Source: EURLEX
Language: en
Format: md

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| 7.3.2019 | EN | Official Journal of the European Union | C 86/272 |

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Opinion of the European Committee of the Regions on the ‘Digital Europe programme (2021-2027)’

(2019/C 86/14)

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| |  |  | | --- | --- | | Rapporteur: | Markku MARKKULA (FI/EPP), Member of the Espoo City Council | | Reference documents: | Proposal for a Regulation of the European Parliament and of the Council establishing the Digital Europe programme for the period 2021-2027  COM(2018) 434 final  Commission Staff Working Document Executive Summary of the Impact Assessment accompanying the document Proposal for a Regulation of the European Parliament and of the Council establishing the Digital Europe programme  SWD(2018) 306 final  Commission Staff Working Document Impact Assessment accompanying the document Proposal for a Regulation of the European Parliament and of the Council establishing the Digital Europe programme for the period 2021-2027  SWD(2018) 305 final | |

I.   RECOMMENDATIONS FOR AMENDMENTS

Amendment 1

Article 2 — point (e)

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| Text proposed by the Commission | CoR amendment |
| |  |  | | --- | --- | | (e) | ‘Digital Innovation Hub’ means legal entity designated or selected in an open and competitive procedure in order to fulfil the tasks under the Programme, in particular providing access to technological expertise and experimentation facilities, such as equipment and software tools to enable the digital transformation of the industry. | | |  |  | | --- | --- | | (e) | ‘Digital Innovation Hub’ means legal entity  or a consortium of legal entities  designated or selected in an open and competitive procedure in order to fulfil the tasks under the Programme, in particular providing access to technological expertise and experimentation facilities, such as equipment and software tools to enable the digital transformation of the industry. | |

Reason

When establishing the network of Digital Innovation Hubs, it is important to have sufficient coverage for all regions; the target is to have a DIH in every region. Providing the possibility of a consortium running the DIH would strengthen the base of the network by involving several stakeholders, such as universities, research centres, innovation centres, etc.

The evaluation procedure should ensure that the network remains both regionally and thematically well-balanced, while being able to deliver high-quality services. The selection procedure for the candidate entities should be conducted from the point of view of the whole network so that effective synergies between the DIHs can be created. This is another good reason to provide the opportunity for a consortium of legal entities to run a DIH.

The legal entity requirement imposes unnecessary constraints, which is why more flexibility needs to be given to practical arrangements. To stress lean structures, coordination could also be assigned to a legal entity in a consortium or a network of legal entities.

Amendment 2

Article 3 — paragraph 1

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| Text proposed by the Commission | CoR amendment |
| The Programme has the following general objective: to support the digital transformation of the European economy and society and bring its benefits to European citizens and businesses. The Programme will: | The Programme has the following general objective: to support the digital transformation of the European economy and society  at local, regional, national and European level  and bring its benefits to European citizens and businesses. The Programme will: |
| |  |  | | --- | --- | | (a) | reinforce Europe’s capacities in key digital technology areas through large-scale deployment, | | |  |  | | --- | --- | | (a) | reinforce Europe’s capacities in key digital technology areas through large-scale deployment, | |
| |  |  | | --- | --- | | (b) | widen their diffusion and uptake in areas of public interest and the private sector. | | |  |  | | --- | --- | | (b) | widen their diffusion and uptake in areas of public interest and the private sector, | |
|  | |  |  | | --- | --- | | (c) | speed up digital transformation by increasing local collaboration and European partnerships. | |

Reason

Based on the subsidiarity principle the DEP needs to cover multi-level governance. The outcomes of the DEP can be reached by effective implementation at the level of cities and regions, with close collaboration between universities, other educational establishments and research institutions as well as with local industries. Multi-level governance is important in order to close the European innovation divide. As an example, EU wide high performance computing ecosystems may be scaled with the help of the DEP to cover all scientific and industrial value chain segments.

Amendment 3

Article 5 — point (d) new and (e) new

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| Text proposed by the Commission | CoR amendment |
| Artificial Intelligence | Artificial Intelligence |
| The financial intervention by the Union under Specific Objective 2. Artificial Intelligence shall pursue the following operational objectives: | The financial intervention by the Union under Specific Objective 2. Artificial Intelligence shall pursue the following operational objectives:   |  |  | | --- | --- | | (d) | improve the quality and amount of data to support and speed up the digital transformation creating a digital platform economy; |  |  |  | | --- | --- | | (e) | scale up the use of technologies, develop innovative business models, increase awareness of users and shorten the time from innovation to market; | |

Reason

The transformation to the platform economy is an outcome of digitalisation. We need to create favourable conditions for tackling this and other major societal challenges. The changing role of cities, citizens and of the business world needs to be taken into account.

