COMMISSION STAFF WORKING DOCUMENT Monitoring of horizontal recommendations 2024 Accompanying the document Communication from the Commission to the European Parliament, the Council and the European Economic and Social Committee and the Committee of the Regions State of the Digital Decade 2025: Keep building the EU's sovereignty and digital future
Date: 2025-06-16
Institutions: Directorate-General for Communications Networks, Content and Technology, European Commission
Subjects: EU Member State, EU programme, artificial intelligence, competitiveness, digital single market, digital transformation, digitisation, innovation, recommendation (EU), technological independence

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 16.6.2025  SWD(2025) 291 final  COMMISSION STAFF WORKING DOCUMENT Monitoring of horizontal recommendations 2024 Accompanying the document Communication from the Commission to the European Parliament, the Council and the European Economic and Social Committee and the Committee of the Regions State of the Digital Decade 2025: Keep building the EU's sovereignty and digital future {COM(2025) 290 final} - {SWD(2025) 290 final} - {SWD(2025) 292 final} - {SWD(2025) 293 final} - {SWD(2025) 294 final} - {SWD(2025) 295 final}  
 
 
MONITORING  
OF HORIZONTAL 
RECOMMENDATIONS 2024 

1 

2025 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
Contents 

Introduction ............................................................................................................................................ 3 

1 

2 

3 

4 

5 

6 

7 

8 

9 

Connectivity .................................................................................................................................... 6 

Technological leadership .............................................................................................................. 15 

Semiconductors ............................................................................................................................ 21 

Edge nodes ................................................................................................................................... 24 

Quantum ...................................................................................................................................... 25 

Take-up of Cloud-AI-Big Data ....................................................................................................... 26 

Digitalisation of SMEs ................................................................................................................... 34 

Unicorns ....................................................................................................................................... 39 

Cybersecurity ................................................................................................................................ 41 

10  Basic skills ..................................................................................................................................... 44 

11 

ICT specialists ............................................................................................................................... 45 

12  EU Digital Identity Framework ..................................................................................................... 46 

13  Digital Public Services ................................................................................................................... 48 

14  e-health ........................................................................................................................................ 54 

15  Safeguarding rights ...................................................................................................................... 57 

16  Protecting children ....................................................................................................................... 59 

17  Human-centred AI ........................................................................................................................ 62 

18  Preserving information integrity and democracy ........................................................................ 64 

19  Smart greening ............................................................................................................................. 69 

20  Strategic Digital Decade National Roadmaps ............................................................................... 73 

21  Fostering coordination and coherence ........................................................................................ 77 

2 

 
 
 
 
 
Introduction 

1 
This document presents an assessment following the requirements in Article 6 of the Digital Decade 
Policy Programme Decision (Decision (EU) 2022/2481) that mandates the European Commission to 
ensure  that  ‘The  Report  on  Digital  Decade  shall  include  information  on  progress  regarding 
recommended policies, measures or actions’.  

In this context, this document assesses progress made between July 2024 and March 2025 against the 
EU-level  recommendations  presented  in  the  2024  State  of  the  Digital  Decade,  based  on  available 
evidence.  In  line  with  the  legal  scope,  the  assessment  focuses  on  the  implementation  of  policies, 
measures  and  activities  recommended  in  the  2024  report,  rather  than  only  tracking  progress  as 
measured by Digital Decade Key Performance Indicators.  

Given  the  cooperative  nature  of  the  Digital  Decade  Policy  Programme  (DDPP),  the  scope  of  the 
assessment includes both joint actions involving the Commission and the Member States, and more 
specific  actions  undertaken  by Member  States  that  have  a  significant  impact  across  the  EU. While 
actions initiated solely by the Commission have been considered, these have been considered relevant 
only where there is a clear link to joint implementation with Member States or where they directly 
support  the  development  of  national  measures.  The  type  of  evidence  and  input  used  also  vary 
depending on the nature of the recommendations.  

The  analysis  also  includes  a  summary  assessment,  based  on  a  qualitative  judgement  and  using 
available evidence and expert input. Each recommendation was evaluated against the following scale: 

•  No Progress – No discernible actions were taken to address the recommendation. 

• 

Limited Progress –  One or few actions were initiated, but  significant  additional efforts are 
needed. 

•  Notable  Progress  –  Several  relevant  actions  were  undertaken,  showing  clear  engagement, 

though full implementation remains incomplete. 

•  Significant  Progress  –  A  broad  set  of  measures  were  adopted,  reflecting  sustained 

commitment and tangible implementation. 

To support consistency, each assessment was grounded in a review of tangible measures and policy 
steps, such as legislative initiatives, dedicated funding, adoption of strategies, or implementation of 
joint projects.  

The objective of this classification provides for constructive analysis to support prioritisation of the 
actions  by  the  EU  and  Member  States  in  the  follow-up  process.  The  approach  helps  identify 
recommendations requiring renewed or increased attention in the coming year.  

Summary overview 

Out of 58 
Recommendations 
monitored: 

No Progress: 
4 (6.9 %) 

Limited Progress: 
28 (48.3 %) 

Notable Progress: 
20 (34.5 %) 

Significant 
Progress: 
6 (10.3 %) 

Connectivity (6)  

0 (0.0 %) 

5 (83.3 %) 

1 (16.7 %) 

0 (0.0 %) 

3 

 
Out of 58 
Recommendations 
monitored: 

No Progress: 
4 (6.9 %) 

Limited Progress: 
28 (48.3 %) 

Notable Progress: 
20 (34.5 %) 

Significant 
Progress: 
6 (10.3 %) 

Technological leadership (4) 

1 (25.0 %) 

2 (50.0 %) 

1 (25.0 %) 

0 (0.0 %) 

Semiconductors (3) 

0 (0.0 %) 

1 (~33.3 %) 

1 (~33.3 %) 

1 (~33.3 %) 

Edge Nodes (1) 

Quantum (1) 

Take-up of Cloud-AI-Big 
Data (4) 

0 (0.0 %) 

0 (0.0 %) 

1 (100.0 %) 

0 (0.0 %) 

0 (0.0 %) 

0 (0.0 %) 

1 (100.0 %) 

0 (0.0 %) 

0 (0.0 %) 

4 (100.0 %) 

0 (0.0 %) 

0 (0.0 %) 

Digitalisation of SMEs (4) 

1 (25.0 %) 

1 (25.0 %) 

1 (25.0 %) 

1 (25.0 %) 

Unicorns (1) 

0 (0.0 %) 

0 (0.0 %) 

0 (0.0 %) 

1 (100.0 %) 

Cybersecurity (2) 

0 (0.0 %) 

2 (100.0 %) 

0 (0.0 %) 

0 (0.0 %) 

Basic Skills (1) 

0 (0.0 %) 

1 (100.0 %) 

0 (0.0 %) 

0 (0.0 %) 

ICT Specialists (1) 

EU Digital Identity 
Framework (1) 

0 (0.0 %) 

1 (100.0 %) 

0 (0.0 %) 

0 (0.0 %) 

0 (0.0 %) 

0 (0.0 %) 

0 (0.0 %) 

1 (100.0 %) 

Digital Public Services (5) 

0 (0.0 %) 

2 (40.0 %) 

3 (60.0 %) 

0 (0.0 %) 

e-Health (3) 

0 (0.0 %) 

0 (0.0 %) 

1 (33.3 %) 

2 (66.7 %) 

Safeguarding Rights (2) 

0 (0.0 %) 

0 (0.0 %) 

2 (100.0 %) 

0 (0.0 %) 

Protecting Kids (2) 

0 (0.0 %) 

1 (50.0 %) 

1 (50.0 %) 

0 (0.0 %) 

Human-centred AI (1) 

0 (0.0 %) 

0 (0.0 %) 

1 (100.0 %) 

0 (0.0 %) 

Preserve information 
integrity and democracy (4) 

0 (0.0 %) 

3 (75 %) 

1 (25 %) 

0 (0.0 %) 

Smart Greening (3) 

1 (33.3 %) 

2 (66.7 %) 

0 (0.0 %) 

0 (0.0 %) 

Strategic Digital Decade 
National Roadmaps (3) 

0 (0.0 %) 

2 (66.7 %) 

1 (33.3 %) 

0 (0.0 %) 

4 

 
Out of 58 
Recommendations 
monitored: 

Fostering Coordination and 
Coherence (6) 

No Progress: 
4 (6.9 %) 

Limited Progress: 
28 (48.3 %) 

Notable Progress: 
20 (34.5 %) 

Significant 
Progress: 
6 (10.3 %) 

1 (~16.7 %) 

1 (~16.7 %) 

4 (~66.7 %) 

0 (0.0 %) 

5 

 
 
 
1  Connectivity  

1.1  Member States are encouraged to work with the Commission to take action to transform 
the electronic communications sector and allow operators to reach critical size  

PROGRESS AND STATE OF PLAY 

Since July 2024, the process of transposing the European Electronic Communications Code (‘EECC’) 
was  completed  by  all  Member  States,  with  the  last  Member  State  to  transpose  the  Directive  in 
September 2024. While this is a positive development, it marked an overall delay compared to the set 
deadline of December 2021.  

The Gigabit Infrastructure Act (‘GIA’), repealing Directive 2014/61/EU and complementing the EECC in 
infrastructure deployment and sharing, entered into force on 11 May 2024 and most of its rules will 
be  applicable  as  of  12 November 2025.  The  GIA  will  increase  deployment  of  very  high-capacity 
networks, reduce costs and improve the efficiency of network roll-out.  

The timely implementation of GIA by Member States contributes to accelerating the achievement of 
the  2030  Digital  Decade  connectivity  targets  for  faster  deployment  of  fibre  and  5G  networks.  This 
requires  Member  States  to  continue  their  efforts  for  timely  reducing  the  administrative  burden 
associated  with  network  deployment,  simplifying  and  digitalising  permitting  procedures,  and 
enhancing the availability of information on existing and planned civil works. 

Based  on  the  available  data,  the  European  electronic  communications  sector  continues  to  face 
challenges in securing the funding needed to invest in future network technologies1. Indicatively in 
2024 (but also in previous years), it had significantly lower mobile broadband ARPU2, as well as lower 
capital expenditure (fixed and mobile), compared to the US, Japan, and South Korea, while shares in 
this sector underperformed globally and at EU level3. This was also one of the conclusions of the Draghi 
report,  which  articulates  the  view  that  EU  telecoms  operators  lack  the  scale  required  to  provide 
citizens with ubiquitous access to  fibre  and 5G broadband and to equip businesses with advanced 
platforms for innovation.  

According  to  Draghi,  the  fragmentation  of  the  sector  into  27  national  markets  hinders  its 
attractiveness  for  large  investors,  creating  varying  supply  and  demand  conditions,  network 
architectures, levels of coverage by very high-capacity networks, and regulatory approaches (although 
these have been partly harmonised).  

To  investigate the  situation further and  address  identified  issues, work is currently  underway  on a 
proposal  for  a  ‘Digital  Networks  Act’  (‘DNA’),  following  the  review  of  the  EECC,  to  create  a  more 
integrated single market for connectivity, driving further alignment across the EU. This means reducing 
fragmentation across Member States, simplifying processes, and reducing burdens for operators by 
removing or aligning applicable rules and conditions.  

1 The White Paper ‘How to master Europe’s digital infrastructure needs?’ highlights that the EU’s ability to carry out the 
investment  and  successfully  transform  the  connectivity  sector  will  depend  on  the  financial  situation  of  its  electronic 
communications sector and its capacity to catch up with the technological shift.  
2 Average Revenue Per User. 
3 According to the 2025 State of the Digital Communications report (State of Digital Communications (2025).pdf), mobile 
ARPU in Europe fell at EUR 14.8 in 2023 - a real terms drop of 5.9% compared to 2022 -, and substantially lower than all peer 
countries when adjusted for differences in GDP/capita.  

6 

 
 
The regulatory framework concerning ex-ante market regulation is also under review, to ensure that 
it is up to date and contributes to the objective of fostering investment. 

Developing future digital infrastructure — including 5G/6G, fibre, satellite, and cloud — will require 
not only private investment but also coordinated public policies and regulatory consistency across the 
EU. This includes using the existing EU tools for coordination, such as spectrum peer review, EU-level 
committees and coordination groups, as well as working closely with the European Commission.  

In this context there is the opportunity to build on the  recent Council Conclusions on Reliable and 
Resilient  Connectivity,  where  the  Member  States  recognised  the  need  to  foster  ubiquitous  and 
seamless connectivity across Europe, enhancing competitiveness and reinforcing the European single 
market as a precondition for resilient  European connectivity infrastructure.  Previously, the  Council 
Conclusions on the White Paper "How to master Europe's digital infrastructure needs?" had notably 
innovation,  security  and  resilience  of  digital 
welcomed  the  Commission’s  goals  to  foster 
infrastructures to unleash further benefits of the Single Market’s potential within the digital sector4. 

SUMMARY ASSESSMENT: Limited progress 

4 Council Conclusions (6 December 2024).  

7 

 
 
 
1.2  Member States should consider further public support, combined with European funds, 
as well as incentivise private investments, to reach market failure  areas, and facilitate 
the development of new 5G use cases based on advanced connectivity and associated 
new ecosystems, such as Connected and Automated Mobility, Smart Cities, eHealth 

PROGRESS AND STATE OF PLAY 

A  majority  of  Member  States  are  participating  in  or  supporting  calls  for  proposals  under  the 
Connecting Europe Facility Digital (CEF Digital) in 2024. 

A  part  of  CEF  Digital  addressed  market  failure,  by  supporting  and  boosting  the  deployment  of  5G 
infrastructure along sections of cross-border transport paths in more than half of EU  Member States, 
thus  enabling  the  deployment  of  future  services  such  as  automated  mobility  and  automated  rail 
operations  (e.g.  Via  Baltica,  North  Sea-Baltic  corridor,  Baltic-Adriatic  Corridor),  as  well  as  inland 
waterways from the North Sea, Orient/East-Med corridor, Scandinavian-Mediterranean Corridor and 
the Iberian and Mediterranean corridors.  

Overall, via the 12 5G Corridor deployment projects funded thus far under CEF Digital, a total of 25 
intra EU borders have been covered, for a distance of 7 275 kilometres5. 

To  support  the  building  of  the  CEF  Digital  project  pipeline  in  the  area  of  rail,  i.e.  in  support  of 
5G-enabled  automated  rail  operations  and  gigabit  connectivity  provision  for  rail  passengers,  the 
Governing Board of the Smart Networks and Services Joint Undertaking (taking into account Member 
States’  advice)  approved  a  5G  Strategic  Deployment  Agenda  for  Connectivity  and  Sustainability  in 
Europe6.  

This  Strategic  Deployment  Agenda,  released  in  December  2024,  represents  a  collaborative  effort 
between the main European industry associations in the field of rail and will serve as a foundation for 
public-private cooperation and investment strategies in rail communications infrastructure. 

A community survey concerning Public funding support for 5G roll-out in the EU Member States, ran 
via  the  5G  for  Smart  Communities  Support  Platform  and  validated  by  the  national  Broadband 
Competence Offices, aimed at gathering an overview of the public support (EU and national funds) 
available at national level across the EU-27 Member States for roll-out of 5G infrastructures in the 
period 2022-2024, revealed that: 

•  Ten  out  of  27  Member  States  (Austria,  Belgium,  Croatia,  Czechia,  France,  Italy,  Lithuania, 
Luxembourg, Portugal, Spain) have funded 5G pilots over the period 2022-2024, for a total budget 
of EUR 2.44 bn, with 10% of these funds having been made available for implementation of 5G 
use cases (as a standalone activity or together with the roll-out of the necessary infrastructure). 
The  majority  of  the  budget  was  allocated  in  just  two  Member  States,  Spain  and  Italy,  for 
infrastructure investments. 

•  Given the low 5G standalone availability in the EU the development of use cases is a challenge. 
Often these are developed in limited sites, with scaling limited in the current environment. Some 
countries might foresee further action in the future to promote Standalone roll out and up-take. 

5  See  Brochure:  Projects  funded  under  Connecting  Europe  Facility  (CEF)  Digital  |  Shaping  Europe’s  digital  future  and  53 
projects selected for up to €274 million under third CEF Digital calls - European Commission.  
6 SNS JU, The 5G Strategic Deployment Agenda for Connectivity and Sustainability in Europe, 2024  

8 

 
 
• 

In terms of funding sources, the Recovery and Resilience Facility (RRF) stands out as the biggest 
source in the 5G funding mix. This is particularly the  case  for  the  roll-out of 5G infrastructure 
investment, where all identified measures are RRF financed. For implementation of use cases, on 
the other  hand,  the  funding  mix  is more  balanced, with  almost  60%  of  the  funds  allocated  to 
implementation of 5G use cases coming from national budgets.  

•  The majority of nationally supported 5G Use Case pilots were implemented under General Block 
Exemption Regulation (GBER) State aid regime, and hence had a strong innovative component. 
Therefore, the commercial viability of these is not guaranteed. Several countries plan assessments 
or impact assessments in 2025 to draw lessons on the commercial viability and possible businesses 
cases. 

•  5G use cases were funded in seven countries (Austria, Belgium, France, Luxembourg, Czechia, 
Lithuania,  Portugal,  and  Spain).  In  terms  of  use  cases  and  verticals  addressed  (in  projects 
dedicated to 5G infrastructure and use cases), most of the projects address transport, defence 
and  security  and  the  healthcare  verticals.  From  a  country  perspective,  based  on  the  mapping 
carried  out  in  the  context  of  the  study,  the  different  verticals  are  represented  in  a  balanced 
manner across the countries:  

o 

transport related use cases have been implemented with priority in Czechia, 
Lithuania and Belgium 

o  defence and security -related projects have been identified in Czechia and Belgium 
o  healthcare -related 5G use cases were proposed especially in Belgium and Czechia.  
Use cases for industry, energy, agriculture and education are more limited in numbers, but have 
been identified in:  

o  Belgium, Lithuania, Austria and Luxembourg (industry 5G use cases);  
o  Belgium and Lithuania (-energy related);  
o  Lithuania, Austria and Luxembourg (agriculture);  
o  Czechia (education).  

A  number  of  projects  have  been  proposed  for  various  verticals,  ranging  from  creative  industries, 
connectivity networks and technology to public administration or waste management.   

However, the development of use cases overall remains suboptimal, e.g. developed in limited sites, 
with scaling limited in the current environment.  

SUMMARY ASSESSMENT: Limited progress 

9 

 
 
 
1.3  Member States should take targeted measures to promote gigabit take-up by end-users, 
in  particular  applying  best  practices  to  connect  end-users  including  to  innovative 
applications as well as, where appropriate, support schemes to foster take-up by end-
users and ensure affordability for higher quality broadband access.  

PROGRESS AND STATE OF PLAY 

Most  available  information  is  linked  to  the  participation  of  Member  States  in  Connecting  Europe 
Facility (CEF) calls supporting 5G deployments for smart communities, or for socio-economic drivers, 
with a view to enabling innovative use cases and innovative applications. Most Member States are 
participating in these calls.  

The  third  call  for  proposals  under  CEF  Digital  has  provided  financial  support  for  an  additional  25 
projects under 5G for Smart Communities (5GSC), for a total of EUR 78 million7.  

This is on top of the EUR 50 million already committed to finance 17 projects for 5GSC under the first 
two CEF Digital calls.  

The funded projects integrate 5G infrastructure with edge-cloud computing, focusing on standalone 
5G, enabling innovative  use  cases such as remote  surgery, virtual reality for learning, drone-based 
monitoring and more.  

Examples of projects:  

•  High Connectivity via 5G (EU contribution: EUR 2.8 million). Focusing on municipal services, 
this project will enable smart traffic management and surveillance as well as connectivity for 
services of general economic interest in the metropolitan area of Toulouse, France. 

•  5G4LIVES (EU contribution: EUR 2.9 million). Focusing on safety and energy, this project will 
enable the development of an emergency management and risk prevention service focusing 
on search and rescue operations in Riga and the management of natural disasters in Turin.  

•  SmartMountain5G (EU contribution EUR 1.7 million). Focusing on climate change challenges 
in mountain areas, by deploying innovative 5G infrastructure, enhancing agriculture through 
optimisation and automation, improving renewable energy management, risk prevention, and 
sustainable tourism in Haute Maurienne.  

Moreover, under the framework of the 5G for Smart Communities Coordination and Support Action 
(CSA) – a technical support scheme implemented under CEF Digital – delegates from Member States 
and regions met  twice a year  and had active  discussions  with the  European Commission and each 
other, sharing good practice and contacting stakeholders to raise awareness about the Connecting 
Europe Facility Digital (CEF Digital) and related opportunities.  

In collaboration with the  Commission,  several Member States  organised  national information days 
engaging stakeholders in their national languages. Another objective is to replicate the good practices 
identified via CEF.  

7 53 projects selected for up to €274 million under third CEF Digital calls - European Commission 

10 

 
 
More precise information on the overall actions taken by Member States to stimulate take-up and 
affordability is not available. Instead, data on take-up shows that, despite an upward trend, there is 
still room to increase take-up of gigabit connectivity and 5G.  

In 2024, only 22.3% of fixed broadband subscriptions were at speeds of 1 Gbps or higher (up from 
18.5% in 2023). As such, there is still need for significant progress in this area.  

SUMMARY ASSESSMENT: Limited progress 

11 

 
 
 
1.4  Member  States  should  ensure  sufficient  access  for  new  players  to  spectrum  for 
innovative  B2B  and  B2C  applications  and  encourage  operators  to  speed  up  the 
deployment  of  standalone  5G  core  networks.  Member  States  could  explore  public 
private partnerships where suitable, for instance where the public capital takes the form 
of  guarantees  or  junior  co-investment,  on  market  terms  to  help  the  electronic 
communications sector fund its transformation  

PROGRESS AND STATE OF PLAY 

The EU-wide assignment of all three 5G pioneer bands is significant yet still incomplete (at 75%, mainly 
driven by the lack of use of the 26 GHz band), while refarming of EU-harmonised spectrum for 5G (e.g. 
2 GHz band) is making some progress, with the ongoing switch-off of 2G/3G networks.  

As  of  mid/end-2024,  further  progress  had  been  achieved  in  authorising  the  700 MHz  and  3.6  GHz 
frequency bands across the EU, reaching an average volume of 90% of assigned spectrum in those 
bands. However, the 26 GHz band has been authorised in only 12 Member States, to a large extent 
due  to  absence  of  market  demand.  This  band  is  pivotal  for advancing  innovative  local  and  private 
networks and fostering overall technological innovation and small cell deployment.   

