HHS ILSA Law Journal Special Edition June 2026

© ILSA Law Journal and Contributors 2026

All rights reserved No part of this publication may be reproduced, stored in a retrieval system or transmitted in any form or by any means, electronic, mechanical or photocopying, recording, or otherwise without the prior permission of the publisher. Without limiting the author’s and publisher’s exclusive rights, any unauthorized use of this publication to train generative artificial intelligence (AI) technologies is expressly prohibited.

ISSN: 2772-9486

Alessia Martinas, Mihai Fala, Meraal

Aoibhe Murphy, Paulina Jakubiec, Olivia Cojanu, Micol Batistella

FOREWORD BY THE EUROPEAN COMMISSION - DG DIGIT

By Alina-Maria Breb enel, Guest Editor and Programme Manager, and Dr. Davide Audrito, Guest Editor and Interoperability Consultant

Interoperability governance, paramount to successful digital transformation of public administration

This interoperability issue of the Law Journal reveals a coherent picture: interoperability in Europe is no longer primarily a technical challenge but a governance challenge. Across diverse contexts – from Romania’s fragmented administrative landscape to municipal innovation in Poland, Italy, Lisbon, Sofia, The Hague and Rome – the same underlying reality appears repeatedly: digital transformation succeeds only when institutions can exchange data, coordinate processes and align organisational cultures aroun d shared standards and common objectives.

The Interoperable Europe Act recognises this reality by establishing interoperability as a strategic capability of public administration rather than a purely technological function. Its provisions on interoperability assessments, cooperation mechanisms, re usable solutions and innovation support reflect a broader shift in European digital policy: the transition from isolated digitalisation projects towards integrated digital public ecosystems. The articles demonstrate that many public administrations have successfully digitalised individual services yet continue to struggle with systemic interoperability. Romanian respondents identified low levels of interinstitutional data exchange, incompatible systems and the absence of common platforms as their principal obstacles. Similar concerns appear in municipal experiences across Italy, Poland and Bulgaria, where legacy systems, fragmented governance structures and inconsistent standards continue to limit effective cooperation.

A recurring theme throughout the articles is the tension between local realities and European ambitions. The Interoperable Europe Act establishes a framework for cross -border interoperability, yet implementation ultimately occurs within municipalities, reg ional authorities and national administrations. The experiences documented in Rome, Bucharest, Kołbaskowo, Udine, Sofia, Lisbon and The Hague illustrate that local authorities frequently carry the greatest implementation burden despite possessing the most limited resources. Smaller municipalities often lack specialised expertise, dedicated interoperability governance structures and sufficient training opportunities. Consequently, interoperability gaps are not only

technical but also organisational and human. This finding aligns directly with the Act’s emphasis on cooperation, capacity building and the development of interoperability skills across the Union.

Interoperability must thus be understood across all layers of the European Interoperability Framework. Technical interoperability remains essential, particularly through APIs, open standards and shared data models. However, the most persistent barriers ari se at organisational, semantic and legal levels. Data protection concerns, differing interpretations of General Data Protection Regulation obligations, unclear institutional responsibilities and inconsistent data standards repeatedly emerge as obstacles to effective information exchange. Several contributors correctly observe that technological solutions already exist in many cases; what remains missing is a shared governance environment capable of enabling trust, accountability and coordinated implementation.

Encouragingly, the articles also reveal a growing ecosystem of good practices. The Dutch Common Ground initiative, Portugal’s interoperability platform, Italy’s National Digital Data Platform (PDND), and various municipal innovation projects demonstrate ho w open standards, reusable components and data-driven governance can reduce administrative burden while improving public service delivery. These initiatives embody the principles contained in the Interoperable Europe Act, particularly the promotion of reus able interoperability solutions and the reduction of duplication across public administrations. Rather than developing isolated systems, public authorities increasingly recognise the value of common building blocks that can be adapted and reused across jurisdictions.

Europe’s interoperability journey has entered a new phase. The question is no longer whether public administrations should digitalise, but how they can govern digital transformation collectively. The Interoperable Europe Act provides the institutional architecture for this transition by creating mechanisms that connect policy objectives with operational realities. Its success, however, will depend on the ability of Member States and local administrations to transform interoperability from a compliance exerc ise into a strategic instrument for delivering citizen-centred public services. Ultimately, interoperability should be understood as the operational foundation of the European Digital Single Market: an enabler of trust, efficiency and cross -border cooperation that allows citizens, businesses and administrations to interact seamlessly across Europe’s increasingly interconnected digital landscape.

FOREWORD BY DR. TOKAJI-NAGY AND DR. NEDERLOF

By Dr. Orsolya Tokaji-Nagy and Dr. David Nederlof, Guest Editors and Coordinators of

the NextGen Government – The EU’s Digital Future Course at The Hague University of Applied

Sciences

This special edition of the ILSA Journal is the fruit of a project that we believe points the way towards what state-of- the-art applied sciences education can and should look like. The first iteration of the “NextGen Government – The EU’s Digital Future” course was at the heart of this project, which was co -created with the European Commission's DG DIGIT and the Interoperable Europe Academy - a collaboration that brought the work field directly into the classroom in the most meaningful sense in the framewor k of the International and European Law LLB Program at The Hague University. Students engaged with the MOOCs developed by the Academy, benefited from outstanding guest lectures from DG DIGIT, and completed a final assessment that asked them to do something both simple and ambitious: go out and empirically investigate the local implementation of the Interoperable Europe Act. The articles in this volume are the result of that endeavour.

The Interoperable Europe Act is cutting -edge legislation, and one of the most significant findings to emerge from this research - consistent with what is already documented in the literature - is that there are real gaps to be bridged. These gaps exist not only in the implementation of the Act itself, but also in the knowledge and readiness of the professionals tasked with applying it: public servants navigating new obligations, and legal professionals who must advise on them. This is precisely where we, as an applied sciences university, see our role. Our students are the future professionals who will contribute to a successful implementation of the Act and ultimately the realization of the Digital Single Market. It is our responsibility to recognize and understand the future trends and its challenges as well as to equip our students for that. Not just at the Brussels level, but at the local and national levels where new talent is needed just as urgently, and where the everyday work of implementation actually happens.

That preparation extends beyond the Interoperable Europe Act itself. Future legal professionals must be fluent in the broader legislative landscape in which it sits - from the GDPR through cybersecurity to internal market law - and must be capable of navigating the growing interdisciplinarity that characterises this field.

Digitalisation is no longer a specialism; it is an inescapable dimension of legal practice. We are committed to training professionals who are not only legally rigorous but genuinely equipped for this reality. Equally, we are committed to training cultural ly aware and sensitive global citizens, with the soft skills and intercultural understanding that complex, multistakeholder environments demand. Our student population - drawn from across the EU and beyond - is itself a learning environment in this respect. The diversity of backgrounds, perspectives, and lived experiences that students bring to their group work sparks curiosity, encourages comparison, and deepens the understanding of what a European perspective truly means in practice. This project was a p articularly vivid example of that dynamic at work, and it enriched the research in ways that are visible in the articles themselves.

We are immensely proud of what our students have accomplished. This was, at its core, a student-led empirical inquiry into local implementation experiences: a genuinely novel and valuable approach to researching how EU law lands on the ground. Through it, students gained something that no textbook can fully provide: the lived understanding that EU law is not only about the creation of frameworks and regulations, but about the very human and technical challenges of putting them into practice. We are deeply g rateful to the local contributors who gave their time and insights to make this research possible, and whose cooperation made these articles what they are.

Looking ahead, we see this project as the beginning of something larger. We are keenly aware that the challenge of implementation is not only a matter of training the next generation of professionals: it is also a matter of supporting the public servants w ho are navigating these obligations today. It is therefore one of our ambitions to develop a professional development course that addresses precisely this need, ensuring that the knowledge and tools required to make the Interoperable Europe Act a success a re available not only to future legal professionals, but to those doing the work right now. We very much look forward to running the undergraduate course again next year, so that more students may benefit from this extraordinary learning experience.

Finally, we wish to express our sincere gratitude to the students who participated in this pilot and who went the extra mile to bring their work to publication standard: their dedication has been remarkable. We thank the ILSA Journal's editorial team and E ditor-in-Chief for their commitment and professionalism throughout this process. And most important of all, we extend our warmest thanks to the brilliant team at the European Commission's DG DIGIT and

Interoperable Europe Academy whose partnership, expertise, and enthusiasm made this entire project possible. We look forward to continuing this collaboration.

EDITOR-IN-CHIEF’S NOTE

Dear readers,

On behalf of the Editorial Board, it is my distinct pleasure to present the first collaborative edition between the HHS ILSA Law Journal, the NextGen Government – The EU’s Digital Future course, and DG DIGIT of the European Commission.

This special edition, entitled Bridging the Gap: Local Perspectives in the Implementation of the Interoperable Europe Act , reflects a shared commitment to fostering dialogue between academic research, public administration s, and the next generation of scholars. At a time when digital transformation is reshaping governance across Europe, the Interoperable Europe Act presents both opportunities and challenges for public authorities. The contributions featured in this publication explore these developments through local perspectives, offering insight into the implementation of European digital policies in practice.

This publication stands as a tangible testament to the dedication of its authors, editors, faculty supervisors, and institutional partners. This edition also forms part of a broader effort to promote academic research and scholarly publication among emerging researchers. One of the Journal's central objectives this year has been to provide opportunities for first -time authors, recognising that students and young researchers possess valuable perspectives that deserve a platform. The articles contained in this issue showcase the analytical rigour and engagement of students demonstrates both the diversity and relevance of the issues surrounding Europe's digital future explored throughout this publication

What makes this special edition noteworthy is its empirical research conducted by students through interviews and surveys. In accordance with research ethics and data protection considerations, the interview transcripts and survey responses are retained on file but are not published. For further information, kindly contact ILSA Journal at ilsajournal.hhs@gmail.com.

We hope that this edition encourages reflection on the future of digital governance in Europe and inspires continued engagement with the challenges and opportunities presented by interoperability, digital public services, and European integration. On behalf of the Editorial Team, I wish you a pleasant and insightful read !

Ms. Aurelie Levesque

Editor-in-Chief, HHS ILSA Law Journal 2025–2026

ACKNOWLEDGEMENTS

The ILSA Law Journal would first like to thank the authors who shared their outstanding contributions in this issue. We are incredibly grateful for the unwavering trust, patience, and enthusiasm they showed towards the realization of this publication.

We would also like to take this opportunity to express our sincere appreciation to the European Commission DG DIGIT acting as Guest Editors: Alina-Maria Brebenel and Davide Audrito for their feedback on the Articles and support in this project. Additionally, we would like to extend our deepest gratitude to Guest Editors Dr. Tokaji-Nagy and Dr. Nederlof for their continued efforts, contributions, and guidance in bringing this project to life. We are deeply thankful for the continuous support they have provided us in conducting the selection and editorial process.

The Journal would also like to thank the 2025 -2026 ILSA Management Board for its unparalleled support and encouragement. We would like to extend our gratitude to President and Treasurer Konstantinos Karlos, Vice-President and Head of Social Events Ms. Kiah ara Fleming, Head of Main Events Ms. Amal Mohamed, Head of Marketing Ms. Melisa Yusufova, and Editor in Chief of the ILSA Journal Ms. Aurelie Levesque.

Finally, we would like to thank the editorial team for their diligence and determination. The Journal would like to express its sincere appreciation for the participation of its members, including Secretary Daria Hasan, Managing Editor Sarah Martins, and Editors Dea Merkaj, Sandrin Petrova, Maria Enea, Emilija Januševičiūtė, Melani van Oenen, Sara Rosic, Kyrre Nilsen, Vin Stosio, Leon Paladinić, Sabina Tilici, Natalia Malecka, Maria Pătraşcu, Alexandru Moise, and Isla Sassetti.

