COMMISSION STAFF WORKING DOCUMENT Monitoring of EU-level recommendations 2025 Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee, the Committee of the Regions State of the Digital Decade 2026: Closing structural gaps and mobilising investments for 2030 and beyond
Date: 2026-06-17
Institutions: Directorate-General for Communications Networks, Content and Technology, European Commission
Subjects: EU programme, artificial intelligence, competitiveness, digital literacy, digital single market, digital transformation, digitisation, information security, innovation, technological independence

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 17.6.2026  SWD(2026) 156 final  COMMISSION STAFF WORKING DOCUMENT Monitoring of EU-level recommendations 2025            Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee, the Committee of the Regions State of the Digital Decade 2026: Closing structural gaps and mobilising investments for 2030 and beyond {COM(2026) 288 final} - {SWD(2026) 154 final} - {SWD(2026) 155 final} - {SWD(2026) 157 final}  
 
 
State of the Digital Decade 2026: 
Monitoring of EU-level  
recommendations 2025 

 
 
 
 
 
Contents 
Executive summary .................................................................................................................... 2 

Reinforcing technological sovereignty, digital leadership, security and competitiveness ........ 6 

1 

Technological leadership .................................................................................................... 6 

2  Unicorns ............................................................................................................................ 10 

3 

4 

5 

Connectivity infrastructure ............................................................................................... 18 

Cloud and Edge Infrastructure .......................................................................................... 23 

Semiconductors ................................................................................................................ 26 

6  Quantum technologies / HPC ........................................................................................... 28 

7  AI/HPC ............................................................................................................................... 29 

8  Digitalisation of SMEs ....................................................................................................... 31 

9  Uptake of advanced technologies .................................................................................... 33 

10 

Cybersecurity ................................................................................................................ 39 

Protecting and empowering people, reducing burdens and harnessing digitalisation for 
sustainability ............................................................................................................................ 44 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

Basic digital skills .......................................................................................................... 44 

ICT specialists ............................................................................................................... 46 

Digital public services ................................................................................................... 49 

EU Digital Identity Wallet ............................................................................................. 51 

Electronic health record ............................................................................................... 53 

Protection of minors .................................................................................................... 56 

Information integrity .................................................................................................... 59 

Green and digital .......................................................................................................... 63 

Simplification ................................................................................................................ 65 

Cities and regions ......................................................................................................... 67 

Funding the Digital Decade ...................................................................................................... 70 

21 

Efficiency of budget ...................................................................................................... 70 

2026 

1 

 
 
 
 
 
Executive summary 

This staff working document reviews progress made by the European Commission and Member States 
between  June  2025  and  April  2026  in  implementing  the  EU-level  recommendations  from  the 
2025 State  of  the  Digital  Decade  report,  as  required  under  Article 6  of  the  Digital  Decade  Policy 
Programme Decision (Decision (EU) 2022/2481), which requires the Report on the Digital Decade to 
include information on progress regarding recommended policies, measures or actions. 

The  58  recommendations  have  been  streamlined  across  21  thematic  areas  and  assessed  using  a 
qualitative scale – no, limited, notable, or significant progress – based on a review of tangible measures 
and  policy  steps  such  as  legislative  initiatives,  dedicated  funding,  adoption  of  strategies,  and 
implementation of joint projects. 

Given  the  cooperative  nature  of the  Digital Decade Policy  Programme,  the  scope  covers  both  joint 
actions involving the Commission and the Member States and actions undertaken by Member States 
with  significant  EU-wide  impact.  Actions  initiated  solely  by  the  Commission  were  considered  only 
where  they  have  a  clear  link  to  joint  implementation  with  Member  States  or  directly  support  the 
development of national measures. 

Overall, progress reflects strong collective effort but a clear imbalance between EU-level action and 
national implementation. Of the 42 consolidated recommendations assessed, none show no progress; 
19  (45.2%)  indicate  limited  progress;  22  (52.4%)  show  notable  progress;  and  only  1  (2.4%) 
demonstrates significant progress. Over the past year, the EU has developed an extensive policy and 
regulatory  framework  across  artificial  intelligence,  cybersecurity, connectivity, digital  health,  media 
freedom, and digital rights. 

Significant progress has been achieved in the deployment of the EU Digital Identity Wallet, the only 
area to reach this assessment level. All Member States are developing national wallets ahead of the 
December 2026 deadline, large-scale pilots in 2025 involved over 300 organisations across more than 
20 Member States, and a certification framework is being progressively established. 

Notable progress is strongest in the areas of skills, technology deployment, and public services. In 
AI/high-performance computing (HPC), digitalisation of SMEs, uptake of advanced technologies, basic 
digital skills, ICT specialists, digital public services, and simplification, all recommendations assessed 
made notable progress. 

Major investments are underway in AI and high-performance computing, including AI factories and the 
operational launch of the JUPITER exascale system; the European digital innovation hubs network now 
spans  all  Member  States  and  associated  countries;  and  progress  is  also  visible  in  connectivity 
infrastructure,  cloud  and  edge  computing,  and  the  strengthening  of  the  digital-defence  policy 
framework.  In  cybersecurity  and  electronic  health  records,  progress  is  mixed,  with  half  of  the 
recommendations achieving notable progress and half remaining at limited. 

Several  structural  challenges  remain,  as  reflected in  the  limited  progress  made  across  key  areas. 
Information  integrity  and  the  green  and  digital  transitions  are  the  most  concerning,  with  all 
recommendations  in  both  areas  assessed  as  having  made  limited  progress.  National  strategies  to 
counter  foreign 
in  most  countries,  and 
environmental sustainability metrics for digital infrastructure are at an early stage. Cities and regions 
are  also  lagging  behind,  with  two  thirds  of  the  recommendations  having  made  limited  progress, 
reflecting uneven territorial implementation. Limited progress likewise affects quantum technologies. 

information  manipulation  remain  underdeveloped 

2 

 
 
Across unicorns, technological leadership, cloud and edge computing, semiconductors, protection of 
minors,  and  efficiency of budget,  progress  is split  evenly  between  limited  and  notable,  pointing  to 
areas where momentum exists but national follow-through remains inconsistent. 

Looking ahead, the EU’s policy architecture is largely in place and the priority for 2026-2027 is effective 
implementation  at  Member  State  level,  relying  on  updated  national  Digital  Decade  strategic  road 
maps, new EU funding instruments, and stronger coordination through governance structures such as 
the  Digital  Decade  Board.  These  findings  underpin  the  2026  state  of  the  Digital  Decade 
recommendations:  areas  with  limited  progress  will  require  reinforced  action,  those  with  notable 
progress  will  focus  on  scaling  and  uptake,  and  the  EU  Digital  Identity  Wallet  –  as  the  sole  area  of 
significant  progress  –  will shift  towards  broader adoption and integration across  public and private 
services. 

3 

 
 
 
 
Table 1: Overview of the recommendation assessments per area 

Recommendations1 

No progress: 

Limited progress: 

Notable progress: 

Significant progress: 

(-) 

19 (45.2%) 

22 (52.4%) 

1 (2.4%) 

Reinforcing technological sovereignty, digital leadership, security and competitiveness 

Technological leadership (2) 

Unicorns (5) 

Connectivity infrastructure (3) 

Cloud and Edge Infrastructure (2) 

Semiconductors (2) 

Quantum technologies/HPC (1) 

AI/HPC (1) 

Digitalisation of SMEs (1) 

Uptake of advanced technologies (3) 

Cybersecurity (4) 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

1 (50.0 %) 

1 (50.0 %) 

4 (80.0 %) 

1 (20.0 %) 

1 (33.3 %) 

2  (66.7 %) 

1 (50.0 %) 

1 (50.0 %) 

1 (50.0 %) 

1 (50.0 %) 

1 (100.0 %) 

- 

- 

- 

- 

1 (100.0 %) 

1 (100.0 %) 

3 (100.0 %) 

2 (50.0 %) 

2 (50.0 %) 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

Protecting and empowering people, reducing burdens and harnessing digitalisation for 
sustainability   

Basic digital skills (1) 

ICT specialists (2) 

Digital public services (1) 

EU Digital Identity Wallet (1) 

Electronic Health record (2) 

- 

- 

- 

- 

- 

- 

- 

- 

- 

1 (100.0 %) 

2 (100.0 %) 

1 (100.0 %) 

- 

- 

- 

- 

1 (100.0 %) 

1 (50.0 %) 

1 (50.0 %) 

- 

1 As part of the 2025 State of the Digital Decade report, 58 EU-level recommendations were issued. For the purpose of this 
assessment,  these  recommendations  have  been  streamlined  and,  where  appropriate,  grouped  thematically  in  order  to 
reduce reporting burden and improve the clarity and consistency of the analysis. The resulting set of 42 recommendations 
reflects this consolidation and does not alter the substance or scope of the original recommendations. 

4 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Recommendations1 

Protection of minors (2) 

Information integrity (2) 

Green and digital (1) 

Simplification (1) 

Cities and regions (2) 

No progress: 

Limited progress: 

Notable progress: 

Significant progress: 

(-) 

19 (45.2%) 

22 (52.4%) 

1 (2.4%) 

- 

- 

- 

- 

- 

1 (50.0 %) 

1 (50.0 %) 

2 (100.0 %) 

1 (100.0 %) 

- 

- 

- 

1 (100.0 %) 

2 (66.7 %) 

1 (33.3 %) 

- 

- 

- 

- 

- 

- 

Funding the Digital Decade   

Efficiency of budget (2) 

- 

1 (50.0 %) 

1 (50.0 %) 

5 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Reinforcing  technological  sovereignty,  digital  leadership,  security 
and competitiveness 

1  Technological leadership 
1.1  Member States should increase their public digital R&I expenditure, prioritising R&I 
in  the  EU’s 

in  digital  technologies  that  play  a  strategic  role 

investment 
competitiveness, resilience and sovereignty 

In November 2024, the European Council reaffirmed its commitment to increasing R&D spending (first 
included in the 2002 Lisbon Strategy) by adopting the Budapest Declaration on the New European 
Competitiveness Deal. Through the declaration, Member States recognise the need to boost Europe’s 
R&I investments, especially in disruptive technologies. For this reason, EU Member States committed 
to reach the target of 3% of GDP expenditure for R&I by 2030. 

According to the most recent (2024) Eurostat data, the 3% objective is still some way off for several 
Member States; only 6 countries reached the 3% target: Sweden (3.6%), Belgium (3.4%), Austria (3.3%) 
and Finland (3.3%), followed by Germany (3.1%) and Denmark (3.0%). At the same time, 7 EU countries 
registered R&I expenditure of below or equal to 1%: Romania and Malta (0.5% each), Cyprus (0.7%), 
Bulgaria (0.8%), Latvia (0.9%), and Luxembourg and Slovakia (1.0%). 

Overall, European R&I intensity2 decreased slightly, by 0.2%, from 2.26% in 2023 to 2.24% in 20243. 

This European R&D intensity remains lower than all main international competitors, with South Korea 
leading the way with an estimated 4.96% in 2023, 1.52% percentage points higher than the United 
States (3.44% R&I intensity in 2023)4. 

A positive trend was detected on the estimated European government budget allocations for research 
and development (GBARD): in 2024 it stood at EUR 127 916 million, equivalent to 0.71% of EU GDP. 
This signals a 3.4% positive increase from 2023, when estimated GBARD stood at EUR 123 675 million5. 

According to Eurostat, in the breakdown of GBARD by socio-economic objectives, 9.4% of government 
budget  allocations  for  R&D  were  spent  on  industrial  production  and  technology  in  2024 6 .  This 
represents a 53% increase in EU spending per inhabitant in the ‘Industrial production and technology’ 
socio-economic  objective  between  2014  and  2024.  The  EU  countries  that  spent  the  most  per 
inhabitant  in  this  objective  in  2024  were  Belgium,  Germany,  Luxembourg  and  Austria  (more  than 
double the EU average). This demonstrates an upward trend in European governments’ prioritisation 
of R&D resources towards technology. 

However, as already highlighted by the Draghi report, the vast gap between European Union (EU) and 
international counterparts in R&D intensity comes from the source of R&D funding and, specifically, 
private spending on R&D. 

Gross expenditure on R&D (relative to GDP) in the European government and higher education sectors 
(0.72%) is similar to its main international counterparts (China 0.57%, Japan 0.68%, South Korea 0.93%, 

2 Calculated as Member States gross domestic expenditure on R&D, identifying the portion of the economy dedicated to 
R&D. 
3 R&D expenditure, Eurostat, Statistics Explained, Eurostat, November 2025. 
4 See note 3, page 8. 
5 EU governments increased R&D allocations by 3% in 2024, Eurostat, 29 July 2025. 
6 Government budget allocations for R&D (GBARD), Eurostat, January 2026. 

6 

 
 
 
United States 0.64%). However, 2024 R&D expenditure by the business enterprise sector in the EU was 
equal to 1.49% of GDP (− 1 percentage point from 2023), whereas this share was as high as 3.93% in 
South Korea (2023 data), 2.72% in Japan (2023 data), 2.70% in the United States (2023 data), and 2.23% 
in Switzerland (2023 data). 

The same trend is confirmed by the 2025 EU Industrial R&D Investment Scoreboard7, which looked at 
the growth rate of nominal R&D investment by EU-headquartered companies included in the report 
(among the 2 000 worldwide with the highest annual R&D spending)8. In 2024 the growth registered 
was 2.9% down from the 9.3% recorded in 2023. This was well below the US (7.8%) and Japan (7.1%). 

To  conclude,  there  have  been  some  positive  trends,  especially  in  the  budget  allocated  by  EU 
governments to research and innovation. At the same time, the 3% of R&D intensity is still a hard-to-
reach  target  for  several  Member  States.  As  the  data  shows,  the  key  difference  remains  business 
enterprise expenditure: those MSs with a higher R&D intensity also recorded higher shares of business 
enterprise expenditure on R&D relative to GDP9. To reach the 3% target, Member States would need 
to facilitate private companies’ R&D expenditure, while continuing to increase government support 
for R&D, which would be essential to encourage private investments and direct them towards common 
strategic priorities. 

SUMMARY ASSESSMENT: Limited progress 

7 The 2025 EU Industrial R&D Investment Scoreboard, IRI, European Commission, 22 December 2025. 
8 The minimum R&D investment needed to enter the scoreboard ranking this year was EUR 63 million. 
9 Sweden (2.61%), Belgium (2.43%), Austria (2.25%), Finland (2.19%), Germany (2.14%), and Denmark (1.89%). 

7 

 
 
 
 
 
1.2  Member States should strengthen their support to innovative actors, including start-
ups proposing disruptive digital applications and services. (b) Member States should 
boost the development of digital infrastructures that contribute to societal resilience 
in  crisis  contexts.  (c)  Member  States  should  better  connect  the  defence  and  digital 
innovation  communities,  foster  a  new  mindset  towards  preparedness  and  security 
culture  across  the  digital  sector,  identify  synergies  between  defence  and  digital 
programmes, investments, and applications. 

The  period  under  review  has  seen  a  significant  acceleration  in  EU-level  policy  activity  at  the 
intersection  of  digital  innovation  and  defence,  driven  by  deteriorating  geopolitical  conditions  and 
growing recognition of the role of technological edge in deterrence. Evidence of systematic national-
level  action  specifically  connecting  digital  and  defence  innovation  communities  remains,  however, 
limited, and Member States have yet to provide comprehensive reporting on dedicated digital-defence 
strategies or measures. 

The  Defence  Readiness  Road  Map  2030  (16 October  2025)  identified  innovation  and  dual-use 
technologies as critical enablers and established cyber, AI and electronic warfare as one of nine priority 
capability areas, calling on Member States to form capability coalitions across all nine areas by Q1 2026. 
Austria took the lead on the capability coalition on AI, which is a concrete example of Member State 
ownership in the digital-defence space. The following month, the Defence Industry Transformation 
Road Map (19 November 2025) reinforced this direction, framing software-defined warfare, dual-use 
spin-in, and engagement with new defence actors (particularly SMEs and start-ups) as cornerstones of 
Europe’s defence industrial transformation. 

On the legislative side, the mid-term review of cohesion policy (October 2025) opened the possibility 
of channelling unused cohesion funds into defence and security projects with 100% EU cofinancing. 
The  Regulation  on  incentivising  defence-related  investments  in  the  EU  budget  (December  2025) 
broadened the scope of the Digital Europe Programme to dual-use across all objectives, extended the 
EIC Accelerator to dual-use and defence companies, and opened the STEP Scale-Up Scheme to defence, 
creating structured pathways for digital and deep tech actors to access funding. 

At programme level, SAFE (adopted May 2025) includes artificial intelligence and electronic warfare 
among eligible procurement categories. Of the 19 Member States that applied for financial assistance, 
the  national  investment  plans  of  eight  were  approved  by  the  Council  in  early  2026,  covering 
EUR 38 billion of the EUR 150 billion available, with first disbursements expected in the course of 2026. 
The  European  Defence  Industry  Programme  (EDIP),  adopted  at  the  end  of  2025,  establishes  a 
framework to strengthen the defence industrial base. From March 2026 its first work programme is 
expected to contain measures relevant to digital and innovative defence actors. Within the European 
Defence Fund, the EU Defence Innovation Scheme accounts for approximately 23% of the 2026 work 
programme and is the primary instrument through which the Commission supports innovative digital-
defence actors. 

Most recently, the Commission tabled the AGILE programme proposal (25 March 2026), designed to 
provide  rapid  and  flexible  support  to  new  defence  actors  (particularly  SMEs,  including  those 
transitioning from dual-use) to develop and deploy mission-driven technologies in response to urgent 
needs identified by Member States. 

8 

 
 
Progress  at  EU  institutional  level  has  been  substantial:  the  policy  architecture  linking  innovation 
support,  programme  synergies  and  rapid  response  mechanisms  is  now  largely  in  place.  Key  gaps 
remain, however. National-level reporting on digital-defence strategies and on the effective uptake of 
the synergies created by recent regulatory changes is limited, as these have still to be implemented in 
the  relevant  work  programmes  of  the  European  Innovation  Council  (EIC)  and  the  Digital  Europe 
Programme (DEP). The structural separation between civilian digital and defence communities persists, 
and the promotion of security culture across the digital sector remains difficult to assess in the absence 
of systematic Member State reporting. Translating the EU-level enabling framework into concrete and 
measurable national actions remains the primary challenge for the period ahead. 

SUMMARY ASSESSMENT: Notable progress 

9 

 
 
 
 
 
2  Unicorns 
2.1  Member States should support coordinated action across the single market to address 
financial, regulatory, and administrative barriers and mobilise public policies tackling 
a comprehensive range of domains. 

Progress on administrative barriers  by Member States is systematically measured by the European 
Startup  Nations  Alliance  (ESNA)  through  its  tracking  of  Member  State  action  to  address  the  ‘Fast 
startup creation, smooth market entry’ and ‘Digital first’ startup nations standards (SNSs) monitored 
by ESNA. These standards set goals of minimising, for example, administrative barriers and costs faced 
by entrepreneurs when establishing a start-up while maximising the use of digital services that start-
ups can use to interact with public sector actors. 

By  the  end  of  2025,  the  ‘Fast  startup  creation,  smooth  market  entry’  SNS  had  reached  a  77% 
implementation rate across Member States, up from 70% in 2024. Businesses can be set up in one day 
for less than EUR 100 in five countries. While no country has yet reached full implementation, Malta 
(98%), Netherlands (96%) and Spain (94%) are close to completing this standard. For example, in 2025 
over 500 companies were able to register following the introduction in December 2024 of a new legal 
form  –  the  variable  capital  company  (VCC)  –  by  the  Bulgarian  authorities.  Also  in  Czechia,  full 
digitalisation of the trade licensing register cut out redundant steps in company registration. 

