²  programs)  and  will  continue  to  develop  it 
through  the  Digital  Europe  Programme.  A  European  Interoperability  Framework  (EIF)  has 
been  in  place  for  more  than  15  years  to  support  governments  in  building  integrated  public 
services. 

Member  States  have  increasingly  called  for  strengthened  EU  level  cooperation  and 
coordination  of  interoperability  relevant  aspects  across  policies6.  The  COVID-19  pandemic 
increased  the  speed  of  digitalisation,  pushing  public  administrations  to  adapt  to  the  online 
paradigm, lockdown after lockdown7. The digital transformation of the public sector enabled 
by interoperability is therefore seen as integral to the post-COVID recovery8. 

While  resilience  is  the  capacity  to  act  under  stress  and  sovereignty  is  the  capacity  to  act 
independently,  interoperability  is  an  enabling  factor  for  both  of  them,  as  the  pandemic  has 
exposed and Member States have recognised9. Interoperability is mentioned repeatedly in the 
key reform areas around digital transformation included by Member States in their plans for 
the Recovery and Resilience Facility10 where an unprecedented EUR 50 billion11 are set aside 
for digital transformation of the public sector. 

1.2. 

1.2. 

Political context 

The  importance  of  ensuring  interoperability  of  network  and  information  systems  supporting 
digital public services and data has been mentioned and recognised by the European Council 
and Member States on numerous occasions over the last few years. The Tallinn Declaration of 

5  
6  

7  

8  
9  
10  
11  

See more in Annex VI: History of interoperability policy. 
The  Member  States’  network  of  CIOs  repeatedly  discussed  the  need  of  an  ‘EU  Government 
interoperability  platform’  to  improve  coordination  and  support  implementation  of  data  and  data 
exchange related EU legislation (for instance Open Data Directive, Single Digital Gateway Regulation). 
A  McKinsey  survey  suggests  that  COVID-19  has  accelerated  digitalisation  by  7  years  globally.  The 
European  Council  and  the  European  Parliament  both  recognised  the  pivotal  role  of  digitalisation  to 
relaunch and modernise the EU economy following the COVID19 crisis (see Annex VI). 
Europe’s moment: repair and prepare for the next generation (COM(2020) 456, 27 May 2020). 
See the ‘Berlin Declaration’ signed by ministers of government digitalisation in December 2020. 
Regulation (EU) 2021/241 - ‘Recovery and Resilience Facility’. 
Calculations based on the Recovery and Resilience Plans as approved on 1 December 2021 on the basis 
of the methodology for digital tagging set out in Annex IV of the RRF, which includes specific fields 
for e-government, digital public services and local digital ecosystems. These are temporary and without 
prejudice to the final figures that will only be available once the 27 plans have been adopted. 

7 

 
                                                           
6 October 2017 on eGovernment12, the conclusions of the European Council conclusions of 9 
June  2020  on  ‘Shaping  Europe’s  digital  future’13,  or  of  October  202114  or  the  2020  Berlin 
Declaration on ‘Digital Society and Value-Based Digital Government’15 all point to the need 
to  ensure  interoperability  to  support  the  exchange  of  data,  ensure  digital  sovereignty,  and 
strengthen resilience of the public sector. 

Strengthening  the  interoperability  of  public  services  in  Europe  is  part  of  the  work  on  the 
Commission’s priority to create ‘A Europe fit for the digital age’. 

It  is  one of the initiatives  announced in  the 2020 digital  strategy  ‘Shaping Europe’s Digital 
Future’16, where the Commission promises to present a reinforced interoperability strategy ‘to 
ensure  coordination  and  common  standards  for  secure  and  borderless  public  sector  data 
flows and services’. At the same time, in the connected European Data Strategy17, one of the 
actions identified is ‘(as regards public services) a strengthened European Interoperability 
Framework’. 

The  Commission,  in  its  Communication  ‘2030  Digital  Compass:  the  European  way  for  the 
Digital  Decade’  (9  March  2021)18  pointed  out  the  need  to  establish  a  strengthened  EU 
interoperability policy to support the digitalisation of public services which is one of the four 
cardinal points of the Digital Compass. Consequently, the Commission included the initiative 
in  its  2022  work  programme,  aiming  to  present  a  legislative  proposal  by  Q2  2022  (see 
REFIT annex)19. 
The  European  Council20  and  the  European  Parliament21  both  recognised  the  pivotal  role  of 
digitalisation in helping to relaunch and modernise the EU economy following the COVID-19 
crisis. Interoperability is key to the digitalisation of public sector. 
In  October  2021,  the  expert  group  on  Interoperability  of  European  public  services22,  which 
consists  of  representatives  of  digital  transformation  leaders  in  the  Member  States’  national 
administrations, unanimously endorsed the recommendations for the next interoperability 
policy (see Annex V) and called on the Commission to take concrete actions through: 

-  A  reinforced  shared  governance  of  EU 

interoperability  (Member  States 

/ 

Commission); 

- 

Interoperability and digital-ready by-default rules to improve EU policymaking; 

-  A better offering of interoperability ‘products’ for reuse by public administration. 

12  

13  
14  
15  
16  
17  
18  

19  
20  

21  

22  

Tallinn  Declaration  on  eGovernment  at  the  ministerial  meeting  during  Estonian  Presidency  of  the 
Council of the EU - 6 October 2017. 
Council conclusions on shaping Europe’s digital future - 9 June 2020. 
European Council conclusions of October 2021. 
Ministerial Declaration ‘Digital Society and Value-Based Digital Government’ Berlin 2020. 
Shaping’s Europe Digital Future - COM(2020)67 February 2020. 
European Data Strategy - COM(2020)66 final. 
Digital  Decade.  The  point  is  also  mentioned  in  the  related  proposed  Decision  establishing  the  2030 
Policy Programme ‘Path to the Digital Decade’, COM/2021/574 final. 
COM(2021) 645 page 7. 
A  roadmap  for  recovery  –  towards  a  more  resilient,  sustainable  and  fair  Europe,  endorsed  on 
23 April 2020. 
Resolution  of  17  April  2020  on  EU  coordinated  action  to  combat  the  COVID-19  pandemic  and  its 
consequences. 
Registry of expert groups - Interoperability of European public services. 

8 

 
                                                           
1.3. 

1.3.  Legal context 

Although interoperability  has been explicitly mentioned as a precondition for numerous EU 
policies23, the topic has not been addressed by binding overarching EU policy provisions. 

Past EU interoperability programmes helped find a common understanding on interoperability 
and to build and test solutions in cooperation with Member States that are today part of many 
EU policies, for example INSPIRE (Directive 2007/2/EC)24 and eIDAS (Regulation (EU) No 
910/2014)25. 

the  EU 
The  non-binding  European  Interoperability  Framework  has  been  part  of 
interoperability  policy  since  2010  and  has  been  revised  last  in  a  communication  issued  in 
2017 
(COM/2017/134).  The  EIF  encompasses  a  set  of  principles,  models  and 
recommendations  aimed  at  guiding  the  EU  public  administrations,  as  well  as  all  levels  of 
administration, in the design and provision of key digital and interoperable public services. 
The implementation of the EIF has been supported by different funding instruments, like the 
ISA² programme and, more recently, by the Digital Europe Programme. 

However,  the  recent  evaluations  of  the  ISA²  programme  and  the  EIF  show  that  the  goal  of 
having  ‘interoperable  European  digital  services’  is  still  far  from  being  achieved  and  the 
informal  approach  to  collaboration  is  not  enough  to  allow  Member  States  to  deliver  on  the 
high level of ambition for digital public services set out in the Digital Decade communication 
and expected by citizens. 

Furthermore,  recent  initiatives  further  demonstrate  that  a  coherent  approach  towards 
interoperability  is  key  to  most  EU  policies  but  especially  relevant  for  the  successful 
implementation of EU digital policies26 and funding programmes: 

  2018  – the  Single Digital  Gateway27  and the once-only  principle; Regulation  on the 

free flow of non-personal data (FFD)28 ; 

  2019 – the EU Cybersecurity Act29 and the Open Data Directive30; 
  2020 – Digital Services Act31 and the Data Governance Act32; 
  2021 – proposals for a framework for a European Digital Identity33; the EU Digital 
COVID Certificate Regulation34; a Regulation laying down harmonised AI rules35;  
  2021 – Proposal for a Regulation (Data act); Proposal for the 2030 Policy Programme 

‘Path to the Digital Decade’36; and, 

  Funding programmes: Digital Europe Programme, Recovery and Resilience Facility, 
Horizon  Europe,  Technical  Support  Instrument  and  other  instruments  (regional 
development, agriculture, etc.). 

23  
24  

25  
26  

27  
28  
29  
30  
31  
32  
33  
34  
35  
36  

See pp. 139-140, CEPS (2021), Study supporting the evaluation of the implementation of the EIF. 
ISA² action: Improving cross-border exchange location information, more examples can be found in the 
ISA² programme evaluation, COM(2021)965. 
Final Sustainability Action Plan. 
It is also relevant  for ‘older’  policies like  the  Web-accessibility Directive, Directive (EU) 2016/2102, 
and GDPR (Regulation (EU) 2016/679) that set requirements (also) for public sector IT infrastructures. 
Regulation (EU) 2018/1724. 
Regulation (EU) 2018/1807. 
Regulation (EU) 2019/881. 
Directive (EU) 2019/1024. 
Proposal for a Regulation - ‘Digital Services Act’. 
Proposal for a Regulation - Data Governance Act, COM/2020/767 final. 
Proposal for a Regulation - European Digital Identity, COM/2021/281 final. 
Regulation (EU) 2021/953. 
Proposal for a Regulation - Artificial Intelligence Act COM/2021/206 final. 
COM(2021) 574 final. European public services targets: 100% online key public services; 100% access 
to electronic health records for citizens, at least 80% of citizens use a digital identification (ID) solution. 

9 

 
                                                           
Most  of  the  current  EU  legislation  with  an  impact  on  digital  transformation,  ranging  from 
legislation  around  data,  digital  identity,  to  sectorial  proposals  like  for  the  digitalisation  of 
cross-border justice systems have included measures on interoperability. Some have referred 
to the EIF but not all. When it comes to the implementation of these policy proposals by the 
EU public sector there is often a lack of coordination across sectors. 

The  proposed  Interoperable  Europe  Act  is  designed  to  facilitate  the  interoperable 
implementation of those policies and programmes, to enable their coherent implementation as 
well as that of future initiatives by setting up a persistent structured cooperation around public 
sector interoperability. Due to  the cross-cutting  nature of interoperability, this proposal  also 
aims  to  facilitate  the  digital  implementation  of  European  policies  both  across  borders  and 
across  sectors.  The  aim  is  to  foster  the  take-up  of  interoperable  solutions  in  future  policy 
developments,  and  equally  enhance  consistency  with  not  only  the  proposed  policy,  but  also 
consistency among policies and specifically their general digital implementation. 

In  this  context,  we  are  assessing  the  impacts  of  different  policy  options  for  the  EU  public 
sectors interoperability policy. This assessment includes the results of the evaluations of the 
implementation of the European Interoperability Framework (EIF - COM(2017) 134)37 and of 
the  ISA²  funding  programme  (2016-2020),  which  supported  the  EIF  implementation 
measures. 

2.  2.  PROBLEM DEFINITION 

The evaluations of the current interoperability policy – the EIF - and its main implementation 
mechanism  - the  ISA²  programme  –  show that  Member States have issued digital  strategies 
and  laws  that  are  to  a  high  degree  aligned  with  the  EIF.  A  number  of  solutions  supporting 
interoperability at EU level have been put in place with their support. 

However,  the  results  of  the  evaluations  show  clearly  that  the  EIF,  as  a  communication 
therefore not binding, has only supported voluntary implementation of interoperability. This 
is  not  sufficient  to  help  remove  cross-border  and  cross-sector  barriers  for  the  EU  public 
sector and has led to persistent limited interoperability of public services in Europe. 

This problem is affected by the three following drivers: 

  Inefficient  governance  of  interoperability  efforts  between  EU  policies,  the 
European  Commission  and  Member  States  for  all  administrative  levels  (national, 
regional, local) and sectors. 

  Lack  of  common  minimum  interoperability  specifications,  shared  solutions, 

standards 

  Lack of an ‘interoperability by default’ approach in the design and implementation 

of EU policies 

Both the problem and problem drivers show that the current policy approach, based solely on 
voluntary  measures  at  Member  States  level  and  no  coordination  at  EU  level,  is  not  fit  for 
purpose. They increase costs and reduce efficiencies at all levels of public administrations in 
the European Union38, add administrative burdens on citizens, businesses and administrations 
themselves,  delay  the  implementation  of  European  policies  by  the  Member  States  and  the 
accomplishment  of  the  Digital  Single  Market,  limit  the  potential to  innovate  and  hinder  the 
EU’s digital sovereignty. 

37  
38  

The results of the EIF evaluation are presented in SWD(2022)720 final. 
See Table 2. Summary of the key findings for time and cost savings estimationsTable 2. Summary 
of the key findings for time and cost savings estimations. 

10 

 
                                                           
The  above  problem,  along  with  its  causes  and  consequences,  is  summed  up  in  the  problem 
tree  (Figure  1),  which  shows  the  issues  faced  when  implementing  interoperability  of 
European public services in the current policy context. 

Figure 1. Problem tree 

2.1. 

2.1.  What is the problem 

The  main  problem  this  initiative  aims  to  tackle  is  the  limited  interoperability  of  network 
and information systems supporting digital public services in the EU. 

Interoperability  is  defined  as  ‘the  ability  of  organisations  to  interact  towards  mutually 
beneficial  goals,  involving  the  sharing  of  information  and  knowledge  between  these 
organisations, through the business processes they support, by means of the exchange of data 
between  their  ICT  systems’.  Interoperability  is  crucial  in  the  implementation  of  digital 
government policies. 

‘Building  a  digital  state  without  interoperability  is  like  building  a  house 
without a foundation – it will not work’ (Keegan McBride, 202139).  

Currently there are no studies that differentiate precisely the impact of interoperability from 
the  one  of  the  overall  digital  transformation  of  the  public  sector,  but  numerous  sources 
highlight interoperability as a key enabling factor and a pre-condition for success on the path 
to successful digital public sector transformation. This is even more the case when we look at 
cross-border interoperability of digital public services. 

Thus, limited interoperability of services and data of public administrations in EU leads to 
limited  digital  public  services,  incapable  of  reaching  their  full  potential  and  deliver  on 
European goal of having a Digital Single Market. 

This  problem  is  quite  visible  when  looking  at  both  the  level  of  implementation  of  digital 
public  services  in  EU  and  the  results  of  the  evaluations  of  the  EIF  and  ISA²  programme, 
which show there is still an important gap to fill. In the latest  Digital Economy and Society 
Index (DESI) the EU average for cross-border digital public services is below 60 out of 100. 

39  

Keegan McBride – Hertie School of Governance – ‘Ohne Interoperabilität kein digitaler Staat’. 

11 

 
 
                                                           
Figure 2. DESI 2020 for cross-border services status in Member States 

Looking at the situation of EU border regions in 2021 a Commission report 43 underlines that 
‘in  the  2020  public  consultation,  respondents  identified  difficulties  in  accessing  reliable 
public transport as the main obstacle to using cross-border public services, closely followed 
by  the  lack  of  joint  digital  services.’  It  also  highlights  that  the  lack  of  cross-border 
interoperability  of  digital  systems  in  border  regions,  particularly  of  those  dealing  with 
employment  services,  leads  to  difficulties  in  identifying  available  jobs  or  reaching  out  to 
potential  employees  due  to  the  lack  of  job  market  integration  and  of  coordination  amongst 
services. 
In  the  latest  EUPACK  study  of  202140,  we  can  see  a  big  gap  between  in  Digital  public 
services provision between Member States, varying from a low of 48 to a high of 89 out of 
100 with an average at 72. This hampers their overall societal and state resilience. 

Figure 3. EUPACK study 2021 first conclusions on digitalisation 

The  JRC  report  that  has  analysed  in  depth  Digital  Government  transformation  in  the  EU 
found  that  the  provision  of  digital  public  services  across  the  EU  is  hampered  by  several 

40  

Will be publicly available in the country reports made by DG REFORM. 

12 

 
 
 
                                                           
factors,  many  of  which,  like  administrative  silos,  fragmented  decision-making  and  lack  of 
coordination41, can be linked to insufficient interoperability. 

The  stakeholders  consulted  in  the  context  of  the  evaluation  of  the  EIF  report  that  the 
framework’s  voluntary  nature  and  the  scope  of  its  recommendations  contribute  only  to  a 
limited extent to the establishment of the Digital Single Market (DSM), most likely due to the 
limited amount of interoperable cross-border services available. 

A higher ranking on digital performance does not always mean that a Member State’s digital 
services  will  be  available  in  cross-border  cases.  The  numbers  of  the  2021  eGovernment 
Benchmark  report42  confirm  this:  only  43%  of  services  are  online  for  cross-border  users. 
Currently,  only  a  quarter  of  the  services  (24%)  enable  access  with  eIDs  from  multiple 
European countries. Even though since 29 September 2018, all EU citizens of countries who 
have notified their eID scheme to the Commission pursuant to the eIDAS regulation should be 
able  to  use  them  in  other  Member  States.  This  is  both  a  question  of  availability  of  eID  for 
citizens but also an interoperability issue as was pointed out in the impact assessment for the 
new proposal on Digital Identity43. 

Figure 4. eGovernment benchmark 2021 - Key figures (EU27+ biennial average) 

Although the EIF has given value to the EU, cross-border interoperability remains limited 
and driven by sectoral needs. It has been driven by specific EU legislation like the eIDAS 
and now the Single Digital Gateway regulations. For example, several studies44 assessing how 
ready Member States are to connect to and exchange data ‘once-only’45 showed a lack of legal 
and  semantic  interoperability  alignment  (different  data  models  and  evidence46  types 
implemented in the Member States). 

From  the  EIF  evaluation,  we  also  see  that  countries  that  have  aligned  their  National 
Interoperability Framework with the European one have more citizens interacting with public 
administrations online. There is a visible positive correlation between the overall performance 

41  

42  
43  
44  
45  

46  

Exploring Digital Government Transformation in the EU - Understanding public sector innovation in a 
data-driven society - Misuraca, G., Barcevičius, E. and Codagnone, C. (JRC). 
eGovernment benchmark 2021 | Shaping Europe’s digital future (europa.eu). 
COM(2021)281. 
Final Sustainability Action Plan. 
Article 14 of the Single Digital Gateway Regulation (SDGR) establishes the ‘once-only-principle’ (i.e. 
users should not have to submit to authorities documents or data already held by other authorities) will 
be applied to cross-border exchanges of evidence for a range of procedures. 
SDGR article 2: ‘evidence’ means any document or data, including text or sound, visual or audiovisual 
recording,  irrespective  of  the  medium  used,  required  by  a  competent  authority  to  prove  facts  or 
compliance with procedural requirements referred to in point (b) of Article 2(2). 

13 

 
 
                                                           
in  the  maturity  of  digital  public  administrations  and  their  adoption  of  an  EIF-inspired 
framework. The lower ranked Member States (e.g. Romania)  have not put in place a robust 
interoperability framework, while the frontrunners (e.g. Spain, Estonia, the Netherlands) have 
well established frameworks that make a difference. 

Figure  5.  Average  effects  of  having  a  ‘complete’  and  ‘incomplete’  EIF  based  NIF  vs. 
countries that did not adopt an EIF-based NIF on the level of Internet use to interact with 
public administrations 

The  next  step  in  the  path  to  fully  digitalised  governments  is  to  move  towards  providing 
proactive  services  to  citizens  and  businesses,  services  which  bring  state  support  when  it  is 
needed. For instance Estonia, where digital public services are amongst the most advanced in 
the  world,  enables  citizens  to  complete  tax  forms,  renew  a  passport,  and  access  family 
benefits  in  only  a  few  clicks  assisted  by  the  app  Bürokratt  which  they  define  as  an 
‘interoperable  network  of  AI  applications’.  These  types  of  proactive  services  are  currently 
used  by  only  6%  of  the  examined  government  services  and  are  not  possible  without 
interoperability47.  With  limited  interoperability  at  national  and  European  level,  citizens  and 
businesses  will  be  stuck  exchanging  PDFs  as  evidence,  which  is  a  common  practice  in  the 
digitalisation of sectorial policies for instance, instead of moving to fully automated end-to-
end digital processes and services. 

The  described  problem  persists  even  though  the  European  Commission  has  been 
continuously  working  to  address  the  issue  for  more  than  25  years48:  The  stakeholders 
consulted  during  the  EIF  evaluation  perceive  that  the  policy  has  brought  limited  benefits  to 
the  development  of  a  coherent  European  public  services  ecosystem  and  the  achievement  of 
interoperable,  user-centric  public  services  in  the  EU49.  The  current EIF  recommendations, 

47  
48  

49  

eGovernment benchmark 2021 | Shaping Europe’s digital future (europa.eu). 
Objective  of  the  IDA  programme  (Decision  (95/468/EC)):  ‘To  improve  the  efficiency  of  the  internal 
market  by  allowing  administrations  to  exchange  essential  information  via  interoperable  telematics 
networks.  It  is  aimed  at  coordinating  the  development  and  implementation  of  telematics  applications 
and services that enable national and European level administrations to transfer information in a number 
of critical areas.’ 
See Annex II. 

14 

 
 
                                                           
principles  and  the  conceptual  model  have  only  partially  helped  meet  the  goals  established 
when the framework was created in back 2005, then revised in 2010 and 201750. 

Even within countries and across sectors interoperability is not ensured. For example, less 
than  half  of  the  services  (44%)  participate  in  a  single  sign-on  scheme,  meaning  that  users 
often  need  to  re-authenticate  when  switching  between  websites  of  different  competent 
authorities even within the same ‘Life event journey’51. 

As  citizens’  expectations  and  upcoming  requirements  (like  the  ones  brought  by  the  Single 
Digital Gateway Regulation), are difficult to meet because of limited interoperability, the EU 
foregoes  the  benefits  of  interoperable  digital  public  services.  This  translates  into  a  loss  of 
significant time savings for citizens and businesses. Two examples can be highlighted: 

 

 

through  the  implementation  of  the  Estonian  interoperability  platform  X-Road  it  is 
estimated that Estonians are saving 844 person-years of working time annually; 

further digitalising public services in Germany, which has one of the lowest levels of 
interoperability amongst Member States, is estimated to potentially enable cuts of over 
80 million hours per year for citizens in their interaction with public authorities, help 
save up to EUR 1 billion in administrative costs for businesses and 64 million hours 
per year for public administrations themselves52. 

2.2. 

2.2.  What are the problem drivers? 

The  problem  of  limited  interoperability  of  services  and  data  of  public  services  in  Europe 
described above is driven by a number of factors analysed further below. 

2.2.1.  2.2.1. 

Inefficient governance of interoperability efforts 

The  evaluation  of  the  EIF  emphasizes  the  inefficiency  of  current  governance  of 
interoperability efforts between EU policies, the European Commission and Member States 
for all administrative levels (national, regional, local) and sectors. 

Limited  coordination  and  cooperation  on  interoperability  efforts  between  and  within 
Member States and with the EU level, when introducing digital solutions for public services is 
one of the identified drivers of the limited interoperability persisting at EU level. 

50  
51  

52  

See timeline of Interoperability initiatives and EIF. 
‘Life event journey’:  Life  events are events that  have a significant  impact  in a citizen’s/stakeholder’s 
life  and  that  warrant  government  awareness  or  involvement,  for  instance  birth  of  a  child,  divorce, 
buying  a  house.  A  journey  is  the  path  the  user  needs  to  go  through  in  his/her  interaction  with  the 
government services to manage the life event. 
More detailed in Chapter 6: Impacts of policy options. 

15 

 
                                                           
Figure 6. Extent to which the following needs and problems and currently experienced by 
European  public  administrations,  businesses  and/or  citizens  (breakdown  by  type  of 
consultation, average score and number of respondents) 

Cross-border  projects  face  particular  challenges  that  affect  the  timing  and  efficiency  of 
delivery.  The  involvement  of  more  than  one  Member  State,  and  often  of  multiple  regional 
and/or local authorities, can particularly impact the timely delivery of digital public services.  

Any delay or obstacle on one side of a border will necessarily impact project delivery and the 
implementation of EU policies. We have seen this time and time again with the delays in the 
development  of  the  implementing  act  on  the  ‘once-only-principle’  for  the  Single  Digital 
Gateway or the issues with sharing data. 

Policy support measures often include digital solutions and specifications which are inscribed 
in EU or national laws before being taken up by the teams that have to implement them (often 
services equivalent to DG DIGIT at Member State level). And when cross-borders or cross-
sectoral exchanges of information or services are needed, interoperability is automatically at 
play. 

At European Commission level, we estimate that 47.2% of policies53 have a digital impact. 
Today  there  is  no  systematic  coordination  or  cooperation  to  ensure  solutions  and 
specifications  (and  in  general  everything  that  can  be  grouped  together  as  ‘interoperability 
resources’)  are  shared  and  reused  when  implementing  EU  policies.  Nothing  similar  to  the 
governance  structure  for  IT  in  the  European  Commission54  exists  for  the  work  with  the 
Member  States.  The  EIF  evaluation  shows  that  the  governance  of  the  selection  and 
adoption of standards and specifications is currently not sufficient55. 

Various models of interoperability governance exist within Member States between different 
levels  of  government.  In  some  cases,  interoperability  is  mandated  through  legislation,  in 
others coordination mechanisms exist with cities and/or regions working together to develop 
common standards, templates and models, promoting interoperability between them, and with 
central government. 

The EIF evaluation showed that in some cases a lack of internal interoperability coordination 
within Member States further  enhances the disconnect  between the high-level  guidance  and 
actual execution. Often Member States, even at national level in centralised states, have more 

53  
54  

55  

Digital ready policymaking. 
COM(2018)7704  -  Streamlining  and  strengthening  corporate  governance  within  the  European 
Commission. 
State of Play of Interoperability Report 2020, p. 40. 

16 

 
 
                                                           
than  one  entity  (e.g.  Ministry  or  Agency)  leading  digital  transformation  efforts56,  which 
sometimes leads to a lack of coordination. 

The EIF evaluation shows a further disconnect between the high-level guidance provided by 
the EIF and actual execution, particularly at the regional and municipal levels. Cross-border 
interoperability  is  not  solely  a  matter  for  the  national  level  of  the  administrations  in  the 
Member  States.  Data  and  services  are  routinely  interacting  between  regional  and  local 
administrations  in  different  Member  States.  Thus,  interoperability  between  national 
administrations is not sufficient if interoperability at the local level does not work. Signatories 
of  Living-in.EU57  emphasized  that  due  to  this  inefficient  governance  investments  in  digital 
transformation at local level have a low impact and lead to sub-optimal outcomes for citizens 
in the quality of public service delivery58.  

The  coordinated  digital  response  to  the  COVID-19  pandemic  within  and  amongst  Member 
States is a topical example of the advantage of governance, coordination and cooperation on 
interoperability across public and private organisations in the face of major shared challenges. 
This coordinated response, however, was emergency-driven and not based on established and 
structured  joint  approaches.  Indeed,  the  absence  of  such  structures  does  not  necessarily 
prevent  successful  crisis  response  or  the  digitalisation  of  individual  public  services  per  se. 
However,  analysis  finds  that  not  addressing  interoperability  ‘by  design’  in  upstream 
coordination risks building disconnected data and operational islands across administrations. 
Using  non-compatible  specifications,  standards  and  tools  in  an  uncoordinated  way,  risks 
leading to costly and/or isolated ad-hoc solutions, lock-in situations and missing out on scale 
effects.  Negative  consequences  may  be  felt  by  administrations  themselves  but  more  so  by 
end-users,  who  increasingly  expect  the  same  kind  of  seamless  service  experience  when 
dealing with public administrations which they are used to from private sector offers.  

2.2.2.  2.2.2. 

Lack  of  common  minimum  interoperability  specifications, 

shared solutions, standards 

The OECD states that ‘one of the most frequently cited barriers to data sharing and reuse 
is the lack of common standards, or the proliferation of incompatible standards’59. This is 
confirmed by the 2020 public consultation for the European strategy for data, where 91.5% of 
the  respondents  agreed  that  standardisation  is  necessary  to  improve  interoperability  and 
ultimately data reuse across sectors. 91.1% of respondents agreed that future standardisation 
activities need to better address the use of data across sectors of the economy or domains of 
society60. 

Meanwhile,  the  limited  availability  and  take-up  of  common  minimum  interoperability 
specifications, shared solutions and standards for the public sector particularly at the levels of 
regional and local administrations has been confirmed as a key challenge in the evaluations of 
ISA²  and  the  EIF.  This  challenge  has  not  been  addressed  by  the  Open  Data  Directive 
(Directive (EU) 2019/1024). Also, the future EU Data act limits its scope to commercial data 
held  by  public  authorities.  This  implies  that  Member  States  would  not  be  supported  with 
concrete guidelines, solutions or specifications to ensure interoperability of their public data. 

56  
57  

58  

59  

60  

More details in: Digital Public Administration factsheets - 2021 | Joinup (europa.eu). 
Living-in.EU  is  a  2019  declaration  of  European  cities  and  communities,  supported  by  the  European 
Commission and other partners. It has set up a governance which aims to boost the sustainable digital 
transformation of cities and communities. 
Living-in.EU  Signatories’  Meeting  of  28  October  2021 
  and  the  workshop  on  Multilevel 
interoperability governance supporting digital transformation of European public administrations at the 
Fit for recovery and transition - Online Conference, 25 November 2021. 
OECD (2019). Enhancing Access to and Sharing of Data: Reconciling Risks and Benefits for Data Re-
use across Societies. 
European Commission (2020b). Outcome of the online consultation on the European strategy for data. 

17 

 
                                                           
The Proposal for a European Interoperability Framework for Smart Cities and Communities 
(EIF4SCC) is a first initiative that gives guidance to interoperability specifications. 

While  the  principles,  the  layered  interoperability  model,  and  the  conceptual  model  for 
integrated public services in the EIF provided sufficient high-level conceptual guidance, there 
is still a gap when it comes to the practical implementation of the EIF at the service level with 
reusable common interoperability solutions and specifications61. Stakeholders commenting on 
the  inception  impact  assessment  provided  several  concrete  ideas  on  how  to  achieve  this 
goal62:  ‘all  EIF  recommendations  should  be  provided  with  a  reference  implementation 
standard’, another stakeholder goes further and asks that ‘all EU policy should come with a 
reference solution to guide its digital implementation’. 

Missing interoperability specifications and standards can also hinder the development and use 
of innovative technologies, such as blockchain, AI or APIs63. That then can help also public 
administrations  that  are  already  highly  digitalised  without  an  ‘interoperability  by  default’ 
approach  because  they  need  to  overcome  the  challenge  of  legacy64  solutions  (e.g.  the 
difficulties  experienced  in  the  implementation  of  the  Single  Digital  Gateway  Regulation  by 
the more digitally advanced Member States). 

Another  important  factor  contributing  to  the  lack  of  development  and  uptake  of  common 
interoperability  solutions  consists  of  the  limited  incentives  and  capacities  for  public 
administrations.  An  important  finding  from  the  ISA²  final  evaluation  in  this  regard  is  that 
EU funding instruments today do not contain sufficient incentives to ensure the development 
of solutions in line with the EIF65. 

The Expert group on interoperability of European public services particularly highlighted that 
EU  policies  often  come  with  competing  and  non-interoperable  standards.  For  instance, 
Estonia  highlighted  in  a  contribution  to  the  expert  group  that  8  different  cross-border  data 
exchange protocols are being used of enforced in just one domain from different Commission 
initiatives66.  The  current  EU  policy  agenda  contains  a  substantial  number  of  initiatives  that 
provide the Commission with a mandate to adopt standards or technical specifications for IT 
systems used by public administration. For example, technical specifications for the renewed 
digitalisation of judicial cooperation67 or a future European Social Security Pass announced in 
the  European  Pillar  of  Social  Rights  Action  Plan68.  Even  though  all  of  the  mentioned 
initiatives  aim  to  align  with  each  other,  there  is  no  mechanism  today  to  ensure  that  the 
solutions proposed are interoperable, which can lead to new barriers to interoperability. 

Therefore,  cooperation  and  effective  alignment  between  sectorial  and  cross-domain 
public  sector  data,  standards  and  specifications  is  needed.  Such  cooperation  mechanism 
should ideally involve the experts from the Member States’ administrations already involved 
in implementing the parallel work strands listed above. This is an explicit call from the Expert 
group  policy  recommendations  to  ensure  consistency,  prevent  creation  of  sectoral  silos  and 
reduce implementation burdens on their side. 

61  

62  
63  
64  
65  
66  
67  
68  

In the context of the ISA2 programme, interoperability solutions were defined as ‘common services and 
generic tools facilitating cooperation between disparate and diverse organisations, either autonomously 
funded  and  developed  under  the  ISA2  programme  or  developed  in  cooperation  with  other  Union 
initiatives,  based  on  identified  requirements  of  European  public  administrations’,  building  also  on 
common specifications and standards. See: Article 2, Decision (EU) 2015/2240. 
Input can be found on the Have Your Say Portal, a summary of input is provided in Annex II. 
JRC Policy for Science report gives insides on how APIs can help overcome legacy issues. 
Legacy IT systems refers to solutions, specifications, technologies outdated but still in use. 
See ISA² programme evaluation in COM(2021)965 
Expressed in position paper from December 2020 on a future interoperability policy (not public) 
COM(2021) 759 final. 
European pillar of social rights action plan 

18 

 
                                                           
2.2.3.  2.2.3. 

Lack  of  an  ‘interoperability  by  default’  approach  in  the 

design and implementation of EU policies 

Member  States  have  prominently  called  upon  the  Commission  and  other  institutions,  most 
recently in the Berlin Declaration, to ensure that ‘policies and legislative acts proposed by the 
European  Commission  are  digital-ready  and  interoperable  by  default’69.  The  consultation 
activities and the work with the Member States experts showed that public administrations are 
struggling  to  translate  requirements  from  EU  policies  into  concrete  interoperable  digital 
services. They expect that this problem could be solved by changing the way EU policies are 
designed,  learning  from  the  Danish  approach  to  digital-ready  legislation  that  was  recently 
evaluated70. 

The  EIF  and  ISA²  evaluation  confirm  this  assumption:  interoperability  actions  are  the  most 
beneficial  and  effective  if  clearly  linked  with  EU  policies.  The  evaluation  however  also 
confirms that the EIF is underutilised across sectors and even by Commission services. 

Interoperability by design was emphasised as vital for effective cross-border contact tracing 
apps  in  the  EU.  The  argument  around  the  EU  Digital  COVID  certificate  included 
standardisation and interoperability. 

Due to the voluntary participation in the implementation of the EIF and the voluntary take 
up  at  EU  level  of  interoperability  resources  developed  through  the  Interoperability 
programmes  (ISA²  and  predecessors),  a  coherent  approach  to  the  topic  is  missing,  beyond 
what has been set up through specific sectorial obligations (e.g. justice, transport). Even when 
digital  resources  are  foreseen  in  EU  legislation,  they  do  not  apply  ‘interoperability  by 
default’  principles  as  there  is  currently  no  uniform  legal  and  technical  framework  to 
establish them. 

For instance, the EIF as  the main point of reference of the  current  interoperability policy is 
mentioned only 18 times in the EU common acquis (see Figure 7). It is not mentioned at all in 
the Single Digital Gateway Regulation or the eIDAS Regulation. To put this into perspective, 
the  Spanish  law  on  digital  public  administration71  refers  136  times  to  the  Spanish  National 
Interoperability  Framework  (NIF),  and  interoperability  is  mentioned  899  times,  while  the 
latest  Spanish  act  on  the  topic  (the  Royal  decree  203/202172)  mentions  interoperability  88 
times and the NIF 24 times. This increase inclusion of ‘interoperability by default’ has led to 
considerable  momentum  gain  in  Spain’s  public  sector  digitalisation  efforts  over  the  same 
period, visible in the annual DESI figures (2015: 60%, 2020:82%)73. 

69  

70  

71  
72  
73  

Berlin Declaration on Digital Society and Value-Based Digital Government at the ministerial meeting 
during the German Presidency of the Council of the European Union on 8 December 2020, p.13. 
For further information see,  Evaluation of  the effort to  make legislation digital-ready (2021), Agency 
for Digitalisation, Ministry of Finance. 
BOE.es - Código de Administración Electrónica. 
BOE.es - BOE-A-2021-5032 Real Decreto 203/2021. 
DESI - Spain | Shaping Europe’s digital future (europa.eu). 