Spectrum for  local use  by verticals (e.g. factories)  has been  made  available in at least  10 Member 
States, yet in a fragmented way (i.e. in different frequency bands, e.g. 2.6 GHz, 3.6 GHz or 26 GHz). 
The 3.8-4.2 GHz band is in the  process of EU harmonisation for local / vertical use,  which is to be 
finalised in Q4/2025. Spectrum for intelligent transport systems (connected and automated mobility) 
in  the  5.9  GHz  band  has  not  been  taken  up  also  due  to  lack  of  consensus  in  the  industry  on  the 
preferred technology to be used. 

By end-2024, Europe had only 10 operational 5G standalone (SA) networks, underscoring the need for 
accelerated deployment if the EU is to remain competitive globally. While additional operators have 
now launched 5G SA configurations, measuring the overall progress of 5G SA across the EU presents 
a challenge, due to reliance on public announcements and the lack of centralised data on the subject.  

It can also be unclear how widespread 5G SA is, when operators launch, and whether it makes up a 
significant portion of their overall network.  

More  precise  information  on  the  overall  action  taken  by  Member  States  to  stimulate  the 
development of 5G standalone networks is not available. Instead, according to recent estimates, in 
2025, Europe significantly lags in the adoption of 5G SA networks, with only 2% of 5G users connected 
via standalone infrastructure. 

SUMMARY ASSESSMENT: Limited progress 

12 

 
 
 
 
1.5  Member  States  should  integrate  a  strong  sustainability  dimension  in  developing  and 
deploying 6G, in particular aligning with the upcoming EU code of conduct and leveraging 
the EU taxonomy  

PROGRESS AND STATE OF PLAY 

Following up on the 2022 Digitalising the Energy System Action Plan, in March 2024 the Commission 
delivered  an  in-depth  technical  report  on  identifying  common  indicators  for  measuring  the 
environmental  footprint  of  electronic  communications  networks  for  the  provision  of  electronic 
communications  services.  Building  on  this,  the  Action  Plan  further  called  on  the  Commission  to 
establish a code of conduct for the sustainability of telecommunications networks by 2025. 

As recognised by the 2024 White Paper on ‘How to master Europe’s digital infrastructure needs’, this 
work is closely related to the EU Taxonomy, a common classification system, which is vital to help 
direct investment towards sustainable projects and activities and ultimately to foster the sustainability 
dimension in future 6G networks.  

The incentives for attracting investment in environmentally sustainable networks were also discussed 
and recognised by Member States in the Council Conclusions on the White Paper of December 2024. 
This  meeting  was  also  the  occasion  for  Member  States  to  have  a  first  discussion  on  how  best  to 
integrate  sustainability  in  the  future  review  of  the  Digital  Decade,  notably  with  regard  to  future 
connectivity networks. 

In their December Conclusions on the White Paper, the Member States, through the Council, called 
on the Commission ‘to consider proposing a target on green digitalisation in the context of the review 
of the Digital Decade Policy Programme, based on an agreed monitoring methodology’. 

The  Commission  has  been  closely  involving  stakeholders  with  relevant  expertise  in  developing  the 
code  of  conduct,  notably  through  a  workshop  on  6 May 2025.  The  Commission  also  involved 
standardisation experts via the StandICT project, which is funded by Horizon Europe.  

At Member State-level, this work is notably supported by a study by the German National Regulatory 
Authority  (BNetzA)  on  the  comparability  of  sustainability  standards  for  telecommunications 
infrastructure. The Commission plans to publish the code of conduct by the end of 2025, as envisaged 
in the Digitalising the Energy System Action Plan.  

Overall, only a limited number of Member States are actively addressing this recommendation and 
supporting the coordinated development of the EU code of conduct. 

SUMMARY ASSESSMENT: Limited progress 

13 

 
 
 
1.6  Member States should implement the new submarine cable recommendation as quickly 
as  possible  to  ensure  a  coordinated  mapping  and  assessment  of  our  cable 
infrastructures, establishing a Cable Security Toolbox of mitigating measures as well as a 
list of Cable Projects of European Interest  

PROGRESS AND STATE OF PLAY 

Following  the  2024  White  Paper  on  ‘How  to  master  Europe’s  digital  infrastructure  needs  and  the 
Recommendation  on  Secure  and  Resilient  Submarine  Cable  Infrastructure,  the  Commission 
established an Expert Group composed of Member State authorities and the European Union Agency 
for Cybersecurity (ENISA), which had its third meeting on 12 March 2025. Moreover, in February 2025 
the Commission and the High Representative adopted an EU Action Plan on Cable Security. 

The Expert Group has been advancing on its comprehensive report on all core deliverables, supported 
by an external contractor. Moreover, the 2025 EU Action Plan on Cable Security put Q4 2025 as the 
target for these deliverables (mapping, risk assessment, Cable Security Toolbox, priority list of Cable 
Projects of European Interest). The broader scope of the Action Plan is expected to further promote a 
comprehensive and coordinated approach across all Member States. 

The Recommendation constitutes the Commission’s strategic policy framework on submarine cable 
infrastructure and its Expert Group is an opportunity to bring together expertise from different areas, 
but also to better align the work across authorities at national level. Supported by external expertise 
under contract EC-CNECT/2024/OP/0070  and as required by the 2025 Action Plan, the  Group is to 
deliver  a  comprehensive  report  in  Q4  2025,  covering  notably  a  mapping  of  existing  and  planned 
infrastructure,  a  consolidated  and  EU-wide  assessment  of  risks,  vulnerabilities  and  dependencies 
(accounting for existing assessments), including a stress test methodology, a Cable Security Toolbox 
of mitigating measures, and a draft list of Cable Projects of European Interest (CPEIs) to help refocus 
and prioritise public funding. 

These policy measures were fully endorsed by the Niinistö report and complement recent legislation, 
in particular the Directives on measures for a high common level of cybersecurity across the EU (NIS 
2 Directive) and on the resilience of critical entities (CER Directive).  

The measures are also reflected in the EU’s international cooperation. For instance, together with key 
partners, in 2024 the EU endorsed the New York Joint Statement on the Security and Resilience of 
Undersea Cables in a Globally Digitalized World. The EU is also in a regular dialogue with NATO, for 
instance on resilience in general and maritime security in particular. The EU-NATO cooperation will be 
further strengthened through dedicated expert exchanges, notably on critical infrastructure. 

Finally,  the  work  under  the  Recommendation  and  related  areas  was  discussed  in  various  Council 
Working Parties  and recognised in the  Council Conclusions of December 2024 on the White Paper 
mentioned above. In its Conclusions, the Council invited the Commission to consider further measures 
to promote the security, resilience and integrity of submarine cable infrastructure. Under the Polish 
Presidency,  the  Council  TTE  Telecoms  Council  Conclusions  on  Reliable  and  Resilient  Connectivity, 
which put an even stronger focus on the security and resilience of these infrastructures, representing 
a collective effort by Member States.  

SUMMARY ASSESSMENT: Notable progress 

14 

 
2 

Technological leadership  

2.1  Member States are encouraged to effectively increase investment in digital R&I across 
sectors  to  achieve  the  target  of  3%  of  EU  GDP.  This  includes  investing  in  critical 
infrastructure and technologies, as well as supporting projects of strategic interest for 
the EU’s digital sovereignty.  

PROGRESS AND STATE OF PLAY 

Given the timeline in R&D statistics, data are not available to determine whether any progress has 
been  made  in  2024  towards  the  target  of  3%  of  EU  GDP  for  digital  R&I  expenditure8.  However,  it 
remains evident that there is a strong need to step up R&D investment, including in the digital sector, 
as underscored by recent initiatives such as the Competitiveness Compass9.  

Moreover, Eurostat data on business expenditure on R&D10 and on R&D personnel in ICT sector11 show 
a slightly decreasing trend between 2021 and 2022 in most Member States for which data across the 
two years is available.  

In  parallel,  Member  States  are  promoting  projects  in  areas  of  strategic  interest.  The  continued 
development  of  European  Digital  Infrastructure  Consortiums  (EDIC),  the  endorsement  of  the  new 
possible  IPCEIs  in  the  digital  sector,  and  the  implementation  of  EuroHPC  and  Chips  JU  initiatives 
demonstrate  tangible  EU-wide  efforts  to  enhance  digital  sovereignty  and  competitiveness. 
Specifically: 

-  Further  EDICs  are  currently in  preparation,  with  an advanced  degree  of  commitment  -  one 
formal application and several pre-notifications have been submitted -and more initiatives are 
under consideration for becoming EDICs.  

-  The  first  Annual  EDIC  gathering  is  planned  for  autumn  2025.  This  event  aims  to  harness 
synergies, foster knowledge exchange, identify common issues and strengthen the connections 
between different stakeholders. It also aims to provide a platform for a structured discussion 
on the functioning and the future of the EDIC ecosystem. 

-  The ecosystem of Important Projects of Common European Interests (IPCEI) is evolving too, 
the  high-level  formation  of  the  Joint  European  Forum  for  IPCEI  endorsed  the  proposal  by 
participating Member States to start working on the design of three digital IPCEI-candidates: on 
Advanced Semiconductor Technologies (IPCEI-AST); on Artificial Intelligence Services (IPCEI-AI), 
and on Deploying Computing Infrastructure (IPCEI-ECI). 

The latter two build on the results of the ongoing IPCEI on Cloud Infrastructure and Services 
(IPCEI-CIS): as a baseline technology to further research and deployment into AI needs (IPCEI-
AI),  and  for  the  development  of  the  technologies  that  could  be  deployed  in  the  relevant 
infrastructure (IPCEI-ECI).  

8 The latest data, referring to 2023, indicated that R&I in the EU stood at 2.2% of GDP.  
9 Competitiveness Compass for the EU, COM(2025) 30 final.  
10  Business  expenditure  on  R&D  (BERD)  in  ICT  sector  as  %  of  total  R&D  expenditure  by  NACE  Rev.  2  activity  (Statistics  | 
Eurostat). This indicator shows a decrease for 9 Member States, out of the 16 for which data are available.  
11 R&D personnel in ICT sector as % of total R&D personnel by NACE Rev. 2 activity (Statistics | Eurostat). This indicator shows 
a decrease for 13 Member States, out of the 17 for which data are available.  

15 

 
 
 
-  The EuroHPC JU is making good progress towards delivering on its objectives and supporting 
the Commission’s goal to set up AI factories across Europe, reinforcing the EU commitment to 
advancing AI technology and innovation. Seven consortia to establish the first AI factories were 
selected in December 2024, and the JU announced the selection of another six new AI factories 
in March 2025.  

-  The  Chips  JU  is  making  good  progress  towards  delivering  on  its  objectives,  having  already 
selected 25 national competence  centres  and  launched the first pilot  lines in five key areas.  
Additionally,  six  Framework  Partnership  Agreements  have  been  established  for  pilot  lines 
focusing on quantum chip technology. 

-  The three EDICs formally established by mid-2024 (Alliance for Language Technologies EDIC, 
Local  Digital  Twins  towards  the  CitiVERSE  EDIC,  and  EUROPEUM-EDIC)  have  progressed  to 
implementation  (putting  in  place  their  registrations  at  national  level  and  the  required 
governance structures). They have also grown in size, each of them gaining new Member States 
as  members  or  observers  (eight  new  MSs  joining  ALT-EDIC,  three  joining  LDT-EDIC  and  two 
joining EUROPEUM-EDIC).  

-  The  first  Annual EDIC  gathering  is  planned  for  autumn 2025,  as  a  platform  for  a  structured 

discussion on the functioning and the future of the EDIC ecosystem. 

SUMMARY ASSESSMENT: Limited progress 

16 

 
 
 
2.2  Member States should help plan and coordinate investment and reforms to deepen the 
Single  Market,  which  is  an  essential  factor  for  accelerating  an  EU-based  digital 
transformation.  

PROGRESS AND STATE OF PLAY 

In her 2024–2029 Political Guidelines, President Ursula von der Leyen reaffirmed the deepening of the 
single market and coordinated investment as a strategic priority to boost Europe's competitiveness 
and resilience.  

Building on Draghi’s report, which underscored the necessity for radical changes to prevent the EU 
from lagging further behind global competitors like the US and China, the European Council endorsed 
the  priority  to  be  given  to  coordinate  investment  and  deepening  of  the  single  market  during  its 
‘Budapest  Declaration’  and  a 
in  Budapest,  culminating 
November  2024  meeting 
competitiveness pact focused on administrative simplification and regulatory clarity.  

in  the 

These efforts reflect a coordinated institutional response to President von der Leyen’s call for a fully 
integrated  single  market  that  stimulates  targeted  public  and  private  investment,  accelerates 
productivity and innovation, and secures Europe’s competitive position in a shifting global landscape. 

In response, the Commission launched the Competitiveness Compass12 in January 2025 as a roadmap 
for reigniting economic dynamism in Europe through innovation-led growth, and to guide Member 
States 
including  digital 
transformation, decarbonisation, and strategic autonomy.  

in  aligning  reforms  and 

long-term  EU  priorities, 

investment  with 

The Council, notably through the March 2025 Competitiveness Council, discussed and welcomed the 
Compass and supported a set of common activities—ranging from strengthening the circular economy 
and diversifying energy supplies to enhancing digital infrastructure and workforce skills.  

These concerted efforts  by the  Council and the European Council reflect a unified commitment to 
implementing the Competitiveness Compass and enhancing Europe's economic resilience and global 
competitiveness.  

As part of the preparatory work for the next 7-year EU budget (multiannual financial framework, MFF), 
the European Commission has initiated a comprehensive MFF impact  assessment to evaluate how 
best to align EU-level investment with clear strategic objectives, while enhancing agility, focus, and 
administrative efficiency, notably building on the experience of the Resilience and Recovery Fund.  

This  exercise  aims  to  ensure  that  future  EU  spending  and  national  investment  plans  are  better 
coordinated,  reinforcing  key  policy  areas  such  as  the  green  and  digital  transitions,  security,  and 
competitiveness.  The  assessment  also  explores  ways  to  streamline  delivery  mechanisms,  reduce 
administrative burdens for beneficiaries, and enhance the responsiveness of EU funding instruments 
to evolving challenges.  

In line with the President’s political guidelines, the goal is to shape a next generation MFF that is not 
only  ambitious  and  future-proof  but  also  delivers  measurable  impact  through  greater  consistency 
between  EU  and Member State  action.  Another key  priority  of  the  guidelines  is  to  ensure  that  no 
region is left behind in the digital transformation. As a consequence, greater prominence should be 

12 Competitiveness Compass for the EU, COM(2025) 30 final. 

17 

 
 
given to the digitalisation of rural areas within the framework of the Competitiveness Compass and 
the  forthcoming  MFF,  considering  the  untapped  potential  held  by  rural  regions  for  innovation, 
entrepreneurship, and sustainable development. 

The information above shows that these topics have gained a significant attention in the last year.  

SUMMARY ASSESSMENT: Notable progress 

18 

 
 
 
2.3  Member  States  should  engage  with  the  research  and  innovation  sector  to  increase 
research security in national research activities, with the aim of managing risks such as 
undesirable  transfer  of  critical  technology,  malign  influence,  and  ethical  or  integrity 
violations by non-EU countries.  

PROGRESS AND STATE OF PLAY 

With  the  European  Economic  Security  Strategy13,  the  European  Commission  has  committed  to 
proposing  measures  to  improve  research  security,  while  preserving  the  openness  of  the  EU’s 
innovation ecosystem. As part of the January 2024 Economic Security package14, the Commission has 
adopted  a  proposal  for  a  Council  Recommendation  on  enhancing  research  security15.  This  was 
adopted  by  Member  States  at  the  Council  of  23 May 202416.  The  Recommendation  focuses  on 
enhancing  research  security,  particularly  in  response  to  the  growing  geopolitical  risks  and  the 
evolving landscape of international research and innovation.  

Special  emphasis  is  placed  on  high-risk  research  areas,  such  as  artificial  intelligence,  quantum 
computing,  biotechnology,  and  advanced  materials,  which  have  the  potential  for  dual-use 
applications. Member States are encouraged to closely monitor these areas and implement stricter 
security measures as necessary. Moreover, the recommendation points to enhancing cybersecurity 
practices,  ensuring  better protection  for  sensitive  research  data,  and  increasing  awareness among 
researchers and institutions about the potential security risks.  

The  Recommendation  calls  for  regular  evaluation  of  the  effectiveness  of  the  measures  taken  by 
Member States to enhance research security. It encourages the EU to monitor progress and provide 
updated guidance as new risks emerge or the geopolitical context changes. Reporting on action taken 
by Member States will be available in the next years. The Commission monitors the progress made in 
following up on  this recommendation in a transparent way and based on clear indicators, in close 
cooperation with the Member States and after consulting the stakeholders concerned, using the ERA 
policy platform, and reports to the Council every two years, as part of its biennial reporting on the 
Global  Approach  to  Research  and  Innovation  and  its  existing  reporting  on  the  Research  and 
Innovation Framework Programme. 

The  first  Biennial  Report  on  the  Implementation  of  the  Global  Approach17,  published  before  the 
Recommendation  was  adopted,  shows  that,  in  the  first  two  years  (2021-23),  the  Global  Approach 
proved its effectiveness and relevance and continues to be the appropriate strategic framework for 
international R&I cooperation – by preserving openness and promoting values and principles and by 
safeguarding the EU’s strategic assets, interests, autonomy and security. The report also provides a 
snapshot  of  the  EU’s  position  in  international  research  and  innovation  cooperation  across  various 
subject  areas.  The  next  Biennial  Report  will  include  the  results  from  the  monitoring  of  the 
Recommendation. 

SUMMARY ASSESSMENT: No progress 

13 EC/EEAS, Joint Communication JOIN/2023/20 final on the European Economic Security Strategy 
14 European Commission, New tools to reinforce the EU’s economic security, Press release, 2024  
15 Council Recommendation COM(2024) 26 final on Enhancing research security 
16 Council Recommendation COM(2024) 26 final on Enhancing research security 
17 European Commission, First biennial report on the implementation of the Global Approach to research and innovation, 
Press release, 29 June 2023 

19 

 
 
2.4  Member  States  are  encouraged  to  fully  engage  in  the  joint  Economic  Security  risk 
assessment exercises. This involves coordinated risk assessments of technology security 
and  technology  leakage  and  notably  to  share  the  relevant  information  in  their 
possession.  

PROGRESS AND STATE OF PLAY 

The 2023 European Economic Security Strategy proposed a common strategic framework to address 
the risks and challenges to economic security. In particular, the risks in the strategy’s focus are: 

-  Risks to the resilience of supply chains, to be assessed by the Commission, by deepening the 
EU’s strategic dependencies analysis, with a particular focus on dependencies that are more 
likely to be weaponised for geopolitical purposes 

-  Risks  to  the  physical  and  cybersecurity  of critical infrastructure  –  this will  continue  to  be 

assessed in line with the Council Recommendation of 8 December 2022. 

-  Risks related to technology security and technology leakage, to be assessed on the basis of 

a list of strategic technologies critical for economic security.  

-  Risks of weaponisation of economic dependencies or economic coercion. 

On 3 October 2023, the Commission adopted a Recommendation to the Member States identifying 
10 technology areas as critical for the EU’s economic security. Four of these technologies, three of 
which are digital, were recommended for an urgent joint risk assessment by the Commission and the 
Member States: Advanced Semiconductor Technologies, Artificial Intelligence Technologies, Quantum 
Technologies and Biotechnologies.  

The  Commission  and  the  Member  States  continue  to  cooperate  in  the  context  of  the  ongoing 
economic  security  risk  assessment  exercises,  aimed  at  identifying  high-risk  areas.  Based  on  the 
outcomes, the Commission will propose a series of targeted and proportioned mitigating measures. 

SUMMARY ASSESSMENT: Limited progress 

20 

 
 
 
 
3 

Semiconductors  

3.1  Member  States  should  stimulate  secure  and  sustainable  domestic  chip  design  and 
manufacturing  capabilities,  including  by  reshoring  packaging  and  assembly  activities 
within  the  EU,  increasing  digital  skills  in  advanced  technologies  across  sectors  and 
strengthening engagement with the European ecosystem  

PROGRESS AND STATE OF PLAY 

Since July 2024, several initiatives have been developing which include the activities under the Chips 
Act (launch of pilot lines, the design platform and the chips competence centres, attracting innovative 
investment  to  the  EU,  monitoring  the  value  chain),  the  Industrial  Alliance  on  Processors  and 
Semiconductor  Technologies  (the  launch  of  the  working  groups)  and  the  Important  Projects  of 
Common  European  Interest  (IPCEI)  on  Microelectronics  (the  conclusion  of  the  first  one  and  the 
progress of the second one, the IPCEI on Microelectronics and Communication Technologies). 

With specific reference to the recommendation, concrete action has been observed by the Member 
States through State aid grants agreed for several companies participating in the second IPCEI ME-CT, 
as well as supporting investment as planned by Pillar II of the Chips Act, for total private and public 
investment worth over EUR 50 billion.  

All this investment covers the whole semiconductor value chain from chip design and manufacturing 
capabilities  to  packaging  and  assembly.  Increasing  digital  skills  in  advanced  semiconductor 
technologies  is the core  activity targeted by the Skills working group  that was  launched under  the 
Industrial Alliance. 

Looking at available data, the European semiconductor sector continues to face challenges at global 
level to enhance technological sovereignty and secure a robust and self-reliant value chain, given the 
investment race by all the relevant regions in the semiconductors ecosystem. 

Following  March  2025,  a  series  of  initiatives  are  envisaged  to  stimulate  secure  and  sustainable 
domestic chip design and manufacturing across the EU, including: 

•  new investment for innovative facilities in the EU, including on semiconductor design; 

•  ongoing discussions  for  designing  the new  IPCEI on Advanced  Semiconductor Technologies 

(IPCEI-AST). 

•  new working group(s) under the Industrial Alliance. 

• 

investment in common hardware platform for automotive, as committed to in the Automotive 
Action Plan. 

•  preparation of the review of the EU Chips Act. 

As the digital transition accelerates, worldwide demand for chips will grow rapidly and is expected to 
exceed  USD  1  trillion  by  2030,  essentially  doubling  its  value  over  this  decade.  It  is  thus  of  utmost 
importance to keep focusing on the initiatives in the sector to face up to global competition and meet 
the envisaged target. 