Bridging the Gaps: Interoperability Implementation Challenges

and Training Needs in EU Municipalities

By Pierina Simone*

Abstract

The article analyses the challenges of the Interoperable Europe Act’s implementation, creating interoperability between public services and its digitalization process in EU municipalities, and specifically, the knowledge and skill gaps that public sector w orkers are facing. While the Interoperable Europe Act and the EU set digital targets, local municipalities are currently bearing the double burden of adapting and solving technical, operational, and legal issues while operating with limited monetary resources and without training strategies set in place. This research includes original, semi -structured expert interviews with representatives across five EU Member States, which occurred between January and March 2025. The empirical data reveal recurrent theme s and explanations of organizational and cultural resistance that account for approximately 75% of implementation challenges and outweigh technical barriers. Legal barriers are complicated by local adaptations, overinterpretation, and financial constraints hitting smaller municipalities the most. The findings highlight substantial training needs with work- integrated and practical training bringing the most immediate and effective results, as well as peer-to-peer learning networks and AI literacy programmes. Promising practices, such as open standards and digital literacy academies, emerged from the interviews, demonstrating that organized capacity building can make sceptics advocates. In conclusion, achieving the EU’s 2030 Digital Decade goals requires attention and care towards local realities, as well as investing in workers -centric training and digital governance structures that allow collaboration across different administrative levels and bodies.

* LL.B. Graduate and Alumni International and European Law Programme, The Hague University of Applied Sciences

I. Introduction

The digital transformation of public services is a key part of the European Union's plan for a more connected and efficient Digital Single Market. 1 Interoperability is the ability of different systems, services, and organisations to share and use information without any problems across borders, sectors, and levels of government. 2 Interoperability is a key part of the change towards the Digital Single Market. 3 The Interoperable Europe Act (IEA), which entered into force in April 2024, establishes a legally binding framework to improve crossborder digital public services and support the EU's 2030 Digital Decade goals, including ensuring that all essential publi c services are available online by 2030. 4

The IEA sets ambitious goals for the EU, but local governments are to be responsible for implementation of the objectives. 5 Four provisions of the IEA are particularly relevant to local- level implementation. Article 3 introduces mandatory interoperability assessments for new or substantially modified network and information systems, creating a direct compliance obligation for local authorities. 6 The Interoperable Europe Board, as per Articles 15 -17 establishes a governance structure aiming to coordinate implementation across Member States. 7 Article 9 creates a catalogue of solutions: the Interoperable Europe Portal. The Portal offers reusable technical components and best practices accessible to all public bodies. 8 Additionally, the Interoperable Europe Academy provides training and capacity -building

1 Vicky Margariti and others, ‘Assessment of Organizational Interoperability in e -Government: A New Model and Tool for Assessing Organizational Interoperability Maturity of a Public Service in Practice’ in Proceedings of the 13th International Conference on Theory and Practice of Electronic Governance (ICEGOV 2020, ACM 2020); Rodriguez Müller, A. P. and Schade, S. ‘Interoperability Assessments: Exploring expected benefits, effort and challenges ’(policy brief JRC137063, 17) European Commission, Joint Research Centre (2024).

2 Regulation (EU) 2024/903 laying down measures for a high level of public sector interoperability across the Union (Interoperable Europe Act) [2024] OJ L 903/21; Rodriguez Müller, A. P. and Schade, S. ‘Interoperability Assessments: Exploring expected benefits, effort and challenges ’ (policy brief JRC137063, 17) European Commission, Joint Research Centre (2024).

3 Vicky Margariti and others, ‘Assessment of Organizational Interoperability in e -Government: A New Model and Tool for Assessing Organizational Interoperability Maturity of a Public Service in Practice’ in Proceedings of the 13th International Conference on Theory and Practice of Electronic Governance (ICEGOV 2020, ACM 2020).

4 Regulation (EU) 2024/903 laying down measures for a high level of public sector interoperability across the Union (Interoperable Europe Act) [2024] OJ L 903/1.

5 ibid 9; Interview with Andrea Cassani, Mayor of the Municipality of Gallarate (Gallarate, 2 January 2025).

6 Regulation (EU) 2024/903 laying down measures for a high level of public sector interoperability across the Union (Interoperable Europe Act) [2024] OJ L 903/12.

7 ibid, pp. 20-22.

8 ibid, pp. 16.

resources. 9 This paper assesses the readiness and training needs of municipalities against these four articles of the Interoperable Europe Act.

These local actors face what this paper refers to as ‘double burden’. This is because they must address the complex technical, legal, and operational challenges of interoperability, including data governance under GDPR, procurement constraints, and semanti c alignment across legacy systems; while also confronting structural resource limitations including smaller budgets, fewer specialized staff, and limited access to training. 10 This double burden is the central analytical focus of the paper.

Against this background, this paper addresses three research questions:

(1) What knowledge and skill deficiencies do public sector employees in EU municipalities face in implementing interoperable systems under the IEA?

(2) How does the double burden of technical- legal complexity and resource constraints affect the operational capacity of municipalities to comply with the IEA's substantive obligations?

(3) What role can EU -level tools, in particular the Interoperable Europe Academy and the Interoperable Europe Portal, play in addressing these deficiencies? The paper draws on empirical data from semi-structured expert interviews across five EU Member Stat es, complemented by desk research on the relevant legal and policy framework. 11

II. Methodology

This study utilised a mixed- methods approach, integrating desk research with empirical fieldwork. The desk research looked at the EU's legal framework, which includes the Interoperable Europe Act, the General Data Protection Regulation (GDPR), the AI Act, and the

9 Interoperable Europe, ‘Interoperable Europe Academy’ <https://interoperableeurope.ec.europa.eu/collection/interoperable -europe-academy> accessed 13 June 2026; Interoperable Europe ‘Interoperable Europe Portal’ <https://interoperable -europe.ec.europa.eu> accessed 13 June 2026.

10 Regulation (EU) 2024/903 laying down measures for a high level of public sector interoperability across the Union (Interoperable Europe Act) [2024] OJ L 903/15; Rodriguez Müller, A. P. and Schade, S. ‘Interoperability Assessments: Exploring expected benefits, effort and challenges ’ (policy brief JRC137063, 7) European Commission, Joint Research Centre (2024); Interview with Dr. Gege Gatt, CEO of EBO, AI and Interoperability Expert (Malta, 14 February 2025).

11 Rodriguez Müller, A. P. and Schade, S. ‘Interoperability Assessments: Exploring expected benefits, effort and challenges ’ (policy brief JRC137063, 11-13) European Commission, Joint Research Centre (2024).

Public Procurement Directive. 12 It examines academic literature on the topics of digital transformation and e-governance in cities. 13

The empirical component includes semi-structured expert interviews that were personally carried out for the research project between January and March 2025. The paper examines interviewees representing different levels of ‘digital maturity’ and geographic areas to get a wide range of points of view: interviewees were selected through purposive sampling and identified through direct institutional outreach. The selection also prioritized diversity across three dimensions: governance level, type of expertise ( technical implementation, AI consultancy, or political leadership), and geographic spread across the EU. This combination was designed to analyse both realities of smaller municipalities and more digitally advanced cities and supranational actors:

1. Andrea Cassani, Mayor of a Gallarate, Italy - representing a smaller Italian municipality navigating digital transformation challenges;14

2. Roland van der Heijden, Chief Cityverse Officer, Municipality of Rotterdam, Netherlands - representing a leading digital city with advanced interoperability initiatives; 15

3. José Luis Garrote Gonzales, Deputy Director of the Spanish Federation of Municipalities and Provinces (FEMP) - providing a national-level perspective on local administration challenges across Spain; 16

12 Directive 2014/24/EU of the European Parliament and of the Council of 26 February 2014 on public procurement and repealing Directive 2004/18/EC [2014] OJ L 94/65.

13 Regulation (EU) 2024/903 laying down measures for a high level of public sector interoperability across the Union (Interoperable Europe Act) [2024] OJ L 2024/903; Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation) [2016] OJ L119/1; Regulation (EU) 2024/1689 of the European Parliament and of the Council of 13 June 2024 laying down harmonised rules on artificial intelligence [2024] OJ L 2024/1689 ; Council Directive 2014/24/EU of 26 February 2014 on public procurement and repealing Directive 2004/18/EC [2014] OJ L94/65.

14 INWIT, Interview with Marco Interview with Andrea Cassani, Mayor of the Municipality of Gallarate (Gallarate, 2 January 2025).

15 Interview with Roland van der Heijden, Chief Cityverse Officer, Municipality of Rotterdam (Rotterdam, 5 February 2025).

16 Interview with José Luis Garrote Gonzales, Deputy Director of the Spanish Federation of Municipalities and Provinces (FEMP) (Madrid, 5 February 2025).

4. Dr. Benedek Jávor, Head of Representation of Budapest to the EU - offering insights from both national and EU -level governance perspectives; 17

5. Dr. Gege Gatt, CEO of EBO, AI and Interoperability Expert, Maltacontributing technical expertise on AI's role in interoperability. 18

Interviews were conducted using a structured questionnaire that addressed three thematic areas: awareness of the IEA and ‘digital readiness’, obstacles to implementing interoperability, and training requirements for public sector employees. Within each the matic area, questions shifted from general perceptions to specific experiences and recommendations. The semi-structured format allowed for follow -up scrutiny where interviewees introduced relevant themes beyond the prepared questions. Thematic coding was u sed to identify patterns across the interview data. The coding scheme is the result of a deductive -inductive observation approach: initial categories were identified from the literature on interoperability barriers and training needs and subsequently refin ed through close reading of the transcripts. Final categories included: technical barriers, legal and compliance barriers, organisational and cultural resistance, financial constraints, and training needs by type and format.

This study presents several limitations, as the number of interviewees allows for exploratory qualitative research but not generalisability. Moreover, the selection is biased towards urban and well-resourced administrations and could underrepresent challen ges of rural municipalities. Two interviews were conducted in Italian with the Mayor of Gallarate and in Spanish with the Deputy Director of FEMP and later transcribed and translated with automated tools and manual revision, which may have introduced minor inaccuracies in nuance.

III. Literature Review: Training for Interoperability

The concept of interoperability in the public sector has been studied across different viewpoints: technical, semantic, legal, and organisational. After the first version of the European Interoperability Framework (EIF) was published in 2004, it has provid ed an architecture plan for cross -border digital public services in the EU. 19 Implementation issues have been identified by academics, who shift implementation responsibility from IT personnel

17 Interview with Dr. Benedek Jávor, Head of Representation of Budapest to the EU (Budapest, 7 March 2025).

18 Interview with Dr. Gege Gatt, CEO of EBO, AI and Interoperability Expert (Malta, 14 February 2025).

19 European Commission, 'European Interoperability Framework Implementation Strategy' COM (2017) 134 final; Cristiano Codagnone and Marc Wimmer, ‘Roadmapping eGovernment Research: Visions and Measures towards Innovative Governments in 2020’ (eGovRTD2020 Consortium 2007).

to organisations as one, identifying public sector workers’ competence as a structural concern rather than technical. 20 The success of interoperability’s implementation, especially in the public sector, strongly depends on the skills and competencies of the workforce. 21 The literature analysed throughout the theoretical part of the research highlights a consistent ‘skills gap’ as a notable barrier to the effective implementation of interoperability. 22 The gap includes technical deficiencies, lack of knowledge of legal frameworks, data governance principles, and the value and advantages of interoperability across different levels of organisation. 23

The EIF’s 2017 revision introduced ‘integrated public service governance’ as requiring governance arrangements and measures of capacity -building when presenting interoperability solutions, showing that technical standards without trained staff able to appl y them are insufficient. 24

The theoretical findings show the necessity of developing targeted training programs addressing these specific challenges: capacity building, including data management, data standardisation, cybersecurity, data protection, management change to tackle organ izational resistance, and the development of soft skills, such as inter-agency collaboration. 25 Literature also highlights a digital literacy deficit among public sector workers, which influences their ability to understand new tools as well as the risks and associated with new technologies. 26 The OECD’s publication on the digital literacy deficit identifies digital skills as one of the main competence gaps in public administration. Moreover, highlights governments’ underinvesting in trainings for employees, meaning their skills are not updated at the same pace as techadvancements. This is particularly influential in sub -national level governments, which are

20 Yannis Charalabidis, Fenareti Lampathaki and Dimitris Askounis, ‘A Comparative Analysis of National Interoperability Frameworks’ (2010) 4(4) eJETA 36.