19 

 
                                                           
Figure  7.  Number  of  times  the  EIF  and  connected  keywords  were  mentioned  in 
regulations, directives and decisions between 2004 and April 2021 

Source:  Study  supporting  the  evaluation  of  the  implementation  of  the  EIF based on  the  CEPS  EurLex  dataset 
and the EurLex website. 

This  finding is  not  caused by a lack of EU policies addressing  digitalisation issues. As it is 
quite visible from the legal and political context, there is a large number of EU and Member 
States policies which have a digital impact. Before the current COVID-19 crisis the keyword 
digital was appearing in 14.5% of announced EU policy proposals, now their share went up to 
47.2%74. 

This is also reflected in the feedback received from the Member States in the Interoperability 
expert group (especially in their recommendations) and throughout the public consultations. 

‘We  need  an  interoperability  policy  that  is  focused  on  enabling  smooth,  interoperable 
implementation and delivery of digital public services at European level without adding new 
obligations  on  Member  States  and  that  helps  increase  our  overall  digital  maturity’  – 
Recommendations  from  the  expert  group  on  Interoperability  of  European  Public  Services75 
(October 2021). 

The Member States have repeatedly highlighted that in general much of the challenge in terms 
of interoperability can be related to issues with legal implementation. Differences in national 
legislation result in different national processes and standards for data-handling, which make 
interoperability across borders more difficult. 

Another side effect of having many EU policies that have an impact on digitalisation of the 
public  sector  is  that  there  is  an  increase  in  reporting  obligations  on  the  public 
administrations of the Member States. Member States authorities need to provide data, mostly 
by  replying  to  surveys,  for  the  establishment  of  DESI,  the  National  Interoperability 
Framework  Observatory,  for  the  upcoming  Digital  Compass,  Single  Digital  Gateway 
Regulation, etc. Beyond EU policies they also provide data to the OECD digital government, 
UN  e-government,  Berlin  Declaration  monitoring  surveys.  There  is  only  anecdotical 
automated data collection or sharing of collected data between these mechanisms. 

There  are  also  legal  uncertainties  related  to  the  topic  on  how  to  facilitate  GDPR-compliant 
data  sharing,  intellectual  property  issues  when  sharing  and  reusing  IT  systems,  or  the 
challenge  of  technical  specifications  that  need  to  constantly  evolve  in  legal  texts.  Those 
blocking factors hinder the scaling up of digital public services across EU Member States and 
must be addressed systematically. 

74  
75  

Digital ready policymaking boosted by COVID-19. 
Register of Commission expert groups and other similar entities (europa.eu) . 

20 

 
 
                                                           
2.3. 

2.3.  How will the problem evolve in the future? 

In  the  literature  there  is  no  argument  for  less  action  on  interoperability  and  digital 
transformation of the public sector or for an expectation that the existing problems could be 
resolved  by  individual  actors  alone.  Without  common  action  and  shared  ownership  of 
interoperability  policies  at  EU  level,  the  gap  between  the  needs  of  citizens,  businesses  and 
especially public administrations across Europe will continue to grow. 

Data sharing and re-use is paramount to shape Europe’s digital future. However, data remains 
fragmented across numerous domains as well as across borders. One of the most frequently 
cited  barriers  holding  back  better  data  use  is  the  lack  of  common  standards,  or  the 
proliferation  of  incompatible  standards.  For  example,  inconsistent  data  formats  are 
impediments  to  the  creation  of  longitudinal  data  sets,  as  changes  in  measurement  and 
collection practices make it hard to compare and aggregate data’76.  

Moreover, the value of data becomes more important in data-centric societies in which more 
evidenced decisions can be made. However, numerous relevant data are still not fully used by 
the  public  sector  for  their  delivered  services  and  developed  policies.  In  order  to  unlock  the 
wealth of data, public sector interoperability is indispensable. 
The problem drivers described above are linked to a constant increase in data traffic77 and to 
the  mobility  of  citizens  and  businesses  in  the  EU.  This  automatically  leads  to  a  constant 
increase  in  the  usage  and  requests  for  cross-border  services  and  exchanges  of  data.  For 
instance, there is a significant number of people who cross borders for the purposes of tourism 
– 64.7% of EU citizens aged 15 or more did so in 2019 and there is an upward trend in the 
total number of nights that tourists spend in a country other than their own (from 100 in 2005 
to  157.8  nights  in  201978).  In  times  of  COVID-19,  most  tourists  will  be  requested  to  show 
their ‘Green passes’79. They can use the app from their home country to do so, thanks to the 
interoperable  EU-level  standards  that  those  apps  are  based  on.  But  tourists  might  also  be 
required to show that the car they are using can enter a certain zone of the city restricted to 
electric vehicles etc. Interoperability could help here and in a large number of other use cases 
to provide real time clearance, data and services. 

Furthermore, by relying  on the internet  (as a borderless  structure), including for their  work, 
individuals are increasingly requiring cross-border services. The number of people living in a 
foreign  country  is  also  trending  upwards  –  Eurostat  has  found  that,  in  2019,  3.3%  of  EU 
citizens  of  working  age  (20  to  64)  lived  in  another  Member  State,  as  compared  to  2.4%  in 
200980. With more and more people finding themselves in a cross-border situation, it is to be 
expected that the usage of cross-border services and exchange of data will increase, placing 
an even greater burden on public administrations. 

3.  3.  WHY SHOULD THE EU ACT? 

3.1. 

3.1.  Legal basis 

The problems described in Chapter 2 show a need for EU action to foster interoperability of 
network  and  information  systems  supporting  public  digital  services  in  the  Union  across  all 
levels and sectors of government.  

76  

77  
78  
79  
80  

OECD (2019). Enhancing Access to and Sharing of Data: Reconciling Risks and Benefits for Data Re-
use across Societies; JRC paper on Business-to-business data sharing, forthcoming. 
Crossing borders - World Bank. 
Nights spent abroad by EU residents - Eurostat. 
REGULATION (EU) 2021/953 - EU Digital Covid Certificate. 
https://ec.europa.eu/eurostat/statistics-
explained/index.php?title=EU_citizens_living_in_another_Member_State_-_statistical_overview 

21 

 
                                                           
and  development  of 

trans-European  networks’ 

The EU’s competence to act in relation to interoperability of trans-European networks is 
set  out  in  Articles  170  -  172  of  the  TFEU,  which  requires  the  EU  to  ‘contribute  to  the 
establishment 
the  area  of 
telecommunications.  Article  171(2)  states  that  ‘Member  States  shall,  in  liaison  with  the 
Commission, coordinate among themselves the  pursued  polices  at  national  level  which may 
have a significant impact’ on the objective of the establishment of trans-European networks, 
and  the  ‘Commission  may,  in  close  cooperation  with  the  Member  States,  take  any  useful 
initiative  to  promote  such  coordination’.  Hence,  action  to  ensure  a  coherent,  human-centric 
approach to interoperability from policymaking to policy implementation, accompanied by a 
clear governance to streamline shared interoperability frameworks, solutions, guidelines and 
specifications  for  digital  public  services  across  EU  borders  is  within  the  scope  of  the  EU’s 
right to act. The EU shares competence in this area with the Member States. 

in 

The  Union  has  used  this  legal  base  and  its  predecessor  since  1994  to  create  funding 
programmes  supporting  the  development  and  dissemination  of  interoperability  solutions  for 
public  administrations  and  businesses  as  well  as  the  set-up  of  cross-border  digital  services 
infrastructures. The Court of Justice of the European Union decided with its judgment in the 
case C-22/96 of 28 May 1998 that Union measures contributions to the ‘telematic interchange 
of data between administrations in the Community’ (IDA)’ fall within the ambit of the trans-
European networks for telecommunication Articles 170 – 172 TFEU and that Art. 114 TFEU 
cannot be used. 

Under  this  legal  base,  the  EU  can  go  beyond  providing  funding;  the  Union  can  establish 
guidelines, identify projects of common interest, implement any measures necessary to ensure 
the  interoperability,  take  initiatives  to  promote  coordination  between  Member  States,  and 
cooperate with third countries for similar purposes (Article 171 TFEU). In the framework of 
other trans-European networks binding standards necessary to ensure the interoperability for 
the respective sectors (e.g. energy and transportation) and governance frameworks with clear 
roles and mandates have been established. For example, the Digital Europe Programme based 
among  others  on  Art.  172  TFEU  defines  a  wide  scope  of  potential  actions  for  the 
interoperability of European public service. Highlighting that interoperability81 

- 

- 

- 

- 

- 

‘concerns all levels of administration: Union, national, regional and local’,  

‘is  to  be  understood  in  broad  sense,  spanning  to  technical  and  legal  layers  and 
encompassing policy elements,’  

removing ‘barriers to a functioning internal market’,  

‘facilitates  cross-border  cooperation  and  the  promotion  of  European  standards  and 
the successful implementation of policies’  

‘offers great potential for avoiding cross-border electronic barriers, further securing 
the emergence of new, and the consolidation of developing, common public services at 
Union level’, 

-  needs ‘a holistic cross-sector and cross-border approach’, 

- 

action facilitates ‘cross-fertilisation between different national initiatives’. 

The objectives of this initiative to contribute to a Digital Single Market and to connect remote 
areas  fit  well  with  the  objectives  of  trans-European  networks  that  shall  help  to  reach  the 
objective  of  the  Internal  Market  (Article  26  TFEU)  and  economic,  social  and  territorial 
cohesion of the EU (Article 174 TFEU). The interoperability-related activities under Digital 

81  

Regulation (EU) 2021/694, Recital 53. 

22 

 
                                                           
Europe Programme will contribute to the implementation of the future interoperability policy 
though a series of projects on legal, organisation, semantic and technical interoperability. 

3.2. 

3.2. 

Subsidiarity: Necessity of EU action 

The  evaluation  of  the  European  Interoperability  Framework  shows  that  the  digital  (and 
interoperable)  transformation  of  the  EU  public  sector  requires  greater  EU  cooperation, 
common  rules  and  initiatives.  The  concrete  needs  across  all  levels  and  sectors  of  public 
administrations that recently became more prominent during the COVID-19 crisis are a telling 
example. 

The COVID-19 crisis has shown that cooperation and governance mechanisms are needed not 
just to improve basic public services but also to build resilience and the capability to deal 
with  unexpected  emergencies.  During  the  pandemic,  countries  with  more  digitalised  and 
interconnected governmental administrations and services reported less service disruptions82. 
The  pandemic  also  highlighted  the  need  for  better  governance  of  response  mechanisms 
across  the  EU.  The  lack  of  data  consistency  hampered  the  EU’s  capacity  to  respond 
cooperatively early in the outbreak83. Interoperability by design was emphasised as vital for 
effective  cross-border  contact  tracing  apps  in  the  EU84.  The  work  around  the  EU  Digital 
COVID  certificate  mainly  consisted  of  working  out  a  standard,  interoperable  technical 
approach among the Member States. 
The Tallinn Declaration of 2017 and the Berlin Declaration of December 202085, the call of 
the Living-in.EU movement and the recommendations of the expert group on interoperability 
of European public services show that public administrations across EU countries see a need 
for coordinated EU action. In the same line, the EIF evaluation notes that in the absence of a 
common  approach,  the  development  of  a  cohesive  landscape  of  digital  and  interoperable 
public  services  across  the  EU  would  be  hindered  by  divergent  measures  taken  at  the 
national level. 

In addition, enhanced interoperability can significantly contribute to overarching goals for 
the  Digital  Single  Market,  the  digital  agenda  of  the  EU86,  fostering  innovation,  ensuring 
digital  sovereignty  and  acting  as  a  crucial  enabler  for  new  initiatives,  such  as  the  European 
Data Spaces announced by the Commission in its Communication on a European Strategy for 
Data87.  National  and/or  sub-national  interventions  alone  would  not  be  able  to  address  the 
relevant policy problem. 

3.3. 

3.3. 

Subsidiarity: Added value of EU action 

The evaluations of the EIF and ISA² confirm the added value of an EU-level intervention for 
interoperability. Building on the experience of implementing the EIF and  ISA², an EU level 
initiative  for  interoperability  is  likely  to  achieve  its  objectives  at  lower  costs  than 
comparable national or sub-national initiatives, by creating economies of scale and economies 
of learning generated by cooperation. The recent political communications are also based on 
this assessment. 

82  
83  

84  
85  
86  

87  

2021 Report on Public Administrations Digital Response to COVID19. 
Renda, A., & Castro, R. (2020). Towards stronger EU governance of health threats after the COVID-19 
pandemic. European Journal of Risk Regulation, 11(2), 273-282. 
National COVID-19 contact tracing apps, Briefing ITRE in Focus, European Parliament. 
Berlin Declaration on Digital Society and Value-Based Digital Government. 
The role of interoperability for enabling digitalisation was highlighted in the Mid-Term Review of the 
Digital Single Market Strategy: COM/2017/0228 final. 
COM(2020) 66 final – ‘A European strategy for data’. 

23 

 
                                                           
Beyond that, the cross-border dimension cannot be addressed only through the efforts of 
national  or  sub-national  governments.  Even  if  national,  regional,  and  local  public 
administrations strive to improve their approach to digital and interoperable public services, 
without  coordination,  the  strategies  and  solutions  selected  may  impede  the  cross-border 
interoperability landscape. 

An EU involvement in cross-border interoperability serves both for coordination, ensuring a 
consistent approach to interoperability throughout the EU and on international level, and as a 
stimulant offering direction and support. EU action cannot and should not aim to replace local 
responsibilities but can reinforce subsidiarity by enabling local actors to better meet the needs 
of  citizens  and  businesses.  This  resonates  in  the  explicit  call  for  building  a  common  EU 
interoperability  coordination,  e.g.  in  the  Tallinn  and  Berlin  declarations,  the  Living-in.EU 
manifesto and the Interoperability expert group recommendations. 

4.  4.  OBJECTIVES: WHAT IS TO BE ACHIEVED? 

4.1. 

4.1.  General objective 

The Commission aims for ‘a reinforced EU governments interoperability strategy to ensure 
coordination and common standards for secure and borderless public sector data flows and 
services’88. 

The  general  objective  of  the  initiative  on  strengthening  interoperability  for  the  EU  public 
sector is to address the issues faced by the Member States and the European institutions when 
delivering digital public services across borders in Europe. It will contribute to the objectives 
set  in  Article  171  and  172  TFUE  to  establish  and  develop  any  measures  that  may  prove 
necessary to ensure the interoperability of the trans-European network as well as to promote 
the  interconnection  and  interoperability  of  national  networks.  Network  is  understood 
holistically  as  the  digital  public  service  infrastructure  underlying  the  delivery  of  public 
services. It has all the components of an interrelated system that enable public services to be 
delivered  electronically.  These  include  underlying  legal,  organisational  and  semantic 
requirements as well as the technical setup. 

A successful policy in this area would: 

- 

- 

- 

enable  public  administrations  across  the  EU  to  exchange  data  in  a  secure  way, 
respecting privacy and fundamental rights;  
allow  for  seamless  user-centric  services  and  the  sharing  of  common  solutions 
developed with EU funding; and  
foster data driven decision-making, foresight and participatory processes. 

It would further help to reduce administrative burdens and costs for citizens and businesses, 
facilitate  cross-border  cooperation,  enable  the  successful  implementation  of  European 
policies, accelerate the digital transformation of public services and ensure their resilience89 in 
case of disruptions brought on by crises like the current COVID-19. It would also support a 
more efficient design and implementation of EU policies. 

Cross-border  interoperability  is  not  solely  enabled  via  centralised  Member  State  digital 
infrastructures. The digital solutions of today also use a decentralised approach. This entails 
data exchange between local administrations in different Member States without necessarily 

88  
89  

As set out in the 2020 Communication ‘Shaping Europe’s digital future’. 
Digital resilience, as defined in the 2020 Strategic Foresight Report, is ‘about ensuring that the way we 
live, work, learn, interact, and think in this digital age preserves and enhances human dignity, freedom, 
equality,  security,  democracy,  and  other  European  fundamental  rights  and  values.’  Resilience 
dashboards. 

24 

 
                                                           
going through national nodes. This underlines the importance of common solutions across all 
administrative levels, particularly for specifications and applications. Needs for cross-border 
digital interactions are increasing and they require solutions that can fulfil these needs. 

Interoperability  cannot  and  should  not  replace  horizontal  and  sectorial  actions  that  will 
continue  to  be  decisive  to  build  a  European  Digital  Single  Market.  Nonetheless  a  smart 
interoperability policy can provide the needed foundations to facilitate policy implementation 
and enforce links between different policies. It helps build digital-ready and interoperable-by-
default policy initiatives at all levels (legal, organisational, semantic, technical). 

This initiative would help tackle the problem and drivers identified in Chapter 2, and ensure a 
coordinated  approach  to  EU  interoperability  to  help  EU  and  Member  States  institutions 
deliver better services to citizens and businesses across Europe. 

4.2. 

4.2. 

Specific objectives 

the  ISA²  evaluation, 

The  EIF  evaluation, 
the 
recommendations  from  the  Expert  group  on  Interoperability  of  European  public  services 
conclude that, in order to help EU public administrations deliver better services, EU action 
is needed in three concrete areas: 

the  stakeholder  consultations  and 

  Ensure  a  coherent,  human-centric  EU  approach 

to 

interoperability 

from 

policymaking to policy implementation; 

  Establish an interoperability governance designed to enable public administrations from 
all  levels  and  sectors  as  well  as  private  stakeholders  to  work  together  –  with  a  clear 
mandate  to  agree  on  shared  interoperability  resources  (e.g.  IT  solutions,  specifications, 
standards or guidelines); and, 

  Co-create  an  ecosystem  of  interoperability resources  (solutions, open standards,  data 
and services) for the EU’s public sector, so that public administrations at all levels in the 
EU and other stakeholders can contribute to and re-use such resources, create public value 
and innovate together.  

Interoperability across different policy areas can only be achieved if there are a political will, 
clear  guidelines90,  and  clearly  identified  interoperability  resources  which  are  taken  up 
systematically.  A successful policy  would establish  effective safeguards  and mechanisms to 
ensure that EU policies set ‘interoperable by default’ requirements for the implementation of 
policies, and that the digital implementation of EU policies by public administrations or other 
stakeholders across the Union is efficiently supported through an established interoperability 
governance91  and  resources.  It  would  offer  administrations  the  needed  guidance  and  tools, 
respected  and  referenced  across  all  policy  areas.  It  would  support  the  design  and 
implementation of EU policies that are digital-ready by default92. 

As  interoperability  is  about  different  entities  working  together  towards  a  shared  goal,  in  a 
complex system like the EU public sector, and in full respect of subsidiarity, it can only be 
achieved through  a  sound multi-level  governance. A successful policy  would offer  a  clear 
governance  setup  co-owned  by  Member  States  and  the  EU,  offering  all  stakeholders 
space to contribute their ideas and concerns, with transparent processes leading to joint 
interoperability resources. Well crafted, governance is empowering because it clarifies rules, 
responsibilities,  input  and  outcomes,  and  accountability.  It  helps  all  involved  actors 
understand decision-making processes and offers opportunities for engagement. A successful 

90  
91  

92  

In Art. 171 TFEU establishing guidelines is the first measure mentioned to reach interoperability. 
The EIF gives guidelines for establishing such an interoperability governance: It recommends covering 
all layers: legal, organisational, semantic and technical. 
Digital-ready policymaking as referenced in the 2021 Better Regulation guidelines. 

25 

 
                                                           
interoperability policy would need to be an integrator for all relevant initiatives, offering an 
agile  cooperation  structure,  transparency  and  inclusiveness,  and  support  take-up  of  the 
outcomes. 

26 

 
Figure 8. Intervention Logic 

27 

 
 
 
5.  5.  WHAT ARE THE AVAILABLE POLICY OPTIONS? 

The  policy  options  identified  include  non-legislative  and  legislative  actions  providing  for 
voluntary  or  mandatory  use  of  interoperability  solutions  and  specifications.  The  options  are 
described in detail below. 

5.1. 

5.1.  What is the baseline from which options are assessed? 

Option 0 (baseline scenario) 

No action is taken to increase the interoperability of the services of public interest in Europe. 
The  Commission  would  not  propose  any  new  specific  measures  to  address  the  problems 
discovered  in  the  recent  evaluation  of  the  EIF  and  the  ISA²  programme  or  the 
recommendations  from  the  expert  group.  The  baseline  is  characterised  by  the  following 
aspects: 

-  The 2017 EIF remains in place with no change; 
-  The Interoperability Action Plan,93 would not be updated and therefore be outdated. 
-  Some  supporting  actions  continue  under  the  Digital  Europe  Programme  such  as  the 

National Interoperability Framework Observatory (NIFO) and the EIF toolbox; 

-  Work  continues  with  the  expert  group  on  Interoperability  of  European  public 

services; 

-  No  support  measures  as  regards  Digital  readiness  for  EC  policy  proposals  are 
undertaken, beyond what is already available in the updated Better Regulation Guidelines 
and Toolbox; and, 

-  Limited  and  informal  support  from  the  EC  Interoperability  Unit94  provided  to  other 
digital  policies  with  high  interoperability  stakes  (e.g.  semantic  work  package  of  Digital 
Single Gateway Once Only Principle), if requested by policy DGs. 

The  formal  ISA²  Committee  where  Member  States  participated  in  strategic  steering  of  the 
programme  and  follow  up  of  interoperability  actions,  ceased  to  exist  at  the  end  of  the 
programme  in  2020.  It  would  not  be  replaced  so  there  will  be  no  direct  governance  with 
Member  States  on  Interoperability  actions.  There  would  be  a  limited  steering  via  the 
Digital  Europe  Programme  committee  which  coordinates  the  implementation  of  the  whole 
programme  where  interoperability  actions  represent  a  very  small  part  of  the  overall 
financing95 and the level of engagement with Member States on this particular topic is limited. 
As  ISA²  has  come  to  an  end  in  December  2020,  some  of  the  existing  EIF  implementing 
actions covered by ISA² will continue to be supported in the new Digital Europe Programme 
but there would be no coherent catalogue of interoperability resources put in place. 

5.2. 

5.2.  Option 1: Non-legislative 

This option is a continuation of the baseline option, with the addition of several non-binding 
policy statements from the Commission. The uptake in public administrations across the EU 
remains voluntary. 

The Commission adopts a Communication which would: 

-  Update the European Interoperability Framework; 

93  
94  

95  

COM(2017) 134 final, EIF - Implementation Strategy, Annex 1 - Interoperability Action Plan. 
The  unit  in  the  Directorate-General  for  Informatics  (DG  DIGIT)  working  on  Interoperability 
(DIGIT.D2). 
The  2021  –  2027  budget  of  the  Interoperability  actions  represents  2.2%  of  the  total  of  the  Digital 
Europe Programme (EUR 168 million out of EUR 7 500 million). 

28 

 
                                                           
-  Update the outdated Interoperability Action Plan96; 
-  Call for the uptake of open-source software; 
-  Call  for  coordination  with  local  public  administrations  by  publishing  the  European 

Interoperability Framework for Smart cities and Communities (EIF4SCC)97; 

-  Announce the intention to work on  synergies between the Commission’s existing and 
future  monitoring  and  reporting  systems  on  digital  public  sector  initiatives,  including 
specific indicators on interoperability; and, 

-  Offer ad-hoc support of the expert group on Interoperability of European public services 

in the design of policies with a high interoperability stake98. 

A  new  version  of  the  EIF  could  address  some  of  the  shortcomings  detected  in  the  EIF 
evaluation  and  take  on  board  some  of  the  recommendations  of  the  expert  group99.  The  EIF 
could  be  restructured  into  a  more  concrete  and  practical  framework  focused  on  facilitating 
implementation, include calls for open-source software and specifications and to facilitate the 
implementation  of  open  and  interoperable  services  that provide incentives  for  the take-up of 
common  specifications100.  Monitoring  would  be  underpinned  by  revised  key  performance 
indicators  and  ‘SMART  goals’  (specific,  measurable,  achievable,  realistic,  and  timely)  to 
facilitate the assessment of its outcomes101. A revised action plan for Interoperability could be 
put  in  place  to  define  actions  further  needed  under  the  Interoperability  specific  objective  of 
the Digital Europe Programme. 

To improve the coordination with local public administrations, the framework for smart cities 
EIF4SCC,  developed  under  the  ISA²  programme  in  conjunction  with  the  Living-in.EU 
community, could be published as an annex to the communication. It would allow the current 
interoperability  expert  group  to  cooperate  more  easily  with  the  Living-in.EU  community 
which, to a certain degree, would help address the specific interoperability challenges faced at 
local level and promote some collaboration across different levels of government. 

For  digital-ready  policy  making  the  expert  group  on  interoperability  of  European  public 
services  could  provide  ad-hoc  support  early  in  the  design  of  some  EU  policies  with  high 
interoperability stake cross-borders or across different sectors. This would necessarily remain 
voluntary and occasional. 

5.3. 

5.3.  Option  2:  Legislative 
for  an 
interoperable  EU  public  sector  infrastructure  and  strengthened  EU  policy 
coordination 

framework 

initiative 

-  New 

legal 

Option  2  would  consist  of  a  package  with  a  policy  communication  on  strengthened  EU 
interoperability  policy  coordination  and  a  legislative  act  that  would  foster  a  coherent  EU 
approach  to  interoperability  by  proposing  the  setup  of  an  interoperable  EU  public  sector 
infrastructure. The legislative act would act on three main pillars – governance, solutions and 
support measures: 

-  Establish  a  multi-level  governance  setup  for  EU  public  sector  interoperability, 
with  clear  roles  and  mandates.  In  this  governance,  Member  States  and  EU 
institutions  and  agencies  set  the  strategic  goals  and  agree  on  concrete  measures  that 

96  
97  
98  

99  

100  
101  

COM(2017) 134 final, EIF - Implementation Strategy, Annex 1 - Interoperability Action Plan. 
Proposal for a European Interoperability Framework for Smart Cities and Communities. 
For  instance,  policies  similar  to  the  Single  Digital  Gateway  Regulation  or  the  Digital  Identity  are 
considered to have a high interoperability stake for public services. 
These potential changes were mentioned in the meeting of the Interoperability Expert Group of 7 July 
2020. 
This example is part of the feedback received on the roadmap summarised in Annex II. 
These potential changes were mentioned in the  meeting of the Interoperability Expert Group of 7 July 
2020. 

29 

 
                                                           
the  cross-border 

can  ensure 
their  digital  public  service 
interoperability  of 
infrastructures;  a  governance  body  or  board  would  be  established  and  it  would  be 
composed of representatives from the Member States, and the Commission to define 
the  general  direction  and  cooperation  on  interoperability  to  promote  the  digital 
interconnection and interoperability of networks and infrastructures supporting digital 
services in the Union. This board would cooperate closely with existing future bodies 
established under Union law in the areas of data policy or digital government, such as 
the Data Governance Act or the AI Act; 

-  Enact the obligation for Member States to designate a national coordinator of digital 
transformation (e.g. a national ‘Chief Information Officer’) at Member State level and 
appoint him/her as member of the governance board; 

-  Set  up  an  ecosystem  of  interoperability  solutions  that  support  cross-border  digital 
public  services:  this  will  include  the  European  Interoperability  Framework  and  its 
specialisations,  and  it  will  add  the  possibility  for  the  governance  to  recommend 
specifications  and  applications  which  can  be  used  to  foster  interoperability  across 
sectors and administrative levels, while not being mandatory; 

-  Put in place interoperability support measures that set out a clear process on how EU 
wide projects in the framework of the Regulation can support interoperable and digital 
EU  policy  implementation  across  the  EU  public  sector.  To  support  36  innovative 
interoperability  solutions  the  governance  can  authorise  the  set-up  of  regulatory 
sandboxes in cross-border contexts. A peer-review system and provisions on training 
enhance  two  further  important  interoperability  enablers  (skills  and  knowledge 
exchange); 

-  A  requirement  for  public  administrations  to  assess  their  alignment  with  the 
recommended  interoperability  resources  and  those  mandated  by  EU  laws  in 
specified  cases  (e.g.  linked  to  EU  funding  or  linked  to  cross-border  public  sector 
infrastructures); 

-  An  obligation  for  Member  States  to  reference  interoperability  resources  on  a 
common platform (e.g. Joinup) if they have been developed with the support of EU 
funding;  

-  A  basis  for  making  future  EU  funding  conditional  to  public  sector  digitalisation 
the  development  of  shared 

to 

projects  being  aligned  and/or  contributing 
interoperability resources; 

-  Legal  clarity  for  the  sharing  and  re-using  of  publicly  owned  interoperability 
resources,  it  would  support  the  use  of  the  latest  version  of  European  Union  Public 
Licence  (EUPL)  to  enhance  legal  clarity  and  mutual  recognition  of  licences  in  the 
Member States;  

-  A  legal  mandate  for  the  Commission  to  develop  international  cooperation  in 

interoperability; and, 

-  A monitoring mechanism in close alignment with the Digital Compass. 

The policy communication would: 

-  Set out the Commission’s policy aims on public sector interoperability, supporting 
coherence  across  sectoral  and  horizontal  EU  policies,  innovative  projects,  and 
accelerating  the  implementation  of  public  sector  digital  transformation  (such  as  the 
Recovery  and  Resilience  Programmes  and  the  Digital  Decade),  including  in  the 
Commission and its own policy-making. 

30 

 
-  Establish  an  Interoperability  agenda  to  support  funding  programmes  with  public 

sector digitalisation in scope 

As in Option 1 - Call for the uptake of open-source software, address coordination with local 
public  administrations  via  the  Interoperability  framework  for  smart  cities  and  communities 
(EIF4SCC), call for synergies between monitoring and reporting systems the Commission has 
on digital public sector initiative. 

Option 2 would establish the needed legal certainty for structural cooperation:  

propose 

resources 

recommended 

interoperability 

Member  States  CIOs  together  with  the  European  Commission  would  form  a  common 
interoperability governance like an interoperable Europe Board with a mandate to identify 
and 
specifications, 
frameworks…),  propose  measures  to foster  the  share  and  reuse  of  interoperable  solutions, 
propose measures to enhance interoperability capabilities of public sector bodies, support the 
work  of  the  European  Data  Innovation  Board,  on  interoperability  solutions  for  the  common 
European Data Spaces, as well as any other Union body working on interoperability solutions 
relevant for the public sector. The Board would be supported by a community of experts that 
would  enable  the  involvement  of  a  broader  set  of  stakeholders  for  the  operational  tasks. 
Governance  means  co-ownership  of  senior  (CIO  level)  Member  State  representatives  with 
clear roles  and responsibilities, transparent  decision-making and involvement of practitioner 
communities to test, evaluate and develop shared interoperability solutions.  

(solutions 

It would introduce obligations on Member States to designate national coordinators which 
would  become  full  members  of  the  main  governance  body.  They  would  also  be  obliged  to 
reference  the  interoperability  resources  developed  with  EU  funding  on  a  common  platform, 
which would allow all participants to share and reuse solutions and specifications in a more 
consistent way.  

Regions  and  cities,  academic  experts,  civil  society,  as  well  as  GovTech  and  open-source 
experts  should  be  appropriately  associated  to  this  cooperation  structure.  These  stakeholders 
can  help  develop  solutions  to  facilitate  the  interoperable  implementation  of  EU  policies  or 
work  on  other  shared  needs,  following  the  example  of  the  cyber-security  competence 
community established with Regulation (EU) 2021/887.  

While more and more policies have, among their objectives, to contribute to the EU’s digital 
transition, it is crucial that they also have a clear interoperability legal reference to link to, 
as it is the case for IT security or data protection and privacy issues. 

The multi-level governance mechanism would help facilitate the coordination between public 
administrations  in  Europe  and  the  European  Commission  in  the  digitally  supported 
implementation  of  EU  policies.  It  would  set  incentives  to  align  the  national/local 
infrastructures with agreed interoperability resources to support cross-border and cross-sector 
digital  services  and  it  would  foster  the  co-design  of  new  innovative  solutions  fit  for  wide 
reuse.  

Where sectors see the need for harmonised standards, they can inject this need into relevant 
EU fora with the support of the governance102. With all resources being issued in  machine-
readable  format  on  an  official  platform  with  agreed  change  procedures,  it  allows  for  the 
flexibility  needed  to  keep  up  with  technological  developments.  This  implies  that  standards 
and specifications which are today issued in legal text (e.g. implementing or delegated acts) or 
just published on various online sites, would be issued in machine-readable code. This implies 

102  

In  cooperation  with  existing  standardisation  legislation  and  fora,  e.g.  the  Multi-Stakeholder  Platform. 
Regulation (EU) No 1025/2012 on European standardisation. 

31 

 
                                                           
that  when  developing  IT  systems  supporting  the  implementation  of  EU  policies,  public 
administrations could implement the code directly. 

The legal instrument could lead to the introduction of policy conditionalities in future EU 
funding  programmes.  In  this  case,  public  administrations  requesting  EU  funding  and 
assistance for their efforts to  modernise and digitise their systems and processes would need 
to  argue  how  they  plan  to  comply  with  -  or  contribute  to  -  the  agreed  interoperability 
resources. 

The  interplay  of  option  2  and  other  EU  or  national  policies  that  set  interoperability 
requirements  would  be  very  considerably  enhanced  in  comparison  with  Option  1. 
Interoperability  policy  would  provide  cross-cutting  support  to  EU  policies  through  mature, 
referenceable  specifications  that  evolve  continuously,  in  a  transparent  process,  based  on  the 
needs of EU policies and EU public administrations.  

5.4. 

5.4.  Option  3:  Legislative  initiative  -  New  legal  framework  introducing  a 
common European Interoperability Architecture for all public services 

Option  3  would  be  the  furthest  reaching  and  most  centralistic  approach  to  attain  the 
objectives in Chapter 4. It would also have the form of a legislative act, building on Option 2, 
while making interoperability requirements more binding for the Member States.  

More specifically, this option would integrate both the multi-level governance for EU public 
sector  interoperability,  and  Community  Projects  (cf.  Option  2),  but  then  add  a  specific 
mandate for a trans-European interoperable  government  network to  set  standards (minimum 
interoperability  requirements)  for  the  development  of  services  of  public  interest  to  be  then 
implemented  by  all  public  administrations  in  the  Union.  The  concrete  standards  would  be 
imposed through implementing acts. 

This option would include the following elements: 

-  A  multi-level  governance  for  EU  public  sector  interoperability  (based  on  the 

outline of option 2; 

-  Establishment of a common European Interoperability Architecture (EIA) for the 

infrastructure of EU public services103; 

-  Set-up of an EU Interoperability Architecture Board co-owned by Commission and 

Member States CIOs; 

-  Mandatory alignment of all EU policy requirements with EIA, exceptions must be 

granted by the Interoperability Architecture Board; 

-  Member  States  required  to  establish  National  Interoperability  Architectures 
(NIA) in alignment with EIA, as well as national Architecture Boards that monitor 
the alignment of national initiatives with the respective NIA; and, 

-  Where  applicable,  EU  policy 

initiatives  must  contain  a  reference  digital 

implementation solution. 

Member  States  designate  national  coordinators  for  interoperability  cooperate  in  a  dedicated 
EU interoperability governance setup similar to the one described above under option 2. As a 

103  

The EIA would represent a comprehensive blueprint of interoperability components and specifications 
to  support  the  implementation  of  digital  services  and  seamless  data  exchanges  across-sectors  and 
borders.  Individual  policy  initiatives  can  build  sectoral  solutions  based  on  the  EIA,  reusing  its 
components  without  deviating  from  core  common  design  principles.  Continuous  technical,  legal  and 
semantic maintenance and development would ensure sustainability of assets, build resilience and foster 
digital sovereignty for EU public services. 

32 

 
                                                           
body, they would be mandated to adopt a European interoperability architecture (building on 
the  existing  European  Interoperability  Reference  Architecture  EIRA104)  as  a  blueprint  for 
building  and  developing  interoperable  digital  public  services  at  all  levels.  This  will  be 
complemented by mandatory common (minimum) interoperability requirements. 

All  Member  States  would  be  required  to  adopt  a  national  interoperability  strategy  or 
framework compliant  with  EU requirements. This would mean, for instance, introducing an 
obligation for any EU and national policies and digital services infrastructure to be compliant 
with  the  EIA  and  the  standards  established  via  implementing  decisions.  The  EU 
Interoperability  Architecture  Board  would  have  the  mandate  to  decide  on  conflicting 
standards.  The  alignment  of  the  national  approaches  and  infrastructures  would  be  reached 
through the requirement to establish national governance structures, building where possible 
on existing bodies and processes in the Member States.  