SUMMARY ASSESSMENT: Notable progress 

21 

 
 
3.2  Member  States  should  consider  policies  to  leverage  trusted  electronics  including,  as 
necessary,  standards,  certification,  and  common  requirements  for  secure  chips, 
including security requirements and related performance-based specifications in public 
tenders (e.g. for communication networks or data infrastructure)  

PROGRESS AND STATE OF PLAY 

The  EC  lead  initiative  of  trusted  chips  started  in  2023.  The  project  coordinator  DKE  held  several 
workshops to define the scope and terminology. The agreed definition is semiconductor products that 
are trustworthy from the design stage onward and maintain this status until end of life, according to 
the characteristics of trustworthiness in ISO/IEC 5723:2022. This standard reference characteristics 
include  accountability,  accuracy,  authenticity,  availability,  controllability,  integrity,  privacy,  quality, 
reliability,  resilience,  robustness,  safety,  security,  transparency  and  usability.  Each  of  these 
characteristics might have sub-categories.  

For  some  characteristics,  standards  are  currently  being  developed,  in  particular  for  cybersecurity 
aspects under Regulation (EU) 2024/2847 (the Cyber Resilience Act). 

The German ‘Trustworthy electronics’ initiative is about the sovereignty of manufacturing processes, 
ensuring that only trustworthy components are used. This means that the production and supply chain 
must  be  traceable  beyond  doubt.  The  individual  components  and  the  structure  of  the  electronic 
components must be known.  

Today, this is often not yet possible. For example, to find solutions for this challenge, Fraunhofer IPMS 
is involved in the flagship initiative ‘Trustworthy Electronics’, run by the German Federal Ministry of 
Education and Research BMBF18.. One of their flagship projects is Velektronik, the platform for trusted 
electronics.  The  platform  focuses  on  the  technological  overview,  contributions  to  the  necessary 
standardisation, connections between research and industry and the ultimate know-how, in order to 
provide concrete solutions to the increasing demand for higher trustworthiness in electronics.  

Overall,  the  trusted  chips  initiative  is  lagging  behind  its  original  goals  due  to  limited  resources,  as 
standardisation  efforts  are  currently  concentrating  on  developing  the  European  Standards  for  the 
Cyber Resilience Act, which covers only one characteristic of the trusted chip framework. 

SUMMARY ASSESSMENT: Limited progress 

18 German Federal Ministry of Education and Research, Microelectronics. Trustworthy and sustainable. For Germany und 
Europe, 2024  

22 

 
 
 
 
3.3  Member  States  should  develop  a  stronger  Foreign  Direct  Investments  policy  to  keep 

intellectual property in Europe  

PROGRESS AND STATE OF PLAY 

Since  July  2024,  the  European  Commission  and  EU  Member  States  have  implemented  several 
measures to strengthen foreign direct investment (FDI) policies and safeguard intellectual property 
(IP) within Europe. 

The European Commission initiatives include: 

•  A  proposal  to  revise  the  FDI  Screening  Regulation:  Following  the  adoption  on 
24 January 2024  of  the  Commission’s  proposal  for  updates  to  the  existing  FDI  Screening 
Regulation to enhance the EU's economic security. 

•  The fourth Annual Report on FDI Screening: In October 2024, the Commission published its 
fourth annual report on the screening of foreign direct investment into the  EU. The report 
highlighted  the  need  to  address  divergences  in  national  screening  mechanisms  among 
Member States and a proposal to revise the FDI Screening Regulation to improve the efficiency 
and effectiveness of the system.  

On  17 December 2024,  the  Council  approved  conclusions  emphasising  the  need  for  cooperation 
between the Council, the Commission, and Member States in shaping the EU's investment protection 
policy. The conclusions call for: 

o  a stronger EU investment protection framework.  

o  a balance between protecting investors and safeguarding public interests.  

o  better cooperation among Member States to address the challenges in investment 

protection.  

As of October 2024, 22 EU Member States have established active FDI screening mechanisms, with 
the remaining five expected to implement theirs shortly. This widespread adoption reflects a collective 
effort to protect national security and public order across the EU.  

Collectively,  these  initiatives  demonstrate  a  concerted  effort  by  the  European  Commission,  the 
Council, and Member States to enhance FDI policies and protect intellectual property within Europe, 
thereby strengthening the EU's economic security and competitiveness. 

SUMMARY ASSESSMENT: Significant progress 

23 

 
 
 
4 

Edge nodes  

4.1  Member States should support the deployment of secure and sustainable edge nodes as 
part of their connectivity, IoT and AI strategies. Member States should ensure that the 
deployment of edge nodes does not create new divides within the single market  

PROGRESS AND STATE OF PLAY 

The  Joint  European  Forum  for  Important  Projects  of  Common  European  Interest  (JEF-IPCEI) 
announced in November 2024 the launch of the design phase of potential new  IPCEIs in clean and 
digital  technologies,  including  a  potential  IPCEI  on  the  Deployment  of  Computing  Infrastructure 
(IPCEI-ECI) and one on Artificial Intelligence Services (IPCEI-AI). Both initiatives, if pursued, could have 
an impact on technologies that are deployed on edge nodes and on edge nodes deployment. These 
two potential new IPCEIs can rely on technological foundations currently being created by the IPCEI 
on Next Generation Cloud Infrastructure and Services (IPCEI-CIS). More specifically, IPCEI-CIS results 
could be used in the IPCEI-AI as a baseline technology for further AI research and development. In the 
context  of  IPCEI-ECI,  IPCEI-CIS  -developed  technologies  could  be  deployed  over  the  computing 
infrastructure.  

As announced in the Competitiveness Compass, and in response to the Draghi report and the mission 
letter to EVP Henna Virkkunen, the European Commission will propose a Cloud and AI Development 
Act (Q4 2025/Q1 2026). The Act will aim to ensure that EU businesses and public administrations have 
access to sufficient AI compute capacity for the EU to become an ‘AI continent’. AI capacity in edge 
nodes can be seen as part of these efforts, offering low-latency AI inference capacity.  

The dynamic of edge node deployment had gained momentum by end of 2024, with a substantial 
single-year increase of 1 072 new nodes in 2024, and varied adoption rates among Member States.  

France, Germany, Italy, and Spain are regarded as ‘trend-setters’, paving the way for the deployment 
of edge nodes. At the opposite end of the spectrum, Member States like Portugal, Romania, Slovakia, 
Slovenia, Greece, Hungary, Latvia, Lithuania, Luxembourg, Malta, Bulgaria, Croatia, Cyprus, Czechia, 
and Estonia show smaller penetration  by edge nodes in their digital infrastructure. These Member 
States are encouraged to begin planning for foundational infrastructure to support the progressive 
deployment of edge nodes according to their needs. 

SUMMARY ASSESSMENT: Notable progress 

24 

 
5  Quantum  

5.1  Member States should advance the objectives of the Quantum Declaration, namely, to 
collaborate with each other and with the Commission in the strategic and high-potential 
domain of quantum technologies, with the ultimate aim of making the EU ‘the quantum 
valley’  of  the  world.  Member  States  should  coordinate  investment  in  quantum 
technologies  across  Member  States  and  strive  to  address  the  relatively  low  level  of 
Europe’s private sector investment 

PROGRESS AND STATE OF PLAY 

In June 2025, the Quantum Declaration has now been signed by 26 Member States, signalling a very 
high level of commitment on their part. On this basis, a Member State Expert Group (the Quantum 
Technologies Coordination Group) has been set up to work on implementing the Declaration’s goal of 
establishing a Quantum Pact. Particular focus is on increased coordination between Member States, 
pooling of resources, and on the need to ensure that Europe’s most promising quantum start-ups can 
access the ambitious investment levels they need to scale up.  

Member States continue to contribute to major EU initiatives in quantum technologies, supported by 
national and EU funding. The EuroHPC Joint Undertaking is in the process of jointly installing, together 
with the Member States, eight quantum computers, to be integrated into  its supercomputers. The 
EU’s Digital Decade target of having the first computers with quantum acceleration by 2025 should be 
met. Member States are also building, together with the EU, their national quantum communication 
networks, which will be linked across borders to form the basis of the EuroQCI, the European quantum 
communication infrastructure. 

The publication of an EU Quantum Strategy (Communication from the Commission) will help foster 
cutting-edge  research  and  deployment  in  quantum computing,  communication,  and  sensing,  drive 
growth in strategic markets, secure Europe’s leadership in this strategically significant field, and build 
a resilient ecosystem that turns scientific excellence into global industrial strength.  

The  work  of  the  Quantum  Technologies  Coordination  Group  is  complemented  by  three  working 
groups (for Research, Infrastructure, and Industrialisation and Standardisation), which bring together 
representatives  and  experts  from  national  authorities  and  academia and meet  regularly  to  discuss 
Europe’s needs and the way forward.  

The groups are expected to deliver their first analysis in early 2025. The Commission remains in regular 
contact with the Quantum Technologies Flagship’s Strategic Advisory Board and with the European 
Quantum Industry Consortium in order to monitor developments in Europe’s quantum landscape, and 
in  particular  the  progress  made  towards  the  Flagship’s  Strategic  Research  and  Industry  Agenda. 
Overall, progress was made, but major effort is still needed, and Member States should be urged to 
take further action. In particular, the coordination of the national quantum strategies and integration 
of resources needs to accelerate if the EU wants to stay at the forefront in quantum. 

SUMMARY ASSESSMENT: Notable progress 

25 

 
6 

Take-up of Cloud-AI-Big Data  

6.1  Member  States  should  take  policy  measures  and  earmark  resources  to  support  the 
adoption  of  trustworthy  and  sovereign  AI-enabled  solutions  by  European  companies, 
step up public investment in general purpose/generative AI based and incentivise private 
investments. Member States should foster the availability of legal and technical support 
to procure and implement trustworthy and sovereign AI solutions across sectors  

PROGRESS AND STATE OF PLAY 

To  further  boost  the  development  and  deployment  of  trustworthy  and  sovereign  AI  solutions,  the 
European Commission and Member States have launched several initiatives since July 2024. 

Launched in February 2025 during the AI Action Summit in Paris, InvestAI is a programme aimed at 
mobilising  investment  in  AI  across  Europe.  It  includes  EUR  20  billion  dedicated  to  building  AI 
gigafactories  equipped  with  cutting-edge  computing  resources,  to  support  the  development  of 
advanced AI models. 

The AI Factories programme, with an initial investment of EUR 10 billion co-financed by the EU and 
Member States, is the largest public investment in AI worldwide. This initiative is expected to unlock 
over  10  times  more  private  investment  and  provide  unprecedented  access  to  supercomputers  for 
start-ups  and  industry.  The  first  seven  AI  factories,  announced  in  December  of  2024,  will  support 
strategic sectors such as health, manufacturing, climate, finance, cybersecurity, and agri-tech. These 
AI Factories will not only multiply the current EuroHPC AI-computing capacity by at least five times 
but  also  create  a  network  of  national  centres  to  provide  services  and  algorithmic  support  to  the 
national AI ecosystem. 

Furthermore,  the  European  Digital  Innovation  Hubs  (EDIHs)  provide  access  to  digital  technologies, 
with a focus on AI, and support their adoption by SMEs and public sector organisations. The EDIHs 
offer a range of services, including training, testing, and experimentation facilities, as well as access to 
expertise and funding opportunities. By providing a local and accessible entry point for companies and 
organisations to develop and deploy AI solutions, EDIHs play a crucial role in fostering AI adoption and 
bridging the digital divide.  

Specifically, more than 80% of EDIHs provide AI-related services, making it the most widely available 
advanced technology support. In addition, according to the latest JRC report on the State of Play of 
the EDIH Network in 2024, AI & Automation services have shown the highest relative growth (more 
than 30%) in digital maturity improvement after EDIH interventions. The network of EDIHs is planned 
to be continued in 2025-2026, and is set to continue supporting adoption of digital and AI technologies 
by businesses and public sector organisations. 

The  Testing  and  Experimentation  Facilities  (TEFs)  initiative  supports  AI  adoption  by  providing 
European companies with access to specialised facilities to test, validate, and certify their AI-powered 
products and services. This enables companies to refine their AI solutions, improve their performance, 
and demonstrate their safety and reliability, ultimately accelerating the development and deployment 
of trustworthy and sovereign AI solutions in Europe. 

In addition to the AI factories programme, the EU has also launched the GenAI4EU initiative, which 
will support the development of novel use cases and emerging applications in several industrial and 

26 

 
societal sectors. This initiative will be implemented through the Horizon Europe and Digital Europe 
programmes, demonstrating the EU's commitment to fostering a vibrant AI ecosystem. 

Furthermore, the Apply AI Strategy (expected to be Q3 of 2025) aims to boost new industrial uses of 
AI and improve the delivery of public services.  

These  initiatives  are  referring  mostly  to  Commission’s  action  and,  at  this  stage,  no  additional 
information is available on the action taken by Member States since the publication of the 2024 
State of the Digital Decade Report. 

SUMMARY ASSESSMENT: Limited progress 

27 

 
 
 
6.2  Member  States  should  stimulate  national  efforts  for  cloud  adoption  through  cloud 
targeted  investment  and  exploitation  strategies  for  advanced  cloud  solutions  among 
businesses (in particular SMEs) as well as by developing dedicated skilling programmes, 
including on cloud security and environmental performance.  

Member States should foster consistency and synergies when leveraging the Recovery 
and Resilience Fund for investing in business cloudification.  

Member States should ensure that the effort towards greater business cloud uptake is 
jointly approached by all governmental and business actors.  

PROGRESS AND STATE OF PLAY 

Several  Member  States  have  made  efforts  to  support  business  cloud  adoption  through  targeted 
investment and exploitation strategies, including by leveraging the Recovery and Resilience Facility. 
In the absence of EU-wide data on national efforts for cloud adoption and their specific content, a few 
examples that stand out are included below.    

Latvian Investment and Development Agency’s grants for business digitalisation: 

In November 2024, the Latvian Cabinet of Ministers approved a new support programme worth over 
EUR 27 million, providing support to companies for digitising their operational processes. Under this 
funding, the Investment and Development Agency of Latvia (LIAA) will be able to provide grants to at 
least 1 750 businesses for internal business process digitalisation.  

By  September  2024,  LIAA  had  issued  support  to 100  businesses, totalling EUR  8.6  million19.  This 
includes funding for ready-made solutions, hardware, sensors, equipment, software, IT infrastructure, 
licences,  installation,  and  customisation,  as  well  as  related  consultations.  Moreover,  non-financial 
support will be provided to 300 companies for initial and follow-up digital maturity tests, development 
of digital roadmaps, and expert opinions.  

Romanian grant scheme helping companies adopt digital technologies: 

Within its RRP, Romania introduced an aid scheme for the digitalisation of SMEs, including a grant 
scheme of up to EUR 100 000 per firm to help SMEs adopt digital technologies.20 The Authority for the 
Digitalisation of  Romania announced  the  eligibility for  188  SMEs  registered  in the  project  ‘Skills  in 
advanced technologies for SMEs’, related to Investment 19, Component 7 (Digital Transformation) of 
the National Recovery and Resilience Plan.21 

Croatia’s digitalisation vouchers: 

As part of the country’s Recovery and Resilience Plan, Croatia has identified an investment scheme in 
the form of digitalisation vouchers to support SMEs in developing a digital business model, covering 
training and services for improving digital skills, including those related to cloud. By the end of 2024, 
several SMEs had participated and benefited from a call on increasing their level of digital maturity by 

19Ministry  of  Economics  of  Latvia,  Over  EUR  27  Million  Available  for  Business  Process  Digitalization,  Press  release,  26 
November 2024  
20 Ministry of Investments and European Projects of Romania, PNRR: The Guide ‘Digitisation of SMEs – grant of up to 100 000 
euros per company to support SMEs in the adoption of digital technologies’ has been updated, Press release, 20 May 2024  
21Authority  for  the  Digitalisation  of  Romania,  The  first  SMEs  declared  eligible  in  the  advanced  technology  skills  training 
programme, 2025  

28 

 
 
developing  digital  business  models,  strengthening  capacities  for  implementing  digitalisation  and 
digital transformation, and improving cybersecurity22.  

In  addition  to  these  examples,  individual  Member  States  have  taken  action  to  support  the 
advancement  of  their  national  cloud  industry,  which  may  have  indirect  positive  effects  on  cloud 
uptake. An example  of this is the  French  call for projects  ‘Strengthening the cloud service  offer’23, 
aiming to strengthen trusted cloud services24. 

The future Cloud and AI Development Act equip the EU with the infrastructure needed to meet the 
computing  demands  of  businesses.  Sufficient  infrastructure  capacity  is  a  prerequisite  for  the 
increasing adoption of cloud services in the EU. 

SUMMARY ASSESSMENT: Limited progress 

22FondoviEU, Croatia, Details of the call ‘VOUCHERS FOR DIGITALIZATION 2 - Voucher for Complex Digital Solutions (VSD)’ - 
label ‘NPOO. C1.1.2.R3-I2.01’ - NRRP (National Recovery and Resilience Plan), 2025 
23 Direction Interministerielle du Numerique, France, France 2030 : la stratégie nationale cloud s’enrichit d’un nouvel appel 
à projets, 2024 
24 BPI France, Call for projects ‘Strengthening the cloud service offering’, 2025  

29 

 
 
 
 
6.3  Member States should boost the uptake of new advanced cloud-edge solutions among 
SMEs by setting up strategies and activities to fully exploit the IPCEI-CIS, by leveraging 
the complementarity activities of the Exploitation Office and the spillover commitments 
already undertaken by the direct participants in this IPCEI CIS. The Member States that 
do not participate in this IPCEI should actively seek out ways of engagement to benefit 
from spillovers, liaise with and possibly establish, post approval decisions, collaborations 
with its interested direct participants or indirect partners  

PROGRESS AND STATE OF PLAY 

As of June 2025, a total of 19 companies from seven Member States (France, Germany, Hungary, Italy, 
the Netherlands, Poland, and Spain) are participating in the IPCEI Next Generation Cloud Infrastructure 
and Services (IPCEI-CIS). This project is meant to put Europe on the path to the cloud infrastructure of 
the future.  

To this end, the seven participating Member States are providing up to EUR 1.2 billion in public funding 
in the coming years, which is expected to unlock an additional EUR 1.4 billion in private investment.  

The  focus  lies  on  R&D&I  activities  and  the  first  industrial  deployment  of  the  outcomes.  Since  the 
kick-off in March 2024, IPCEI-CIS is in its project  implementation phase  (R&D&I  and  first  industrial 
deployment), which will last until 2031 (as projects from different companies have different durations, 
this is the latest permissible end date for a participating project).  

The milestones during the implementation phase vary from one participating  company to another. 
Generally,  the  phase  consists  of  the  following  steps:  launch  of  R&D&I  projects:  their  research and 
development activities; and the first industrial deployment of the results, including by developing use 
cases in many of the projects.  

The  IPCEI-CIS  commits  to  delivering  important  positive  spill-over  effects  across  the  EU,  beyond 
participating Member States and companies. Dedicated positive spill-over activities by the companies 
(direct participants) in the IPCEI-CIS will play an important role25. The Cloud Infrastructure and Services 
Exploitation Resources Office (CISERO) funded under the Digital Europe Programme, may provide, if 
and where necessary, assistance to the IPCEI-CIS participating companies in delivering their spill-over 
actions.  

Over the course of 2025, CISERO will contribute to the creation of a catalogue of the solutions and 
other outcomes delivered as part of the IPCEI-CIS; a catalogue of best practices for the adoption of 
IPCEI-CIS results; a technological and business roadmap to support sustainability strategies for these 
results; and will help put in place a platform to facilitate collaboration among interested stakeholders 
and participants of the IPCEI-CIS project.  

CISERO may complement IPCEI-CIS actions as an additional contact point, besides the primary direct 
contact with the IPCEI CIS coordinators and governing bodies, as announced on the IPCEI CIS website 

25 For example they will (i) beyond their usual open-source software practices and business models, grant permissive, non-
restrictive open-source software licenses to any interested party and actively engage with and contribute to the development 
of open-source communities; (ii) provide access to interested parties to at least 20% of the capacity of the edge nodes and 
laboratories employed in their projects; (iii) expand the developed technologies to additional sectors of the economy ; (iv) 
perform targeted trainings, produce self-standing technical materials, engage in conferences, publications, partnerships with 
universities and research organisations; and (v) license intellectual property rights at fair, reasonable, and non-discriminatory 
terms. 

30 

 
 
www.8ra.com, for non-participating Member States and industry to learn more about and ultimately 
benefit from the outcomes of the IPCEI-CIS.  

Given that the activities under IPCEI-CIS are still in the early phases of project implementation, it is too 
early  to  evaluate  whether  participating  Member  States  are  boosting  the  uptake  of  the  project 
outcomes. And given that the activities of CISERO are expected to take shape over the course of 2025, 
it is equally too early to evaluate whether non-participating Member States are seeking out ways of 
engagement through this additional intermediary.  

SUMMARY ASSESSMENT: Limited progress 

31 

 
 
 
6.4  Member States should continue to foster secure and trusted data sharing, in particular 
by supporting the deployment of common European data spaces and by implementing 
relevant  data  legislation  such  as  the  Data  Governance  Act  and  the  Data  Act.  In  this 
context, Member States should also take full advantage of relevant newly created EDICs 
(ALT-EDIC and LDT CitiVERSE EDIC), as well as speed up the creation of other relevant 
EDICs in preparation (e.g., Mobility and Logistics EDIC, the EDIC for Digital Commons)  

PROGRESS AND STATE OF PLAY 

Both the Data Governance Act (Regulation (EU) 2022/868) and Data Act (Regulation (EU) 2023/2854) 
provide  rules  governing  the  access  to  data,  in  particular  industrial  data,  as  well  as  governance 
structures to facilitate trustworthy and secure data sharing. Already, a number of these governance 
structures are being implemented by Member States26. Even so, some Member States are still in the 
process of  designating  competent  authorities  in  accordance  with  the  Data  Governance  Act.  This  is 
crucial  for  enforcing  the  Data  Governance  Act  at  national  level,  and  needed  for  data  intermediary 
service providers and data altruism organisations to register.  

For  similar  reasons,  it  will  be  equally  important  that  the  Member  States  promptly  designate 
competent authorities for the Data Act, which shall apply from 12 September 2025.  

A good example is the European Legal Data Space, which aims at providing easily accessible, reusable, 
interoperable data in the area of legislation and case law across the EU. This data can be then used in 
decision making, research and the development of innovative legal tools (including AI tools tailored to 
the needs of the judicial sector).  

However,  while  EU  laws  and  case  law  are  already  available,  national  data  rely  on  Member  States’ 
willingness to make the data available in the standardised formats (ELI and ECLI) and in a generalised 
manner. Currently, the availability of national data remains very fragmented and various efforts are 
being made at EU level to support Member States (including through funding). 

Additionally,  within  the  Digital  Europe  Programme  the  focus  is  on  deploying  data  spaces  and 
successfully  exploiting  high-value  datasets.  Over  EUR  350  million  have  already  been  invested  in 
fostering  data  sharing  and  the  development  of  a  European  Data  Infrastructure,  not  counting  the 
substantial funding directed towards Simpl software as the cloud middleware for data spaces.  