21 Rodriguez Müller, A. P. and Schade, S. ‘Interoperability Assessments: Exploring expected benefits, effort and challenges’ (policy brief JRC137063, 15) European Commission, Joint Research Centre (2024); Nunzio Casalino, ‘Learning to Connect: a Training Model for Public Sector on Advanced E -Government Services and InterOrganizational Cooperation’ [2024] 7(1) iJAC 1.

22 Rodriguez Müller, A. P. and Schade, S. ‘Interoperability Assessments: Exploring expected benefits, effort and challenges’ (policy brief JRC137063, 12) European Commission, Joint Research Centre (2024).

23 ibid 91.

24 European Commission, ‘New European Interoperability Framework’ COM (2017) 134 final, 12 –14.

25 Regulation (EU) 2024/903 laying down measures for a high level of public sector interoperability across the Union (Interoperable Europe Act) [2024] OJ L 2024/903, 36; Nunzio Casalino, ‘Learning to Connect: a Training Model for Public Sector on Advanced E-Government Services and Inter-Organizational Cooperation’ [2024] 7(1) iJAC 4.

26 Rodriguez Müller, A. P. and Schade, S. ‘Interoperability Assessments: Exploring expected benefits, effort and challenges’ (policy brief JRC137063, 35) European Commission, Joint Research Centre (2024).

more limited in resources and specialized staff. 27 At the EU level, the Interoperable Europe Academy and the Interoperable Europe Portal offer openly accessible resources, best practices, and training courses specifically designed to address these competency gaps among public sector professionals.

Lastly, the academic discourse underlines the importance of “work -integrated learning” and peer-to-peer arrangements, which are more effective than abstract and theoretical courses.28 The best results were achieved when training is practical, continuous, and linked to the daily work tasks of public sector employees. 29 These findings align with academia on public sector learning, which stresses that effective and efficient digital training requires structural embedding, rather than singular interventions, referring to this process as “transformative capacity”. 30 This literature review establishes a baseline for the empirical part of the research that follows, allowing for a deeper analysis of the specific public sector workers’ training needs according to the interviewed specialists in the field. 31

IV. Findings: Barriers to Interoperability Implementation

A. Technical and Semantic Barriers

The base requirement for interoperable systems is the ability for tech -solutions to communicate with each other. The interviews consistently identified technical and semantic barriers as fundamental challenges to the implementation of interoperability. Exa mples of such technical and semantic barriers would be legacy systems, proprietary formats, and a lack of common standards.

Secondary data support the interview findings. The NIFO Digital Public Administration Factsheets show significant disparities in the adoption of common data

27 OECD, ‘Digital Government Review of Norway: Boosting the Digital Transformation of the Public Sector’ (OECD Digital Government Studies, OECD Publishing 2023); OECD, ‘Skills for a Digital World’ (OECD Digital Economy Papers No 250, OECD Publishing 2016).

28 Jan Frick, ‘Facilitating Data Sovereignty and Digital Transformation in Municipalities and Companies: An Examination of the Data for All Initiative’ [2023] 14(3) International Journal of Business Administration, 1; Rodriguez Müler, A. P. and Schade, S. Interoperability Assessments: Exploring expected benefits, effort and challenges , policy brief, European Commission (2024), Joint Research Centre, JRC137063, 7.

29 Nunzio Casalino, ‘Learning to Connect: a Training Model for Public Sector on Advanced E -Government Services and Inter-Organizational Cooperation’ [2024] 7(1) iJAC 2.

30 Ines Mergel, Nathalie Edelmann and Noella Haug, ‘Defining Digital Transformation: Results from Expert Interviews’ (2019) 35(6) Government Information Quarterly 101385.

31 Rodriguez Müller, A. P. and Schade, S. ‘Interoperability Assessments: Exploring expected benefits, effort and challenges’ (policy brief JRC137063, 13) European Commission, Joint Research Centre (2024).

standards in different EU Member States. 32 The DESI public services dimension also demonstrates that, despite progress in digitalisation, data integration between administrative systems on the back end is still largely underdeveloped across the EU. 33

1. Data standardization and legacy systems

The Italian local-municipality’s mayor said that there is “a lack of standardisation in the structure of data” across administrative systems. 34 Mentioning that data is made available voluntarily and in “partial data with specific structures that require equally specific programming for each set of data”. 35 This fragmentation makes it difficult for systems to communicate with each other. 36 The mayor has added that some central state agencies make data available, but they severely limit access to the number of operators, and other agencies “provide data that is clearly out of date by several years”. 37 These fragmentation issues delineate the concept of the semantic layer of the Europe Interoperability Framework, which defines semantic interoperability as ensuring that the exact format and meaning of exchanged data is kept and understood between parties . 38

2. Vendor lock- in

Rotterdam’s Chief Cityverse Officer pointed out a major technical problem: ‘vendor lock-in’. 39 Apparently “90% of governments in the Netherlands, maybe even 100%,” depend on one GIS company that uses proprietary data formats. 40 He added, “Up until today, they still use their own formats for data. And we're all stuck with that”. 41 This dependence reduces flexibility and makes it difficult for systems to work together. 42 He went on to say that “when

32 National Interoperability Framework Observatory (NIFO), ‘Digital Public Administration Factsheets 2024’ (European Commission, Interoperable Europe Portal, July 2024) <https://interoperableeurope.ec.europa.eu/collection/nifo-national-interoperability-framework-observatory/digital-publicadministration-factsheets-2024\> accessed 12 June 2026.

33 European Commission, ‘The Digital Economy and Society Index’ (2023), State of the Digital Decade Report 2023 <https://digital-strategy.ec.europa.eu/en/policies/desi-digital-public-services\> accessed 12 June 2026.

34 Interview with Andrea Cassani, Mayor of the Municipality of Gallarate (Gallarate, 2 January 2025).

35 ibid.

36 ibid.

37 ibid.

38 European Commission, ‘New European Interoperability Framework – Promoting Seamless Services and Data Flows for European Public Administrations’ COM (2017) 134 final, 27.

39 Interview with Roland van der Heijden, Chief Cityverse Officer, Municipality of Rotterdam (Rotterdam, 5 February 2025), 8.

40 ibid.

41 ibid.

42 Interview with Roland van der Heijden, Chief Cityverse Officer, Municipality of Rotterdam (Rotterdam, 5 February 2025), 6.

public organisations use proprietary software stacks, you can only develop within that software stack. I don't want only to develop within one system. I want to develop, and meanwhile I don't want to have a preference on the software stack at all”. 43 This concern directly translated into the legal dimension, as the Public Procurement Directive 2014/24/EU, forbids technical specifications that favour specific suppliers and requires contracting authorities to allow for equally working solutions. This provision directly applies to proprietary software procurement by municipalities. 44 The interview with Mr. van der Heijden makes clear that these provisions do not prevent vendor dependence in practice, suggesting that enforcement and awareness could be potential targets of training.

3. The relevance of open standards

Mr. Van der Heijden, representing Rotterdam, made it clear what the answer was: open standards for sharing data, meaning public and non -proprietary technical specifications that anyone can use, that are not owned by any company. He compared sharing data to language “The language of your data within your own system, I don't care, but when we exchange data between your system and my system, then we use an open language”. 45 This approach needs a big change “from software-driven towards data-driven”.46 The city's Open Urban Platform is a good example of this, as it requires all participants to use ‘open standards’ for data exchange. 47

B. Legal and Regulatory Barriers

As surfaced across all interviews, legal and regulatory barriers are one of the biggest implementation issues, especially regarding data protection, privacy in balance with public interest, and the AI Act. This section examines how these legal challenges d isplay in local settings. 48

1. GDPR complexity

43 ibid 10.

44 Directive 2014/24/EU of the European Parliament and of the Council of 26 February 2014 on public procurement and repealing Directive 2004/18/EC [2014] OJ L 94/65, art 42.

45 ibid 11.

46 ibid 6.

47 ibid 2.

48 Rodriguez Müler, A. P. and Schade, S., ‘Interoperability Assessments: Exploring expected benefits, effort and challenges’ (policy brief) European Commission (2024), Joint Research Centre, JRC137063, 60, 64; Albert Sanchez-Graells, ‘Public Procurement of Artificial Intelligence: Recent Developments and Remaining Challenges in EU Law’ [2024] 2 LTZ 123.

As a FEMP’s Deputy Director remarked, “data protection regulations are very protective, and they bring challenges regarding how to promote interoperability. 49 This challenge results in more cumbersome implementations, which leads to longer timelines and higher implementation costs”. 50 The Italian mayor took a more critical view, stating that “data protection regulations are severely deteriorated by the interpretations of individual subjects at every dispositive and operational level ”. 51 This over-interpretation, he argued, often “distorts the purpose of protection by ridiculing acts and procedures” that do not involve direct personal identification. 52 This critique, while voicing a practical operational concern, can be read alongside academic literature on the GDPR -interoperability tension. Hijmans and Raab refer to the GDPR as a principle-based instrument instead of a rules -based one, where general clauses, such as the lawfulness ground of public task under Article 6(1)(e), allow critical scope for data sharing between public bodies when properly justified. 53 Mantelero also argues that data protection impact assessments under the GDPR should not be considered a way of preventing the development and improvement of data -driven public services, but as tools for identifying and mitigating risks to fundamental righ ts while allowing socially beneficial data use.54 Similarly significant is the once-only principle presented in Article 14 of the Single Digital Gateway Regulation, which operationalises cross -border data exchange specifically to reduce the strain of repeated same-data transfer to different authorities, which the mayor criticised at the domestic level. 55

2. Balancing privacy with public interest

In a principle-based interpretation, suggested by the Italian local municipality’s mayor: “The protection of some personal data must be considered yielding in favour of the public interest, understood as an interest for the community”. 56 He suggested that access must be restricted, for example, to “that which is strictly necessary for the public activity that has to be

49 Interview with José Luis Garrote González Deputy Director of the Spanish Federation of Municipalities and Provinces (FEMP) (Madrid, 5 February 2025), 2.

50 ibid.

51 Interview with Andrea Cassani, Mayor of the Municipality of Gallarate (Gallarate, 2 January 2025), 3.

52 ibid.

53 Hielke Hijmans and Charles Raab, ‘Ethical Dimensions of the GDPR, AI Regulation, and Beyond’ [2021] 18(100) RDP 63, 64–65.

54 Alessandro Mantelero, ‘AI and Big Data: A Blueprint for a Human Rights, Social and Ethical Impact Assessment’ (2018) 34 Computer Law & Security Review 754, 756 –757.

55 Regulation (EU) 2018/1724 of the European Parliament and of the Council of 2 October 2018 establishing a single digital gateway to provide access to information, to procedures and to assistance and problem -solving services [2018] OJ L 295/1, art 14.