This option would also introduce strong interoperability targets for Member States in order to 
monitor the implementation of the provisions included in the policy. This option would also 
have direct effects on the implementation of all EU policies with high interoperability stake, 
such as digital identity and data spaces: standards foreseen in those policies would need, by 
law (and not only by an internal Commission commitment – see option 2), to be aligned with 
EU minimum interoperability requirements which would become mandatory. 

5.5. 

5.5.  Options discarded at an early stage 

Inspired  by  the  institutional  setup  created  for  cyber  security105  or  high-performance 
computing106 the option of establishing a common body or a joint undertaking was among the 
initial  options  assessed.  However,  actions  performed  by,  e.g.,  a  joint  undertaking  cannot 
replace  but  only  complement  an  overall  coherent  approach  to  interoperability  and  progress 
might  be  slowed  down  by  difficult  budgetary  discussions.  Therefore,  this  option  was 
discarded at the current point in time but should be reassessed in the future, which is explicitly 
mentioned in Chapter 9. 

It  was  also  discussed  to  what  extent  the  right  for  data  portability,  established  in  Art.  20 
Regulation  (EU)  2016/679  (GDPR)  could  be  extended  to  personal  data  used  by  public 
administrations.  This  would  give  citizens  and  businesses  a  right  to  have  their  personal  data 
processed  in  a  machine-readable  format.  It  would  however  contradict  the  explicit  exception 
for data processed in performance of a task carried out in the public interest or in the exercise 
of official authority in the GDPR and would need a recast of the latter. This would go beyond 
the scope of the initiative. 

6.  6.  WHAT ARE THE IMPACTS OF THE POLICY OPTIONS? 

The  impacts  of  a  public  sector  interoperability  policy  are  more  difficult  to  identify  and 
quantify  than  those  of  many  other  EU  initiatives.  A  study  by  the  Joint  Research  Centre 
(JRC)107 analysed the economic impact of location interoperability overall based  on 20 case 
studies. It finds that, due to its very nature as an enabling factor across many policy fields, the 
impact  of  interoperability  is  hard  to  isolate  from other  elements  of  a  policy  and 
itself  but  always  an  enabling  precondition. 
interoperability 

is  never  an  aim 

in 

104  
105  
106  
107  

European Interoperability Reference Architecture. 
EU Cybersecurity competence centre. 
EU High Performance Computing - joint undertaking. 
Ulrich,  P.,  Duch  Brown,  N.,  Kotsev,  A.,  Minghini,  M.,  Hernandez  Quiros,  L.,  Boguslawski,  R.  and 
Pignatelli, F., Quantifying the Benefits of Location Interoperability in the European Union, EUR 31004 
EN,  Publications  Office  of  the  European  Union,  Luxembourg,  2022,  ISBN  978-92-76-48846-0, 
doi:10.2760/72064, JRC127330. 

33 

 
                                                           
Interoperability in its many forms is an important enabler; yet, it is the interoperable policies 
and public services that are delivering the benefits and consuming resources. 

Nevertheless, the evidence available is rather conclusive. For instance, in terms of economic 
impact,  the  study  by  the  JRC  finds  that,  if  all  solutions  are  made  interoperable,  even  with 
conservative estimates, citizens could save up to 24 million hours per year due to improved 
interoperability.  This  would  represent  monetary  savings  in  the  order  of  EUR  543  million 
annually.  For  businesses,  the  establishment  of  a  full  interoperable  economy  would  lead  to 
time savings of 30 billion hours. In monetary terms, this translates into savings of EUR 568 
billion  annually.  Improvements  in  public  sector  performance  due  to  interoperability  could 
lead  to  an  increase  of  0.4%  in  GDP.  Overall,  the  potential  positive  benefits  derived  from 
increased  interoperability  for  the  public  sector  in  the  EU  are  considerable.  For  instance, 
converting  these  estimates  to  monetary  terms,  a  1%  improvement  in  the  indicators  used, 
because of better interoperability, would imply an increase of the EU GDP in the range of 
EUR 21 to 56 billion.  

The final evaluation of the ISA² programme and the evaluation of the EIF show a crucial role 
of  interoperability  action  during  the  COVID--19  pandemic108.  Not  acting,  therefore  could 
also  have  wider  repercussions,  affecting  the  resilience  of  the  public  administrations  and 
foregoing the opportunity to strengthen capabilities.  

The impacts of the different policy options are analysed below (for a full overview see Annex 
III Who is affected and how?). 

6.1. 

6.1. 

Impacts of Option 0 - baseline scenario 

If no action is taken the objectives outlined in Section 4 will not be achieved as the Member 
States’  take-up  of  interoperable  resources  and  specifications  when  implementing  EU 
policies  remains  patchy  and  voluntary  unless  more  binding  requirements  are  brought  by 
sectoral policy initiatives. Sectoral initiatives may, as a result, be uncoordinated and deepen 
the  interoperability  gap.  Member  States  can  continue  to  implement  solutions  and 
specifications in diverging ways. Their ability to exchange data cross-borders depends on 
their  respective  levels  of  digitalisation,  bilateral  agreements  between  Member  States’ 
administrations or sectoral policy initiatives of the EU and thus remains uncertain. 

Continuing with the status quo of the 2017 EIF and an outdated Interoperability Action Plan 
would  not  address  the  main  problems  identified  in  the  evaluations  of  the  EIF  and  the  ISA² 
programme109.  Even though future  actions  on interoperability  are planned to  be funded also 
outside  the  Interoperability  Action  Plan,  for  example  as  part  of  the  Digital  Europe 
Programme,  such  interoperability  action  would  have  no  specific  governance  or  ensure 
coordination across different funding programmes and policies.  

Informal  and  necessarily  limited  support  could  on  an  ad-hoc  basis  be  provided  to  policy 
DGs by DG DIGIT’s Interoperability unit for the implementation of sectoral digital measures, 
if  requested  by  the  policy  DGs.  To  date,  this  support  is  generally  requested  too  late  in  the 
process to be able to make a difference and ensure interoperable-by-default and digital-ready 
policies. 

Due to the already high-level of 2017 EIF implementation on the conceptual level, little costs 
can  be  directly  linked  to  keeping  the  baseline  scenario  (see  Table  2).  On  the  EU  level  the 
costs for monitoring and facilitating the access to guidance can be assumed to fall within the 
range of costs noted for the implementation of the NIFO action during the ISA² programme. 

108  
109  

See and ISA² evaluation COM/2021/965 final, SWD/2021/965 final. 
See and ISA2 programme final evaluation COM/2021/965 final, SWD/2021/965 final. 

34 

 
                                                           
The  NIFO  action  relied  on  a  budget  of  approximately  EUR  2.5  million  between  2016  and 
2020110. 

However,  the  indirect  costs  and  unresolved  administrative  burden  linked  to  an  outdated 
interoperability policy are likely to be considered significant and would potentially grow over 
time.  The  literature  shows  strong  negative  mostly  indirect  economic  impacts  of  the 
baseline  scenario  due  to  untapped  potential  for  cost  reduction.  The  overall  feedback  to 
both  targeted  and  public  consultations  also  shows  that  limited  negative  impacts  may  be 
expected with respect to the costs of interacting with public administrations, the costs borne 
by  public  administrations  in  providing  services,  and  research  and  innovation  (with  average 
scores  of  -0.2  on  a  scale  from  -2  to  2,  based  on  121,  120  and  115  responses  for  each  area, 
respectively)111.  

Even  though  it  seems  likely  that  social  and  environmental  impacts  and  the  right  of 
individuals  to  freely  move  in  the  EU  would  not  be  negatively  affected  through  the  baseline 
option,  the  potential  benefits  outlined  in  the  introduction  of  this  chapter  would  not  be 
unlocked. 

In this option there are very limited incentives for the Union or its Member States to take a 
more  coordinated  approach  on  the  design,  approval  and  take-up  of  shared  interoperability 
resources  when  implementing  their  policies.  Ongoing  policies  will  have  an  impact  on 
interoperability  of  data  and  public  services  cross-borders  and  across  sectors  at  an  EU  level 
(Digital Services Act, Data Governance Act and future Data act, Open Data Directive, Digital 
Identity,  Digitalisation  of  justice  cross-borders,  Single  Digital  Gateway  Regulation  etc.), 
limited  to  their  own  specific  scope  without  any  coordination  between  measures  that  impact 
implementation on the ground. Member States have complained repeatedly about the lack of 
coordination  at  Commission  level  (see  recommendations  from  the  expert  group)  and  will 
continue to  lack pragmatic guidance on implementation,  leading to  more  delays  for sectoral 
policies.  For  instance,  18  Member  States  have  had  infringement  proceedings  open  on 
30/09/2021112  owing  to  the  lack  of  transposition  measures  for  the  Open  Data  Directive 
adopted in 2019. 

6.2. 

6.2. 

Impacts of Option 1: Non-legislative actions 

Option 1 would be mainly a continuation of the current policy approach, updating the current 
instruments without adding substantially new ones.  

This  approach,  very  much  in  line  with  what  has  been  put  in  place  in  2017  with  the  current 
version of the EIF, has been proven via the evaluations to provide limited contributions, when 
it comes to developing more effective, simplified and user-friendly digital public services at 
the national, regional and local levels 113. 

In  consequence  this  would  mean  that  the  possible  positive  economic  impacts  of  such 
interoperable services would most probably continue to remain untapped. This assessment has 
been  confirmed by the consulted stakeholders in  both  the targeted  and public consultations: 
option 1 is  expected to  bring only limited positive impacts  on  the  free  movement  of  goods, 
services,  capital,  and  workers  across  the  Member  States,  and  on  research,  development  and 
innovation (with an average score of 0.5 on a scale from -2 to 2, based on 112 responses). 

110  

111  
112  
113  

Information  on  the  budget  allocated  to  ISA²  actions  throughout  the  duration  of  the  programme  is 
available on the ISA² Dashboard: (retrieved on 3 June 2021). 
All the stakeholder inputs are detailed in Annex II Stakeholder consultation. 
Infringement Decisions (europa.eu). 
See Evaluation of the ISA² programme, COM(2021)965. 

35 

 
                                                           
Under  this  option,  the  uptake  of  interoperability  by  public  administrations  across  the  EU 
would remain voluntary as in the baseline and would most likely produce limited effects, in 
line with the results of the current policy set-up for Interoperability shown in the evaluation 
results for the EIF and ISA². 

The interplay of Option  1 and other EU or Member State policies when it comes to design, 
approval and take-up of shared interoperability resources will not substantially differ from the 
base-line  scenario.  While  an  updated  EIF  would  make  more  coherent  links  with  the  policy 
developments  since  2017,  option  1  would  not  ensure  that  those  policies  would  be 
implemented in compliance with the EIF or could build on a more formal input from a public 
sector community on the topic. 

The direct costs of the current interoperability policy (EIF implementation) for EU countries 
can be quantified more easily and are very low (see Table 1). 

Table 1. Overview of costs and benefits identified in the EIF evaluation 

Citizens 

Businesses 

Public administrations 

Quantitati
ve 

Commen
t 

Quantitat
ive 

Comme
nt 

Quantitati
ve 

Comment 

Costs 

EUR 
24 000 – 
EUR 
169 000, 
correspond
ing 
respectivel
y to 150 
and 550 
person-
days. 

The costs of 
implementat
ion of the 
EIF vary 
depending 
on whether 
the Member 
State 
updates 
drafts of 
existing 
national 
documents 
and 
strategies 
based on the 
EIF or 
designs 
national 
documents 
and 
strategies 
based on the 
EIF without 
relying on 
any other 
prior such 
documents.  

Direct 
compliance 
costs: 
Implementat
ion of the 
EIF (one-off 
costs) 

0 

No direct 
complian
ce costs 
applicabl
e. 

No direct 
complianc
e costs 
applicable. 

No direct 
complian
ce costs 
applicabl
e. 

36 

 
 
 
 
Citizens 

Businesses 

Public administrations 

Quantitati
ve 

Commen
t 

Quantitat
ive 

Comme
nt 

Quantitati
ve 

Comment 

General comment: The costs of implementing the EIF are borne by 
public administrations only. 

Benefits 

A 10% 
improveme
nt in the 
quality of 
online 
public 
services 
would 
encourage 
approximat
ely 4.3 
million to 5 
million 
more EU 
citizens per 
year 

This 
result is 
part of an 
economet
ric 
analysis 
run on 21 
EU 
Member 
States, 
Iceland, 
Norway, 
Switzerla
nd and 
the UK.  

Direct 
benefits: 
additional 
EU users of 
the Internet 
to interact 
with their 
public 
administrati
ons 
(recurrent 
benefits, but 
expected to 
decrease 
over the 
time) 

General comment: It is important to note that although no benefits are 
quantified for businesses and public administrations, the evaluation 
supports qualitatively that benefits exceed the costs for public 
administrations and bring substantial benefits to both businesses and 
citizens.  

Source: Study supporting the evaluation of the implementation of the EIF 

Also, for the impacts on the costs of interacting with public administrations and the costs 
of  doing  business  in  the  EU,  option  1  is  not  expected  to  bring  results  much  beyond  the 
limited contributions already achieved under the new EIF from its adoption in 2017 to 2020. 
The 119 stakeholders contributing to the targeted and public consultations rate those impacts 
with  an  average  score  of  0.3  on  a  scale  from  -2  to  2.  An  effective  mechanism  to  ensure 
synergies  across  funding  programmes  and  EU  policies  could  significantly  enhance  the 
potential benefits114. 

Option  1  only  implies costs for public administrations  (variable from  country to  country) 
and  no  potential  additional  burdens  on  businesses  and  citizens.  The  potential  costs 
incurred by public administrations in implementing this option are expected to be low and are 
based on the voluntary take-up of new guidance and its implementation in at least some areas 
of  activities  of  public  administrations.  With  regards  to  the  Commission,  there  would  be 
upfront  costs  involved  in  revising  the  EIF  and  costs  in  monitoring  the  progress  of  its 
implementation in line with current costs. 

114  

Stakeholders  rate  this  option  with  an  average  score  of  0.8  on  a  scale  from  -2  to  2,  based  on  113 
responses to the public and targeted consultations. 

37 

 
 
 
 
 
 
 
 
 
 
                                                           
With  respect  to  social  impacts,  Option  1  is  expected  to  contribute  to  improve  to  a  limited 
extent  the  quality  of  the  services  provided  by  public  administrations  via  updated  guidance 
and a common and human-centric EU approach to public sector interoperability. Respondents 
to  both  the  targeted  and  public  consultations  confirm  that  positive  impacts  may  materialise 
(with an average score of 0.5 on a scale from  -2 to 2, based on 119 responses). An updated 
EIF  would  allow  for  updated  guidance  and  recommendations  to  be  provided  for  the 
development of digital and interoperable public services based, among others on the learnings 
drawn  from  the  evaluation  of  the  EIF  as  well  as  the  final  evaluation  of  the  ISA² 
programme115. 

Turning  to  environmental  impacts,  Option  1  is  likely  to  have  either  limited  positive  or  no 
sizeable  impacts  on  the  green  transition.  The  assessment  focused  on  the  potential  (indirect) 
impacts  on  the  green  transition  in  the  EU,  e.g.,  the  role  played  by  interoperability  in  the 
development  of  the  common  European  data  spaces  (with  a  common  European  Green  Deal 
data  space  foreseen  in  this  framework)116.  Common  EU  guidance  on  interoperability  could 
contribute to achieving some of the goals set through the European Green Deal117. 

Finally, when it comes to impacts on fundamental rights the most imminent impact can be 
seen on Article 41 of the EU Charter of Fundamental Rights (CFR), namely the ‘right to good 
administration’118.  Measures  to  support  the  digitalisation  of  public  services  can  be  seen  as 
enablers  of  the  right  to  good  administration,  having  the  potential  to  contribute  to  the  key 
principles  of  good  administration  that  include  impartiality,  fairness,  and  reasonable  time  of 
resolving  affairs119.  No  further  action  on  the  EIF  and  its  related  principles  could  also  have 
negative impacts, for instance on Art. 9 CFR, the right to protection of personal data; and Art. 
22, CFR the right to linguistic diversity. When it comes to the right to move freely in the EU, 
studies  on  SMEs  show  that  non-interoperable  administrative  procedures  hinder  European 
SMEs to do business in other EU countries and thus affect their right of freely acting in the 
Single Market120. 

Option 1 is technically feasible as it is mainly a continuation of current policy, and likely to 
be  politically  feasible  as  it  only  introduces  small  changes,  not  expected  to  face  strong 
opposition.  However,  looking  at  the  far-reaching  recommendations  of  the  expert  group  on 
interoperability  of  public  services  and  European  Parliament121  voices  on  the  topic,  it  is  not 
unlikely that the Parliament or the Council would ask for more ambitious measures. 

In  summary,  this  option  would  mostly  be  a  continuation  of  the  current  system  with  all  its 
benefits  and  drawbacks,  with  some  small  improvements  through  updating  of  the  current 
Interoperability  Framework  setup.  Its  scope  would  however  be  limited  as  an  update  cannot 
ensure  that  the  framework  stays  future-proof  and  coherent,  nor  can  it  generate  an  overall 
closer cooperation on the topic. 

115  

116  
117  

118  

119  
120  
121  

See COM/2021/965 final, SWD/2021/965 final and CEPS (2021), Study supporting the final evaluation 
of the ISA2 programme. Study supporting the evaluation of the implementation of the EIF. 
COM(2020) 66 - A European strategy for data. 
ELISE  -  European  Location  Interoperability  Solutions  for  e-Government:  Energy  &  Location 
Applications. 
Even though the wording of the charter restricts that right to EU bodies, in the Case C-604/12 the CJEU 
confirmed that it was applicable to national proceedings linked to EU law. 
Matusiak, J., Princ, M. (2018), EGovernment As an Element of the Right to Good Administration. 
SWD(2020) 54 final, Identifying and addressing barriers to the Single Market. 
See positions of Parliament on Interoperability in Annex VI. 

38 

 
                                                           
6.3. 

Impacts of option 2: New legal framework for an interoperable EU public 

6.3. 
sector infrastructure 

focusing  on  strengthened  cooperation  without  centrally 

In 
imposing  uniform 
implementation  obligations,  this  option  responds  to  the  subsidiarity  needs  of  public  sector 
digital  transformation:  Member  States  are  sovereign  in  designing  their  government  setup; 
creating distributed but connected – interoperable – public sector ecosystems allows meeting 
local needs while delivering on the objectives of interoperability. 

This  option  is  expected  to  generate  an  improved  sense  of  ownership  of  interoperability  by 
offering a platform for structured cooperation on interoperability across the EU. The benefit 
lies in more direct involvement in the development of interoperability initiatives, facilitating 
the  take-up  of  jointly  piloted  interoperability  solutions.  The  speed  of  developments  may 
depend on the configuration of the governance and on the prioritisation of issues taken up by 
it.  Option  2  could  be  combined  with 
introducing  conditionalities  for  respecting 
interoperability requirements  to  receive  EU funding or a label  to  certify  solutions  that fulfil 
the requirements are set-up by the collaboration platform on interoperability. 

Against this background, the feedback from stakeholders indicates that Option 2 would likely 
bring  positive  effects  across  all  categories  of  impacts  considered  (see  Annex  II  Stakeholder 
consultations). Overall, responses from the citizens consulted through the public consultation 
tend  to  be  the  most  positive,  followed  by  responses  received  from  representatives  of  EU 
public authorities (engaged in both the targeted and the public consultations). And this is the 
option which is most in line with the recommendations of the expert group. 

In  terms  of  economic  impacts,  Option  2  is  expected  by  stakeholders  to  have  particularly 
positive effects on the free movement of goods, services, capital and workers across the 
Member  States  and  on  research,  development  and  innovation  (with  average  scores  of  1  and 
0.9  on  a  scale  from  -2  to  2,  based  on  116  and  117  responses,  respectively).  The  positive 
impacts are expected from enhanced cooperation across the EU, contributing to improving the 
development and delivery of digital and interoperable public services. Similarly, Option 2 is 
likely to lead to a reduction in the costs of interacting with public administrations as well 
as the costs of doing business in the EU (according to feedback from stakeholders showing 
average  scores  of  0.9  and  0.8  on  a  scale  from  -2  to  2,  based  on  122  and  115  responses, 
respectively).  Some  positive  overall  economic  impacts  are  especially  expected  from 
introducing  conditionalities.  These  include  positive  impacts  on  innovation  and  research  (as 
confirmed by respondents to both targeted and public consultations, with an average score of 
1 on a scale of -2 to 2, based on 117 responses). To the extent that more interoperable projects 
and services are developed, this may lead to cost reductions both for public administrations as 
well as businesses and citizens interacting with public administrations. 

By establishing a common governance with the mandate to issue agreed positions on the use 
of interoperability resources, those resources could also be mandated for future EU funding 
programmes.  In  this  case,  public  administrations  requesting  EU  funding  and  assistance  for 
their efforts to  modernise and digitise their systems  and processes would need to  argue how 
they  plan  to  comply  with  or  contribute  to  the  agreed  interoperability  resources.  Such  a 
measure  would  ensure  that  digitalisation  efforts  in  public  administrations  build  on  existing 
solutions, reduce the risk of duplication of work and contribute to a harmonised approach to 
interoperability. In addition, relying on conditionalities can also ensure that solutions already 
funded at the EU level are used. The result would be an emerging distributed trans-European 
network of public administrations and services. 

This  is  further  supported  by  examples  from  Member  States  on  cost-savings  linked  with 
interoperable digital services, summarised in Table 2. 

39 

 
Table 2. Summary of the key findings for time and cost savings estimations 

Geographical 
coverage 

Implemented solutions 

Cost savings 

Belgium122 

Digital government solutions 

Estonia123 

Digital signatures 

Digital strategies and 
implementation of key 
principles: digital-by-default 
public services 

Estimates for 2016: 

  EUR 4.6 million for businesses; and 
  EUR 28 million for citizens. 

2% of Estonia’s GDP saved (according to 
2018 estimates) 

GBP 1.7 billion to GBP 1.8 billion saved 
every year 

The UK124 

The 
Netherlands 
and 
Belgium125 

Spain126 

EU127 

Digital strategies and 
implementation of key 
principles: once-only principle 

Estimates from 2017: EUR 163 million 
(Netherlands) and around EUR 100 million 
(Belgium) saved per year  

Digital strategies and 
implementation of key 
principles: e-administrations, 
once-only principle, and 
interoperability platforms 

EUR 22 billion saved between 2008 and 
2011, with: 

  60% e-administration; 
  20% implementation of once-only 

principle;  

  20% to interoperability platforms. 

Digital strategies and 
implementation of key 
principles: once-only principle 
and digital-by-default public 
services 

Estimates from 2014: 

  EUR 5 billion saved per year linked to 

the once-only-principle; and 

  EUR 10 billion saved per year linked to 

the digital-by-default principle. 

EU 

The use of open source 
software 

Estimated benefits from an increase of 10% 
in open source software contributions: 

  An additional 0.4% to 0.6% GDP per 

year in the EU; 

  Over 600 additional ICT start-ups per 

year in the EU. 

Source: Study supporting the impact assessment for a future interoperability strategy 

122  
123  
124  
125  

126  

127  

Digital Dashboard Belgium, Evolution of cumulative annual cost reduction per target group 2016. 
For further details please see: e-Estonia guide 2020. 
For more details please see: How digital and technology transformation saved 1.7bn. 
For further details please see: Cave J. et al (2017), EU-wide digital Once-Only Principle for citizens and 
businesses. 
Gallo,  C.,  Giove,  M.,  Millard,  J.,  Thaarup,  R.  (2014),  Study  on  eGovernment  and  the  Reduction  of 
Administrative Burden, European Commission, p. 35. 
Ibid., p. 25, 48. 

40 

 
                                                           
The impacts on the costs borne by public administrations in providing public services need to 
be considered in terms of both shorter-term implications and potential longer-term benefits. In 
the shorter run, public authorities may incur costs in setting up the mechanism for structured 
cooperation among administrations in the EU and the Member States. These costs would be 
offset  over the longer term by the benefits  generated through the improved cooperation  and 
the  development  and  implementation  of  common  interoperability  measures  for  public 
services, thus reducing duplications of efforts and unnecessary burdens. In addition, measures 
such as interoperability checks on EU legislation and EU funding would ensure that EU funds 
are spent in a much more cost-effective way, thus generating benefits such as facilitating data 
sharing across sectors and the re-use of digital tools. Overall, the feedback from stakeholders 
is positive, suggesting at least some reduction in the costs borne by public administrations in 
providing public services (with an average score of 0.5 on a scale from -2 to 2, based on 118 
responses). 

This assessment is complemented by estimations of the benefits that are likely to result from 
Option  2  (the  summary  of  the  estimations  is  presented  in  section  7.3  and  Annex  4).  In  this 
case,  the  scenario  for  the  potential  costs  incurred  assumes  a  higher  commitment  to 
implementing  common  interoperability  solutions  based  on  the  enhanced  cooperation 
mechanism  on  interoperability  among  EU  and  Member  States’  public  administrations.  This 
option is not expected to generate additional costs for citizens and businesses compared to the 
baseline  situation.  Regarding  social  impacts,  Option  2  is  likely  to  lead  to  a  significant 
increase in the quality of the services provided by public administrations compared to the ‘no-
change’ scenario. The findings from the evaluations  of the  ISA² programme and the EIF as 
well as the stakeholders consulted confirm this assessment (with an average score of 1.1 on a 
scale  from  -2  to  2,  based  on  116  responses).  Both  evaluations  emphasise  the  need  for 
enhanced  governance  and  cooperation  to  help  build  a  coherent  landscape  of  public  sector 
interoperability across the EU128. This can in turn improve the provision and quality of public 
services.  Furthermore,  the  specialised  literature  underlines  the  importance  of  governance 
mechanisms  and  cooperation  for  the  success  of  digital  government  strategies  and 
implementation  of interoperability  requirements129.  Interoperability can be  a key  enabler for 
generating public value  for stakeholders130, including to  better  equip  public administrations 
to address social challenges (the Dutch Government Data Agenda focuses particularly on the 
role  of  data  to  tackle  social  issues)131.  Interoperability  can  also  contribute  achieving  the 
Sustainable  Development  Goals132,  seen  as  essential  to  foster  positive  social  impacts 
according to the UN133. 

As  far  as  environmental  impacts  are  concerned,  the  measures  proposed  in  Option  2  are 
likely to have positive effects on the green transition in the EU. Interoperable processes, 
and in particular, interoperable data play a significant role across policy areas, including the 
green  transition134.  For  instance,  the  2021  Ministerial  Declaration  on  A  Green  and  Digital 
Transformation  of  the  EU  reinforces  the  need  to  share  data  ‘through  standardised  and 
interoperable common European data spaces to unleash the potential from data on realising 
the European Green Deal’135. The role of interoperable data is also emphasised in the context 

128  
129  

130  

131  
132  
133  
134  
135  

See EIF final evaluation SWD(2022) 720 final, and ISA² final evaluation SWD(2021) 965 final. 
Nielsen, M. M., Jordanoski, Z. (2020), Digital transformation, governance and coordination models: A 
comparative study of Australia, Denmark and the Republic of Korea, pp. 285–293. 
Chantillon, M., Crompvoets, J., and Peristeras, V. (2020), Prioritizing Public Values in E-government 
Policies: A Document Analysis, Information Policy. 
OECD (2019)  The Path to Becoming a Data-Driven Public Sector. 
The Digital Public Goods Alliance, https://digitalpublicgoods.net/about/. 
UN (2020), The Impact of Digital Technologies, UN75 Issue Briefs. 
Towards a green competitive and resilient EU economy. 
Ministerial Declaration on A Green and Digital Transformation of the EU, 19 March 2021. 

41 

 
                                                           
of  the  Zero  Pollution  Action  Plan136.  Combining  different  types  of  data  (for  instance 
pollution-related data and spatial data) can bring innovations that help alleviate environmental 
impacts  from  pollution.  Establishing  a  common,  machine-readable,  way  of  defining  and 
exchanging  environmental/climate  footprint  data  with  all  market  players  could  save  the 
burden in setting up and operating public procurement in an age in which everybody will be 
responsible  for  knowing  and  reporting  their  own  climate  footprint  (e.g.  today  every  time 
something is procured we need to define again and again how/when/in which way the vendor 
should communicate such data). In addition, enhanced interoperability of data and processes 
can  also  bring  direct  environmental  impacts  from  reducing  paper-based  processes  in  the 
public  administrations  as  well  as  limiting  physical  travel  required  from  the  users  of  public 
services when completing administrative procedures137. 

Option  2  is  also  expected  to  have  generally  positive  impacts  on  fundamental  rights,  in 
particular on the individuals’ rights to move freely within the EU. The positive impacts would 
come  from  the  enhanced  provision  and  higher  quality  of  digital  and  interoperable  public 
services  which may further facilitate this right.  The feedback from stakeholders goes in this 
sense  (with  an  average  score  of  0.9  on  a  scale  from  very  negative,  -2,  to  very  positive,  2, 
based on 111 responses). From this perspective, Option 2 may also further support the right to 
good  administration  as  captured  in  Article  41  of  the  EU  Charter  of  Fundamental  Rights138. 
Especially introducing conditionalities is expected to have positive impacts on the quality of 
services (with an average score of 1.3 on a scale of  -2 to  2, based on 56 and 54 responses, 
respectively, received to the targeted consultations). 

Looking at political feasibility, Option 2 is very closely aligned with the recommendations of 
the  expert  group  on  interoperability  of  public  services  (see  Annex  V)  and  with  the  Berlin 
declaration. It can therefore be expected to receive political support from Member States. The 
European Parliament often underlines the importance of interoperability in its opinions (e.g. 
in the recent discussions around the Digital Markets Act) we can assume that it would support 
this initiative. 

6.4. 

6.4. 
bodies 

Impacts of option 3: Legal interoperability requirements for public sector 

Option  3,  focusing  on  a  legislative  approach  based  on  interoperability  requirements,  is 
expected  by  stakeholders  to  speed  up  the  benefits  in  terms  of  harmonisation  of  the  public 
sector interoperability landscape in the EU. Such benefits, however, must be weighed against 
the costs and the overall feasibility of implementation. 

The benefits and costs linked with this option would derive from the binding approach taken. 
This  option  includes  making  an  updated  EIF,  or  parts  thereof,  mandatory  to  be  taken  up  in 
national  frameworks.  The  costs  of  implementing  the  EIF  would  thus  vary  across  the  EU 
depending on whether only an update is required to the national framework or if the national 
framework needs to be built from scratch (which would be the case for 5 Member States). In 
addition,  the  binding  approach  would  also  see  more  common  standards  being  taken  up  by 
public  administrations  across  the  EU  and  associated  maintenance  costs.  Relevant  standards 
would need to be developed and adopted in implementing acts before being implemented in 
IT  systems  of  EU  public  administrations.  The  high  number  of  technical  specifications  and 

136  
137  

138  

SWD(2021) 140, Digital Solutions for Zero Pollution. 
The  Once Only initiative  – a stepping  stone  to Europe’s recovery; eGovernment Using technology to 
improve public services and democratic participation. The environmental impact from improved digital 
public services is also noted in several government strategies for digital government including the UK 
(Greening  Government:  ICT  Strategy  2011,  p.  12,  )  and  Malta  (A  Strategic  Plan  for  the  Digital 
Transformation of the Public Administration 2019 – 2021, p. 46, ). 
Regarding its applicability beyond proceedings of EU bodies see Case C-604/12. 

42 

 
                                                           
standards implemented in ICT systems makes it impossible to use implementing acts to cover 
anything beyond basic minimal requirements. 

In  terms  of  economic  impacts,  Option  3  is  expected  to  have  positive  impacts  on  the  free 
movement  of  goods,  services,  capital  and  workers  across  the  Member  States  as  well  as  on 
research, development and innovation. It would help establish common specifications across 
the  IT  systems  of  Member  States  public  sector  and  ensure  smooth  data  flows  which  are  a 
basic requirement for free movement. In the long term it will likely contribute to a reduction 
in  the  costs  of  interacting  with  public  administrations  as  it  would  facilitate  the  ‘once-only 
principle’. But Option 3 may have more limited positive effects on the costs borne by public 
administrations in providing public services. This reflects the dual nature of costs: in the short 
term,  the  introduction  of  minimum  requirements  for  interoperability  is  likely  to  lead  to  an 
important  increase  in  the  costs  borne  by  public  administrations;  over  the  longer  term,  the 
benefits from more coordination and harmonisation are expected to outweigh the initial costs. 
However,  the  requirements  may  be  more  burdensome  on  countries  already  facing  resource 
scarcity issues (limited financial resources as well as qualified staff) or countries that already 
have  made  high  investments  in  their  domestic  interoperability  landscape  and  have  a  high 
number of legacy IT systems. 

In  terms  of  social  impacts,  significant  positive  impacts  are  expected  by  consulted 
stakeholders when it comes to the quality of the services provided by public administrations 
(with  average  scores  of  1.2  and  1.1  on  a  scale  from  very  negative,  -2,  to  very  positive,  2, 
based  on  119  and  112  responses,  respectively,  received  to  both  the  targeted  and  public 
consultations).  The  implementation  of  minimum  interoperability  requirements,  mandated 
through a legal act, would likely contribute to a more harmonised landscape of public services 
across the EU, facilitating the access to and quality of services, and it would further support 
wider efforts for public sector digitalisation and innovation. 

With regard to environmental impacts, the introduction of minimum requirements proposed 
in Option 3 is expected to contribute to the green transition in the EU, even if indirectly in line 
with Option 2. 

Finally,  Option  3  would  also  bring  positive  impacts  on  fundamental  rights,  further 
facilitating  the  individuals’  rights  to  move  freely  within  the  EU.  Stakeholders  consulted  in 
both the targeted and the public consultations see particularly positive impacts stemming from 
this option (as confirmed with an average score of 1 on a scale from very negative, -2, to very 
positive, 2, from 106 answers). In addition, building on the identified social impacts, Option 3 
may  also  further  enable  the  right  to  good  administration  (Article  41  of  the  EU  Charter  of 
Fundamental Rights139). 

The  option  of  introducing  new  minimum  interoperability  requirements  through  a  legislative 
act  could  potentially  generate  significant  benefits  for  citizens,  businesses,  and  public 
administrations.  It  would,  however,  also  create  the  highest  costs  among  all  options.  While 
Member  States  are  still  in  the  course  of  implementing  several  EU  policies  with  high 
interoperability  implications  (like  the  Digital  Single  Gateway  or  the  Open  Data  Directive), 
their preference is on establishing a good cooperation mechanism around the topic and not on 
further legally binding result obligations (see Expert Group recommendation in Annex V). 

A more in-depth feasibility assessment would be needed on this option as it is the one that has 
the farthest-reaching impacts on existing and future policies both at Commission and Member 
States level. Getting an agreement on common mandatory interoperability requirements at EU 
level would be a major challenge, even more so if we factor in concerns of commercial actors 
that could come up or the ones of all the different levels of administrations across the Member 

139  

Regarding its applicability beyond proceedings of EU bodies see Case C-604/12. 

43 

 
                                                           
States.  This  would  make  it  very  difficult  to  align  enough  up-front  to  legislate  on  concrete 
technical requirements via implementing or delegated acts. Where in Option 2 there is a focus 
on  ensuring  the  process  is  in  place  with  some  clear  but  limited  obligations,  roles  and 
mandates,  Option  3  adds  on  top  a  ‘standardisation’  oriented  approach  which  does  not  seem 
appropriate considering the differences in levels of digitalisation of the Member States.  

The  advantage  of  the  process-focused  approach  in  Option  2  is  that  issues  can  be  taken  up 
when  they  are  topical  and  ‘ripe’140,  like  for  the  COVID-19  ‘Green  passes’,  and  not  in 
abstracto when it will be difficult to activate the relevant actors across multiple policy areas 
to  take  a  proportionate  and  technical  sound  decision.  It  is  also  easier  to  react  to  political 
priorities in the first place, and to do so in a more flexible way. 

Politically, Member States would most likely not be in favour of very strong legally binding 
obligations  (see  expert  group  recommendations  in  Annex  V)  which  may  lead  to  this  option 
being blocked in Council discussions.  