This covers a dedicated call on fostering the exploitation of high-value datasets and several projects 
creating a roadmap for developing 14 data spaces, all in areas of industrial importance such as the 
Green Deal, manufacturing, mobility, healthcare, agriculture or tourism.  

Initiatives  connected  to  the  coordination  of  data  spaces,  such  as  the  Data  Spaces  Support  Centre 
(DSSC)  and  the  European  Data  Innovation  Board,  continue  to  play  an  essential  role  in  creating 
networks of stakeholders, ensuring interoperability across all data spaces and maximising impact.  

Membership of the ALT-EDIC and of the LDT CitiVERSE EDIC has been expanding (25 Member States 
are participating in the ALT-EDIC and 14 in the LDT CitiVERSE EDIC, compared to 17 and 11 Member 
States in spring 2024). New EDICs are in the process of being set up, aiming to support secure and 
trusted data sharing in different domains (mobility and logistics, digital commons or health).  

26 European Commission, National competent bodies and authorities under the Data Governance Act, 2023.  

32 

 
 
To ensure European AI companies benefit from an expanding data ecosystem, the Commission will 
build on past and future initiatives to enhance data availability for AI. In this context, the forthcoming 
Data Union Strategy is intended to explore new and improved mechanisms to facilitate access to and 
use of data for AI development.  

The Data Union  Strategy  could  include  several  practical  steps:  listening  closely to companies'  data 
needs and finding ways to meet them, exploring ways to increase the availability of high-quality data, 
including potential investment to scale up data use and AI development in Europe.  

Beyond  making  more  data  available,  the  strategy  should  also  focus  on  cutting  unnecessary 
bureaucracy. It should simplify how businesses can meet EU data rules, making it easier for them to 
share and use data for AI. At the same time, the strategy is poised to look at how Europe can attract 
more  valuable  data  while  ensuring  that  sensitive  European  data  are  protected  when  shared 
internationally. 

A broad consultation  is scheduled to  be initiated in the second quarter of 2025  to assess the  data 
needs  of  generative  AI  companies  and  other  key  stakeholders,  ensuring  that  the  strategy  is  well-
aligned  with  industry  demands  and  technological  advancements.  In  parallel,  building  on  the 
foundation of common European data spaces, it will focus on promoting the use of data spaces by AI 
factories,  leveraging  initiatives  such  as  the  Data  Spaces  Support  Centre  to  facilitate  adoption  and 
integration.  

To ensure trust in new technologies, including AI and Generative AI, the consistent and harmonised 
enforcement  of  the  GDPR  is  essential,  including  its  rules  on  international  transfers  in  line  with 
priorities identified in the Second report on the application of the GDPR. 

In addition, through the Digital Europe Programme, the Commission will invest EUR 200 million over 
the  next  three  years  in  deploying  data  infrastructures  to  support  AI  factories.  This  will  include 
developing data spaces in critical sectors and further enhancing Simpl middleware software, and an 
additional EUR 100 million are earmarked for big data analytics research under Horizon Europe. 

SUMMARY ASSESSMENT: Limited progress 

33 

 
7  Digitalisation of SMEs  

7.1  Member States should strengthen their policies and  incentives for accelerating SMEs’ 
digitalisation,  in  particular  with  specific  strategies,  sharing  of  best  practices  and 
leveraging common projects. 

Member States should increase linkages between EDIHs and other networks (e.g., local 
and  national  digitalisation  frameworks,  Testing  and  Experimentation  Facilities, 
National/European  Cybersecurity  Competence  Centres  and  High-Performance 
Computing centres) and communities. The goal is to ensure a cohesive ecosystem that 
offers  comprehensive  digital  transformation  services  across  various  technologies  and 
sectors  

PROGRESS AND STATE OF PLAY 

Most EU countries are making strides in business digitalisation. There are considerable opportunities 
to further enhance this progress through various policy support measures already adopted, including 
sector-specific initiatives, as well as through support of the extensive EDIH Network. 

One  area  of  progress  is  the  European  Digital  Innovation  Hubs  (EDIHs)  network,  a  pan-European 
ecosystem supporting SMEs, mid-caps, and public sector organisations in their digital transformation. 
By  bridging  the  gap  between  business  needs  and  digital  technologies,  EDIHs  play  a  crucial  role  in 
fostering innovation, enhancing competitiveness, and supporting the EU’s digital transition goals. 

Over  the  last  year,  the  European  Digital  Innovation  Hubs  (EDIHs)  Network  has  expanded  its 
collaboration  with  TEFs,  Cybersecurity  Competence  Centres,  High-Performance  Computing  (HPC) 
Centres, and national digitalisation frameworks. These  connections are  critical for SMEs, mid-caps, 
and public sector organisations (PSOs) to access integrated digitalisation services. 

TEF-EDIH collaboration has grown, ensuring AI, robotics, and automation technologies can be tested 
before full-scale deployment. Currently, more than 80% of EDIHs provide AI-related services, aligning 
increasingly  with  TEFs  to  deliver  structured  AI  validation  for  SMEs  in  manufacturing,  agri-tech, 
healthcare and smart cities fields. 

Cybersecurity Competence Centres and EDIHs are strengthening cyber resilience initiatives. More than 
half  of  EDIHs  offer  cybersecurity  services,  providing  SMEs  with  threat  assessments,  penetration 
testing, and compliance guidance under the Cyber Resilience Act. 

HPC  Centres are increasingly  accessible to SMEs through EDIHs.  More than 30% of EDIHs facilitate 
HPC-powered  AI  applications,  big  data  processing,  and  computational  modelling,  particularly  in 
biotech, climate simulation, and precision manufacturing. 

Cross-border  services  remain  limited,  with  only  2%  of  EDIHs  services  actively  delivered  to  SMEs 
outside their own country. However, more than a quarter of the 37 countries in the EDIH Network, 
comprising the EU Member States and 10 associated countries to the Digital Europe Programme (DEP) 
- Norway, Iceland and Lichtenstein, along with the seven newly associated countries (Türkiye, Serbia, 
Albania,  Ukraine,  Kosovo,  Montenegro,  and  North  Macedonia)  -  have  EDIHs  offering  interregional 
digitalisation services, reflecting a growing trend toward pan-European cooperation.  

34 

 
The  recent  network  expansion  to  include  EDIHs  and  Seals  of  Excellence  from  these  associated 
countries  is  expected  to  strengthen  international  cooperation  and  enhance  digital  transformation 
support across regions and national borders. 

EDIHs  are  now  well  integrated  into  national  and  regional  digitalisation  frameworks,  aligning  with 
public  funding  programmes  and  smart  specialisation  strategies.  This  ensures  SMEs  receive  more 
coordinated  access  to  technical  support,  innovation  funding,  and  digital  skills  training.  The  hubs 
facilitate networking, matchmaking and collaboration between businesses, research institutions, and 
solution providers, fostering synergies within the tech ecosystem. 

Furthermore,  AI  factories,  launched  by  EuroHPC  in  December  2024,  are  expected  to  accelerate  AI 
adoption.  These  new  facilities  will  provide  SMEs,  start-ups,  and  researchers  with  access  to  AI 
supercomputing  resources,  ensuring  advanced  AI  solutions  are  developed  and tested  in  alignment 
with European standards and values.    

A more structured EDIH policy approach is being introduced through new calls for tender, ensuring 
the continuation of the network beyond 2025 and for the next three years, as the first funding period 
comes to an end. These calls aim to strengthen the network with AI foundations and further expand 
the  EDIH  Network  to  newly  associated  DEP  countries.  They  are  designed  to  enhance  coordination 
between  EDIHs,  AI  factories,  TEFs,  HPC  Centres,  and  national  digitalisation  agencies,  ensuring  a 
cohesive, pan-European digital transformation strategy. 

SUMMARY ASSESSMENT: Notable progress 

35 

 
 
 
7.2  Member States are in particular encouraged to prioritise the integration and adoption 
of  AI  within  the  EDIH  framework.  This  includes  providing  specialised  AI  services, 
facilitating access to, for example, AI Testing and Experimentation Facilities and the AI 
on demand platform   

PROGRESS AND STATE OF PLAY 

To  accelerate  AI  adoption,  EU  Member  States  have  introduced  strategic  measures  that  foster 
collaboration, provide financial support, and promote knowledge-sharing. One of the key initiatives 
that will promote the AI adoption and deployment is definitively the EDIHs network, jointly supported 
at the EU level, national and regional and local levels. 

Over  the  last  12  months,  the  EDIHs  have  progressively  evolved  into  key  players  within  the  AI 
ecosystem, helping SMEs, mid-caps, and PSOs integrate AI into their digital transformation, based on 
local needs. The new calls for consolidation and expansion of the network in 2025-2026 will further 
accelerate AI adoption, strengthening the EDIHs as centres for AI innovation and deployment. The EU 
is intensifying its focus on AI within the EDIH framework, expanding access to specialised services, 
Testing  and  Experimentation  Facilities  (TEFs),  and  the  AI-on-Demand  platform,  ensuring  a  more 
structured and effective AI roll-out across sectors. 

Over 80% of EDIHs currently provide AI-related services, supporting SMEs in AI adoption, testing, and 
deployment.  AI  services  are  now  available  in  the  vast  majority  of  the  regions  covered  by  EDIHs, 
ensuring broad access. 

As  part  of  the  AI  ecosystem,  EDIHs  work  more  and  more  closely  with  TEFs  to  provide  AI  testing 
environments. SMEs can experiment with AI-driven automation, robotics, and digital twins, to ensure 
safe and efficient AI integration. 

The AI-on-Demand platform serves as a central hub for AI models, tools, and computing resources.  

High-Performance  Computing  (HPC)  Centres,  supporting  more  than  30%  of  EDIHs,  enable  SMEs  to 
leverage  supercomputing  for  AI-intensive  applications  in  biotech,  climate  modelling,  and  smart 
manufacturing. 

Cybersecurity Competence Centres and EDIHs collaborate to ensure AI adoption meets EU security 
and compliance requirements. More than half of the EDIHs offer AI-driven cybersecurity solutions, 
helping SMEs implement secure and compliant AI systems. 

Despite progress, cross-border AI service delivery remains low at around 2%, highlighting the need for 
stronger cooperation between Member States. 

SUMMARY ASSESSMENT: Limited progress 

36 

 
 
 
7.3  Member  States  are  encouraged  to  address  the  critical  challenge  of  financing  by 
establishing  EDIHs  as  primary  gateways  for  businesses  to  access  public  procurement 
opportunities  in  digital  services  and  goods,  and venture  capital,  facilitate connections 
with financial intermediaries and leverage EU support  

PROGRESS AND STATE OF PLAY 

The EDIH Network leveraged synergy funding, primarily from ERDF (European Regional Development 
Fund) and RRF (Recovery and Resilience Facility), to co-finance its initiatives. More specifically, DEP 
(Digital Europe Programme) covers 50% of project costs, requiring EDIHs to secure additional funding. 
The co-funding sources for the EDIHs have been so far as follows: 32% chose RRF; 22% opted for ERDF; 
15%  are  using national funding and 21% mix funding sources. 11%  rely on own funding  or non-EU 
regional funding.  

According to JRC research, EDIHs that relied on RRF and ERDF experienced the most delays, while 
those with national or mixed funding had fewer issues.  

This new research indicates that better streamlining of co-funding mechanisms between the Member 
States and the EU is paramount for the success of the EDIHs network. 

In terms of concrete results provided by the EDIHs, over the last year, European Digital Innovation 
Hubs (EDIHs) have reinforced their position as financial brokers (‘sherpas’) for SMEs, mid-caps, and 
PSOs, guiding them through funding, procurement, and investment opportunities. 

Public Procurement and Financial Services – According to data reported by the EDIHs in 2024, 17% of 
EDIHs  provide  direct  funding  support,  helping  SMEs  access  public  procurement,  EU  grants,  and 
national  financial  schemes.  EDIHs  assist  in  navigating  digital  tenders,  compliance  frameworks,  and 
contract acquisition. 

Financial Matchmaking and Investment Access - According to data reported by the EDIHs in 2024, 
one-third  of  the  EDIHs  are  involved  in  financial  matchmaking,  facilitating  direct  connections  with 
financial intermediaries, venture capital firms as well as regional investment funds and increasing SME 
access to private sector financing. 

Therefore, all in all, half of the EDIHs play a role in financial support, either through direct funding 
assistance or investment facilitation. 

Pooling Financial Guidance and Innovative Funding Models - EDIHs are pooling financial intelligence 
by  country  and  consolidating  national  co-financing  opportunities,  EU  investment  instruments,  and 
local venture capital programmes. Some EDIHs are testing token-based funding models, allowing SMEs 
to exchange digital credits for financial advisory services and investment-readiness programmes. 

Despite progress, cross-border financial access remains low at 2%, highlighting the need for stronger 
pan-European investment linkages. 

SUMMARY ASSESSMENT: Significant progress 

37 

 
 
 
7.4  Member  States  should  intensify  their  activities  to  foster  dissemination  of  the  use  of 
digital  tools  by  SMEs,  in  particular  with  local  actors  (business  organisation,  cities, 
universities, etc.)  

PROGRESS AND STATE OF PLAY 

Beyond information described in the previous recommendation that relates to the dissemination of 
digital  technologies  –  notably  through  EDIH  and  testing  and  experimenting  facilities  that  are 
contributing  to  the  use  of  digital  tools  by  SMEs  –  no  specific  and  relevant  information  has  been 
collected. 

SUMMARY ASSESSMENT: No progress 

38 

 
 
 
8  Unicorns  

8.1  Member States should mobilise public policies – especially in the area of tech transfer 
and the use of the public procurement budget to procure innovations from start-ups – 
to  foster  the  scaling  up  of  start-ups  and  facilitate  the  creation  of  spin-offs  from 
universities  and  research  centres.  Progress  in  these  areas  should  be  monitored. 

Member States should introduce or improve policy initiatives that aim to increase the 
amount  and  diversity  of  private  capital  (for  example  from  national  pension  funds) 
available for co-investing in high-growth start-ups  

PROGRESS AND STATE OF PLAY 

Developments in 2024 in supporting of the Digital Decade unicorn goal include the following: 

• 

• 

• 

The European Tech Champions Initiative (ETCI), a ‘fund of funds’ launched in 2023 by several 
Member  States  and  the  EIB,  made  progress  in  2024  in  supporting  European  technology 
scale-ups.  ETCI  has  so  far  backed  8  funds  with  an  amount  of  more  than  EUR  2  billion  in 
commitments.  This  investment  has  mobilised  five  times  that:  EUR  10  billion  in  combined 
public and private sector resources. To date, 16 tech scale-up investments have been made in 
France,  Germany,  Italy,  the  Netherlands,  and  Spain,  across  various  sectors,  including 
cybersecurity, artificial intelligence, and deep tech. 

In 2024, three more Member States formally joined the European Startup Nations Alliance 
(ESNA), the Member State-driven initiative promoting the sharing and implementation of best 
policy  practice  for  start-ups.  Membership  of  ESNA  is  now  at  21  of  27  EU  Member  States, 
representing 93% of EU's population, and 86% of its GDP. This expansion of ESNA membership 
signals  a  growing  commitment  by  EU  countries  to  implement,  under  national  direction, 
growth-friendly policies and programmes for start-ups.  

In terms of tech transfer and spin-off creation, the ‘2024 EU Startup Nations’ report (published 
by  ESNA)  outlined that  Member  States  made  progress  in 2024  on  the  indicator  relating  to 
delivery of policies that support the smooth transfer of research developed in universities to 
spin-offs. In aggregate, Member States scored 77% on this indicator, an increase on the 71% 
achieved in 2023). Nevertheless, there is still considerable opportunity for growth in spin-off 
creation: while 28% of European researchers express interest in starting a spin-off, only 3% 
ultimately become academic entrepreneurs (source: WIPO, 2024). 

•  With over EUR 300 billion of a growth funding gap compared to the US, the EU has less capital 
to allocate to its companies with unicorn potential. EU pension funds can play a role to address 
this given their EUR 3 trillion in assets under management by increasing their tiny (approx. 
0.01%) allocation to venture capital. There are initiatives in some countries to address this 
opportunity (for example ZuFinG II in Germany, Tibi 2 in France and Italy's amendment to the 
Decreto Concorrenza requiring funds to invest 10% of their assets in the real economy). 

•  The Commission has announced that in 2025 it would launch a Startup Scaleup Strategy 27 that 
is expected to address the difficulties that European start-ups and scaleups face in accessing 

27 European Commission, Towards an EU Startup and Scaleup Strategy, 2025.  

39 

 
 
 
capital, markets, services, infrastructure as well as talent needed to enable them to thrive in 
Europe and compete globally.  

•  The Commission is currently preparing a proposal for a 28th regime aimed at making it possible 
for innovative companies to benefit from a single, harmonised set of EU-wide rules wherever 
they invest and operate in the single market as announced in the Competitiveness Compass 
28. 

In Q3 2025 the Commission is expected to launch the Apply AI Strategy which will outline the EU level 
action needed to stimulate widespread adoption of AI. This will also address the role of start-ups in 
driving uptake of AI in Europe’s key industrial verticals.  

SUMMARY ASSESSMENT: Significant progress 

28  European  Startup  Nations  Alliance,  EU  Startup  Nations  Standard  Report  2024,  2025;  European  Commission,  Spin-offs: 
Driving  innovation  across  the  EU-27,  2025;  European  Commission,  EU-funded  startups  drive  technological  sovereignty  in 
Europe, 2025. 

40 

 
 
 
 
9  Cybersecurity  

9.1  Member States should continue their efforts to take specific measures to address the 

cybersecurity skills gap 

PROGRESS AND STATE OF PLAY 

According to cybersecurity professionals’ association ISC2, a Cybersecurity Skills Academy pledger, the 
growth of the cybersecurity workforce size in the EU in 2024 slowed while  demand for these skills 
continued to increase29. While the overall workforce needs in the EU remained steady between 2022 
and 2024, ranging between 1.15 M and 1.25 M, the gap in the cybersecurity workforce grew from an 
estimated 260 000 professionals to 274 000 in 2023 and to 299 000 in 2024.  

The  communication  on  a  Cybersecurity  Skills  Academy30  encouraged  Member  States  to  set  up  a 
European  Digital  Infrastructure  Consortium  (EDIC)  addressing  cybersecurity  skills,  an  area  of 
cooperation  foreseen  in  the  Digital  Decade  Policy  Programme  2030.  With  the  support  of  the 
Commission on awareness-raising about the project, Member States, under the leadership of Greece, 
have continued working on the project and the Commission has invested EUR 10 million in support of 
the  implementation  of  the  Cybersecurity  Skills  Academy  under  Digital  Europe  Programme  calls  in 
2024.  

Furthermore, the Polish Presidency of the Council has  identified that  ‘the backbone of an efficient 
cybersecurity system is appropriately qualified professionals’31, making cybersecurity skills a priority 
of  their  Presidency.  Following  up  on  a  workshop  with  Member  States  held  under  the  Hungarian 
Presidency  of  the  Council  and  co-organised  with  the  Commission  and  European  Union  Agency  for 
Cybersecurity, in February 2025 the Polish Presidency of the Council hosted a dedicated debate under 
the Horizontal Working Party on Cyber Issues. 

In parallel, National Coordination Centres (NCCs), in the  framework of the European Cybersecurity 
Competence  Centre  (ECCC),  are  contributing  to  the  implementation  of  actions  laid  down  in  the 
communication on  a  Cybersecurity  Skills  Academy  –  such  as  building  a  repository  of  cybersecurity 
training content and certifications, identifying funds invested in cybersecurity, or defining indicators 
to monitor the cybersecurity workforce. 

The  European  Cybersecurity  Skills  Conference  co-organised  in  September  2024  by  the  Hungarian 
Presidency of the Council and the ENISA32 further provided an opportunity for Member States and 
other stakeholders (industry, European Cybersecurity Competence Centre, etc.) to discuss and present 
ongoing  activities  and  explore  synergies  between  them,  in  particular  to  advance  the  work  on  an 
attestation scheme for cybersecurity skills.  

Lastly, in December 2024, building on the Cybersecurity Skills Academy’s call for action directed at 
industry, which has resulted in a growing pledgers community, the European Commission published a 
call  for  expression  of  interest  directed  at  higher  education  institutions,  vocational  education  and 

29 ISC2, First Look at the 2024 Cybersecurity Workforce Survey, 2024 
30 European Commission, Communication COM(2023) 207 final on the Cybersecurity Skills Academy 
31 Polish Presidency of the Council of the EU, Programme of the Presidency 
32 ENISA, European Cybersecurity Skills Conference 2024, 2024 

41 

 
 
training  providers  and  European  Universities  alliances33,  to  create  an  Industry-Academia  Network 
addressing skills development, to grow the cybersecurity workforce in Europe. 

The formal application for the setting up of the Cybersecurity Skills Coalition EDIC is expected in 2025. 

In  2025,  the  European  Commission  should 
launch  the  Industry-Academia  Network  of  the 
Cybersecurity Skills Academy, addressing skills development, to grow the cybersecurity workforce in 
Europe. 

As part of the Cybersecurity Skills Academy implementation, the ECCC is working on a report mapping 
funds  invested  at  EU  and  national  level  in  cybersecurity  skills.  Member  States  in  the  ECCC  will 
ultimately decide whether this report can, in full, in parts or at all, be made public. 

SUMMARY ASSESSMENT: Limited progress 

33 European Commission, The Commission launches Industry-Academia Network to bridge cybersecurity skills gap, 2024 

42 

 
 
 
 
9.2  Member  States  that  have  not  yet  implemented  the  EU  toolbox  for  5G  Cybersecurity 
should urgently adopt relevant measures to quickly and effectively address cybersecurity 
risks  

PROGRESS AND STATE OF PLAY 

A  vast  majority  of  Member  States  have  reinforced  or  are  in  the  process  of  reinforcing  security 
requirements for 5G networks based on the EU Toolbox. However, some of the key measures have 
not  been  fully  implemented  in  all  Member  States.  In  particular,  while  most  Member  States  have 
legislative  powers  to  perform  a  risk  assessment  of  suppliers  and  issue  restrictions,  only  13  have 
imposed restrictions on high-risk suppliers.   

This  situation  creates  a  significant  risk  of  strategic  dependency  on  high-risk  suppliers  in  the  single 
market and the EU’s 5G networks being subject to interference from non-EU countries. This could also 
affect future 6G infrastructure, which could be built on 5G legacy networks from high-risk suppliers.  

