Interoperability assessments: a plain-English checklist for smaller public bodies

Since 12 January 2025, public sector bodies in EU Member States have had a new duty under the Interoperable Europe Act, Regulation (EU) 2024/903. Before deciding on new or substantially modified binding requirements for a trans-European digital public service, they must assess the effects on cross-border interoperability.¹ Large ministries have specialists for this. A regional agency or a municipality may not.

This checklist is a practical way through it. It isn’t legal advice; the official text and your national contact point have the final word. The guide to the Interoperable Europe Act covers the rest of the law.

Step 1: Check whether an assessment is needed

Three questions decide it, using the Act’s own definitions:¹

1. Is it a trans-European digital public service? That means a digital service public bodies provide to each other or to people and businesses in the EU that requires interaction across Member State borders through their network and information systems. A service that only ever runs inside one country is not in scope.
2. Are you setting a binding requirement? The Act means an obligation, prohibition, condition, criterion or limit of a legal, organisational, semantic or technical nature that affects cross-border interoperability. A rule in a regulation, a specification in a tender or a mandatory data format can all qualify.
3. Is it new or substantially modified? Unchanged requirements don’t trigger a fresh assessment.

There are also exemptions. No further assessment is needed where one has already been carried out for the same requirements, or where they are implemented through solutions provided by EU entities.¹

Step 2: Identify who is affected

The assessment must identify the stakeholders concerned and consult those directly affected by the service, including citizens or their representatives.¹ For a small body, a short list is usually enough: the other administrations that exchange data with the service, the people or businesses who use it from other countries, and any supplier whose system must change.

Step 3: Work through the layers

The Act asks for the European Interoperability Framework to be used as a support tool.¹ A simple way to apply it is to ask one question per layer:

• Legal: does the requirement create a rule that conflicts with how other countries handle the same data or procedure?
• Organisational: does it change who does what, or how long another body has to respond?
• Semantic: does it introduce a definition, code list or data format that other systems must understand? This is where most surprises hide; see semantic interoperability.
• Technical: does it require a particular interface, protocol or product that others would have to adopt?

Alongside that, the Act asks bodies to identify any existing Interoperable Europe solutions that could help.¹ Reusing a labelled solution is often both cheaper and the easiest way to show the requirement supports interoperability.

Step 4: Write it up and publish

An annex to the Act sets out a common checklist for the report, and the Commission provides an online tool on the Interoperable Europe portal to complete and publish it.¹ The report must be published in a machine-readable format on an official website and shared with the Interoperable Europe Board.¹

The Board adopted guidelines for interoperability assessments at its first meeting on 5 December 2024.² They are the best place to check what a proportionate report looks like.

Step 5: Keep it proportionate

The Act itself expects assessments to be proportionate. Its recitals say a single project in a local authority should be able to take a pragmatic, narrow focus, and that the Board’s guidelines should take account of the capacity of regional and local bodies and avoid excessive administrative burden.¹ A short, honest assessment of one tender is more useful than a long one nobody reads.

Who to ask

Each Member State has designated competent authorities and a single point of contact for the Act.¹ If you are unsure whether a decision is in scope, that contact is the first call.

Early figures suggest many bodies are still finding their feet. The Commission’s first annual report on interoperability records that it completed 32 assessments of its own in 2025, while Member States had submitted two reports since assessments became mandatory.³ If you are doing one now, you are early, and the experience will be worth sharing with peers.