7.  7.  HOW DO THE OPTIONS COMPARE? 

In this chapter, we compare the policy options on basis of the following five criteria: 

-  coherence with the existing legal framework at EU and national level;  

-  effectiveness, in terms of the potential to achieve the general and specific objectives of the 

initiative; 

-  efficiency,  in  terms  of  the  benefits  in  time  and  cost-savings  for  citizens  and  businesses, 
impacts  on  the  quality  of  public  services,  impacts  on  green  transition,  fundamental  rights, 
implementation  costs  for  public  administrations,  compliance  costs  for  citizens  and 
businesses;  

-  subsidiarity,  in  terms  of  what  could  be  achieved  by  Member  States  acting  alone,  and 

whether the objectives can be met more (cost-) efficiently at EU level; and 

-  expected support from stakeholders. 

The results of the analysis are summarised in  Table 3 and explained in further detail in this 
section. The table should be read as follows: ‘0’ if no new impact compared to the status quo 
is expected; ‘-’ if negative impacts are likely to arise; ‘- -’ if the option would result in very 
negative impacts; ‘+’ pointing to positive impacts; ‘++’ referring to very positive impacts; and 
‘+++’ to the best performance among the options. 

Table 3. Comparison of options 

Criteria 

Core policy options 

Option 0 –
Baseline 

Option 1 – 
revised 
EIF 

Option  2  – 
Governance 

–

3 

Option 
Interop. 
requirements 

Coherence 

 ST  LT  ST   LT 

 ST 

LT 

 ST 

LT 

Coherence 
ongoing 
initiatives  in  the  field  of  digital 

with 

-- 

-- 

 + 

- 

+ 

++ 

 - 

++ 

140  

The work of Commission, Member States and private actors on the COVID-19 ‘Green passes’ is a good 
example of the success of standardisation and interoperability efforts now embodied in the EU Digital 
Covid Certificate Regulation. 

44 

 
  
                                                           
Criteria 

Core policy options 

Option 0 –
Baseline 

Option 1 – 
revised 
EIF 

Option  2  – 
Governance 

–

3 

Option 
Interop. 
requirements 

transformation 

Effectiveness 
objectives 

Establish  an 
governance  

- 

Specific 

interoperability 

approach 

Coherent 
policymaking 
implementation 

from 
to 

Co-create  an  ecosystem  of 
interoperability 
standards, 
solutions  and  services  for  the 
EU’s public sector 

ST   LT  ST  LT 

 ST 

LT 

ST  

LT 

- 

-- 

 0 

- 

+ 

++ 

+ 

++ 

0 

0 

 + 

0 

++ 

++ 

++ 

+ 

0 

0 

 + 

0 

++ 

++ 

+ 

+ 

Efficiency 

 ST  LT  ST   LT 

ST  

LT 

ST  

LT 

0 

 0 

+ 

++ 

++ 

++ 

++ 

 0 

+ 

++ 

++ 

++ 

++ 

Benefits  (time-  and/or  cost-
savings) 

Impacts on the quality of public 
services  

Impacts  on  the  green  transition 
in the EU 

Impacts on fundamental rights 

Implementation  costs  incurred 
by public administrations  

0 

- 

- 

0 

0 

- 

- 

0 

0 

 0 

 0 

0 

+ 

 0 

+ 

 - 

0 

- 

Compliance  costs  incurred  by 
citizens and businesses  

 0 

0 

 0 

0 

0  

Subsidiarity 

Stakeholders support 

Overall 
consultations 

respondents 

to 

National  and  regional  public 
administrations 

0 

0 

- 

+ 

++ 

+ 

++ 

 + 

+ 

45 

0 

+ 

- 

0 

+ 

+ 

- 

0 

+ 

+ 

-- 

0  

- 

++ 

+ 

 
  
 
 
 
 
 
  
  
  
  
+ +  Very positive impact 

+ 

0 

- 

Positive impact 

Neutral impact 

Negative impact 

- - 

Very negative impact 

ST = short term; LT = long term 

7.1. 

7.1 Coherence 

In  terms  of  coherence  with  the  ongoing  initiatives  in  the  field  of  digital  public  sector 
transformation,  the  baseline  (Option  0)  has  the  clear  disadvantage  of  a  guiding  policy 
instrument (EIF) that is already outdated in a very dynamic policy field. It would have a very 
negative impact as it would no longer be consistent and coherent with all initiatives adopted 
since 2017 (see legal context). Updating the EIF as foreseen in  Option 1 would in the short 
term  resolve  this  problem  of  coherence  with  newer  policies  but  would  not  provide  a 
sustainable solution in the long term as the amount of policy initiatives with impacts on digital 
is only expected to increase. 

Option  2  scores  best  in  terms  of  coherence  as  it  offers  a  governance  framework  for  an  EU 
public sector infrastructure that can develop and adapt over time to relevant new policy and 
technological  developments.  Coherence  would  depend  on  the  take-up  of  the  agreed 
interoperability  specifications  in  other  policy  initiatives  and  instruments.  This  has  the 
downside that it needs to be ensured through Commission-internal rules in the first place141. 
On the upside, it would avoid conflicting rules across policy fields – as it would foster clear 
and dynamic links between the policies. 

Option 3 would in the short term be problematic, as coherence with the existing and proposed 
policies with high interoperability stake, like the Digital Services Act142, the Data Governance 
Act143 a  framework  for  a  European Digital Identity144,  and  a  Regulation  laying  down 
harmonised AI rules would need to be created ex-post. In the medium and long term, it could 
foster coherence as it would push for a stronger alignment of interoperability requirements set 
in  policies across different  administrative levels, like those foreseen in  a future Data act  for 
the data spaces. As standards and specifications would need to be set through implementing 
acts,  it  would  be  a  challenge  to  ensure  alignment  with  rapid  technical  development  and 
maintain a coherent and up-to-date framework, also given the very large group of interested 

141  

142  

143  

144  

While the co-legislators could conceivably ensure such coherence as well, this task should naturally be 
achieved upstream, from the very inception of a new policy proposal and through its elaboration by the 
Commission services until its official adoption. Work on internal measures to support this are advanced 
and continue. 
Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on a 
Single  Market  For  Digital  Services  (Digital  Services  Act)  and  amending  Directive  2000/31/EC, 
COM/2020/825 final. 
Proposal  for  a  REGULATION  OF  THE  EUROPEAN  PARLIAMENT  AND  OF  THE  COUNCIL  on 
European data governance (Data Governance Act) COM/2020/767 final. 
Proposal  for  a  REGULATION  OF  THE  EUROPEAN  PARLIAMENT  AND  OF  THE  COUNCIL 
amending  Regulation  (EU)  No  910/2014  as  regards  establishing  a  framework  for  a  European  Digital 
Identity, COM/2021/281 final. 

46 

 
 
                                                           
actors both in the public sector and among the private actors who have a commercial interest 
in  supplying  digital  technologies  to  the  public  sector.  The  focus  on  specific  requirements 
might not be fit to ensure long-term future coherence.  

Option  2  would  not  impose  a  harmonised  and  general  interoperability  obligation  across 
Europe (different from option 3) but would support gradually building up an interoperability 
infrastructure  with  public  administrations  performing  transparent  assessments  of  the 
possibilities for reusing and further developing common interoperability resources.  

7.2. 

7.2 Effectiveness 

The objective of establishing an interoperability governance designed to enable the different 
administrative  levels,  sectors  and  stakeholders  to  work  together  is  not  delivered  through 
Options  0  or  1  and  they  would  most  probably  have  negative  impacts  as  the  body  that  was 
governing the Interoperability Action plan  – the ISA² committee, does not exist anymore (it 
has  been  replaced  by  the  higher  level  Digital  Europe  Programme  committee).  The 
interoperability expert group would allow for limited and occasional involvement of relevant 
Member State stakeholders. 

The  governance  objective  is  expected  to  be  most  effectively  achieved  with  Option  2.  The 
legislative  proposal  presented  under  this  option  would  focus  on  defining  a  clear  mandate, 
roles and responsibilities for the relevant actors, ensuring continued delivery of the required 
policy outcomes: common resources and aligned implementation. Option 3 can be expected 
to be similarly effective, although the focus on mandatory requirements might overshadow the 
cooperation potential. 

Option  3  could  give  a  strong  push  for  digital-ready  implementation  of  EU  policies  in 
Member States by making interoperability requirements mandatory. Option 2 seems however 
the  best  placed  to  ensure  measures  are  fit-for-purpose  in  the  short  and  in  the  long  term  by 
establishing  a  mechanism  that  allows  Member  States  to  work  permanently  together  on 
interoperable solutions for the implementation of EU policies, based on their needs.  Staying 
with the baseline (Option 0) would be neutral to negative for this objective. The current EIF is 
issuing just one high-level recommendation on the topic that would remain valid and could be 
addressed with different measures also outside the current policy framework without creating 
incoherencies.  Negative  impacts  can  be  expected  especially  in  the  longer  term  with  staying 
with the status quo that would be less and less fit for purpose to be the main point of reference 
for  a  strong  and  coherent  EU  approach.  Option  1  could  be  a  vehicle  to  clarify  the 
Commission’s  commitment  and  continued  engagement  in  the  field,  without  a  promise  of 
stronger impact. 

Options  2  and  3  are  considered  most  effective  to  reach  the  objective  of  co-creating  an 
ecosystem  of  interoperability  standards,  solutions  and  services  for  the  EU’s  public 
sector. Option 2 would however be most effective in providing a framework for the consistent 
and  continued  co-creation  of  such  an  eco-system.  Option  1  would  remain  on  the  level  of  a 
Commission  statement  of  intention  and  the  speed  of  development  would  most  probably 
remain on the level of the last 20 years, not meeting Member State and policy expectations. 
While  Option  3  would  be  very  effective  in  pushing  for  a  (limited)  set-of  reuse  of  shared 
interoperability standards and solutions, it risks being overall less effective because it would 
not  be  focused  on  an  open  and  innovative  growing  ecosystem  of  diverse  interoperable 
solutions. It is less likely that regional and local public administrations would be actively and 
constructively involved as the focus is more on the regulatory than on the community building 
part. Moreover, option is 3 less likely to garner political support, due to its broad scope and 
high  subsidiarity  sensitivity  (e.g.  as  regards  EU  and  Member  States  legacy  systems). 

47 

 
Therefore,  it  is  presumed  to  impact  much  less  in  guaranteeing  a  flexible  and  responsive 
reaction to rapidly changing technological and policy requirements. 

Whereas  option  2  is  less  intrusive,  striking  a  good  balance  between  efficiency  and  political 
engagement  from  Member  States.  It  creates  a  much  more  realistic  scenario  of  cooperation 
between  Member  States  and  the  European  Commission  to  stablish  a  more  flexible  and 
pragmatic  governance  that  can  adjust  rapidly  to  keep  up  to  new  needs  and  technological 
changes.  It can also lead to option  3 gradually over time, once trustworthy relationships are 
fostered. 

7.3. 

7.3 Efficiency 

Most time- and/or cost-savings for businesses and citizens are expected from options 2 and 3. 

The analysis conducted for this impact assessment report, reuses the study on Quantifying the 
Benefits of Location Interoperability in the European Union by JRC and adapts it to a wider 
area  of  digital  services  related  to  fundamental  administrative  procedures,  as  explained  in 
Annex IV. For policy option 2, the JRC study looks at the impact of increased interoperability 
of public services for citizens, businesses and the public sector.  It  provides estimates  of the 
number of hours saved and its economic value (in EUR) under two scenarios: a static scenario 
in  which  the  time  saved  from  interoperability  comes  only  from  existing  online  users,  and  a 
dynamic  scenario  assuming  a  behavioural  change  in  which  the  proportion  of  online  users 
increases. 

For  the  purposes  of  the  computation  of  the  impacts  associated  to  this  initiative,  i.e.  the 
benefits  that  can  attributed  to  cross-border  interoperability,  further  assumptions  and 
calculations were made on: 

  Number of hours spent by businesses in dealing with administration. A sensitivity 
analysis  was  performed  using  as  parameter  a  percentage  calculated  as  number  of 
hours  spent  by  businesses  in  dealing  with  administration  with  respect  to  total  hours 
worked.  Calculations  were  done  for  a  30%  (the  high  variant,  corresponding  to  the 
original numbers used in the JRC report), 25%, 20%, 15% (as intermediate variants) 
and 10% (for the low variant). In the case of citizens, such wide potential variations on 
number  of  hours  spent  do  not  occur.  As  a  matter  of  fact,  according  to  Eurostat’s 
Harmonised European Time Use Surveys145, the EU-27, on average, citizens spend 27 
min per year dealing with the administration. This represents 0.01% of their working 
time  (excluding  sleeping  time,  holidays  and  weekends).  Any  sensitivity  analysis 
around  this  figure  would  be  little  informative  and  not  bring  any  meaningful  fine-
grained cost saving analysis. 

  Online  public  services  available  cross-border.  Using  data  from  the  eGovernment 
benchmark  of  2021  and  2022,  the  proportion  of  public  services  offered  online  and 
available cross-border was calculated. The EU-27 average is 21% for businesses and 
12% for citizens. The calculations are made at country level, showing a high variation. 
For instance, in the case of businesses for Greece the share is only 2% while is close to 
40% in Spain. For citizens, it ranges from 3% in Romania to 35% in Malta. 

  Degree  of  use.  The  fact  that  a  service  is  available  cross-border  and  online  does  not 
guarantee that it is used. In order to estimate accurately the expect impact, the figures 
are adjusted to take into account the intensity of use.  To do so, data from Similarweb 

145  

https://ec.europa.eu/eurostat/web/time-use-surveys 

48 

 
                                                           
on  cross-border  traffic  to  public  sector  websites  offering  services  (extracted  in  the 
previous step) was used. The EU-27 average is 12%, and the proportion of domestic 
users of online public services is 88%. These figures are also at the country level, with 
Greece showing the lowest intensity (5%) and Luxembourg the highest (35%). 

  Intensity of cross-border usage. For policy option 3 an additional assumption is that 
given  the  broader  scope  of  the  intervention,  the  intensity  of  cross  border  usage 
would increase as it becomes easier to take care of cross-border online public services. 

The JRC original results are re-scaled using the steps above to better approximate the impacts 
of  policy  option  2.  This  results  in  ten  different  scenarios  for  businesses  and  two  different 
scenarios  for  citizens  for  each  policy  option  in  terms  of  savings  (quantified  as  time  and 
money; see below). 

Table 4. Policy option 2 savings 

Policy option 2: Savings 

Business 

Scenari
o 1 

Scenario 
2 

Mh 
EUR 
million 
Mh 
EUR 
million 

Low 

Intermediate
-low 

273.3 

379.2 

Intermediat
e 
523.3 

Intermediate
-high 

674.9 

5 742.7 

8 114.6 

11 343.4 

14 852.6 

297.8 

413.9 

570.3 

738.1 

6 259.5 

8 865.2 

12 352.8 

15 948.6 

Citizen
s 

0.22 

5.5 

0.26 

6.3 

High 

812.6 
17 
553.2 
888.1 
19 
190.7 

Policy option 3 implies setting standards for the development of services of public interest to 
be  implemented  by  all  public  administrations  in  the  Union.  This  would  introduce  strong 
incentives to achieve higher interoperability targets for Member States while digitalising more 
public services. It is expected that in this context, a larger proportion of users will move to the 
online provision of the services. In this case, the results coming from scenario 2 seem more 
realistic.  As  said  earlier  on,  for  policy  option  3  an  additional  assumption  is  that  given  the 
broader  scope  of  the  intervention,  the  intensity  of  cross  border  usage  would  increase  as  it 
becomes easier to take care of cross-border online public services. 

Table 5. Policy option 3 savings 

Policy option 3: Savings 

Business 

Scenario 
1 

Scenario 
2 

Mh 
EUR 
million 
Mh 
EUR 
million  

Low 

314.3 
6 
604.1 
342.5 
7 
198.4 

Intermediate
-low 

436.0 

Intermediat
e 
601.8 

9 331.8 

13 044.9 

476.0 

655.9 

Intermediate
-high 

High 

16 770 

776.1 

934.5 
20 
186.2 
848.8  1 021.4 

10 195 

14 205.7 

18 341 

22 069 

Citizen
s 

0.45 

11.7 

0.52 

13.4 

Based on the evaluation of the EIF and assuming that the speed of development would remain 
the same, option 1 would in this respect also be expected to bring some results but more likely 
in  the  (very)  long  term.  The  effects  of  Option  1  would  likely  be  significantly  higher  if 
introducing 
funding 
programmes (similar to option 2). 

interoperability  synergies  between  EU 

(Commission 

internal) 

49 

 
 
 
 
 
Regarding  impacts  on  the  quality  of  public  services,  the  most  positive  impacts  are,  again, 
expected from Options 2 and 3. Staying with the baseline and Option 1 might have negative 
impacts while more and more recommendations for public sector service design, that in some 
countries are even translated into legal provisions, become outdated. 

As  outlined  in  chapter  6,  the  initiative  could  have  limited  but  positive  effects  on  the  green 
transition, for example by enabling more reuse of data for decision-making and also saving 
energy for the storing of duplicated data. These positive effects are most likely to be achieved 
best in Option 2. While Option 3 introduces clear standards as of its adoption, under Option 2 
these standards would still be co-developed but then in the long-term can be expected to be 
more future proof because more flexibly adaptable. 

By introducing mandatory minimum interoperability requirements Option 3 is likely to create 
the highest friction in its development phase as well as the highest implementation costs for 
public administrations. If requirements do not fit the existing the national IT architecture in 
a Member State they might result in significant new investments in IT infrastructure as well as 
potentially  in  costly  and  lengthy  adaptation  processes  for  their  legacy  systems.  In  the  long-
term implementation costs could however be lower due to more possibilities to share solutions 
among  Member  States  public  administrations.  Also,  here  Option  2  appears  to  be  the  most 
sustainable solution. 

As the EIF is mostly implemented today, no implementation costs would result from staying 
with the status quo. Based on the evaluation of the EIF and the costs that can be linked to the 
implementation  of  that  framework,  it  is  likely  that  also  the  costs  for  an  EIF  update  under 
option  1  would  be  relatively  low.  The  implementation  costs  for  option  2  would  very  much 
depend  on  the  decisions  of  Member  States  and  the  different  projects  public  administrations 
would engage in.  Implementation costs could  be adapted according to  the funding available 
from different sources (EU programmes and MS funding). 

As  none  of  the  options  is  proposing  to  introduce  obligations  to  citizens  and  businesses,  no 
compliance costs are expected for them. 

7.4. 

7.4 Subsidiarity 

This  initiative  is  subsidiarity-sensitive  by  its  very  nature:  Member  States  and  their  regional 
and local authorities are sovereign in deciding their administrative organisation. It is the local 
level with whom citizens and businesses interact most closely. It is essential to preserve the 
freedom  of  administrations  to  act  in  their  areas  of  responsibility.  However,  confronted  with 
shared  challenges  of  digital  transformation,  administrations  at  all  levels  seek  cooperation, 
shared  resources,  and  legal  and  investment  certainty  in  their  modernisation  decisions.  This 
becomes  evident  from  the  Living-in.EU  movement  of  local  communities  and  the 
recommendations from the Member State level expert group on interoperability. 

Option 2 is expected to best uphold the subsidiarity principle as it intends to set up a multi-
level  governance  on  interoperability,  fostering  the  development  of  common,  diverse  yet 
interoperable  solutions.  Co-ownership  of  EU  level  interoperability  initiatives  would  foster 
buy-in through self-regulation in a persistent and continuous fashion. Option 1, due to its non-
binding  nature  would  also  allow  for  a  diverse  ecosystem  but  be  less  effective  in  fostering 
exchange and legal certainty over time. 

The  baseline  and  Option  3  are  considered  as  neutral  to  negative  in  subsidiarity  terms.  The 
baseline because necessary decisions on the update of the framework would not be taken, and 
Option  3  because  it  focuses  on  one  harmonised  approach  not  necessarily  supporting  the 
emergence  of  an  ecosystem  of  different  yet  interoperable  solutions  and  strong  IT  legacy  in 
numerous Member States and domain areas. The result would be formal compliance with the 

50 

 
subsidiarity principle but without the support (local) administrations need to make subsidiarity 
a sustainable reality. 

In  conclusion,  an  interoperability  governance  as  set  out  in  Option  2,  would  establish  a 
minimally 
invasive  and  self-sustaining  subsidiarity  support  mechanism  for  public 
administrations at all levels; freedom to address local needs in service design while relying on 
common  interoperability  resources  to  reduce  development  efforts  and  offer  seamless  public 
services to citizens and businesses. 

7.5. 

7.5 Stakeholder support expected 

When it comes to the expected support from stakeholders, different stakeholder groups have 
to  be  distinguished:  among  contributors  from  EU  institutions,  in  the  overall  consultations, 
option  3  –  with  a  strong  legal  framework  –  obtained  the  highest  scores;  among  Member 
States: option 2 is likely to have more support as it is most in line with the recommendations 
on  a  future  interoperability  policy  issued  by  the  expert  group  on  interoperability  of  public 
services. 

In the public consultations all stakeholders supported a stronger approach, introducing more 
obligations on interoperability. 

8.  8.  PREFERRED OPTION 

In the light of the above comparison, option 2 is the preferred option.  

The European Commission should propose a legislative act establishing an interoperable EU 
public  sector  infrastructure  and  strengthened  EU  policy  coordination.  It  should  introduce 
interoperability  as  a  foundational  principle  for  EU  digital  policies  implementation,  under  a 
governance shared between Member States and the Commission.  

Figure 9. Role of interoperability in the EU public sector digital infrastructures 

This  would  ensure  building  gradually  a  common  European  infrastructure  of  interoperable 
public  services  and  data  exchange,  successful  examples  for  which  can  be  found  at  Member 
State  level,  for  instance  in  Spain  or  Denmark.  This  option  would  over  time  build  a  trans-
European network of public services, evolving with EU and Member States policy needs and 

51 

 
 
implementation  priorities;  a  subsidiarity  enabling  framework  flexible  enough  to  adjust  to 
adapting policy and implementation circumstances. 

The recommendations from the expert group on Interoperability of European public services 
on a future public sector interoperability policy, endorsed in October 2021 by all the Member 
States,  call  for  ‘a  clear  strategy  focused  on  enabling  delivery  on  the  ground  and  a  proper 
governance  at  European  level,  that  makes  it  possible  to  align  and  coordinate  efforts  of  this 
scale’.  They  request  the  European  Commission  to  ‘establish  a  shared  governance  of 
interoperability with a stronger, structural involvement of the Member States’146. 

Such  a  common  ‘Interoperable  Europe’  governance  secures  full  co-ownership  by  Member 
States  in  a  subsidiarity  sensitive  area  and  allows  for  the  necessary  sustainability  of 
interoperability  solutions  in  a  fast-changing  technology  and  policy  context.  It  would  act  in 
cooperation  with  established  European  structures  and  policies  (such  as  in  standardisation, 
Digital Decade, innovation or data protection) and facilitate sectoral policy implementation by 
ensuring ‘interoperability by default’. A dedicated public sector interoperability governance is 
a  focused  support  instrument  for  better  regulation,  helping  reduce  policy  implementation 
effort and cost, and streamline investments. 

An interoperability legislative act could be usefully presented in a package, combined with a 
policy communication setting out the objectives of the strengthened European Public Sector 
Interoperability  Policy  and  its  interaction  with  existing  and  emerging  EU  policies.  It  could 
include  as  an  annex  the  European  Interoperability  Framework  for  Smart  Cities  and 
Communities.  The  policy  communication  could  in  addition  set  out  the  intention  of  the 
European Commission to strengthen its own interoperability-ready policy-making principles, 
by  including  regular  digital  and  interoperability  checks  in  its  internal  procedures,  during 
policy formulation, impact assessments and policy implementation. 

Proportionality assessment of the preferred option 

Despite  imposing  some  obligations  on  Member  States  public  administrations,  the  preferred 
option  would  not  require  the  adoption  of  measures  that  would  burden  them  beyond  what  is 
necessary  for  the  achievement  of  this  initiative’s  objectives.  Member  States  would  have  to 
implement  measures  that  ensure  the  functioning  of  the  governance,  designate  a  national 
coordinator, publish references to EU funded interoperability resources they develop, enhance 
the uptake and sharing of interoperability solutions. 

The objectives to ensure a coherent EU approach, an EU-wide multi-level governance and a 
dynamic ecosystem  cannot be achieved by Member States action alone but need EU action. 
The analysis of the options and the experience of the last 25 years of non-binding action in the 
field,  have  shown  that  only  a  legislative  approach  introducing  structural  cooperation 
requirements  and  a  certain  level  of  coherence  on  interoperability  requirements  is  needed  to 
reach  the  objectives.  The  legislative  obligations  from  Option  2  would thus be  entirely 
proportionate to the objectives of the initiative. 

REFIT (simplification and improved efficiency) 

As  detailed  throughout  the  assessment,  interoperability  is  an  enabler  for  increased  public 
sector  efficiency  and  more  effective  public  services.  It  plays  a  central  role  in  reducing 
administrative barriers. Some of the recommendations of the EIF from 2017147 were around 
administrative simplification and burden reduction. 

The evaluation of the EIF shows that its’ benefits on burden reduction originate mostly from 
two factors: 

146  
147  

See Annex V. 
European Interoperability Framework (2017). 

52 

 
                                                           
-  Affirming  the 

importance  of  administrative  simplicity.  By  streamlining  and 
simplifying  the  digital  delivery  of  public  services,  the  EIF’s  implementation  costs  were 
negligible in  comparison to  the cost  savings associated with  interactions between public 
administrations, as well as between administrations and their constituents; and, 

-  Encouraging  data  reuse.  The  EIF’s  goal  is  to  assist  public  administrations  in  avoiding 
duplication  of  effort  and  effectively  leveraging  existing  resources  and  information, 
resulting in better service quality. 

From  Figure  10  we  can  see  there  is  quite  a  strong  correlation  between  the  level  of  Digital 
public  services  offered  by  a  Member  State  and  the  perceived  complexity  of  administrative 
procedures:  the  highest-ranking  states  in  digital  public  services  and  interoperability148  have 
the lowest perceived complexity. 

Figure 10. EUPACK study 2021 Administrative burden reduction and digitalisation 

The  following  table  summarises  the  REFIT  potential  detected.  Following  the  analysis,  the 
positive impacts of the preferred option on interoperability of the public sector are expected to 
be  far  more  important  than  those  of  the  current  EIF.  With  extra  new  measures  which  will 
focus  on  ensuring  more  coherence  in  the  implementation  of  EU  policies,  the  potential  for 
simplification and improved efficiency of this policy is very high. 

Table 6. REFIT cost savings 

REFIT Cost Savings – Preferred Option  

Description  

Amount  

Stakeholders who save costs 

Replacing proprietary 
solutions with co-designed, 
open solutions 

2021 study149 on the role of 
open-source software, an 
increase of 10% in the use of 
open-source software in the EU 
may generate an additional 
0.4% to 0.6% GDP per year 
as well as more than 600 

Public administrations 

148  
149  

EIF Monitoring | Joinup (europa.eu). 
https://digital-strategy.ec.europa.eu/en/library/study-about-impact-open-source-software-and-hardware-
technological-independence-competitiveness-and 

53 

 
 
                                                           
REFIT Cost Savings – Preferred Option  

Description  

Amount  

Stakeholders who save costs 

additional ICT start-ups per year 
in the EU 

Digital-ready policies  

– implement at lower costs 

Danish examples: Reducing 
administrative burdens with 
digital-ready legislation 

- Public administrations 

- Citizens and businesses 
depending on the policy 

More interoperable digital 
services save time and 
money for their users (see 
more in Annex IV)  

More informed decisions 
due to better data 

JRC analysis performed for this 
impact assessment 

Savings for citizens in the EU 
per year: ranging from 5.5 to 6.3 
million EUR 

Savings for businesses in the 
EU per year: ranging from 5 
743 to 19 190.7 million EUR 

Not quantifiable – could 
potentially sum up to the costs 
of a pandemic that can be 
prevented due to available data 
for timely decisions or not 

-  Citizens  
-  Businesses 
- 

-  Citizens  
- 

9.  9.  HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED? 

The initiative would ideally contribute to an integrated monitoring system involving different 
Commission  services  –  measuring  the  quality  of  (digital)  public  administration,  its  digital 
maturity,  especially  the  monitoring  system  that  is  planned  to  be  established  under  the 
proposed  Decision  ‘Path  to  the  Digital  Decade’150.  In  this  context  the  national  reports  and 
country  recommendations  could  include  topics  emerging  from  the  monitoring  of  the 
Interoperability  policy.  Furthermore,  the  EIF  evaluation  recommends  focussing  future 
monitoring  on  using  developed  technologies  (e.g.  through  data  mining)  and  providing  a 
better cost perspective. 

The main indicators and tools that can be used for monitoring and evaluating the digitalisation 
of  the  public  sector  are:  the  eGovernment  Benchmark  reports,  the  Digital  Economy  and 
Society  Index  (DESI)151,  the  upcoming  Local  and  Regional  Digital  Indicators  framework 
(LORDI)152 index, focusing on the local and regional levels. Turning to indicators specifically 
designed to track progress in public sector interoperability, the monitoring work done for the 
Berlin  Declaration  and  the  EIF  could  be  continued  and  built  upon.  The  current  EIF 
Monitoring Mechanism153 is a good basis for developing monitoring activities for the future 
interoperability  policy  and  can  also  provide  reference  points  against  which  future 
developments can be contrasted and compared. It can be complemented by the Digital Public 
Administration  Factsheets  and  the  State  of  Play  of  Digital  Public  Administration.  Beyond 

150  
151  
152  
153  

COM(2021) 574 final. 
https://digital-agenda-data.eu/charts/desi-composite. 
https://living-in.eu/groups/commitments/monitoring-measuring. 
EIF Monitoring | Joinup (europa.eu). 

54 

 
 
 
 
                                                           
these,  several  interesting  indicators  in  the  field  have  been  developed,  like  the  ones  of  the 
OECD  Digital  Government  Index  or  the  UN  e-Government  Development  Index  or  Norway 
and Australia. 

A  set  of  specific  indicators  for  the  initiative  complementing  the  mentioned  systems  is 
proposed in Table 7. A full evaluation every five years would be useful for assessing impacts 
and contextual issues. It could look into the necessity for introducing a more binding approach 
to  interoperability  standards  across  sectors  or  the  need  for  a  joint  undertaking  to  further 
enhance joint investments. 

55 

 
 
Table 7. Summary of potential indicators to monitor the intervention over time 

Operational 
objective 

Indicator  

Definition 

Potential metric 

Unit of 
measure 

Potential 
data sources 

Frequency of 
measurement 

Target 

Set up of a 
multi-level 
governance on 
EU public 
sector 
interoperability 

Extend to 
which a multi-
level 
governance is 
established and 
functional. 

Enhanced 
multi-country 
collaboration 

Extent to 
which public 
administrations 
work together 
to develop 
interoperability 
solutions 

The multi-
level 
governance 
should ensure 
active 
involvement of 
the relevant 
stakeholders in 
EU 
interoperability 
action and a 
good 
interlinkage 
between 
related 
initiatives 

Multi-country 
projects can be 
initiated 
through the 
governance or 
initiated under 
other 
programmes 
but making 
links to the 
interoperability 

National contact points 
designated 

Number of involved 
actors in strategic and 
operational governance 
by stakeholder group 

Number of new sub-
groups, number of 
existing sub-groups 
joining the governance 
framework. 

Number of projects by 
category and type and 
number of involved 
stakeholders and 
outcome. 

Use of the regulatory 
sandbox 

56 

Numbers per 
year 

EC 
monitoring 

Continuous 
score board 

Numbers and 
key topics 

EC 
monitoring 

Continuous 
score board 

100% national 
contacts 
designated 
within 12 
months, all 
stakeholder 
groups 
involved, 
+10% growth 
of network per 
year 

+10% of 
multi-country 
projects per 
year 

 
 
 
 
 
 
Operational 
objective 

Indicator  

Definition 

Potential metric 

Unit of 
measure 

Potential 
data sources 

Frequency of 
measurement 

Target 

EU approach 
to 
interoperability 
established 
across sectors 

Extent to 
which new 
proposals at 
the EU level 
with digital 
impacts link to 
the policy 

Agreed 
interoperability 
solutions 
available 

Extend to 
which the 
governance 
agrees on 
recommended 
interoperability 
solutions 

governance. 

The 
requirement to 
assess for 
digital impacts 
is part of the 
new BR 
guidelines. It 
should be 
monitored in 
how far this, 
combined with 
a stronger 
interoperability 
policy leads to 
more 
references.  

The 
governance 
would have the 
mandate to 
recommend 
solutions. It 
should be 
monitored in 
how far this 
mechanism is 
used. 

Number of EC policy 
files with digital 
impacts 

Number of references 
to interoperability 
policy in proposed or 
adopted policy files by 
category and sector. 

Number of 
recommended 
interoperability 
solutions published 

-  By type of solution 
-  Share of machine-
readable solutions 

57 

Percentage of 
total files per 
year 

SWD impact 
assessments 
and EU acts 
published on 
Eurlex 

Continuous 
score board 

50% policy 
files assess 
digital impacts, 
+10% per year 
link to 
interoperability 
policy  

Number 

EC 
monitoring 

Continuous 
score board 

5 new 
solutions per 
year 

 
 
 
Operational 
objective 

Indicator  

Definition 

Potential metric 

Unit of 
measure 

Potential 
data sources 

Frequency of 
measurement 

Target 

Uptake of 
recommended 
solutions 

Share and 
reuse GovTech 
ecosystem 

Extent to 
which public 
administrations 
(EU, MS, 
regions and 
cities) use 
recommended 
solutions 

Extent to 
which public 
administrations 
share and reuse 
existing 
solutions in 
developing 
digital public 
services in a 
specific field 

The uptake of 
recommended 
solutions 
ensures that 
costs for 
developing 
ICT tools are 
not duplicated 
and it 
contributes to a 
harmonised 
interoperability 
landscape of 
common 
solutions. 

The level of 
re-use of 
solutions 
fulfils two 
roles: it 
ensures that 
costs for 
developing 
ICT tools are 
not duplicated 
and it 
contributes to a 
harmonised 
interoperability 

Number of downloads 
of the solution, number 
of mentioning in 
related procurement 
documents, number of 
reported uptake in 
annual monitoring 

Number per 
year per sector, 
per 
administrative 
level (EU, 
Member 
States, regions, 
cities. 

Platform data, 
procurement 
data, reporting 
by Member 
States 

Yearly 

+10% per year 

Number of 
uploads and 
downloads of a 
solution from a 
central 
platform and 
Member States 
reporting. 

Number of solutions 
added a common 
platform 

-  EU funded 
-  Non EU funded 

Number of solutions 
downloaded from the 
common platform 

Reported instances of 
reuse by Member State 

58 

Number of 
cases 

Yearly 

+5 % of shared 
and +10 % of 
reused solution 
by year 

 
 
 
 
 
Operational 
objective 

Indicator  

Definition 

Potential metric 

Unit of 
measure 

Potential 
data sources 

Frequency of 
measurement 

Target 

and sector 

Number of EU funding 
programmes which 
take-up interoperability 
requirements as 
eligibility criteria. 

Discrete scale 
(ranging from 
no 
interoperability 
requirements 
to having it 
among the 
eligibility 
criteria) 

Eurlex data, 
Questionnaire, 
case studies. 

Yearly 

High level of 
consideration 

Interoperability 
requirements 
in future EU 
funding 
programmes 

Extent to 
which 
interoperability 
requirements 
are integrated 
in the process 
of 
implementing 
EU funding 
programmes 
(e.g. at the 
level of 
proposals and 
award of 
funding) 

landscape of 
common 
solutions. 

Consideration 
of 
interoperability 
requirements 
in the design 
and use of 
funding would 
reinforce 
synergies 
between the 
future 
interoperability 
policy and 
existing 
funding 
programmes. It 
would help 
limit 
inconsistencies 
and ensure that 
the funds are 
used in a way 
that supports 
interoperability 
goals. 

Source: Study supporting the impact assessment for a future interoperability strategy 

59 

 
 
 
 
ANNEXES 

Annex I. Procedural information 

Lead DG: Directorate General for Informatics 

Decide  Planning:  PLAN/2020/7507  -  ‘Evaluation  of  the  implementation  of  the  European 
Interoperability  Framework  (EIF)  and  proposal  for  an  EU  governments  interoperability 
strategy’. 