In this development, the necessary quality and amount of data is essential. Firstly, we need to provide the right metrics to measure data quality. Secondly, algorithms can be developed to assess data quality, detect data outliers not to be used in the analysis and correct information with a view to getting more robust responses from algorithms. Thirdly, data quality can be improved by measures to enhance the completeness, comparability and the timelines of data flows to be used in AI-based digital services at national and subnational government level.

These measures are not explicitly mentioned in the DEP, although a reference to data integrity and data confidentiality is contained in the text and there are references to the general role of software and algorithms libraries.

Data quality and integrity must also be complemented by measures to preserve the integrity of individuals’ rights to their information and to ensure quality in terms of the ability to maintain an adequate level of security for information and personal data.

Amendment 4

Article 7

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| Text proposed by the Commission | CoR amendment |
| The financial intervention by the Union under Specific Objective 4. Advanced Digital skills shall support the development of advanced digital skills in areas supported by this programme, thus contributing to increase Europe’s talent pool, fostering greater professionalism, especially with regard to high performance computing, big data analytics, cybersecurity, distributed ledger technologies, robotics and artificial intelligence. The financial intervention shall pursue the following operational objectives: | The financial intervention by the Union under Specific Objective 4. Advanced Digital skills shall support the development of advanced digital skills in areas supported by this programme  and in a gender responsive manner , thus contributing to increase Europe’s talent pool, fostering greater professionalism, especially with regard to high performance computing, big data analytics, cybersecurity, distributed ledger technologies, robotics and artificial intelligence. The financial intervention shall pursue the following operational objectives: |
| |  |  | | --- | --- | | (a) | support the design and delivery of long-term trainings and courses for students, IT professionals and the workforce; | | |  |  | | --- | --- | | (a) | support the design and delivery of long-term trainings and courses for students, IT professionals and the workforce; | |
| |  |  | | --- | --- | | (b) | support the design and delivery of short-term trainings and courses for entrepreneurs, small business leaders and the workforce; | | |  |  | | --- | --- | | (b) | support the design and delivery of short-term trainings and courses for entrepreneurs, small business leaders and the workforce; | |
| |  |  | | --- | --- | | (c) | support on-the-job trainings and traineeships for students, young entrepreneurs and graduates. | | |  |  | | --- | --- | | (c) | support on-the-job trainings and traineeships for students, young entrepreneurs and graduates. | |

Reason

It is important to ensure that the digital skills formation system of tomorrow also takes into account the gender perspective, ensuring an inclusive digital society of tomorrow.

Amendment 5

Article 8 — paragraph 1 — points (a), (g) and (j) new

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| Text proposed by the Commission | CoR amendment |
| Deployment, best use of digital capacities and Interoperability | Deployment, best use of digital capacities and Interoperability |
| The financial intervention by the Union under Specific Objective 5. Deployment, best use of digital capacities and Interoperability shall achieve the following operational objectives: | The financial intervention by the Union under Specific Objective 5. Deployment, best use of digital capacities and Interoperability shall achieve the following operational objectives: |
| |  |  | | --- | --- | | (a) | ensure that the public sector and areas of public interests, such as health and care, education, judiciary, transport, energy, environment, cultural and creative sectors, can deploy and access state-of-the-art digital technologies, in particular high performance computing, artificial intelligence and cybersecurity; | | |  |  | | --- | --- | | (a) | ensure that the public sector and areas of public interests, such as health and care, education, judiciary,  urban planning,  transport, energy,  natural resources, forestry, food,  environment, cultural and creative sectors, can deploy and access state-of-the-art digital technologies, in particular high performance computing, artificial intelligence,  information security  and cybersecurity; | |
| |  |  | | --- | --- | | (g) | ensure a continuous capacity  at Union level  to observe, analyse and adapt to fast-evolving digital trends, as well as  sharing and mainstreaming best practices; | | |  |  | | --- | --- | | (g) | ensure a continuous capacity  at regional, national and European level  to observe, analyse and adapt to fast-evolving digital trends, as well as  co-creating new digitalised solutions, sharing best practices and mainstreaming the bench-learning culture; | |
|  | |  |  | | --- | --- | | (j) | integrate the deployment activities of the Digital Europe programme to regional smart specialisation strategies, Horizon Europe and other major European initiatives and partnerships. | |

Reason

Urban planning, forestry and food need to be included in the list under point (a), since they are important for all societal development. Smart and sustainable digital solutions in the fields of sustainable management of urban development, natural resources, food production and forestry play a strategic role in tackling various environmental challenges related to climate change.