In  2025  the  ‘Digital  first’  SNS  reached  a  75%  implementation  rate  across  Member  States,  a 
4 percentage-point increase from 2024. Businesses can be set up in one day for less than EUR 100 in 
five countries. Two Member States (LU, MT) achieved full implementation, while seven others are at 
95%,  so  close  to  completing  this  standard.  One  example  is  Czechia’s  ‘eDoklady’  mobile  app, which 
provides digital official documents. 

Financial barriers are addressed by the ‘Access to finance’ startup nations standard, which reached a 
77%  implementation  rate  across  Member  States  in  2025,  up  from  72%  in  2024.  Examples  of  new 
initiatives in this area are presented in this report in the section on the analysis of the recommendation 
that  ‘Member  States  should  increase  the  amount  and  diversity  of  private  capital  available  for  co-
investing in high-growth start-ups’. 

Regulatory barriers are reflected by the ‘Innovation of regulation’ startup nations standard, which is 
also monitored by ESNA. By contrast, progress in implementing the ‘Innovation in regulation’ standard 
had reached only 55% by the end of 2025. This is the lowest level of implementation of all eight startup 
nations  standards,  confirming  that  this  is  an  area  where  Member  States  need  to  double  down. 
Examples of new initiatives of relevance to this standard include the Irish government’s commitment 
to  systematically  apply  SME  testing  in  all  new  legislation;  in  Belgium,  the  Flemish  government’s 
‘Regelrecht’ aims to reduce regulatory pressure through public consultation with citizens, businesses 
and other stakeholders; in Germany, a draft ‘Regulatory Sandboxes Act’ was adopted by the Federal 
Cabinet. However, by the end of 2025, it had still not been finalised. 

SUMMARY ASSESSMENT: Limited progress 

10 

 
 
 
 
2.2  Member States should promote tech transfer, facilitate the creation of spin-offs from 

universities and research centres. 

Progress in tech transfer is systematically measured by the European Startup Nations Alliance (ESNA) 
through its ‘Existence of policies for smooth tech transfer’ indicator. The indicator – which includes a 
broad scope of institutional initiatives, including tech transfer offices, dedicated funding schemes, and 
legislation  aimed  at  reforming  intellectual  property ownership  –  revealed  an  average  score  among 
countries surveyed in 2025 of 96%, a 19-percentage point improvement on 2024. The progress was 
driven primarily by Bulgaria, Estonia, and Poland (which improved from 0% to 100%) and Germany and 
Italy, which doubled their score from 50% to full implementation. Romania showed a negative trend, 
decreasing from full implementation in 2024 to 0% in 2025. 

Nevertheless, there is significant diversity in approaches. Some Member States focus on a university 
network  of  tech  transfer  offices  to  manage  IP  rights  and  spin-off  activities,  while  others  have 
implemented  legislative  reforms  to  clarify  IP  ownership  of  publicly  funded  research.  Some  have 
established  funding  programmes  for  early-stage  start-ups  and  institutional  support  for  academic 
research transitioning into entrepreneurship. 

2025 saw some Member States adopt reforms aimed at facilitating technology transfer and spin-off 
creation. For example, in 2025 Poland launched ‘Science4Business’, a programme aimed at enhancing 
synergies/cooperation  between  scientific  research  and  business  stakeholders  that  will  receive 
PLN 296.7 million in funding between now and 2029. 

Other examples include: 

•  Harmonisation by the Netherlands of its IP framework, with Dutch universities updating the 
national IP deal term principles to provide transparent, fair, and market-aligned agreements 
between researchers, universities, and enterprises. 

•  The  launch  by  Germany  of  its  High-Tech  Agenda,  which  aims  to  strengthen  the  ability  to 
translate  research  innovation  into  commercial  use  cases.  For  example,  AI  spin-offs  are 
supported through EXIST, a federal programme that provides funding for academics to develop 
and commercialise their research. 

In parallel, Member States should continue working with ESNA to compare the IP policy and spin-off 
frameworks they have in place with other Member States, to see if they are aligned with best policy 
practices, and update their frameworks accordingly. 

SUMMARY ASSESSMENT: Notable progress 

11 

 
 
 
 
2.3  Member  States  should  mobilise  public  procurement  budget  to  procure  innovative 

products and services from start-ups. 

Public procurement remains an important lever in driving innovation across the EU. Annually, Member 
States spend 14% of their GDP on goods and services, creating a powerful mechanism for stimulating 
demand  for  innovative  products  and  services  from  start-ups  while  improving  the  quality  of  public 
services.  Nonetheless,  only  10%  of  public  procurement  funds  across  the  EU  are  designated  for 
innovative products and services, compared to 20% in the United States and 25% in South Korea10. 
According to the 2025 EU Startup Nations Standards Report11, the average score for the ‘existence of 
incentives for public buyers and procurement services to procure innovation from startups’ indicator 
among the countries surveyed was 83%, up 26% year-on-year. These include innovation partnerships, 
pre-commercial procurement, competitive dialogues, design contests and other measures designed to 
promote  innovation  procurement.  Czechia,  Italy  and  Slovenia,  in  particular,  have  managed  to  raise 
their  score  from  0%  to  100%  since  2024.  Currently,  18  Member  States  explicitly  promote  public 
procurement from start-ups, up from 11 in 2024. 

In  the  Netherlands,  under  the  Dutch  Startup  in  Residence  Intergov  programme,  civil  servants  and 
entrepreneurs  co-create  solutions  to  pressing  challenges  facing  public  administrations.  The 
programme offers simplified innovative tenders worth EUR 25 000, with the potential for continued 
collaboration, thereby creating a path for sustainable growth through procurement. 

Germany, under its High-Tech Agenda, has committed to streamlining innovative public procurement 
procedures  and  to  leveraging  the  dynamic  capabilities  of  start-ups  to  drive  economic  growth  and 
improve public service quality. For instance, the agenda proposes a special direct order value threshold 
of EUR 100 000 to reduce the administrative burden on start-ups. 

In its 2026 budget, the Spanish Centre for the Development of Industrial Technology12 (CDTI) allocated 
EUR 75 million  for  innovative  public  procurement,  including  pre-commercial  procurement  for  high-
tech prototypes and demonstrators across digital health, autonomous mobility, clean energy, and food 
security. 

A major reason for the slow uptake of innovation procurement in the public sector in Europe is the 
lack  of  strategic  planning.  The  2015  opinion 13  of  the  European  Research  Area  and  Innovation 
Committee (ERAC) – an advisory committee of the Council of the European Union – to create EU and 
national  action  plans  for  innovation  procurement  has  not  yet  been  fully  implemented.  EU-wide 
benchmarking shows that research and innovation programme support for innovation procurement is 
growing but still limited. Only a few Member States have incorporated innovation procurement as a 
strategic  objective  in  their  R&I  policies.  Existing  procurement  frameworks  often  remain  rigid,  risk-

10 Commission staff working document – The EU Startup and Scaleup Strategy: Choose Europe to start and scale, European 
Commission, SWD(2025) 138 final, 28 May 2025. 
11 EU Startup Nations Standards Report 2025, Europe Startup Nations Alliance (ESNA), February 2026. 
12 From science to market: CDTI Innovation will allocate up to EUR 1.817 million in 2026 in grants, venture capital 
investment, public procurement and soft loans for business R&D&I, transfer and scaling, CDTI Innovación (Ministry of 
Science, Innovation and Universities, Spain), 16 February 2026. 
13 Commission staff working document – The EU Startup and Scaleup Strategy: Choose Europe to start and scale, European 
Commission, SWD(2025) 138 final, 28 May 2025. 

12 

 
 
 
averse,  and  burdensome,  posing  significant  barriers  to  the  participation  of  emerging  firms.  Recent 
research  highlights  issues  such  as  insufficient  use  of  innovation-friendly  criteria,  and  limited 
procurement literacy among start-ups as bottlenecks. A lack of financial incentives for public buyers is 
another  reason  holding  back  innovation  procurement  in  Europe.  Existing  solutions  are  typically 
cheaper  than  innovative  ones,  as  the  latter  are  not  yet  produced  at  large  scale141516.  Furthermore, 
procurement  procedures  frequently  do  not  accommodate  emerging  technologies,  leading  to 
exclusionary tender conditions that reinforce the status quo. Overspecification in tender documents 
remains  a  significant  barrier  to  innovation.  Public  buyers  often  reuse  specifications  from  previous 
procurements,  which  tend  to  favour  established  solutions.  By  prescribing  specific  outcomes  rather 
than defining the problem to be solved, such practices limit the ability of suppliers with innovative 
alternatives to compete. 

Identifying  innovation  procurement  opportunities  remains  challenging  for  innovative  companies. 
Although  public  buyers  can  flag  relevant  tenders  as  ‘innovation  procurements’,  this  option  is 
underused in practice, making it particularly difficult for smaller firms to navigate the vast volume of 
annual tender notices. Public buyers often design their calls for tenders without fully exploring market 
capabilities, particularly regarding innovative solutions. 

SUMMARY ASSESSMENT: Limited progress 

14 Suresh, K. (2022), ‘Analysing Incentive Issues and Failures in Innovation Procurement’, SSRN Electronic Journal. 
15 Manika, S. (2020), ‘Mechanisms for innovative-driven solutions in European Smart Cities’, Smart Cities, 3(2), pp. 183-199. 
16 Edler, J. & Georghiou, L. (2007), ‘Public procurement and innovation – Resurrecting the demand side’, Research Policy, 
36(7), pp. 949-963. 

13 

 
 
 
 
 
2.4  Member States should increase the amount and diversity of private capital available 

for co-investing in high-growth start-ups. 

In 2025 several actions were initiated or reinforced by Member States, demonstrating commitment 
and progress. Although implementation is ongoing, progress has been made and measures adopted. 

Several  new  measures  shaped  in  2025  saw  Member  State  authorities  partner  with  the  European 
Investment Fund (EIF), part of the European Investment Bank (EIB) Group. For example, in 2025 the 
German Ministry of Economic Affairs and the EIF worked on improving access to professional venture 
capital and growth funds for technology‑driven start-ups. The result (announced in January 2026) was 
the  investment  of  an  additional  EUR  1.6 billion  through  the  long-standing  EIF  German  Equity 
programme. At the same time, the setup of the Growth Fund II (Wachstumsfonds II), the successor of 
Both 
the  Growth 
Wachstumstumsfonds include private investors on the fund-of-fund-level. 

(Wachstumsfonds  Deutschland),  was 

Fund  Germany 

prepared. 

In  November  2025  the  EIB  Group  and  the  state-owned  Polish  development  fund  started  working 
together  on  a  new  digital  platform  that  helps  innovative  projects  access  funding.  The  EIF  will  also 
allocate PLN 500 million to the new Future Tech Poland fund. 

In 2025 Romania’s state-owned development bank, BID, committed EUR 20 million17 to the Three Seas 
Initiative  (3SI)  Innovation  Fund,  taking  the  3SI  fund  –  which  is  designed  to  catalyse  investment  in 
growth-stage  companies  across  central  and  eastern  Europe  –  to  the  EUR 100  million  milestone. 
Romania’s contribution joined those of Czechia, Croatia, Hungary and Poland. The EIF matches national 
contributions and aims to mobilise at least EUR 1 billion for private equity, venture capital, and private 
credit investments. 

Luxembourg introduced a tax credit of 20% on investments made by individual taxpayers in eligible 
start-up entities, up to a maximum of EUR 100 000 per year18. 

Moreover,  some  Member  States  continued  to  implement  previously  established  measures.  For 
example,  France’s  Tibi  initiative  (a  multiannual  programme  to  channel  private  savings  into 
technological innovation) announced in Sept 202519 that it was aiming to bring total capital allocated 
by the initiative to more than EUR 15 billion by the end of 2026. 

Although there has been progress in 2025, the reality remains that later-stage European investments 
are increasingly dominated by US venture capital (VC) firms. For example, in 2024-2025, 54% of lead 
investors in late-stage VC investments (USD 100 million+) in European AI start-ups were from American 
investors. Against that background, in 2025 the European Commission launched the Scaleup Europe 
Fund, which will invest only in EUR 100 million+ investment rounds. However, EU-level action alone in 
this area is not enough. Member States should take action and increase the European capital available 
for late-stage investment rounds. 

17 Romanian Investment and Development Bank (BID) joins EIF-led fund to boost CEEs companies, European Investment 
Fund, 14 November 2025. 
18 New in 2026, Luxembourg Government, 29 December 2025. 
19 Initiative TIBI: un objectif réhaussé à 15 milliards d'euros, French Ministry of Economy and Finances, 16 September 2025. 
14 

 
 
 
 
 
 
 
 
It is noteworthy that in December 2025 the EIB announced20 ETCI 2.0, an expansion of the European 
Tech  Champions Initiative, with the  EIF and EIB committing a total of  EUR 1.25 billion of their own 
funds to ETCI 2.0. While several Member States (BE, DE, ES, FR, IT and NL) are already contributing to 
ETCI, there remains a significant opportunity for the majority of Member States to join the reinforced 
ETCI 2.0 initiative. 

SUMMARY ASSESSMENT: Limited progress 

20 EIB Group renews record-high financing target of €100 billion to boost Europe’s strategic and technological 
independence, European Investment Bank, 11 December 2025. 
15 

 
 
 
 
 
2.5  Member  States  should  identify  and  support  tech  innovators  in  their  countries  (e.g. 
identified  through  the  innovation  radar,  or  EIC  or  the  Strategic  Technologies  for 
Europe Platform Seal of Excellence). 

In 2025 a number of relevant actions were initiated at Member State level to support tech innovators 
in their countries that had received previous recognition at EU level (e.g. EIC or STEP Seal of Excellence 
holders). This shows that some progress has been made with respect to this policy recommendation. 
However, not all Member States have pursued such opportunities. Moreover, countries that launched 
initiatives often did not target all types of Seal of Excellence (SoE) holders. 

Countries that launched national or regional funding opportunities for Seal of Excellence  holders in 
2025 include Belgium, Bulgaria, Spain, Italy and Portugal. Bulgaria and Slovakia also launched initiatives 
that used structural funds and Recovery and Resilience Facility (RRF) funds for EIC Seal of Excellence 
holders.  Lithuania  chose  to  transfer  such  funds  to  the  European  Commission  and  empowered  the 
Commission to distribute this funding to Lithuanian EIC Seal of Excellence holders. 

In 2025 the European Commission issued STEP seals to over 100 European digital innovation hubs that 
successfully passed the evaluation, regardless of whether or not they were selected for funding by the 
EU. Due to the strategic technology aspect of these hubs, the STEP Seal presents new opportunities 
for Member States to identify and fund these hubs. Bulgaria and Romania are notable in promoting 
such opportunities for such STEP holders in their territories. 

In 2026 the SoE landscape will expand further with the first ‘SoE for consortia’ being awarded under 
the EIC Transition programme. 

Member State authorities have not adequately leveraged the growing store of data and intelligence 
available via the Commission’s Innovation Radar platform. This platform – which in 2025 passed the 
milestone of 16 000 EU-funded innovations – offers a rich, sophisticated and growing dataset of EU 
innovators  who  have  developed  cutting-edge  innovations.  These  are  proven  innovators  with  real 
potential to enrich national innovation programmes. 

In Bulgaria projects that received an SoE under EIC Accelerator from 2024 onwards are supported by 
a  similar  national  scheme  under  the  European  Regional  Development  Fund  (ERDF)  programme 
‘Research, Innovation and Digitalisation for Smart Transformation’ 2021-2027 (PRIDST). In 2025 the 
Veneto  region  in  Italy  opened  a  call  to  support  Seal  of  Excellence  holders  based  in  the  region.  In 
Portugal  a  support  scheme  for  holders  of  the EIC  Seal  of  Excellence  (SoE)  was  launched  under  the 
multiannual funding framework ‘Portugal 2030’ and ran up to the end of October 2025. Additionally, 
in 2025 Romanian and Bulgarian national funding authorities started to identify digital innovation hubs 
that have a STEP Seal of Excellence with a view to providing hubs 100% funded by national programmes. 
The first hubs to be launched under this scheme are expected to start operating in 2026. 

Although Member States have taken some actions, they have been sporadic and – in many cases – 
time-limited.  It  appears  that  some  actions  that  ended  before  2025  were  not  renewed.  Examples 
include  Spain  (support  for  EIC  Accelerator  SoEs),  Poland  (under  the  European  Funds  for  a  Modern 

16 

 
 
 
 
 
Economy, FENG) and Bulgaria (recovery and resilience plan support for innovative SMEs that hold an 
SoE). 

Moreover, many Member States have not engaged with the opportunities presented by SoE holders 
in their country. 

This is a recommendation where there is considerable opportunity for quick gains and true synergies 
between  EU  funding  actions  and  national  and  regional  initiatives  seeking  to  support  the  best 
innovators. 

Member  States  are  also  recommended  always  to  provide  the  Commission  with  details  of 
national/regional SoE holders they have supported. This opens up the opportunity to understand how 
the Seal of Excellence programme benefits Member States and adapt it accordingly. It also presents 
the opportunity for the Commission to spotlight the innovative excellence being supported across the 
Union. 

SUMMARY ASSESSMENT: Limited progress 

17 

 
 
 
 
3  Connectivity infrastructure 
3.1  Member States should introduce targeted  measures to accelerate fibre roll-out and 

take-up by end users. 

In 2025 several relevant actions were initiated and continued at Member State level, demonstrating 
sustained commitment and tangible progress with respect to this policy recommendation. Although 
implementation is ongoing, significant progress has been made and the measures adopted indicate 
that there are structured efforts and steps towards achieving the stated objectives. 

In most EU Member States, previously established support measures continued to operate in 2025. 

On the basis of Chapter III on “New public funding fibre roll out in 2025” of  the draft study ‘Public 
funding support for 5G roll-out in EU Member States 2026 edition v2’ prepared by the 5G for Smart 
Communities – Coordination and Support Action platform (5GSC CSA), this is the case, for example, in 
Czechia, Cyprus, Poland and Sweden. In Sweden, for instance, a multiannual programme was already 
in operation, with dedicated allocations for 2025 and 2026. In Poland, the 4th call for proposals under 
the National Recovery and Resilience Plan (investment  C1.1.1) continued to channel public funding 
into broadband infrastructure development.  

The  year  2027  will  be  the  final  year  for  new  applications  under  the  programme,  while  projects 
approved in that year are expected to be completed by 2030. 

New measures were launched in 2025 in six Member States (Bulgaria, Estonia, France, Italy, Hungary 
and  Slovenia).  Most  of  these  measures  introduced  new  funding  schemes  supported  by  ERDF 
cofinancing or the RRF budget. The target group, the beneficiaries of the deployment of very high-
capacity networks providing internet access, are located primarily in rural and sparsely populated areas. 
However, there are also cases, e.g. in France, where complex fibre-optic connection works carried out 
on private property were extended from users of 3 000 municipalities to a nationwide scheme in few 
months  and  remained  open  to  private  individuals  and  small  businesses,  or  in  Slovenia,  where  the 
intention is to upgrade or expand existing networks. 

Bulgaria  (an  EUR  200 million  project  supported  by  the  RRF)  focused  on  large-scale  deployment  of 
digital  infrastructure.  Italy  allocated  EUR 95 million  under  its  national  complementary  plan  for  the 
development of a new fibre-optic backhaul network and EUR 733 million via its National Connectivity 
Fund, a facility-type instrument, to stimulate private investment and improve access to financing in 
the ultra-broadband network infrastructure sector. Estonia (EUR 45 million  supported by the  ERDF) 
focused on high-speed access networks in rural areas. 