56 ibid.

carried out in the context, place and time of use of data,” with interoperability used to determine which data is needed in any given procedure. 57

3. AI Act implications

Dr. Gatt’s comments on the AI Act underline a deeper structural challenge that is emerging in both academia and policy: the imposition of several EU compliance frameworks on the same municipal arrangement scenario, what this paper refers to as “triple asse ssment burden”. 58 According to him, if we have a private sector that does not adhere to ethical standards from the ideation of technology, it will be difficult to get solutions in the market. 59 This Act, which he feels is a wake-up call for the public sector, he added, will push it towards compliance and a risk-reactive approach, which can transform outcomes. 60 A municipality deploying an interoperable AI-enabled service, this must follow the interoperability assessment under Article 3 of the IEA, the Fundamental Rights Impact Assessment under Article 27 of the AI Act, and the Data Protection Impact Assessment u nder Article 35 of the GDPR.61 Despite being developed independently, different in methodologies, and overseen by different bodies, these three frameworks intersect on the same deployment scenario at the municipal level. Hijmans and Raab noted that the GDPR already requires ethical dec isions from data controllers and not only procedural requirements. 62 Moreover, Mantelero supports the idea of integrated human rights and social impact assessment models to address these obligations holistically, as the lack of integrated assessment methodologies could create subsequent overlapping procedural burdens, part icularly for local governments.63 The ‘triple assessment burden’ shows that municipalities need to cover legal, technical, and ethical skills in targeted trainings together instead of addressing compliance requirements one by one.

C. Operational and Organizational Barriers

57 ibid.

58 Interview with Dr. Gege Gatt, CEO of EBO, AI and Interoperability Expert (Malta, 14 February 2025), 1.

59 ibid.

60 Interview with Dr. Gege Gatt, CEO of EBO, AI and Interoperability Expert (Malta, 14 February 2025), 3.

61 Regulation (EU) 2024/903 (Interoperable Europe Act) [2024] OJ L 2024/903, art 3; Regulation (EU) 2024/1689 of the European Parliament and of the Council of 13 June 2024 on artificial intelligence (Artificial Intelligence Act) [2024] OJ L 2024/1689, art 27; Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data (General Data Protection Regulation) [2016] OJ L 119/1, art 35.

62 Hielke Hijmans and Charles Raab, ‘Ethical Dimensions of the GDPR, AI Regulation, and Beyond’ [2021] 18(100) RDP 63, 75–76.

63 Alessandro Mantelero, ‘AI and Big Data: A Blueprint for a Human Rights, Social and Ethical Impact Assessment’ (2018) 34 Computer Law & Security Review 769 –770.

1. The primacy of organizational culture

Organisational culture is the most important barrier affecting operations. 64 According to Rotterdam’s Chief Cityverse Officer, “only 25% of the barriers that you encounter in innovation are about content and techniques. In contrast to that, at least 75% of the barriers are about organisational and cultural barriers”. 65 He elaborated that “they have nothing to do with techniques because the techniques are there. But they’re all other kinds of reasons why people won’t use it or aren't interested in it”. 66 Or simply put, resistance to change.

2. Resistance to change and accountability

The Chief Cityverse Officer in Rotterdam identified a few sources of organisational resistance. 67 He said employees could think: “I am afraid to lose my job because it will still be needed in the future”. The transparency remark also emerges: “People are saying, but we must not be too transparent. […] In the sense: in offering our data to the outer wo rld, but also how our working process is going on”. 68 The planner noted that, if processes are made to be transparent, they are often critiqued by the general public. 69

One revealing observation was around the unwillingness to create measurable indicators. “I know that a lot of people in those roles who are responsible don’t want to be held to account so they don’t want any KPIs. Because then somebody could point out that they had to committed to eight and delivered only six”. 70

At its core, the resistance described isn’t about technical complexity but about basic human fears: losing one's job, being judged, or having one's work exposed to outside scrutiny. These fears appear as avoidance of transparency and measurable accountabil ity, showing that the biggest barriers to interoperability are rooted in the organizational humanity of its users, not in the underlying code.

64 Rodriguez Müler, A. P. and Schade, S. ‘Interoperability Assessments: Exploring expected benefits, effort and challenges’ (policy brief) European Commission (2024), Joint Research Centre, JRC137063, 64; José Marcelo A. P. Cestari, Eduardo de Freitas Rocha Loures, Eduardo Alves Portela Santos, Herv é Panetto ‘A capability model for public administration interoperability’ [2020] 14(8) Enterprise Information Systems 1074.

65 Interview with Roland van der Heijden, Chief Cityverse Officer, Municipality of Rotterdam (Rotterdam, 5 February 2025), 11.

66 ibid 12.

67 ibid.

68 ibid 12-13.

69 ibid 13.

70 ibid.

3. Collaboration challenges

According to the Deputy Director of the Spanish Federation, “the different levels of competence do not favour collaboration between the administrations”. 71 There are forums where all the levels are represented. However, “this distribution of competences is an element that slows the work down”.72 The mayor of the Italian local municipality also noted that “there is currently no real collaboration” between central agencies and the municipalities, due to restrictions on data access and the presence of outdated datasets, as well as “the total absence of governance of interoperability”. 73

D. Financial Constraints

Financial limitations remain a persistent limitation to the progress of interoperability’s implementation, even where clear legal frameworks are in place. Several EU-level funding instruments exist in principle to address this investment gap. The Digital Europe Programme (2021–2027) explicitly supports the deployment of interoperability solutions in public administrations, including through the funding of digital innovation hubs and cross -border digital services. 74 The Connecting Europe Facility, Digital (CEF Digital) similarly funds digital connectivity infrastructure and the deployment of trans -European digital services, with interoperability as an explicit objective. 75 The Recovery and Resilience Facility (RRF), the largest EU post-pandemic stimulus instrument, required Member States to dedicate a minimum of 20% of their national recovery plans to digital transformation. 76 However, as the interviews reveal, the mere existence of these instruments does not guarantee uptake at the municipal level, particularly where administrative capacity to apply for and manage EU funding is itself limited.

1. Funding gaps

71 Interview with José Luis Garrote Gonzales, Deputy Director of the Spanish Federation of Municipalities and Provinces (FEMP) (Madrid, 5 February 2025) 2.

72 ibid.

73 Interview with Andrea Cassani, Mayor of the Municipality of Gallarate (Gallarate, 2 January 2025) 2.

74 Regulation (EU) 2021/694 of the European Parliament and of the Council of 29 April 2021 establishing the Digital Europe Programme [2021] OJ L 166/1.

75 Regulation (EU) 2021/1153 of the European Parliament and of the Council of 7 July 2021 establishing the Connecting Europe Facility [2021] OJ L 249/38.

76 Regulation (EU) 2021/241 of the European Parliament and of the Council of 12 February 2021 establishing the Recovery and Resilience Facility [2021] OJ L 57/17, art 18(4)(e).

Dr. Gatt identified financial constraints as a main hindrance, stating that most public institutions still operate with a very outdated digital infrastructure 77 Additionally most countries don't want to make the necessary investments for updating the digital infrastructure . 78 He added that there is underinvestment in AI in national budgets. 79

2. Impact on the smaller municipalities

The Italian mayor noted that even when funding is receivable, as it is under the National Recovery and Resilience Plan (PNRR), implementation remains difficult. 80 The noncompulsory aspect of the funding and absence of data harmonisation will likely deter participation. 81 Furthermore, a failure to ensure participation could “completely nullify the holistic value of interoperability, reducing it to a tinsel with some local or very limited utility” 82

The Italian mayor's reference to the PNRR, Italy's National Recovery and Resilience Plan, requires further contextualisation. Under Mission 1, Component 1 (M1C1: Digitalisation, Innovation and Security in the Public Administration), Italy allocated approxi mately €6.74 billion to public sector digitalisation, of which around €1.78 billion was directed specifically at local authorities.83 Investment 1.3 within M1C1, dedicated to data and interoperability, received a budget of €0.65 billion with the explicit aim of enhancing interoperability between public administration information systems. 84 Monitoring data indicate that over 90% of Italian municipalities have launched digitalisation projects under the PNRR, and 90% have formally joined the National Digital Data Platform (PDND), the infrastructure enabling the once -only principle between public databases.85 Yet formal adherence does not equal operational integration: as the mayor observed, the non- compulsory nature of participation and the absence of data harmonisation standards mean that even well -funded municipalities can find themselves unable to extract systemic interoperability gains from individual projects.

77 Interview with Dr. Gege Gatt, CEO of EBO, AI and Interoperability Expert (Malta, 14 February 2025), 2.

78 ibid.

79 ibid.

80 Interview with Andrea Cassani, Mayor of the Municipality of Gallarate (Gallarate, 2 January 2025), 2.

81 ibid.

82 ibid.

83 Piero Calcagno, ‘Italian Municipalities, Digitization, and PNRR’ ( Medium, 2023) <https://medium.com/@justpierus/italian-municipalities-digitization-and-pnrr-why -change-and-why-nowcbe7f07e3469\> accessed 12 June 2026.

84 European Commission, ‘Council Implementing Decision on the Approval of the Assessment of the Recovery and Resilience Plan for Italy’ COM (2023) 765 final, Annex, M1C1 Investment 1.3.

85 ‘Local Public Administration Digital Services: Transforming Territories’ ( OpenEconomics , 2025) <https://www.openeconomics.eu/en/post/local-public-administration-digital-services-transforming-territories\> accessed 12 June 2026.

Even when funding is available, the absence of common data standards limits interoperability investments and progress. Interoperability does not work around individual systems that cannot consolidate into an integrated system.

E. Sociological Barriers: Trust and Digital Divide

1. Trust deficits

Trust emerged repeatedly across interviews as a fragile yet essential component of successful digitalisation. The Spanish Federation Deputy Director pointed to a “generation gap that makes it difficult to change from an analogue model of administration to a digital one” as the divide is not merely generational. He added that “there is a group of users who cannot access digital administration, and therefore all services must be maintained in a dual format”. 86 Moreover, this dual-track requirement, keeping paper-based systems alive alongside new digital ones, imposes costs and slows progress. 87

Transparency, often referred to as a virtue, carries its own risks. Rotterdam’s Chief Cityverse Officer observed that openness about data use and internal processes can foster discomfort. 88 When work becomes visible, it invites scrutiny, and not every public body welcomes that level of accountability. 89 The hesitation this creates can stall digital initiatives before they gain traction. 90

2. Digital literacy

On the skills front, Dr. Gatt identified what he called a ‘talent’ deficit, stating most public officials lack digital literacy, or do not understand the risks and benefits of technology, let alone interoperability. 91 Such gaps in foundational knowledge, he suggested, feed directly into resistance. 92 If public servants cannot see how a tool benefits them or their work, the default response is caution. 93

86 ibid.

87 ibid.

88 Interview with Roland van der Heijden, Chief Cityverse Officer, Municipality of Rotterdam (Rotterdam, 5 February 2025) 12-13.

89 ibid.

90 ibid.

91 Interview with Dr. Gege Gatt, CEO of EBO, AI and Interoperability Expert (Malta, 14 February 2025) 2.

92 ibid.

93 ibid.

In conclusion, trust and digital literacy are not outlying concerns but part of foundational issues of interoperability’s implementation as they are essential in digital systems’ struggle to be accepted by their users. In all five themes analysed, the find ings show a multifaceted relationship between the barriers. This suggests that implementing interoperable solutions requires a holistic and creative approach where the specificity of local realities’ capacities comes first, and technical support comes seco nd.

VI. Findings: Training Needs and Existing Initiatives

After reviewing the multifaceted issue of implementation barriers, this section explores examples of the current state of training, identifies specific skill issues, gaps, and highlighting effective approaches to be noted as promising practices for future training strategies.

A. Assessment of Current Training

The landscape of available training is fragmented. The Spanish Federation of Municipalities and Provinces’ Deputy Director acknowledged whilst the FEMP runs an annual training plan targeting technical skills., the challenge lies in “implementing technical retraining for active professional profiles”. 94 Making tools available to an existing workforce is inherently harder than onboarding new staff with fresh skills. 95

Rotterdam has adopted a different approach. Mr. Van der Heijden explained that they do not only offer training on interoperability. 96 Instead, they include interoperability concepts into the practical tasks staff already perform. 97 They asked themselves the following question: “how can interoperability help their work?” 98 This reframing, from abstract concept to practical tool, appears to lower resistance. 99

However, the Italian mayor took a more cautious view. He suggested that meaningful training will only emerge “when it will be possible to create real, more significant practical

94 Interview with José Luis Garrote Gonzales, Deputy Director of the Spanish Federation of Municipalities and Provinces (FEMP) (Madrid, 5 February 2025) 4.