As the CoR has stated in its current term 2015-2020 priorities, a bottom-up approach, entrepreneurial mindset and targeted investments are needed in implementing the fully-functioning Digital Single Market.

Amendment 6

Article 13 — paragraph 3 (new)

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| Text proposed by the Commission | CoR amendment |
| Synergies with other Union programmes | Synergies with other Union programmes |
|  | 3.     The programme will support the regional and European collaboration and partnerships to scale up innovative digital solutions and ensure synergies with regional strategies. |

Reason

The CoR points out that the impact assessment makes numerous references to EU policies and programmes such as the ERDF, ESF+, CEF etc. that are essential for reaching the DEP aims and objectives. The synergic use of EU instruments and local/regional mechanisms and funding is heavily stressed in the EU policy. However, there are no clear procedures and mechanisms in place in this DEP to address how to arrange the interplay between these instruments at all levels of government. There is no reference to partnership or MLG provisions. Thus, the important role of regions needs to be included in this article. The EU Commission in its policy highlights the crucial role of regional smart specialisation strategies as a natural instrument for increasing regional level collaboration and European partnerships. This needs to be supported by the DEP.

Amendment 7

Article 16 — paragraphs 1, 2, 3 and 4

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| Text proposed by the Commission | CoR amendment |
| Digital Innovation Hubs | European Digital Innovation Hubs |
| 1.   During the first year of the implementation of the Programme, an initial network of Digital Innovation Hubs shall be established. | 1.   During the first year of the implementation of the Programme, an initial network of  European  Digital Innovation Hubs shall be established.  The Hubs in this network have a strong regional role to increase European collaboration. |
| 2.   For the purpose of the establishment of the network mentioned in paragraph 1, each Member State shall designate candidate entities through an open and competitive process, on the basis of the following criteria: | 2.   For the purpose of the establishment of the network mentioned in paragraph 1, each Member State shall designate candidate entities through an open and competitive process, on the basis of the following criteria: |
| |  |  | | --- | --- | | (a) | appropriate competences related to the functions of the Digital Innovation Hubs; | | |  |  | | --- | --- | | (a) | appropriate competences related to the functions of the Digital Innovation Hubs,  including capacity and competences with respect to R & D, infrastructure, data protection, security and innovation; | |
| |  |  | | --- | --- | | (b) | appropriate management capacity, staff and infrastructure; | | |  |  | | --- | --- | | (b) | appropriate management capacity, staff and infrastructure; | |
| |  |  | | --- | --- | | (c) | operational and legal means to apply the administrative, contractual and financial management rules laid down at Union level; | | |  |  | | --- | --- | | (c) | operational and legal means to apply the administrative, contractual and financial management rules laid down at Union level; | |
| |  |  | | --- | --- | | (d) | appropriate financial guarantees, issued preferably by a public authority, corresponding to the level of Union funds it will be called upon to manage. | | |  |  | | --- | --- | | (d) | appropriate financial guarantees, issued preferably by a public authority, corresponding to the level of Union funds it will be called upon to manage; | |
|  | |  |  | | --- | --- | | (e) | alignment with regional strategies. | |
| 3.   The Commission shall adopt a decision on the selection of entities forming the initial network. These entities shall be selected by the Commission from candidate entities designated by Member States on the basis of the criteria mentioned in paragraph 2 and the following additional criteria: | 3.   The Commission shall adopt a decision on the selection of entities forming the initial network. These entities shall be selected by the Commission from candidate entities designated by Member States on the basis of the criteria mentioned in paragraph 2 and the following additional criteria: |
| |  |  | | --- | --- | | (a) | the budget available for the financing of the initial network; | | |  |  | | --- | --- | | (a) | the budget available for the financing of the initial network; | |
| |  |  | | --- | --- | | (b) | the need to ensure by the initial network a coverage of the needs of industry and areas of public interest and a comprehensive and balanced geographical coverage. | | |  |  | | --- | --- | | (b) | the need to ensure by the initial network a coverage of the needs of industry and areas of public interest and a comprehensive and balanced geographical coverage  throughout the EU and Member States. | |
| 4.   Additional Digital Innovation Hubs shall be selected on the basis of an open and competitive process, in such a way to ensure the widest geographical coverage across Europe. The number of entities of the network shall be proportional to the population of a given Member States and there shall be at least one Digital Innovation Hub per Member State. To address the specific constraints faced by the EU outermost regions, specific entities may be nominated to cover their needs. | 4.   Additional Digital Innovation Hubs shall be selected on the basis of an open and competitive process, in such a way to ensure the widest geographical coverage across  regions in  Europe. The number of entities of the network shall be proportional to the population of a given Member States and there shall be at least one Digital Innovation Hub per Member State. To address the specific constraints faced by the EU  sparsely populated and  outermost regions, specific entities may be nominated to cover their needs. |