SUMMARY ASSESSMENT: Notable progress 

18 

 
 
 
 
3.2  Member  States  should  use  regulatory  and  financing  measures  to  incentivise  the 
densification  of  5G  networks  and  accelerate  deployment  of  secure  5G  stand-alone 
networks, 
including  by  fostering  cross-border  collaborations  and  promoting 
innovative use cases; 

In  2025  several  relevant  actions  were  initiated  and  continued  at  Member  State  and  EU  level, 
demonstrating  sustained  commitment  and 
limited  progress  with  respect  to  this  policy 
recommendation. 

In recent years, Member States have been able to benefit from EU funding via CEF Digital (the digital 
part of the Connecting Europe Facility). The 2025 CEF Digital Call 4 saw exceptional participation from 
eligible  entities  across  the  EU  Member  States.  To  date,  four  calls  for  proposals  have  resulted  in  a 
project portfolio of 47 projects for 5G for smart communities and 31 for 5G corridors, 13 inception 
studies and 18 works projects, corresponding to a total of EUR 331 million in grants, EUR 153 million 
of it for 5G corridors. Many projects are cross-border and involve multiple countries, regions and local 
communities.  Most  projects  bundle  5G  stand-alone  with  edge  cloud  capacities,  leveraging  5G 
technology  to  enhance  the  quality  of  services.  For  smart  communities,  the  four  calls  have  covered 
20 Member States in total. In Call 4 (2025) the Commission observed a further increase in geographical 
diversity,  e.g.  Ireland.  For  5G  corridors,  a  broad  and  geographically  balanced  footprint  has  been 
achieved on the basis of the four calls, with a total of 22 cross-border sections of corridors covered and 
an overall combined length of 9 000 km of 5G corridors, road, rail and waterways to be achieved once 
all 18 works projects have been completed. 

In  addition  to  this,  Member  States  have  also  made  significant  progress  via  other  types  of  funding 
schemes. On the basis of the draft Study ‘Public funding support for 5G roll-out in EU Member States 
2026 edition v2’ prepared by the 5GSC CSA, Member States’ 5G-related public investment aggregated 
data for 2022-2025 amounted to at least EUR 2.91 billion. Public support for 5G in the EU was driven 
primarily by the objective of supporting infrastructure deployment. The largest funding volumes were 
concentrated in a limited number of Member States and were financed predominantly through the 
Recovery and Resilience Facility (RRF). At the same time, the data shows that public intervention was 
not  confined  to  network  deployment  alone.  In  several  countries,  support  measures  also  aimed  at 
fostering  the  development  of  5G  use  cases,  thereby  linking  infrastructure  investment  to  broader 
objectives relating to innovation, experimentation and market uptake. It can be observed that public 
funding  remains  highly  concentrated  geographically.  Italy  and  Spain  account  for  by  far  the  largest 
identified funding envelopes, each mobilising more than EUR 1 billion over the period concerned. 

However, across the 27 schemes identified in 13 Member States, variations can be observed in the 
technological orientation of the measures, e.g. explicit targeting of 5G stand-alone (SA) remains limited. 
Only  two  measures  were  reported  as  supporting  5G  SA  exclusively,  suggesting  that  most  schemes 
continue to support deployment in broader technological terms rather than prioritising 5G SA-specific 
roll-out. Current deployment data shows limited progress on 5G SA specifically, and it should be noted 
that  while  public  financing  plays  an  important  catalytic  and  incentive  role,  the  bulk  of  investment 
required to achieve widespread 5G SA deployment is expected to come from the private sector. 

19 

 
 
 
 
 
 
SUMMARY ASSESSMENT: Limited progress 

20 

 
 
 
 
3.3  Member  States  should  support  coordinated  action  for  planning  and  developing  a 
reliable, sovereign and resilient network of digital infrastructures across the EU and 
with international partner countries. 

Recommendation  (EU)  2024/779  highlights  the  need  to  strengthen  the  security  and  resilience  of 
submarine cable infrastructures through various measures, on both governance and funding. 

As described in the Annex I to the 2026 State of the Digital Decade Report, in order to follow up on the 
Recommendation,  a  Commission  expert  group  composed  of  Member  State  authorities  and  the 
European Agency for Cybersecurity (ENISA) developed an EU risk assessment (October 2025) as well 
as a Cable Security Toolbox of mitigating measures and a list of priority areas for public investment – 
the  Cable  Projects  of  European  Interest  (February  2026).  While  this  represents  notable  progress 
achieved  with  Member  State  participation,  the  Cable  Security  Toolbox  and  the  Cable  Projects  of 
European  Interest  can  be  implemented  only  over  the  medium  term.  Significant  efforts  remain 
necessary to achieve reliable and sovereign networks, implying mobilisation of strategic investments 
in critical backbone infrastructure combining EU and MS resources, addressing inter alia supply chain 
risks and regulatory issues reported. 

Moreover, the Council Conclusions on reliable and resilience connectivity of 6 June 2025 required a 
comprehensive EU strategic approach to the development of a reliable and resilient communications 
network 
infrastructure,  comprising  submarine,  terrestrial  and  non-terrestrial  networks  and 
coordinated  action  between  the  EU  and  MSs  to  enhance  security,  resilience,  and  international 
partnerships. 

This strategic  imperative is already reflected in the strong and growing demand for EU support  for 
digital infrastructure projects. Continuing the trend observed in recent years, the 2025 CEF Digital Call 
4 saw exceptional participation from eligible entities across the EU Member States. The three topics 
(digital  global  gateways,  5G  for  smart  communities,  and  5G  corridors)  were  significantly 
oversubscribed, setting a new record for demand compared to previous CEF Digital calls. 

The digital global gateways topic was significantly subscribed and saw the highest demand, receiving 
41  eligible  proposals,  requesting  EUR 512  million  (EUR 348  million  more  than  the  available  topic 
budget). This high oversubscription ensures the high quality and EU added value of proposals selected, 
though several worthy projects could not be funded due to limited resources. 

The  intense  competition  highlights  the  growing  importance  of  the  CEF  Digital  fund,  the  strategic 
priority that Member States give to digital infrastructures and the urgent need to scale up funding to 
support more high-impact initiatives. It also indicates that while some funding for submarine cables is 
available via national budgets or other EU instruments, such as the European Regional Development 
Fund and the Recovery and Resilience Facility,  CEF Digital remains the main funding instrument for 
such projects which are, by definition, projects with high cross-border impact and EU added value. 

21 

 
 
 
 
Beyond  funding,  the  Body  of  European  Regulators  for  Electronic  Communications  (BEREC)  has 
reviewed the national regulatory efforts on submarine cable connectivity in its BoR(25) 171 report21. 
The overview stresses that public funding instruments are vital for assuring connectivity, especially for 
replacing  the  current  submarine  cable  systems  reaching  the  end  of  their  lifecycle  and  when  that 
submarine  cables  serve  sparsely  populated  remote  areas  or  coastal  villages,  where  not  only  the 
investment costs, but also the maintenance and operation costs, are not justified by future revenues. 
While issues concerning resilience and security are reported to receive increased attention at national 
level too, the focus of the overview is on the measures to preserve competition, with a minority of 
countries (Croatia, France, Greece, Iceland, Portugal, and Spain) reporting having carried out market 
analyses regarding or including domestic submarine cables leading to regulation of submarine cables 
with  designation  of  an  operator  with  significant  market  power.  Of  those  six,  four  (Croatia, Greece, 
Iceland,  Portugal)  are  still  regulating,  and  two  (France  and  Spain)  deregulated  in  2017  and  2024 
respectively, but still monitor market trends. The report does not, however, examine permit granting 
or other potential deployment or upgrade hurdles. 

SUMMARY ASSESSMENT: Notable progress 

21 BoR (25) 171_BEREC Report on domestic submarine cables connectivity in Europe_1.pdf. 

22 

 
 
 
 
 
4  Cloud and Edge Infrastructure 
4.1  Member States should support the deployment of secure and sustainable cloud and 
edge  nodes  and  focus  national  efforts  on  infrastructure-targeted  investments  and 
strategies  to  ensure  that  businesses  have  access  to  the  sovereign  compute 
infrastructure required for serving their cloud and AI needs 

Several  relevant  actions  have  been  undertaken  at  Member  State  level,  demonstrating  clear 
engagement and progress with respect to this policy recommendation. Although implementation is 
ongoing, the measures adopted indicate that there are structured efforts and steps towards achieving 
the stated objectives. If edge deployment maintains its current rate of progress, projections indicate 
that the EU will meet its goal of deploying 10 000 climate-neutral and highly secure edge nodes by 
2028. 

The Edge Observatory reported that 7 451 neutral and highly secure edge nodes were operating across 
the  EU.  Edge  node  distribution  across  the  EU  remains  varied.  By  2025,  Germany  had  the  highest 
number of  carbon-neutral and  secure  on-premises  edge  nodes,  totalling  1 771,  followed  by  France 
with 737, Italy with 629, Poland with 536, and Spain with 529. Germany also leads the way in public 
edge  node  deployment,  closely  followed  by  France  and  the  Netherlands.  Together,  these  three 
countries account for 51% of all public edge nodes in the EU. 

A notable trend is the concentration of edge nodes in densely populated metropolitan areas, due to 
increased demand and infrastructure requirements, which correlates with regions of higher GDP and 
larger populations. Manufacturing (accounting for over 50% of nodes), retail and transport sectors are 
key players in advancing edge computing. Furthermore, for 25% of organisations, AI workloads are the 
main focus of their edge computing. 

Beyond this, and in connection with cloud and AI infrastructure deployment, there is evidence, as of 
March/April 2026, that over the last year Member States have focused their efforts on infrastructure-
targeted investments, and especially strategies to ensure adequate access to compute infrastructure 
in their national territory. The French government has published a list of sites considered favourable 
for data centre implantation to help attract infrastructure investment and compete at European level22. 
Similarly,  Italy  has  developed  a  strategy  for  attracting  investment  in  data  centres23,  as  well  as  an 
experimental initiative on Edge Cloud Computing (ECC) within telecom operators’ access networks to 
enable  low-latency  services  and  support  distributed  application  models  across  the  territory;  the 
objective is to assess the technical and economic benefits of deploying ECC platforms closer to end 
users24. Finland has also recently developed a national road map for data centres25, while Spain has 
developed  a  national  strategy  for  IA,  with  measures  on  the  deployment  of  data  centres 26 .  The 
Netherlands had already developed a road map for the growth of data centres in the country in 201927. 

22 Ministères économiques et financiers, Implantation de centres de données, 2025. 
23 Strategia per l’attrazione in Italia degli investimenti industriali esteri in data center, Italian Ministry of Enterprises, 2025. 
24 https://innovazione.gov.it/notizie/articoli/edge-cloud-computing-sperimentazioni-per-migliorare-qualita-e-prestazioni-
dei-servizi-digitali/, Italian Department for Digital Transformation, 2026 
25 National Roadmap for Data Centres: Rapporteur’s Report, Finnish Government, 4 November 2025. 
26 Estrategia de Inteligencia Artificial 2024, Spanish Ministry for Digital Transformation, 2024. 
27 Spatial Strategy for Data Centres, Ministry of the Interior and Kingdom Relations (Netherlands), March 2019. 

23 

 
 
 
 
In  this  respect,  implementation  has  advanced,  though  not  yet  comprehensively  across  all  Member 
States. Plans for the upcoming months are scheduled for a few Member States, which indicates the 
continued  momentum.  The  German  government  is  developing  a  national  strategy  to  promote  the 
operation and settlement of data centres28. Portugal is also finalising its  data centre strategy for AI 
development29. 

SUMMARY ASSESSMENT: Notable progress 

28 National Data Centre Strategy, German Federal Ministry for Digital and State Modernisation, 18 March 2026. 
29 Governo anuncia estratégia nacional de centros de dados para alimentar procura por Inteligência Artificial, Expresso, 
3 November 2025. 

24 

 
 
 
 
 
 
4.2 

(a) Member States should closely work with the Commission on the upcoming Cloud 
and AI Development Act to triple EU data centre capacity within five to seven years 
and  bringing  it  to  a  level  that  matches  the  demands  of  EU  businesses  and 
administrations by 2035. This is an objective that could become a new Digital Decade 
target. (b) Member States should engage fully with the Commission in the discussion 
on the study supporting the Cloud and AI Development Act to establish methods for 
assessing and tracking the EU cloud compute infrastructure capacity. 

The first part, Part (a), of this recommendation is aligned with the ambitions of the AI Continent Action 
Plan to triple EU data centre capacity within the next five to seven years and to make it match the 
demand of EU businesses and public administrations by 2035. On the basis of the review of measures 
and policy steps, we assess the overall progress made on this recommendation to be limited. Although 
good collaboration with Member States has been established with respect to policy development, the 
concrete  implementation  of  this  recommendation  requires  further  engagement  in  the  following 
months. Since this recommendation was first made, the Commission and Member States have initiated 
discussions,  during  bilateral  and  institutional  meetings,  on  the  proposal  for  a  Cloud  and  AI 
Development  Act,  which  will  provide  a  clear  legislative  framework  to  enhance  EU  data  centre 
infrastructure  and  measures  to  achieve  the  recommended  objective.  Nevertheless,  the  increase  in 
data centre capacity to meet the needs of businesses and public administrations will require significant 
investment and effort from Member States in the years to come, and the current pace of development 
will not allow this goal to be met. 

With respect to Part (b), the second part of this recommendation, we consider that limited progress 
has been made on Member States’ engagement to define methods for assessing the EU cloud compute 
infrastructure capacity as part of the study supporting the Cloud and AI Development Act. This is due 
to the fact that public authorities have engaged with the study mainly on public sector demand trends 
and  future  requirements  and  accelerated  permitting  procedures.  Even  though  the  two  workshops 
organised in the context of the study were well attended by national representatives to discuss and 
validate the findings of the analysis, including the methodology for assessing EU compute capacity, 
further work will be needed to finalise the proposed methods. This will ensure that national capacity 
is accurately reflected in any future monitoring exercise. The study provided a strong initial foundation 
and methodology that can be reused to establish a robust tracking system, but its implementation will 
require continued collaboration and commitment from Member States and the Commission. 

Overall, while some initial progress has been made in collaboration and policy development, the actual 
implementation  of  data  centre  capacity  expansion  at  Member  State  level  still  requires  significant 
progress. The Cloud and AI Development Act is a critical factor in driving this implementation forward 
and providing a clear direction for the effective outcome of the tracking system 

SUMMARY ASSESSMENT: Limited progress 

25 

 
 
 
 
 
5  Semiconductors 
5.1  Member States should increase investments in semiconductors and stimulate secure 
and  sustainable  domestic  chip  design  and  manufacturing  capabilities  and  continue 
their commitment in supporting both essential semiconductors and cutting-edge chips 
in leading value chain areas; 

Significant investment in first-of-a-kind semiconductor manufacturing projects have been notified to 
the Commission under the EU Chips Act, in particular in Czechia, Germany, Italy and Austria during the 
reporting period. These investments help strengthen Europe’s semiconductor ecosystem across key 
segments  of  the  value  chain,  particularly  in  manufacturing  and  advanced  technologies,  and  reflect 
continued  Member  State  commitment  to  scaling  up  domestic  capabilities.  In  parallel,  around  20 
Member States are preparing the Important Project of Common European Interest (IPCEI) on Advanced 
Semiconductor  Technologies  (IPCEI  AST),  currently  in  the  company  selection  phase.  This  indicates 
strong pipeline development and coordinated action at EU level, although the overall scale, timing of 
implementation, and geographical distribution of investments will remain critical to achieving a fully 
resilient and competitive semiconductor ecosystem. 

SUMMARY ASSESSMENT: Notable progress 

26 

 
 
 
 
 
5.2  Member States should enable a conducive investment framework by developing the 

workforce with the semiconductor skills needed. 

Although several relevant actions have been undertaken at Member State level, which demonstrates 
a clear commitment with respect to this policy recommendation, there is  still not a structured and 
conducive investment framework for achieving the stated objective that can effectively address the 
talent  gap.  Workforce  demand  is  expected  not  to  be  matched  by  education  and  training  systems 
throughout the European countries, with an estimated gap of about 65 000 jobs by 2030. 

The national chips competence centres and the relevant coordination network, as provided for by the 
Chips Act Regulation, have been established in all Member States over the past year and will address 
skills  development  and  other  targets.  The  focus  group  of  this  network  on  ‘training  and  skills 
development’ aims to coordinate and roll out education and upskilling initiatives. 

Overall,  the  competence  centres,  still  being  in  their  infancy,  have  great  potential  and  their  actual 
implementation will require support by Member States to make significant progresses. 

SUMMARY ASSESSMENT: Limited progress 

27 

 
 
 
 
 
 
6  Quantum technologies / HPC 
6.1  Member States should step up and coordinate investment in quantum technologies 

across Member States and strive to increase private sector investment 

The coordination of investments in quantum technologies across Member States  has increased. For 
instance,  the  Chips  Joint  Undertaking  is  already  funding  the  first  quantum  pilot  lines  with 
EUR 150 million from the EU, which will be matched by national contributions. The joint undertaking 
will implement a full EU road map for the production of quantum chips and their industrialisation. 

Moreover,  the  recently  adopted  EuroHPC  amendment30 transfers  the  implementation  of  quantum 
calls to the European High-Performance Computing Joint Undertaking (EuroHPC JU) and, as such, will 
require  the  input  and  contribution  of  Members  States  for  the  implementation  of  future  calls  and 
initiatives. 

SUMMARY ASSESSMENT: Limited progress 

30 EuroHPC JU’s Mandate Expanded Under New Regulation Amendment, European High-Performance Computing Joint 
Undertaking, 20 January 2026. 

28 

 
 
 
 
 
7  AI/HPC 
7.1  Member  States  should strengthen  efforts  in  the  area  of  AI  infrastructure,  including 
robust support to AI Factories and other EU initiatives in the field of AI, fostering a 
collaborative environment and maximising the impact of these efforts. 

Member States have made progress in strengthening their AI infrastructures, AI factories and other 
EU initiatives in the field of AI. The EuroHPC Joint Undertaking is rolling out 19 AI factories and 13 
antennas  across  Europe,  backed  by  around  EUR 2.6  billion  in  investment.  This  includes  15  new  AI-
optimised supercomputers, increasing Europe’s AI computing power fivefold. The network supports 
research in sectors like  healthcare, climate  and  finance.  The EU  has also launched JUPITER,  its  first 
exascale supercomputer (September 2025), with three EuroHPC systems in the global top 10 in 2025.  

The  federated  network  of  the  EuroHPC  JU,    enables  cross-border  collaboration,  boosting  the  EU’s 
digital  sovereignty.  The  AI Continent  Action Plan outlines  a  cross-sector  AI adoption  road  map  and 
establishes the Apply AI Alliance – a coordination forum for policymakers, industry, academia, and civil 
society.  An  AI  Observatory  will  track  progress  (e.g.  uptake,  investments,  labour  impacts).  While  AI 
factories provide foundational infrastructure, AI gigafactories will scale up capacity to train next-gen 
AI  models  (with  hundreds  of  trillions  of  parameters)  via  public-private  partnerships,  using  energy-
efficient data centres. A 2025 call for expressions of interest drew 77 proposals from 16 EU states. 
Following  a  December  2025  EuroHPC  JU  regulatory  amendment,  a  formal  AI  gigafactories  call  is 
expected in spring 2026, with joint procurement securing long-term compute access, signalling strong 
market interest. 

