The Interoperable Europe Act

The Interoperable Europe Act, Regulation (EU) 2024/903, sets common EU rules for making public administrations' digital services work together across borders. It applies to EU institutions, bodies and agencies and to public sector bodies in the Member States that regulate, provide, manage or implement trans-European digital public services, and it creates shared governance, mandatory interoperability assessments and ways to share and test solutions.¹ Before it, public sector interoperability was not covered by any binding, overarching EU rules; the main reference was the voluntary European Interoperability Framework (EIF).²

Why it was proposed

The Commission proposed the Act on 18 November 2022. Its explanatory memorandum argued that while more public services were going digital, their interoperability was still insufficient, leaving citizens and businesses with unnecessary administrative burden and administrations with extra costs.² The first recital of the final text is blunter: the existing informal cooperation should be replaced by a clear legal framework.¹

An evaluation of the EIF, published with the proposal, found that the framework did not sufficiently support practical implementation. The Commission weighed three options: developing the EIF further, setting up a structured cooperation mechanism in law, or writing directly applicable minimum interoperability requirements into law. It chose the middle option, judging that legal minimum requirements would be slow, costly to implement and less likely to win political support, given their reach into existing national and EU systems, while noting that its choice could gradually lead there over time.²

What it covers and how it builds on the EIF

The Act leaves Member States the power to decide what counts as a public service. Within that limit, it turns on a few defined terms:¹

• Trans-European digital public services: digital services that EU entities or public sector bodies provide to each other or to people and businesses in the EU, and that require interaction across Member State borders, among EU entities or between EU entities and public sector bodies, through their network and information systems.
• Binding requirement: an obligation, prohibition, condition, criterion or limit of a legal, organisational, semantic or technical nature, set for one or more of those services, that affects cross-border interoperability.
• Interoperability solution: a reusable asset such as a framework, guideline, reference architecture, specification, standard, application or documented source code.

The EIF sits at the centre. The new Interoperable Europe Board develops it, the Commission adopts and publishes it, interoperability assessments use it as a support tool, and national interoperability frameworks must take it into utmost account.¹ The guide to the EIF explains the framework itself.

Interoperability assessments

The Act's main obligation is the interoperability assessment. Before deciding on new or substantially modified binding requirements, an EU entity or public sector body must assess their effects on cross-border interoperability, using the EIF as a support tool, and identify the stakeholders concerned and any Interoperable Europe solutions that could help.¹ It must consult those directly affected by the service, including citizens or their representatives, and publish a machine-readable report on an official website, sharing it with the Board.¹

An annex sets out a common checklist for the report, and the Commission provides an online tool to complete and publish it on the Interoperable Europe portal. No further assessment is needed where one has already been done for the same requirements, or where they are implemented through solutions provided by EU entities.¹ The Board adopted its assessment guidelines at its first meeting on 5 December 2024, ahead of the obligation applying from 12 January 2025.⁵

The Board, the portal and shared solutions

The Interoperable Europe Board has one representative from each Member State and one from the Commission, which chairs it. The Committee of the Regions, the EU Agency for Cybersecurity (ENISA) and the European Cybersecurity Competence Centre each designate an expert as an observer.¹ The Board's tasks include developing the EIF, recommending solutions for the "Interoperable Europe solution" label and adopting a yearly Interoperable Europe Agenda of priorities.¹ It adopted the first Agenda on 4 December 2025 and, at the same meeting, approved the first labelled solutions: the Core Vocabularies, covered in ontologies and core vocabularies, and DCAT-AP, the European application profile of the Data Catalog Vocabulary (DCAT).⁴

The Interoperable Europe portal is the single, free point of entry for information on cross-border interoperability, including labelled and other solutions. On request, a public body must share a solution that supports a trans-European digital public service with another public body, with its documentation and, where applicable, its source code, subject to exceptions such as third-party intellectual property rights and security.¹ When choosing solutions, bodies must prioritise those without restrictive licensing terms, such as open source, where they are otherwise equivalent. Each Member State designates competent authorities and a single point of contact, and EU entities designate interoperability coordinators.¹

Regulatory sandboxes, GovTech and support

Interoperability regulatory sandboxes are controlled environments where public bodies can develop, train, test and validate innovative solutions, in real-world conditions where appropriate, for a limited period under regulatory supervision.¹ The Commission authorises a sandbox on a joint request from at least three participants, after consulting the Board; data protection authorities supervise any processing of personal data; and participation lasts no more than two years, with a possible extension of up to one year.¹ The Act set 12 April 2025 for the Commission's detailed rules. They were adopted in July 2025 as Implementing Regulation (EU) 2025/1420 and entered into force on 7 August 2025.³⁴

The Act defines GovTech as technology-based cooperation between public and private sector actors supporting public sector digital transformation, and GovTech actors such as start-ups and small firms can take part in innovation measures and sandboxes.¹ Other support includes policy implementation support projects, training on the EIF and on labelled solutions, a duty on public bodies to train relevant staff, and voluntary peer review by experts from other Member States.¹

Key dates

The dates come from the Act; the Commission gives 11 April 2024 for entry into force.¹⁴ The Commission must also present an annual report on interoperability in the Union, and the first was published in December 2025.¹³ The 2028 report must specifically assess whether mandatory interoperability solutions are needed.¹

Open questions about capacity

The Act reaches public sector bodies at every level, not only ministries, so the question is whether smaller administrations can carry the work. Its recitals acknowledge the risk: assessments should be proportionate, a single project in a local authority should be able to take a pragmatic, narrow focus, and the Board's guidelines should take account of the capacity of regional and local bodies and avoid excessive administrative burden.¹ Member States must also give their competent authorities adequate competence and resources.¹

Early figures are mixed. The first annual report records that 26 of the 27 Member States had appointed competent authorities by the 12 January 2025 deadline, and that the Commission completed 32 interoperability assessments of its own in 2025. Since assessments became mandatory, Member States had submitted two reports, from Cyprus and Germany.³ The report doesn't explain the gap; few qualifying decisions, slow uptake and limited capacity would all produce a low number, and each calls for a different response.

Money is the other open question. Subject to available funding, the EU budget covers the portal, labelled solutions and support measures, while Member States bear their own implementation costs, which the Commission expected to be offset over time by reuse and less duplication.¹² The annual report expects updated guidance and tools to simplify assessments.³ Whether that is enough for a small municipality without an interoperability specialist is for the 2028 review to judge.