Reason

In terms of speeding up the digital transformation, DIHs not only develop but also deliver and help to deploy innovative technologies in public administration and private industries, as well as supporting the changing role of cities and regions. In addition to providing access to these solutions, DIHs could help to build adequate capacity for the different actor groups to implement innovative technology solutions in their digital platforms and support the design of specific digital service infrastructure making use of data analytics services. For these reasons, the strong European nature of DIHs needs to highlighted and these Hubs should be named European Digital Hubs.

Capacity and competences in validating technologies and the use of latest R & D knowledge are essential criteria for selecting the best candidate entities.

The impact assessment clearly states that the DIHs shall have a strong regional dimension (particularly for SMEs). However, this is not reflected in the legislative proposal. The success of DIHs should be built on effective regional collaboration, based on regional strategies such as RIS3.

When establishing the network of DIHs, it is important to have sufficient coverage for all regions; the target is to have a DIH in every region.

The evaluation procedure should ensure that the network remains both regionally and thematically well-balanced, while being able to deliver high-quality services. The selection procedure for candidate entities should be conducted from the point of view of the whole network so that effective synergies between the DIHs can be created.

Amendment 8

Article 20 — paragraph 1 — points (d) and (e) new

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| Text proposed by the Commission | CoR amendment |
| Award criteria | Award criteria |
| The award criteria shall be defined in the work programmes and in the calls for proposals, taking into account at the minimum the following elements: | The award criteria shall be defined in the work programmes and in the calls for proposals, taking into account at the minimum the following elements: |
| |  |  | | --- | --- | | (a) | the maturity of the action in the project development; | | |  |  | | --- | --- | | (a) | the maturity of the action in the project development; | |
| |  |  | | --- | --- | | (b) | the soundness of the implementation plan proposed; | | |  |  | | --- | --- | | (b) | the soundness of the implementation plan proposed; | |
| |  |  | | --- | --- | | (c) | the stimulating effect of Union support on public and private investment, when applicable; | | |  |  | | --- | --- | | (c) | the stimulating effect of Union support on public and private investment, when applicable; | |
| |  |  | | --- | --- | | (d) | the need to overcome financial obstacles such as the lack of market finance; | | |  |  | | --- | --- | | (d) | synergic use of different financing instruments and  the need to overcome financial obstacles such as the lack of market finance; | |
| |  |  | | --- | --- | | (e) | where applicable, the economic, social, climate and environmental impact, and accessibility; | | |  |  | | --- | --- | | (e) | where applicable, integration of the project with regional strategies; | |
| |  |  | | --- | --- | | (f) | where applicable, a trans-European dimension; | | |  |  | | --- | --- | | (f) | where applicable, the economic, social, climate and environmental impact, and accessibility; | |
| |  |  | | --- | --- | | (g) | where applicable, a balanced geographical distribution across the Union, including the outermost regions; | | |  |  | | --- | --- | | (g) | where applicable, a trans-European dimension; | |
| |  |  | | --- | --- | | (h) | where applicable, the presence of a long-term sustainability plan. | | |  |  | | --- | --- | | (h) | where applicable, a balanced geographical distribution across the Union, including the outermost regions; | |
|  | |  |  | | --- | --- | | (i) | where applicable, the presence of a long-term sustainability plan. | |

Reason

The CoR highlights that 70 % of EU legislation is implemented at local and regional level and emphasises the synergies between different EU programmes, financial instruments and regional strategies. Regional Smart Specialisation Strategies have proved to be useful and important instruments for economic transformation and for the sharing of best practices through European partnerships.