In  December  2025,  the  Council  of  the  EU  amended  the  EuroHPC  JU  Regulation  to  establish  AI 
gigafactories in Europe, with a procurement call expected in spring 2026. AI gigafactories will secure 
long-term AI compute access, positioning Europe as a leader by empowering start-ups, researchers, 
and industries. To accelerate adoption, European digital innovation hubs (EDIHs) are being repurposed 
as centres offering one-stop support for digitalisation and AI. Two STEP SEAL funding calls involve DEP 
co-funding of up to 50%. Under the Apply AI Strategy, EDIHs will also promote EU-made, open-source 
AI solutions, with a call for sector-wide deployment by companies. 

During the last year significant policy developments have been made. In October 2025, the Apply AI 
Strategy, a follow-up to the AI Continent Action Plan, published a cross-sectoral blueprint for EU AI 
adoption, establishing the Apply AI Alliance as a central coordination hub for policymakers, industry, 
and civil society, backed by an AI Observatory tracking uptake, investments, and labour market impacts. 
To  scale  up  infrastructure,  AI  gigafactories,  building  AI  factories’  baseline  capabilities,  will  provide 
industrial-level HPC for next-gen AI models (with hundreds of trillions of parameters via public-private 
partnerships),  ensuring  energy-efficient,  large-scale  compute  power  to  bolster  EU  technological 
autonomy.  Market  demand  is  already  emerging:  a  2024  call  for  expressions  of  interest  drew  77 
proposals from 16 Member States. Meanwhile, EDIHs are evolving into AI experience centres for SMEs 
and  public  bodies  with  a  strategic  AI  focus,  open-source  priorities,  and  deeper  ties  to  testing  and 
experimentation facilities (TEFs) and AI regulatory sandboxes. Two consolidation calls (one finalised, 
another  assessed  post  March  2026)  are  reshaping  the  network,  with  Member  States  funding 
preselected hubs. To accelerate the deployment of EU-made AI, the Commission will launch a call for 

29 

 
 
 
companies  to  share  AI  models  via  EDIHs,  promoting  multilingual,  open-source  solutions  across 
strategic  sectors.  Together,  these  measures  aim  to  position  the  EU  as  a  global  AI  leader,  driving 
innovation, competitiveness, and sovereign capability. 

Significant progress has been made in the EU AI infrastructure. With EuroHPC AI factories deploying 
AI-optimised  supercomputers  and  streamlined  access  prioritising  start-ups,  scale-ups  and  SMEs,  AI 
gigafactories will support end-to-end large-scale AI model life cycles, boosting EU strategic autonomy 
in  critical  sectors.  Meanwhile,  EDIH  networks  have  proved  highly  effective,  delivering  more  than 
67 000 services (which includes training, networking, testing, and funding) to 29 000 companies across 
EU  regions  engaging  60 000  entities  through  9 800  events  with  high  user  satisfaction.  However, 
barriers persist, including low AI adoption, data quality/reliability issues and gaps, alongside funding 
misalignment and national/EU criteria disparities that risk fragmenting support. To address this, policy 
(e.g. AI Continent Action Plan, Apply AI Strategy) and infrastructures (AI factories, gigafactories, EDIHs, 
TEFs) are aligning under a harmonised governance model – led by the EU AI Office’s AI Board – to foster 
cross-initiative collaboration, including AI regulatory sandboxes mandated by the AI Act. Critical next 
steps include seamless co-funding, simplified reporting, and deeper integration between EDIHs, TEFs 
and AI regulatory sandboxes to optimise resources, ensure a smooth journey for SMEs/start-ups, and 
maximise AI’s societal and economic impact. 

The  strengthening  of  the  AI  innovation  ecosystem  and  provision  of  comprehensive  support  to 
(prospective) providers, especially SMEs including start-ups will be crucial; equally, coordination and 
collaboration across initiatives will be essential to ensure optimalisation of the resources and a smooth 
journey for AI providers. 

SUMMARY ASSESSMENT: Notable progress 

30 

 
 
 
 
 
 
8  Digitalisation of SMEs 
8.1  Member States should strengthen their policies to accelerate SME digitalisation, with 
a particular focus on the integrating and adopting AI and tailored support within the 
framework of EDIHs. and testing and experimentation facilities (TEFs). 

Member States should strengthen policies to accelerate SME digitalisation, paying particular attention 
to  AI  adoption  and  tailored  support  through  key  facilitators/networks  and  facilities  such  as  the 
European  digital  innovation  hubs  (EDIHs)  and  testing  and  experimentation  facilities  (TEFs).  This  is 
especially important for SMEs, which often face difficulties in identifying viable AI use cases, accessing 
expertise, testing solutions in practice and managing compliance requirements. 

The European digital innovation hubs (EDIHs) are key EU one-stop shops that help SMEs and public 
sector organisations adopt AI and other digital technologies by providing test-before-invest facilities, 
technical  expertise,  training,  regulatory  support,  and  ecosystem  networking.  They  act  as  regional 
gateways to Europe’s wider AI ecosystem, connecting firms to resources such as AI  factories (high-
performance  computing  and  data  infrastructures),  AI-on-demand  platforms  and  AI  skills  initiatives, 
enabling SMEs to develop and deploy AI solutions in practice. For instance, through concrete use cases, 
such as AI-driven SME advisory platforms, General Data Protection Regulation-compliant AI chatbots 
and healthcare AI pilots, EDIHs help organisations experiment safely before scaling up. 

As of January 2026, the EDIH network has consisted of 161 co-funded hubs spanning all EU Member 
States,  three  EEA  associated  countries  (Iceland,  Liechtenstein  and,  Norway)  and  seven  associated 
countries from the Western Balkans (Albania, Kosovo31, Montenegro, North Macedonia and Serbia), 
Türkiye and Ukraine. Switzerland will join the EDIH network in the second  half of 2026, following a 
dedicated call. Associated countries strengthen the EDIH network by extending its reach beyond the 
EU and reinforcing pan-European cooperation. The hubs in the associated countries provide similar 
services while fostering reinforced cross-border collaboration, closer links with EU Member States, and 
stronger integration into the digital single market. 

The testing and experimentation facilities (TEFs) are an important complement to EDIHs for SME AI 
uptake.  By  providing  structured  environments  to  test  and  validate  AI  systems,  they  help  reduce 
adoption risks, support innovation and facilitate compliance with the AI Act. According to the OECD’s 
2025 report, nearly half of EU Member States reported AI testing and experimentation initiatives. Most 
initiatives focus on the EU priority areas of the agri-food sector, healthcare, manufacturing, and smart 
cities and communities. 

The EDIH network is now moving into its second iteration, focused on consolidation and completion 
with a stronger AI orientation. This phase is marked by the award of the STEP Seal through dedicated 
STEP  calls,  recognising  the  quality  and  strategic  relevance  of  the  EDIH  network  for  Europe’s 
technological sovereignty and competitiveness. It is therefore expected that the EDIHs’ status in their 
country  and  regions  will  be  further  consolidated,  thus  facilitating  their  operations  as  strategic 

31 This designation is without prejudice to positions on status, and is in line with UNSCR 1244/1999 and the ICJ Opinion on 
the Kosovo declaration of independence. 

31 

 
 
 
 
digitalisation  and  AI  intermediaries  for  companies,  especially  SMEs,  and  the  public  through  their 
facilitation and catalyst role within the wider AI ecosystem. 

The  STEP  Seal  is  also  helping  improve  funding  pathways  for  the  EDIHs  in  the  consolidation  stage, 
including in countries such as Bulgaria and Romania, where STEP budget lines have been mobilised to 
reduce the risk of renewed funding gaps. 

The policy direction on TEFs is also becoming clearer. Member States are increasingly using testing and 
experimentation infrastructures to support SME uptake of AI, but  funding for these infrastructures 
often  remains  difficult  to  track,  as  it  is  frequently  embedded  in  broader  programmes  or  financed 
through mixed sources. 

Overall, progress has been significant over recent years, leading to the current consolidation of the 
EDIH  network.  EDIHs  have  become  a  central  nervous  system  for  digital  and  AI  uptake,  while  TEFs 
increasingly  complement  them  by  providing  practical  environments  for  testing  and  validation.  The 
OECD’s  2025  Progress  in  Implementing  the  EU  Coordinated  Plan  on  Artificial  Intelligence  report 
suggests that EDIHs are most effective where they are embedded in a broader national and regional 
support architecture, as illustrated by Belgium, the Netherlands, Finland, or, for instance, Germany. 
More broadly, the OECD notes that EDIHs are active in all EU Member States and that many national 
SME support measures are channelled through them. 

At the same time, progress remains uneven. In some Member States, EDIHs still need stronger strategic 
anchoring, more stable co-funding, clearer implementation frameworks and more consistent national 
and regional policy follow-through in order to fulfil their full potential as delivery structures for SMEs, 
mid-caps and public sector organisations. 

For TEFs, the main gaps relate to the visibility and continuity of funding, their concentration in only a 
limited  number  of  sectors,  and  the  need  to  connect  testing  activities  more  closely  to  regulatory 
experimentation and compliance support. 

Overall, the main challenge  is now  less  the  creation of support  structures than their consolidation, 
strategic anchoring and effective integration into a wider ecosystem capable of supporting AI uptake 
at  scale.  In  this  context,  it  is  important  to  underline  that  EDIHs  support  not  only  SMEs  and  other 
businesses,  but  also  public  sector  organisations.  This  dual  role  can  further  accelerate  business 
digitalisation  and  AI  uptake,  as  a  more  digital  and  AI-ready  public  sector  helps  create  the  right 
framework conditions, stimulates demand, and demonstrates good practices that can be replicated by 
companies. 

The strengthening of EDIHs as strategic intermediaries could ensure more stable and visible funding 
for  TEFs,  while  connecting  testing  activities  more  closely  to  regulatory  experimentation  and 
compliance support. 

SUMMARY ASSESSMENT: Notable progress 

32 

 
 
 
 
 
 
 
 
9  Uptake of advanced technologies 
9.1  Member States should take targeted measures and earmark resources to support the 
adoption  of  advanced,  trustworthy  and  sovereign  AI-enabled  solutions;  step  up 
investment, also by mobilising the private sector, in general purpose/generative AI. 

Currently, only 12 Member States have financed their AI strategies through a stand-alone AI budget, 
with  the  remainder  incorporating  AI  spending  into  broader  digitalisation  plans  or  ministry-led 
programmes.  Among  those  with  dedicated  AI  budgets,  Germany  and  France  lead  in  investment32. 
Germany allocated between EUR 482.8 million and EUR 625 million each year between 2018 and 2025, 
while  France  merged  AI  strategy  funding  with  supplementary  financing,  totalling  approximately 
EUR 1 billion per year from 2022 to 202533. In 2025 Czechia earmarked EUR 753.7 million to implement 
its  Action  Plan  for  Implementation  of  Digital  Czechia,  which  includes  AI  initiatives34.  Other  annual 
budgets include Italy (EUR 270 million), Spain (EUR 100 million), Estonia (EUR 31.7 million), Slovenia 
(EUR 22.5 million), Bulgaria (EUR 5-20 million), with Malta, Cyprus, and Denmark dedicating between 
EUR 2.5  million  and  EUR 5  million  each35.  It  is  important  to  note  that  these  figures  typically  reflect 
budgetary commitments rather than actual spending and may incorporate both EU and private funding. 
Additionally, many Member States have relied on the EU’s Recovery and Resilience Facility (RRF) to co-
fund their AI strategies. For example, Slovenia expects around half of its AI programmes to be RRF-
financed.  Similarly,  Lithuania  and  Romania  have  both  declared  that  the  RRF  plays  a  pivotal  role  in 
financing their AI initiatives. 

To  support  the  adoption  of  AI-enabled  solutions,  24  Member  States  had  formalised  national  AI 
strategies by December 2025, with the remaining three (Greece, Croatia, Slovakia) still in the process 
of finalising theirs36. Approximately half of the Member States have further revised their AI strategies 
to address the changes caused by the widespread adoption of generative AI. This policy shift has been 
accompanied  by an  increased focus on boosting AI uptake nationwide, alongside  specific initiatives 
aimed at accelerating AI adoption across key sectors in accordance with national objectives and needs. 
This trend coincides with the objectives outlined in the Apply AI Strategy. Examples of Member States 
broadly  promoting  AI  adoption  include  France  transitioning  from  a  research-based  approach  to 
prioritising  economic  impacts,  Denmark  putting  AI  adoption  in  the  public  sector  at  the  core  of  its 
agenda,  Ireland  fostering  AI  adoption  among  SMEs,  and  Belgium  launching  an  initiative  aimed  at 
facilitating the adoption of generative AI in the form of grants of up to EUR 80 000 for SMEs. 

The most  significant  challenge  in  evaluating  progress  toward  this Digital Decade  goal  is  the  lack  of 
separate accounting for AI expenditure. This is exacerbated by the fact that EU funding initiatives, such 
as Horizon Europe and the RRF, do not track AI-specific spending. Nevertheless, various Member States 
have committed to developing monitoring frameworks to better track AI-related financing. Overall, 
despite  the  limited  number  of  dedicated  AI  budgets,  Member  States  are  making  major  efforts  to 

32 Progress in Implementing the European Union Coordinated Plan on Artificial Intelligence (Volume 1), Organisation for 
Economic Co-operation and Development (OECD), 2025. 
33Ibid., p. 34. 
34 See note 32, page 35. 
35 Ibid., pp. 34-35. 
36 Ibid., p. 14. 

33 

 
 
 
 
promote  AI  uptake,  as  evidenced  by  their  significant  financial  commitments,  evolving  policy 
frameworks, and targeted initiatives. 

SUMMARY ASSESSMENT: Notable progress 

34 

 
 
 
 
9.2  Member  States  should  focus  national  efforts  on 

infrastructure 
investments  to  ensure  that  businesses  and  the  public  sector  have  access  to  the 
compute infrastructure required for serving their cloud and AI needs, especially for 
fine-tuning and inference operations. 

incentivising 

As of the assessment period between Q2 2025 and Q2 2026, notable progress can be seen to have 
been  made  in  several  Member  States  and  regions  in  creating  more  supportive  conditions  for 
investments  in compute infrastructure  with the aim of improving access to cloud capacity for both 
business users and the public sector. 

France is leading AI and data centre investment, targeting EUR 109 billion in infrastructure funding, 
including EUR 400 million in eco-friendly data centres capable of hosting 25 000 graphics-processing 
units  for  AI  processing37.  Meanwhile,  other  EU  nations’  measures  partly  funded  by  RRF  funds  are 
expanding data centres to digital government and AI strategies38. 

In  Sweden,  public  cofinancing  has  been  allocated  to  help  Swedish  organisations  participate  in  EU 
investments in infrastructure and capacity-enhancing projects for cloud services, data and AI39, and 
the 2026 AI strategy links competitiveness to facilitating investment, faster permit processes and the 
strengthening  of  Sweden’s  position  across the  AI  value  chain,  including  data  centres40.  Finland  has 
announced  measures  to  safeguard  competitiveness  in  attracting  data  centre  investments41.  In  the 
Netherlands, provincial action in North Holland shows an active policy approach: the province’s 2025-
2027 data centre strategy continues cluster-based planning and seeks additional space to keep future 
siting possible, while treating digital infrastructure as important for innovation and competitiveness42. 
In Germany, the federal state of Hessen has launched a regional data centre strategy and a dedicated 
Data  Centre  Office43,44,  while  North  Rhine-Westphalia  has  created  a  competence  centre  for  digital 
infrastructure 45  and  is  supporting  hyperscale  capacity  in  the  Rheinisches  Revier  to  increase  the 
availability of cloud services46. In Spain, Aragon repeatedly used its ‘investment of regional interest’ 
mechanism in 2025 to accelerate  several new  data centre campuses47,  while Madrid is investing in 
public sector data centre modernisation48 and a broader regional AI and data strategy49. 

37 Faire de la France une puissance de l’IA, Élysée, 11 February 2025. 
38 OECD, Progress in IM. 
39 Sweden’s National Reform Programme 2023, Government of Sweden, 2023. 
40 Sweden’s AI Strategy in five minutes, Swedish Ministry of Finance, 25 February 2026. 
41 Government safeguards Finland’s competitiveness in attracting data centre investments, Prime Minister’s Office 
(Finland), 26 March 2026. 
42 Datacenter Strategy, Province of North Holland, 2025. 
43 State wants to strengthen its position as a leading data centre location, Hessische Landesregierung, 17 September 2025. 
44 Contact point for information, advice and networking, Hessen Digital (Hessisches Ministerium für Digitalisierung und 
Innovation). 
45 State launches new Digital Infrastructure NRW Competence Centre, Ministry of Economic Affairs, Industry, Climate Action 
and Energy NRW, 21 February 2025. 
46 Groundbreaking ceremony for Microsoft’s data centres in the Rhenish mining area, Ministry of Economic Affairs, Industry, 
Climate Action and Energy NRW, 12 March 2026. 
47 BOA Resultados avanzados, Aragon Regional Government. 
48 La Comunidad de Madrid adjudica a Fujitsu la administración y gestión de los centros de datos del SERMAS, Comunidad 
de Madrid, 8 June 2025. 
49 La Comunidad pondrá en marcha una Estrategia IA 2030 para posicionar a Madrid como referente europeo en la materia, 
Comunidad de Madrid, 1 October 2025. 

35 

 
 
 
 
These developments are increasingly aligned with the Cloud and AI Development Act. 

With regard to the availability of AI compute capacity for inference at the  edge, the analysis of the 
edge computing policy landscape across Member States reveals a wide range of approaches, with 13 
of the 27 Member States including measures supporting the edge target in their strategic road maps. 
In addition, two other Member States have indicated that they are considering introducing measures 
in support of the edge target. This diversity is also reflected in public investment levels. 

More specifically, edge-related measures in the Digital Decade strategic road maps encompass a wide 
range of initiatives, with IPCEI CIS50 being the most prominent. Other national-level initiatives include 
measures in support infrastructure roll-out, such as installing edge nodes for public services or creating 
reusable shared building blocks, and the development of edge AI technologies. In some Member States, 
measures from the strategic road maps are complemented by national policies on edge computing. 

Given the early maturity of edge computing, it is anticipated that its position in national agendas will 
continue evolving. For instance, Italy recently launched a call for studies to assess the potential of edge 
cloud  computing  platforms  at  the  edge  of  telco  networks,  backed  by  EUR 4  million  in  funding. 
Nonetheless, other Member States, such as France and the Netherlands, indicate that no significant 
increase in the role of edge computing is currently foreseen within their national agendas. While both 
countries are taking measures to support the deployment of edge computing, they emphasise that any 
potential expansion would depend on a stronger uptake and engagement by industry at national level. 
In addition, a noteworthy trend for future developments is the growing interest in edge AI. 

While  IPCEI  CIS  is  helping  to  encourage  Member  States  to  invest  in  edge  and  cloud  computing, 
complementary initiatives are being pursued by participating Member States to further support these 
developments.  The  potential IPCEI on  artificial intelligence51 (IPCEI-AI)  aims to cover both research, 
development  and  innovation  (R&D&I)  and  first  industrial  deployment  (FID)  for  next-generation  AI 
services based on cutting-edge technologies that are open, distributed, sustainable and highly scalable. 
This  IPCEI-AI  seeks  to  address  the  entire  AI  stack:  from  data  processing  and  orchestration  to  the 
development of foundation models, including of general-purpose and sector-specific AI models. 