The Initiative is part of CWP 2022 - REFIT initiatives, point 12, and is referenced under the 
Policy  objective  ‘A  Europe  fit  for  the  Digital  Age’.  The  adoption  is  planned  for  Q2  (June 
2022). 

Organisation and timing 

31/08/20 

15/09/20 

Decide Political Validation (Hahn, Vestager) 

1st ISSG meeting  

Participating DGs: CNECT, DEFIS, DIGIT, ECFIN, EMPL, 
ENER, ENV, ESTAT, FISMA, GROW, the JRC, JUST, MOVE, 
NEAR, OP, REFORM, REGIO, RTD, SANTE, SG and 
TAXUD 

15/10/20 

Publication of combined Evaluation Roadmap and Inception 
Impact Assessment 

01/02/21– 26/04/21  Public consultations 

12/10/21 

15/10/21 

ISSG approval for supporting studies 

Recommendations  of  the  Expert  Group  on  interoperability  of 
public services 

24/11/21 

9th ISSG meeting 

Participating DGs: CNECT, ENV, ESTAT, GROW, JUST, the 
JRC, MOVE, OP, REGIO, RTD, SANTE, SJ, SG, TAXUD, 
DIGIT 

19/01/22 

RSB meeting 

Consultation of the RSB 

An upstream meeting with the RSB took place on 12 March 2021, whose recommendations 
were duly taken into account.  

This  draft  Impact  assessment  was  submitted  to  RSB  on  17  December  2021  towards  the  19 
January  2022  RSB  hearing.  It  has  received  a  positive  with  reservations  opinion  with  the 
following comments: 

60 

 
 
Table  8.  Modifications  to  the  draft  Impact  Assessment  based  on  comments  received  from 
the Regulatory Scrutiny Board 

Main RSB considerations 

Changes made to the IA 

The report is not clear on the scope of 
the initiative and its links to the 
proposed legal base. The report does 
not sufficiently explain the interaction 
of the interoperability policy with other 
related policies. 

Chapter  1.  ‘Introduction’,  Chapter  3.  ‘Legal 
basis’,  Chapter  4. 
‘Objectives’  have  been 
reworked to better explain these aspects. 

covers 

measures 

It  has  been  clarified  that  the  legal  mandate  for 
binding 
cross-border 
interoperability  between  public  services.  Cross-
border  processes  are  however  not  restricted  to 
to  central  government 
central  government 
interactions. Therefore, they concern citizens and 
businesses  using  public 
all 
administrative levels. 

services 

at 

The report does not provide sufficient 
evidence of the identified problems nor 
of their evolution in the future. It does 
not explain why some Member States 
have chosen not to implement an EIF-
inspired interoperability framework.  

Chapter 2. Problem definition has been reworked 
to  better  show  the  evidence  for  the  respective 
relevant  stakeholders  and  distinguish  between 
cross-border interoperability and interoperability 
within  countries,  giving  qualitative  examples 
where the data base is not sufficient. 

We  have  further  explained  in  this  chapter  the 
factors  that  led  some  Member  States  not  to 
implement  an  EIF 
interoperability 
framework. 

inspired 

 The content of the options is not 
sufficiently clear. The report does not 
explain how the policy options, in 
particular the preferred one, would be 
implemented in practice. In particular, 
the role and decision-making power of 
the envisaged governance bodies 
remains too vague. 

Chapter  5.  ‘What  are  the  available  policy 
the 
options?’  has  been 
comments  provided,  giving  also  examples  of 
their practical implementation. 

refined  based  on 

The policy proposal is still under discussion and 
implementation 
not  yet  finalised.  Expected 
practice has been further detailed in the updated 
report in this chapter. 

The  differences  between  the  cooperative,  multi-
level governance introduced in Option 2 and the 
EC led governance in Option 3 have been further 
explained.  We  have  clarified  that  the  current 
interoperability  policy  contains  no 
formal 
governance mechanism – it just has the European 
Interoperability  Framework  as  a  guidance 
interoperability 
document  and 
projects  through the Digital  Europe Programme. 
We  have  explained  how  these  elements  are 
insufficient  for  the  sustainable  design  and  full 
take  up  of  interoperable  digital  services  across 
Europe.  

funding 

for 

In the reviewed report we have further explained 

61 

 
Main RSB considerations 

Changes made to the IA 

the  elements  of  the  proposed  measures  and 
shown  more  clearly  how  the  preferred  option  is 
expected 
the 
to  substantially  contribute 
specific  objective  of  digital-ready  policies 
complementing the newly introduced EC internal 
Better  Regulation 
a  needed 
cooperation  mechanism  to  put  the  theory  into 
practice. 

rules  with 

to 

The report does not sufficiently explain 
the  differences  between  the  different 
estimates  of  potential  savings. 
In 
particular,  the  report  overestimates  the 
savings from interoperability, as it does 
not  disaggregate  them  from  savings  of 
other  simplification  and  digitalisation 
policies.  

effects 

We  have  highlighted  further  the  expected  very 
suffer 
positive 
‘non-interoperable 
significantly  more 
public  administrations’)  and  enhanced 
the 
findings  on 
correlation  of 
the  positive 
interoperability and innovation. 

on  SMEs 
from 

(that 

impacts  and 

As  seen  from  the  studies  and  the  various 
quantifications  methods  we  have  used  to  assess 
impacts,  it  is  extremely  difficult  to  isolate  the 
precise  costs  and  benefits.  Interoperability  has 
far-reaching 
is  a  foundational 
enabler for digitalisation. It’s a key part of many 
recent  EU 
Justice 
digitalisation,  digital  health,  etc.).  The  policy 
itself  aims  to  support  the  deployment  of  EU 
policies that are interoperable by design and will 
start 
of 
set 
a 
interoperability specifications and solutions. 

establishing 

common 

policies 

(Data 

act, 

Nevertheless, we have reviewed further the costs 
and benefits to try to isolate some of them more 
specifically. 

related 

fact,  a  streamlined  analysis  has  been 
In 
conducted  with  the  help  of  JRC  to  quantify  the 
cost  savings,  reusing  the  study  on  ‘Quantifying 
the  Benefits  of  Location  Interoperability  in  the 
European  Union’  by  JRC  and  adapting  it  to  a 
wider  area  of  digital  services 
to 
fundamental administrative procedures stemming 
from  the  eGovernment  benchmark  report.  It 
provides estimates of the number of hours saved 
and  its  economic  value  (in  EUR)  under  two 
scenarios:  a  static  scenario  in  which  the  time 
saved  from  interoperability  comes  only  from 
existing  online  users,  and  a  dynamic  scenario 
assuming  a  behavioural  change  in  which  the 
proportion  of  online  users  increases.  This  has 
been carried out for policy options 2 and 3. The 
whole methodology and approach is described in 
detail in Annex IV. 

62 

 
Main RSB considerations 

Changes made to the IA 

The report has been reworked to introduce more 
stakeholder  concerns  on  the  various  policy 
options, particularly with regards to expectations 
from  Member  States  Chief  Information  Officers 
which  are  consistently  addressed  throughout  the 
report,  given  their  role  as  core  interoperability 
stakeholders.  We  have  further  detailed  in  the 
report 
the 
recommendations  issued  by  the  expert  group  on 
Interoperability  in  the  proposed  policy  options 
and how differing views from stakeholders have 
been  included,  particularly  on  the  elements  part 
of the different options. 

how  we 

addressed 

have 

Evidence, sources and quality 

The Commission has been working for more than 25 years now on interoperability at EU 
level with different stakeholders involved in the digital transformation of the public sector and 
creation of EU-wide digital public services.  

The evidence used in the Impact Assessment have been collected from the following main 
sources and has been used at different steps in the preparation of the initiative: 

  National Interoperability Framework Observatory (NIFO) data collection: 

o  The  Digital  Public  Administration  Factsheets  collected  and  published  yearly; 

available on the Joinup platform;154 

o  The European Interoperability Framework (EIF) Monitoring Mechanism;155 

  Other  databases  including:  Eurostat,  the  World  Bank  Worldwide  Governance 
Indicators, United Nations e-Government survey, and the Organisation for Economic 
Co-operation and Development (OECD) Digital Infrastructure indicators; the datasets 
related to the e-Government Benchmark reports156; 

  Expert Group on interoperability of public services inputs and recommendations 

o  The interoperability expert group was created on 14/02/2020 with representatives 
of the national administrations CIO offices, members appointed for all 27 Member 
States and observers from EFTA and Western Balkans countries 

o  Position  papers  from  18  Member  States:  In  December  2020  the  Commission 
kindly asked the members of the expert group to react on a short policy paper with 
some  initial  ideas  for  the  next  interoperability  policy  (vision,  general  approach, 
policy instruments, etc.); 

o  Co-creation  workshops  –  five  informal  discussions  and  brainstorming  sessions 
took place between January and December 2021 with more than 200 participants; 
o  Bilaterals – the Commission organised 26 bilateral calls with 26 different Member 

States between July and September 2021; 

o  Policy recommendations – they were formally endorsed by consensus of the whole 
group  on  the  5th  of  October  2021.  Those  recommendations  served  as  a  basis  to 
build the draft legal text and the two dedicated workshops.  

154 The factsheets can be consulted on Joinup. 
155 An overview of the EIF Monitoring Mechanism. 
156 The e-Government Benchmark datasets are available at: https://digital-agenda-ata.eu/datasets/e-gov 

63 

 
                                                           
o  Two workshops on legal draft – They took place in November 2021 gathering both 

around 40 external participants each.  

  CEPS  external  supporting  studies  -  The  Commission  contracted  the  Centre  for 
European  Policy  Studies  (CEPS)  to  conduct  three  independent  supporting  studies 
between September 2020 and October 2021. 
o  Supporting study for the evaluation of the ISA² programme 
o  Supporting study for the evaluation of the EIF 
o  Supporting study on the impact assessment for a future interoperability strategy  
  Joint  Research  centre  (JRC)  analysis  –  JRC  has  provided  extensive  support  in 
preparation  of  the  Impact  Assessment,  in  particular  with  a  study  on  quantifying  the 
benefits of Location Interoperability and general costs of interoperability in the EU (in 
publication) 

  Input  received  to  the  Inception  Impact  Assessment  feedback  period157,  13 

responses that are summarised in Annex II. 

  Targeted online survey 94 responses that informed the analysis and the conclusions 

of the study, summarised in Annex II. 

  In-depth interviews with 23 experts and stakeholders 
 

Input  from  Public  Consultation  launched  for  12  weeks,  from  01/02/21–  26/04/21, 
summarised in Annex II. 

  4  public  workshops:  1  inception  workshop  and  2  validation  workshops  in  the 
framework  of  the  DIGITall  conference,  1  public  expert  panel  on  options  for  a  legal 
instrument, more than 200 participants overall 

The Impact Assessment was based on certain assumptions, namely:  

 

It  was  estimated  that  the  number  of  cross-border  cases  of  usage  of  digital  public 
services  would  be  growing  with  the  increase  of  the  number  of  people  living  and 
working in a Member State different from the one of their origin and with the increase 
of the number of people traveling for tourism purposes. 

The data limitations encountered in this Impact Assessment were the following:  

 
 

 
 

lack of data focusing solely on the benefits and costs of interoperability; 
lack of comparable data on the costs and benefits of transposing the EIF into national 
frameworks, due to the voluntary nature and heterogeneous uptake of the framework; 
relatively low number of respondents to the different surveys and online consultations; 
limited availability of data on local effects. Therefore the analysis focuses mainly on 
the EU and national levels and may underestimate the calculated costs as it focuses on 
general costs at the national level. 

To mitigate the impact of the data limitations (to the extent possible), the external contractor 
followed  up  directly  with  some  of  the  stakeholders  to  clarify  certain  aspects  via  targeted 
interviews. The Joint Research Centre kindly offered their expertise and has developed a more 
specific  study  that  took  both  a  qualitative  approach  (20  use  cases  on  location  data 
interoperability) and quantitative (estimation of general costs of interoperability at EU level). 
In addition, where quantification of costs and benefits was not feasible, a qualitative approach 
was  chosen  instead  (description  of  practices,  processes  and  types  of  costs  and  benefits 
deriving  from  the  options).  To  increase  the  number  of  stakeholders  involved  an  important 
number of consultation activities public and targeted were put in place. 

157 See relevant web page on Europa Have your say, available here. 

64 

 
                                                           
Annex II. Stakeholder consultation 

Summary of the stakeholder strategy 

A  continuous  and  active  stakeholder  consultation  strategy  was  designed  and  followed  in 
preparation for the Impact Assessment on the EU public sector interoperability policy. It was 
complemented  by  active  communication  activities  on  our  dedicated  social  media  channels 
(Twitter, LinkedIn, YouTube). 

A  broad  range  of  activities  were  put  in  place  to  ensure  that  all  interested  parties  and 
stakeholders will have the opportunity to provide feedback on the various policy options that 
the Commission has identified with regard to its initiative, and their likely impacts, as well as 
on  the  relevance,  effectiveness,  efficiency  and  the  added  value  of  the  initiative.  In  that 
context,  the  Commission  reached  out  to  a  broad  range  of  stakeholders,  including  Member 
State national authorities, non-governmental organisations, professional associations, business 
organisations and individual citizens. 

To  involve  a  broader  range  of  stakeholders  the  following  consultation  activities  were 
conducted: 

  Public consultation on the inception impact assessment (15/10/21): The key ideas for 
the  review  of  the  European  Interoperability  Framework  and  a  future  policy  were 
outlined  in  an  Inception  Impact  Assessment  (IIA).  The  published  IIA  informed 
citizens  and  stakeholders  about  the  Commissions’  plans  in  order  to  allow  them  to 
provide feedback on the intended initiative. This fed into the subsequent consultation 
activities  that  ensured  an  inclusive  process  with  all  interested  parties  being  actively 
invited to contribute. 

  Online kick-off workshop ‘How interoperability can achieve seamless data flows and 
services  for  the  EU’s  public  sector’,  conducted  on  3  December  2020.  It  aimed  at 
raising  awareness  about  the  EIF  evaluation  and  the  impact  assessment  process  and 
engaging stakeholders in the process. 

  Online survey (19 January – 7 March 2021), targeting specific stakeholder groups. 
  In-depth  interviews  (1  February  –  8  March  2021)  with  19  selected  stakeholders  to 
collect  detailed  data  and  information  contributing  to  the  EIF  evaluation  (12 
stakeholders) and the impact assessment (7 stakeholders), respectively. The interviews 
are complemented by expert assessments conducted by independent experts who were 
tasked with, inter alia, completing the questionnaire that served as the basis for the in-
depth interviews158. 

  A  12-week  long,  Internet-based  public  consultation  (1  February  –  26  April  2021), 

open to the wider public and available in English, German, and French. 

  Validation  workshop  in  the  digitalALL  conference159  on  22  April  2021  presenting 
and  validating  the  outcome  of  the  consultation  activities  with  126  registered 
participants. 

  An  innovative  co-creation,  co-design  process  has  been  put  in  place  with  the 
interoperability  expert  group  with  Member  States.  Workshops  and  roundtables 
following design-thinking methodologies and participatory practices were led with the 
experts  to  discuss  and  develop  the  needs  for  a  future  interoperability  policy:  5 
brainstorming  sessions  with  more  than  200  representatives  from  Member  States,  5 
formal expert group meetings with also more than 200 participants overall, 18 position 

158  

159  

Five  independent  experts  provided  their  assessment  for  the  EIF  evaluation  and  four  for  the  impact 
assessment. 
Further 
be 
public/planning/UGxhbm5pbmdfMzk2Mzcw 

https://app.swapcard.com/event/digitall-

information 

found 

can 

65 

 
                                                           
papers  issued  by  the  Member  States,  26  Member  States  bilaterals  throughout  the 
summer of 2021. 

  The topic was also presented and discussed in 2 meetings of the Chief Information 
Officers network organised by the Presidencies of the European Council (Portugal - 
May  2021,  Germany  -  December  2020)  and  presented  to  the  digital  attachés  in  the 
Telecom Working Party of the Council in April and November 2021. Member States 
have provided us  with  positive and constructive  feedback which has been taken into 
account in the construction of the proposal. 

Summary of the feedback on the Inception impact assessment 

Input on the Inception Impact assessment (IIA) 

In  total  there  were  13  feedback  replies  on  the  IIA  from  8  different  EU  countries  (3  from 
Germany, 2 from Spain and Belgium, 1 from each Sweden, Italy, Greece, France and Finland) 
and one non-EU country (Norway) and different stakeholder groups (see Figure 11). 

Figure 11. Feedback on the IIA by category of respondent 

Source: Have Your Say Portal 

The input was relevant for the formulation of problem and objectives as well as for the policy 
options and the impacts and it is summarized below. 

On the problems stakeholders highlighted the effects of competing and non-open standards. 
One stakeholder suggested that the EIF evaluation should include an analysis on the reasons 
that led to some recommendations to be better implemented than others. This suggestion was 
taken up in the EIF evaluation.  

On  the  objectives  several  stakeholders  draw  links  to  public  values  beyond  digitalisation  as 
such.  They  suggested  to  highlight  the  value  of  interoperability  for  the  democratisation  of 
public knowledge, civil rights, digital involvement of all citizens and diversity.  

One  stakeholder  suggested  to  strengthen  the  ambition  of  EIF  beyond  guaranteeing  the 
necessary state tasks, public services should support the optimal processing and easy usage of 
digital data. In general, most stakeholders advocate to strengthen the principle of openness for 
the  reuse  of  technical  solutions  as  a  core  principle.  One  suggests  including  codified  design 
principles and to encourage an API centric approach. Another stakeholder suggests that the 
EIF should more explicitly be also addressed to regions and sectors. 

Eight  of  the  13  contributions  mention  explicitly  the  need  for  agreed  and  open  standards. 
Two  stakeholders  request 
interoperability  between 
blockchains  into  the  EIF  with  a  clear  definition  and  open  standards.  One  stakeholder 

include  specific  reference 

to 

to 

66 

 
 
highlights  that  this  should  include  standards  around  metadata,  another  the  importance  of 
unique  and  trusted  digital  identifiers.  Two  stakeholders  ask  for  more  and coordinated 
involvement of the public sector in standardisation organisations.  

Five  stakeholders  bring  forward  the  idea  of  fostering  and  EU-wide  sharing  and  reuse  of 
mature,  reusable  and open  source  interoperable  solutions  for  public  administrations.  One 
stakeholder asks to facilitate the multiple use of the same privacy by design infrastructure at 
no extra cost. The future policy should incentivise the sharing of design costs around usable, 
trusted and secure solutions also between public and private stakeholders. 

Three  stakeholders  mention  the  need  for  more  guidance  on  the  use  of  open  standards  and 
open source, including clear definitions. One stakeholder asks for a dedicated task force for 
immediate,  middle  term  and long-term technical  assistance at  all  levels  to  support  any 
interoperability action, including relevant training resources in the Interoperability Academy. 
One stakeholder asks for a certification programme for interoperability trainers. 

Three  stakeholders  highlight  the  importance  of  making  the  interoperability  policy 
consistent with other EU policies like the EU AI strategy. Two stakeholders brought forward 
the  idea  of  a  reference  implementation  on  the  city  level published  under  a  free  software 
license which would act as formal specification and can be implemented directly. This idea is 
mentioned linked to EU policies but also to EIF standards, that should come with at least one 
Open-Source implementation to confirm its implementability. 

For the policy instrument two stakeholders suggest a more binding instrument, one of them a 
consolidated  EU  Regulation  while  another  sees  the  risk  that  a  strict  legal  framework  might 
hinder interoperability – but harmonisation of organisational procedures could be beneficiary. 

One stakeholder highlights the importance for the different sectors on the example of authors’ 
rights. It asks not only for effective cooperation mechanism but also for effective safeguards 
to  ensure  their  respect.  Another  stakeholder  has  a  similar  idea  in  developing  a process for 
assessing compliance with the EIF.  

Stakeholders  highlighted  the  potential  impact  of  a  holistic  transformation  of  (digital)  public 
services  on  the  private  ICT  sector  with  the  potential  to  create  an  ecosystem  of  related  apps 
and services. 

Consultation activities for the EIF evaluation and Impact assessment 

The  consultation  activities  led  by  the  contractor  targeted  several  groups  of  stakeholders. 
The following grouping is used to analyse the feedback to the consultation activities: 

o  Civil society; 
o  Companies and business associations; 
o  EU and non-EU citizens; 
o  EU public authorities; 
o  Experts and academia (including the independent expert assessments); 
o  National and sub-national public authorities in the Member States. 

The  questionnaires  used  throughout  the  consultation  activities  mainly  used  Likert  scale 
responses, referring to a scale from (1) to (5), (-2) to (2) or (--) to (++), depending on the type 
of question160: 

1.  (1) – not at all; (2) – to a limited extent; (3) – to some extent; (4) – to a great extent; or (5) 

– completely; 

160  

For each question, the respondent also had the possibility to select the answer ‘don’t know/no opinion’. 

67 

 
                                                           
2.  (-2)  –  definitely  would  not;  (-1)  –  probably  would  not;  (1)  –  probably  would;  (2)  – 

definitely would; 

3.  (--) – very negative; (-) – negative; (+) – positive; (++) – very positive. 

With  a  total  of  112  respondents  for  the  EIF  Evaluation  and  134  respondents  for  the 
Impact  Assessment  for  a  Future  Interoperability  Strategy,  the  consultation  activities 
reached all types of stakeholders described in Table 9. In what follows, the feedback received 
during  the  consultation  activities  are  presented  according  to  the  type  of  consultation,  i.e. 
public  versus  targeted  consultation161.  Feedback  received  during  in-depth  interviews  are 
grouped together with those from the targeted online survey since both consultation activities 
were based on the same questionnaire; only more qualitative feedback was sought in the in-
depth interviews. 

Table  9.  Overview  of  responses  to  the  EIF  Evaluation  (EIF)  and  the  Impact  Assessment 
(IA) by stakeholder group 

Consultation 

In-depth 
interview 

Online survey 

Public 
consultation 

TOTAL 

Stakeholder 

EIF 

IA 

EIF 

IA 

EIF 

IA 

EIF 

Civil  society  (all 
other 
stakeholders) 

Companies  and 
business 
associations 

EU  and  non-EU 
citizens 

- 

- 

- 

EU 
authorities 

public 

5 

1 

- 

- 

3 

Experts 
academia 

and 

6* 

6* 

2 

3 

2 

8 

4 

1 

5 

4 

10 

3 

7 

8 

9 

IA 

10 

14 

13 

17 

18 

18 

31 

20 

35 

- 

4 

- 

5 

13 

13 

14 

14 

and 

National 
sub-national 
public authorities 

2 

- 

25** 

28** 

12 

16 

39 

44 

TOTAL 

13 

10 

44 

50 

55 

73 

112 

134 

*The six in-depth interviews include the five expert assessments. 
**One follow-up interview to the targeted online survey was conducted in the scope of the EIF  Evaluation and 
one was conducted in the scope of the Impact Assessment. 
Source: Study supporting the impact assessment for a future interoperability strategy 

In the public consultations, feedback was received from 13 Member States, with the highest 
number of received answers from Spain (see Figure 12). In addition, six respondents are non-
EU citizens. For the work with the Expert Group all 27 Member States provided input. 

161  

Averages do not account for respondents answering ‘don’t know/no opinion’. 

68 

 
 
                                                           
Figure 12. Geographical distribution per stakeholders’ category  

Source: Study supporting the impact assessment for a future interoperability strategy 

The group of respondents to the public consultations from public authorities includes a mix of 
administrations  exercising  at  the  international  (3  respondents),  national  (4  respondents), 
regional (6 respondents) and local (3 respondents) levels (see Figure 13). 

Figure 13. Scope of public authorities (share of respondents and number of respondents in 
brackets) 

Source: Study supporting the impact assessment for a future interoperability strategy 

On average, respondents have a good level of knowledge in the field, noting they are familiar 
to  a  great  extent  with  digital  public  services  and  interoperability  (see  Figure  14).  When  it 
comes  to  specific  knowledge  about  the  EIF,  the  difference  between  the  respondents  to  the 
targeted  consultation  and  those  contributing  to  the  public  consultation  is  more  pronounced, 
with  respondents  to  the  public  consultation  reflecting  a  relatively  lower  level  of  knowledge 
(see  Figure  15).  Nevertheless,  the  consulted  stakeholders  are  on  average  familiar  at  least  to 
some extent with the EIF. 

69 

 
 
 
Figure 14. Knowledge of digital public services and interoperability (breakdown by type of 
consultation; average score and number of respondents) 

Score: (1) not at all; (2) to a limited extent; (3) to some extent; (4) to a great extent; or (5) completely. 
Source: Study supporting the impact assessment for a future interoperability strategy 

Figure  15.  Knowledge of the EIF (breakdown by type of consultation; average score and 
number of respondents) 

Score: (1) not at all; (2) to a limited extent; (3) to some extent; (4) to a great extent; or (5) completely.  
Source: Study supporting the impact assessment for a future interoperability strategy 

Results: EIF Evaluation 

The framework is deemed to be relevant to some extent. The needs and problems originally 
identified  by  the  EIF  continue  to  be  experienced  across  the  relevant  stakeholders  and  the 
framework  has  only  partially  addressed  them  (see  Figure  16).  Respondents  to  the  targeted 
consultations call for more guidance for public administrations to improve the governance of 
their  interoperability  activities  and  address  the  problems  linked  to  the  fragmentation  in  the 
delivery  of  digital  public  services  and  the  organisation  and  format  of  public  data.  Public 
administrations  particularly  point  to  the  need  for  more  cooperation,  especially  in  specific 
sectors  (e.g.,  health).  Several  other  needs  were  highlighted,  such  as  the  need  to  increase 
awareness, for staff with IT skills in public administrations and to build investment capacity 
to keep pace with rapid technological change and bridge technological barriers. 

Figure 16. Extent to which the following needs and problems are currently experienced by 
European  public  administrations,  businesses  and/or  citizens  (breakdown  by  type  of 
consultation; average score and number of respondents) 

70 

 
 
 
 
Score: (1) not at all; (2) to a limited extent; (3) to some extent; (4) to a great extent; or (5) completely.  
Source: Study supporting the evaluation of the implementation of the EIF 

Stakeholders participating in both consultations consider that the recommendations of the EIF 
have been effective to some extent in achieving the objectives (see Figure 17). However, the 
EIF  has  been  seeking  to  achieve  broad  objectives  and  the  recommendations  require  more 
granularity. The targeted consultation generally emphasises the contribution of the framework 
to raising awareness of the importance of cross-border interoperability, although more needs 
to  be  done  at  the  sub-national  level.  The  principles  set  out  by  the  EIF  have  enhanced 
interoperable digital public services but are difficult to assess due to their abstract nature or 
still  limited  achievements.  Stakeholders  call  for  more  clarification  when  it  comes  to 
transparency, technological neutrality and user-centricity. The layered interoperability and the 
conceptual  model  could  be  improved  with  more  practical  guidance  for  implementing  the 
models. Overall, positive impacts have been experienced across stakeholders, in particular in 
enhancing the quality of services provided by public administrations and in fostering the free 
movement of goods, services, capital and workers across the EU. Nevertheless, more could be 
achieved to increase the direct and indirect benefits gained by stakeholders. 

Figure 17. Extent to which the recommendations listed in the EIF have contributed so far 
to the achievement of the following objectives (breakdown by type of consultation; average 
score and number of respondents) 

Score: (1) not at all; (2) to a limited extent; (3) to some extent; (4) to a great extent; or (5) completely. 
Source: Study supporting the evaluation of the implementation of the EIF 

Although  costs  and  benefits  are  difficult  to  assess  due  to  a  plethora  of  factors,  stakeholders 
participating  in  the  targeted  consultation  acknowledge  that,  in  the  long  run,  the  EIF  brings 
benefits  that  exceed  the  cost  of  implementation.  The  EIF  results  in  efficiency  gains  by 

71 

 
 
supporting  data  re-use,  enabling  synergies  in  implementing  and  designing  new  services  and 
from  a  national  public 
streamlining  administrative  procedures.  A 
administration noted that the costs of several ICT projects have been eliminated due to timely 
considerations  of  interoperability.  The  costs  of  implementing  the  framework  are  relatively 
moderate, both at the national and EU levels; initial investments can be challenging, but over 
time the benefits outweigh the costs and expand beyond a single administration. 

representative 

In terms of internal coherence, the respondents consider that the components of the EIF are 
generally synergetic (see Figure 18); the framework could be improved by better linking the 
conceptual  model  with  the  principles  and  the  layered  interoperability  model.  In  addition, 
clarification  of  some  thematically  overlapping  sets  of  recommendations  would  make  the 
framework more actionable. At the level of external coherence, synergies are identified with 
the  Single  Digital  Gateway,  the  Digital  Single  Market  Strategy  and  the  Data  Strategy; 
overlaps and inconsistencies remain limited, but challenges may arise within own frameworks 
that are developed as part of sectoral initiatives (see Figure 18). 

Figure  18.  Extent  to  which  there  are  synergies,  overlaps  between  the  EIF  and  other  EU 
initiatives  with  similar  objective  (breakdown  by  type  of  consultation;  average  score  and 
number of respondents) 

Score: (1) not at all; (2) to a limited extent; (3) to some extent; (4) to a great extent; or (5) completely.  
Source: Study supporting the evaluation of the implementation of the EIF 

Finally,  respondents  to  both  types  of  consultations  generally  agree  that  national  or  sub-
national  initiatives  would  bring  only  limited  contributions  to  the  objectives  pursued  by  the 
EIF, confirming its EU added value (see Figure 19). In particular, the cross-border dimension 
cannot  be  achieved  solely  by  national  or  sub-national  administrations.  The  EIF  is  not 

72 

 
 
sufficiently  used  across  areas  and  by  Commission  services.  Furthermore,  cross-border 
interoperability remains limited and is driven by specific sectoral needs. 

Figure  19.  Extent  to  which  national  or  sub-national  interventions  (in  the  absence  of  the 
EIF) would be able to achieve the following objectives (breakdown by type of consultation; 
average score and number of respondents) 

Score: (1) not at all; (2) to a limited extent; (3) to some extent; (4) to a great extent; or (5) completely.  
Source: Study supporting the evaluation of the implementation of the EIF 

Results: Impact Assessment 

On average, there is broad agreement among respondents that the specific objectives defined 
by the impact assessment are largely relevant, with the caveat that many of these objectives 
are  interrelated  and  cannot  be  achieved  separately.  Several  additional  objectives  are 
mentioned  by  stakeholders  participating  in  both  consultations:  the  development  and 
promotion  of  specific  standards  and  guidelines  that  could  guide  public  administrations 
towards  interoperability-by-design,  a  shift  towards  pro-active  and  self-sovereign  services, 
enhancing transparency through the implementation of the once-only principle and a system 
that centralises users’ information. 

73 

 
 
Figure 20. Extent to which a future interoperability policy of the EU’s public sector should 
aim to achieve the following objectives (breakdown by group of stakeholders, average score 
and number of respondents) 

Score: (1) not at all; (2) to a limited extent; (3) to some extent; (4) to a great extent; or (5) completely. 
Note: Averages do not account for respondents answering ‘don’t know/no opinion’ (DK/NO). 
Source: Study supporting the impact assessment for a future interoperability strategy 

The policy options on which stakeholders have been consulted come from the CEPS  ‘Study 
supporting the impact assessment for a future interoperability strategy‘. Options 0 and 1 are 
well  aligned  with  the  ones  detailed  in  the  impact  assessment.  Option  2  and  3  in  the  impact 
assessment already include the add-on options from the study and reflect the evolution of the 
proposals over time. 

Stakeholders  provided feedback on the  impacts  expected to  stem from the core and add-on 
policies option (see Figure 21). Only limited impacts are expected to stem from the baseline 
option (option 0). The soft law approach (option 1) is expected to have some minor positive 

74 

 
 
impacts. A soft law approach may provide enhanced guidance and contribute to some extent 
to  interoperability  in  the  EU,  but  a  voluntary  approach  would  likely  make  a  limited 
contribution. A governance mechanism for interoperability initiatives at the EU level, rooted 
in  a  legal  act,  (option  2)  is  expected  to  have  positive  impacts.  The  coordination  approach 
through  hard  law  will  contribute  to  interoperability  across  the  different  areas  of  impact 
identified; nevertheless, coordination without stricter measures for enhancing implementation 
can  only  bring  limited  contributions.  Finally,  mandating  the  implementation  of  minimum 
interoperability  requirements  at  the  Member  State  level  (option  3)  is  likely  to  bring  the 
highest  level  of  positive  impacts  among  the  core  options  based  on  the  feedback  from 
stakeholders. 

Respondents across most stakeholder groups and consultation activities generally confirm that 
add-on  option  1  (providing  incentives  for  the  development  and  take-up  of  interoperability 
solutions)  would  have  positive  impacts  to  a  certain  degree,  in  particular  with  respect  to 
research, development and innovation in the EU. While add-on option 2 (conditionalities) is 
generally expected to improve the quality of the services provided by public administrations, 
conditionalities  are  expected  to  have  a  more  limited  positive  impact  on  the  costs  borne  by 
public administrations in providing public services. Using the European Semester as a tool to 
monitor  the  progress  made  in  the  field  of  interoperability  (add-on  option  3)  can  bring 
positive impacts primarily with respect to the quality of public services. 

When it comes to the effectiveness of the options, hard law approaches accompanied by 
add-options are preferred in order to bolster interoperability, with a particular preference for 
option 3. Stakeholders responding to  both  types  of consultation  emphasised that a directive 
would provide targets  at different  levels  of maturity and thus  allow countries to  progress  in 
the  same  direction.  The  legal  framework  should  be  flexible  enough  to  account  for  local 
conditions and sector specificities. 

In terms of the efficiency of options, feedback is mixed depending on the type of the option. 
Participants to the targeted consultation generally noted that implementing a hard law might 
be  more  costly  for  Member  States.  At  the  same  time,  the  add-on  options  are  more  widely 
supported. 

The  core  options  1,  2  and  3  as  well  as  the  add-on  options  are  coherent  with  other  EU 
initiatives at least to some extent. In particular, the Data Governance Act could pave the way 
for  the  design  of  a  governance  mechanism  for  interoperability  and  enhanced  EU-level 
cooperation (option 2). In addition, the approach outlined in option 3 has complementarities 
with  the  INSPIRE Directive in  terms  of the  general  approach of  relying  on a directive  with 
requirements for interoperability.  

Finally,  the  feasibility  of  options  varies,  but  respondents  to  the  targeted  and  public 
consultations consider, on average, that the implementation of the options will be supported to 
some extent. Option 2 and 3 require a need for discussion and cooperation. Option 3 raises, in 
particular, potential burdens through the stricter focus on implementation which may in turn 
limit its feasibility. By contrast, a soft law through updated guidance (Option 1) approach may 
encounter more limited resistance. 

75 

 
Figure  21.  Impacts  of  the  different  Policy  Options  (breakdown  by  type  of  consultation; 
average score and number of respondents) 

Score: (-2) very negative; (-1) negative; (1) positive; or (2) very positive.  
Source: Study supporting the impact assessment for a future interoperability strategy. 

76 

 
 
Stakeholders  from  different  stakeholder  groups  in  the  public  and  targeted  consultations 
estimated the impacts quite differently. Stakeholders from companies and businesses saw the 
highest  negative  impacts  of  staying  with  the  status  quo.  Stakeholders  from  EU  public 
administrations  associated  the  highest  positive  impacts  with  policy  option  3  of  introducing 
new  interoperability  minimum  requirements.  In  the  consultations  also  national  public 
administrations  gave  the  highest  rating  for  option  3.  The  co-design  process  with  the  Expert 
Group however showed more support for the option 2. 