II.   POLICY RECOMMENDATIONS

THE EUROPEAN COMMITTEE OF THE REGIONS

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|  | 1. | welcomes the European Commission’s legislative proposal for the new Digital Europe programme (DEP). This is the first time that the Commission has proposed a package integrating digitalisation, research and innovation into all major EU programmes and into European wide societal development. The key role of local and regional authorities in implementing the DEP should be considered in all measures to speed up the development of the Digital Single Market (DSM); |

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|  | 2. | points out the crucial role of people, businesses and skills in maximising the benefits to be gained from the DSM. In relation to the implementation of the DEP, the CoR stresses that completion of the EU DSM also needs a clear and stable legal environment and favourable conditions to stimulate innovation, tackle market fragmentation and allow all players to tap into the new market dynamics; |

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|  | 3. | stresses the crucial role of the DEP, becoming a robust investment and development programme to capitalise the opportunities needed and created to achieve a fully-functioning DSM. The key question is how to make the DEP to be so attractive that cities and regions — with their industries, universities and citizens — speed up the European wide digital and economic transformation by considerably increasing public and private investment in human and physical capital; |

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|  | 4. | highlights the importance of removing regulatory barriers, cutting red-tape and modernizing EU regulation, which are key factors in ensuring a highly competitive European industry, coupled with the need to improve the readiness of the public and private sectors to execute digital innovations; |

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|  | 5. | welcomes DEP investments in advanced high-capacity digital infrastructure such as 5G networks, which are necessary to enable the deployment of digital services and technologies everywhere in Europe. Broadband has an instrumental role in developing innovative and competitive digital services, for which reason the CoR calls for a quick 5G standardisation to ensure the interoperability of telecommunication networks; |

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|  | 6. | stresses the pivotal role of cities and regions in providing digital services for citizens, as well as in creating and managing digital infrastructure such as data generation. Digital services offer opportunities for societal innovation, entrepreneurship and job and business creation; |

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|  | 7. | requests that the DEP reflect and ensure the digitalisation of public administrations and services in order to enable cities to tackle societal needs. This requires EU-wide interoperability and access to data, technology and know-how; |

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|  | 8. | emphasises the importance of the quality and amount of data, which is essential for reaching the DEP targets. Previous CoR opinions have stressed the role of cities and regions in data harmonisation, collection, quality, access and use, as well as in ensuring a secure and interoperable digital infrastructure for cross-border data flows in the digital economy; |

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|  | 9. | stresses the importance of artificial intelligence (AI) as a promising technology to be applied for sustainable growth and societal challenges. AI therefore has to be strengthened, ensuring the quality of data and securing personal privacy, while still allowing anonymous data mining, machine-based learning and the foundation for pattern recognition; |

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|  | 10. | recognises that AI libraries with data provide key input for the design of intelligent public services. However, data of poor quality may affect the expected impact and effectiveness of services, thereby lowering the potential benefit of AI. High-quality data is essential to enable public administrations to design, implement and monitor the impact of the policies they adopt, on the basis of empirical evidence and making use of data analytics capabilities. This would strengthen the transparency and accountability of public action and help enhance policy effectiveness. Data will have a huge influence in creating a culture of knowledge, in which evidence becomes the foundation of a smarter and citizen-centric administration and policy-making process; |

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|  | 11. | calls for the proper integration of several ongoing data economy and data driven society measures into the DEP. These have been dealt with under the Digital Single Market in the various data packages: on Building the European Data Economy (COM(2017/9), the Framework for the free flow of non-personal data in the European Union (2017/0228) and, this year, with the 3rd Data Package. The latter includes a Communication ‘Towards a common European data space’ which addresses the issue of access to private sector data for public interest purposes (with a list of key principles on business-to-government or ‘B2G’ data sharing) and includes a guidance document on sharing private sector data. In parallel, the Commission has adopted a proposal for a recast of the Directive on the re-use of public sector information (PSI directive); |