In addition,  and specifically targeting infrastructure deployment, the  potential Important Project of 
Common European Interest on Compute Infrastructure Continuum (IPCEI-CIC)52 seeks to facilitate the 
establishment  of  a  cross-border,  federated,  and  distributed  network  of  cloud  and  edge  computing 
infrastructure for AI applications, forming a sovereign and distributed computing continuum for AI and 
beyond, across Europe. 

Taken  together,  this  suggests  that  the  current  actions  across  the  EU  are  testimony  to  uneven  but 
notable progress with respect to this measure. 

SUMMARY ASSESSMENT: Notable progress 

50 Approved IPCEI Next Generation Cloud Infrastructure and Services, European Commission (DG Competition), 5 December 
2023. 
51 IPCEI Artificial Intelligence, German Federal Ministry for Economic Affairs and Energy. 
52 https://www.bundeswirtschaftsministerium.de/Redaktion/EN/Dossier/ipcei-cic.html. 

36 

 
 
 
 
 
9.3  Member  States  should  foster  secure  and  trusted  data  sharing,  supporting  the 
deployment  of  European  Data  Spaces,  including  via  practical  tools  such  as  model 
contract  clauses,  taking  full  advantage  of  relevant  existing  EDICs  and  accelerating 
those being prepared. 

To  this  date  the  Commission  has  funded  (through  the  Digital  Europe  Programme)  projects  for  the 
deployment  of  common  European  data  spaces  in  14  sectors.  The  latest  projects  supporting  the 
deployment of the Green Deal, agriculture, and energy data spaces started in April 2025. Beyond EU-
funded initiatives, a broader ecosystem is taking shape. The Data Spaces Support Centre tracks 235 
relevant  initiatives,  and  the  European  Data  Spaces  Awards  2025  highlighted  several  mature 
deployments, including: 

•  djustconnect.be  (agriculture)  –  recognised  for  strong  user  focus  and  a  viable  long-term 

financial model, funded by Regional and Flemish funds 

•  Catena-X  (automotive)  –  a  collaborative  data  ecosystem  funded  by  the  German  Federal 

Ministry for Economic Affairs and Climate Action, now reaching good maturity 

•  Data.gouv.fr  (open  data)  –  France’s  public  data-sharing  ecosystem  spanning  key  societal 

domains 

• 

• 

sphin-X (health/pharma) – a privately funded data space advancing discoverable, usable data 
across pharma, MedTech, and research 

SM4RTENANCE  (manufacturing)  –  focused  on  agile  asset  management  and  predictive 
maintenance, co-funded through the Digital Europe Programme 

•  DEPLOYTOUR  (tourism)  –  connecting  tourism  with  mobility,  smart  cities,  and  culture,  co-

funded through the Digital Europe Programme 

EDICs are also playing an important role. A notable example is the Common European Language Data 
Space (LDS), now in its fourth year under the Digital Europe Programme and among the most advanced 
European data spaces. It provides a secure marketplace for exchanging and monetising high-quality 
language data in compliance with EU rules, with growing engagement from both industry and research. 
To  ensure  long-term  sustainability,  the  LDS  operates  in  close  coordination  with  the  Alliance  for 
Language Technologies EDIC (ALT-EDIC) – its future governance body – launched in March 2025 under 
French chairmanship, with 18 Member States as members and eight as observers. ALT-EDIC combines 
national  efforts  on  multilingual  datasets,  supporting  Europe’s  competitiveness 
language 
technologies while preserving its linguistic and cultural diversity. 

in 

Similarly, the EDICs on mobility and agriculture aim to create a sustainable infrastructure for sharing 
mobility  and  agricultural  data  by  aligning  common  standards,  governance,  and  interoperability 
frameworks. In  particular, the  EDIC  on mobility  and logistics  aims to improve  cross-border mobility 
services  through  better  data  sharing  between  transport  authorities  and  operators,  enhancing 
multimodal travel and traffic management. Meanwhile,  the agriculture  EDIC focuses on developing 
and implementing a digital Farm ID aligned with EU Business Wallets in order to accelerate data sharing 

37 

 
 
 
through data spaces, increase data availability for AI, and reduce administrative burdens in B2G and 
B2B data sharing. 

Overall, a range  of EU-funded and national initiatives have moved data space deployment  forward 
across sectors, backed by emerging governance mechanisms such as EDICs. However, broad adoption, 
interoperability, and long-term sustainability are still developing and are likely to still require support 
from both the EU and Member States to deliver the intended results. 

SUMMARY ASSESSMENT: Notable progress 

38 

 
 
 
 
10 Cybersecurity 
10.1  Member States that have not already done so shall transpose the NIS2 Directive as a 
matter of urgency and should take actions, also going beyond what is necessary, to 
maximise the effects of the full implementation of the cybersecurity acquis, including 
the  NIS2  Directive  and  the  5G  cybersecurity  Toolbox  (encompassing  where 
appropriate the imposition of restrictions or exclusions as regards high-risk suppliers). 

NIS2 Directive 

19  Member  States  have  notified  complete  transposition  of  the  NIS2  Directive  (Network  and 
Information  Systems  Directive  2),  while  three  Member  States  have  notified  partial  transposition. 
Considering  that  the  deadline  for  transposing  the  Directive  was  17 October  2024,  it  is  particularly 
urgent  for  all  Member  States  to  complete  the  transposition  of  the  Directive,  enabling  full 
implementation of the NIS2 framework across the EU. 

The Commission has continued monitoring the transposition of the Directive in the Member States. 
On 7 May 2025, the Commission issued reasoned opinions to 19 Member States that had failed to fully 
transpose the Directive. 

5G cybersecurity toolbox 

22 Member States have a legislative framework in place to be able to restrict high-risk suppliers. Of 
those  22  Member  States,  13  have  put  restrictions  on  high-risk  suppliers.  However,  there  are 
differences within these Member States as regards the scope of those restrictions. 

In the meantime, the Commission has adopted the proposal for a revised Cybersecurity Act (CSA2), 
which includes a trusted ICT supply chain framework. This is a cross-cutting, risk-based and technology-
neutral framework to address non-technical risks linked to ICT supply chains. The framework will be 
applied first to the telecommunications sector, in particular 5G networks where an EU coordinated risk 
assessment  has  already  been  conducted.  It  aims  to  fill  gaps  and  harmonise  the  implementation of 
restrictions  on  high-risk suppliers  in electronic  communications  networks  throughout  the  EU. Once 
CSA2 and the relevant implementing acts have been adopted, the 5G Toolbox will become obsolete in 
terms of addressing non-technical risks. 

However, until CSA2 enters into force, the 5G Toolbox will remain relevant. The proposal reinforces 
the objective of the 5G Toolbox to protect 5G networks from foreign interference and dependencies 
and  encourages  Member  States  to  effectively  impose  and  enforce  necessary  restrictions  and 
exclusions on high-risk suppliers. 

SUMMARY ASSESSMENT: Limited progress 

39 

 
 
 
 
 
10.2  Member States should step up efforts to increase cybersecurity capabilities, including 
relevant  to  ensure  the  development  of  skills  for  the  cybersecurity  workforce  by 
making use of available resources at EU level such as the European Cybersecurity Skills 
Framework. 

Member  States  have  sustained  their  efforts  at  national  level,  in  line  with  the  NIS2  Directive 
requirement to promote and develop education and training on cybersecurity and cybersecurity skills. 
In this regard, all National Cybersecurity Strategies, including those adopted in 2025 (Czechia, Greece 
Hungary and Sweden) and 2026 (France and Slovakia) address the skills gap affecting their national 
cybersecurity workforce53. In January 2026, five Member States (AT, CY, EL, HR, SI) have submitted an 
application to the Commission for a Cybersecurity Skills European Digital Infrastructure Consortium 
(EDIC), which is a milestone in setting up the EDIC (see Section 12.2 on ICT specialists). 

Furthermore, 18 Member States in total have adopted the European Cybersecurity Skills Framework 
(ECSF),  including  four  in  the  period  between  July  2025  and  March  2026.  For  instance,  Hungary’s 
National  Cybersecurity  Strategy  envisages  the  ‘training  of  outstanding  domestic  professionals  in 
accordance  with the  European  Cybersecurity  Skills  Framework  (ECSF)’54.  Bulgaria  introduced  a  new 
cybersecurity  profession  in  the  Bulgarian  vocational  education  and  training  (VET)  system,  linking  a 
learning  outcome  to  making  use  of  the  role  profiles  defined  in  the  ECSF55.  The  Romanian  National 
Cybersecurity Directorate, in the context of a Digital Europe Programme project, used the ECSF as a 
reference framework to define learner profiles and structure curricula, enabling the translation of EU 
cybersecurity  skills  needs  into  coherent  education,  training,  and  upskilling  programmes 56 .  The 
Cybercampus  Sweden,  a  national  initiative  that  conducts  research,  innovation  and  education  in 
cybersecurity and cyberdefence, is using the ECSF to mitigate the skills shortage57. 

Additionally, over the analysed period, eight Member States continued to engage with ENISA in the 
pilot project on an attestation scheme for cybersecurity skills, as planned in the communication on 
the Cybersecurity Skills Academy. 

The  Commission  also  took  a  significant  step  to  support  workforce  development  by  presenting  its 
proposal for a Cybersecurity Act 2 on 20 January 2026. Building on the pilot project on an attestation 
scheme for cybersecurity skills, the proposal sets out a mechanism to develop a European system of 
attestations, with the view of supporting skills portability and growth and strengthening the European 
cybersecurity workforce. 

SUMMARY ASSESSMENT: Notable progress 

53 National Cyber Security Strategies, ENISA. 
54 Hungary’s National Cybersecurity Strategy, Hungary’s Official Gazette, 2025, Issue 35. 
55 Ordinance No 78 of 21 November 2025 on obtaining a qualification in the profession ‘cybersecurity’, Minister of 
Education and Science, 2 December 2025, State Gazette No 103. 
56 EU-iNSPIRE website. 
57 Guide for skills development – organizations in the public and private sector, Cybercampus Sverige, June 2025. 

40 

 
 
 
 
10.3  (a) Member States should, within the NIS Cooperation Group, develop a roadmap to 
ensure  a  synchronized  transition  to  PQC  throughout  the  whole  EU  for  public 
administrations and critical infrastructure; (b) Member States should progress in the 
transition  of  their  crypto  systems  to  post  quantum  cryptography by  2035,  ensuring 
intermediate  milestones  are  also  met  for  high  risk  use  cases  and/or  very  complex 
systems to be migrated by 2030. 

The NIS Cooperation Group adopted a Coordinated Implementation Road Map for the Transition to 
Post-Quantum  Cryptography  (PQC)  in  June  2025,  written  by  the  PQC  work  stream  of  that  group 
supported  by  the  Commission.  This  was  in  reaction  to  the  Commission’s  Recommendation  for  the 
transition  to  PQC  from  April  2024.  Additional  steps  are  now  being  taken  by  the  Member  States’ 
representatives of the PQC work stream within the NIS Cooperation Group to possibly provide more 
sectorial  guidance.  This  work  has  been  initiated  involving  experts  in  different  domains.  However, 
progress in those further steps currently relies on non-continuous engagement by the different experts. 
In the meantime, the proposal for a Directive as regards simplification measures and alignment with 
the Cybersecurity Act amends the NIS2 Directive by requiring EU policies (including the above road 
map) to be incorporated into national cybersecurity strategies. Implementation within the MSs will be 
more difficult to monitor, and further work would be needed to ensure that cross-border testing of 
critical  infrastructure  could  actually  take  place  and  that  critical  EU  assets  are  deployed  with  post-
quantum security. Moreover, further actions would be needed to ensure that a full ecosystem of PQC-
compliant solutions flourishes in the EU, thus allowing the transition to PQC to take place on the basis 
of EU-based solutions. 

SUMMARY ASSESSMENT: Limited progress 

41 

 
 
 
 
 
10.4  (a) Member States, together with the Commission, should urgently operationalise the 
different actions outlined in the Action Plan. Building on the transposition of NIS 2 and 
CER, priority should be given to the aim of ensuring comprehensive cable security; (b) 
Member States should fast-track key deliverables, including the Expert Group’s tasks 
(mapping,  risk  assessments,  Cable  Security  Toolbox,  priority  Cable  Projects  of 
European Interest) the development of a common strategy to reinforce cable repair 
capacities, and the establishment of Regional Cable Hubs. The goal of these hubs will 
be  to  establish  an  integrated  surveillance  mechanism  for  the  EU  to  monitor  and 
respond to cable security threats, in coordination with the cable repair capacities. 

The  actions  were  placed  under  four  pillars  on  the  basis  of  a  resilience  cycle  approach:  PREVENT, 
DETECT and RESPOND/REPAIR, DETER. 

In October 2025 the Commission published an EU risk assessment on submarine cable infrastructures, 
accompanied by a thorough mapping of these infrastructures as well as a policy and market analysis, 
and stress test guidance. It was prepared and agreed with Member States in the framework of the 
cable expert group set up under Commission Recommendation (EU) 2024/779 on Secure and Resilient 
Submarine Cable Infrastructures. Under the prevention pillar, the action plan delivered: (i) a mapping 
of existing and planned submarine data cable infrastructures connecting EU territories to each other 
and  with  other  parts  of  the  world;  ii)  a  coordinated  risk  assessment  identifying  seven  main  risk 
scenarios that build on different threats, vulnerabilities and dependencies; and iii) guidance to stress-
test these risk scenarios. The assessment also provided a comprehensive policy and market overview 
of EU submarine data cable infrastructures. 

In October 2025, the European Cybersecurity Competence Centre (ECCC) published DEP-related calls 
for the preparedness measures (EUR 10 million for stress-testing infrastructure, including cables) and 
the seed financing of the regional cable hubs (EUR 10 million to set up two or three hubs). These calls 
required the DEP work programme to be amended to find the right financing for the hubs and create 
the necessary synergies with the other work strands (repair, defence). The calls are open until the end 
of March. 

In February 2026, the Commission followed up with a Cable Security Toolbox of mitigating measures, 
in response to the results of the EU risk assessment, and a list of priority areas for Cable Projects of 
European Interest (CPEIs), to be prioritised for future public support, under the Connecting Europe 
Facility (CEF) and other programmes. 

In  February  2026,  the  Commission  launched  a  dedicated  pilot  call  for  deploying  modular  repair 
equipment  in  the  Baltic  Sea.  It  also  launched  calls  on  smart  cables  and  awarded  the  CEF-related 
projects. 

Cable resilience is also included in the upcoming cyber blueprint exercise. 

In March 2026, the Commission organised a high-level conference on submarine cables to take stock 
of the EU deliverables related to submarine cable infrastructures since the 2024 Recommendation and 
2025  action  plan and discuss the next steps, together  with representatives  from public authorities, 
industry, and academia. 

Overall,  the  implementation  of  the  action  plan  is  on  track,  in  terms  of  both  mobilising  financial 
resources, mobilising Member States and delivering on security reports. 

42 

 
 
 
SUMMARY ASSESSMENT: Notable progress 

43 

 
 
 
 
Protecting  and  empowering  people, 
harnessing digitalisation for sustainability 

reducing  burdens  and 

11 Basic digital skills 
11.1  (a) 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; (b) Member States should promote AI literacy and basic cybersecurity practices. 

Member  States  have  made  significant  investments  in  digital  education  and  skills  at  primary  and 
secondary  level,  improving  school  digital  infrastructure  and  supporting  innovative  teaching  and 
learning methods. Examples include Germany reaching agreement on its EUR 250 million Digitalpakt 
2.058,  Greece  announcing  the  establishment  of  innovation  centres  in  each  Regional  Directorate  of 
Education in the  country59,Czechia encouraging the recognition of international digital competence 
certificates  (such  as  ECDL/ICDL,  Cisco,  Oracle,  etc.)  for  school-leaving  examinations 60 ,    and  Italy 
creating the Digital Facilitation Service Network, now counting around 4 000 active facilitation points, 
and supporting approximately 2.5 million citizens in developing basic digital skills. 

Significant actions have also been taken by Member States to ensure equal access to AI technologies 
and applications in schools, foster their effective use for learning and support the necessary teacher 
skills. According to an OECD-EC study61, more than half of EU Member States have implemented digital 
literacy initiatives in primary and secondary education, commonly integrating AI-focused components 
such as coding, robotics, and algorithmic thinking. Notable examples are Estonia’s national initiative 
TI-Hüpe  2025,  aimed at  integrating  AI  tools and skills into the education system;  Finland’s Digivisio 
2030 programme, which consolidates digital competence courses and open learning materials into a 
unified platform, with AI supporting student guidance and counselling services; Slovakia’s Responsible 
Use of Artificial Intelligence in Education Plan 2025–202762, the Finnish National Agency for Education’s 
updated joint qualification components of vocational upper secondary qualifications, which emphasise 
data protection and AI63, and the Italian Strategy for Artificial Intelligence 2024-2026 which includes a 
dedicated section on AI literacy64 . 

Looking beyond formal education, several Member States are including AI in broader adult learning 
and skills strategies: at least 14 countries have adopted national strategies that include AI literacy as a 

58 Digital Pact for Schools 2.0: Federal and state governments invest €5 billion by 2030, Florentine Anders, 18 December 
2025. 
59 13 innovation centres are being established in each Regional Directorate of Education in the country: a strategic 
investment in the digital and innovative era, Ministry of Education, Religious Affairs and Sports (Greece), 7 July 2025. 
60 Amendment to the Education Act gives schools room to make school-leaving exams more meaningful and simpler, 
DigiKoalice, 18 September 2025. 
61 Progress in Implementing the European Union Coordinated Plan on Artificial Intelligence (Volume 1) – Member States’ 
Actions, OECD, 10 November 2025. 
62 Plan for the Responsible Use of Artificial Intelligence in Education 2025-2027, Ministry of Education, Research, 
Development and Youth (Slovakia), 5 September 2025. 
63 New joint components of qualifications emphasise communication and financial literacy in vocational upper secondary 
qualifications, Finnish National Agency for Education, 12 January 2026. 
64 Italian Strategy for Artificial Intelligence 2024-2026 

44 

 
 
 
 
key pillar65. Hungary’s Artificial Intelligence Strategy 2025-2030 includes AI literacy within the pillar on 
education  and  competence  development 66.  In  Austria,  the  Digital  Skills  Initiative  ensures  that  AI 
literacy is integrated into nationwide digital education. Similarly, Portugal’s Digital Skills Pact prioritises 
basic digital skills training for the whole population, including through mobile units67. 

Member States have also taken action to enhance cyber resilience, emphasising knowledge, skills and 
awareness. In line with the NIS2 Directive requirement to promote and develop education and training 
on  cybersecurity,  all  national  cybersecurity  strategies,  including  those  adopted  in  2025  (Czechia, 
Greece, Hungary, and Sweden) and 2026 (France and Slovakia) address the promotion of cybersecurity 
awareness  and  cyber  hygiene 68.  For  example,  Greece’s  recently  published  National  Cybersecurity 
Strategy supports skills development and the cultivation of a security culture covering all levels – from 
primary  and  secondary  to  tertiary  and  lifelong  learning69.  Furthermore,  the  National  Cybersecurity 
Coordination Centre of the Latvian Ministry of Defence, in cooperation with CERT.LV, launched the 
information  campaign  ‘Sniff  out  the  scam!’,  which  aims  to  strengthen  the  public’s  knowledge  of 
cybersecurity and resilience to threats, while educating them about cyber hygiene and digital fraud 
schemes70. 