95 ibid.

96 Interview with Roland van der Heijden, Chief Cityverse Officer, Municipality of Rotterdam (Rotterdam, 5 February 2025) 14.

97 ibid.

98 ibid.

99 Interview with Roland van der Heijden, Chief Cityverse Officer, Municipality of Rotterdam (Rotterdam, 5 February 2025) 17.

interoperability”. 100 For now, the deficits are less structural than informational: “for the data that are used, there is only a lack of adequate and continuous information on the available data sets and the methods of use; for the data that are made available to other subject s, there is only a lack of adequate and continuous information on the required structuring and on the cleaning and revision techniques”. 101

In some Member States, there is no need for more abstract training, but there is a need for basic and continuous guidance on how to structure and work with data daily.

B. Identified Training Needs

What essential competencies do public sector workers need? For Rotterdam’s Cityverse Chief Officer, the answer is practical, hands -on learning that answers a concrete question: “How can we make data available, because that can benefit them”. 102 Interoperability, in this view, is not the headline, but its results on improving public sector workers’ daily workflows.103

The expert identified literacy in artificial intelligence as a critical component. He emphasised that AI is not there to replace workers but to augment the capabilities that they have, which means training must be coupled with policy orientation, retrainin g, and the provision of hands-on training. Additionally, AI literacy to municipalities’ employees who are going through these particular programs. 104 In short, establishing AI tools without accompanying education is a method which is very unlikely to succeed.

The Italian mayor advocated for a broader skill set. He argues that “The processing of digital data and especially the digital management of activities require very different training within the public sector”, 105 he argued. The most valuable part, he said, is teaching staff how to structure procedures and the data that accompanies them. 106 Furthermore, he also insisted on involving “as many personnel as possible in the implementation phase”, but with an important safeguard: “the procedural and data structures are not independently customizable by

100 Interview with Andrea Cassani, Mayor of the Municipality of Gallarate (Gallarate, 2 January 2025) 2.

101 ibid 3.

102 Interview with Roland van der Heijden, Chief Cityverse Officer, Municipality of Rotterdam (Rotterdam, 5 February 2025) 12.

103 ibid.

104 Interview with Dr. Gege Gatt, CEO of EBO, AI and Interoperability Expert (Malta, 14 February 2025) 2.

105 Interview with Andrea Cassani, Mayor of the Municipality of Gallarate (Gallarate, 2 January 2025) 3.

106 ibid.

individual operators”. 107 Therefore, in his view, standardisation, in his view, is essential to prevent fragmentation.

C. Promising Practices

Despite these challenges, several promising practices emerged from the interviews. Rotterdam's collaboration with Tampere, Finland, illustrates the value of peer learning. 108 Mr. Van der Heijden explained: “They are further than we are on the development on citywide vision on what the Metaverse City first development could do. We are, I think, a step further than Tampere on the development of a digital infrastructure for your city and the governance construction that we've organized around it. So, there we try to learn from each other”. 109 The Budapest representative strongly advocated for this approach at the EU level, assigning to the EU the role of facilitator and “implement something which has been proven already successful in other Member States”, such as Estonia, Slovenia, and the Net herlands. 110 This reciprocal exchange, each municipality sharing its comparative advantage, creates mutual benefit, without wasting energy on trial and error. 111 He added that the EU should focus its assistance on bridging the gap between regional targets and implementation realities. 112

Dr. Gatt recommended starting with small, visible projects. He recommended implementing chatbots, automatic classifications for AI, AI for better allocation of resources in municipalities, reiterating that this does not result in job losses.113 He cites Helsinki as an example: after introducing their first AI chatbot, their municipality was able to answer 25% of resident queries overnight. This allowed employees to shift their focus on more strategic projects like urban planning. 114 Demonstrating immediate gains can build momentum and shift perceptions.115

Denmark offers another educational model. Dr. Gatt mentioned that the country set up a digital literacy academy. After they detected resistance to AI in their employees, they set up

107 ibid.

108 Interview with Roland van der Heijden, Chief Cityverse Officer, Municipality of Rotterdam (Rotterdam, 5 February 2025) 19.

109 ibid.

110 Interview with the Head of Representation of Budapest to the EU (Budapest, 7 March 2025) 2 -3.

111 ibid.

112 ibid.

113 Interview with Dr. Gege Gatt, CEO of EBO, AI and Interoperability Expert (Malta, 14 February 2025) 1.

114 ibid.

115 Alice Iordache, Chrysoula Mitta and David Osimo, ‘The Interoperability Imperative A Tale of Four Cities: How to Deliver Good Public Services to All European Citizens’ (Policy Brief, The Lisbon Council 2023).

the training, and now they have become 2000 advocates for AI. 116 Turning sceptics into advocates is an outcome that requires sustained investment and represents what we can consider as the ultimate test of a training programme's success. 117

D. The Interoperable Europe Academy and the Awareness Gap

The EU's institutional response to exactly the training deficit documented in this paper is the Interoperable Europe Academy, yet its absence from the interviews is itself a significant finding. The Academy, established under the sponsorship of DG DIGIT an d hosted on the EU Academy platform, offers over 34 free e - learning courses across 10 curriculum categories, covering the legal, semantic, organisational and technical dimensions of interoperability. 118 Its curriculum is aligned with the IEA and explicitly targets public servants engaged in digital transformation at all levels of government, from national administrations to local authorities. 119 The 2024 Academy event, co-organised with KU Leuven and attended by 150 participants in person, brought together public servants, policymakers and academics to deepen understanding of the IEA's practical implications.120

Despite this offer, the FEMP Deputy Director, a senior official of the Spanish federation of municipalities, an organisation representing thousands of local authorities, indicated in his interview that he was unfamiliar with the Academy's work. 121 This is a remarkable finding. The EU's flagship capacity -building initiative for interoperability is unknown to exactly the kind of intermediary organisation that should be channelling it to municipal practitioners. It points to a structural awareness gap that goes beyond individual knowledge: the Academy's outreach and dissemination strategy does not appear to be reaching sub-national and intermediary actors effectively. Addressing this gap, through partnerships

116 Interview with Dr. Gege Gatt, CEO of EBO, AI and Interoperability Expert (Malta, 14 February 2025) 2.

117 Nunzio Casalino, ‘Learning to Connect: a Training Model for Public Sector on Advanced E -Government Services and Inter-Organizational Cooperation’ (2024)7(1) iJAC 24; Vasiliki Margariti and others, ‘Assessment of Organizational Interoperability in e -Government: Α new model a nd tool for assessing Organizational Interoperability maturity of a public service in practice’ (ICEGOV 2020) (ACM 2020) 8.

118 Interoperable Europe Academy, ‘Courses and Curriculum’ (Interoperable Europe Portal) <https://interoperable-europe.ec.europa.eu/collection/interoperable -europe-academy/courses -curriculum\> accessed 12 June 2026.

119 ‘eLearning’ (Interoperable Europe Portal) <https://interoperable -europe.ec.europa.eu/collection/digital-skillspublic-sector/solution/interoperable-europe-academy/elearning\> accessed 12 June 2026.

120 Interoperable Europe Academy 2024 (KU Leuven, 11 –12 April 2024) <https://interoperableeurope.ec.europa.eu/collection/digital-skills-public-sector/solution/interoperable-europeacademy/event/interoperable -europe-academy-2024\> accessed 12 June 2026.

121 Interview with José Luis Garrote Gonzales, Deputy Director of the Spanish Federation of Municipalities and Provinces (FEMP) (Madrid, 5 February 2025) 4.

with national federations of municipalities, regional digital hubs, and organisations such as the Council of European Municipalities and Regions (CEMR), is as urgent a policy priority as the content of the training itself.

VII. Discussion

A. Integrating Empirical and Academic Findings

The interview findings align with much of the academic literature on interoperability barriers, while providing enhanced nuance. Existing research has already documented technical and semantic obstacles in detail. 122 The interviews contribute to a richer understanding of organisational cultural weight. Rotterdam’s Chief Cityverse Officer estimates that 75% of barriers are organisational or cultural, rather than technical. This highlights a point that academic research often overlooks; solving the human side of digital transformation is at least as important as solving the technical side. 123 These findings also show a refinement of existing theoretical frameworks on interoperability maturity. Standard maturity models tend to treat capacity as a function of technical infrastructure and legal alignment, with training appearing as a secondary enabler. 124 The empirical data here suggest the inverse: organisational and human factors are primary barriers, and technical solutions remain inert without the cultural and skills conditions to deploy them. This repositions training not as a downstream support activ ity but as a precondition for any meaningful progress along the interoperability maturity curve.

Legal challenges also appear more complex than the literature often suggests. Academics have documented GDPR compliance difficulties. 125 But the Italian mayor's critique

122 Anthony Jnr and others, A Framework for Standardization of Distributed Ledger Technologies for Interoperable Data Integration and Alignment in Sustainable Smart Cities’ [2023] 15 Journal of the Knowledge Economy 12053-12055; Rodriguez Müller, A. P. and Schade, S. Interoperability Assessments: Exploring expected benefits, effort and challenges , policy brief, European Commission (2024), Joint Research Centre, JRC137063 1,5.

123 Interview with Roland van der Heijden, Chief Cityverse Officer, Municipality of Rotterdam (Rotterdam, 5 February 2025), 11.

124 Rodriguez Müller, A. P. and Schade, S. Interoperability Assessments: Exploring expected benefits, effort and challenges , policy brief, European Commission (2024), Joint Research Centre, JRC137063; Yannis Charalabidis, Fenareti Lampathaki and Dimitris Askounis, 'A Comparative Analysis of National Interoperability Frameworks' (2010) 4(4) eJETA.

125 JMAP, Cestari, and others 2018. ‘A method to diagnose public administration interoperability capability levels based on Multi-Criteria Decision-Making’. International Journal of Information Technology & Decision Making 17 (1): 209–245; Sofia Terzi and Ioannis Stamelos, ‘Architectur al Solutions for Improving Transparency, Data Quality, and Security in eHealth Systems by Designing and Adding Blockchain Modules, While Maintaining Interoperability: The eHDSI Network Case’ (2024) 14 Health and Technology 451,459.

of an exaggerated privacy interpretation points to a cultural layer beyond the regulation itself. 126 When individual actors apply data protection rules far more restrictive than required, the result is a form of regulatory overreach that no policy change alone can fix. 127

1. The Importance of Training

Across all the interviews, training and capacity building emerged as indispensable. The Spanish Federation’s emphasis on peer-learning formats, 128 Rotterdam's focus on job-integrated training, 129 and Dr. Gatt’s call for AI literacy programs all converge on the same insight: training must be contextual, practical, and sustained. 130 The success stories such as Helsinki's chatbot, 131 and Denmark's academy, 132 demonstrate that well-designed training can do more than impart skills; it can transform attitudes, turning resistance into advocacy. 133 This suggests that training is not merely a support function but a strategic tool for digital transformation. 134 This insight is also reinforced by the European Commission’s approach to digital transformation policymaking, which aims to embed interoperability considerations structurally from the drafting stage, developing the Legislative Financial and Digital Statem ent (LFDS).

2. Implications for Policy and Practice

Several implications for policy and practice follow from the findings. Regarding data standardization, Mr. Van der Heijden insisted on open standards as the “backbone for interoperability”. 135 As it resonates with both academic literature and the Italian’s mayor's

126 Interview with Andrea Cassani, Mayor of the Municipality of Gallarate (Gallarate, 2 January 2025) 3.

127 ibid.