In  light  of  this  situation,  it  is  now  of  utmost  importance  to  avoid  critical  dependencies  on  single 
suppliers,  de-risk  our  supply  chain  from  high-risk  suppliers  and  secure  our  critical  infrastructure. 
Member States should therefore achieve the full implementation of the measures recommended via 
the Toolbox without further delay. 

In addition, given the importance of increasing the effectiveness and consistency of implementation 
by Member States of the EU Toolbox measures, the Commission is looking at further action to enhance 
the resilience of the single market, including exploring possible legislative avenues. 

More  information on the state of play of  the  5G Toolbox  implementation can be  found in the NIS 
Cooperation Group second progress report on the 5G Toolbox implementation from June 2023. 

In addition, in  its  Communication from June  202334, the Commission assessed two 5G suppliers as 
presenting materially higher risks than other suppliers and committed to reflect this assessment in all 
relevant  EU  funding  programmes  and  instruments,  as  well  as  in  its  corporate  communications 
networks. Since then, the Commission has included strong security requirements to exclude high-risk 
suppliers  from  participating  in  EU  projects  or  procurements.  It  has  also  taken  steps  to  apply  its 
commitment to its corporate communication networks.  

SUMMARY ASSESSMENT: Limited progress 

34 European Commission, C(2023) 4049 final. 

43 

 
 
 
 
10  Basic skills  

10.1  Member States should prioritise investment in digital education and skills in line with the 
Council Recommendation on improving the provision of digital skills and competences 
in education and training, including targeted policies for groups most in need including 
vulnerable  groups,  the  older  population,  people  with  little  or  no  formal  education, 
people living in rural areas and people with disabilities  

PROGRESS AND STATE OF PLAY 

Member  States  are  actively  engaged  with  the  Digital  Skills  and  Jobs  Platform,  operated  by  the 
European Commission. This platform provides Member States with a one-stop-shop for high-quality 
information  on  data,  training  initiatives  and  resources  for  digital  skills  at  all  levels,  from  basic  to 
advanced. In 2024, the platform was visited 285 000 times. It is home to the Digital Skills and Jobs 
Coalition, consisting of over 15 000 registered stakeholders, and connects 25 National Digital Skills 
and Jobs Coalitions, representing the Member States. In addition, 22 national websites are connected 
to the  core  platform, continuously  updating information on national initiatives. The Commission is 
also supporting the further development of the National Coalitions and exploring possibilities to set 
up new ones.  

Under  the  Digital  Decade  Policy  Programme,  Member  States  began  using  the  Best  Practice 
Accelerator (BPA)35 to share best practices and experiences with overcoming digital policy challenges, 
including  the  achievement of  basic or  advanced digital skills. In  July  2024,  under the leadership of 
Slovenia,  the  Digital  Skills  Cluster  was  launched,  sharing  over  25  replicable  and  concrete  policy 
measures  to  increase  basic  skills  across  age  groups  and  geographical  areas.  Additionally,  on 
4 July 2024, the winners of the 2024 edition of the European Digital Skills Awards were announced. 
Out of 267 applications, five outstanding projects were chosen, showcasing innovative approaches by 
Member  States  to  empower  individuals  with  digital  competences,  and  foster  digital  literacy  and 
inclusion. 

SUMMARY ASSESSMENT: Limited progress 

35 The Best Practice Accelerator (BPA) is a platform that enables Member States to share successful measures and challenges 
encountered in their efforts to meet their Digital Decade targets and objectives. Best practices are available to all Member 
States  via  the  BPA  Repository  and  showcased  in  regular  workshops,  currently focused  on three  thematic  clusters:  Digital 
Skills, Green IT, and the Uptake of Digital Technologies. 

44 

 
 
11  ICT specialists 

11.1  . Member States should swiftly develop initiatives, strengthen their policy and prioritise 
action  in  line  with  the  specific  recommendations  for  addressing  the  shortage  of  ICT 
professionals in the Council Recommendation on improving the provision of digital skills 
and  competences  in  education  and  training.  They  should  in  particular  support  early 
exposure of young people, particularly girls, to STEM, promote VET and lifelong learning 
in  the  domain  of  ICT,  increase  the  academic  offer  in  advanced  digital  skills,  facilitate 
collaboration among higher education institutions, boost industry integration and foster 
diversity and inclusion, particularly of women 

PROGRESS AND STATE OF PLAY 

Since  July  2024,  Member  States  have  been expanding  their academic  offerings  in  advanced  digital 
skills,  focusing  on  creating  joint  programmes  to  foster  collaboration  among  higher  education 
institutions.  They  also  provide  short-term  training  programmes  in key  digital areas  to  support  and 
promote lifelong learning in the area of ICT. At the same time, the community of stakeholders involved 
in  developing  state-of-the-art  education  and  training  programmes  has  grown  to  more  than  435 
organisations.  This  community  includes  147  higher  or  secondary  education  establishments,  165 
private companies and training providers, and 45 research organisations, from 26 Member States.  

Member  States  have  actively  engaged  in  EU  Code  Week,  an  initiative  aimed  at  promoting  early 
exposure to STEM, particularly for young girls. In 2024, over 70 000 activities relating to coding and 
algorithmic  thinking  were  organised  across  all  27  Member  States,  attracting  two  million  young 
participants, with girls representing 48% of the total. In addition, on 4 July 2024, the winners of the 
European Digital Skills Awards were announced. Of the 267 applications, five outstanding projects 
were selected, highlighting innovative strategies used in Member States to empower individuals with 
digital competences, including initiatives to support women and girls in becoming ICT professionals. 

The Digital Decade’s Best Practice Accelerator has helped Member States to share initiatives aimed at 
increasing the participation of women in digital studies and careers. Notable best practices include an 
initiative by the Technological University in Dublin, Ireland,  aimed at  encouraging more  women to 
pursue studies in computer science. Additionally, the ‘Women in Digital’ project by Croatia’s Ministry 
of Justice, Public Administration and Digital Transformation has also been highlighted as a key effort 
in this area. 

As  part  of  the  European   Quantum  Declaration,  Member  States  are  currently  discussing  their 
participation in quantum competence clusters of the Quantum Technologies Coordination Group. The 
aim of these clusters is to promote industry-focused research, innovation, and training. These efforts 
are integral to building a cohesive ecosystem across Member States and at the EU level, enhancing 
collaboration and development in quantum technologies. 

SUMMARY ASSESSMENT: Limited progress 

45 

 
 
 
12  EU Digital Identity Framework  

12.1  Member States should give priority to the development of concrete use cases to support 
users and private and public service providers in the use of the EU digital identity wallet 
and trust services based on the European Digital Identity Framework 

PROGRESS AND STATE OF PLAY 

As of May 2024, following the entry into force of Regulation (EU) 2024/1183 establishing the European 
Digital Identity (EUDI)  Framework, Member States  are actively  developing  their own EUDI  Wallets, 
with plans to launch them by the end of 2026. These efforts are supported by the adoption of rules in 
November 2024 and April 2025, which outline the core functionalities and certification requirements 
of  EUDI  Wallets,  and  the  adoption  of  Directive  EU  2025/2536,  which  introduces  the  EU  Company 
Certificate and digital EU power of attorney, both designed to work with the EU Digital Identity Wallet. 

Under the Digital Europe Programme, Member States  are participating  in  large-scale pilot projects 
aimed  at  testing  EUDI  Wallets  in  everyday  scenarios  that  benefit  citizens,  businesses,  and 
governments. Since April 2023, these projects have involved over 350 private and public entities from 
almost all EU Member States, as well as Norway, Iceland, and Ukraine, exploring 11 different use 
cases. 

•  Nordic-Baltic eID (NOBID), involving Nordic and Baltic countries along with Italy and Germany, 

is currently piloting the use of EUDI Wallets for SEPA Instant payments. 

•  Potential  involves  over  140  public  and  private  partners  from  17  EU  Member  States  and 
Ukraine. It aims to pilot six use cases: access to online public services, mobile driving licences, 
opening of bank accounts, SIM card registration, e-signatures and e-prescriptions. 

•  EU  Digital  Identity  Wallet  Consortium  (EWC),  led  by  Sweden,  focuses  on  testing  three  use 
cases: digital travel credentials, payments and organisation identity. This large-scale project 
(LSP) involves more than 50 public and private partners.  

•  Digital Credentials for Europe (DC4EU), led by Spain is focused on the piloting of educational 
and professional qualifications and social security credentials, including the European Health 
Insurance Card and Portable Document A1 for seconded workers. 

To support the piloting of EUDI Wallets, the Commission launched a second funding round for pilot 
projects in 2024, which received strong interest from public and private actors across Member States. 
This initiative will support two pilot projects with a total investment of over EUR 23 million from the 
Commission.  These  projects,  involving  over  300  public  and  private  entities  from  the  majority  of 
Member States, as well as Norway, Bosnia and Herzegovina, Moldova, and Ukraine, are scheduled to 
start in Q3-2025 and will run for two years.  

The ‘We Build’ pilot project, jointly led by Sweden and the Netherlands, includes participation from 
six other Member States and over 170 entities from various sectors. It focuses on expanding the use 
of wallets to a variety of business and 13 payments scenarios across B2C and B2B contexts.  

36 Directive (EU) 2025/25 amending Directives 2009/102/EC and (EU) 2017/1132 as regards further expanding and upgrading 
the use of digital tools and processes in company law.  

46 

 
 
Led by France, the ‘Aptitude’ pilot project involved a high level of participation by public and private 
actors  across 11 Member States and Ukraine,  bringing together  over 110  participants.  This project 
focuses on advancing the use of wallets for travel and payment purposes.  

Results from these two pilot projects will significantly contribute to the development of the wallet 
ecosystem and facilitating the launch of EUDI Wallets by Member States by the end of 2026. 

The  Council  Directive  (EU)  2025/50  of  10 December 2024  on  faster  and  safer  relief  of  excess 
withholding taxes (FASTER) (see also 13.1 below) is based among others on a common EU-wide digital 
tax residence certificate that will shift the issuance of tax residence certificates from a paper-based 
to a digitalised process. This will make the withholding tax relief procedures faster, more efficient and 
less resource intensive. The Directive envisages the use of the EUDI Wallet as a means of verification 
of the tax residence, provided that all EU-level legal and technical requirements are met. 

SUMMARY ASSESSMENT: Significant progress 

47 

 
 
 
13  Digital Public Services  

13.1  Member States should focus investment and regulatory measures to develop and make 
available  secure,  sovereign  and  interoperable  digital  solutions  for  online  public  and 
government services, including possibly in the context of public procurements 

PROGRESS AND STATE OF PLAY 

Over the past year, Member States have continued to invest in robust digital infrastructures at both 
national and subnational levels, enhancing the support for secure and interoperable online services.  

The 2024 Digital Public Administration factsheets show that investments are being made in upgrading 
existing infrastructure and creating new systems to improve digital connectivity and service delivery. 
The focus has been on data-related initiatives, primarily in establishing and enforcing legal frameworks 
for  data  management  and  access,  to  align  with  EU  legislation  and  develop  effective  data  policies. 
These initiatives highlight the pivotal role of innovative technology in driving societal and economic 
progress,  and  the  importance  of  public  sector  data  in  fostering  innovation  and  economic 
competitiveness.    To support  cross-border  digital  public  services,  the  Interoperable  Europe  Act37  , 
while an implementing act on interoperability regulatory sandboxes will be adopted in Q2/Q3 2025. 
These initiatives are analysed in Sections 13.2 and 13.4. 

Member  States  are  finalising  the  transposition  of  the  Digitalisation  Directive  (EU)  2019/1151, 
enabling  fully  online  company  registration  and  preparing  for  the  transposition  of  Directive  (EU) 
2025/25,  due  by  mid-2027,  which  applies  the  ‘once-only’  principle  and  introduces  a  digital  EU 
Company  Certificate,  expected  to  save  EUR  400  million/year.  The  application  of  the  ‘once-only’ 
principle through the Business Registers Interconnection System (BRIS), also making more company 
information publicly available and exchangeable between business registers, means that companies 
will not need to resubmit documents when they set up subsidiaries and branches in other Member 
States. In addition, they will be able to use the digital EU Company Certificate as a European corporate 
identity card, as it is compatible with the forthcoming European Business Wallet. Implementing acts 
related to this Directive will be adopted in 2026. 

Member States are also making progress on the Single Digital Gateway38 and its Once-Only Technical 
System. By the end of 2025, most Member States are expected to be technically ready to implement 
these  tools,  enhancing  cross-border  interactions  for  citizens  and  businesses  and  enabling  direct 
document transfers between authorities. However, further efforts are needed to connect all relevant 
authorities and  provide comprehensive online  digital public  services.  A 2024 study  has shown that 
these systems could cut SMEs’ cross-border administrative costs and time by more than half. 

Progress  on  the  industrial  permitting  front,  which  is  crucial  for  boosting  the  EU’s  business 
competitiveness in sectors like renewable energy and semiconductors, varies across Member States. 

37  Regulation  (EU)  2024/903  laying  down  measures  for  a  high  level  of  public  sector  interoperability  across  the  Union 
(Interoperable Europe Act).  

38 Regulation (EU) 2018/1724 establishing a single digital gateway to provide access to information, to procedures and to 
assistance and problem-solving services and amending Regulation (EU) No 1024/2012  

48 

 
 
While the Single Digital Gateway, the Net Zero Industry Act39, and the Critical Raw Materials Act40 
provide  a  legal  framework  to  streamline  these  procedures,  only  some  Member  States  have  made 
significant progress in streamlining and digitalising permitting. Consequently, several Member States 
still lack the necessary organisational reforms and digital infrastructure. 

In March 2025, the High-Level Forum on Justice for Growth was launched to explore, among others, a 
common ‘Justice IT/AI toolbox’ to allow Member States to share AI and digital tools for the justice 
sectors. On  24 September 2024,  the  Public  Procurement  Data  Space  (PPDS)  was 
launched, 
aggregating procurement notices from several Member States including Austria, Finland and Germany 
as well as Norway. This platform aims to improve reporting on public procurement. Member States 
are  required  to  integrate  approximately  80 000  national  authorities  into  the  Once-Only  Technical 
System  under  the  Single  Digital  Gateway  Regulation  in  order  to  enhance  interoperability  and  the 
availability of online public services across the EU. 

Regarding  the  work  carried  out  by  Member  States  since  July  2024  to  develop  sovereign  digital 
solutions for online public and governance services, no specific information has been  submitted to 
the Commission. 

Member  States  are  also  making  progress  on  customs  and  taxation  through  EU-supported  digital 
reforms.  The  Customs  and  Fiscalis  programmes  fund  both  central  systems  and  national 
implementation,  helping  Member  States  to  develop  digital  capacity.  The  Union  Customs  Code  has 
advanced paperless and automated customs, with key projects like I Control System 2 and the new 
computerised  transit  system  (NCTS),  improving  national  efficiency  and  security.  New  VAT  rules 
(Council Directive (EU) 2025/516) will allow Member States to introduce mandatory e-invoicing and 
real-time  digital  reporting,  easing  compliance  and  harmonising  cross-border  trade.  The  FASTER 
Directive  supports  Member  States  by  streamlining  withholding  tax  relief  through  a  digital  tax 
residence  certificate.  For  SMEs,  Directive  (EU)  2020/285  promotes  interoperable  digital  tools  that 
simplify VAT procedures across Member States. 

SUMMARY ASSESSMENT: Notable progress 

39  Proposal  for  a  Regulation  on  establishing  a  framework  of  measures  for  strengthening  Europe’s  net-zero  technology 
products manufacturing ecosystem (Net Zero Industry Act) COM/2023/161 final 
40 Regulation (EU) 2024/1252 establishing a framework for ensuring a secure and sustainable supply of critical raw materials 
and amending Regulations (EU) No 168/2013, (EU) 2018/858, (EU) 2018/1724 and (EU) 2019/1020 

49 

 
 
 
 
13.2  Member  States  should monitor  the effective  use  of  online  public  services  by  national 
and, possibly, by cross-border users as well as possible gaps, including between urban 
and rural areas  

PROGRESS AND STATE OF PLAY 

Through  the  adoption  of  the  Interoperable  Europe  Act,  Member  States  committed  to  enhancing 
cross-border  interoperability  and  further  developing  trans-European  digital  public  services  (TDPS). 
Interoperability assessments – Article 3 of the Act – aim to ensure that binding requirements for TDPS 
have  fully addressed  cross-border  interoperability  issues  early  on. Depending  on  the  scope,  public 
organisations, including both Member States and EU entities, are either legally required to carry out 
interoperability assessments, or, in other cases, a public organisation may carry out interoperability 
assessments  on  a voluntary  basis.  Depending  on  the  context,  interoperability  assessments  can  be 
conducted at national, regional and local level.  

The  criteria  for  the  selection  of  labelled  interoperability  solutions  have  been  approved  by  the 
Interoperable Europe Board in May 2025.  

Following this milestone, the first selection of Interoperable Europe solutions will happen during the 
third Board meeting in December 2025. During this meeting, Board members will also discuss the first 
Annual  Report  on  the  State  of  Interoperability  in  the  Union,  drafted  under  the  new  Monitoring 
Mechanism, which monitors the Act’s implementation in the EU.  

SUMMARY ASSESSMENT: Limited progress 

50 

 
 
 
13.3  Member  States  should  intensify  their  efforts to ensure  that  everyone,  including  older 

people and people with disabilities, has equal access to online public services  

PROGRESS AND STATE OF PLAY 

Initial data from the 2022-2024 monitoring period of the Web Accessibility Directive indicates that 
Member States are increasing their efforts to ensure that everyone, including older people and people 
with disabilities, has equal access to online public services. Member States’ reports highlight ongoing 
training and awareness-raising  initiatives, which are crucial for improving the  accessibility of  these 
services. 

To align with the European Accessibility Act, the harmonised standard EN 301 549 on the accessibility 
of  ICT  products  and  services,  is  being  updated.  A  new  version  of  this  standard  is  scheduled  to  be 
published by 15 September 2025. This update is essential as it will ensure that the standard and its 
supporting documents meet the latest web accessibility guidelines and maintain compatibility with 
the Web Accessibility Directive. 

Overall,  progress  in ensuring  people with  disabilities  have  equal  access  to  online  public  services  is 
steady.  Member  States  are  improving  their  monitoring  and  reporting  capabilities,  which  improves 
their ability to assess the accessibility of websites and mobile applications of public services. While 
improvements have been made in website accessibility, significant efforts are still needed to make all 
online public services fully accessible to people with disabilities. 

SUMMARY ASSESSMENT: Notable progress 

51 

 
 
 
13.4  Member States should work with the Commission on ways to ensure digital technologies 
and  tools  are  put  at  the  service  of  more  agile,  red-tape  free,  data-based  regulatory 
frameworks 

PROGRESS AND STATE OF PLAY 

The  Competitiveness  Compass  identifies  regulatory  sandboxes  as  key  tools  to  support  the  EU’s 
innovation  and  simplification  initiatives.  Introduced  by  the  Interoperable  Europe  Act,  regulatory 
sandboxes  allow  new  technologies  and  regulatory  approaches  to  be  tested  in  a  controlled 
environment before being fully implemented. Several Member States are integrating AI tools for data 
analysis  to  inform  regulatory  decisions.  Some  of  them  have  shown  interest  in  collaborating  on 
regulatory sandboxes to support cross-border digital public services. With the implementing act on 
regulatory  sandboxes  (Q2/Q3  2025)  and  the  EDIC  in the  making  (IMPACTS  EDIC)  planning  a  cross-
border sandbox, the Interoperable Europe Board is set to define specific use cases.  

SUMMARY ASSESSMENT: Limited progress 

52 

 
 
 
 
13.5  Member  States  are  invited  to  make  further  progress  with  their  multi-country 
commitments and cooperation in the field of connected public administration and the 
European Blockchain Services Infrastructure, through the EDICs recently established  

PROGRESS AND STATE OF PLAY 

The  Innovative  Massive  Public  Administration  InterConnected  Transformation  Services  (IMPACTS) 
EDIC is currently being set up, with a significant milestone reached on 4 December 2024 when four 
Member States – Greece, Croatia, Hungary and Poland – submitted a formal application. Additionally, 
Cyprus, Finland, Germany, Luxembourg, Malta and Slovenia are listed as observers. The applications 
are now being assessed by the European Commission. The goal of IMPACTS EDIC is to create a long-
term  collaboration  mechanism  between  Member  States  to  launch  common  innovative  projects  to 
support cross-border interoperability in advanced public services. 

SUMMARY ASSESSMENT: Notable progress 

53 

 
 
 
14  e-health  

14.1  Member States should ensure that access to electronic health records, with a minimum 
set of health-related data stored in public and private electronic health record systems, 
is technologically enabled and easily accessible for people (via a patient portal or patient 
mobile  app).  In  alignment  with  the  goals  of  the  European  Health  Data  Space,  this 
include  electronic  health  record  summaries,  electronic 
minimum  set  should 
prescriptions  and  dispensations,  as  well  as  electronic  results  and  reports  including 
medical imaging studies, laboratory results, and hospital discharge reports  

PROGRESS AND STATE OF PLAY 

Significant strides have been made towards achieving the objectives outlined in the Digital Decade 
Policy Programme, particularly the target of ensuring that 100% of EU citizens have access to their 
electronic  health  records.  The  composite  score  for  the  EU’s  progress  in  this  area  has  risen  from 
79.1/100 in 2023 to 82.7/100 in 2024, reflecting an annual growth rate of 4.5%. All Member States 
have some form of electronic health access service in place, whether at regional or national level, and 
have extended the range of health data accessible to users. This includes advancements in technology 
and  methods  used  for  access,  as  well  as  broadening  the  categories  of  individuals  who  can  access 
services. 

Despite improvements in the availability of hospital discharge reports across the EU, no progress has 
been  noted  in  the  availability  of  medical  images.  The  most  significant  data  enhancements  in  2024 
were in the areas of personal information, procedures and operations, e-dispensation, and lab test 
results. 

Moreover, there has been a steady increase in the number of healthcare providers integrating and 
contributing  data  to  electronic  health  records  across  Member  States.  However,  a  significant  gap 
remains between public and private providers, with private actors lagging behind in their integration 
efforts. The adoption of a (pre-)notified eID compliant with the EUDI Regulation for authentication 
purposes has increased substantially across Member States, facilitating more secure and widespread 
access to health data. 

The European Health Data Space Regulation41 entered into force on 26 March 2025. This regulation 
supports citizens’ rights to access their electronic health data, requiring Member States to ensure such 
access through services provided at national, regional or local levels. 