The  European  Digital  Skills  Awards  continue  to  highlight  outstanding  Member  State  initiatives 
supporting  digital  competences,  digital  literacy  and inclusion.  On 12 November,  the winners of the 
2025 edition were announced. From 195 applications, five projects were selected. Engineers for a Day 
promotes STEM careers among girls, while Digital Überall delivers community-based basic digital skills 
training, including for vulnerable groups. In cybersecurity, Digital Angel raises awareness and equips 
citizens and organisations with practical skills to navigate online risks. In education, Escape Fake uses 
game-based learning to strengthen media literacy and critical thinking among students. At professional 
level,  the  EBU  Academy  –  School  of  AI  provides  applied  AI  training  tailored  to  workforce  needs, 
particularly in the media sector71. 

SUMMARY ASSESSMENT: Notable progress 

65 Progress in Implementing the European Union Coordinated Plan on Artificial Intelligence (Volume 1), OECD, 10 November 
2025. 
66 Hungary’s Artificial Intelligence Strategy 2025-2030, Government of Hungary, 3 September 2025. 
67 State Reform advances with Digital Strategy and Agenda for Artificial Intelligence, XXV Constitutional Government 
(Portugal), 4 December 2025. 
68 National Cyber Security Strategies, European Union Agency for Cybersecurity (ENISA), 4 June 2025. 
69 Greece – National Cybersecurity Strategy 2026-2030, Digital Skills and Jobs Platform, 20 January 2026. 
70 Ministry of Defence and CERT.LV launch cybersecurity campaign ‘Sniff out the scam!’ – eprasmes.lv, Digital Skills and Jobs 
Platform, 9 September 2025. 
71 Meet the winners of the European Digital Skills Awards 2025!, Digital Skills and Jobs Platform, 19 November 2025. 

45 

 
 
 
 
 
12 ICT specialists 
12.1  (a) Member States should promote ICT careers among young people, with notably a 
dedicated attention to girls; (b) Member States should enhance the academic offer for 
advanced digital skills and strengthen VET and lifelong learning in order to contribute 
to the EU’s strategic digital objectives in key areas such as AI Factories, cybersecurity, 
data and semiconductors; (c) Member States should increase efforts to expand labour 
migration pathways to attract highly skilled ICT specialists from non-EU countries and 
incentivise the return of European ICT talent to the EU, leveraging both national and 
European frameworks 

Since July 2025, Member States have further expanded their academic offer of advanced digital skills, 
in particular through joint programmes run by higher education institutions. They have also provided 
short-term training in key digital areas to support lifelong learning in ICT. The stakeholder community 
involved in developing state-of-the-art education and training programmes, supported by the Digital 
Europe  Programme,  has  grown  to  more  than  577  organisations  from  26  Member  States,  including 
education institutions, private companies, training providers and research organisations. 

Member  States  are  taking  varied  approaches  to  promoting  ICT  careers  among  young  people.  The 
Dutch government has set up ‘development pathways’, describing ICT jobs, specialisations and growth 
opportunities for people entering the sector, switching careers or developing their skills72, while the 
Maltese government has announced a new EUR 400 000 initiative to support individuals aged 16 and 
above  in  attending  basic  coding  courses 73 .  The  Luxembourg  government  has  launched  a  new 
programme to encourage girls aged 13-16 to consider tech/STEM careers, through school immersion 
days  for  girls  and  teacher  mobilisation.  It  has  also  set  up  ‘TechTalks4Girls’  events  to  inspire  girls 
through real-world tech role models74. All Member States also continue to engage in EU Code Week. 
In 2025, over 70 000 activities relating to coding and algorithmic thinking were organised across all 27 
Member States, attracting two million young participants, 48% of whom were girls. 

To  strengthen  advanced  digital  skills  in  the  workforce,  Member  States  have  formed  strategic 
partnerships with businesses, research institutions and social partners. Notable examples include: 
Austria’s new DKO Business Platform, which aims to increase the number of IT professionals and reskill 
and  upskill  professionals  in  critical  areas  such  as  AI,  data  use,  and  cybersecurity;  and  the  Spanish 
government’s  allocation of  EUR 200 million  from  the RRF for a digital skills training programme  for 
professional associations, which will train 80 000 professionals in digitalisation and AI75. Poland has 
significantly  expanded  its  PW  eSkills  initiative,  by  signing  agreements  with  nine  new  institutions76. 

72 First development pathways for ICT now live – cybersecurity, data and AI to follow soon, Digital Holland, 2 September 
2025. 
73 Malta Launches EU Code Week With New Schemes To Make Coding Accessible to All, Malta Daily, 9 October 2025. 
74 Girls: Deploy Your Talents!, IMS Luxembourg, 2025. 
75 Digital Transformation allocates 200 million euro to the training of 80 000 professionals in digitalisation and artificial 
intelligence, Government of Spain, 11 August 2025. 
76 Digital Poland Foundation joins PW eSkills initiative – together we build Poland’s digital future, Digital Poland Foundation, 
8 July 2025. 

46 

 
 
 
 
Support  for  cities  and  municipalities  is  also  present,  for  example through  Slovakia’s  declaration on 
cooperation between the Association of Towns and Municipalities and the National Digital Coalition77. 

AI also plays an important role in Member States’ strategies to support workforce upskilling. Many 
Member States reported measures to boost AI skills for adult upskilling and reskilling. Within its AI 
Skills Pact, which aims to have one million Danes enhance their AI skills by 2028, Denmark has launched 
the country’s first AI Skills Framework, giving leaders and employees a concrete tool to understand, 
use and develop AI skills78. Luxembourg has announced the launch of three skills academies in data 
and  AI,  cybersecurity  and quantum  computing  in 202679.  Many Member  States  are  also  promoting 
gender  inclusion  in  STEM  fields,  laying  important  groundwork  for  more  diverse  participation  in  AI, 
although efforts targeted specifically at women in AI remain scarce. Austria’s ‘SHE GOES AI’ is a notable 
example  promoting  digital  and  AI  skills,  facilitating  entry  into  AI-related  professions,  and  actively 
involving women in shaping AI80. 

Member States are also working to attract highly skilled ICT specialists from non-EU countries through 
a range of measures. The Blue Card scheme is widely used to attract highly qualified workers, with fast-
track options for shortage sectors such as ICT. The Netherlands offers a highly skilled migrant scheme; 
Estonia promotes ICT recruitment through its e-Residency programme and start-up visa; Denmark uses 
its Positive List scheme to identify shortage occupations, including in ICT; Ireland prioritises flexible 
visa options to attract tech professionals; and Finland is building pathways through fast-track visas and 
bilateral agreements, focusing on start-up growth and innovation. Member States also participate in 
other EU initiatives, such as talent partnerships, to attract ICT specialists from abroad. 

SUMMARY ASSESSMENT: Notable progress 

77 Representatives of cities and municipalities want to strengthen their digital and green skills, Digitálna koalícia, 13 October 
2025. 
78 Denmark’s first AI Skills Framework aims to make AI accessible to everyone, Digital Dogme, 4 December 2025. 
79 Three new academies for the jobs of tomorrow at the Digital Learning Hub, Luxembourg government, 2026. 
80 https://www.bundeskanzleramt.gv.at/bundeskanzleramt/nachrichten-der-bundesregierung/2025/10/bundesregierung-
will-mit-she-goes-ai-frauen-in-der-ki-staerken.html – Bundesministerium für Frauen, Wissenschaft und Forschung, 
30 October 2025. 

47 

 
 
 
 
 
12.2  (a)  Member  States  should  support  the 

implementation  of  EU  Digital  Skills 
Academies(b)  Member  States  should  leverage  EU  funding  opportunities  and 
governance  

The European Commission is establishing digital skills academies in multiple digital areas. The most 
advanced is the Cybersecurity Skills Academy, which was launched in 2023. To support its governance, 
Member  States  are  currently  setting  up  a  European  Digital  Infrastructure  Consortium  (EDIC).  The 
consortium  is  led  by  Greece  and  includes  Croatia,  Cyprus,  Austria  and  Slovenia  as  members,  with 
Czechia and Poland participating as observers. DG CNECT has recently received the formal application, 
and the EDIC is expected to be legally established in the near future, pending the Commission Decision. 

The EuroHPC Virtual Training Academy was established in April 2025, involving institutions from seven 
Member States. It will help ensure the availability of common quality and qualification standards in 
HPC, compatibility of training modules and learning objectives, and greater standardisation of training 
and education in the European HPC ecosystem. 

Three new digital skills academies in quantum, AI and virtual worlds have been called for under the 
Digital Europe Programme in 2025. A total of 31  applications were submitted, covering 26 Member 
States. The selected consortia will start their activities in summer 2026. 

Under  the  governance  of  the  Digital  Decade  Policy  Programme,  the  Best  Practice  Accelerator  has 
continued  its  work.  Member  States  have  shared  initiatives  aimed  at  increasing  the  participation  of 
women  in  digital  studies  and  careers  and  supporting  the  inclusion  of  vulnerable  groups  through 
improved digital skills. 

Member States are also actively engaging with the Digital Skills and Jobs Platform81, 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 2025 the platform was visited more than 430 000 times. It hosts the Digital Skills and Jobs 
Coalition, consisting of over 21 000 registered stakeholders, and connects 25 national digital skills and 
jobs coalitions representing the Member States. In addition, 23 national websites are connected to 
the core platform, continuously updating information on national initiatives. 

SUMMARY ASSESSMENT: Notable progress 

81 Digital Skills and Jobs Platform, European Commission, 2026. 
48 

 
 
 
 
 
 
13 Digital public services 
13.1  Member  States  should  focus  investments  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 procurement and 
including the completion of the connection of authorities to the Once-Only Technical 
System. 

Member  States,  supported  by  a  comprehensive  EU  policy  framework,  have  undertaken  significant 
actions  to  develop  secure,  interoperable  and  user-centric  digital  public  services.  These  collective 
efforts  have  led  to  measurable  improvements  in  availability  and  usability  across  the  EU.  However, 
implementation  remains  uneven,  with  persistent  gaps 
in  cross-border  service  provision, 
interoperability in practice, and emerging challenges related to security, advanced technologies and 
digital sovereignty. 

Cross-border service provision remains the main structural bottleneck. Despite progress at national 
level, a substantial number of services still require further development to meet Digital Decade targets. 
Key  sectors  affecting mobility,  in  particular  health  and  employment,  continue  to  face  difficulties  in 
delivering  fully  online  cross-border  services  for  citizens,  while  procedures  associated  with  the 
digitalisation of permits, official business certificates and proof documentation remain most complex 
for  cross-border  businesses.  This  reflects  the  fact  that,  while  interoperability  frameworks  are  well 
established at EU level, their implementation across administrations is still ongoing. Core components, 
including  cross-border  data  exchange  and  the  once-only  principle,  are  not  yet  fully  operational  in 
practice. 

EU-level instruments, including the Interoperable Europe Act, the Single Digital Gateway Regulation 
and the European Digital Identity Framework, provide the foundation for cross-border data exchange 
and  authentication.  Their  effectiveness,  however,  depends  on  sustained  and  coordinated 
implementation by Member States. 

Progress  is  also  visible  in  enabling  functionalities  and  user  experience,  in  particular  through  the 
increased use of prefilled forms to reduce administrative burden and the continued high performance 
of user support and mobile-friendly services. 

At  the  same  time,  common  challenges  persist  in  security,  sovereignty  and  the uptake  of  advanced 
technologies. While improvements have been made, uneven compliance with security controls and 
secure  internet  standards  across  public  sector  websites  indicates  the  need  for  further  efforts  to 
strengthen trust and readiness to face an evolving threat landscape. At the same time, reliance on non-
EU network operators for the hosting and network-level delivery of government and email services 
raises  shared  concerns  regarding  digital  sovereignty  and  long-term  resilience.  Finally,  although 
Member  States  are  exploring  AI  in  public  service  delivery  through  chatbots  for  user  support,  its 
deployment remains at an early stage, limiting its impact on efficiency and user experience. 

49 

 
 
 
 
 
 
 
 
Overall,  Member  States  have  made  steady  progress,  but  achieving  fully  interoperable,  secure  and 
sovereign cross-border digital public services by 2030 will require sustained and coordinated collective 
action across the EU. 

SUMMARY ASSESSMENT: Notable progress 

50 

 
 
 
 
 
14 EU Digital Identity Wallet 
14.1  Member States should continue their strong commitments to the development of use 
cases to link private and public service providers to the  wallets and offer the user a 
large variety of use cases upon first issuance of the wallets at national level in 2026. 

Under Regulation (EU) 2024/1183 establishing the European Digital Identity (EUDI) Framework, each 
Member State is required to provide an EU Digital Identity Wallet by the end of 2026. All Member 
States are actively working on developing their European Digital Identity Wallets. 

To ensure that EUDI Wallets are secure and protect users, each national EUDI Wallet must be certified 
in accordance with the Cybersecurity Act. A certification scheme for the EU Digital Identity Wallets is 
key to the successful functioning of the wallets concept. 
While an EU-level certification scheme following the Cybersecurity Act is being developed, the first-
generation wallets will have to be certified under national certification schemes. The Commission has 
set up a support mechanism for Member States, including several work streams. In addition, to ensure 
users’ privacy and data protection, the requirements of the General Data Protection Regulation must 
also be respected. 

In addition, the Commission is supporting Member States through the financing of  large-scale pilot 
projects, which are critical in testing, validating, and maturing the EU Digital Identity Wallet ecosystem 
across multiple Member States and use cases. The four pilots concluded in 2025 – NOBID, Potential, 
EWC,  and  DC4EU  –  covered  a  wide  range  of  use  cases,  from  payments  and  travel  credentials  to 
education, social security, and public/private sector digital services. Together, they involved over 300 
organisations, including public authorities and private sector partners, across more than 20 Member 
States. 

The pilots have successfully delivered major tangible outputs, including actual wallet implementation, 
cross-provider testing, stakeholder engagement, and early  insights into business models. The pilots 
demonstrated the real-world use of EUDI Wallets in everyday scenarios, including in a cross-border 
context. For example, the wallet  has been used to authenticate and authorise secure payments for 
products and services, showing that it can support actual payment transactions both online and in-
store. In addition, the large-scale pilots tested use cases such as the opening of a bank account online, 
registering  a  SIM  card,  accessing  government  services  (for  example  electronic  identification  and 
authentication  for  public  services,  presentation  of  certificates  such  as  proof  of  residence,  or 
representation of legal persons through the presentation of company registration attestation), signing 
documents with a qualified electronic signature, and redeeming e-prescriptions. 

These pilots have laid a robust foundation for the next phase of digital identity deployment in Europe, 
providing valuable lessons on technical feasibility, cross-border interoperability, user experience, and 
governance that the next generation of large-scale pilots – WE BUILD and APTITUDE – can build upon. 

Overall, the breadth of measures undertaken, including (i) the development of national wallets across 
all  Member  States,  (ii)  the  establishment  of  certification  frameworks,  and  (iii)  the  successful 
completion  of  large-scale  cross-border  pilots  covering  a  wide  range  of  use  cases,  demonstrates 
sustained commitment and tangible implementation at EU and Member State level. This justifies the 

51 

 
 
 
assessment of significant progress, although further efforts will be needed to ensure full deployment 
and uptake of wallets by 2026. 

SUMMARY ASSESSMENT: Significant progress 

52 

 
 
15 Electronic health record 
15.1  (a) Member States should continue to implement the necessary measures to achieve 
full  access  for  citizens  to  their  electronic  health  records.  (b)  Member  States  should 
cooperate to fully deploy the innovation potential of health data by: (i) maximising 
the use of existing and future health data initiatives and infrastructure; (ii) investing 
in the research and deployment of advanced technologies such as high-performance 
computing  and  trustworthy  AI  applications 
in  healthcare;  (iii)  strengthening 
cybersecurity measures and enhancing cooperation through EDICs in this area. 

Digitalisation  remains  a  key  enabler  of  the  transformation  of  health  systems,  supporting  universal 
access  to  electronic  health  records  (EHRs)  and  enabling  the  deployment  of  advanced  digital 
technologies, including artificial intelligence (AI), through the effective use of health data. EU Member 
States have reached 87% of citizens with access to their EHRs, an increase of  4 percentage points 
compared  to  2025 82 .  This  progress  reflects  sustained  efforts  to  improve  the  timely  availability, 
accessibility and interoperability of health data across healthcare providers. 

Significant  policy  developments  and  cooperative  initiatives  have  taken  place  over  the  assessment 
period. Member States have strengthened cooperation to maximise the innovation potential of health 
data infrastructures. The 1+Million Genomes (1+MG) initiative has entered its scale-up phase, with 26 
Member States contributing to governance, trust, and technical frameworks. This is supported by the 
Digital  Europe  Programme  (DIGITAL)  projects  Genome  of  Europe  (GoE)  and  the  Genomic  Data 
Infrastructure (GDI), with the latter establishing a decentralised, federated infrastructure for secure 
access to genomic and clinical data. By late 2026, 15 Member States are expected to have operational 
federated infrastructures in place, supporting research pilots, high-quality genomic data generation, 
and connectivity with the EHDS. In 2026 an application is also expected to be submitted for the creation 
of an EDIC laying the basis for governance and sustainability. 

Similarly, under the European Cancer Imaging Initiative, cooperation has been stepped up on the use 
of medical imaging and AI for personalised cancer care. The Cancer Image Europe platform deployed 
through the DEP-funded European Federation for Cancer Images (EUCAIM) project is now operational, 
providing  access  to  a  public  catalogue  of  over  80  medical  imaging  datasets  and  more  than  35 
preprocessing  tools.  The  platform  is  being  expanded  through  the  EU4Health-funded  projects 
BreastSCan and UNICA, with the latter bringing additional breast, lung, and prostate cancer imaging 
datasets from 12 medical centres. 18 Member States are now preparing the submission of a new EDIC. 

Progress  in  AI  deployment  and  supporting  infrastructure  has  also  been  notable.  According  to  the 
Commission,  at  least 19 Member States  identify  health as a priority sector for AI deployment.  The 
Commission  has  established  19  AI  factories,  17  of  which  focus  on  health,  life  sciences,  or 
pharmaceuticals,  providing  Member  States,  researchers,  and  SMEs  with  access  to  advanced 
computing capacity, data, and AI expertise. These efforts are complemented by planned investments 
of EUR 20 billion in AI gigafactories, which will support the development and deployment of cutting-
edge AI models for strategic sectors, including healthcare. 

The European Virtual Human Twins (VHT) Initiative is advancing the next generation of AI-enabled 
virtual  human  twin  solutions  for  personalised  healthcare.  The  Commission  convened  a  high-level 

82 The 2025 Digital Decade eHealth indicator study, 2026 State of the Digital Decade report, European Commission, June 
2026.  

53 

 
 
 
 
event in October 2025, bringing together around 200 stakeholders to align on its long-term vision and 
strategic priorities. In addition, a framework contract was signed in June 2025 to develop an advanced 
VHT platform supporting modelling, integration, and validation. Two Horizon Europe research topics 
published in December 2025 and the VHT Uptake Incubator, a EUR 7.2 million knowledge-sharing and 
collaboration hub developed under the Apply AI Strategy, will further expand the VHT Initiative. 

Progress has also been made in strengthening cybersecurity in the health sector, in cooperation with 
the  European  Union  Agency  for  Cybersecurity  (ENISA),  the  European  Cybersecurity  Competence 
Centre (ECCC), and Member States. The Commission continued to implement the European action plan 
on  the  cybersecurity  of  hospitals  and  healthcare  providers.  In  this  context,  the  ECCC  launched  a 
EUR 30 million call to reinforce cybersecurity capacities in hospitals and healthcare providers, while 
ENISA issued guidance on cybersecurity practices in September 2025. Building on these activities, the 
Commission will put forward recommendations to further refine the action plan. 