Figure  22.  Impact  of  option  0  (baseline)  on…  (breakdown  by  group  of  stakeholders; 
average score and number of respondents) 

Scale: (--) very negative; (-) negative; (0) neutral; (+) positive; or (++) very positive. 
Note: Averages do not account for respondents answering ‘don’t know/no opinion’ (DK/NO). 
Source: Study supporting the impact assessment for a future interoperability strategy 

77 

 
 
Figure  23.  Impact  of Option 1 on… (breakdown by group of stakeholders; average score 
and number of respondents) 

Scale: (--) very negative; (-) negative; (0) neutral; (+) positive; or (++) very positive. 
Note: Averages do not account for respondents answering ‘don’t know/no opinion’ (DK/NO). 
Source: Study supporting the impact assessment for a future interoperability strategy 

78 

 
 
Figure  24.  Impact  of  option  2  on…  (breakdown  by  group  of  stakeholders;  average  score 
and number of respondents) 

Scale: (--) very negative; (-) negative; (0) neutral; (+) positive; or (++) very positive. 
Note: Averages do not account for respondents answering ‘don’t know/no opinion’ (DK/NO). 
Source: Study supporting the impact assessment for a future interoperability strategy 

79 

 
 
Figure  25.  Impact  of  option  3  on…  (breakdown  by  group  of  stakeholders;  average  score 
and number of respondents) 

Scale: (--) very negative; (-) negative; (0) neutral; (+) positive; or (++) very positive. 
Note: Averages do not account for respondents answering ‘don’t know/no opinion’ (DK/NO). 
Source: Study supporting the impact assessment for a future interoperability strategy 

80 

 
 
 
Input of the Expert Group co-design process 

We  have  put  in  place  an  innovative  co-creation,  co-design  process  with  the  interoperability 
expert group162 with Member States that encourages open cooperation and transparency. This 
has  led  to  a  constant  increase  in  the  engagement  and  interaction  in  meetings.  Moving  all 
discussions online since more than 18 months now has also led to an increase in the number 
of participants. In physical meetings we would have had 1 or maximum 2 representatives per 
Member State for a maximum of 35 approximately, whereas online we regularly have more 
than  54  participants.  Workshops  and  roundtables  follow  design-thinking  methodologies  and 
participatory practices. We organised since mid-2020: five brainstorming sessions with more 
than  200  representatives  from  Member  States,  five  formal  expert  group  meetings  with  also 
more than 200 participants overall. Member States issued 18 position papers and we met them 
throughout the summer of 2021 in 26 bilaterals to discuss around the recommendations on the 
future policy. 

The  main  result  of  this  process  with  the  expert  group  are  the  recommendations  on  a  future 
interoperability policy (Annex VI). Other intermediate results can be interesting to understand 
the view of the stakeholders that are likely to be the most affected by the policy initiative. 

Figure 26. Co-design process with the Expert Group 

The co-design process with the expert group was structured around five work phases: 

  Position  papers  from  18  Member  States  –  CIOs  office  –  In  December  2020  the 
Commission kindly asked the members of the expert group to react on a short policy paper 
with  some  initial  ideas  for  the  next  interoperability  policy  (vision,  general  approach, 
policy  instruments,  etc.).  This  was  only  on  a  voluntary  basis,  however  two-third  of  the 
members  replied  positively  and  shared  position  papers  explaining  their  views  on  the 
upcoming policy and the proposed instruments; 

  Co-creation workshops – five informal discussion sessions took place between January 
and December 2021 (see the list below), involving around 40-45 members of EU national 
administrations  each  time.  The  working  methodology  was  based  on  design-thinking 
principles,  including  ‘diverge’  and  ‘converge’  working  phases,  and  participants  were 
sometimes  asked  to  fill  polls  (e.g.  see  below  a  poll  from  the  workshop  on  the  30th  of 
April).  These  meetings  were  moderated  using  Chatham  House  rules  (no  recording, 

162  

https://ec.europa.eu/transparency/expert-groups-register/screen/expert-
groups/consult?lang=en&groupID=3714 

81 

 
 
                                                           
participants do not formally engage their country), in order to foster interactions between 
people  and  ideation.  Several  working  papers  were  circulated  to  stabilize  ideas  along  the 
process and the subjects of these workshops helped build the structure of the draft policy 
recommendations  of  the  group  (see  point  d.).  All  papers  were  available  to  all  the 
participants and we encouraged transparent feedbacks directly on a Teams space. 

o  04/02/2021  -  General  debate  on  the  policy  approach  for  the  next  interoperability 

policy following the position papers (e.g. vision, priorities, etc.) 

o  14/04/2021  -  Communities  of  Practioners  (e.g. 

topics,  organisation  and 

composition, etc.)  

o  30/04/2021  -  Synergies  and  Funding  (e.g.  links  with  other  EU  digital  policies, 

financial support to Member States for interoperability implementation) 

o  20/05/2021  -  Digital  Checks  and  digital-ready  policy  (e.g.  experience  from 

Member States, replicability at the EU institutional level)  

o  10/06/2021  -  Governance  (e.g.  composition,  structure  and  mandate  of  a 

strengthened EU interoperability governance) 

Figure 27. Example of poll during the co-creation workshop on the 30th of April 2021 

82 

 
 
 
 
  Bilaterals – the Commission organised 26 bilateral calls with 26 Member States between 
July  and  September  2021  (only  one  country  did  not  reply  because  of  a  lack  of  internal 
resources  at  that  time).  Each  of  these  informal  discussions  lasted  between  45  and  120 
minutes. They were very rich in terms of content and feedback received, while helping the 
Commission  to  identify  points  of  tension,  test  ideas  with  the  Member  States  and  build 
mutual trust; 

  Policy recommendations – this is the main outcome of the expert group since its creation 
in February 2020. They were formally endorsed by consensus of the whole group on the 
5th of October 2021. The document includes 27 recommendations structured around three 
chapters, each of them reflecting the common ideas expressed by the Member States in the 
position papers, the co-creation workshops and the bilaterals: 

o  Chapter 1 - A strengthened governance 
o  Chapter 2 - Interoperability for better EU policies 
o  Chapter 3 - Upgrade EU interoperable solutions 

Those recommendations served as a basis to build the draft legal text and the two 
dedicated workshops; 

  Two workshops  on the legal draft –  They took  place in  October and  November 2021. 
The first  one  gathered around 40 external  participants who expressed their views on the 
legal concepts introduced by the Commission and discussed the composition and mandate 
of the future strengthened EU interoperability governance. Following the first workshop, 
the  Commission  circulated  a  first  draft  of  the  legal  text  with  the  members  of  the  expert 
group  and  organised  a  workshop  to  collect  preliminary  ideas  and  suggestions  to  be 
integrated  in  the  impact  assessment  and  the  upcoming  legal  proposal.  Member  States 
provided written feedback by the 3rd of December 2021. 

Main outcomes of the public workshop on legal draft – 28th of October, 2021  

Title: ‘Regulating public sector interoperability – How to?’ 

Registered participants: 50 from 20 different Member States 

Expert panel:  

1.  Joep Cromepvoets, professor  for  Information  management  in  the  Public  Sector  and 
senior  researcher  in:  e-Government,  Digital  Government,  Public  Sector  innovation, 
GIS, and Spatial Data Infrastructures at KU Leuven,  

2.  Laurence Diver, Postdoctoral legal researcher at the ’Counting as a Human Being in 
the  Era  of  Computational  Law’  project  at  the  Vrije  Universiteit  Brussel  and  co-
founder,  with  Mireille  Hildebrandt,  of  the  new  open-access Journal  of  Cross-
disciplinary Research in Computational Law (CRCL).  

3.  Sachiko  Muto, Chief  Executive  Officer  of OpenForum  Europe (OFE), a  Brussels-
based  think  tank  that  promotes  openness  in  ICT  and  a  level  playing  field  for  open 
source  software,  researching  at  TU  Delft  on  the  social  and  political  implications 
of technological change. 

4.  Arne Pilniok, Assistant  Professor  for  Public  Law,  Public  Administration  and  Legal 
legal  questions  of  digital  public 

Education  at Uni  Hamburg, researching  on 
administration in the European context. 

83 

 
 
 
Main outcomes of the discussion 

Between guiding implementation and influencing policy design  -  What  is  the EU right  to 
take action in the field? 

Legal basis single market Art. 114 TFEU or better Art. 172 TFEU? 

  case law confirmed Art. 172 TFEU as a legal basis 

 

for topic digital-ready policymaking: 

o 

 measures cannot restrict right of initiative of the Commission  

o  success depends on institutional commitment  

o  suggestion  for  an  updated  inter-institutional  agreement  on  better 

regulation 

 

for implementation support: 

o  right for action depends on the degree to which the initiative is binding and 

on the decision-making procedures suggested 

o  flexibility in decision making should be built in law 

What  kind  of  governance  for  public  sector  interoperability  is  needed  and  who  should  be 
involved?  

A.  Governance around interoperability of public services is the instrument to create to public 

value and not only for costs cutting 

  Governance  should  bring 
interoperability board,  

together MS  and  EU  ‘permanently’ 

in  sort  of 

  To  develop  solutions  a  multi-level  setup  is  needed  to  involve:  End-users,  private 

sector, regions and cities 

B.  Tech is not neutral! Interoperability should mean also ensuring legal protection by design 

of GovTech solutions 

 

 

requirements need to be assessed before taking policy decisions; 

running services need continuous governance; 

  GovTech cannot be steered by market instruments alone. 

What kind of issues need binding interoperability agreements and for whom?  

  With Tallinn, Berlin declaration far reaching commitments but no instruments to bind 

parties around the implementation. 

 

If  IT is  regulated with  binding - need flexible way to  change  ‘binding’ parts to  keep 
them future proof. 

  Anything binding needs to be open by default. 

What are issues that could profit from incentives in law?  

  Open-source communities show that cooperation around tech can be very fruitful – public 

sector to learn from it and link to it 

  Stability of cooperation depends also on availability of funding – incentives in EU funding 

to produce interoperability solutions and profit from the cooperation framework 

 

Incentives to cooperate on digital implementation of EU policies 

84 

 
  To consider the use benchmarking for monitoring 

A legal text can contribute to clarity of roles, co-ownership but actions beyond legal text 
needed – a cultural change, people willing to cooperate, skills, catalogues. 

Annex III. Who is affected and how? 

The benefits of the various policy options for citizens and businesses were estimated based on 
a  study163  of  the  European  Commission’s  Joint  Research  Centre  (JRC)  that  provides  an 
economic impact assessment of public sector interoperability in general. A sensitivity analysis 
was  applied  to  the  original  findings,  and  additional  calculations  (using  the  eGovernment 
Benchmark  reports  of  2021164  and  2022165)  were  used  to  estimate  the  share  of  cross-border 
interoperability. 

On  this  basis  the  preferred  policy  option  would  affect  the  following  stakeholders  in  the 
following ways: 

Citizens 

Citizens receive benefits from enhanced interoperability at the national level (when they need 
to  use  national  public  services)  and  at  the  cross-border  level  (e.g.  when  they  settle,  travel, 
study  in  another  Member  State)  as  interoperability  helps  reduce  barriers  for  citizens  to  act. 
The  use  of  digital  tools  will  not  require  significant  costs  of  investments  on  the  part  of  the 
citizens. 

We  have  considered  that  an  increase  in  interoperability  would  reduce  exclusively  the  time 
devoted by those individuals already using the internet to deal with the administration. We did 
exclude  the  effect  that  enhanced  interoperability,  due  to  improved  accessibility  and  service 
quality, might also motivate some individuals to engage with the administration online. 

Businesses and SMEs 

The businesses will be affected by the new initiative in a similar manner as the citizens. There 
are no specific costs that are foreseen for businesses – in order to make use of the digital tools, 
they need to possess a computer and to have access to the internet.  

Businesses interacting online with public administrations, will benefit from a reduction in the 
time spent on filling in administrative forms or from better availability of the information they 
seek (e.g. to start a business, VAT rules and rates, open a branch, finding partners, standards 
in Europe, providing services abroad, resolving disputes, access to finance, and exchanges for 
new entrepreneurs). Similarly, businesses and SMEs involved in cross-border transactions are 
expected to benefit directly from the improved interoperability of digital public services (e.g. 
multilingual  digital  public  services).  This  could  also  give  impetus  to  the  SMEs  to  engage 
more  in  cross-border  transactions  within  EU.  The  private  companies  who  provide  digital 
solutions  for  public  services  as  well  as  other  relevant  stakeholders  will  have  no  new 
obligations. They will benefit from new or increased opportunities, for example for publishing 
open-source solutions on a share and reuse platform that could be picked up to be certified by 
the governance as a recommended solution or by contributing to the work of a community in 
the new framework. 

Again, we have considered that an increase in interoperability would reduce exclusively the 
time devoted by those individuals already using the internet to deal with the administration. 

163  

164  
165  

Baseline  for  the  estimates  of  the  JRC:  ‘Quantifying  the  Benefits  of  Location  Interoperability  in  the 
European Union’ (2022). 
Data from the ‘eGovernment benchmark of 2021’. 
Data from the ‘eGovernment benchmark of 2022’. 

85 

 
                                                           
Public sector authorities 

Public  administrations  are  the  main  beneficiaries  of  improved  interoperability  measures,  as 
they  can  reduce  the  time  spent  resolving  customised  requests,  processing  the  same 
information  several  times  or  searching  for  data  through  more  centralised  systems  between 
national and cross-border public administrations. 

The implementation of the preferred policy option would have practical implications foremost 
for public sector bodies. There would be a general obligation to contribute to the Interoperable 
Europe  governance  body  and  to  assign  a  responsible  authority  in  the  Member  State.  They 
would have new obligations around transparency: for example, an obligation to reference all 
public  sector  IT  solutions  and  specifications  developed  throughout  the  Union  with  EU 
funding on a central platform, or to assess the possibility for reuse of common solutions. Most 
practical implications however translate into more opportunities to work together with public 
sector  bodies  from  other  Member  States  on  interoperable  solutions,  in  enhanced  legal 
certainty  around  topics  like  share  and  reuse  and  the  possibility  of  co-developing  innovative 
cross-border digital solutions.  

However, as previously explained (section 7.3 and developed in Annex IV) citizens and 
business  benefit  substantially  from  saved  hours  spent  to  deal  with  administrative 
obligations. 

Overview of cost savings – Preferred option 

Citizens/Consumers  

Businesses 

Administrations (total EU-27) 

One-off  Recurrent  One-off  Recurrent 

One-off 

Recurrent 

5.5 

5 742.7 

Action 
(a)  

Direct 
cost 
savings 
(EUR 
million) 

Indirect 
cost 
savings 
(EUR 
million 

Annex IV. Methodology 

This  annex  presents  the  methodology  employed  for  the  back-to-back  evaluation  and  impact 
assessment. It details the types of data collected and their  validation, the methods used, and 
the main limitations of the analysis. 

Overview of information and data sources 

In  the  Data  Collection  Phase,  a  mix  of  data  collection  methods  and  desk  research  was 
employed to gather both primary and secondary information and data, as follows: 

  Primary  information  and  data  were  collected  via  the  following  consultation 

activities: 

86 

 
 
 
 
 
 
 
 
 
 
 
 
o  Work  on  recommendations  with  the  Expert  Group  on  Public  Sector 

interoperability; 

o  Targeted in-depth interviews; 
o  Targeted online survey; 
o  Public consultation; 
o  feedback  received  on  the  Combined  EIF  Evaluation  Roadmap  and 

Inception Impact Assessment166. 

  Secondary information and data were collected by reviewing: 

o  The  Digital  Public  Administration  Factsheets,  developed  as  part  of  the  NIFO 

action and available on the Joinup platform167; 

o  The EIF Monitoring Mechanism168; 
o  Relevant literature; 
o  Official  EU-level  documents  such  as  communications,  regulations,  and 

directives; 

o  Official national-level documents such as national interoperability frameworks; 
o  Databases  including  Eurostat,  the  World  Bank  Worldwide  Governance 
Indicators and Doing Business report, and the Organisation for Economic Co-
operation and Development (OECD) Digital Infrastructure indicators; and 

o  The datasets related to the e-Government Benchmark reports169. 

The above-mentioned sources were complemented by expert assessments conducted by five 
independent  experts  who  were  part  of  the  Team  on  the  supporting  studies  conducted  by 
CEPS, in accordance with the Technical Proposal. The independent experts were tasked with 
completing  the  questionnaire  that  served  as  the  basis  for  the  in-depth  interviews  and  with 
providing additional expert input to support the evaluation and impact assessment. 
Several of the secondary data sources170 mentioned above were used by the JRC to quantity 
the general benefits of interoperability in the European Union, and to respectively estimate the 
proportion  of  these  benefits  that  can  be  attributed  to  cross-border  interoperability. 
Furthermore, to follow a conservative approach, a sensitivity analysis has been applied to the 
benefits for businesses. 

Primary data 

The  consultation  activities  were  launched  in  December  2020  (with  a  kick-off  workshop  to 
raise awareness on the evaluation process) and lasted until the end of April 2021 (marked by 
the end of the public consultation). The duration of each consultation activity was planned to 
ensure  that  stakeholders  had  enough  time  to  provide  their  inputs.  This  was  complemented 
with  a co-creation process  with  the Expert Group on interoperability of  public services (see 
Annex II). 

The  general  consultation  activities  resulted  in  a  total  of  134  responses  for  the  impact 
assessment  and  112  responses  for  the  EIF  evaluation,  which  can  be  divided  into  six 
stakeholder groups as presented in Table 10. The stakeholder categories were defined on the 

166  

167  

168  

169  
170  

The  feedback of stakeholders can be consulted at:  https://ec.europa.eu/info/law/better-regulation/have-
your-say/initiatives/12579-European-Interoperability-Framework-EIF-evaluation-and-EU-
governments-interoperability-strategy/feedback?p_id=9804060&page=1 
The  factsheets  can  be  consulted  on  Joinup:  https://joinup.ec.europa.eu/collection/nifo-national-
interoperability-framework-observatory/digital-public-administration-factsheets 
An 
EIF 
https://joinup.ec.europa.eu/collection/nifo-national-interoperability-framework-observatory/eif-
monitoring-mechanism 
The e-Government Benchmark datasets are available at: https://digital-agenda-ata.eu/datasets/e-gov 
Details  are  explained  in  the  JRC  report  ‘Quantifying  the  Benefits  of  Location  Interoperability  in  the 
European Union’ (2022), and as part of the methodology section (below). 

Mechanism 

Monitoring 

overview 

available 

the 

at: 

of 

is 

87 

 
                                                           
basis  of  the  assessment  of  relevant  stakeholders  conducted  in  the  inception  phase  and  by 
taking into account the need to ensure the comparability of results between the three strands 
of  the  consultation  activities:  in-depth  interviews,  online  survey,  and  public  consultation 
(considering in particular the mandatory template for background information used for public 
consultations). 

Table 10. Overview of responses to the consultation activities by stakeholder group for the 
impact assessment/evaluation 

Consultation 

Stakeholders  

Civil society (all other 
stakeholders) 

Companies and business 
associations 

EU and non-EU citizens 

EU public authorities 

Experts and academia 
(including the independent 
expert assessments) 

National public authorities 

TOTAL 

In-depth 
interview 

Online survey  Public 

TOTAL 

consultation 

1/- 

-/- 

-/- 

3/5 

6*/6* 

-/2 

10 

1/2 

5/3 

4/2 

10/8 

3/4 

8/7 

10/9 

13/14 

18/17 

31/18 

- 

5/4 

35/20 

13/13 

14/14 

27/25** 

16/12 

44/39 

50 

73 

134/112 

Note: x/y:x: Number of participants in impact assessment, y: number of participants for EIF evaluation. 
* In-depth interviews conducted with experts and academia include four independent expert assessments. 
**One follow-up interview to the targeted online survey was conducted.  
Source: Study supporting the impact assessment for a future interoperability strategy 

In  order  to  facilitate  the  comparison  of  stakeholders’  responses,  the  questionnaire  of  each 
consultation  activity  relied  on  Likert  scales.  Respondents  were  thus  asked  to  provide  their 
feedback  by  referring  to  a  scale  from  (1)  to  (5)  or  (--)  to  (++),  depending  on  the  type  of 
question:171  

1. 

2. 

(1) – not at all; (2) – to a limited extent; (3) – to some extent; (4) – to a great extent; or 
(5) – completely; 
(--) very negative; (-) negative; (0) neutral; (+) positive; or (++) very positive. 

The SWD presents the aggregate results of the consultation activities using bar charts showing 
the  average  scores  of  responses  from  each  stakeholder  group.  The  average  scores  do  not 
account  for  ‘don’t  know/no  opinion’  answers.  The  data  labels  of  the  bar  charts  display  the 
average score first, then the corresponding number of respondents in brackets.  

In order to assess the reliability of primary data, Figure 28 and Figure 29 provide an overview 
of the level of knowledge in the field of digital public services as well as the knowledge of the 
EIF  among  the  participants  who  contributed  to  the  consultation  activities.  Overall, 
stakeholders  reflect  a  high  level  of  knowledge,  strengthening  the  reliability  of  the  primary 
data collected. 

171  

For each question, the respondent also had the possibility to select the answer ‘don’t know/no opinion’. 

88 

 
                                                           
Table 11. Overview of the level of knowledge of respondents 

On average, respondents have a good level of knowledge in the field, noting they are 
familiar to a great extent with digital public services and interoperability. EU and non-EU 
citizens report a relatively lower level of knowledge, but even in this case, the respondents 
are familiar at least to some extent (3.50) with the field of digital public services and 
interoperability.  

Figure 28. Knowledge of digital public services and interoperability (breakdown by group 
of stakeholders; average score and number of respondents) 

Score: (1) not at all; (2) to a limited extent; (3) to some extent; (4) to a great extent; or (5) completely. Note: 
Averages do not account for respondents answering ‘don’t know/no opinion’ (DK/NO). 
Source: Study supporting the impact assessment for a future interoperability strategy 

Furthermore, respondents across almost all groups are, on average, familiar to a great extent 
with the EIF (see Figure 29). The only exception concerns respondents among EU and non-
EU citizens who have a relatively lower level of familiarity with the EIF, but they are still, 
on average, familiar to some extent with the EIF. 

Figure  29.  Knowledge  of  the  EIF  (breakdown  by  group  of  stakeholders;  average  score 
and number of respondents) 

Score: (1) not at all; (2) to a limited extent; (3) to some extent; (4) to a great extent; or (5) completely. 
Note: Averages do not account for respondents answering ‘don’t know/no opinion’ (DK/NO). 
Source: Study supporting the impact assessment for a future interoperability strategy 

89 

 
 
 
Secondary data 
The  impact  assessment  builds  on  the  evaluations  of  the  ISA²  programme  and  the  EIF172, 
which  were  conducted  simultaneously  with  the  impact  assessment  as  key  sources  to  assess 
achievements accrued so far in the field of public sector interoperability in the EU as well as 
lessons learnt. The estimations of the benefits primarily draws on previous work of the JRC 
and  sets  it  into  the  context  of  the  Interoperable  Europe  Act  by  applying  the  necessary 
additional calculations. 

The  EIF  Evaluation  relies  on  an  extensive  review  of  available  secondary  data.  One  of  the 
main  sources  of  data  is  the  National  Interoperability  Framework  Observatory  (NIFO) 
action  supported  by  the  ISA²  programme  and  its  outputs  that  are  available  in  the  Joinup 
collection with the same name173. The particular sources developed as part of NIFO and used 
as evidence feeding into the evaluation of the EIF include: 

  The  Digital  Public  Administration  Factsheets,  contributing  to  the  assessment  of  the 
effectiveness  of  the  EIF  by  providing  an  overview  of  the  development  of  national 
interoperability frameworks or similar strategies174; 

  The  2020  Report  on  the  State-of-Play  of  Digital  Public  Administrations  and 
Interoperability, detailing the progress made by the EU Member States in enhancing the 
provision  of  digital  and  interoperable  public  services  (the  report  also  covers  nine 
additional  countries:  Iceland,  Liechtenstein,  Norway,  Switzerland,  the  United  Kingdom, 
Ukraine,  Montenegro,  Turkey  and  the  Republic  of  North  Macedonia)175;  this  Report 
contributes to the assessment of the effectiveness and coherence of the EIF by providing 
an  overview  of  key  developments  across  the  EU  and  the  level  of  implementation  of  the 
EIF; 

  The  2019  EIF  Monitoring  Mechanism,  tracking  the  implementation  of  the  EIF  and  its 
principles, model and recommendations across the EU, thus contributing to the assessment 
of the effectiveness of the EIF176; 

  Other  reports  and  documents  developed  as  part  of  NIFO  and  available  on  Joinup, 
including  the  Report  on  Public  Administrations’  Digital  Response  to  Covid-19  in  the 
EU177, contributing in particular to assessing the relevance of the EIF. 
  The webpages of ISA² actions and the ISA² Rolling Work Programmes. 

172  

173  

174  

175  

176  

177  

CEPS  (2021),  Study  supporting  the  final  evaluation  of  the  ISA2  programme.  Available  at: 
https://op.europa.eu/en/publication-detail/-/publication/afa4297a-0acc-11ec-adb1-
01aa75ed71a1/language-en/format-PDF/source-229005953 
CEPS  (2021),  Study  supporting  the  evaluation  of  the  implementation  of  the  EIF.  Available  at 
https://op.europa.eu/en/publication-detail/-/publication/29d694d4-4696-11ec-89db-
01aa75ed71a1/language-en/format-PDF/source-search 
For  further  details  please  see:  National  Interoperability  Framework  Observatory,  Knowledge  Centre, 
available  on  Joinup:  https://joinup.ec.europa.eu/collection/nifo-national-interoperability-framework-
observatory/knowledge-centre 
The  factsheets  can  be  consulted  on  Joinup:  https://joinup.ec.europa.eu/collection/nifo-national-
interoperability-framework-observatory/digital-public-administration-factsheets 
Bouhend,  A.,  et  al.  (2020),  ‘Report  on  the  State-of-Play  of  Digital  Public  Administrations  and 
Interoperability’, 
at: 
https://joinup.ec.europa.eu/sites/default/files/news/2020-10/SC263_D04.02_State-of-
play%20report%20on%20digital%20public%20administration%20and%20interoperability%202020_v
FINAL.pdf 
The  underlying  data  was  shared  with  the  Study  Team  by  DIGIT.D2  to  facilitate  the  analysis.  An 
overview of the EIF Monitoring Mechanism is available at:  https://joinup.ec.europa.eu/collection/nifo-
national-interoperability-framework-observatory/eif-monitoring-mechanism 
Charay  et.  al.  (2021),  Report  on  Public  Administrations’  Digital  Response  to  COVID-19  in  the  EU, 
Publications 
at: 
Available 
https://joinup.ec.europa.eu/collection/nifo/report-state-play-digital-public-administration-and-
interoperability 

Commission. 

Available 

European 

European 

Union. 

Office 

the 

of 

90 

 
                                                           
Official  documents  such  as  communications,  regulations,  directives  and  decisions  were 
reviewed contributing in particular to the assessment of the coherence and EU added value of 
the  EIF.  In  addition,  official  national-level  documents  such  as  national  interoperability 
frameworks were also  reviewed, primarily  as part  of the analysis of the effectiveness  of the 
EIF, while also contributing to understanding the EU added value of the framework. For the 
impact assessment these data sources contributed across the study, from depicting the policy 
context to comparing the policy options considered for this impact assessment. 

In  building  the  evidence  base,  the  relevant  literature  in  the  field  of  interoperability  was 
reviewed and considered throughout the evaluation process. The key insights from literature 
contribute  particularly  to  the  assessment  of  the  relevance  of  the  EIF  and  for  the  impact 
assessment particular the existing problems in the field of public sector interoperability. 

Relevant indicators measuring digitalisation in the public sector were considered from a 
variety  of  databases,  namely:  Eurostat,  the  World  Bank  Worldwide  Governance  Indicators 
and  Doing  Business  report,  and  the  Organisation  for  Economic  Co-operation  and 
Development (OECD) Digital Infrastructure indicators. In addition, the datasets related to the 
e-Government  Benchmark  reports178  were  used,  contributing  in  particular  to  (i)  the 
assessment  of  the  effectiveness  and  efficiency  of  the  EIF;  (ii)  for  the  impact  assessment  - 
contributing  in  particular  to  quantifying  the  existing  problems  and  the  assessment  of  the 
potential  impacts  stemming  from  the  policy  options  considered  for  this  impact  assessment; 
and  (iii)  for  the  estimation  of  the  benefits  of  cross-border  interoperability  for  citizens  and 
businesses. 

Data validation 

To  ensure  the  robustness  of  evidence,  the  collected  data  were  validated  via  triangulation. 
Tool  #4  of  the  Better  Regulation  Toolbox  on  evidence-based  better  regulation  defines 
triangulation  as  ‘the  application  and  combination  of  several  research  methodologies  in  the 
study  of  the  same  phenomenon’179.  Validation  requires  checking  ‘whether  the  findings  of  a 
study  are  true  and  certain:  ‘true’  in  the  sense  that  research  findings  accurately  reflect  the 
situation;  and  ‘certain’  in  the sense that research findings are supported  by evidence’180. To 
ensure  that  the  findings  are  supported  by  well-founded  evidence,  data  were  collected  from 
multiple sources and using different tools to analyse the evaluation criteria and questions. 
This approach allows for increasing confidence in collected data, comparing and contrasting 
findings, and providing a clearer understanding of the issues at stake. The analysis relies on 
three different types of triangulation to provide a solid basis for drawing robust conclusions: 

  Triangulation  of  data,  relying  throughout  the  impact  assessment  on  data  collected 
from multiple sources and stakeholders. 
  Triangulation  of  methods,  based  on  data  collected  via  at  least  two  different  data 
collection  methods  (e.g.,  interview,  targeted  questionnaire,  public  consultation,  desk 
research). 
  Triangulation of evaluators. Several members of the Core Study Team and Support 
Team  were  involved  in  data  collection  activities;  in  addition,  each  element  of  the 
impact assessment was addressed by at least two members of the Core Team. Hence, 
conclusions were agreed upon by at least two researchers. 

178  
179  

180  

Regulation 

The e-Government Benchmark datasets are available at: https://digital-agenda-ata.eu/datasets/e-gov  
Tool 
Better 
https://ec.europa.eu/info/sites/default/files/file_import/better-regulation-toolbox-4_en_0.pdf 
Triangulation:  Establishing  the  Validity  of  Qualitative  Studies,  Lisa  A.  Guion,  David  C.  Diehl,  and 
Debra McDonald, 2011. 

Evidence-based 

regulation, 

Toolbox 

(2017), 

better 

#4 

91 

 
                                                           
Methods 

The evaluation  and impact  assessment  combines  both  quantitative and qualitative data, thus 
relying  on  a  variety  of  methods  and  tools  to  analyse  the  collected  data.  In  particular,  the 
qualitative  information  was  aggregated,  compared  and  summarised  to  substantiate  the 
evidence  feeding  into  evaluation  and  impact  assessment.  To  analyse  the  findings  from  the 
consultation activities, the Study Team employed descriptive statistics. To complement these 
methods,  other  specific  quantitative  methods  were  used  to  evaluate  the  effectiveness, 
efficiency and coherence of the framework: 
Cost-benefit analysis (CBA)181  

CBA  is  a  method  of  comparing  the  costs  and  benefits  associated  with  a  certain  initiative, 
typically a government policy, programme or project, in order to assess whether the initiative 
is expected to bring about a net improvement. A key feature of CBA is that all costs and all 
benefits are quantified and expressed in monetary terms, and are adjusted for the ‘time value 
of money’ (through some discounting mechanism), so that all benefits and costs that occur at 
different points in time are expressed on a common basis in terms of their ‘present value’. The 
main limitations of CBA concern the difficulties in attributing a monetary value to items for 
which  no  market  exists  and  the  fact  that  certain  non-monetisable  effects  simply  cannot  be 
taken into consideration. CBA was used to assess of the potential impacts stemming from the 
proposed policy options. 
The standard cost model (SCM)182  

SCM  aims  at  assessing  administrative  costs  imposed  by  rules  or  policies  inter  alia  on 
businesses  and  public  administrations.  It  is  based  on  the  identification  of  the  basic 
components  of  a  rule,  the  Information  Obligations,  whose  costs  for  the  addressees  can  be 
measured  and quantified. An  Information Obligation is  a specific duty to gather, process  or 
submit information to the public authority or a third party. The SCM is employed to measure 
the costs borne in terms of days spent by national public administrations to transpose the EIF 
into national frameworks as well as the costs that would be borne by public administrations 
when implementing the proposed policy options. 
The Multi-criteria analysis (MCA)183  

MCA is a technique for comparing and ranking different courses of action that yield multiple 
outcomes expressed in different units of accounts (i.e. some are expressed in monetary terms, 
others in physical units of different nature, e.g. number of lives saved and quality of gaseous 
emissions). In some respects, it can be said that MCA goes one step further than CBA, as it 
gives  explicit  recognition  to  the  fact  that  a  variety  of  both  monetary  and  non-monetary 
objectives  (i.e.  social,  environmental,  technical,  economic,  and  financial)  may  influence 
policy decisions. At the same time, this kind of analysis inevitably includes a higher degree of 
subjectivity  compared  to  CBA,  especially  regarding  the  weighting  and  ranking  of  different 
criteria.  Therefore,  unlike  CBA,  a  basic  feature  of  MCA  is  its  implementation  through 
participatory processes, involving policymakers, experts (e.g. through Delphi panel method), 

181  

182  

183  

(2017),  Tool  #59  Methods 

to  assess  costs  and  benefits, 

Better  Regulation  Toolbox 
https://ec.europa.eu/info/sites/default/files/file_import/better-regulation-toolbox-59_en_0.pdf 
European Commission (2017), ‘Tool #60. The standard cost model for estimating administrative costs’, 
in 
the  Better  Regulation  ‘Toolbox’,  available  at  https://ec.europa.eu/info/sites/info/files/better-
regulation-toolbox_2.pdf;  SCM  Network  (2005),  ‘The  International  SCM  Manual;  Measuring  and 
at: 
Reducing 
http://www.administrativeburdens.com/filesystem/2005/11/international_scm_manual_final_178.doc 
For an excellent review, please see Department for Communities and Local Government, Multi-criteria 
analysis: a manual, London, January 2009. 

Administrative 

Businesses’, 

available 

Burdens 

for 

92 

 
                                                           
stakeholders, etc. This method was employed to compare the proposed policy options based 
on their effectiveness, efficiency, coherence and feasibility. 

Text mining  

Text  mining  is  a  technique  referring  to  a  set  of  data-processing  operations  that  extract 
knowledge according to a criterion of novelty or similarity in texts. In practice, this technique 
is  based  on  an  algorithm  that  counts  the  number  of  times  a  specific  reference  is  made  in  a 
given  text  corpus.  In  this  evaluation,  text  mining  is  used  to  evaluate  the  degree  of  external 
coherence  of  the  EIF,  together  with  its  principles,  interoperability  layers  and  conceptual 
model. In particular, this approach allows checking, throughout the corpus of EU legislation 
and Commission communications, the extent to which the EIF and its components are taken 
into  consideration  by  other  EU  initiatives  in  the  field  of  interoperability  that  were  adopted 
since the first version of the EIF (2004). 

This analysis can be done in two steps: 

  Searching  through  the  corpus  of  EU  legislation  and  Commission  communications 
since the adoption of the first version of the EIF (2004) to obtain an overview of the 
number of times the EIF and keywords related to the EIF are mentioned in official EU 
documents; 

  Taking  a  more  in-depth  look  at  a  selection  of  relevant  official  documents  and 
conducting  a  more  granular  analysis  to  understand  which  elements  of  the  EIF  are 
referenced. 

While  the  first  approach  provides  a  quantifiable  overview  of  the  references  to  the  EIF  in 
different pieces of legislation and  communications over time, the second approach provides 
more insights into the take-up of the EIF and its specific elements. 

To quantify the number of mentions of the EIF and keywords related to the EIF in pieces of 
EU  legislation,  the  Study  Team  relied  on  an  extensive  dataset,  the  ‘CEPS  EurLex  dataset’, 
customised to facilitate text mining184. The dataset contains 142,036 pieces of EU legislation 
adopted between January 1952 and August 2019, representing almost the entire corpus of the 
digitally available EU legal acts from this timeframe. The dataset covers three types of legally 
binding  acts  adopted  by  the  EU  institutions:  regulations,  directives,  decisions,  and 
implementing and delegated acts. When it comes to quantifying the number of references to 
the EIF and keywords related to the EIF in Commission communications, the analysis was run 
for  documents  including  green  and  white  papers,  communications,  reports  (categorised  as 
‘DC’  on  EurLex)185.  Importantly,  the  analysis  excluded  self-references  to  the  EIF 
Communications. 