SUMMARY ASSESSMENT: Significant progress 

41 Regulation (EU) 2025/327 on the European Health Data Space and amending Directive 2011/24/EU and Regulation (EU) 
2024/2847  

54 

 
 
 
 
14.2  Member States should cooperate to fully deploy the innovation potential of health data 
by maximising the use of existing and future health data initiatives and infrastructure, 
investing  in  the  research  and  deployment  of  advanced  technologies  such  as  high-
performance  computing  and  trustworthy  AI  applications 
in  healthcare,  while 
strengthening cybersecurity measures  

PROGRESS AND STATE OF PLAY 

The European Cancer Imaging Initiative’s central hub was set up and completed its technical validation 
in  2024.  These  developments  will  further  support  data  analytics  and  the  access  to clinical  data  by 
clinicians,  researchers  and  innovators  across  Member  States  to  develop  AI-based  solutions. 
Additionally,  a  public  procurement  funded  by  the  DIGITAL  programme  for  EUR  24 million  was 
launched to develop a platform for Virtual Human Twins, aimed at improving interoperability among 
computational models and datasets. Eight Horizon Europe actions (EUR 80 million) are expected to 
contribute as users of the platform in the future. 

The  European  Health  Data  Space  (EHDS)  will  provide  Member  States  with  a  common  legal  and 
technical framework to enable secure, privacy and data protection-compliant re-use of health data. It 
aims  to  support  national  efforts  by  giving  researchers  and  policymakers  access  to  high-quality, 
interoperable  datasets,  overcoming  fragmentation  and  strengthening  data-driven  innovation  in 
health. In 2024, 70 institutes from 24 European countries advanced the development of the European 
Genomic  Data  Infrastructure  (GDI)  that  in  its  second  year  of  technical  progress  showcased 
demonstrators for federated access to genomic data. A new large pan-European project, the Genome 
of Europe (GoE) started in late 2024 to build the first European reference genome. The GoE data will 
feed  into  GDI,  enabling  groundbreaking  medical  research,  and  supporting  public  health  policy.  A 
coordination and support action project starting in 2025 to facilitate the overall strategic orientation 
of the 1+MG Initiative and to facilitate the creation and operation of a Genome EDIC will support the 
sustainability of the data infrastructure. 

Following  the  announcement  of  the  AI  Innovation  package  in  early  2024,  the  EuroHPC  Joint 
Undertaking  launched  the  AI  factories  initiative  around  AI-optimised  supercomputers,  aiming  to 
pioneer advancements in AI models and applications in, health and life sciences among other areas. 
In December 2024, the sites to host the first AI factories were selected across seven Member States 
in a collaborative effort involving 17 European countries. Five of these sites will include a focus on life 
sciences. 

On 15 January 2025, the European Commission presented a European action plan on the cybersecurity 
of  hospitals  and  healthcare  providers,  a  ‘100  days’  priority  for  the  new Commission.  It  focuses on 
strengthening  the  sector’s  capacities  to  prevent  incidents;  improving  threat  detection,  as  well  as 
response and recovery; and deterrence. The plan will be implemented progressively during 2025 and 
2026, in collaboration with health providers, Member States, and the cybersecurity community. 

SUMMARY ASSESSMENT: Notable progress 

55 

 
 
 
14.3  Member States are invited to make further progress in setting up the proposed EDICs in 
the  area  of  genomics  and  cancer  imaging  data  with  a  view  to  driving  innovation  in 
personalised healthcare and AI solutions in cancer care  

PROGRESS AND STATE OF PLAY 

In 2024 Member States engaged in the long-term implementation and sustainability of the European 
Genomic  Data  Infrastructure  (GDI).  Within  this  framework  and  as  part  of  the  1+  million  genomes 
(1+MG) initiative, they proposed creating an EDIC for genomics. This EDIC is envisioned to sustain the 
operation of the 1+MG Data Infrastructure, facilitating secure access and curated genomic and related 
health data. It is also intended to align with and connect to the broader European Health Data Space 
(EHDS).  

In  addition,  an  EDIC  Task  Force  was  created  under  the  GDI  project.  This  task  force  focused  on 
discussing  the  setup,  technical  and  legal  interoperability  with  the  EHDS,  and  the  long-term 
implementation of the 1+MG initiative. Over the past year, the task force made progress on the draft 
statute and business model of the future EDIC and prepared the additional documentation needed for 
setting it up. 

Progress  was  also  made  in  setting up  the  European Cancer Imaging (EUCAIM) EDIC,  with the  pre-
notification of the EDIC application submitted to the Commission in January 2025, supported by Spain, 
Latvia, and France. 

SUMMARY ASSESSMENT: Significant progress 

56 

 
 
 
15  Safeguarding rights 

15.1  Member States should accelerate action that is necessary for the implementation of the 
regulatory  framework,  particularly  the  DSA.  They  should  focus  on  establishing  the 
necessary  governance  system  at  national  level  and  to  foster  close  cooperation  and 
engagement  with  the  Commission,  the  newly  created  European  Board  for  Digital 
Services, Digital Services Coordinators and civil society  

PROGRESS AND STATE OF PLAY 

By  17 February 2024,  Member  States  were  required  to  designate  their  national  Digital  Service 
Coordinator  (DSC)  and  empower  them  to  oversee  intermediary  service  providers  and  enforce  the 
Digital Services Act (DSA). 26 Member States have designated their DSCs, and 19 have empowered 
them.  The  European  Commission  had  opened  infringement  proceedings  against  13  non-compliant 
Member States for not having fulfilled their obligations. Since then, it closed 3 proceedings with 10 
still ongoing.  In addition, DSCs must have all the necessary resources (technical, financial, and human) 
to supervise providers and carry out their investigative and enforcement powers independently. By 
31 January 2025, 16 DSCs had increased their staff working on the DSA, according to a survey of 26 
designated DSCs and 1 prospective DSC. The same survey found that 10 had taken some enforcement 
action, including 3 that sent requests for information (RFIs), while 17 had not yet acted. 

DSCs  are  also  responsible  for  certifying  trusted  flaggers,  independent  entities  such  as  NGOs  that 
detect and notify illegal content, and out-of-court dispute settlement bodies. As of 31 January 2025, 
16 trusted flaggers and 6 out-of-court dispute settlement bodies have been certified. These certified 
entities  play  a  crucial  role  in  ensuring  the  effective  enforcement  of  the  DSA  and  protecting  users' 
rights.  

The  European  Board  for  Digital  Services,  an  independent  advisory  group  for  the  cooperation  and 
coordination of DSA supervision and enforcement among the DSCs and the Commission, has held 12 
meetings as of 13 March 2025 and established 8 thematic working groups (WGs) to help ensure the 
consistent application of the DSA. The Board has adopted documents on elections and information 
integrity. 

SUMMARY ASSESSMENT: Notable progress 

57 

 
 
 
15.2  Member  States  should  step  up  effort  to  develop  research  and  knowledge  on  –  and 
monitor the trends in – the online domain, notably on the interplay between digital tool 
usage,  exposure  to  harmful  content,  and  mental  health  (including  on  children  and 
adolescents) 

PROGRESS AND STATE OF PLAY 

The  European  Commission  is  committed  to  ensuring  that  people  have  safe  and  healthy  digital 
experiences. The Digital Services Act (DSA) obliges the providers of all online platforms to ensure a 
high level of privacy, safety – including mental well-being – and security for children on their services. 
Moreover, the DSA obliges the providers of very large online platforms and search engines that have 
more than 45 million average monthly active recipients in the EU to analyse systemic risks to their 
users’ mental and physical health and to mitigate against any identified risks. As part of the ongoing 
enforcement  of  the  DSA,  the  Commission  has  for  example  launched  investigations  against  the 
providers of TikTok, Facebook and Instagram, which include grievances related to these platforms’ 
measures to safeguard users from ‘rabbit hole’ effects and online addiction.  

A  notable  example  is  the  Commission’s  intervention  against  TikTok  Lite’s  ‘Task  and  reward 
programme’,  which was  deemed  to pose  a  risk of exacerbating addiction and other mental health 
concerns.  As  a  result  of  this  intervention,  the  provider  of  TikTok  suspended  the  programme  and 
committed  to  not  introducing  similar  initiatives  in  the  EU,  a  pledge  that  has  been  made  legally 
binding42. Moreover, one of the working groups (WG 6) of the European Board for Digital Services is 
dedicated specifically to the protection of minors.  

In  addition,  the  political  guidelines  for  2024-2029  emphasise  the  commitment  to  support  young 
people. To that end, the Commission will launch an inquiry on the impact of social media on young 
people’s mental well-being, propose measures to address the addictive design of online services 
and, still in 2025, launch an action plan against cyberbullying. 

SUMMARY ASSESSMENT: Notable progress 

42 European Commission, TikTok commits to permanently withdraw TikTok Lite Rewards programme from the EU to comply 
with the Digital Services Act, 2024. 

58 

 
 
 
16  Protecting children  

16.1  Member States should work with the Commission to ensure secure, privacy preserving, 
user-friendly and interoperable digital identity solutions and trust services, including for 
age verification, to enable the development of a harmonized solution from 2025 across 
the EU, notably leveraging the EUDIW  

PROGRESS AND STATE OF PLAY 

Some Member States strongly prioritised this topic, including proposing age verification solutions at 
national  level,  notably  in  the  process  of  transposing  Article  28b of  the  Audiovisual  Media  Services 
Directive  (AVMSD).  However,  to  avoid  fragmentation  across  Member  States,  a  multifaceted, 
harmonised, and holistic approach is required at EU level. This should include policies and effective 
actions that restrict minors' access to explicit or violent content, and ensure an age-appropriate digital 
childhood across the EU, in close cooperation with the Member States. The EU Digital Identity Wallets 
(EUDIW) which will be available by the end of 2026 to EU citizens and residents, will play a key role 
in this respect.  

Meanwhile, the Commission has been working with Member States on a short-term solution to age 
verification, and has set up a Task Force on Age Verification with Member States’ authorities, ERGA43, 
and EDPB. The task force has been focusing on developing an EU-wide privacy preserving solution for 
age verification, in line with single market rules and rooted in the EU Digital Identity framework. The 
task force met three times in the first half of 2024, and its work continues under the WG6 of the DSA 
Board, where age verification is a key priority. The WG6 is the main forum to discuss progress at EU 
level and ensure Member States’ continued commitment. ERGA and EDPB representatives are also 
involved.  

Importantly, an EU-wide age verification solution (AV app) is being procured by the Commission, with 
the contract launched in January 2025 to deliver a white label app by summer 2025. This will be a 
privacy  preserving  and  interoperable  short-term  solution  to  bridge  the  gap  until  EUDI  Wallets  are 
available.  

SUMMARY ASSESSMENT: Notable progress 

43 See also ERGA’s 2024 report on the coordination of approaches to the protection of minors on video-sharing platforms 
(VSPs) and on-demand services, including age verification tools, criteria for content flagging, and parental control. Moreover, 
the successor of ERGA, the European Board for Media Services (‘EBMS’), is expected to continue to focus on the issues of 
protection of minors and age verification in an online environment. 

59 

 
 
 
 
 
16.2  Member  States  are  encouraged  to  continue  coordinating  with  the  Commission  to 
increase protection, digital empowerment and safety of children online, notably in the 
implementation of the European Strategy for a Better Internet for Kids  (BIK+). Special 
attention should be given to awareness-raising initiatives concerning new challenges to 
child safety and well-being raised by artificial intelligence, virtual worlds, overexposure 
to digital content, digital threats (such as hate speech, cyberbullying, harassment, child 
sexual abuse, grooming, and violent content), or aggressive marketing, including through 
child protection safeguards by design. 

Member States should step up effort to cooperate on protecting children from the risks 
that the use of digital technologies has on their health including with better monitoring 
and research  

PROGRESS AND STATE OF PLAY 

The 2022 Better Internet for Kids (BIK+) strategy supports and complements the implementation of 
the Digital Services Act (DSA) provisions on protection of minors, through the expertise and activities 
of  the  network  of  Safer  Internet  Centres  (SICs)  and  by  the  BIK  platform44.  Together  they  develop 
awareness campaigns and provide resources on online risk for children, parents/carers and teachers 
in all EU official languages. The SICs also offer helplines services to provide support on a wide range of 
online topics, and hotlines to which the public can report child sexual abuse material online.  

In 2024, the network and the BIK platform: 

•  Reached  more  than  35  million  users,  providing  them  with  almost  2  300  new  resources. 
Network resources address diverse online opportunities and challenges, including topics such 
as  algorithms,  artificial  intelligence,  cyberbullying,  online  harms,  media  literacy,  healthy 
screen use, and digital marketing tactics, alongside many others.  

•  On Safer Internet Day 2024 almost 19 000 schools and over 17 000 other organisations were 

involved in SIC actions across Europe alone. 

•  Organised more than 2 100 events involving youth participation. 

• 

• 

Launched  the  #MediaSmartOnline  campaign  to  spotlight  media  literacy  actions,  initiatives, 
and resources across Europe. The campaign builds on the resources available within the SICs 
network  while  maximising  the  efforts  and  activities  of  other  stakeholders  involved  in 
supporting practices, developing policy and carrying out research into media literacy including 
NGOs, government agencies and industry. The campaign aims to raise awareness on issues 
such  as disinformation and misinformation,  and generally  to  enhance  media  literacy  skills 
among children and young people, while also better upskilling those that support them (such 
as parents, caregivers and teachers). 

Launched the #AdWiseOnline campaign (a joint DG CNECT/DG JUST initiative) to address the 
risks faced as young consumers by children online. The campaign aims to raise awareness on 
children's  consumer  rights  by  informing  parents,  guardians,  educators,  and  policymakers 
about  specific manipulative  gaming  and  digital marketing practices  (e.g.  persuasive design, 

44 European Commission, Better Internet for Kids, https://better-internet-for-kids.europa.eu/en  

60 

 
 
dark patterns, and loot boxes) targeting children and young people.   

•  Created  a  guide  to  age  assurance,  available  on  the  BIK  platform,  including:  family-friendly 
explainers,  a  report  mapping  age  assurance  typologies  and  requirements,  a  guide  to  age 
assurance for digital providers. 

The full results of the first evaluation of BIK+ were s published in May 202545. The monitoring of the 
implementation of BIK+ is also under way at national level through the BIK Policy monitor (6th report 
has been published in May 2025). 

In  addition,  the  Commission  and  Member  States  continue  to  work  towards  a  better  protection  of 
children  against  online  risks  while  fostering  their  empowerment  and  active  participation  online  in 
2025, as exemplified with the actions described under preceding recommendations. Preventing and 
protecting  children  against  any  form  of  violence,  including  online,  is  also  underlined  in  the  2024 
Commission  Recommendation  on  integrated  child  protection  systems46.  The  Commission  and 
Member States are advancing in its implementation, notably via the EU Network for children’s rights. 

SUMMARY ASSESSMENT: Limited progress 

45 European Commission, First evaluation of the European strategy for a better internet for kids, May 2025  

46  Commission  Recommendation  (EU)  2024/1238  of  23  April  2024  on  developing  and  strengthening  integrated  child 
protection systems in the best interests of the child.  

61 

 
 
 
 
17  Human-centred AI  

17.1  Member  States  should  accelerate  action  that 

is  necessary  to  accompany  the 
implementation  of  the  AI  Act.  This  requires  notably  to  foster  close  cooperation  and 
engagement with the Commission, the newly created AI office and National regulators, 
and civil society. 

Member  States  should step  up  their  efforts  to  develop  research  on  human-centric  AI 
systems  

PROGRESS AND STATE OF PLAY 

The AI Board, where Member States come together regularly to exchange best practices and discuss 
implementation issues, has started operating, with its first meeting held on 10 September 2024. The 
AI Board has two official support groups, the Scientific Panel and the Advisory Forum, and numerous 
subgroups that address detailed areas of the implementation process. In addition, on 2 February 2025 
the prohibitions of AI systems that are incompatible with fundamental rights became applicable. To 
help users understand these provisions, on 4 and 6 February 2025 the Commission adopted guidelines 
regarding prohibited practices, and guidelines regarding the definition of an AI system.47 For general 
purpose  AI  (GPAI)  models,  the  Commission  has  launched  a  group  of  stakeholders,  coming  from 
industry, academia, and civil society, among others, to create codes of practice. These will be adopted 
before the rules for GPAI enter into force in August 2025. 

The  Commission  also  launched  the  AI  Pact,  an  initiative  to  accompany  organisations  in  their 
compliance  journey  and  foster  early  action  by  front-running  organisations  to  support  the 
development and deployment of trustworthy AI. The Pact consists of a network of more than 2 300 
stakeholders (including companies, not-for-profit organisations, academics, and public organisations) 
who should contribute to the creation of a collaborative community, sharing their experiences and 
knowledge. To that end, the AI office organises webinars for a better understanding of the AI Act and 
how to prepare for its implementation, and gathers insights into best practices and challenges faced 
by the participants. In addition, more than 190 companies are involved in the Pact. These companies 
come from diverse sectors and include multinational corporations and European SMEs that provide 
or deploy AI systems. They have accepted to sign pledges to take measures to anticipate compliance 
with key AI Act requirements as far as possible, and to share corresponding good practices. 

Member States have continued working to enhance research on human-centric AI systems through 
several programmes, and through participation in EU-supported initiatives: 

1.  Horizon Europe, providing substantial funding for AI research with a focus on human-centric 
approaches. This involves collaborative projects that prioritise user safety, privacy, and ethical 
considerations in AI development. 

2.  The Digital Europe Programme aiming to boost Europe's digital capabilities, including AI, by 
supporting the development of state-of-the-art infrastructure and by fostering collaboration 
among Member States. 

47 Commission on the Commission Guidelines on prohibited artificial intelligence practices established by Regulation (EU) 
2024/1689 (AI Act), https://ec.europa.eu/newsroom/dae/redirection/document/112367, 4 February 2025 

62 

 
 
3.  Digital Innovation Hubs supporting the creation and expansion of networks of AI innovation 

hubs to promote collaboration of entities based across the EU. 

4.  Public-private  partnerships  between  governments,  industry,  and  academia  translating 

human-centric AI research into practical applications. 

5.  Providing  targeted support  for  SMEs  and  start-ups,  including  financial  incentives,  guidance 

and resources. 

6. 

Infrastructure  development  including  investing  in  computing  resources,  and  data  storage 
facilities that can support AI development and deployment. 

SUMMARY ASSESSMENT: Notable progress 

63 

 
 
 
18  Preserving information integrity and democracy 

18.1  Member  States  should  foster  the  growth  of  a  community  that  would  tackle  different 
challenges  linked  to  disinformation,  like  fact-checking,  media  literacy  and  research 
activities,  such  as  engaging  in  more  research  on  disinformation,  regarding  structural, 
psychological, sociological, and technological factors driving it.  

Member  States  could  in  particular  foster  the  growth  of  fact-checking  services  to 
contribute  to  the  new  digital  media  ecosystem  as  well  as  invest  in  developing 
technological tools that can help users better detect and contextualise disinformation. 

Member  States  should  create  and  implement  a  strategy  for  countering  foreign 
information  manipulation  and  interference  (FIMI)  campaigns.  They  should  continue 
working  on  identifying  FIMI  campaigns,  while  also  creating  efficient  and  effective 
channels for the exchange of data.  

PROGRESS AND STATE OF PLAY 

The  fight  against  disinformation  remains  an  important  priority,  despite  efforts  to  enhance  fact-
checking, media literacy, and research activities. A cornerstone of these efforts is the European Digital 
Media  Observatory  (EDMO),  an 
independent  platform  that  unites  fact-checkers,  academic 
researchers, and other stakeholders with the aim of combating disinformation. EDMO has expanded 
into  a  network  of  14  hubs  covering  all  27  Member  States,  as  well  as  Norway.  These  hubs  are 
instrumental  in  detecting  and  analysing  disinformation  campaigns  and  organising  media  literacy 
activities at both national and European levels. 

Regarding fact-checking services, the EU has been proactive in supporting initiatives that increase the 
capacity to identify and counter disinformation. For instance, the Commission supports a new set of 
projects that improve media literacy skills among Europeans, promote critical thinking, and mitigate 
the impact of disinformation. These efforts are complemented by the development of technological 
tools  designed  to  help  users  better  detect  and  contextualise  disinformation.  Different  research 
projects have resulted in the development of tools to detect disinformation and AI-generated content, 
as well as tools to help the public, fact-checkers, and journalists with content verification and analysis.  

One important initiative spanning the entire EU is the European Fact-Checking Standards Network 
(EFCSN) - an independent coalition of fact-checking organisations spanning Europe. The EFCSN was 
set up to promote high standards in fact-checking, enhance collaboration among fact-checkers, and 
counter  disinformation  effectively.  As  of  January  2025,  the  EFCSN  comprises  48  verified  member 
organisations from 19 Member States and several other countries.  

The  2022 Code  of  Practice  on  Disinformation  was  converted  into  a  code  of  conduct  under DSA48, 
marking further progress in this area. As part of the code, signatories, including providers of online 
platforms,  players  from the  advertising  ecosystem,  fact-checkers,  civil  society, research,  and  other 
organisations, agreed to create a framework for close collaboration through a permanent taskforce. 
The Code’s Taskforce has since proved its effectiveness in exchanging information and cooperation 
between signatories. In particular, the Rapid Response System (RRS) of the Code proved to be a very 
effective tool during European Parliament and national elections in 2024 (e.g. in France and Romania), 

48 Converted into a code of conduct under Article 45 DSA in February 2025, see Commission Staff Working Document “Digital 
Decade 2025: progress and outlook” accompanying the State of the Digital Decade 2025 

64 

 
 
allowing civil society organisations, fact-checkers and online platforms to cooperate on time-sensitive 
content that they deemed a threat to the integrity of the electoral process.  

In addition, the enforcement of the Digital Services Act (DSA) is ongoing and will continue throughout 
2025.  Through  this  work,  the  European  Commission  will  systematically  scrutinise  the  algorithmic 
systems  of  very  large  online  platforms  and  search  engines  and  how  their  providers  implement 
measures to fight disinformation. 

SUMMARY ASSESSMENT: Notable progress 

65 

 
 
 
18.2  Member  States  should  explore  the  establishment  of  a  European  Observatory  on  the 
Digital  Divide  to  analyse,  from  a  comparative  perspective,  the  issue  of  digital  divide 
impacting vulnerable social groups across the EU  

PROGRESS AND STATE OF PLAY 

The  digital  divide  in  the  EU  disproportionately  affects  vulnerable  groups,  with  only  33.61%  of 
individuals with low education, 28.19% of those aged 65-74, and 47.5% of rural residents possessing 
at least basic digital skills, limiting their access to essential services and economic opportunities in an 
increasingly digital society. In this context, the Digital Decade targets are consistent with those of the 
European Pillar of Social Rights Action Plan to improve skills and employment and reduce poverty, and 
with  the  commitment  of  the  European  Declaration  on  Digital  Rights  and  Principles,  to  ‘a  digital 
transformation that leaves no one behind’.  