Progress  towards  full  access  to  EHRs  is  expected  to  accelerate  with  the  phased  application  of  the 
European  Health  Data  Space  (EHDS)  Regulation,  which  entered  into  force  on  26 March  2025.  The 
application of general requirements is expected from March 2027, followed by rules on the primary 
and secondary use of specified health data categories from March 2029. Additional provisions for the 
remaining data categories, including genomic data for secondary use, will become operational from 
March 2031. 

To facilitate access to data, computing infrastructure, skills, and regulatory guidance for AI deployment 
in health, the Apply AI Strategy launched in October 2025 sets out four flagship initiatives to boost AI 
adoption, with healthcare and pharmaceuticals identified as priority sectors. Among these are: (i) the 
network of European AI-powered advanced screening centres, which will integrate AI solutions for 
cancer and cardiovascular diseases and assess their impact; and (ii) the European Network of Expertise 
on  AI  Deployment  in  Healthcare,  which will  consolidate  guidelines  and  best  practices  for  safe  and 
effective AI integration in healthcare settings. 

Overall,  Member  States  have  made  notable  progress  in  expanding  citizens’  access  to  EHRs  and 
strengthening  cooperation  on  health  data  for  AI.  However,  major  barriers  and  gaps  remain.  EHR 
deployment  is  uneven  across  the  EU  due  to  disparities  in  digital  maturity,  investment  capacity, 
workforce skills, and cybersecurity preparedness. More broadly, the deployment of AI in healthcare 
continues to be constrained by fragmented data ecosystems, outdated IT infrastructure, regulatory 
complexity, financial affordability, and persistent challenges related to data quality and standards83. 
Addressing  these  gaps  will  require  sustained  coordinated  action  at  both  EU  and  national  level, 
including  continued  investment  in  AI  uptake  in  health,  stronger  interoperability,  and  effective 
implementation of the EHDS. 

SUMMARY ASSESSMENT: Notable progress 

83 Study on the deployment of AI in healthcare – Publications Office of the EU, Directorate-General for Health and Food 
Safety (European Commission), PwC, EEIG, Open Evidence, 2025. 
54 

 
 
 
 
 
 
15.2  Member  States  should  implement  the  actions  foreseen  in  the  Action  Plan  on 

cybersecurity of hospitals and healthcare providers. 

Member States have begun preparations for a coordinated security risk assessment on medical devices, 
as  outlined  in  the  action  plan.  Moreover,  some  Member  States  have  reported  on  preparation  of 
national action plans for cybersecurity in the health sector (HU, SK). Member States have not reported 
on the distribution of cybersecurity vouchers for hospitals and healthcare providers. 

As  the  set-up  of  a  cybersecurity  support  centre  for  hospitals  and  healthcare  providers  at  ENISA  is 
ongoing, activities  for Member  States indicated in the  action  plan  that involve  interaction with the 
support centre have still to be initiated. 

SUMMARY ASSESSMENT: Limited progress 

55 

 
 
 
 
 
16 Protection of minors 
16.1  Member States should implement the harmonised EU age-verification solution in the 
national EUDI Wallets, including systems for issuing the proof-of-age attestations, and 
accelerate the issuance of electronic means of identification to minors; 

Member States are required to provide European Digital Identity Wallets (EUDIWs) to their citizens by 
24 December 2026. The wallet will support the privacy-preserving exchange of proofs of age, including 
a  specific ‘I am over the  age of NN’  attestation which citizens can use to confirm  that  they meet a 
minimum age requirement when accessing services. 

Wallets are issued to minors on the basis of national regulations, as harmonisation across the EU has 
not yet been achieved. As a result, some Member States make the wallet available from the age of 12, 
while others restrict it to adults (18+). 

To  support  online  platforms  in  implementing  a  robust,  user-friendly,  data  protection,  and  privacy-
preserving age verification method, the European Commission, in close collaboration with the Member 
States, has developed a harmonised approach in parallel. This resulted in the release of a blueprint for 
an EU age verification solution, based on the technical specifications of the EUDIW, in July 2025, which 
is currently being piloted with Members States, platforms, and users. 

Several Member States (CY, DK, EL, ES, FR, IT) are planning to run pilots, with the first national apps 
expected  in spring  2026.  Once  available  in  app  stores,  published  by  either  Member  States  or  third 
parties, the application will allow users to prove that they are over 18 when accessing age-restricted 
content or products online (such as pornography, gambling, or alcohol purchases), without sharing any 
additional personal data. The system is adaptable to extend the age verification solution to other age 
thresholds (e.g. 13+, 15+, 16+), or to other use cases, such as purchasing alcohol in a shop. Member 
States can decide on their exact functionality when customising it to the national context, or at any 
later stage. 

SUMMARY ASSESSMENT: Limited progress 

56 

 
 
 
 
 
16.2  Member States should take action to ensure the protection of minors and their well-
being  online,  by  cooperating  on  important  issues  such  as  age  verification  and 
cyberbullying, 
including  through  support  for  the  future  action  plan  against 
cyberbullying 

The  digital  services  coordinators  (DSCs)  and  competent  authorities  in  charge  of  scrutinising  the 
implementation by online platforms of the Guidelines on the protection of minors under Article 28(1) 
of the Digital Services Act (DSA) meet monthly with the Commission and discuss compliance solutions 
and exchange best practices with regard to the enforcement of the Guidelines. Over the last year, the 
working group has adopted an implementation strategy for the Guidelines and also contributed to the 
development  of  the  Commission’s  blueprint  for  age  verification.  Moreover,  concrete  actions 
concerning enforcement against providers of pornographic content are expected by Q2 2026. 

The  Commission  continues  to  monitor  the  transposition  and  effective  implementation  of  the 
Audiovisual  Media  Services  Directive  (AVMSD)  by  the  Member  States,  including  the  provisions 
pertaining  to  the  protection  of  minors.  Moreover,  since  its  establishment  in  February  2025,  the 
European Board for Media Services has also functioned as a forum for exchange  and collaboration 
between  Member  States  on  the  implementation  of  the  AVMSD,  especially  with  regard  to  pressing 
challenges such as the protection of minors online, which was one of the media board’s work priorities 
in 2025. 

The  Commission  adopted  the  action  plan  against  cyberbullying  after  extensive  consultations  with 
stakeholders, including Member States’ representatives through the expert group on safer internet for 
children. The action plan focuses primarily on minors, while also considering the gender dimension 
and enhanced vulnerability of certain groups of young people. 

It aims to establish an EU framework with a common understanding of cyberbullying at its core. The 
action plan is founded on three interlinked pillars: 

 

 
 

first, ensuring a coordinated EU approach for protection, by making full use of the existing 
policy and legal instruments; 
second, increasing prevention and awareness; 
third, improving reporting and support, including with a dedicated online safety app. 

On the basis of the 2026 Better Internet for Kids (BIK) policy monitor, Member States have continued 
to take significant action to protect minors and support their well-being online. National approaches 
are  increasingly  aligned  with  the  BIK+  strategy  and  reinforced  by  the  implementation  of  key  EU 
legislation such  as  the  DSA  and  the  AVMSD.  There  has  been  a  clear  shift  towards  more  structured 
governance,  with  more  countries  adopting  national  action  plans,  clarifying  responsibilities,  and 
grounding  policies  more  explicitly  in  children’s  digital  rights.  Cooperation  is  also  becoming  more 
operational, for example through closer links between digital services coordinators and safer internet 
centres, and the use of tools such as risk assessments and trusted flaggers. 

Measures addressing online risks, including cyberbullying and harmful content, are now widespread 
across  Member  States  and  increasingly  embedded  in  broader  policy  frameworks.  Countries  are 

57 

 
 
 
 
 
 
strengthening  oversight  of  platforms,  introducing  school  policies  to  support  digital  well-being,  and 
integrating online safety, media and AI literacy into education systems. Digital empowerment is well 
established,  with  most  Member  States  running  initiatives  on  disinformation,  youth-focused  fact-
checking,  and  support  for  parents.  At  the  same  time,  gaps  remain:  data  collection  is  still  uneven, 
monitoring  is  not  always  systematic,  and  only  a  limited  number  of  countries  have  put  in  place 
mechanisms to involve children directly in shaping digital policies. 

Progress is also visible on age-related safeguards and efforts to address cyberbullying. Age verification 
is  receiving  increased  attention,  with  more  Member  States  introducing  or  developing  measures, 
although approaches remain at different stages and are not yet consistent. Taken together, this points 
to  notable  progress,  with  clear  engagement  and  a  solid  basis  for  further  cooperation,  including  in 
support of the action plan against cyberbullying, while further work is needed to improve consistency, 
evidence, and structured participation across Member States. 

SUMMARY ASSESSMENT: Notable progress 

58 

 
 
 
 
 
17 Information integrity 
17.1  (a)  Member  States  should  increase  resilience  against  disinformation  by  investing  in 
areas  such  as  fact-checking,  media  literacy  and  technological  detection  tools;  (b) 
Member  States  should  promote  further  research  on  information  manipulation, 
looking  into  the  structural,  economic,  psychological,  and  technological  factors  that 
contribute to its spread; (c) Member States should develop and implement national 
strategies for countering foreign information manipulation and interference, including 
improved detection, response capacity, and secure information exchange channels 

The erosion of information integrity poses a threat to democratic resilience, particularly in an era when 
foreign information manipulation and interference (FIMI) and coordinated inauthentic behaviour (CIB) 
have  grown  in  sophistication, exploiting algorithm-driven amplification, deepfake technologies, and 
fragmented  media  ecosystems.  As emphasised  by the  European  Council,  strengthening  democratic 
resilience is of primary importance and Member States are invited to enhance their efforts to counter 
FIMI84. 

Recent Eurobarometer data shows that 42% of Europeans view foreign information manipulation and 
disinformation,  especially  during  elections,  as  a  major  threat  to  democracy,  second  only  to  public 
distrust in institutions (49%)85. This underscores the importance of safeguarding information integrity 
to  maintain  public  trust,  empower  citizens  through  media  literacy,  and  strengthen  democratic 
resilience against emerging digital threats. 

The European Democracy Shield (EDS), adopted in late 2025, bolsters and complements the initiatives 
undertaken within the Digital Services Act (DSA) framework. The democracy shield is a comprehensive 
initiative to protect democratic processes, institutions, and media freedom from foreign interference, 
disinformation,  and  cyber  threats.  It  focuses  on  enhancing  societal  resilience,  ensuring  electoral 
integrity,  and  combating  malicious  manipulation  using  AI  and  deepfakes.  This  complements  the 
processes under the DSA and the Code of Conduct on Disinformation, to significantly boost the EU’s 
capacities to combat FIMI and safeguard the integrity of the information space. 

Member States have made some progress in recognising and integrating media literacy as a tool to 
counter  disinformation.  However,  implementation  remains  fragmented  in  both  scope  and  target 
audience. Estonia stands out for its collaborative approach86 to media literacy guided by the National 
Media Literacy Action Plan for 2024-202687. However, most Member States bundle media literacy with 
broader digital skills initiatives, often focusing narrowly on school-aged populations. At the same time, 
Member States have made efforts to advance research on information manipulation. However, these 
efforts  remain  fragmented  and  unevenly  distributed,  often  driven  partially  by  national  security 
frameworks. 

84 European Council Conclusions, 19 March 2026. 
85 Special Eurobarometer 568, ‘Protecting and promoting democracy’, May 2025. 
86 In Estonia, national responsibility for media literacy is held by the Government Office (Riigikantselei), in collaboration 
with the Ministry of Education and Research (Haridus- ja Teadusministeerium). 
87 National Media Literacy Action Plan for 2024-2026 [in Estonian], Estonian Government. 

59 

 
 
 
 
The  European  Digital  Media  Observatory  (EDMO)  complements  these  national  efforts  through  its 
network of 15 regional EDMO hubs. EDMO integrates the work of independent academic researchers, 
fact  checkers,  and  media  literacy  practitioners.  Each  hub  helps  detect  and  analyse  disinformation 
campaigns,  producing  content  to  support  mainstream  and  local  media  and  public  authorities  in 
exposing  harmful  disinformation  campaigns,  organising  media  literacy  activities  at  national  or 
multinational level, and helping national authorities monitor online platforms’ policies and the digital 
media ecosystem. 

In 2025  Member States  made  limited  progress  in  developing  national  strategies to counter  FIMI, 
with  approaches  ranging  from  comprehensive,  multi-pillar  frameworks  to  fragmented,  sectoral 
measures. France and Ireland stand out as leaders, having adopted formal national strategies: France’s 
National Strategy to Combat Information Manipulation (2026-2030) and Ireland’s National Counter-
Disinformation Strategy (NCDS). 

However,  most  Member  States  do  not  have  unified  FIMI  strategies,  and  rely  instead  on  sectoral 
approaches through broader national security, cybersecurity, or DSA-related measures. To effectively 
safeguard information integrity, Member States should fully leverage the FIMI Toolbox to maximise 
coordination, scale up responses and provide information for proactive, deterrence-based strategies88. 

SUMMARY ASSESSMENT: Limited progress 

88 4th EEAS Annual Report on Foreign Information Manipulation and Interference Threats, European External Action 
Service, June 2026. 

60 

 
 
 
 
 
17.2  Member States should develop new strategies to ensure a  pluralistic media sphere, 
including  through  financing  provisions  for  news  media,  in  ways  that  respect  media 
independence. 

According to the Media Pluralism Monitor 2025 report on risks to media pluralism and media freedom, 
no Member State falls into the extreme risk bands (very high/very low), with only HU falling into the 
high-risk category. Most (22) of the countries are assessed as medium-risk, with roughly half of them 
falling into the upper band of this category (medium-high) (BG, CY, CZ, EL, ES, HR, IS, IT, MT, PL, RO and 
SK) and the other half (AT, BE, EE, FI, FR, IE, LT, LU, LV and PT) at the lower tier (medium-low). The 
average  risk  score  for  the  EU,  estimated  at  49%,  falls  within  the  medium-low  risk  band.  Only  four 
Member  States  –  DE,  DK,  NL  and  SE  –  are  assessed  as  falling  in  the  low-risk  category.  Their  good 
performance reflects strong fundamental protection of the media, as well as good safeguards for the 
political independence of the media and, to a lesser extent, for the inclusive media environment. HU 
stands out as the worst-performing country by a considerable margin, followed by MT and RO, which 
show shortcomings in the areas of market plurality and political independence. BG, CY, RO and, to a 
lesser extent, EL are all associated with an especially poor performance in market plurality and social 
inclusiveness. The worst-performing Member States scored particularly poorly in market plurality, with 
CY, HU, and RO falling into the highest-risk category. 

According to the 2025 European Media Industry Outlook, the viability of the news media sector is at 
risk  in  nearly  all  Member  States  (except  for  LU  and  NL).  Total  revenues  have  been  decreasing,  in 
particular in the press and magazine subsectors. The distribution of news is increasingly dominated by 
online platforms and search engines, which generate structural imbalances in the online advertising 
market and limit opportunities for news media actors to monetise their content. The viability of local 
news media is under particular strain, with a medium-to-high risk of emerging news deserts in most 
(19) Member States, which further weakens the pluralism of the media sector. 

The  European  Media  Freedom  Act  (EMFA),  a  key  piece  of  legislation  to  protect  media  freedom, 
independence and pluralism within the EU’s internal market, entered into force across the European 
Union in August 2025. The EMFA aims to enhance the integrity of the internal market and thus protect 
media pluralism and independence in the EU. The 2025 Rule of Law Report highlighted that the EMFA 
triggered readiness checks of Member States’ legislation before most of its provisions had been applied 
and that the newly set up European Board for Media Services, an independent advisory body consisting 
of representatives of national media regulators, will play a central role in monitoring, coordinating and 
supporting media policies across EU Member States. 

In  November  2025  the  Commission,  jointly  with  the  High  Representative  of  the  Union  for  Foreign 
Affairs and Security Policy, adopted a communication on the European Democracy Shield. It also lays 
down the Commission’s plans to deploy its financial tools to support independent and local journalism 
under  a  new  Media  Resilience  Programme  to  bridge  current  support  with  funding  programmes 
proposed in the 2028-2034 multiannual financial framework (MFF). The Commission also proposed to 
further increase support to the news media sector under the next MFF with the AgoraEU programme. 

61 

 
 
 
 
The Commission operates in full accordance with the principle of subsidiarity. Action to support the 
sector is also needed from the Member States. 

The 2025 Rule of Law Report explained that measures put forward in previous years in several key 
areas,  such  as  strengthening  the  safety  and  protection  of  journalists,  addressing  strategic  lawsuits 
against public participation (SLAPP) and addressing structural challenges in the media landscape more 
generally under the European Media Freedom Act (EMFA), were at different stages of implementation. 
The  report  referred  to  deteriorating  conditions  for  journalists  in  several  countries,  with  increased 
physical violence during protests, more online harassment and smear campaigns by politicians, as well 
as  growing  risks  from  highly  concentrated  media  ownership  and  the  dominance  of  a  few  digital 
platforms. 

The  2025  European  Media  Industry  Outlook  highlighted  that  news  media  organisations  struggle  to 
harness technological developments, including AI systems, and to develop industry-wide technological 
infrastructures to scale up and unlock new revenues. While EU-level support for media viability and 
media  pluralism  is  expected  to  increase,  it  is  also  necessary  to  support  the  development  of  such 
technological  infrastructures,  which  can  help  news  organisations  overcome  language  and  cultural 
barriers, reach new audiences or generate new advertising revenues. 

SUMMARY ASSESSMENT: Limited progress 

62 

 
 
 
 
18 Green and digital 
18.1  (a)  Member  States  should  support  the  development  of  harmonised  environmental 
impact metrics for digital solutions including AI-based solutions as well as metrics for 
digital infrastructures such as, edge computing, data centres, and telecommunications 
networks; (b) Member States should reinforce their cooperation with the AI Office, 
the  Green  Digital  Coalition,  and  the  European  Green  Deal  Data  Space,  as  well  as 
contributing to the upcoming EU Code of Conduct for sustainable telecommunications 
networks; (c) Member States should incorporate digital sustainability KPIs into their 
national digital and green transition plans. 

In January 2026 the Commission published an EU Code of Conduct (EU CoC) for the sustainability of 
telecommunications networks, as provided for in the 2022 ‘Digitalising the energy system’ action plan. 
Member  States  contributed  via  BEREC,  in  particular  during  stakeholder  workshops  in  May  and 
November 2025. BEREC has included in its 2026 work programme the establishment of an ad hoc data 
collection mechanism, through a questionnaire on the implementation of key sustainability indicators 
that national regulatory authorities will distribute to market players. Moreover, references to the EU 
CoC  are  included  in  the  Commission’s  Digital  Networks  Act  (DNA)  proposal,  which  is  currently  in 
interinstitutional negotiations. 

In February 2025, the second phase of the European Green Digital Coalition (EGDC) pilot project was 
launched. Between now and February 2027 the EGDC will apply the science-based methodology for 
assessing the net carbon impact of ICT solutions, which was developed in phase one and published in 
2024, to 50 case studies. The project also includes close collaboration with financial institutions  on 
setting eligibility criteria for climate-aligned investments. By January 2026, the European Green Digital 
Coalition had held alignment discussions with several national agencies in different Member States, 
such  as  ADEME  (the  Agency  for  Ecological  Transition)  and  Arcep  (the  Electronic  Communications, 
Postal and Print  Media  Distribution Regulatory Authority)  in  France  and DENA  (the German Energy 
Agency) in Germany, that are developing their own national frameworks closely aligned with the EGDC 
methodology in order to measure and assess the net environmental impact of digital solutions and 
infrastructure.  The  EGDC  is  also  highlighted  by  the  World  Economic  Forum  in  its  new  AI  Energy 
Foresight Tool. Furthermore, the EGDC will continue working closely with similar initiatives at an EU 
and global level on developing a repository for sharing knowledge from the 50 case studies. 