The datasets were used to search for specific keywords in the timeframe 2004 (the year of the 
adoption of the first EIF) to August 2019. In addition, to cover the period from August 2019 
and  April  2021,  the  EurLex  website  was  used.  The  keywords,  selected  based  on  their 
connection to the EIF and the extent to which they would be expected to yield results in a text 
mining exercise, were grouped into three clusters as follows186: 

  Cluster 1: European Interoperability Framework. This cluster refers exclusively to the 
EIF  and contains  three keywords:  ‘European  Interoperability Framework’, ‘EIF’  and 
‘interoperability framework’; 

184  

185  

186  

Borrett, Camille; Laurer, Moritz, 2020, ‘The CEPS EurLex dataset: 142,036 EU laws from 1952-2019 
with full text and 22 variables’, https://doi.org/10.7910/DVN/0EGYWY, Harvard Dataverse. 
Hradec,  Jiri,  2021,  the  database  is  part  of  the  ‘Trends  in  Global  Governance  and  Europe’s  Role’ 
(TRIGGER) project. 
An additional keyword, ‘conceptual model’ (related to the EIF conceptual model for integrated public 
services provision), was dropped from the analysis as it did not yield results related to the EIF. 

93 

 
                                                           
  Cluster  2:  Interoperability  layers.  This  cluster  gathers  together  the  following 
keywords:  ‘semantic  interoperability’,  ‘technical  interoperability’,  ‘organisational 
interoperability’ and ‘legal interoperability’; 

  Cluster 3: Key interoperability concepts. This cluster contains the following keywords: 
‘once-only’  (keyword  related  to  the  ‘once-only’  principle),  ‘digital  by  default’, 
‘privacy  by  design’,  ‘user-centricity’,  ‘re-use  of  data’,  ‘interoperability  principle’, 
‘interoperable e-Government service’. 

The datasets of EU legislation and communications were searched for the keywords, resulting 
in  a  list  of  pieces  of  legislation  and  communications  where  the  keywords  were  found.  The 
results were thus summarised by year and number of mentions per cluster of keywords. 

Calculating the economic impact of cross-border interoperability 

The  original  2022  JRC  report  provides  an  economic  impact  assessment  of  public  sector 
interoperability in general. This work distinguishes the impact of improved interoperability on 
citizens,  on  businesses,  and  on  the  public  sector.  Results  are  provided  as  time  savings  in 
hours,  and  also  in  monetary  terms  (i.e.  translated  into  annual  savings  in  EUR).  These 
calculations do take country differences into account and are based on statistics from sources 
such  as  Eurostat,  OECD,  the  Worldbank  and  others.  It  is  one  of  the  most  comprehensive 
analyses  of  interoperability  benefits  in  Europe  available. The  report  itself187  provides  the 
necessary details.  

To estimate the benefits that can attributed to cross-border interoperability (the scope of the 
Interoperable Europe Act), the eGovernment benchmark of 2021 and 2022 provides valuable 
information  that  compares  how  governments  across  Europe  deliver  digital  public  services. 
This information includes a list of public sector services provided by the governments. These 
services  (i)  can  be  provided  by  local,  regional  or  national  authorities,  (ii)  can  be  provided 
offline  and  online,  (iii)  can  cover  services  for  both  citizens  and  companies,  and  (iv)  are 
comparable across all Member States since the methodology for data collection is the same. 

Using this source, it becomes possible to collected information about all services covered by 
the different Member States. On this basis, it is possible to extract all those services that are 
provided  online,  and  that  are  available  cross-border.  The  graph  below  illustrates  the 
proportion  of  public  services  included  in  the  eGovernment  benchmark  that  are  provided 
online and cross-border – for both businesses and citizens. As it can be seen, for the EU-27 
countries,  the  averages  are  21%  for  businesses  and  12%  for  citizens,  although  with  large 
variations across the different Member States. 

187  

JRC ‘Quantifying the Benefits of Location Interoperability in the European Union’ (2022). 

94 

 
                                                           
Figure 30. Proportion of public services included in the eGovernment benchmark that are 
provided online and cross-border – for both businesses and citizens and per country (in %) 

Assuming that these two lists of services are representative of the widest portfolio of public 
services  offered by the different  Member States,  it is  possible to  calculate the proportion of 
public services that may be subject to the impacts of enhanced interoperability as envisaged in 
the  Interoperable  Europe  Act.  In  this  way,  the  actual  scope  of  the  proposed  regulation  is 
addressed as close as possible. 

The  fact  that  a  service  is  available  cross-border  and  online  does  not  assure  that  it  is  used. 
Hence,  there  is  a  need  to  correct  the  intensity  of  use  in  order  to  accurately  estimate  the 
expected  impacts.  For  this  purpose,  the  eGovernment  benchmark  offers  an  extensive  list  of 
websites that users can visit to perform the desired administrative procedures. After removing 
duplicates  and  errors,  a  list  of  1608  public  sector  websites  in  the  27  EU  Member  States 
remain. For these websites, it is possible to obtain information about the geographic origin of 
the internet traffic to these websites188. This data (illustrated in the figure below) provides the 
proportion of visits to the public services websites that have an origin in a different country 
from  the  one  that  provides  the  service.  And  this  is  a  measure  of  cross-border  usage  of  the 
offered services. The EU-27 country average is 12%, meaning that the proportion of domestic 
users of a public service is 88% while the usage from foreign users (from another EU Member 
States) is 12% on average. Again, with imbalances among Member States. It is worth noticing 
that the number of visits is a good approach for user’s usage because concrete visits reflect the 
‘attention’ generated by the visited services. Visits are a good proxy for actual online service 
usage,  in  the  absence  of  more  precise  indicators,  such  as  conversion  rates.  Moreover,  the 
applied methodology used ‘real visits’, i.e., visits that imply that users spend some time on the 
respective  website.  All  bounced  visits,  i.e.  visits  for  cases  where  the  user  left  the  webpage 
shortly after entering it, were removed. 

188  

The Similarweb tool provided the required calculations: https://www.similarweb.com/ 

95 

 
  
 
 
 
                                                           
Figure 31. The proportion of visits to the public services websites that have an origin in a 
different country from the one that provides the service 

Combining the information from  the JRC study  with  the new data collected to  perform this 
exercise  it  is  possible  to  estimate  the  economic  impacts  of  increased  cross-border 
interoperability  in  the  EU-27  countries,  i.e.  to  simulate  the  potential  effects  of  the  IEA. 
Taking into account the proportion of cross-border services, as well as the cross-border usage 
of  these  services, the  impact  that  would  correspond  to  the  IEA  would  represent,  on  average 
for the EU-27 countries, the 3% of the total impact of no interoperability for businesses and 
2%  for  citizens  with  differences  by  Member  States,  as  shown  in  the  next  figure.  These 
proportions, when converted to economic impact, provide the figures shown above. 

Figure  32.  The  total  impact  of  no  interoperability  for  businesses  and  for  citizens,  per 
Member State 

To reach those figures, the following formulas have been applied: 

𝑐 = 𝐻𝑖
𝐼ℎ

𝑐 ∗ 𝛼𝑐 ∗ 𝛽𝑐 

96 

 
  
 
 
 
 
𝑐 represents the impact in terms of hours saved (h) in country c as calculated in the 
Where 𝐼ℎ
𝑐 is the number of hours estimated in the JRC report for scenario i189, 𝛼𝑐 is the 
JRC report, 𝐻𝑖
proportion  of  public  services  included  in  the  eGovernment  benchmark  that  are  provided 
online and cross-border and 𝛽𝑐 is the measure of cross-border usage of the offered services. 
The calculation of the impact in terms of hours saved can be done for citizens and businesses. 
The transformation of the impact in hours in an economic impact, is done by multiplying the 
number  of  hours  by  its  price,  the  hourly  wage  rate  by  country  (𝜔𝑐),  as  indicated  in  the 
following equation: 

𝑐 = 𝐼ℎ
𝐼€

𝑐 ∗ 𝜔𝑐 

Finally, to get the total impact at the EU-27 level, we sum the impacts over all the Member 
States: 

27

𝑐
𝐸𝑈 = ∑ 𝐼€
𝐼€

𝑐=1

A similar expression can be used to compute the EU-27 impact in number of hours saved. 

Given  the  available  evidence,  the  expected  impact  on  citizens  and  businesses  calculated  for 
the  Impact  Assessment  of  the  Interoperable  Europe  Act  and  for  policy  option  2,  can  be 
expressed in a static scenario (scenario 1) and a dynamic scenario (scenario 2) as depicted in 
the  table  below.  In  the  dynamic  scenario,  we  assume  that  increased  interoperability  affects 
user  behaviour,  whereas  we  do  not  do  so  in  the  static  one.  Moreover,  given  the  limitations 
explained below, we have performed a sensitivity analysis. This resulted in five variants: 30% 
(as  the  high  variant,  corresponding  to  the  original  numbers  used  in  the  JRC  report),  25%, 
20%, 15% (for the intermediate variants) and 10% (for the low variant). 

Table 12. Policy option 2 savings 

Policy option 2: Savings 

Business 

Citi
zens 

Scenario 1 

Scenario 2 

Mh 
EUR 
million 
Mh 
EUR 
million 

Low 

273.3 

Intermediate
-low 

Intermediate 

Intermediate
-high 

High 

379.2 

523.3 

674.9 

812.6  0.22 

5 742.7 

8 114.6 

11 343.4 

14 852.6  17 553.2 

5.5 

297.8 

413.9 

570.3 

738.1 

888.1  0.26 

6 259.5 

8 865.2 

12 352.8 

15 948.6  19 190.7 

6.3 

In summary, this impact assessment estimates annual cost savings of policy option 2 between 
5.5 million Euros and 6.3 million Euros for citizen, and between 5.7 billion Euros (in a static 

189  

There  are  several  scenarios,  one  static  in  which  interoperability  only  reduces  the  number  of  hours 
required  to  deal  with  the  administration,  while  the  dynamic  scenario  also  implies  that  the  number  of 
citizens  and/or  businesses  using  online  tools  to  access  public  services.  In  addition,  in  the  case  of 
businesses, a sensitivity analysis takes into account the intensity of usage of these tools. 

97 

 
 
 
 
 
 
 
 
 
                                                           
scenario  with  the  lowest  proportion  of  time  saved)  and  19.2  billion  Euros  (in  a  dynamic 
scenario with a large volume of time saved) for businesses. 

Main limitations 

The mix of primary data and information, obtained through consultation activities, and 
secondary data and information, mainly obtained through desk research, was crucial in 
allowing to draw conclusions and, more importantly, to provide estimates of costs and 
benefits. Nevertheless, the following limitations may affect the main findings: 

1.  The scarcity and difficult comparison of data for assessing the costs and benefits 
of  transposing  the  EIF  into  national  frameworks.  The  voluntary  nature  of  the 
framework reflects a heterogeneous uptake of the framework across the EU, limiting 
the availability of data and making the comparison between countries difficult, as the 
framework is adopted on an ad hoc basis. Furthermore, the implementation of the EIF 
has  not  followed  the  same  timeline  in  the  different  countries.  To  overcome  this 
limitation, the Study Team contacted the national public authorities that responded to 
the consultation activities and indicated their availability to participate in a follow-up 
interview in  order to  gain  insight  on the time spent  (in terms  of person-days) on the 
transposition of the EIF, or part of it, into their national framework. 

2.  Starting  with  the  JRC  report,  the  calculations  of  the  benefits  of  the  Interoperable 
Europe  Act  are  based  on  a  series  of  assumptions  (for  the  JRC  report  they  are 
extensively listed in the original report). Assumptions are necessary when actual data 
is  not  available  but  they  can  lead  to  imperfect  results190.  To  give  one  example,  the 
figures reported in the JRC report for the time spent by businesses in dealing with the 
administration is subject to assumptions and uncertainties, all explained in the original 
report. Due to a lack of reliable data, a sensitivity analysis was performed to account 
for the level of uncertainty here. 

3.  The overarching scope of the EIF hinders the assessment of the direct costs and 
benefits  stemming  from  its  implementation.  Costs  and  benefits  deriving  from  the 
EIF do not just pertain to the implementation of the framework, as costs and benefits 
depend on the levels of digitalisation of the Member States or on the different degrees 
of  centralisation  and  varying  organisational  structures  involved  in  delivering  public 
services. The costs related to interoperability initiatives are borne at different levels of 
administration in several countries. 

4.  The conclusions drawn in the  Impact  Assessment  are built  upon the EIF  Evaluation, 
which  evaluates  the  latest  implementation  of  the  EIF  (i.e.  from  2017  to  2020). 
However, the framework seeks to achieve overarching goals and impacts that require 
time to show results. 

Another limitation may be the potential ‘consultation fatigue’ of respondents. In particular, 
this Impact Assessment was carried out in a context in which the feedback of stakeholders 
may have been sought for several relevant developments: the end of the ISA² programme, the 
roll-out of the new Digital Europe Programme, the 2030 Digital Compass and the new policy 
initiatives related to digitalisation in the EU. 

Annex V. Recommendations of the Expert group on interoperability of public services 

Introduction 

Europe  has  set  the  goal  of  100%  key  digital  public  services  by  2030.  All  enabled  by  a 
strengthened  digital  sovereignty  and  interoperability  that  foster  innovation  in  line  with  EU 

190  

Activities  available  online  and  used,  cannot  be  fully  referred  to  the  administrative  activities–  for 
example some enforcement activities are also included. 

98 

 
                                                           
core values and standards. This is one of the four pillars helping to deliver Europe’s Digital 
Decade for 2030. 

It  means  that  the  pace  of  implementation  and  delivery  of  digital  public  services  needs  to 
increase. The level of digital maturity of Europe’s public services needs to increase.  

Europe’s  public  sector  spends  12.4%  of  GDP  (around  EUR  1  trillion  per  year)  on  the 
purchase  of  services,  works  and  supplies.  Digitalising  Europe’s  public  sector  digitalises 
Europe. 

Cooperation at EU level is a must to deliver on this goal. We have seen that very clearly with 
the  COVID-19  pandemic:  European  solidarity  and  cooperation  have  helped  us  navigate  a 
crisis of unprecedented scale and magnitude. But to deliver on our goals and help build better 
digital public services for Europe more of this cooperation is needed.  

Member States are under a lot of pressure to implement European policies that have an impact 
on their digital transformation on top of their own national priorities. At central levels there 
are  the  Single  Digital  Gateway  Regulation,  the  Open  Data  Directive,  the  NIS  directive, 
GDPR, the upcoming revised eIDAS regulation or the Data Act, just to name a few. There are 
also the numerous sectoral initiatives: e.g. digitalisation of justice, e-Customs, revised TEN-E 
regulation, digital health and many more. 

Interoperability of solutions, data, and services is not only key for a sound implementation of 
the above-mentioned policies, but it will also help to reduce efforts and costs. It helps build 
resilient digital  public administrations that can deliver public services that span borders  and 
sectors  across  the  EU,  allow  us  to  share  data  and  stay  connected.  This  calls  for  a  paradigm 
change in how citizens, public administrations and democratic institutions interact. To make 
this become a reality we need a clear strategy focused on enabling delivery on the ground and 
a proper governance at European level that makes it possible to align and coordinate efforts of 
this scale. 

Purpose and scope of these policy recommendations 

The  European  Commission  has  announced  in  the  2020  communication  Shaping’s  Europe’s 
Digital Future a ‘strengthened interoperability strategy’. This is the opportunity to rethink the 
voluntary efforts of the past 20 plus years on interoperability and establish a more structured 
and  pragmatic  cooperation  both  between  Member  States  at  a  horizontal  level  and  between 
different European services and policies at a vertical level. We need an interoperability policy 
that  is  focused  on  enabling  smooth,  interoperable  implementation  and  delivery  of  digital 
public services at European level without adding new obligations on Member States and that 
helps increase our overall digital maturity. 

The expert group on Interoperability of European public services was set up in February 2020 
with  members  representing  the  national  public  administrations  of  the  European  Member 
States and observers from EFTA and candidate countries. One of its roles is to provide advice 
and expertise to the Commission in relation to the preparation of the legislative proposals and 
policy initiatives. 

The following policy recommendations are expressed by the Member States to the European 
Commission. They will be one of the cornerstones for the upcoming European Commission 
policy proposal on the next interoperability policy and will accompany the impact assessment 
of policy options and evaluation of the European Interoperability Framework. 

The  recommendations  have  been  co-designed  and  co-created  by  the  members  of  the  expert 
group on Interoperability throughout a series of brainstorming sessions, workshops, bilateral 
discussions with the European Commission and written contributions spanning almost a year. 

99 

 
We share a common vision for the next interoperability policy 

We need a visionary and at the same time pragmatic approach to interoperability policy, that 
builds  on  all  the  work  done  in  the  past  20  years  and  takes  a  bolder  stance  on  European 
Interoperability.  We  want  to  enable  a  structured  cooperation  focused  on  delivery  of  cross-
borders and cross-sectors European digital public services.  

The  members  of  the  Interoperability  expert  group  recommend  a  new  interoperability  policy 
to: 

  Establish  a  shared  governance  of  interoperability  with  a  stronger,  structured 

involvement of the Member States  

  Deepen  the  synergies  with  other  ongoing  EU  policies  and  funding  programmes 

(particularly those with an impact on the digitalisation of the public sector)  
Identify common specifications and encourage their uptake 
Include more operational and pragmatic actions  

 
 
  Focus on more exchange of best practices between Member States  
  Better promote, via external communication and awareness raising, the achievements 

and benefits of interoperability work by the Member States and the EU. 

  Engage with sectoral areas and policies. 

To  translate  this  vision  into  concrete  actions,  we  call  on  the  European  Commission  to 
implement the following policy recommendations.  

Chapter I: Reinforce the European cooperation on interoperability 

In this chapter, we focus on the core aspect of a reinforced European interoperability policy: 
create  a  structured  cooperation  with  a  comprehensive  governance 
the 
implementation of interoperability in the Member States.  

to  support 

Governance  is  one  of  the  aspects  that  can  trigger  the  best  virtuous  effects  and  where  quick 
progress  is  the  most  needed.  It  will  help  increase  the  level  of  digital  maturity  of  the  public 
sector  in  the  EU  and  ensure  a  cohesive  digital  delivery  across  organisational  boundaries, 
cross-borders and cross-sectors.  

To  do  so,  we  articulate  our  proposal  around  three  topics:  (A)  Establish  a  shared  strategic 
governance  with  a  clear  mandate,  (B)  supported  by  communities  of  Member  States’ 
practitioners and (C) reinforce innovation and international cooperation. 

A.  Establish a shared strategic EU Interoperability Governance 

Recommendation n°1: Establish a common EU Interoperability Governance that will have a 
legal mandate to set the priorities at EU level and steer the implementation of interoperability 
actions. This governance structure will act in full respect of subsidiarity and proportionality, 
while  supporting  Member  States 
implementation  efforts  and  encouraging 
coordination  and  exchange.  Depending  on  the  specific  objective,  decisions  from  the 
governance  structure  should  be  adopted  in  the  appropriate  voting  system  (e.g.  consensus, 
qualified  majority).  They  may  be  non-binding  (e.g.  guidelines,  opinions)  or  binding  (e.g. 
European Interoperability Framework updates). 

their 

in 

Recommendation n°2: This EU Interoperability Governance should have a clear, simple and 
effective governance. We recommend to structure it into two layers: a ‘strategic layer’, co-led 
by  the  Member  States  governments’  leaders  of  digital  transformation  with  the  support  the 
European  Commission,  and  an  ‘operational  layer’  of  thematic  subgroups,  communities  of 
practice (see recommendations 4, 5, 6) supporting the work of the strategic layer. 

Recommendation  n°3:  The  mandate  of  the  EU  Interoperability  Governance  should  at  least 
cover the following tasks: 

100 

 
  Foster synergies with any existing or new EU policy initiatives that have an impact 
on  interoperability  of  European  digital  public  services  (e.g.  Data  Governance  Act, 
Digital  Decade) by giving recommendations on interoperability impact  of EU policy 
initiatives (see Recommendations 10, 11, 12); 

  Oversee  the  evolution  of  the  European  Interoperability  Framework  as  a  clear 
reference  for  related  cross-cutting  and  sectorial  policies  in  the  EU,  decide  on  the 
evolution of its principles and recommendations, and provide for a regular monitoring 
of progress across Member States (see Recommendations 13, 14, 15); 
Improve the coherence between the different EU data policies that impact the public 
sector (see Recommendation 18, 19, 20), for instance by liaising with EU governance 
bodies  with  a  broader  scope  (e.g.  Data  Innovation  Board,  Digital  Decade 
governance) to avoid duplication of work; 

 

  Help build a catalogue of interoperability solutions and update it based on Member 

States’ needs (see Recommendations 21, 22, 23); 

  Promote  Open  Culture,  Open-Source  Software  and  Open  Standards  in  European 

public administrations (see Recommendations 24, 25); 

  Ensure that adequate funding is provided at EU level to deliver better interoperability 

solutions (see Recommendation 26, 27, 28); 

  Reinforce  innovation,  GovTech  and  experimentation  cooperation  amongst  Member 
States  and  associated  countries,  both  at  national  and  local  levels  but  also 
internationally (see Recommendations 7, 8, 9); 

  Provide guidance to the European Commission on joint reporting of Member States’ 
interoperability  implementation  progress,  aligned  with  all  relevant  reporting  tools 
(e.g. OECD, UN, Digital Decade, etc.), monitoring (see Recommendations 16, 17). 

B.   Supported by communities of Member States’ practitioners 

A  strategic  governance  alone  cannot  do  much:  interoperability  implementation  requires 
the  involvement  of  practitioners  from  all  levels  and  sectors  of  EU  public  administrations 
that  have  hands-on  expertise  and  can  help  build  consensus  on  solutions  and  technical 
specifications. This should form the ‘operational layer’ of the EU Interoperability Governance 
in  a way that  is  consistent, efficient  and based on the actual needs and practices of the EU, 
Member States, regions and local communities. 

Recommendation  n°4:  Communities  of  Practice  shall  be  the  operational  layer  of  the  EU 
Interoperability Governance. They can take the form of a temporary Working Group and 
they must have a clear mandate, a defined list of problems to solve, a deadline and expected 
outcomes.  They  are  assisted  by  the  secretariat  (European  Commission)  which  ensures 
alignment with the work of the strategic layer of the governance and with the policy initiatives 
at EU level. They can include voluntary experts from academia, private sector, civil society, 
all administrative levels (e.g. local, regional, national) or other domains as needed depending 
on the subject. 

Recommendation n°5: the strategic EU Interoperability Governance can set-up a Community 
on  practical  issues  related  to,  at  least,  one  of  the  four  EIF  layers  (legal,  organisational, 
semantic and technical) and relevant for the implementation of EU level services (e.g. Data 
Spaces), while: 

  Ensuring  that  there  is  no  overlap  with  existing  or  new  created  communities/bodies 
dealing with similar topics (e.g. between the Single Digital Gateway Regulation, Data 
Governance Act, eGovernment Action Plan, ICT standards, Living-in.eu, etc.); 

  Bringing together the relevant experts in their domains (e.g. from the GovTech sector, 
academia,  NGOs,  civil  society)  to  define  technical  solutions  that  are  interoperable. 
This  involves  working  closely  also  with  private  partners;  local  entities  (e.g.  involve 

101 

 
regions,  municipalities),  EU  standardisation  and  other  international  organisations 
(OECD,  UN,  international  standardisation  bodies,  etc.)  as  well  as  citizens’ 
representatives depending on the subjects to be handled. 

Recommendation  n°6:  These  communities  can  develop  cross-border 
interoperability 
initiatives,  proofs  of  concept,  pilots  (e.g.  technical  guidance,  specifications,  prototypes, 
applications, etc.). Initiatives that reach a certain level of maturity and have a large support 
can  be  included  in  the  Interoperability  catalogue  by  the  strategic  level  of  the  EU 
Interoperability  Governance.  In  any  case,  we  reaffirm  that  it  is  very  important  to  critically 
evaluate  whether  a  specific  standard  or  specification  is  relevant  and  applicable  for  a 
specific use case before making it mandatory. 

C.   Reinforce innovation and international cooperation 

Public sector innovation has now a strong focus on digital technologies as enablers (e.g. AI, 
blockchain). The pandemic has only accelerated and reinforced the need to rapidly innovate 
and emphasized further the inequalities in preparedness of the public administrations.  For this 
reason there is an urgency to ensure in the EU context that digital innovation can be replicated 
between  the  front-runners  and  laggards,  allowing  leapfrogging  for  some  of  them.  This  goes 
with  a  number  of  activities  such  as  exchange  of  best  practices,  experimentation  and  close 
cooperation, including the private (GovTech) sector.  

Digitalisation  issues  (including  interoperability)  are  global  by  nature,  especially  since  the 
pandemic  -  and  they  are  nurtured  by  innovation  and  international  cooperation  with  other 
countries,  international  organisations  like  the  United  Nations,  CAF  (Development  Bank  of 
Latin America), the World Bank or the OECD, but also with private actors and civil society. 
The EU and its MS should take a coordinated approach towards contributing to these diverse 
fora to ensure consistency and promote the EU public values of digital public services. 

Recommendation n°7: A future interoperability policy should facilitate early alignment with 
the  European  standardisation  efforts  and  cooperation  with  international  standardisation 
organisations to ensure that EU public sector’s needs for standards are taken into account in 
an effective way. 

Recommendation  n°8:  Provide  opportunities 
cooperation  on 
interoperability, outreach, partnerships, exchanges, with relevant international organisations 
and  partners  to  increase  usefulness  of  international  interoperability  and  complement  our 
digital sovereignty. 

international 

for 

Recommendation  n°9:  Provide  means  to  allow  exchange  of  best  practices,  such  as  the 
Innovative  public  Services  Observatory  to  promote  sharing  and  reuse  and  ensure 
interoperability  by  default.  Provide  for  Open  Source,  GovTech  and  experimentation 
cooperation  amongst  Member  States  and  associated  countries,  both  at  national  and  local 
levels  but  also  internationally.  Ensure  multiplication  through  other  channels  and  financing 
programmes (EIC, Horizon Europe, International Cooperation). 

Chapter II: Make the most of interoperability for better EU policies 

A stronger governance on interoperability is not enough on its own: we must ensure that the 
policies  and  European  legislation  we  implement  for  our  citizens  and  businesses  are 
interoperable and digital-ready ‘by default’.  

Interoperability  and  (digital)  implementation  of  policies  are  too  rarely  considered  as  a  high 
priority  in  the  European  policy-design  process,  even  though  it  can  bring  better  coherence 
across  sectors,  help  save  time  and  public  money,  while  increasing  the  legal  robustness  of 
legislative acts and making it easier for policymakers to reuse data. 

102 

 
We reaffirm the call from the Berlin Declaration:  

  To  ensure  through  the  Better  Regulation  framework  that  policies  and  legislative  acts 
proposed by the European Commission are digital-ready and interoperable by default  

  To  strengthen  Europe’s  digital  sovereignty  and 

interoperability  by  fostering 
interoperability  ‘by  design’  of  policies  to  enhance  cross-border  and  cross-sector 
interconnections  

Therefore, the next interoperability policy should improve the policy-design at EU level (A) 
and  leverage  on  a  more  pragmatic  European  Interoperability  Framework  (B)  to  ensure 
coherence and better support implementation by the Member States, especially when it comes 
to data-related policies (C). 

A.  Introduce new mandatory checks to ensure that EU policies are ‘digital-ready’ and 

interoperable ‘by-default’ 

Public  administrations  are  bound  by  a  specific  legal  context.  The  design  of  such  legal 
provisions  influences  how  technical  solutions  can  be  deployed  across  different  public 
administrations that should be interoperable and allow secure and controlled data flows. The 
vision  of  an  interoperable  public  sector  can  only  become  a  reality  if  legal  provisions  are 
digital-ready.  

An increasing number of Member States are developing – or plan to develop – guidelines and 
mandatory  checks  to  ensure  that  new  legislation  is  fit  for  the  Digital  Age.  Because  their 
decisions impact hundreds of millions of citizens and businesses, the EU Institutions should 
also lead by example and incorporate such checks as early as possible in the decision-making 
process. 

Therefore,  recommendations  10,  11  and  12  are  mostly  oriented  towards  the  European 
Commission and the modernization of its legal processes, while ensuring proper support and 
advice-sharing from the Member States. 

Recommendation n°10: Introduce mandatory but lightweight ‘digital checks’ along all steps 
of EU policymaking (European Commission, Council and European Parliament) and across 
policies.  This  should  align  with  the  Better  Regulation  agenda.  Among  others,  such  checks 
should  direct  policymakers’  attention  towards  user-centric  implementation,  best  (re)use  of 
public  data,  coherence  with  digital  policies  and  upcoming  data  initiatives  (e.g.  Digital 
Decade/Compass,  Data  Act  or  other  sectorial  policies),  and  the  reuse  of  existing  technical 
and semantic specifications and interoperable solutions. 

Recommendation n°11: The EU Interoperability Governance and the European Commission 
should  create  guidelines  for  such  digital  checks  (e.g.  expected  outcome,  life  cycle, 
monitoring, etc.). They should establish a clearly defined process, which ensures that: 

  The digital checks are conducted as early as possible in the policy design; 
  Member  States’  interoperability  experts  are  timely  consulted  on  EU  policy  proposals 

with significant digital impacts; 

  The  outcome  of  the  digital  checks  is  transparent  and  being  fed  into  the  inter-

institutional decision-making. 

Recommendation n°12:  Establish a community of practice on  ‘digital-ready’ policymaking 
that  provides  user-friendly  guidelines,  tools  and  best  practice  examples  and  that  gives 
advice to  national,  local and EU policymakers. This  community of  practice should support 
the implementation of Recommendation 10. 

103 

 
 
 
B.  Reinforce the European Interoperability Framework 

The EIF is the cornerstone of EU interoperability action and it must remain an effective guide 
for  implementation  in  the  EU,  Member  States  and  at  local  levels.  Due  to  its  non-technical 
approach, the EIF has proven to be a useful instrument to raise awareness on interoperability 
beyond technical audiences. However, the EIF in its current state is not frequently referenced 
in EU policies. Public administrations across the EU could all benefit from a reinforced EIF 
that  is  more  closely  linked  to  EU  sectorial  policies  and  provides  more  pragmatic  and 
operational guidance.  

Recommendation  n°13:  Make  the  EIF  a  clear  reference  for  related  cross-cutting  and 
sectorial policies in the EU to ensure a holistic approach to interoperability. 

Recommendation  n°14:  Work  on  operationalising  the  EIF  to  make  it  simpler  to  implement 
especially in highly decentralized countries.  

Recommendation n°15: Empower the EU Interoperability Governance to:  

  Assess the implementation of both, principles and recommendations of the EIF in the 
technical  specifications 

including  solutions,  standards  and 

Member  States, 
implemented in the context of the EIF; 

  Update the framework – both  principles  and recommendations  – based  on progress 
made  and  take  into  account  the  evolution  of  practices  (e.g.  move  from  an  approach 
focusing on digital service delivery to a focus on public sector data flows); 

  Promote  the  reuse  and  take-up  of  relevant  interoperability  solutions,  standards  and 
specifications for the implementation of relevant EU policies and share best practices 
and examples of implementation at different levels (e.g. national, local, international).  

Recommendation  n°16:  Establish  a  more  automated  monitoring  mechanism  for  the 
implementation of the EIF and ensure data collected is reused by all Commission services 
following  the  ‘once  only  principle’  (e.g.  reuse  between  the  Digital  Decade,  eGovernment 
benchmark,  NIFO,  Berlin  Declaration  monitoring,  etc.).  Reuse  relevant  information  and 
reporting  on  digital  government  progress  collected  by  other  international  organisations 
(OECD, UN). 

Recommendation n°17: Encourage a culture of  ‘interoperable by design’ by including more 
information on the digital maturity of the public sector in Europe in the annual digital public 
administration factsheets. 

C.  Improve the coherence between EU interoperability, digital and data policies, ensure 

availability of operational capacities at the EU level 

The upcoming reinforced EU interoperability policy is the opportunity to bring more support 
for  the  evolving  EU  data  policy  landscape,  to  facilitate  building,  operation  and  inter-
connection of data spaces.  

Recommendation n°18: Provide guidance on interoperability of data through: 

  The  creation,  maintenance  and  promotion  of  technical  specifications  on  semantic 
interoperability  to  facilitate  the  sharing  and  re-use  of  data,  taking  into  account  EU 
values and diversity; 

  Supporting data use and experimentation, in particular cross sector and cross border, 

by liaising with relevant data governance bodies.  

A  fully  interoperable  Europe  can  only  be  achieved  with  the  political  willingness  and  the 
operational  capacity  to  execute  it.  This  needs  a  well-designed  organisational  set-up  that 
fosters  cooperation  and  coordination  across  sectors  and  across  borders.  Therefore,  a 
reinforced  governance  structure  must  be  supported  by  the  European  Commission  with 

104 

 
dedicated multidisciplinary teams and the adequate resources to support Member States in the 
implementation of interoperability. 

Recommendation  n°19:  The  European  Commission  services  should  reduce  internal  friction 
and improve the way they cooperate on the design and implementation of policies that have 
an impact on digital transformation of the public sector.  

Recommendation  n°20:  The  European  Commission  services  responsible  for  public  sector 
interoperability should guarantee an effective support of the EU Interoperability Governance. 

Chapter III: Upgrade the current EU interoperable solutions offering 

The  European  Commission  has  been  providing  interoperability  solutions  and  technical 
specifications for over twenty years, under the CEF-Digital and ISA² programmes (and their 
predecessors). While these products have brought added value to the Member States, we call 
on  the  European  Commission  to  improve  the  governance  and  offer  of  EU  interoperability 
solutions  and  technical  specifications.  Member  States  should  be  more  closely  involved  in 
planning and priority setting for solutions developed at the EU level (e.g. co-decide on which 
former ‘building block’ or ISA² solution should be adapted, improved or removed, etc.). 

Three actions are proposed to foster the development and uptake of interoperability solutions: 
set  up  a  catalogue  of  key  interoperability  solutions  and  open  standards  (A),  support  the 
development  of  an  open  source  ecosystem  for  the  public  sector  (B)  and  provide  adequate 
funding to deliver better interoperability solutions (C). 

A.   Enrich the EU catalogue of interoperability solutions and open standards 

EU  public  administrations  need  a  federalised,  one-stop-shop  of  interoperable  solutions, 
technical specifications and open standards, where they could easily find free-to-use products 
provided  by  European  public  administrations  or  other  stakeholders.  Such  a  catalogue  could 
help EU public administrations save time and resources. 

The  European  Commission  has  been  developing  such  a  catalogue,  however  it  is  not 
systematically used by public administrations and its content should be enriched. 

Recommendation  n°21:  Encourage  EU  and  non-EU  public  administrations  to  consult,  use 
and actively participate in  the JoinUp platform.  Participating  in these communities will  not 
only benefit the administrations, but also other re-users like companies and citizens. 

Recommendation  n°22:  The  European  Commission  should  foster  the  transformation  of  this 
catalogue 
the  EU  Interoperability 
Governance. Its content should be based on: 

into  a  federalised  one-stop-shop  managed  by 

(a)  A  systematic  collection  of  Member  States’,  agencies’  and  local  administrations’ 
assessments, to keep the catalogue up to date with actual needs  

(b)  A  thorough  process  (e.g.  proportion  of  reusability  in  a  minimum  of  Member  States, 
Open Source, sustainability, ‘future-proofness’, security, privacy etc.). 

B.   Make the best use of Open Source products for the common good 
A  recent  study  showed  that  Open  Source  Software  and  infrastructure  are  key  for  the  digital 
transformation  of  the  public  sector  and  can  be  a  major  boost  to  the  EU’s  GDP.  A  future 
interoperability  policy  should  be  the  occasion  to  support  open  source  functions  in  public 
administrations,  the  use  of  open  source  products  to  provide  public  value  and  foster  the 
participation of EU public administration in the open source communities. 

Recommendation n°23: Better support Open Source Software as a means to foster EU digital 
for  example  by  encouraging 
sovereignty  and  prevent  vendor 

lock-in  situations, 

105 

 
administrations to actively participate in existing international communities working on open 
source projects and open specifications; 

Recommendation n°24: Provide a catalogue of Open Source solutions for the public sector. 
Such catalogue should be integrated in the catalogue of interoperability solutions and open 
standards. 

C.  Provide adequate funding to deliver better interoperability solutions 

IT solutions are often developed based on the ad-hoc needs of the requesting sector but would 
benefit from a shared commitment across countries or sector. The EU should look into ways 
to  ensure  funding  for  interoperability  solutions  by  creating  more  incentives  to  ensure 
interoperability when spending public money for the purpose of digital transformation of the 
public sector. 

Existing EU funding opportunities for interoperability projects are not always aligned and are 
complex for Member States to navigate. 