Setting up  a European Digital Divide Observatory49  is  a crucial  opportunity to monitor and address 
digital  inequalities  at  the  local  level,  helping  municipalities  identify  gaps,  share  best  practices,  and 
secure targeted funding for digital inclusion. By enabling cities to analyse the digital divide within their 
populations, this initiative would support evidence-based policymaking and collaboration to ensure 
that no one is left behind in the digital transition. 

Setting up local Digital Divide Observatories involves a wide range of stakeholders, including municipal 
governments  which  are  responsible  for  implementing  local  digital  inclusion  policies,  European  city 
networks like Eurocities which facilitate knowledge exchange and advocacy, and EU-funded projects 
such as Living-in.EU, CitiMeasure, and UserCentriCities which provide frameworks and resources for 
digital transformation.  

However,  these  initiatives  remain  sparse  and  fragmented,  with  only  a  handful  of  cities,  such  as 
Barcelona, Ghent, and Bordeaux actively developing Digital Divide Observatories. Specifically in 2024, 
Bordeaux Metropole carried out a qualitative sociological study, gathering testimonials from citizens. 
But  many  municipalities  lack  the  resources,  expertise,  or  political  prioritisation  to  engage  in  such 
projects,  resulting  in  uneven  progress  across  Europe.  Without  structured  EU-level  support  and 
dedicated  funding,  smaller  or  less  well-equipped  cities  risk  falling  further  behind,  exacerbating 
regional disparities in digital inclusion. 

Should the creation of an EU-wide observatory not be immediately pursued, Member States could be 
encouraged to support and scale up existing local observatories across Europe, including by facilitating 
their collaboration and enabling them to function as a network. 

In this context, the Commission is exploring with Member States best practices to encourage digital 
inclusion. 

SUMMARY ASSESSMENT: Limited progress 

49  Digital  Divide  Observatories  by  European  cities,  https://eurocities.eu/latest/a-digital-divide-observatory-by-european-
cities/  

66 

 
 
 
 
18.3  Member States are encouraged to continue supporting the Commission in the effective 
enforcement of the Digital Services Act in relation to the fight against disinformation, 
especially by providing supporting data  

PROGRESS AND STATE OF PLAY 

In February 2024, the European Board for Digital Services, an advisory body tasked with supporting 
the Commission with the enforcement of the Digital Services Act (DSA), notably by helping coordinate 
the work of the national Digital Services Coordinators (DSCs), started operating50. A working group 
was set up under the Board - Working Group 4 on Integrity of Information Space (WG4) - to coordinate 
the work on information integrity, which includes disinformation and online integrity of elections.  

This  facilitated  intensive  collaboration,  with  a  special  focus  on  major  elections  such  the  European 
Parliament election, but also elections in France, Austria, Lithuania, Croatia, Romania and Germany. 
The experience and best practices gathered during this work were formalised in the Elections Toolkit 
for the DSCs adopted by the Board in February 2025.  

Gathering data to help better understand the online environment at both EU and Member State-level 
is an important part of this workstream, as is the sharing with the Commission of potential evidence 
on the potential breaching of the DSA obligations by very large online platforms and very large online 
search engines. Coordination on this via WG4 has been steadily progressing.    

The delegated act on data access, planned for adoption in the second quarter of 2025, will further 
boost  data  gathering  capabilities  at  EU  and  Member  State-level.  The  role  of  the  DSCs  will  be  to 
designate the vetted researchers that would be able to access the non-public data on online platforms. 
Although indirectly (via networks of researchers supporting the implementation of the DSA), this will 
help Member State and EU authorities to gain a better understanding of the functioning of the online 
environment and capture potential breaches of the DSA.  

SUMMARY ASSESSMENT: Limited progress 

50 See Recommendation 15.1 above. 

67 

 
 
 
 
18.4  Member States should foster media freedom and pluralism to help citizens to access a 
diverse online information and news space, by supporting the industry and cooperating 
with other Member States and with the European Commission 

PROGRESS AND STATE OF PLAY 

A free and pluralistic media environment is essential for the rule of law, with free and independent 
media playing an important role as watchdogs of democracy and holding power to account. 

Since 2020, the Commission’s annual Rule of Law Reports monitor the rule of law situation in each 
Member State and the EU as a whole, including media freedom and pluralism. Since 2022, the Reports 
include specific recommendations to Member States, also on issues related to media freedom and 
pluralism, such as independence of public service media, allocation of state advertising or working 
environment of journalists, which the Member States have been addressing to varying degrees.  

The European Media Freedom Act (EMFA)51, which entered into force on 7 May 2024, aims to improve 
the  functioning  of  the  single  market  for  media  services  as  they  become  increasingly  digital  and 
inherently cross-border.  

The  Commission  has  actively  assisted  Member  States  in  applying  the  Regulation,  including  by 
organising a preparatory meeting in December 2024 and a bilateral ‘readiness check’ meetings with 
each Member State which focused on the provisions of the Act that require Member States to adopt 
measures to bring their legal frameworks into compliance with the EMFA, most of whose provisions 
will become applicable in August 2025.  

The importance of the EMFA is illustrated by the fact that when citizens get their news from traditional 
media  tend  to  be  equally  convinced  of  the  positive  contribution  of  information  to  public  debate. 
Conversely, people who get their news from social media are more likely to think that the news is 
divisive, harmful or spreads lies (2024 EU-27 Media consumer survey). 

In addition, Member States are in the process of transposing Directive (EU) 2024/1069 of 11 April 2024 
aimed at protecting people who engage in public participation from manifestly unfounded claims or 
abusive court proceedings (‘Strategic lawsuits against public participation’, SLAPP) by the deadline of 
May  2026.  With  this  directive,  for  the  first  time  ever  in  the  EU,  a  system  of  powerful  procedural 
safeguards  for  cross-border  SLAPP  cases  has  been  put  in  place.  The  safeguards  presented  therein 
(protection against early dismissal of manifestly unfounded claims, remedies  against  abusive  court 
proceedings  and  protection  against  third  country  SLAPP-judgements)  enable  courts  to  deal  with 
abusive litigation, as well as deter potential claimants from engaging in such practices. 

The Commission will publish in Q2 2025 a new edition of the European Media Industry Outlook, which 
will provide insights at EU-27 level on market data and trends in the audiovisual, videogames, news 
media industries and XR, and consumer preferences, using the results of the 2024 consumer survey. 

SUMMARY ASSESSMENT: Limited progress 

51 Regulation (EU) 2024/1083 establishing a common framework for media services in the internal market and amending 
Directive 2010/13/EU (European Media Freedom Act)  

68 

 
 
 
 
19  Smart greening 

19.1  Member States should consider wider deployment of digital solutions in supporting the 
sustainability targets of climate-critical sectors such as energy, transport, buildings, and 
agriculture. This will also support the competitiveness and growth of the EU green digital 
tech market  

PROGRESS AND STATE OF PLAY  

By  early  2025,  the  EU  had  accelerated  the  deployment  of  digital  solutions  across  climate-critical 
sectors through a range of EU-level initiatives, policy measures, and innovation projects. In the energy 
sector, a flagship Horizon Europe project ‘TwinEU’ was launched to develop a digital twin of Europe’s 
electricity  grid,  improving  grid  efficiency  and  enabling  the  integration  of  renewables.  The  Horizon 
Europe project ‘Divine‘ was launched to set up an ecosystem to aggregate private and public agri data 
that interconnects existing agri data spaces, thereby enabling the sharing of data among stakeholders, 
while other initiatives such as ‘AgriDataValue‘ have been working on combining advanced big data 
and  data-spaces  technologies  with  agricultural  knowledge,  new  business  models  and  agricultural 
policies. In parallel, the ECLIPSE project, co-funded by the Digital Europe Programme, began deploying 
the  Common  European  Reference  Framework  for  energy-saving  applications.  This  Framework 
integrates  smart  meter  data  and  user-specific  tools  to  enable  real-time  energy  monitoring  and 
behavioural change, contributing to energy demand reduction and security. Furthermore, in March 
2024, the Commission adopted a delegated regulation under the recast Energy Efficiency Directive 
making  it  compulsory  for  large  data  centres  to  report  energy-related  key  performance  indicators 
(KPIs), laying the groundwork for greater transparency and efficiency in the ICT infrastructure sector.  

In transport, the common European mobility data space (EMDS) started to be deployed in late 2023 
with the launch of the deployEMDS project, piloting data-sharing use cases in nine cities and regions 
across  several  Member  States.  The  objective  is  to  accelerate  sustainable  and  smart  mobility  and 
contribute to a reduction in transport emissions.   

Digital  solution  and  tools  are  crucial  for  the  proper  uptake  in  policies  of  environmental  big-data  
(e.g.  satellite)  also  through  the  development  of  AI-based  solutions  that  is  explored  in  a  series  of 
Horizon Europe projects.    

In agriculture, the conclusion of the AgriDataSpace project in Q2 2024 resulted in a comprehensive 
blueprint  for  the  Common  European  Agricultural  Data  Space  (CEADS),  with  deployment  actions  to 
commence in 2025.  

In buildings, digital tools such as AI-driven energy management systems and simulation models began 
to  be  deployed  in  smart  city  energy  grids  and  public  buildings,  although  these  efforts  remain 
fragmented.  The  Digital  Product  Passport  initiative  gained  momentum  with  the  adoption  of  the 
Ecodesign  for  Sustainable  Products  Regulation  in  mid-2024,  mandating  digital  traceability  of 
sustainability metrics.  

In other cross-cutting sectors, the European Green Digital Coalition published in 2024 a science-based 
methodology to assess the net carbon impact of ICT solutions, creating an evidence base to scale green 
digital technologies. A follow-up pilot was launched in February 2025 to produce 50 case studies and 
involve  financial  institutions  in  drawing  up  eligibility  criteria  for  climate-aligned  investments. 
Additionally,  Destination  Earth  (DestinE)  released  its  first  high-precision  digital  twins  of  the  Earth 
system in mid-2024, enabling improved modelling for climate adaptation and disaster prevention. The 

69 

 
pre-operational  core  public  infrastructure  of  the  EU  Digital  Twin  Ocean  has  been  unveiled  in  June 
2024.  By  enabling  sophisticated  "what-if"  scenario  analysis,  the  EU  DTO  will  offer  unprecedented 
capabilities for modelling and science-driven decision making by authorities and businesses. 

SUMMARY ASSESSMENT: Limited progress 

70 

 
 
 
19.2  Member  States  should  accelerate  and  intensify  their  preparatory  action  necessary  to 

report on data centre sustainability building on the Energy Efficiency Directive  

PROGRESS AND STATE OF PLAY 

The  EU  Energy  Efficiency  Directive  (EED  recast)  requires  that  large  data  centres  (above  500 kW 
capacity) report on a number of KPIs related to the environmental impact of data centres. In March 
2024, the Commission adopted Delegated Regulation (EU) 2024/1364 laying down the KPIs that data 
centre operators must report to a European database, for the first time by 15 September 2024 in line 
with Article 12 of the EED recast. These cover detailed information regarding the energy and water 
consumption, cooling efficiency, use of waste heat and type of refrigerant used in date centres. Since 
March 2024, the Commission has been working with Member States to set up the process and the 
platform for the reporting. The first annual reporting exercise, which was extended to give data centre 
operators time to adapt, yielded incomplete and insufficient information on data centre sustainability 
performance  in  the  EU.  Nevertheless,  it  was  a  significant  first  step.  Existing  data  and  data  that  is 
collected in the future will inform further policy action under the EED recast.  

The KPIs laid down in the Delegated Regulation, on which data centre operators are now reporting, 
will form the basis for an EU-wide rating scheme for data centre sustainability, work on which will take 
place over the course of 2025. To prepare the rating scheme, the Commission has launched a technical 
study, which includes surveys and interviews with industry, and a series of workshops to discuss the 
design of the rating scheme with stakeholders. In accordance with the EED recast and based on the 
information gathered through the study and workshops, the Commission will present by May 2025 a 
report to the European Parliament and to the Council. This report will assess the sustainability of data 
centre in the EU and the steps that are being taken to improve it. On this basis, the report will outline 
a  proposal  for  the  rating  scheme  alongside  possible  minimum  performance  standards  or  other 
pathways towards climate-neutral data centres.  

The second reporting cycle ended on 15 May 2025.  

In accordance with the Energy Efficiency Directive, the Commission is assessing the available data and 
submit  a  report  to  the  European Parliament  and  to  the  Council,  possibly  exploring  future  possible 
policy action such as future legislative proposals on minimum performance standards for new data 
centres. 

Overall,  despite  significant  advances  in  drawing  up  the  reporting  methodology  and  setting  up  the 
mechanism/platform, more action needs to be taken for the reporting to provide more complete and 
consistent data for policy-making.  

SUMMARY ASSESSMENT: Limited progress 

71 

 
 
19.3  Member  States, 

in  cooperation  with  the  European  Commission  and  relevant 
stakeholders,  should  develop  a  methodology  to  assess  the  carbon  footprint  and 
enablement of digital infrastructures, and in particular, the energy consumption of edge 
nodes,  with  the  view,  by  end  of  2025,  to  progress  towards  Digital  Decade  metrics  to 
improve  the  sustainability  of  digital  infrastructures  and  energy  efficiency  of  edge 
computing. 

Member States should use the European Green Digital Coalition methodology released 
in  April  2024  to  measure  avoided  GHG  emissions  due  to  the  use  of  digitally  enabled 
solutions in sectors such as energy, transport, buildings, agriculture, health, smart cities, 
and  manufacturing.  These  measurements  will  provide  the  necessary  evidence  for 
eligibility of climate (green) financing for digitalisation of climate critical sectors.  

Member  States  should  intensify  the  work  with  the  European  Commission  and 
institutional  financial  actors  on  eligibility  criteria  for  green  finance  to  support  the 
deployment  of  digital 
infrastructures  and  solutions  that  demonstrate  positive 
sustainability impact. 

PROGRESS AND STATE OF PLAY 

The methodology to assess the carbon footprint and enablement of digital infrastructure has been 
developed by the Commission and a call for proposals has been launched. The study will start soon 
(Q2 2025). During the next two years, 50 measurements will be done in order to gather data about 
energy  consumption.  To  make  progress,  Member  States  should  look  at  what  the  European 
Commission is doing for inspiration.  

SUMMARY ASSESSMENT: No progress 

72 

 
 
 
20  Strategic Digital Decade National Roadmaps  

20.1  Member States  should ensure that all EU targets are covered by national targets and 

trajectories, reflecting EU’s level of ambition.  

Member States should ensure that those national targets and objectives are translated 
into more ambitious measures, including budget considerations.  

Member States should present an analysis of the impact that these measures create to 
ensure a more sustained progress towards these targets and objectives  

PROGRESS AND STATE OF PLAY 

Article  8  (3)  of  the  Decision  establishing  the  Digital  Decade  Policy  Programme  2030  requires  the 
Member States concerned to submit adjustments to their national roadmaps within 5 months of the 
publication of the second report on the Digital Decade. This update shall consist of policies, measures 
and  actions  Member  States  intend  to  undertake,  including,  where  relevant,  proposals  for  multi-
country projects to foster progress in achieving the general objectives and the areas concerned by the 
digital targets. If a Member State considers that no action is required and that its national roadmap 
does not require updating, it shall provide its reasons to the Commission.    

A total of 21 Member States submitted a fully updated roadmap and/or an addendum, i.e. a document 
focusing on the key elements mentioned above. 11 Member States provided an addendum, 8 provided 
a full roadmap update and 2 provided both a full roadmap update and addendum. The below graph 
presents  an  overview  of  the  targets  set  by  Member  States  in  their  national  roadmaps  and  a 
comparison with the EU-level targets. 

SUMMARY ASSESSMENT: Notable progress 

73 

 
 
 
 
20.2  Member  States  should  pay  greater  attention  to  the  challenges  concerning  the 
achievement of general objectives (i.e. human centred digital space,  competitiveness, 
resilience,  sovereignty,  inclusiveness,  sustainability  and  greening,  coherence  of  the 
action) and on the necessary measures that should be taken, including as regards the 
implementation of the Declaration on Digital Rights and Principles 

PROGRESS AND STATE OF PLAY 

In 2024 and 2025, Member States and the EU have taken several measures to address the challenges 
related  to  achieving  general  objectives.  These  include  creating  a  human-centred  digital  space, 
enhancing  competitiveness,  resilience,  sovereignty,  inclusiveness,  sustainability,  and  ensuring  the 
coherence of actions. These efforts are particularly focused on the implementation of the European 
Declaration on Digital Rights and Principles. Key actions and developments with a specific focus on 
competitiveness and sovereignty include: 

1.  National Strategic Roadmaps: 

•  Member States submitted national roadmaps detailing their planned actions to reach 
the 2030 Digital Decade targets. These roadmaps were reviewed and adjusted also to 
better align with the EU's digital objectives. The roadmaps focus on enhancing digital 
infrastructure,  promoting  digital  skills,  and  supporting  the  uptake  of  digital  tools 
among SMEs. The roadmaps also emphasise the need to focus more on overcoming 
challenges  to  achieving  the  general  objectives,  including  competitiveness  and 
sovereignty. 

2.  Digital Rights and Principles: 

•  With the contribution of Member States, the Commission monitored the application 
of  digital  rights  and  principles  across  the  EU,  identifying  gaps  and  providing 
recommendations  to  improve  implementation  at  national  level.  The  Commission, 
supported by a study52, identified over 2 000 initiatives that implement digital rights 
and  principles  across  all  Member  States  by  the  end  of  2024.  The  total  number  of 
ongoing  initiatives  continued  to  increase  in  2024,  with  a  majority  of  initiatives 
running for several years. However, fewer digital rights initiatives were launched in 
2024 than in 2023. The bulk of the activity in  the 27 Member States is associated with 
two main Declaration areas of Solidarity and inclusion (Chapter II) and Safety, security 
and  empowerment  (Chapter  V),  while  the  biggest  gaps  are  seen  in  the  area  of 
Sustainability (Chapter VI).    

•  The impact indicator framework developed by the study suggests that an effective 
implementation of digital rights initiatives on the ground is still limited, estimated 
to be applied only at 61% on average and across all Declaration areas. This shows that 
significant  gaps  still  exist  and  digital  rights  and  principles  require  further  attention 
from the Member States. 

•  The highest impact (67%) is seen in horizontal commitments related to ‘Putting people 
at the centre of the digital transformation’ (Chapter I). This shows that Member States 

52 Study to support the monitoring of the Implementation of the Declaration on Digital Rights and Principles, Available here: 
https://digital-strategy.ec.europa.eu/en/news-redirect/883230 

74 

 
 
implement measures at a rather strategic level, while more operational action in more 
concrete Declaration areas is needed, especially in ‘Participation in the digital public 
space’ (Chapter IV) and ‘Safety, security and empowerment’ (Chapter V). 

3.  Funding and Investment: 

•  The  EU  has  made  a  significant  financial  contribution  to  the  digital  transformation 
through various programmes, including the Recovery and Resilience Fund, the Digital 
Europe  Programme,  and  the  Connecting  Europe  Facility.  These  funds  support  the 
deployment  of  digital  infrastructure,  the  development  of  digital  skills,  and  the 
adoption  of  advanced  technologies  by  businesses  and  public  services.  The 
investments  aim  to  foster  competitiveness  and  reduce  dependencies  on  foreign 
technologies. 

4.  Collaborative Efforts: 

•  Member  States  and  the  EU  have  worked  together  to  promote  a  safer  and  more 
responsible  online  environment  notably  with  new  legislation  such  as  the  Digital 
Services Act. The European Board for Digital Services and other regulatory bodies have 
played a crucial role in ensuring the effective implementation of these frameworks. 
In the same vein, the Member States and the EU collaborate to promote fairer and 
more contestable digital markets in Europe with the Digital Markets Act, coordinating 
with  sectoral  regulators  within  the  DMA  High  Level  Group,  and  cooperating  with 
Member  State  authorities  through  the  European  Competition  Network.  The  EU's 
digital sovereignty agenda aims to reduce  reliance on foreign technology, enhance 
infrastructure,  and  address  privacy  concerns  while  facing  challenges  from  US  and 
Chinese dominance53. 

These actions demonstrate the commitment of Member States and the EU to developing synergies 
and improving coordination to achieve the objectives set out in the Declaration on Digital Rights and 
Principles, ultimately contributing to a more coherent and effective digital transformation across the 
EU, with a strong focus on competitiveness and sovereignty. 

SUMMARY ASSESSMENT: Limited progress 

53 World Economic Forum, What is digital sovereignty and how are countries approaching it?, 2025.  

75 

 
 
 
 
20.3  Member  States  should  associate  stakeholders  in  appropriate  consultation  in  the 

adjustment of the national roadmaps  

PROGRESS AND STATE OF PLAY  

For 9 out of the 21 adjustments submitted, a consultation on the entire adjustment took place. For 
the remaining adjustments, stakeholders were consulted on some aspects of the adjustment and/or 
the consultation took place in the form of regular ongoing exchanges and/or other consultations (e.g. 
as part of national digital strategy).  

SUMMARY ASSESSMENT: Limited progress 

76 

 
 
 
21  Fostering coordination and coherence  

21.1  Member States should cooperate with the Commission to implement tools and solutions 
to promote consistency in the application of existing legislative acts and to explore ways 
to reduce administrative burdens, in particular for SMEs. 

PROGRESS AND STATE OF PLAY 

Reducing the administrative burden is one of the European Commission’s main priorities, as reflected 
in the guidelines and mission letters presented to the new College of Commissioners. The Commission 
has committed to simplifying regulations, reducing bureaucracy, and enhancing digital transformation 
to support these goals. 

Since July 2024, the European Council54 and the Council55 have supported these efforts, recognising 
the importance of streamlining regulations to foster economic growth and innovation. The Council 
has backed initiatives aimed at reducing the regulatory burden on businesses, particularly SMEs, and 
has encouraged Member States to implement measures that align with these objectives. 