The Green Deal Data Space is seeking to enable the Digital GreenTech community to scale up cross-
sector solutions using reusable components and high-quality datasets. Priority actions include data-
driven services for the European Water Resilience Strategy, digitisation of permitting processes, pilots 
on textile traceability and nature credits, and advanced forest monitoring with machine learning on 
open and confidential data. 

With  respect  to  environmental  impact  metrics  for  digital  infrastructures,  the  Commission  has 
introduced the Data Centre Energy Efficiency Package, which includes a rating scheme for data centres, 
covering energy efficiency, water efficiency, renewable energy use, waste heat reuse and flexibility, 
based on the existing reporting scheme. 

SUMMARY ASSESSMENT: Limited progress 
63 

 
 
 
64 

 
 
 
 
19 Simplification 
19.1  Member States should fully leverage the DDB’s role and expertise to help streamline 
the implementation of digital acquis and support the development and deployment 
of solutions for simplification and reduction of administrative burden. 

The  Digital  Decade  Board  (DDB)  continues  to  play  an  important  role  as  a  platform  for  exchange, 
coordination and peer learning between Member States on the implementation of the Digital Decade 
Policy Programme (DDPP) and the broader digital acquis. Throughout 2025 and in early 2026, Member 
States engaged regularly in the DDB, structuring their work around monitoring progress, preparing the 
DDPP review and addressing implementation challenges. 

Engagement has taken place through regular meetings, targeted exchanges under successive Council 
Presidencies  and  more  structured  formats  such  as  ‘deep  dives’.  These  discussions  have  enabled 
Member States to share experiences, identify common challenges and help implement and review the 
DDPP.  In  particular,  Member  States  have  consistently  highlighted  issues  related  to  administrative 
complexity,  reporting  burdens,  KPI  methodology,  and  the  alignment  of  EU  recommendations  with 
national governance and budgetary processes. 

In  2025  Member  States  collectively  strengthened  their  focus  on  regulatory  simplification  and 
administrative burden reduction. A dedicated deep dive on simplification, held in September 2025, 
enabled  exchanges  on  national  road  maps  and  on  streamlining  reporting  and  implementation 
processes.  Simplification  concerns  also  featured  prominently  in  broader  discussions,  with  several 
Member  States  calling  for  lighter  monitoring  requirements,  better-aligned  indicators  and  more 
actionable  recommendations.  Subsequent  exchanges,  including  in  the  context  of  the DDPP  review, 
confirmed simplification as a shared priority. 

This collective orientation was reinforced by the adoption of the 2025-2026 DDB work programme. 
The  programme  introduces  thematic  deep  dives  on  governance  and  simplification  and  plans  the 
preparation of a DDB Opinion on the DDPP review as a key joint deliverable, supporting more strategic 
and evidence-based discussions between Member States. 

At the same time, Member States are cooperating closely in preparing the DDB Opinion through a 
collaborative drafting process supported by the Commission and led by designated penholders. The 
Opinion  is  expected  to  include  proposals  on  governance  simplification,  administrative  burden 
reduction and improved coordination mechanisms, building on DDB exchanges. 

These developments point to a gradual strengthening of the DDB’s role, with Member States moving 
towards more structured and output-oriented cooperation. However, this is a gradual process. While 
discussions  have  become  more  focused  and  operational,  tangible  collective  outputs  in  the  area  of 
simplification  –  such  as  jointly  agreed  guidelines,  common  tools  or  coordinated  implementation 
approaches – remain limited at this stage. 

Overall,  Member  States  have  demonstrated  sustained  engagement  in  the  DDB  and  advanced 
collective discussions on simplification, governance and implementation of the digital acquis. More 
structured cooperation is emerging, in particular through thematic deep dives and the preparation of 

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the  DDB  Opinion,  but  this  has  not  yet  translated  into  concrete  shared  tools  or  coordinated 
implementation practices. 

Further efforts might be needed to strengthen the DDB’s operational role and translate discussions 
into tangible outcomes. This could include developing common guidelines, practical toolkits or shared 
approaches to reducing administrative burdens, particularly in areas such as reporting, monitoring and 
alignment  of  national  road  maps.  The  ongoing  DDPP  review  and  forthcoming  DDB  Opinion  could 
provide an opportunity to reinforce the Board’s role as a more strategic and action-oriented forum 
supporting simplified and coordinated implementation across the EU. 

SUMMARY ASSESSMENT: Notable progress 

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20 Cities and regions 
20.1  Member States should encourage cities to participate in multi-country projects such 

as the LDT CitiVERSE EDIC and support cross-border reuse of digital public services; 

Although Member States and local and regional authorities are investing in digital capacity building 
and  data-driven  governance,  these  efforts  remain  fragmented  and  project-based.  There  is  limited 
coordination across borders or policy domains at EU level. Joint frameworks and collective actions are 
still in their early stages, as the Commission has only recently established the governance and legal 
structures for initiatives such as the LDT CitiVERSE EDIC, which participating Member States and cities 
are now building and scaling up. 

In  this  context,  the  progress  made  so  far  can  be  described  as  limited  but  foundational:  individual 
administrations are experimenting and investing, but the conditions for large-scale, interoperable and 
reusable digital solutions across the EU have not yet been fully established. The next three years are 
therefore  expected  to  be  critical,  as  Member  States  and  cities  transition  from  isolated  pilots  and 
national  or  regional-level  initiatives  to  more  coordinated,  EDIC-driven  investment  and  shared 
governance. This should transform the current limited progress into significant, systemic advancement 
in local digital capabilities and data-driven governance. 

Living-in.eu is a bottom-up movement that aims to accompany cities in their digital transformation and 
enables cities and regions to work together on societal challenges with the help of digital solutions. 
The initiative is a cooperation of Eurocities, Open & Agile Smart Cities & Communities (OASC) and the 
European  Network  of  Living  Labs  (ENoLL)  and  is  supported  by  the  European  Commission  and  the 
European  Committee  of  the  Regions.  Currently,  the  Go  Li.EU  project  funded  by  the  Commission 
provides support for the governance structure until September 2026. 

Over the past three years, the focus has been on creating the conditions for upscaling existing and 
‘proven  digital  solutions’  and  supporting  Member  States,  cities,  and  regions  in  strengthening  local 
digital capacities and promoting data‑driven governance. In the last year of the  project (November 
2025  to  September  2026),  more  effort  has  been  dedicated  to  curating  existing  and  proven  digital 
solutions in line with the increasing demand from within the community, the European Commission, 
and other stakeholders for best practices and use cases that showcase how, in practice, technology is 
used in cities to improve the quality of life of the people who live there. 

The Local Digital Twin (LDT) CitiVERSE EDIC, legally established on 12 December 2024 in Valencia, is 
the  only  EDIC  accepting  cities,  regions  and  public  institutions  as  members.  It  sets  a  new  global 
benchmark for cooperative smart city development. It focuses on AI-based solutions to enhance and 
better  customise  urban  planning,  including  simulations  addressing  the  impact  of  changing  traffic 
conditions  on  air  quality,  decarbonisation,  and  congestion.  Additionally,  it  explores  generative  AI-
based  virtual  reality  applications  to  improve  citizen  interaction,  for  instance,  simplifying  the 
consultation and understanding of planned urban changes. 

The LDT CitiVERSE EDIC now involves 15 Member States (Belgium, Czechia, Germany, Estonia, Ireland, 
Spain,  France,  Croatia,  Italy,  Latvia,  Luxembourg,  Netherlands,  Portugal,  Slovenia  and  Slovakia) 
including  Germany,  which  joined  on  11 February  2026,  and  supports  cross-border  reuse  of  digital 
public services through common infrastructure and solutions implemented in regions and cities. 

SUMMARY ASSESSMENT: Limited progress 

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20.2  (a) Member States should anchor local digital strategies in the European Declaration 
on Digital Rights and Principles (DRP); (b) Member States should invite cities to adopt 
their own local Digital Rights and Principles Charters; 

In 2025 the European Union continued to strengthen structured cooperation between Member States 
and  subnational  authorities,  particularly  cities  and  regions.  Initiatives  such  as  the  Living-in.EU 
community have further expanded, facilitating alignment with EU digital principles and enabling peer 
learning across municipalities, although participation remains uneven across countries. 

Collaborative  platforms,  including  Eurocities-led  initiatives,  have  supported  experimentation  and 
scaling-up  of  digital  urban  solutions,  reinforcing  citizen-centric  service  delivery,  in  particular  at  the 
2025  Eurocities  Digital  Forum  –  Digital  rights  at  the  heart  of  cities,  which  gathered  city  leaders, 
policymakers, and experts to address the role of local administrations in safeguarding digital rights. At 
the same time, the network of European digital innovation hubs (EDIHs) has consolidated its role in 
supporting local digitalisation processes. The EDIH network has established itself as a significant driver 
for local digitalisation and AI uptake across both businesses and public administrations. While some 
hubs focus more strongly on SMEs and others on the public sector, in practice their work often bridges 
both. By early 2026 EDIHs had a presence in nearly 90% of European regions through more than 200 
hubs. They provide tailored support in areas such as test-before-invest, networking, access to finance, 
and skills development. This support is anchored locally, while the hubs are increasingly coordinating 
their efforts at national level and stepping up exchanges of good practices and mutual support across 
Europe. 

The LDT CitiVERSE EDIC significantly expanded its membership and operational scope in 2025, fostering 
the development of a European ecosystem for AI-enabled Local Digital Twins.  It contributes to the 
implementation of smart communities data spaces and supports interoperability and open standards 
fostering  collaboration  between  actors  to  develop  municipal  strategies  aimed  at  people-centred 
digitalisation,  while  enhancing  technological  sovereignty,  interoperability  and  the  use  of  digital 
technologies to promote sustainability and collective well-being. In this way, the LDT CitiVERSE EDIC 
acts as a catalyst for the territorialisation of the European Declaration on Digital Rights and Principles. 
Despite  these  advances,  the  uptake  of  EU-supported  frameworks  by  national  and  regional 
administrations  remains  limited,  constraining  their  overall  impact.  Progress  in  data  collection  and 
monitoring is also still fragmented. While tools such as the Local and Regional Digital Indicators (LORDI) 
framework  and  its  maturity  assessment  system  (LORDIMAS)  have  expanded  –  reaching  over  150 
participating  authorities  by  early  2025  –  data  coverage  remains  insufficient  for  comprehensive 
benchmarking. In this context, LORDIMAS serves as a practical tool to advance the implementation of 
the  European  Declaration  on  Digital  Rights  and  Principles  at  local  level,  by  helping  authorities  to 
identify gaps in areas such as inclusiveness, transparency, interoperability, and citizen participation, 
and supporting the alignment of digital strategies with a human-centric approach. 

Overall, cities continue to play a central role in operationalising the Declaration on Digital Rights and 
Principles beyond the national authorities. Local initiatives across Europe are increasing their efforts 
to  embed  inclusiveness,  transparency,  and  data  protection  in  digital  governance.  However, 
implementation gaps persist, and awareness of digital rights frameworks varies considerably between 
Member States. 

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SUMMARY ASSESSMENT: Notable progress 

20.3  Member  States  should  invest  in  local  digital  capacity  and  data-driven  governance: 
foster the development of local observatories (e.g. to monitor the digital divide) and 
encourage  participation  in  tools  to  improve  data  availability  and  inform  targeted 
policymaking. 

Although the European Commission and Member States are actively investing in local digital capacity 
to ensure that cities are co-creators of European data spaces, overall progress remains limited as these 
initiatives  are  still  largely  in  foundational  or  pilot  phases.  Current  efforts  are  heavily  focused  on 
developing  the  necessary  tools,  middleware,  and  standardisation  frameworks,  meaning  that 
widespread deployment and the targeted establishment of local observatories have not yet been fully 
realised. 

To build local capacity, the European Data Space for Smart Communities project is providing structured 
support, mentoring,  and  training  to  11  pilots  across 14 Member  States  (Austria,  Belgium, Bulgaria, 
Germany,  Ireland,  Spain,  Croatia,  Finland,  Italy,  Hungary,  Netherlands,  Portugal,  Romania  and 
Slovenia). These pilots, covering domains such as traffic management and climate, serve as practical 
testing grounds for cities to learn how interoperability and governance function in real urban contexts. 
Concurrently, the deployment of Simpl – an open-source, smart middleware platform – is addressing 
critical barriers related to data sovereignty, security, and cross-industry interoperability, establishing 
a common technical baseline for data-sharing initiatives. 

A major focus of current progress is the drive towards standardisation to improve data availability and 
reduce the high fragmentation of the smart city market. Through the LDT and MIM project, efforts are 
being  made  to  develop  European  standards  for  an  AI-based  Local  Digital  Twin  (LDT)  reference 
architecture. This aims to ensure that smart city solutions can be exchanged and reused across borders, 
catering to the distinct operational needs of large metropolitan hubs, medium-sized cities, and rural 
communities alike. 

Furthermore,  to  foster  true  data-driven  governance,  significant  collective  action  is  directed  at 
standardising  minimal  interoperability  mechanisms  (MIMs).  Current  initiatives  aim  to  formally 
standardise key specifications (MIMs 1, 2, and 7). This standardisation will eventually enable cities to 
procure interoperable components, scale up successful models, and avoid vendor lock-in, paving the 
way for more targeted policymaking and significant progress in the coming years. 

Overall, the Local Digital Twin (LDT) CitiVERSE EDIC – driven by the vision of ‘Networked Local Digital 
Twins towards the CitiVERSE’ – is meant to serve as the primary vehicle for utilising these standards 
and technologies. Currently involving 15 Member States, the initiative aims to connect existing Local 
Digital Twins to form a unified European ecosystem of data-driven collaboration. By fostering multi-
country  projects,  it  seeks  to  create  a  common  infrastructure  of  interoperable  data  platforms  and 
services with a special focus on  geodata, AI, and virtual worlds. This will enhance  capacity building 
through a shared set of practice-validated products and facilities. By ensuring scale, replicability, and 
portability on the basis of international open standards, the EDIC will soon offer its AI-based urban 
planning and citizen interaction solutions to members through a dedicated marketplace, ultimately 
strengthening local governance while securing European values and digital sovereignty. 

SUMMARY ASSESSMENT: Limited progress 

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Funding the Digital Decade 

21 Efficiency of budget 
21.1  (a)  Member  States  should  prioritise  strategic  digital  investment  in  their  national 
budgets, aligned with Digital Decade objectives, EU digital principles, and sovereignty 
imperatives,  including  taking  action  to  mobilise  private  investment.  (b)  Member 
States  should  pursue  reforms,  including  in  public  procurement,  to  facilitate  the 
emergence and scaling of sovereign digital technologies and infrastructure. 

Member  States  have  included  approximatively  1 933  measures  in  their  national  Digital  Decade 
strategic  road  maps,  including  national  and  EU-funded  measures  with  a  total  public  budget  of 
EUR 222.1  billion.  Several  of  these  measures  contribute  to  Digital  Decade  objectives,  EU  digital 
principles and sovereignty imperatives and cover actions such as developing secure infrastructure and 
capacities for cutting-edge technologies (e.g. AI, quantum technologies, semiconductors, 5G) as well 
as  fostering  digital  capabilities,  protection  and  empowerment.  However,  these  elements  are  often 
integrated as a complementary aspect.  The  number of measures  directly targeted and designed to 
address Digital Decade objectives, EU digital principles and sovereignty imperatives is smaller. 

SUMMARY ASSESSMENT: Limited progress 

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21.2  Member States should collaborate actively in the development of large-scale digital 
projects  with  transnational  relevance,  potentially  supported  by  new  common 
financing mechanisms or a dedicated Digital Sovereignty Fund 

Member States’ continued collaboration in the area of large-scale digital projects has resulted in two 
new European Digital Infrastructure Consortia (EDICs) being set up in the last quarter of 2025 and two 
more formal applications to set up EDICs submitted in the first quarter of 2026. This means that the 
EDIC  ecosystem  has  grown  from  three  established  EDICs  in  May  2025  to  five  established  EDICs  in 
Q1 2026, with the possibility of seven EDICs being established by Q2 or Q3 2026. 

More specifically, in addition to the existing Alliance for Language Technologies EDIC (ALT-EDIC), the 
Local Digital Twins towards the CitiVERSE EDIC  (LDT CitiVERSE EDIC) and the EDIC for the European 
Blockchain  Partnership  and  European  Blockchain  Services  Infrastructure  (EUROPEUM-EDIC),  the 
following EDICs were  set up:  the Digital Commons European Digital Infrastructure Consortium  (DC-
EDIC)  and  the  Innovative  Massive  Public  Administration  interConnected  Transformation  Services 
European Digital Infrastructure Consortium (IMPACTS-EDIC). 

The DC-EDIC aims to build a European community around digital commons by facilitating access to 
funding, supporting development and scale-up, enhancing public contributions, and participating in 
digital  commons  projects.  It  will  act  as  a  one-stop  shop  for  stakeholders  such  as  open-source 
communities,  public  administrations  and  developers,  serve  as  an  incubator  for  strategic  digital 
commons, and accelerate joint projects (e.g. a European digital workplace). Through collaborative and 
open governance models, the DC-EDIC also supports the development and scaling of reusable digital 
solutions  and  common  digital  infrastructures  that  can  strengthen  interoperability,  resilience  and 
cooperation across Member States. 

IMPACTS-EDIC  aims  to  accelerate  the  adoption  of  advanced  technologies,  supporting  the 
implementation  of  the  Interoperable  Europe  Act  (IEA).  With  the  goal  of  advancing  collaboration 
between Member States, European agencies, and institutions, IMPACTS-EDIC aims to enhance public 
services  through  innovative  interoperability  solutions.  It  will  facilitate  digitisation  of  cross-border 
public  services  by  promoting  shared  governance  models  and  technological  innovation,  such  as 
GovTech  and  the  European  Interoperability  Framework.  This  will  benefit  citizens,  businesses,  and 
economies by streamlining processes and reducing administrative burdens. 

In addition to the  new EDICs set  up, the overall number of Member States engaged in the existing 
EDICs also increased. To date, all EU Member States  have participated in at least one of the EDICs, 
either  as  members  or  as  observers.  The  geographical  coverage  is  already  improving,  and  further 
growth in terms of budget size, use case development, or involvement of industry is likely in the next 
stage.  

While  the  governance  structures  underpinning  several  EDICs  are  now  becoming  operational,  a  key 
challenge  will  be  translating  these  frameworks  into  sustainable  ecosystems  capable  of  delivering 
concrete  cross-border  projects,  attracting  stakeholders  and  ensuring  broader  uptake  at  national, 

71 

 
 
 
 
regional and local level. Further efforts will be required to strengthen coordination and scale reusable 
digital solutions across participating Member States. 

The Commission proposal for the draft European Competitiveness Fund regulation recognises EDICs as 
one of the implementation mechanisms for large-scale digital projects (multi-country projects). As a 
structural measure to facilitate cooperation with Member States in setting up EDICs (also responding 
to the Digital Decade Board’s plea for further support for EDICs in realising their full potential), the 
introduction of national contact points for EDICs at Member State level will be proposed as a general 
recommendation. 

SUMMARY ASSESSMENT: Notable progress 

72