Recommendation  n°25:  Mandate  the  EU  Interoperability  Governance  to  issue  opinions  on 
funding  priorities  (e.g.  for  Digital  Europe  Programme,  building  on  former  ISA²  committee 
practice). 

Recommendation  n°26:  Publish  regular  guidance  on  the  relevant  European  funding 
available to promote interoperability in the scope of the digital transformation of European 
public administrations. 

Recommendation  n°27:  Ensure  that  EU  funding  for  the  digital  transformation  of  public 
sector is guaranteed to produce solutions that are interoperable by default. 

Annex VI Political and policy context 

Table 13. Overview relevant political statements of the last years 

EC Council Conclusions 

European  Council 
conclusions 
of 
October 
2021 
(EUCO 17/21) 

Policy Objectives 
and Priorities for 
2020-2024 (2021/C 
18 I/02) 

the  value  of  data 

In  October  2021  the  European  Council  stressed  the  importance  of 
‘unlocking 
through  a 
comprehensive regulatory  framework that is  conducive to  innovation 
and  facilitates  better  data  portability,  fair  access  to  data  and  ensures 
interoperability’ 

in  Europe,  notably 

‘The  COVID-19  crisis  has  accelerated  hyper-connectivity  and  the 
integration  of  new  technologies  that  shape  the  way  we  live  and 
transform how we learn, work, socialise and consume. The crisis also 
exposed  the  vulnerabilities  Europe  is  facing  -  ranging  from  cyber 
security to capacity issues and insufficient broadband infrastructure in 
many regions. To bolster our place in the global economy and defend 
our  values,  we  will  shape  our  own  digital  solutions  and  establish 
Europe’s  digital 
focus 
simultaneously on access to and protection of data, the development 
of innovative technology and upgrading our infrastructure.’ 

sovereignty.  Our  efforts  need 

to 

‘Shaping Europe’s 
digital future’ 9 June 
2020 (8711/20) 

‘A  swift  and  comprehensive  digital 
transformation  of  public 
administrations at all levels is an essential element of the digitalised 
Single Market and the crisis recovery strategy and a driving force 
for  new  and  innovative  technological  solutions  for  public  services 

106 

 
and societal challenges.’ 

The  Council  calls  on  the  Commission  ‘to  ensure  coordination  and 
support for the digital transformation of public administrations in 
all  EU  Member  States,  including  interoperability  and  common 
standards for secure and borderless public sector data flows and 
services.’ 

The  COVID-19  pandemic  has  further  exposed  the  vulnerabilities  of 
our  societies  and  the  potential  for  damage  from  large-scale  cyber 
incidents  to  the  economy,  democracy,  essential  services  and  critical 
infrastructure, most notably in the health sector. It has also increased 
the importance of connectivity and society’s dependence on reliable, 
trustworthy and secure network and information systems 

Exploring the 
potential of the Joint 
Cyber Unit initiative 
- complementing the 
EU Coordinated 
Response to Large-
Scale Cybersecurity 
Incidents and Crises 
of 10 October 2021 
(12534/21)  

European Parliament 

European Parliament 
resolution of 18 
December 2019 on 
enabling the digital 
transformation of 
health and care in 
the Digital Single 
Market; empowering 
citizens and building 
a healthier society 
(2019/2804(RSP)) 

 ‘whereas,  owing  to  the  lack  of  interoperability  and  market 
fragmentation across health systems, citizens cannot yet fully benefit 
from the digital single market;’ 

instruments,  such  as 

20.  Calls  on  Member  States’  health  authorities  to  make  use  of  EU 
financing 
the  European  Structural  and 
Investment  Funds  and  the  European  Fund  for  Strategic  Investments, 
for  the  deployment  of  interoperable  electronic  health  records  at 
national and regional level, which will enable citizens to access their 
personal  health  data,  and  for  investment  in  building  solid  and  more 
reliable  infrastructure  which  supports  the  digital  transformation,  and 
helps to reduce the digital divide between all Member States; 

31.  Is  of  the  opinion  that  ensuring  a  fit-for-purpose  regulatory 
environment  is  a  key  element  in  protecting  public  health  and 
providing access to high quality medicines; is also of the opinion that 
the  effective  use  of  IT  systems  will  improve  regulatory  efficiency 
across  Europe;  urges  the  Commission,  therefore,  to  optimise  the 
framework  by  harmonising  regulatory 
European 
telematics  projects  with  a  focus  on  data  quality,  interoperability 
and the interdependency of the European regulatory framework; 

regulatory 

European Parliament 
resolution of 25 
March 2021 on a 
European strategy 
for data 
(2020/2217(INI)). 

the  most 

‘C.  whereas  the  EU  requires  the  availability  of  interoperable, 
flexible,  scalable  and  reliable  IT  architecture  that  is  capable  of 
supporting 
innovative  applications;  whereas  artificial 
intelligence  (AI)  is  one  of  the  strategic  technologies  for  the  21st 
century, both globally and in Europe; whereas adequate infrastructure 
is also required in the EU, notably high-performance hardware to run 
applications and store data; 

J. whereas cloud markets (i.e. Infrastructure, Platform and Software as 
a Service – IaaS, PaaS and SaaS) are characterised by a high degree of 
market  concentration,  which  may  put  start-ups,  SMEs  and  other 

107 

 
European  actors  at  a  competitive  disadvantage  in  the  data  economy; 
whereas the Commission should ensure competitive markets through 
interoperability,  portability  and  open  infrastructures,  and  remain 
vigilant  about  any  potential  abuses  of  market  power  by  dominant 
actors; 

2. Notes that the COVID-19 crisis has highlighted the role of and need 
for high-quality, real-time databases, information and data sharing, as 
well as shortcomings in the infrastructure and interoperability of 
solutions  across  Member  States;  stresses  the  impact  of  the  digital 
transformation and the availability of a wide range of technologies on 
the Union’s economy and society; 

3. Underlines that future data legislation must be designed to facilitate 
technological  development,  innovation,  data  access,  interoperability 
and  cross-border  data  portability;  urges  the  Commission,  in  this 
respect,  to  carry  out  an  evaluation  and  mapping  of  the  existing 
legislation  in  order  to  assess  what  adjustments  and  additional 
requirements are needed to support the data society and economy 
and  safeguard  fair  competition  and  legal  clarity  for  all  the 
relevant actors;  calls for the  Union to  be a leader in  establishing  an 
international framework for data, while respecting international rules; 

13. Stresses that the increasing volume, development, sharing, storage 
and processing of industrial and public data in the Union is a source 
of sustainable growth and innovation that should be tapped into, 
in  compliance  with  Union  and  Member  States’  laws  such  as  data 
protection,  competition  law  and  IPR;  notes  that  data  is  becoming 
increasingly valued by the market; believes that economic growth can 
be secured by ensuring a level playing field and a competitive, multi-
player and fair market economy, while ensuring interoperability and 
access  to  data  for  actors  of  all  sizes,  in  order  to  counter  the  market 
imbalances;’ 

‘1. Believes the EU’s digital policy should create and support the key 
foundations needed for the European public and private sectors to be 
world  leaders  in  trustworthy,  human-centric  digital  innovation; 
considers that the digital single market is one such foundation and is 
about  ensuring  the  full  potential  of  new  technologies  by  removing 
legal  clarity  for 
unjustified  national  barriers,  by  establishing 
consumers  and  businesses,  benefiting  for  European  citizens  and 
strengthening competition; believes that having a better organised and 
common European approach for market integration and harmonisation 
can contribute to that result; believes that further actions are needed at 
both Member State and EU level to achieve this; 

9.  Highlights  that  the  Commission  should  adopt  a  balanced,  future 
proofed  and  evidence  based  approach  to  legislation  based  on  the 
subsidiarity principle that  creates  a digital  single  market  that ensures 
the  provision  of  public  services,  is  competitive,  fair,  accessible, 
consumer-friendly, 
technologically  neutral, 
human-centric  and  trustworthy,  and  that  builds  a  secure  data  society 
and economy; 

innovation-friendly, 

108 

European Parliament 
resolution of 20 May 
2021 on shaping the 
digital future of 
Europe: removing 
barriers to the 
functioning of the 
digital single market 
and improving the 
use of AI for 
European consumers 
(2020/2216(INI)) 

 
European Parliament 
resolution of 10 June 
2021 on the EU’s 
Cybersecurity 
Strategy for the 
Digital Decade 
(2021/2568(RSP)) 

College decisions: 

A European strategy 
for data. COM(2020) 
66 final, 

14.  Calls  on  the  Commission  to  aim  at  both  an  innovation  and 
consumer friendly regulatory environment, strengthening the financial 
and  institutional  support  for  the  European  digital  economy  in  close 
coordination with  Member States and stakeholders through measures 
such as: investing in education, research and development, supporting 
innovations  in  Europe,  providing  increased  and  broader  access  to 
easily readable and interoperable high quality industrial and public 
data’ 

‘6.  Considers  that  digitalisation  of  our  society  means  that  all  sectors 
are  interconnected  and  the  weaknesses  in  one  sector  can  hamper 
others;  insists,  therefore,  that  cyber-security  policies  be  incorporated 
into the EU digital strategy and EU funding, and that they be coherent 
and interoperable across sectors’ 

‘Data interoperability and quality: Data interoperability and quality, as 
well  as  their  structure,  authenticity  and  integrity  are  key  for  the 
exploitation  of  the  data  value,  especially  in  the  context  of  AI 
deployment.  Data  producers  and  users  have  identified  significant 
interoperability  issues  which  impede  the  combination  of  data  from 
different  sources  within  sectors,  and  even  more  so  between  sectors. 
The application  of  standard  and  shared  compatible  formats  and 
protocols for gathering and processing data from different sources in a 
coherent and interoperable manner across sectors and vertical markets 
should  be  encouraged 
ICT 
standardisation and  (as  regards  public  services)  a  strengthened 
European Interoperability Framework. 

rolling  plan 

through 

the 

for 

 ‘2030 Digital 
Compass: the 
European way for 
the Digital Decade’, 
COM/2021/118 final 

European  businesses  often  experience  problems  with  multi-cloud 
interoperability, in particular data portability. 

framework  will  –  where  appropriate  –  be 
The  horizontal 
complemented  by  sectoral  legislation  for  data  access  and  use,  and 
mechanisms for ensuring interoperability. ‘  

The European Commission has set the goal of 100% key digital public 
services by 2030 as one of the four pillars helping to deliver Europe’s 
Digital  Decade.  The  Communication  points  out 
that  digital 
transformation enables modern public services but also acknowledges 
that:  ‘the gap  to  reach  this  vision  is  still  significant.  Despite  the 
increasing use of public services online, services provided digitally are 
often basic e.g. filling in forms. Europe must harness digitalisation to 
drive  a  paradigm  change  in  how  citizens,  public  administrations  and 
democratic  institutions  interact,  ensuring  interoperability  across  all 
levels of government and across public services.’ 

Ministerial Declarations 

2020 Berlin 

‘Digital  sovereignty  and  interoperability’  is  one  of  the  7  principles 

109 

 
 
Declaration on 
‘Digital Society and 
Value-Based Digital 
Government’, 

guiding  digital  transformation  endorsed  by  all  Member  States,  the 
Commission has been called to: ‘continue coordinating cross-border 
interoperability  and  strengthen  the  European  interoperability 
framework’. 

EU Ministerial 
Declaration of 
Digital Day 2021: 
Green and Digital 
Transformation of 
the EU Ministerial 
Declaration  

‘Specifically, we will engage and work together to:  

  Make  high  quality  data  available  and  accessible 

through 
standardised and interoperable common European data spaces to 
unleash  the  potential  from  data  on  realising  the  European  Green 
Deal; 

  Promote  the  use  of  a  digital  twin  in  the  form  of  a  Building 
Logbook  for  new  public  buildings;  as  well  as  work  with  local 
authorities  and  other  relevant  stakeholders  to  set  up  a  European 
network of digital twins of the physical environment; Support EU 
cities and regions  to use green digital  solutions  in their transition 
to climate neutrality;’ 

Others 

COTER-VII/005 
142nd 
session, 
February 
OPINION 
Border 
Services in Europe  

plenary 
3-4 
2021 
Cross-
Public 

  underlines  the  need  for  an  EU  legal  framework  to  allow  for  an 
efficient  establishment  and  management  of  cross-border  public 
services  which  would  address  the  needs  of  our  citizens  living  in 
border regions 

  calls on the European Commission, as the institution in charge of 
monitoring  the  implementation  of  EU  legislation,  and  more 
importantly  the  Member  States  and  regions  with  legislative 
powers,  to  coordinate  the  transposition  of  directives  with  the 
neighbouring states and regions, so that new legal barriers do not 
arise as a consequence of a lack of coordination;  

  points out that impact assessments can provide an excellent insight 
into the effects of EU legislation and calls on the EC to establish 
methodologies that would allow for effective cross-border impact 
assessments; 

  points out that e-services might open a very interesting field of 
development for the cross-border provision of public services. 
For example, by using automated translation interface, one of the 
first  obstacles  for  CBC  in  general,  and  the  provision  of  public 
services across borders in particular, the language barrier, could be 
overcame.  An  increased  use  of  e-procedures  will  lead  to  a 
necessary  harmonisation  of  administrative  provisions,  solving 
another good set of obstacles. Also, the development of Artificial 
Intelligence-based systems, could promote further European-wide 
provision of services; 

History of Interoperability Policy 

The  European  Commission  has  identified  the  need  for  interoperability  between  public 
administrations  already  back  in  1994  and  has  since  then  supported  programmes  to  develop, 
promote  and  use  interoperability  solutions  in  the  EU  for  the  use  of  public  administrations, 
businesses and citizens.  

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The history of financing programmes supporting interoperability at EU level  

  1995  –  1997:  Community  contribution  for  telematics  interchange  of  Data  between 

Administrations (IDA);  

  1999 – 2004: Second phase of the IDA programme (IDA II) 

 

 2005  –  2009:  Interoperable  Delivery  of  Pan-European  eGovernment  Services  to 
public Administrations, Business and Citizens (IDABC),  

  2010 – 2015: Interoperability Solutions for European Public Administrations (ISA) 

  2016 – 2020: Interoperability solutions and common frameworks for European public 

administrations, businesses and citizens (ISA²) 

In  2004 
Interoperability Framework for Pan-European eGovernment Services.  

the  Commission  published  under 

the  IDABC  Programme 

the  European 

In  2010  it  adopted  a  Commission  Communication  entitled  ‘Towards  interoperability  for 
European public services’191 containing in annex the European interoperability strategy (EIS) 
and the European interoperability framework (EIF). Since then, the European interoperability 
framework has served as a reference throughout the Union and beyond and was the basis of 
most national interoperability frameworks (NIFs) and strategies. 

In the context of the Communication on a Digital Single Market Strategy put forward by the 
Juncker Commission in 2015192, the interoperability agenda needed to be revised and brought 
into  line  with  the  emerging  challenges  in  the  field  of  ICT  and  the  provision  of  European 
public services. European Interoperability Policy has been a prominent element of the 2016-
2020  European  eGovernment  Action  Plan193.  Interoperability  was  one  of  its  underlying 
principles  and  the  plan  contained  a  dedicated  action  to  ‘propose  a  revised  European 
Interoperability Framework (EIF) ... support its take-up by national administrations with the 
aim to strengthen the interoperability of public services in the EU’, for the period 2016-2019. 
This led the Commission to publish an updated EIF in 2017194. 

The  new  EIF  expanded  on  the  previous  version  from  2004  adopted  by  the  PEGSCO 
committee  of  the  IDABC  programme195  and  of  the  2010  communication  adopted  by  the 
Commission196  and  brought  more  targeted  recommendations  taking  into  account  new 
technological  and  policy  developments.  The  number  of  recommendations  in  the  new  EIF 
increased  from  25  to  47  and  several  recommendations  were  updated  or  newly  developed  to 
support relevant EU policies and initiatives, such as the Directive on re-use of Public Sector 
Information197  (subsequently  revised  and  renamed  as  the  Open  Data  Directive  in  2019),  the 
INSPIRE directive198, the eIDAS Regulation199, the EU eGovernment Action Plan 2016-2020, 

191  
192  

193  

194  
195  

196  

197  
198  

of 

179 

final 

COM(2010) 744 final ‘Towards interoperability for European public services.’ 
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. 
COM(2016) 
content/EN/TXT/?uri=CELEX%3A52016DC0179 
COM(2017) 134 final. 
https://wayback.archive-
it.org/12090/20200212143524/https://ec.europa.eu/idabc/en/document/3473/5887.html 
COM(2010)  744  final  COMMUNICATION  FROM  THE  COMMISSION  TO  THE  EUROPEAN 
PARLIAMENT,  THE  COUNCIL,  THE  EUROPEAN  ECONOMIC  AND  SOCIAL  COMMITTEE 
AND THE COMMITTEE OF THE REGIONS Towards interoperability for European public services. 
Directive 2013/37/EU. 
Directive  2007/2/EC  of  March  2007  establishing  an  Infrastructure  for  Spatial  Information  in  the 
European Community (INSPIRE). 

https://eur-lex.europa.eu/legal-

19.4.2016, 

111 

 
                                                           
the  Single  Digital  Gateway  (proposed  in  2017  and  subsequently  adopted  as  a  Regulation  in 
2019)200, and the European Cloud Initiative. 

199  

200  

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. 
See  the  Staff  Working  Document  accompanying  the  2017  EIF  Communication:  https://eur-
lex.europa.eu/legal-content/ES/TXT/?uri=CELEX:52017SC0112 

112 

 
                                                                                                                                                                                     
Table 14. Key conclusions of the EIF and ISA² evaluations 

Relevance 

EIF 

EIF  

Enhanced EU policy for interoperability with more binding requirements. Coordination is required to create an EU-wide digital 
public service landscape. Having EU-wide rules would help ensure that cross-border aspects of digital public services are considered. 

The needs and problems identified by the EIF are still being experienced by the stakeholders. To increase the relevance of the EIF, 
public administrations would benefit from a common, more practical, end-to-end approach to the EIF, from policy to 
implementation 

ISA² 

The original needs and problems that the programme was intended to address are after the experience of the pandemic even more 
relevant. Several new needs could be identified:  

  Need for an enhanced interoperability governance involving EU countries and regional and local public administrations.  
  Need for digital-ready EU policies. 
  Need for structured and proactive collaboration and the exchange of best practices between all levels of EU public 

administrations (national, regional, local) involved in developing digital public services. 

  Need for strategic and collaborative interoperability planning across different policy programmes and funding initiatives in 

order to steer investments based on user needs towards a set of key mature solutions.  

  Need for systematic links with European standardisation work and increase awareness in the public sector at all levels of 

the key role of standards in supporting the twin digital/green transitions. 

  Need for promotion of successful solutions and continued awareness-raising of interoperability. 

Effectiveness 

EIF  

The recommendations contained in the EIF are usually high-level; further clarity and guidance would be required to ensure that 
they are implemented by Member States; 

EIF  

More granularity is required for efficient framework implementation, especially at the local level 

EIF  

Further advice is needed to the make the layered interoperability and conceptual models more actionable 

EIF  

Given the EIF’s strategic and overall high-level recommendations, best practices for implementation might be added 

113 

 
 
 
ISA²  

ISA²  

ISA²  

ISA²  

ISA² actions have contributed effectively to the implementation of different EU policies and actions (for example SDG, Open Data 
Directive, e-procurement, Inspire, ESS). Member States seek a more holistic and strategic approach. All relevant EU policies should 
be accompanied by interoperable implementation solutions.  

The Joinup platform funded by ISA² was an effective tool to facilitate the re-use of interoperability solutions but more could be done 
to boost the take-up of solutions and encourage re-use especially at regional and local level. 

ISA² was partly effective in developing, maintaining and promoting a holistic approach to interoperability. The latest political 
declarations however ask for a solution to ‘ensure interoperability’.  

ISA² was less effective in contributing to effective, simplified and user-friendly digital public services especially at regional and 
local level. 

Efficiency 

EIF  

The implementation of national interoperability frameworks inspired by the EIF has clearly brought several benefits 

EIF  

Monitoring efforts should focus on the extent of re-use of developed tools and on providing a better overview of costs 

ISA²  

For those packages where it was possible to apply cost-effectiveness techniques, costs per end-user (e.g.: business, citizens, etc.) 
have been estimated as low. 

ISA²  

Benefits however risk to fade, in the absence of appropriate sustainability measures. 

Coherence 

EIF  

To increase interoperability governance and the EIF’s role, strengthened references in associated legal acts are needed.  

EIF  

Heterogeneity of solutions and strategies across the EU hinders interoperability at the EU level. 

ISA²  

Prioritising a smaller set of actions would increase synergies. 

ISA²  

ISA² worked closely with a wide range of other relevant EU programmes, policies and initiatives. This could, however, be done 
more systematically. 

114 

 
 
 
EU-added value 

EIF  

National or subnational governments cannot achieve cross-border interoperability alone. Economies of scale (through shared 
technologies) and experience enable the EIF to achieve its goals at cheaper costs than equivalent national or subnational projects 
(dialogue and shared solutions).  

EIF  

Foster coordination through common rules. Digital public services across the EU could be improved while simultaneously 
strengthening the public sector’s resilience to unanticipated shocks. 

EIF  

The EIF has contributed to some extent to the advancement of common EU policies but more could have been achieved 

EIF  

Enhanced EU policy for interoperability with more binding requirements 

EIF  

Use of conditional interoperability solutions and interoperability-by-design in the development of digital public services could 
help achieve interoperable cross-domain and cross-border services throughout the EU. 

ISA²  

EU-level approach is better suited to addressing the challenges related to interoperability. 

Sustainability (ISA² evaluation only) 

ISA²  

Some concrete actions should be carefully assessed to enhance these activities and ensure they are sustainable: 

  Focusing on developing a smaller set of key mature solutions, continually developing them and encouraging their take-up. 

Concentrating on critical priorities and user needs could also increase user satisfaction. 

  Providing a one-stop-shop for mature interoperability solutions, to help incorporate them into to the existing interoperability 
ecosystem, give existing solutions more visibility and boost their take-up regionally and locally with the support of the Member 
States. 

  Improving the quality of existing solutions by better considering user needs and involve users in co-creation. 
  Supporting experimentation and innovation by setting up an agile process for developing solutions and leveraging innovation 

procurement coupled with ‘sandboxing’ for testing solutions and getting better feedback. 

  Encouraging collaboration with open-source communities for the sustainable and open development of existing and future 

solutions. 

115 

 
 
 
 
Table 15. ISA² programme to the EIF and the interoperability Action plan 

Package 

Action 
number 

Action name 

Contribution to the EIF and the IAP 

1. Key and 
generic 
interoperability 
enablers 

2016.19  Trusted Exchange Platform (e-

TrustEx) 

2016.29  Catalogue of Services 

1. Key and 
generic 
interoperability 
enablers 

2. Semantic 
interoperability 

2016.07  SEMIC: Promoting Semantic 
Interoperability Amongst the 
European Union Member States 

e-TrustEx is a platform offered to public administrations at European, national 
and regional levels to undertake secure exchange of natively digital documents 
or scanned documents from system to system via standardised interfaces. 

  Contribution  to  the  EIF:  The  action  thus  contributes  particularly  to 
Recommendation  15  of  the  revised  EIF,  through  enabling  the  secure 
exchange of documents. 

  Contribution  to  the  IAP:  The  platform  supports  public  administrations  in 
implementing  EU  policies  that  require  the  electronic  exchange  of 
information,  contributing  to  the  implementation  of  the  eIDAS  Regulation 
among  others.  In  this  context,  e-TrustEx  contributes  to  Action  15  of  the 
IAP. 

The Catalogue of Services is one of the interoperability enablers for integrated 
public services according to the conceptual model defined by the revised EIF. 
To  that  end,  the  action  is  defining  a  technical  specification  (data  model)  and 
implementing  a  set  of  tools  to  facilitate  the  creation  of  catalogue  of  public 
services. 

  Contribution  to  the  EIF:  The  action  addresses  Recommendation  44  of  the 

revised version of the EIF on the catalogue of public services. 

  Contribution to the IAP: The Catalogue of Services responds in particular 

to Action 13 of the IAP. 

The Action supports the implementation of the EIF and the EIS by promoting 
semantic 
the  definition  and  use  of  common 
specifications. 

interoperability, 

through 

  Contribution 

to 
Recommendation 16 of the revised EIF.  In addition,  the action covers the 

the  EIF:  The  action  contributes  primarily 

to 

116 

 
Package 

Action 
number 

Action name 

Contribution to the EIF and the IAP 

2. Semantic 
interoperability 

2016.16  Public Multilingual Knowledge 
Management Infrastructure for 
the Digital Single Market 

3. Access to 
data/data 
sharing/open 
data 

2016.03  Big Data for Public 

Administrations 

following  underlying  principles  of  the  EIF:  Reusability,  Multilingualism, 
Openness,  Semantic 
interoperability  and 
interoperability,  Technical 
Standardisation. 

  Contribution  to  the  IAP:  SEMIC  supports  several  actions  of  the  IAP, 

including: 12, 13, 14 and 18. 

The creation of a Public Multilingual Knowledge Infrastructure aims to support 
EU  public  administrations  in  creating  services  that  can  be  accessible  and 
shareable independently  from  the language actually used, as well as  allowing 
SMEs to sell goods and service cross-border in a DSM. 

  Contribution  to  the  EIF:  The  action  is  based  on  several  recommendations 
(primarily  Recommendation  16  on  taking  into  account  multilingualism  in 
the setting up of European public services) and principles of the new EIF, 
in particular those concerning multilingualism, accessibility, administrative 
simplification, transparency, and reusability of the solutions. 

  Contribution  to  the  IAP:  This  action  contributes  to  Action  7  of  the  IAP, 
with  its  focus  on  the  particular  area  of  multilingualism  to  improve  the 
delivery of services and exchange of information. 

the 

increase 

This  action  will  facilitate 
the  sharing  of  open  data  between  public 
administrations  through  the  support  to  the  execution  of  analytics  projects  on 
Big  Data; 
in  public 
administrations  by  supporting  knowledge  sharing  on  evidence-based  policy-
making  practices;  support  the  re-use  of  open  source  data  analytics  tools 
developed  by  Member  States  of  EU  Institutions;  and  provide  public 
administrations with the opportunity to test  (open source) technologies in  this 
domain before making a decision on the technical way forward. 

transparency  of  decision-making 

  Contribution  to  the  EIF:  This  action  contributes  to  several  EIF  principles 
including  ‘openness’,  ‘transparency’,  ‘reusability’  and  ‘technological 
neutrality’. 

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Package 

Action 
number 

Action name 

Contribution to the EIF and the IAP 

3. Access to 
data/data 
sharing/open 
data 

2016.06  Sharing Statistical Production 

and Dissemination Services and 
Solutions in the European 
Statistical System 

3. Access to 
data/data 
sharing/open 
data 

2016.18  Development of an Open Data 
Service, Support and Training 
Package in the Area of Linked 
Open Data, Data Visualisation 
and Persistent Identification 

  Contribution to the IAP: This action contributes primarily to Action 14 of 

the IAP. 

This  action  contributes  to  several  areas:  developing,  maintaining  and 
promoting  interoperable  solutions  for  the  production  and  dissemination  of 
statistics  by EU public administrations (including the EC) and 2) developing, 
maintaining  and  promoting  a)  a  specification  of  the  EIRA  to  support  better 
interoperability  and  cooperation  for  the  production  and  dissemination  of 
Official  Statistics 
the  European  Statistical  System;  b)  a  common 
infrastructure  for  the  exposure  and  consumption  of  shared  statistical  services. 
In addition, the proposal contributes significantly to the realisation of the ESS 
Vision 2020 objectives in the domain of sharing tools and improving statistical 
dissemination. 

in 

  Contribution  to  the  EIF:  Through  its  focus  on  aligning  infrastructures  for 
shared  statistical  services,  the  action  builds  on  the  principles  and 
recommendations of the EIF, in particular Recommendation 36. 

  Contribution  to  the  IAP:  The  activities  undertaken  as  part  of  this  action 

feed into Actions 7 9, 22. 

The action supports open data initiatives by facilitating data re-use and sharing 
and offering tools to visualise data effectively. 

  Contribution to the EIF: The action contributes to the new EIF, namely the 
transparency,  reusability,  user–

interoperability  principles:  openness, 
centricity and multilingualism, accessibility. 

  Contribution to the IAP: The action contributes to several priorities listed in 
the IAP: organisational interoperability (Actions 6 and 7); sharing of good 
practices  (Action  11);  governance  structure  (Action  2)  and  key  enablers 
focused on EU open data initiative (Action 14). 

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Package 

Action 
number 

Action name 

Contribution to the EIF and the IAP 

4. Geospatial 
solutions 

2016.10  European Location 

Interoperability Solutions for e-
Government (ELISE) 

ELISE  has  aimed  to  deepen  the  understanding  of  location  interoperability 
enablers and barriers related to the transition towards digital government. 

  Contribution to the EIF: ELISE builds on several areas of the EIF including 
user-centricity, 
technological 

openness, 
multilingualism, and administrative simplification. 

reusability, 

neutrality, 

  Contribution to the IAP: ELISE brings contributions in particular to Action 
17,  through  its  support  for  the  implementation  of  the  INSPIRE  Directive. 
ELISE also contributes to Actions 4, 6 & 19. 

This  action  supports  several  activities  designed  to  simplify  procurement  and 
facilitate  the  participation  in  online  procurement  as  well  the  re-use  of  data  in 
the field. 

to 

  Contribution 

in  particular  on 
the  EIF:  The  action  builds 
Recommendations  28  and  30  of  the  EIF,  as  well  as  facilitating  the 
implementation  of 
the  area  of  public 
procurement. 
  Contribution 

‘European  Public  Procurement 

the  once-only  principle 

IAP:  The 

the 

in 

to 

2016.05 

European Public Procurement 
Interoperability Initiative 

5. 
eProcurement/ 
eInvoicing - 
Supporting 
instruments 

6. Decision 
making and 
legislation - 
Supporting 
instruments 

2016.23  Legal interoperability (former 

ICT Implications of EU 
Legislation) 

The ‘Legal Interoperability’ action supports policymaking across policy areas, 
bringing to the forefront the importance of considering potential digital impacts 
and the role of interoperability when developing new legislation. 

Interoperability Initiative’ contributes in particular to actions 1, 7 and 18. 

  Contribution  to  the  EIF:  The  action  implements  Recommendation  27  on 

legal interoperability of the new EIF. 

  Contribution  to  the  IAP:  This  ISA²  action  implements  action  3  of  Focus 
Area  1  on  the  governance  and  coordination  of  interoperability  initiatives, 
and  actions  19  and  20  of  Focus  Area  5  on  supporting  instruments  for 
interoperability. 

119 

 
Action 
number 

2017.04 

Package 

6. Decision 
making and 
legislation - 
Supporting 
instruments 

Action name 

Contribution to the EIF and the IAP 

Inter-Institutional Register of 
Delegated Acts (RegDel)  

This action focused on developing an IT tool setting up the Inter-Institutional 
Register of Delegated Acts, increasing transparency around delegated acts and 
thus responding to the 2016 commitment of the Commission in this sense. 

8. Supporting 
instruments for 
public 
administrations 

2016.20 

Joinup – European Collaborative 
Platform and Catalogue  

8. Supporting 
instruments for 
public 
administrations 

2016.21  National Interoperability 
Framework Observatory 

  Contribution  to  the  EIF:  This  action  contributes  primarily  to  the 
transparency principle of the EIF and to Recommendation 5 of the new EIF 
by providing a transparent overview of delegated acts. 

  Contribution  to  the  IAP:  This  action,  by  enhancing  inter-institutional 

governance, contributes to Action 1 of the IAP. 

The  action  facilitates  the  sharing  and  re-use  of  solutions  for  public 
administrations and provides the stakeholders with the means to collaborate via 
a collaborative platform. 

  Contribution  to  the  EIF:  ‘Joinup’  builds  especially  on  the  reusability 
principle  of  the  EIF,  facilitating  access  and  supporting  the  re-use  of 
available interoperable solutions. 

  Contribution  to  the  IAP:  The  activities  ran  as  part  of  the  ‘Joinup’  action 
have  contributed  to  Action  10  of  the  IAP,  which  explicitly  asked  for 
‘maintaining, improving and animating the Joinup platform for better user 
engagement and community building’, as well as action 21. 

The NIFO action has monitored interoperability initiatives in the Members and 
developed the Monitoring Mechanism to  keep track of the implementation of 
the EIF Recommendations by Member States. NIFO has also developed an EIF 
Toolbox to support Member States in the implementation of the EIF. 

  Contribution to the EIF: NIFO provides an overarching contribution to the 
EIF, by helping monitor the alignment of national initiatives with the EIF 
and  the  implementation  of  the  EIF  in  the  Member  States.  The  action 
responds to the commitment from the 2017 EIF Communication that called 
for the development of a framework for monitoring the implementation of 

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Package 

Action 
number 

Action name 

Contribution to the EIF and the IAP 

8. Supporting 
instruments for 
public 
administrations 

8. Supporting 
instruments for 
public 
administrations 

8. Supporting 
instruments for 
public 
administrations 

2016.32  European Interoperability 

Architecture (EIA) 

2016.35  EUSurvey 

2016.37 

IMAPS 

the  EIF.  This  was  achieved  with  the  development  of  the  EIF  Monitoring 
Mechanism as part of the NIFO action. 

  Contribution  to  the  IAP:  NIFO  has  contributed  to  Actions  4  and  5  of  the 

Action Plan. 

This action helps define the needs and shortcomings with relation to a common 
interoperability  architecture  for  European  public  services  and  contribute  to 
defining such an architecture as well as map reusable solutions and guidelines 
services as interoperability building blocks. 

  Contribution  to  the  EIF:  The  ‘EIA’  actions  contribute  in  particular  to 
Recommendation 23 of the EIF and to overall interoperability governance. 

  Contribution to the IAP: The ‘EIA’ action implements Action 22. 

EUSurvey contributes primarily to the multilingualism principle of the EIF. As 
a survey tool widely used in EU policymaking, EUSurvey has also contributed 
to Action 11 of the IAP on the engagement of stakeholders in the development 
of digital public services. 

This  action  supports  tools  for  the  assessment  of  the  interoperability  maturity 
level of digital public services, helping to identify improvement priorities. 

  Contribution  to  the  EIF:  This  action  contributes  to  the  principles  of 
reusability  and  user-centricity  (in  particular,  Recommendation  12  of  the 
EIF) by creating a mechanism for analysis, design, assessment and further 
development of the European Public Services. 

  Contribution to the IAP: The IMAPS action contributes to action 20 of the 

IAP. 

8. Supporting 
instruments for 
public 

2017.01  Standard-Based Archival Data 

Management, Exchange and 

The  action  contributes  to  supporting  data  standards  in  the  field  of  archival 
information management, studying among others how Open Data formats can 

121 

 
Package 

Action 
number 

Action name 

Contribution to the EIF and the IAP 

administrations 

Publication 

be used in this area. 

  Contribution to the EIF: The action builds on several principles of the EIF 
including  openness,  transparency,  reusability,  technological  neutrality, 
preservation of information, user-centricity. 

  Contribution to the IAP: This action contributes to implementing Action 14 

of the IAP. 

8. Supporting 
instruments for 
public 
administrations 

2019.01 

Interoperability Academy 

9. 
Accompanying 
measures 

2016.30  Raising Interoperability 

Awareness – Communication 
Activities 

This  action  was  established 
increase  awareness  of 
interoperability,  the  EIF  and  the  solutions  developed  under  ISA².  The  action 
facilitates access to information and learning material in this sense. 

in  order 

to  help 

  Contribution  to  the EIF: This  action promotes the principle of reusability. 
In addition, it provides an overall contribution to the EIF, by promoting the 
principle, models, and recommendations of the Framework and facilitating 
access to information about implementing the EIF. 

  Contribution to IAP: The Interoperability Academy contributes primarily to 

Actions 5, 8, 11 of the IAP. 

Contribution to the EIF: This action contributes to the principles of inclusion, 
accessibility 
about 
transparency  by  disseminating 
interoperability and the work of ISA². 

information 

and 

Source: Study supporting the final evaluation of the programme on interoperability solutions for European public administrations, businesses and citizens (ISA²) 

  Contribution to the IAP: The communication activities implement Action 8 

of the IAP. 

  Contribution to IAP: The Interoperability Academy contributes primarily to 

Actions 5, 8, 11 of the IAP. 

122