The Commission and Member States have taken several actions to reduce the administrative burdens 
for  SMEs,  with  a  particular  focus  on  enhancing  competitiveness  and  simplifying  regulatory 
environments. Key actions and developments include: 

1.  Omnibus Simplification Package: 

This  package,  adopted  on 26 February 2025,  aims  to streamline  EU  sustainability  reporting 
requirements  and  reduce  the  administrative  burden  for  companies,  particularly  SMEs.  It 
includes  amendments  to  the  Corporate  Sustainability  Reporting  Directive  (CSRD),  the 
Corporate Sustainability Due Diligence Directive (CSDDD), and the EU Taxonomy. The goal is 
to reduce administrative burden by at least 25% in general and by at least 35% for SMEs by 
the end of the Commission's mandate56. On 21 May 2025, the Single Market Simplification 
proposal introduced a new category of small-mid caps. The measures will ease compliance 
obligations and thus free resources for growth and investment across the Single Market. The 
measures boost incentives for SMEs to scale up, digitise regulatory processes, reduce red tape, 
and support the Commission's goal to cut administrative costs by 25% overall and by 35% for 
SMEs by the end of this mandate. 

2.  Digital  Transformation:  The  Commission  has  emphasised  the  role  of  digital  tools  and 
platforms  in  reducing  administrative  burden.  Initiatives  such  as  the  Single  Digital  Gateway 
provide  a  one-stop-shop  for  regulatory  information  and  online  procedures,  simplifying 
compliance for businesses. 

3.  Simplification  of  Revenue  Administration:  The  EU's  Technical  Support  Instrument  2025 
Flagship  project  focuses  on  simplifying  and  modernising  tax  and  customs  administration 
systems  to  reduce  the  administrative  burden  for  SMEs.  This  initiative  aims  to  streamline 
processes,  implement  digital  solutions,  and  enhance  tax  certainty.  The  project  supports 
Member States in reviewing their tax policies and administrative procedures to create a more 

54 European Council meeting on 20 March 2025 – Conclusions.  
55 Council of the European Union, Council conclusions on a tax decluttering and simplification agenda which contributes to 
the EU’s competitiveness, 2025. 
56 European Commission, Commission simplifies rules on sustainability and EU investments, 2025.  

77 

 
 
business-friendly environment. This is the case for the 2025 TSI project aimed at introducing 
an  electronic  transaction-based  B2B  tax  reporting  system  in  Germany,  and  the  project  on 
reforming  the  design  of  concurrent  payment  systems  for  payroll  tax  and  social  security 
contributions in Greece.  

4.  Digital  Tools  and  Support:  The  Single  Digital  Gateway  (SDG)  provides  a  one-stop-shop  for 
reliable administrative and regulatory information, online  procedures, and assistance at all 
levels of public  administration. This tool aims to reduce  the burden and costs for SMEs  by 
simplifying access to regulatory information and procedures. 

5. 

In 2025, several TSI projects from five Member States—Denmark, Finland, Germany, Romania, 
and  Spain—have  been  identified  as  supporting  the  implementation  of  the  Single  Digital 
Gateway (SDG) and the Only Once Technical System (OOTS). Denmark, through the Danish 
Agency  for  Digital  Government,  is  working  on  a  digital  solution  to  ensure  vertical  and 
horizontal  traceability  of  interoperability  assessments  for  planned  digital  public  services. 
Finland, represented by the Digital and Population Data Service Agency, is focusing on eIDAS 
information security audits and compliance management, benefiting both Finland and other 
Member States. In Germany, efforts are directed at improving the digital interoperability of 
294 German counties. Romania, through the Authority for the Digitalisation of Romania (ADR), 
is developing innovative technologies and tools to create user-centric digital public services. 
Lastly, Spain is enhancing the governance of digital public services at the regional level, with 
initiatives led by the Viceconsejerías de Transformación Digital in Castilla y León and Castilla-
La Mancha, as well as the Agencia Digital de Andalucía. 

6.  Council and Member State Reactions: The Council and Member States have been involved in 
discussions and actions to reduce administrative burden. The Council has supported initiatives 
to simplify regulatory environments and reduce compliance costs for SMEs. Member States 
have  also  taken  individual  measures  to  streamline  their  regulatory  frameworks  and 
implement EU directives aimed at reducing administrative burden. 

These actions demonstrate a collaborative effort between the European Commission and Member 
States  to  create  a  more  supportive  and  competitive  environment  for  SMEs  by  reducing  their 
administrative burden and simplifying regulatory processes. 

SUMMARY ASSESSMENT: Notable progress 

78 

 
 
 
21.2  Member States should exchange best practices on consolidation and codification of the 

existing digital regulatory framework together with the Commission. 

PROGRESS AND STATE OF PLAY 

The Commission had a preliminary discussion with Member States on regulatory simplification and 
administrative burden reduction during the meeting of the Digital Decade Board on 6 March 2025. 
Member State representatives were invited to consider organising an exchange on that subject under 
the Best Practice Accelerator of the Digital Decade Policy Programme. 

SUMMARY ASSESSMENT: No progress 

79 

 
 
 
21.3  Member  States  should  cooperate  with  the  Commission  to  develop  synergies  and 
improve coordination of existing EU laws with their various governance structures and 
entities  to  increase  the  overall  efficiency  and  coherence  of  EU  legislation  while 
contributing  to  the  improvement  of  compliance  and  the  reinforcement  of  the  single 
market. 

PROGRESS AND STATE OF PLAY 

Member  States,  in  collaboration  with  the  European  Commission,  have  taken  several  actions  to 
develop synergies and improve the coordination of existing EU laws. Key initiatives and efforts include: 

1.  Streamlined Implementation: 

Member States have been working to ensure a coherent and efficient implementation of EU directives 
and regulations. This involves transposing EU laws into national legislation while considering specific 
local characteristics, and aligning with overarching EU objectives. Additionally, the European Board 
for Digital Services has set up working groups on specific issues related to platform environment and 
regulation (see 10.3 above). The AI Board also helps to ensure a coherent application of the AI Act, in 
cooperation with local and international stakeholders (see 9.1 above).  

2.  Collaborative Governance: 

Member States participate in collaborative governance structures to improve the coordination of EU 
laws,  including  in  EU-wide  initiatives  where  they  share  best  practices  and  cooperate  with  other 
Member  States  and  EU  institutions.  The  Commission's  work  programme  for  2025,  developed  in 
cooperation with Member States, emphasises the importance of shared responsibility and joint efforts 
to achieve common EU objectives. 

The  Best  Practice  Accelerator  (BPA),  an  operational  component  of  the  Digital  Decade  Policy 
Programme  (DDPP),  was  officially  launched  in  summer  2024.  The  BPA  was  conceived  during 
discussions  at  the  Digital  Decade  Board  meetings  and  was  developed  to  enhance  structured 
cooperation  among  EU  Member  States  in  addressing  shared  digital  policy  challenges.  The  BPA  is 
organised into thematic clusters, each co-led by Member States, providing a systematic framework 
for  the  collection,  sharing,  and  replication  of  proven  policy  measures  through  a  cluster-based 
approach. Its goal is to identify and promote the adoption of effective solutions that can be replicated 
by Member States, contributing significantly to the attainment of the Digital Decade's 2030 targets. 

So far 11 BPA workshops have taken place, focusing on three clusters: Digital Skills, Green IT, and Tech 
Uptake. The Digital Skills Cluster, led by Slovenia, has been particularly active, with 34 best practices 
shared by Member States in 7 workshops between July 2024 and June 2025. These practices focus on 
a  wide  range  of  demographic  groups,  including  children,  adults,  seniors,  public  institutions,  and 
businesses, rural and urban areas, and have been developed in collaboration with the National Skills 
and Jobs Coalitions. 

The governance of the BPA is supported by a dedicated IT platform and a measure repository hosted 
by  the European Commission. This platform  gathers all best practices and challenges  in one place, 
providing a uniform template co-developed with the Member States. Although the repository is not 
yet publicly accessible, it provides a secure and collaborative environment for preparing submissions, 
facilitating  peer  exchanges,  and  supporting  the  documentation  process.  For  a  measure  to  be 
recognised as a best practice, it must meet specific criteria: it should contribute to the Digital Decade 

80 

 
targets,  demonstrate  replicable  and measurable  results,  be  grounded  in  concrete  implementation, 
and exhibit significant evidence of effectiveness or potential impact. 

By  June  2025,  52  best  practices  were  submitted  to  the  repository  across  the  initial  clusters. 
Contributions have been submitted by many Member States, as follows: Germany (10 best practices), 
Finland  (6),  France  (5),  Belgium  (5),  Slovenia  (4)  best  practices),  Hungary  (3),  Ireland  (3),  Italy  (3), 
Luxembourg (3) Czechia (2), Netherlands (2) and Croatia, Denmark, Greece, Portugal, Romania, Spain 
(1 best practice each). Additional practices are currently being developed. On top of those included in 
the  repository,  several  other  best  practices  were  presented  during  workshops  by  Ireland,  the 
Netherlands, Austria, Czechia, and Denmark. 

New  thematic  clusters  are  also  being  considered  for  the  next  reporting  period,  focusing  on 
implementing the digital rights and principles, reducing the administrative burden on businesses, and 
ensuring  digital  sovereignty.  Member  States  were  invited to  express  interest  in  leading  these  new 
areas.  

3.  Policy Alignment: 

Member  States  align  their  national  policies  and  reforms  with  EU  priorities  to create  synergies  and 
avoid fragmentation. This involves adapting national legislation to comply with EU laws, ensuring a 
coherent regulatory framework that supports the single market and other EU objectives. 

SUMMARY ASSESSMENT: Limited progress 

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21.4  Member States should fully leverage the Digital Decade Board’s role and  expertise to 

help support the implementation of digital acquis  

PROGRESS AND STATE OF PLAY 

Throughout 2024 and 2025, the Digital Decade Board (DDB) has been acting as a platform for sharing 
ideas  through  dynamic  roundtable  discussions  and  regular  exchanges  with  Member  State 
representatives. These activities have helped to improve alignment and cooperation among Member 
States on the Digital Decade Policy Programme (DDPP) and the priorities of the new Commission. 

DDB meetings are held four times a year to discuss the implementation of the Digital Decade Policy 
Programme  (DDPP).  The  agendas  of  these  meetings  have  included  monitoring  the  Programme’s 
various instruments and their concrete implementation across Member States. These meetings also 
collect  feedback  on  any  obstacles,  including  the  complexity  of  administrative  due  processes.  This 
directly fulfils the recommendation by ensuring that challenges are addressed and progress is tracked. 
In addition, several DDB Members called for the DDB to play a greater coordination role. 

Such strategic and practical discussions were held under the Belgian and Hungarian Presidencies, in 
May  2024  and  November  2024,  respectively,  in  Brussels  and  in  Budapest.  While  these  meetings 
enabled an exchange of views, as well as a demonstration of the EU Digital Wallet’s applications in 
Belgium,  their  outcomes  highlight  the  need  to  take  further  steps  to  translate  discussions  into 
actionable  progress.  For  instance,  the  DDB  meeting  of  March  2025  focused  on  regulatory 
simplification but underscored the persistent need for streamlining processes across Member States. 

DDB meetings have also been linked to the Best Practice Accelerator (BPA) of the DDPP, with BPA 
participants sharing potential solutions for implementation challenges. In addition, in 2025, Member 
States  were  encouraged  to  lead  new  Clusters  of  work  within  the  BPA,  including  considering  the 
creation of a cluster on administrative burden reduction, which remains at an early stage of discussion. 

In addition, preparations for the 2025 State of the Digital Decade Report (SDD25) have provided a 
key opportunity to assess the  implementation of the  body of EU  law in this area. This assessment 
would benefit from more comprehensive reviews, broader stakeholder engagement, and data analysis 
to ensure consistent progress in integrating and operationalising EU law across Member States. 

Further discussions at DDB meetings are expected under the Polish Presidency (June 2025), and the 
Danish Presidency. The Commission is already holding discussions with Cyprus in preparation for the 
first half of 2026.  

In addition, DDB Members will facilitate the presentation of the report in their respective countries, 
fostering discussions to identify actionable next steps.  

SUMMARY ASSESSMENT: Notable progress 

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21.5  Member  States  should  cooperate  with  the  Commission  to  develop  further  synergies 
across  the  funding  programmes  that  are  mobilised  for  EU’s  digital  transformation,  to 
avoid duplication and pursue complementarities.  

Member States should maximise the impact of the EU budget by supporting in particular 
projects with strong cross-border dimension which have received Seals of excellence or 
should  further  extend  their  coverage,  thus  ensuring  European  investments  act  as  an 
accelerator  for  upcoming  initiatives  to  achieve  the  Digital  Decade’s  objectives  and 
targets. 

Member  States  should  cooperate  with  the  Commission  to  promote  a  streamlined 
investment  process  to  ensure  the  visibility  of  project  pipelines  and  maximise  existing 
synergies  

PROGRESS AND STATE OF PLAY 

Creating  synergies  between  different  programmes  is  often  an  explicit  part  of  their  establishing 
legislation. However, under the current set up, in practice, unless embedded in the very structure of 
the  implementing  body  at  instrument  level  (such  as  a  Joint  Undertaking,  or  a  European  Digital 
Infrastructure Consortium - EDIC),57 the creation of synergies by combining funding at project level 
remains complex and difficult to implement.   

The complexity of the funding landscape makes it difficult for stakeholders to understand how the 
different programmes fit together in an overall intervention logic for moving digital technologies up 
the technology readiness level (TRL) scale and to deployment and use. This is the case especially for 
SMEs that, unlike large companies and research organisations, do not have the capacity to invest in 
opportunity seeking, often with relatively low chances of success.  

There is also a clear need for more synergies between programmes at EU, national and regional levels. 
For example, there are many national and regional support schemes in place for start-ups and spin-
offs that could provide close-to-market support to innovators with market ambition emerging from 
an EU-funded project,  though clear signposting and operational bridges  between those  are largely 
missing.  In many cases,  the  burden of creating the actual synergies is left  to the  stakeholders and 
misses a clear top-down driver.  

Partnerships, Joint Undertakings in particular, have created clear synergies among programmes. While 
they  originated  mostly  from  Horizon  programmes,  they  are  now  often  funded  from  multiple 
programmes, in effect taking the entire ecosystem that they represent from one programme to the 
other. The EuroHPC JU is a highly successful example of this. 

Synergies between sectors have been more difficult to orchestrate. For instance, because of the twin 
transition,  strong  synergies  with  the  transport  and  energy  sector  were  expected.  However,  the 
synergies  across  programmes  were  limited,  even  between  the  Digital  strand  of  the  CEF  and  the 
Transport and Energy strands of the same programme.  Difficulties in creating bridges between the 
ecosystems of multiple sectors in a substantial way (that is, beyond the occasional cross-participation 
of a few actors) have not been addressed to the same extent as those within the digital sector itself. 

57 Combination of funding from multiple sources is foreseen in the basic acts of these instruments. 

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The  emphasis  on  maximising  the  impact  and  effectiveness  of  public  spending,  by  increasing 
coordination and focus, is also a key element of the Competitiveness Compass and the Communication 
on the next multiannual financial framework (MFF)58. During the European Council of March 2021, EU 
leaders stressed the importance of supporting EU competitiveness, welcoming the Competitiveness 
Compass, and had a first exchange of views on the new MFF.  

Moreover, a recent ECA report on the contribution of the Recovery and Resilience Facility to the digital 
transition recommended to better link EU funding schemes and the main digital needs identified. 
The Court recommendation is to ‘target the allocation of funding more effectively, such as by requiring 
a clear link to the EU’s digital transition strategy and prioritising the funding of the previously identified 
digital needs’59. These conclusions will be used notably in the preparation of the next MFF. 

SUMMARY ASSESSMENT: Notable progress 

58 Communication (EC) COM/2025/46 final, The road to the next multiannual financial framework. 
59European Court of Auditors, ECA Special report 13/2025, Support from the Recovery and Resilience Facility for the digital 
transition in EU Member States, A missed opportunity for strategic focus in addressing digital needs, 2025. 

84 

 
 
 
 
21.6  Member  States  should  cooperate  with  the  Commission  to  stimulate  a  closer  and 
bidirectional dialogue with regions and cities including through existing networks; and to 
identify,  collect  and  disseminate  best  practices,  notably  reflecting  the  Declaration  of 
Digital  Rights  and  Principles.  This  should  build  on  existing  ‘Local  Observatories’  which 
could act as the main vehicle for collecting best practices and disseminating them across 
governance levels. Member States should improve data collection and monitoring of the 
digital  transformation  at  the  local  level  in  support  of  the  Digital  Decade  Policy 
Programme  

PROGRESS AND STATE OF PLAY 

There has been notable and continuous progress in stimulating a closer and bidirectional dialogue 
between  Member  States,  the  Commission,  regions,  and  cities.  Several  EU-led  initiatives  have 
contributed to addressing this recommendation: 

•  The  Living-in.EU  movement  has  continued  expanding  its  network,  fostering  cooperation 
among cities and regions to exchange best practices and align digital transformation efforts 
with EU principles. However, engagement levels remain inconsistent across Member States. 
Initiatives like the Eurocities Lab60, launched through the Eurocities Digital Forum, support the 
co-creation and scaling of smart urban solutions by testing new methods of collaboration and 
accelerating the uptake of proven innovations across cities. This approach enables cities to 
learn from each other and deliver more efficient, people-centred digital services. 

•  The European Digital Innovation Hubs (EDIHs) have increasingly supported cities in adopting 
advanced  digital  tools,  with  their  core  mission  focused  on  the  digitalisation  of  businesses.   
EDIHs  have  proven  to  be  powerhouses  for  delivering  digital  solutions  that  empower  local 
communities—whether  by  offering  courses  through  a  national  service  catalogue  (as  in 
Finland), pooling digital services for rural communities in the Somme department (France) or 
organising joint  events with other EDIHs on smart  cities and innovation (Germany, Poland, 
Czechia). Their role is expected to grow further in the coming years. 

•  The  LDT  CitiVERSE  EDIC  currently  involves  14  Member  States  (France,  Belgium,  Croatia, 
Slovakia, Czechia, Italy, Ireland, Luxembourg, Slovenia, Netherlands, Latvia, Estonia, Portugal, 
and Spain) and is rapidly expanding with an expected membership of tens of cities by the end 
of 2025. The EDIC and its members already started to create its structures, developing an EU-
wide ecosystem for AI-driven solutions, services, and platforms, with a focus on scaling up 
innovations  such  as  those  from the  Local Digital  Twins  (LDT)  Toolbox  by  bringing  together 
cities  and  technological  companies.  The  European  AI  office  closely  oversees  the  ongoing 
development of the LDT Toolbox. Once delivered, this useful set of tools for creating Local 
Digital Twins will be handed over to the CitiVERSE LDT-EDIC so that it can be used by other 
interested parties. 

To sum up: these recent initiatives provide a structured approach to supporting cities with data-
driven  policy  tools.  However,  take-up  by  national  and  regional  authorities  remains  a  critical 
challenge if this initiative is to reach its full potential. 

60 Algorithm Register, Eurocities' Digital Forum Lab, available at: https://www.algorithmregister.org/eurocities 

85 

 
 
Moreover, on data collection and monitoring, progress has been limited. Some Member States have 
improved  local-level  digital  indicators,  but  there  is  no  harmonised  methodology  for  systematically 
tracking digital transformation progress at city and regional level.  

The  Local  and  Regional  Digital  Indicators  framework  (LORDI)  digital  maturity  assessment  tool 
(LORDIMAS)  provides valuable insights, but  data integration from cities and municipalities  remains 
fragmented.  The first report on LORDIMAS seeks to partially address this knowledge gap by utilising 
LORDIMAS  data  to  provide  insight  into  the  state  of  digital  maturity  of  subnational  public 
administrations. 2024 marks the first full year of LORDIMAS data collection, encompassing data from 
approximately  100  local, metropolitan,  and  regional  governments.  It  features an  analysis of  digital 
maturity based on the LORDIMAS self-assessments conducted in 2024 by 99 local, metropolitan and 
regional authorities. To enhance the representativeness of data and strengthen the evidence base for 
European policymaking, LORDIMAS aims to increase the number of participating administrations year-
on-year. The number of participating local and regional administrations continues to rise in line with 
ongoing outreach campaigns (status 6 March 2025: 135 entries).  

In  addition,  the  LDT  CitiVERSE  EDIC  will  contribute  to  European  common  data  infrastructure  and 
services  area  of  activity,  with  a  focus  on  the  transversal  Data  Space  for  Smart  Communities,  and 
Climate Neutral Cities initiatives.  It will ensure an open digital infrastructure environment, foster an 
industrial ecosystem for digital twins and a market  for EU SMEs and industry. It will also  carry out 
targeted training for digital smart city solutions. Strategic business and policy priorities for the LDT 
CitiVERSE EDIC concentrate on:  

•  Technical  developments:  design,  development,  deployment,  and  scaling  up  of  EU 
infrastructures  for  digital  twins;  implement  the  common  EU  architecture  blueprint  for  the 
Smart  Communities  Data  Space;  develop  Artificial  Intelligence-based  solutions  for  Smart 
Communities; establish sustainable mechanisms for the EU infrastructure; contribute to the 
CitiVERSE  (Virtual  Worlds)  initiative  to  support  a  strong  EU  ecosystem;  creation  on  and 
animation of an open-source community for Smart Communities; and liaising with existing EU 
infrastructures  like  Destination  Earth  and  the  Euro  High-Performance  Computer  joint 
undertaking.  

•  Cooperation:  identify  opportunities  for  Member  States’  digital  transformation  with  the 
support of LORDIMAS; implement an EU-based data strategy and common governance; define 
funding schemes and draft joint procurements; develop an active digital strategy; cooperate 
with other relevant EU initiatives (e.g., EDIHs, Scalable Cities, EU mission 100 climate neutral 
cities, digital public services, eID, EU Product passport). A special action point is to create a 
New European Bauhaus node for sustainable urban development which also supports digital 
services and capacity building. 

•  Communication  and  dissemination:  capacity  building  and  concerted  actions;  assistance  to 
cities in the process of introducing and implementing Digital Twins; transfer of knowledge in 
relation to scale-up solutions across Europe; share expertise and coordinate mechanisms for 
an interoperable EU (including standardisation).  

Furthermore, cities continue to play a key role in implementing the Declaration of Digital Rights and 
Principles,  ensuring  that  digital  transformation  is  ethical,  inclusive,  and  aligned  with  fundamental 
freedoms. Local initiatives such as the Brussels Digital Rights Charter and Leipzig’s Hardware for Future 
illustrate  how  cities  are  translating  these  principles  into  concrete  actions  that  reinforce  digital 

86 

 
inclusion  and  citizen  protection.  However,  awareness  and  implementation  remain  uneven  across 
Member States, and further action is needed to systematically embed digital rights at local level. The 
Commission's monitoring of digital rights and principles aims to pay closer attention to cities’ and local 
actors’ initiatives and emphasise their role in promoting digital rights. 

SUMMARY ASSESSMENT: Notable progress 

87