128 Interview with José Luis Garrote Gonzales, Deputy Director of the Spanish Federation of Municipalities and Provinces (FEMP) (Madrid, 5 February 2025) 3; Interview with Roland van der Heijden, Chief Cityverse Officer, Municipality of Rotterdam (Rotterdam, 5 February 2025) 14; Interview with Dr. Gege Gatt, CEO of EBO, AI and Interoperability Expert (Malta, 14 February 2025) 2.

129 Interview with Roland van der Heijden, Chief Cityverse Officer, Municipality of Rotterdam (Rotterdam, 5 February 2025) 14.

130 Interview with Dr. Gege Gatt, CEO of EBO, AI and Interoperability Expert (Malta, 14 February 2025) 2.

131 ibid 1.

132 ibid 2.

133 ibid 1-2.

134 Regulation (EU) 2024/903 of the European Parliament and of the council of 11 April 20224 laying down measures for a high level of public sector interoperability across the Union (Interoperable Europe Act) [2024] OJ L 2024/903, art 10; AP Rodriguez Müiler, and S Schade, ‘Interoperability Assessments: Exploring expected benefits, effort and challenges’ (Policy Brief, European Commission (2024), Joint Research Centre, JRC137063, 75.

135 Interview with Roland van der Heijden, Chief Cityverse Officer, Municipality of Rotterdam (Rotterdam, 5 February 2025) 6.

frustration with fragmented data systems. 136 It is clear that, without a common language, interoperability cannot be improved.

Regarding governance structures, the Italian mayor's observation that “there is currently no real collaboration” between administrative levels; as such, this “total absence of governance of interoperability” points to a structural void. 137 In short, technical solutions cannot fill that void; instead, clear roles, accountability mechanisms, and coordination structures are needed.

Concerning knowledge transfer, the Budapest representative called for a more proactive role in sharing successful experiences of frontrunner Member States. 138 The EU highlighted the representative should invest in peer-learning networks, platforms, and technical assistance programmes, that allow local municipalities to adapt solutions to their realities.

139 This approach shows multiple advantages, such as addressing the ‘double burden’ of local governments by reducing the cost and uncertainty of trying out new solutions alone.

140 This issue is worsened by the differences in administrative traditions across Member States. Dr. Benedek Javor stated, different EU Member States possess “completely different elements”, 141 complicating the project of having a unified European digital strategy unless local needs are addressed first. He argues that while EU digital targets are important, the real work consists in adapting them to national and local realities, and that an impo rtant part for everybody’s success is frontrunners sharing proven solutions with the realities that need more support.142

The findings are of relevance for the Interoperable Europe Board set up under Articles 15-17 of the IEA which is the main governance body for the implementation of interoperability across Member States. 143 The first-cycle agenda for the Board should prioritise three items that directly emerge from this research. First, the development of guidance specifically tailored to the capacity constraints of smaller and medium-sized municipalities, recognising that the IEA’s obligations fall on local authorities regardless of their resource base. Second, the establishment

136 Interview with Andrea Cassani, Mayor of the Municipality of Gallarate (Gallarate, 2 January 2025) 2.

137 ibid.

138 Interview with The Head of Representation of Budapest to the EU (Budapest, 7 March 2025) 2 -3.

139 ibid.

140 ibid.

141 Interview with Dr. Benedek Jávor, Head of Representation of Budapest to the EU (Budapest, 7 March 2025) 3.

142 ibid.

143 Regulation (EU) 2024/903 (Interoperable Europe Act) [2024] OJ L 2024/903, arts 20 -22.

of structured outreach to national and regional federations of municipalities such as FEMP in Spain and ANCI in Italy to ensure that capacity -building instruments, including the Interoperable Europe Academy reach sub -national practitioners; and third, the co-design of peer-learning mechanisms that allow frontrunner municipalities to share proven solutions with those at earlier stages of digital maturity, as called for by Dr Jávor in his interview. 144 Partnerships with organisations such as the Council of European Municipalities and Regions (CEMR), which represents over 110,000 local and regional authorities across 41 European countries, would provide a ready -made channel for exactly this kind of struc tured dissemination. 145

Although different inputs were given on the training theme, the FEMP's workshop format, 146 Rotterdam’s embedded approach, 147 and the AI expert’s emphasis on AI literacy 148 all reinforce a single takeaway: training that does not demonstrate immediate value to public sector workers will not be effective.

Lastly, the AI expert argued that the future of government needs to be distributed and more decentralized. Although the initial focus should remain on governance and policy, he highlights that extensive collaboration with academia, the private and public s ector is needed. 149 He noted that, at the moment, there is zero public sector participation in developing critical digital infrastructure, which represents both a risk and an opportunity. 150

A more fundamental question raised by the findings is whether the IEA’s current design addresses the double burden, or whether it implicitly assumes a level of municipal capacity that is not present in most Member States. The IEA's mandatory interoperabili ty assessment under Article 3 applies to all public sector bodies introducing new or substantially modified binding requirements for trans -European digital services, a category that includes many municipal digital projects. 151 Yet the compliance cost of conducting such assessments, integrating their results into procurement and governance processes, and aligning with the EIF's

144 Interview with The Head of Representation of Budapest to the EU (Budapest, 7 March 2025) 2 -3.

145 ‘Council of European Municipalities and Regions’ (CEMR) <https://ccre -cemr.org/who-we-are\> accessed 12 June 2026.

146 Interview with José Luis Garrote Gonzales, Deputy Director of the Spanish Federation of Municipalities and Provinces (FEMP) (Madrid, 5 February 2025) 3.

147 Interview with Roland van der Heijden, Chief Cityverse Officer, Municipality of Rotterdam (Rotterdam, 5 February 2025) 14.

148 Interview with Dr. Gege Gatt, CEO of EBO, AI and Interoperability Expert (Malta, 14 February 2025) 2.

149 ibid.

150 ibid.

151 Regulation (EU) 2024/903 (Interoperable Europe Act) [2024] OJ L 2024/903, art 12.

four-layer model falls equally on a well-resourced capital-city administration and a small municipality with a part-time IT officer. The IEA contains no tiered compliance mechanism, no explicit small- authority exemption, and no dedicated capacity fund. Unless these structural gaps are addressed, whether through Board guidance, targeted funding under the Digital Europe Programme, or delegated compliance arrangements, the risk is that the IEA’s formal obligations will be nominally met by larger administration s while remaining effectively unimplemented at the local level where most citizens interact with public services.

In sum, findings urge the need for practical training, embedded in daily work, and designed to demonstrate immediate value to the solution user. Most notable practices include Rotterdam’s work-integrated approach and Denmark’s digital academy, demonstratin g that training can deter scepticism, foster advocacy and support the cultural change essential for digital transformation.

VIII. Conclusion

This article sought to identify the challenges of implementing interoperability in EU municipalities, with particular attention to the knowledge and skill gaps facing public sector workers. The findings show an intricate picture in which technical barriers , especially data standardisation and legacy system integration, which intersect with legal complexities and deep-rooted organizational and cultural resistance. The ‘double burden’ on local administrators encompasses not only resource constraints but also fear of job loss, wariness of transparency, and reluctance to be held accountable.

Training and skill-building are essential to overcoming these barriers, but they must be designed strategically. Practical, work -integrated training that demonstrates how interoperability simplifies rather than complicates professional tasks. The promising practices identified, including peer learning between cities, small -scale pilot projects, and programmes that convert sceptics into advocates, offer actionable pathways forward.

For the EU to achieve its Digital Decade targets, including the online availability of all key public services by 2030, attention must shift from high -level policy frameworks to the local realities where implementation occurs. This requires a steady investment in training, governance structures that enable collaboration, and a persistent focus on the human factors that ultimately determine the success or failure of interoperability’s implementation.

Ultimately, interoperability will succeed not on technical excellence alone, but on whether the people who use it experience it as a help rather than a hindrance. 152

Several concrete recommendations follow from this analysis. First, the Interoperable Europe Board should provide guidance specifically tailored to municipalities, acknowledging the double burden and providing proportionate compliance pathways for smaller a uthorities. The second point is that the Interoperable Europe Academy should have a curriculum strand co-designed with the Council of European Municipalities and Regions (CEMR), where training is adapted to local realities and actively disseminated through municipal networks, rather than self-discovery. Thirdly, future funding cycles should be conditional on the completion of baseline training for the staff implementing interoperability -related digital investment in national recovery and resilience plans.

This study has several limitations that future research should address. The sample of five interviewees, while sufficient for exploratory qualitative research, limits generalisability. The selection skews towards urban and relatively well -resourced administrations; Rotterdam, Budapest, and the FEMP all represent larger or capital - level entities and include no rural or peripheral municipalities where the double burden is likely most acute. Nordic and Baltic frontrunner administrations, notably Estonia, Finland, and Denmark, are referenced through the accounts of others but were not interviewed directly; their perspectives on what successful implementation requires would substantially enrich the picture. Finally, the IEA's implementation is still at an early s tage: longitudinal monitoring of municipal compliance rates, training uptake, and interoperability outcomes over the next three to five years will be essential to assess whether the Act's ambitions translate into operational reality at the local level .

152 AP Rodriguez Müller, and S Schade, ‘Interoperability Assessments: Exploring Expected Benefits, Effort and Challenges’, (Policy Brief, Joint Research Centre 2024) JRC137063, 16,73; Interview with Roland van der Heijden, Chief Cityverse Officer, Municipality of Rotterdam (Rotterdam, 5 February 2025), 14.

Research Analysis on the Level of Interoperability of the Romanian Public System: A Case Study

of the Ministry of Economy, Digitalization, Entrepreneurship and Tourism

By Alessia Mărtinaș,(a) Mihai Fala,(b) Meraal El-Satieha,(c) and Lamia Eid (d)

Abstract

This exploratory policy paper investigates the state of digital interoperability within Romania’s public administration, with particular focus on the Ministry of Digitalisation, Economics, Entrepreneurship and Tourism, against the backdrop of Regulation (E U) 2024/903 (the Interoperable Europe Act, IEA).

Three questions guide the investigation:

1. What is the current level of digital interoperability within Romania’s public administration, as perceived by ministry staff?

2. What structural, governance, and technical barriers do they identify?

3. Which EU best practices, aligned with the IEA, are transferable to the Romanian context?

The study employs a mixed -methods approach combining a pilot survey (N=8 respondents drawn from across ministry departments through voluntary convenience sampling) with desk research drawing on European Commission, OECD, and NIFO assessments. Given the small and non-representative sample, survey data are treated as illustrative qualitative themes rather than statistically representative findings.

Respondents identified severe interoperability deficits: digital collaboration between ministries was rated 5.25/10, system interoperability at 4.6/10, and the legal framework governing data transfer at only 4.4/10. All eight respondents identified cross -ministry data exchange as the area most affected. These findings align with the gaps that Art. 3 IEA (interoperability assessment) is designed to surface, and with the governance -coordination mechanisms established in Art. 17, which requires Member States t o designate authorities and single points of contact to support cross -administrative and cross -border cooperation.

(a) L.L.B. Candidate, International and European Law Programme, The Hague University of Applied Sciences.

(b) L.L.B. Candidate, International and European Law Programme, The Hague University of Applied Sciences.

(c) L.L.B. Candidate, International and European Law Programme, The Hague University of Applied Sciences.

(d) L.L.B. Candidate, International and European Law Programme, The Hague University of Applied Sciences.

