The FSFE calls for Free Software as the model for digital public
services
In its feedback regarding the review of the European Interoperability
Framework, the FSFE is calling for Free Software and Open Standards to
be the default when procuring and creating interoperable digital public
services.

© European Union, 2026, licensed under CC BY 4.0
Digital public services are becoming an increasingly important
component of our daily lives, with around 85% of services available
digitally for both businesses and citizens according to data from
the European Commission. Transparency and control over these
processes have become more important than ever for citizens and public
administrations alike. The European Interoperability Framework (EIF) has
been setting the guidelines for providing digital services since its
creation. Under the Interoperable
Europe Act, the EIF’s role has been strengthened. It needs to be
taken into account when introducing new digital public services,
substantially updating existing ones, and when developing new
regulations and guidance.
The status quo and next steps
For the EIF currently in force, the Free Software Foundation Europe's
contributions helped establish a model of "active and fair
consideration" of Free Software solutions and the recommendation to
contribute changes upstream whenever possible, contributing to level the
playing field for Free Software solutions. Nevertheless, shortcomings
such as deeming so-called "fair,
reasonable, and non-discriminatory" (F/RAND) terms an
appropriate licensing model, negatively impact the creation and
deployment of Free Software solutions.
Nine years later, a revision of the current EIF is underway. Members
of the Interoperable Europe Board and respondents to the call for
evidence have raised concerns regarding control over public
administrations' services and data and gaps between guidance and
concrete implementation.
“Today, public administrations are more concerned than ever about
their digital autonomy – as we saw recently in the European Commission’s
Tech Sovereignty Package. Free Software and Open Standards are
prerequisites for technological sovereignty and need to be in the
spotlight of the upcoming EIF. The involvement of civil society actors
in the process and secure long-term funding for the Free Software
ecosystem are key for the success of the Interoperable Europe Act and
digital public services.” – explains Sofía Aritz, Policy Consultant.
In
its position, the FSFE addresses these problems by calling for,
among other measures:
- Shifting to a "Free Software by default" model:
Free Software is a prerequisite for technological sovereignty due to the
controllability and transparency that it provides, while also playing a
fundamental role in reusability and cross-border collaboration. Free
Software needs to become the default model for creating, implementing,
and customising digital public services, in accordance with the
principles of "Public Money? Public Code!"
- Requiring Open Standards in digital public
services: Open Standards that are implementable in Free
Software are crucial to the development of a thriving market for
interoperable digital public services.
- Developing guidance for Free Software procurement:
Creating and promoting guidelines and training tailored to procurement
professionals on Free Software procurement and the detection of
openwashing.
Free Software and the Interoperable Europe Act
The European Interoperability Framework provides recommendations for
legal, organisational, semantic and technical interoperability, first
created in 2004. Since the adoption
of the Interoperable Europe Act, it is going to be developed by the
Interoperable Europe Board. This new legislative framework and new
digital challenges have raised the need of reviewing the current EIF,
which was last updated in 2017.

The revised EIF Conceptual Model. Infographic from the European Commission
The FSFE considers that the Interoperable Europe Board should seize
this opportunity and use the EIF as a practical reference for the rest
of Interoperable Europe instruments. The FSFE is calling for the
inclusion of additional criteria to existing guidelines and the
"Interoperable Europe solution" label. Such criteria needs to take into
account whether proposed solutions are Free Software, make use of Open
Standards, implement them adequately, and follow a collaboration-first
model.
The FSFE has called for the development of legal and financial
instruments that secure long-term funding for Free Software solutions
while reducing fragmentation between existing Union funding programmes,
European Digital Infrastructure Consortia (EDICs), and other
cross-border initiatives.
The inclusion of civil society into the wider Interoperable Europe
governance, especially the Interoperable Europe Board and the
"Interoperable Europe solution" process, remains fundamental to the
implementation of the Interoperable Europe Act and the fostering of a
market of interoperability solutions. The FSFE will closely follow the
next steps towards the new EIF, sharing upcoming developments with our
community.
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