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|  | 12. | highlights the results of the Commission stakeholder dialogue on the Communication on Building a European Data Economy, especially finding strong support for non-regulatory measures to maximise and organise access to and the reuse of data in B2B contexts. As an example on the digital transformation of healthcare, a public consultation investigated the need for policy measures promoting digital innovation to improve the quality of healthcare throughout Europe (a need that has received particular attention from the CoR); |

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|  | 13. | calls for the use of Joint Undertakings, EIT KICs and other EU initiatives, as well as European Partnerships between regions, as mechanisms to implement the DEP. Smart and sustainable digital solutions play a key role in achieving local and regional level targets on sustainable development and in tackling major societal challenges like climate change. The solutions require high-quality HPC computing, AI-based solutions and cyber security. Cities and regions should be encouraged to become forerunners in participating in the DEP, especially as a spatial testing ground for new applications. As an example, digitalisation has a growing importance in urban planning, especially through regional information modelling; |

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|  | 14. | notes that the full benefits from investing in digital technologies and platforms need to be scaled up to European level. Investing in talented professionals is a necessary prerequisite, even though it is not sufficient on its own. Citizens need to be trained and equipped with digital proper skills. Special measures are needed on retraining of professionals to apply their specific competences to new digitalised tasks. In European education systems, providing young learners with advanced digital skills is an obligatory investment to safeguard the quality of the future workforce for Europe. The growing importance of STEAM (science, technology, engineering, arts, mathematics) education is evident. The implementation of the DEP needs to be operationalised in synergy with Digital Education Action Plan; |

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|  | 15. | stresses the importance of the transformation to a digital platform economy by ensuring that the provision of public and private services is user-centric, digital and interoperable by design, and compliant with the once-only principle with regard to national, regional and local governments; |

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|  | 16. | recognises that government digital platforms are not explicitly mentioned in the DEP legal text. However, the concept of these platforms is linked to Objective 5 of the programme, related to the interoperability and implementation of digital technologies by government and the private sector. This is also spelled out more in Annex 2 with respect to activities linked to the interoperability of public administration services, the application of the once-only principle and digital service infrastructure; |

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|  | 17. | calls for building digital platforms by creating generic reusable solutions in digital authentication, trust and secure services. These are combined with advanced reusable solutions based on data-driven methods powered by artificial intelligence. This will help to ensure that public services are interconnected across policy domains and levels of government. It also helps government services to be smarter, tailored to the specific needs of users and available on web and mobile platforms; |

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|  | 18. | recommends that the cross-border use of digital technologies be combined with removing legal and other obstacles to this cooperation, here the CoR refers to Article 8 on ‘Deployment, best use of digital capacities and Interoperability’; |

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|  | 19. | emphasises the importance of establishing the network of DIHs with sufficient coverage for all regions. While the impact assessment clearly states that the DIHs shall have a strong regional dimension (particularly for SMEs), this is not reflected in the legislative proposal. The selection of DIHs should be an open and reliable process, which includes not only one DIH, but a network of DIHs in each Member State, if relevant. DIHs should be selected nationally and in a regionally and thematically balanced way. The network of DIHs should have close links to other networks such as EIT Digital and Enterprise Europe Network; |

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|  | 20. | highlights the importance of artificial intelligence, and the links to extended Reality (XR), VR, AR, 3D technologies and robotics, which will form a new basis for global business, the platform economy and learning platforms. This helps to deliver equal access to various educational and cultural content and to create innovative knowledge transfer platforms for the retraining of workers. Furthermore, it will support sustainable development, since it significantly reduces the need for physical goods, travel and carbon emissions; |

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|  | 21. | stresses the importance and the role of security in the digital domain and highlights the role of cities and regions in tackling cybercrime and protecting data security; |

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|  | 22. | welcomes provisions on third countries associated to the programme, especially in embedding digitalisation in activities to reaching the targets of the United Nations’ Sustainable Development Goals (UN SDGs). This means emphasising the added-value through collaboration mentality and openness in innovation and deployment. In focusing sustainable growth, the specific nature of ICT revolution allows the EU to achieve a strong global role on technology knowhow for prosperity; |

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|  | 23. | acknowledges that the Commission’s proposal complies with the principles of subsidiarity and proportionality. |

Brussels, 5 December 2018.

The President of the European Committee of the Regions

Karl-Heinz LAMBERTZ

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