Comparative analysis examines Luxembourg’s GovTech Lab, the Netherlands’ Common Ground initiative, and France’s DINUM and Cloud de Confiance model as benchmarks. Three recommendations are proposed:

1. Establishing a public-private GovTech Partnership Programme

2. Implementing common open data standards and shared APIs

3. Developing a unified governmental cloud with an embedded digital identity system

I. Introduction

The purpose of this report is to investigate the current level of interoperability within Romania’s public administration, with a focus on the Ministry of Digitalisation, Economics, Entrepreneurship and Tourism, following three questions to help guide the research:

i. What is the current level of digital interoperability within Romania’s public administration, as perceived by ministry staff?

ii. What structural, governance, and technical barriers impede progress towards a coherent digital ecosystem as required by the IEA?

iii. Which EU best practices, that are aligned with the IEA, are transferrable to the Romanian context?

This study has employed a layered mixed-method approach to explain interoperability between ministries and subordinated institutions and with the private sector. Over two weeks, our team surveyed employees of the Romanian Ministry of Digitalisation, Economics, Entrepreneurship, and Tourism to identify challenges and levels of expertise regarding institutional interoperability.

The goal was to understand both the professional context of respondents and their perspectives and experiences on digital collaboration and interoperability within the Ministry and other institutions. By analysing these perspectives, we sought to identify gaps and strengths in current practices. This information allowed us to provide tailored advice and recommendations for enhancing the interoperability of the Romanian public administration in line with the requirements set by the Interoperable Europe Act ( IEA) (Regulation (EU) 2024/903).

II. Methodology

This survey is best understood as an exploratory pilot study. The primary empirical instrument was a structured survey of approximately 40 questions, combining open -ended responses, limited-choice items, rating scales (out of 10), and yes -or-no questions. The questionnaire covered respondents’ professional background, experience, familiarity with digital tools and systems, and views on interoperability and AI integration.

The survey was conducted via Microsoft Forms over a two -week period. Microsoft Forms collects only the responses themselves, the date and time of survey initiation (not completion), and the respondent’s position within the ministry. No names, email address es, or other directly identifying personal data were collected or stored. The survey link was distributed informally within the ministry departments by a contact familiar with the research team’s work. Participation was entirely voluntary and optional, wit h no tracking of who received the invitation (making a formal calculation rate of responses impossible), making the sampling strategy best characterised as voluntary convenience sampling.

Eight (8) complete responses were received. While the sample is small, it does offer representation across different functional areas of the ministry, including public communications, institutional visual identity, inter-departmental data transfer, and IT, which partially compensates for the limited number of responses by way of departmental diversity.

As for ethical considerations, no consent form was administered separately as voluntary completion of an anonymous survey of this nature is widely regarded as constituting implied informed consent; also, no sensitive personal data categories as defined by Art. 9 GDPR were collected. 1

Responses were converted into numeric summaries (percentages for binary/multiplechoice items; averages out of 10 for rating scales) and combined with desk research drawing on European Commission, OECD, and NIFO reports to contextualise and validate the qualitative themes that emerged. Throughout the analysis, raw response counts are reported alongside percentages (e.g. “7 of 8 respondents”) to maintain transparency about the small sample size. Findings are presented as recurring qualitative themes rather t han statistically representative conclusions. Readers should interpret all percentages with caution: with n=8, a single response shifts percentages by 12.5 points, meaning the difference between 87.5% and 75% is one response.

A. Limitations

There are several important limitations to be aknowledged. First, the sample of eight respondends is not statistically representative of Romania’s public administration or even of

1 Regulation (EU) 2016/679 of The European Parliament and of The Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Da ta Protection Regulation) [2016] OJ L 119/1.

the ministry, therefore findings cannot be generalised beyond the specific respondents. 2 Second, the convenience and voluntary nature of sampling introduce self -selection bias, meaning estimates could be biased. 3 Third, as mentioned earlier, the absence of a defined invitation list means no response rate can be calculated. Fourth, because the survey was conducted in a single ministry over two weeks limits institutional perspectives. The findings should be read as indicative qualitative data warranting further investigation through largerscale, systemically sampled research.

III. Empirical Findings

A. Profile of Respondent

The eight (8) survey respondents are workers primarily in public communication, institutional visual identity, inter-departmental data transfer, and IT. A recurring theme across respondents was significant work experience: 4 of 8 respondents had 6 -10 years of work experience, 2 of 8 had over 10 years, and the remaining 2 had fewer than 5 years of publicsector experience. This spread provided perspectives from both seasoned professionals and newer employees navigating digital systems. A strong qualitative t heme was comfort and familiarity with digital tools: all 8 respondents reported using digital tools regularly and finding them useful in their line of work.

Regarding training, 4 of 8 had participated in courses on digital tools. Among those who had received training, the majority received from their employer, while others sought it independently. However, only 3 of 8 respondents reported participating in trai ning irregularly, and 1 of 8 had never received any digital training, suggesting that gaps in systematic skill development are a recurring concern, which are directly relevant to the IEA’s requirements for Member States.4

B. Current Digital Landscape

2 Andrade C, ‘The Inconvenient Truth About Convenience and Purposive Samples’ (2020) 43 Indian Journal of Psychological Medicine 86, 88 (Take -Home Message).

3 Bethlehem J, ‘Selection Bias in Web Surveys’ (2010) 78 International Statistical Review 161, 162; “Unfortunately, many web surveys rely on self-selection of respondents instead of probability sampling. This has serious impact on the quality of survey results. The theory of probability sampling cannot be applied, and estimates are often substantially biased.”.

4 Authors’ own survey, Evaluarea nivelului de interoperabilitate digitală și a implementării Actului privind Europa Interoperabilă în cadrul Ministerului Economiei, Digitalizării, Antreprenoriatului și Turismului din România (Den Haag, October 2025).

Regarding the use of tools, all 8 respondents used Microsoft Office, 5 of 8 used institutional platforms, 4 of 8 used Google Apps, and 3 of 8 used AI tools. However, the challenges they face are significant; 7 of 8 (87.5%) identified both technical problem s and low interoperability between institutions are major obstacles. Additionally, 4 of 8 respondents mentioned the lack of proper instructions for using systems. 5 Moreover, respondents rated their institution's digitalisation level quite modestly, with 4 of 8 giving it a score of 5 out of 10, meaning they see their organisations as only halfway digitalised. This is particularly striking given that 6 of 8 (75%) rated the importance of digitalisation as a perfect ten, revealing a persistant gap between what is needed and what exists in reality. 6

C. Benefits, Risks, and AI Integration

Despite the challenges, respondents overwhelmingly recognised the benefits of digitalisation. All 8 respondents identified faster document processing, reduced bureaucracy, and fast information access as key advantages. Additionally, 7 of 8 (87.5%) of respo ndents reported improvements in institutional collaboration and service optimisation as important benefits, whilst 6 of 8 (75%) highlighted better transparency and resource savings. 7

This Graph represents what the most visible benefits of digitalisation are in the respondent's view, such as faster informati on access and reduced bureaucracy.

Conversely, cybersecurity and GDPR concerns topped the list of disadvantages at of all 8 respondents (100%), followed by a lack of standardisation among institutions and digital dependency (6 of 8, 75%). Regarding training, 5 of 8 respondents (62.5%) worr ied about both inadequate employee training and the potential exclusion of disadvantaged groups, showing awareness of equality issues. When asked about AI integration, 5 of 8 (62.5%) partially agreed

5 ibid.

6 ibid.

7 ibid.

with using AI for data collection and processing, indicating that AI is gradually being incorporated into the process. The areas where AI is seen as most useful are in facilitating business dialogue, document administration, and workflow automation. 8

2

This Graph represents what the most apparent concerns and risks are in the respondent's view, for example, cybersecurity concerns and lack of standardization.

D. The Interoperability Challenge

Interoperability means how well different public institutions’ digital systems can connect, share data, and work together without technical or organisational barriers. This is where the survey revealed the most critical issues. Respondents rated digital co llaboration between ministries at just 5.25 out of 10, and interoperability of digital systems at even lower 4.6 out of 10, indicating that current systems barely communicate effectively with each other. When asked about common standards (shared rules for how data is formatted, exchanged, and interpreted so all institutions systems can communicate in the same way) for data exchange, 5 of 8 respondents said standards exist but don't cover everything, while 3 of 8 believed there are no common standards at all. 9

8 ibid. 9 ibid.

3

This Graph shows that respondents believe there are significant issues with current digital processes, meaning that while digitalisation is moving forward, it is notbeing implemented effectively or in a well-planned manner, with many areas lagging.

E. Barriers to Collaboration

The barriers to collaboration were a prominent qualitative theme: 7 of 8 (87.5%) of respondents identified a lack of common platforms and delays in obtaining information from other institutions as major problems. Six of 8 respondents cited a lack of common standards for data exchange, and 5 of 8 (62.5%) pointed to technological incompatibility, unclear institutional responsibilities, poor hierarchical communication, and absence of unified legal frameworks. Notably, all of the 8 respondents said data exchang e with other ministries and collaboration with local authorities are the areas most affected by poor interoperability, 10 which is directly relevant to the Interoperability Assessment obligations established under Art. 3 of the IEA.

Figure 4

This Graph indicates what respondents believe to be the greatest barriers to effective collaboration (such as great delays in information sharing) between ministries and even departments.

F. Institutional Mergers and Memory

During institutional reorganisations, respondents described merger processes as lengthy, difficult, and poorly structured, with data transfer management rated at just 4.75 out of 10. Integration of digital platforms scored even lower at 4.1, meaning merger s typically involve significant technical chaos. The obstacles are consistent: 7 of 8 respondents (87.5%) cited inompatible IT platforms and absence of clear migration plans, while 6 of 8 (75%) mentioned insufficient resources, lack of qualified personnel, and bureaucratic delays.11

G. Support and suggestions

Respondents are clear about what support they need; all respondents called for better logistical support (equipment and connectivity), while approximately 7 of 8 identified technical, legal, financial, and training support as equally critical. The legal fr amework for data transfer was rated poorly at 4.4 out of 10, meaning current regulations are seen as unclear and difficult to apply consistently. Suggested improvements are centred on creating unified platforms, ensuring political will backed by adequate r esources, standardising processes and data formats, and investing in both technology and training. The message is clear: interoperability isn't just a technical problem; it requires coordinated legal, organisational, and financial solutions.12

IV. Gaps and challenges

This section, based on desk research and recent assessments from the European Commission’s Digital Decade Report, 13 the OECD Digital Government Review, 14 and NIFO’s interoperability analyses,15 shows that Romania’s progress toward an interoperable digital public administration continues to be shaped by several factors. These include structural, governance, and technical constraints, and recurring weaknesses that limit the country’s ability to advance digital transformation at the required pace. These shortcomings are also directly relevant to Romania’s obligation under the IEA, which established requirements for interoperability assessment, governance coordination, and capacity -building that the gaps below demonstrate have not yet been met.

11 ibid.

12 ibid.

13 European Commission, Digital Decade Country Report: Romania 2024 (European Commission 2024).

14 OECD, Digital Government Review of Romania (OECD Publishing 2023).

15 National Interoperability Framework Observatory (NIFO), Interoperability Assessment: Romania 2024 (European Commission 2024).

A. Structural Gaps

Romania's public sector faces a persistent shortage of up -to-date ICT infrastructure, which limits its capacity for interoperability. 16 This is confirmed by the pilot survey, public servants rating the interoperability of their digital systems at just 4.6 out of 10. The core problem is a lack of common platforms and technically incompatible systems, issues cited by 7 of 8 respondents. Th is lack of infrastructure directly hinders the ability to meet Europeanlevel requirements, a challenge made clear by the fact that all respondents identify data exchange with other ministries as the area most affected.

While Romania has strong broadband connectivity, other critical components are underdeveloped. 17 The situation is most present during institutional mergers, where the survey showed that integration of digital platforms scores a low 4.1 out of 10. This creates a significant gap between what is desired and what the reality is: while 6 of 8 of civil ser vants see digitalization as very important (10/10), half rate their own institution’s level of digitalisation at only 5/10, highlighting the urgent need for more cohesive infrastructure. 18 Such gaps could be easily surfaced via an interoperability assesment under Article 3 IEA, and because of lack of such assesments, Romania’s ministries and public bodies function with great discrepancies as identified by ministry staff. 19

B. Institutional and Governance Challenges

The OECD notes that governance fragmentation is one of Romania’s most significant obstacles, a finding strongly supported by the experiences of public servants surveyed. 20 The lack of a single institution coordinating interoperability across the administration leads to operational chaos. Survey respondents identified: 7 of 8 a lack of common platforms (87.5 per cent) and 5 of 8 unclear institutional responsibilities (62.5 p er cent) as major barriers to collaboration, directly reflecting the consequences of dispersed mandates. 21

16 OECD (2023), Digital Government Review of Romania: Towards a Digitally Mature Government, OECD Digital Government Studies, OECD Publishing, Paris, < https://doi.org/10.1787/68361e0d-en> accessed 27 March 2026, page 96.

17 ibid, page 12.

18 European Commission, Digital Decade Country Report: Romania 2024 (European Commission 2024).

19 Regulation (EU) 2024/903 of the European Parliament and of the Council of 13 March 2024 laying down measures for a high level of public sector interoperability across the Union (Interoperable Europe Act) [2024] OJ L 903, art 3.

20 OECD (2023), Digital Government Review of Romania: Towards a Digitally Mature Government, OECD Digital Government Studies, OECD Publishing Paris, < https://doi.org/10.1787/68361e0d-en> accessed 27 March 2026, 12.

21 ibid 13.

Furthermore, the constant restructuring of the executive power contributes to overlapping mandates and inconsistent priorities. 22 This instability is clearly illustrated during institutional mergers, which respondents described as lengthy and poorly structured, rating the integration of digital platforms at a very low 4.1 out of 10. The primary obstacles cited were incompatible IT platforms and an absence of clear migration plans by 7 of 8 (87.5 per cent), showing how political volatility disrupts technical coherence.

This governance fragmentation leads to uneven implementation of Romania’s numerous digital strategies. The result is a system where digital collaboration between ministries is rated at just 5.25 out of 10, and projects remain vulnerable to leadership chang es rather than being guided by a long-term vision. 23 The overwhelming consensus from the ground is that interoperability requires coordinated legal, organisational, and financial solutions, signalling that strategic success depends on first fixing the fractured governance model. 24 This is the governance problem that Chapter III of the Interoperable Europe Act is designed to resolve, by requiring each Member State to designate a national competent authority with a clear and permanent mandate to coordinate interoperability implementa tion, providing the institutional continuity that Romania's current model lacks. 25

C. Technical and Implementation Barriers

Technical assessments show that Romanian public institutions lack common data models and metadata catalogues, which are essential for standardized data exchange. 26 This diagnosis is confirmed by the survey, where public servants report severe operational challenges: they rated the interoperability of their digital systems at just 4.6 out of 10. The resulting complexity leads 7 of 8 (87.5 per cent) of respondents to identify technological incompatibility and a lack of common platforms as major obstacles.

Although Romania has adopted a national interoperability framework, its implementation remains limited. 27 This gap between policy and practice is visible in the survey data: respondents rated the clarity and applicability of the legal framework for data transfer at

22 ibid 12.

23 ibid 12.

24 ibid 13.

25 Regulation (EU) 2024/903 of the European Parliament and of the Council of 13 March 2024 laying down measures for a high level of public sector interoperability across the Union (Interoperable Europe Act) [2024] OJ L 903, Chapter III Support Measures.

26 ibid 17.

27 ibid 19.

only 4.4 out of 10. 28 All respondents identified data exchange with other ministries as the area most affected by poor interoperability, demonstrating that these technical and regulatory shortcomings are fundamentally hindering the creation of a coherent digital ecosystem. 29

Article 7 of the Interoperable Europe Act offers a practical pathway here; rather than designing solutions from scratch, public sector bodies can draw on expert -developed, EUvalidated interoperability tools published on the Interoperable Europe Portal, wh ich in turn reduces both implementation risk and the burden on already stretched internal capacity. 30

V. Comparative Analysis: EU Best Practices

In mapping models relevant to the Romanian public sector, three European initiatives stand out: Luxembourg’s GovTech Lab, the Netherlands’ Common Ground under its Digital Government Agenda, and France’s secure digital infrastructure through DINUM and Cloud de Confiance. These examples demonstrate how the government can combine innovation, secure and unified infrastructure, and promote efficiency and inclusiveness in the public sector.

A. Luxembourg- GovTech Lab

GovTech Lab, launched in 2020 by the Ministry for Digitalisation (“MDIGI”) and the Government IT Centre (“CTIE”), connects governments, start -ups, and academia to collaborate on digital public services. 31 The Lab operates through an open innovation model, seeking solutions to real challenges facing the ministries. The model provides private innovators with the opportunity to submit proposals that address government needs. 32 The winning candidates go through a multi-stage procurement process; if successful, full deployment is offered by the CTIE. 33 More specifically, GovTech encompasses a wide range

28 Authors’ own survey, Evaluarea nivelului de interoperabilitate digitală și a implementării Actului privind Europa Interoperabilă în cadrul Ministerului Economiei, Digitalizării, Antreprenoriatului și Turismului din România (Den Haag, October 2025).

29 ibid.

30 Regulation (EU) 2024/903 of the European Parliament and of the Council of 13 March 2024 laying down measures for a high level of public sector interoperability across the Union (Interoperable Europe Act) [2024] OJ L 903, art 7.

31 ‘Accelerating public services innovation – Launch of the GovTech Lab and its first call for solutions: Bye Bye Robots!’ (Minstere de la Digitalisation, 26 November 2020) <https://gouvernement.lu/en/actualites/toutes_actualites/communiques/2020/11 -novembre/26-hansengovtechlab.html> accessed 27 May 2026.

32 OECD (2023), Digital Government Review of Romania: Towards a Digitally Mature Government, OECD Digital Government Studies, OECD Publishing, Paris, < https://doi.org/10.1787/68361e0d-en> accessed 20 October 2025.

33 Ministry of Digitalisation (Luxembourg), GovTech Lab Luxembourg (The Luxembourg Government, 19 August 2025) <https://gouvernement.lu/en/dossiers.gouv2024_mindigital+en+dossiers+2021+govtechlab.html> accessed 27 May 2026.

of actions aimed at making the public sector more innovative to enhance the technological functionality of public services. 34

The Lab also utilises a programme called ‘SpeedUP’ for shorter, more focused solutions, such as rapid legal analysis, thereby facilitating high -risk innovation and tactical experimentation. 35 In addition, the Lab builds a community of public servants and innovators through various events, including hackathons, and seminars. 36

Relevance for Romania: The Luxembourg model illustrates how a platform supported by public institutions and open to private innovators can accelerate the digital transformation. Romanian municipalities may adopt GovTech Lab model as a way to enable risk-managed experimentation and reduce gaps in procurement.

B. The Netherlands - Common Ground & The Digital Government Agenda

The Netherlands’ Common Ground initiative is led by the Ministry of the Interior and Kingdom Relations (‘BZK’) and the Association of Dutch Municipalities (‘VNG’). The initiative aims to recreate government IT systems based on shared data and modular architecture. 37 The strategy focuses on four main areas: first, unified data in Dutch municipalities, second, the use of open APIs, thereby reducing data duplication, third, reusing services and components, and fourth, decentralized data storage and keeping data with the source institution. 38

A crucial dimension of the programme is institutional collaboration and clear governance with an open architecture, which brings cohesion. 39 The initiative promotes trust and transparency through standardized data management, byreducing repeated data entry and other administrative inefficiencies. The strategy demonstrates improvement in interoperability across over 300 Dutch municipalities by storing data uniformly, separating the data

34 ibid.

35 ‘SpeedUP’ (GovTech Lab Luxembourg) <https://govtechlab.public.lu/en/call -solution/speedup.html> accessed 27 May 2026.

36 OECD (2022), Digital Government Review of Luxembourg: Towards More Digital, Innovative and Inclusive Public Services , OECD Digital Government Studies, OECD Publishing, Paris, <https://doi.org/10.1787/b623803d-en> accessed 05 November 2025.

37 ‘Visie op Common Ground’ (Shift2) < https://en.shift2.nl/visie-op-common-ground> accessed 20 October 2025.

38 ibid.

39 ibid.

management from the specific administrative processes, and maintaining data at the source, rather than storing it in multiple institutions.40

Relevance for Romania: The Common Ground’s architecture shows how open standards and shared models can boost collective efficiencies. Therefore, a balanced approach with a layered data architecture for data exchange in public organizations enhances interoperability.

C. France - DINUM & Cloud de Confiance

France’s Direction interministérielle du numérique (DINUM) promotes cooperation across ministries while emphasising digital sovereignty, IT security, and data protection. 41 The two main pillars are FranceConnect and the Cloud de Confiance policy. 42 FranceConnect is a unified digital identity system that enables citizens and businesses to authenticate with multiple public services through a single interface. 43 Services include applying for health insurance, declaring income, paying taxes.44 Cloud de Confiance ('trusted cloud’) is a label issued by the French government to non- European services of high technical and legal security. 45 The Cloud de Confiance enables enhanced security protocols to protect sensitive data from cyber threats and external intrusions. 46 Moreover, Cloud de Confiance provides enhanced protection against extraterritorial regulations, including the US Cloud Act, which enables authorities to retrieve data stored on international servers. France is the first European country to protect its dat a from foreign interference. 47

The strategy enhanced policy coherence and created a strong alignment with the objectives of the Interoperable Europe Act, including security and reusability. 48 It has demonstrated the value of a centralized coordination entity and investment in EU -compliant

40 ibid.

41 ‘Stratégie numérique de l'État’ (Direction interministérielle du numérique (DINUM)) <https://www.numerique.gouv.fr/numerique -etat/#strategie> accessed 27 May 2026.

42 ibid.

43‘Connect to a website with FranceConnect’ (Interministerial Delegation for the Reception and Integration of Refugees (DIAIR)) <https://refugies.info/en/procedure/62a75a0bf5a766b75fd10318> accessed 27 May 2025.

44 ibid.

45 ‘France: New Label “Cloud de Confiance”’ (Trusted Cloud) (Digital Policy Alert, 17 May 2021) <https://digitalpolicyalert.org/event/639-new-label-cloud-de-confiance-trusted-cloud> accessed 27 May 2026.

46 Wilfried Kirschenmann, ‘From Cloud Souverain to Cloud de Confiance: a political definition of clouds’ (ANEO, 13 May 2024) <https://www.aneo.eu/en/blog/cloud -souverain-cloud-de-confiance> accessed 27 May 2026.

47 ibid.

48 European Commission, ’France 2023 Digital Public Administration Factsheets’ (Interoperable Europe Portal, 2023) <https://interoperable-europe.ec.europa.eu/sites/default/files/inline -files/DPAF_Annex_2023_France_vFINAL.pdf> accessed 27 May 2026.

cloud infrastructure. 49 Furthermore, France was ranked 12th among the EU leaders in the 2022 Digital Economy and Society Index (“DESI”) for digital public services. 50

Relevance for Romania: The model aligns the national digital transformation strategy across all ministries. A national-level control, such as DINUM, can promote interoperability while also preserving sovereignty.

VI. Recommendations

After processing the empirical data gathered from the Ministry and identifying the gaps in the Romanian public system, the main priority concerning digital transformation is the development of the technological infrastructure for the public system, along w ith the coordination of data transfer between institutions.

In achieving our purposes, we looked at the overall level of development of the private IT sector within the Romanian market. Given Romania’s reputation for its policies on taxation, it is often the case that numerous tech -oriented Start-ups choose to incorporate under Romanian legislation. 51 Having one of the most competitive rates in Europe, Romania’s tax regime registered a corporate income tax rate of 16 per cent, along with additional financial incentives for IT Start-ups, such as reduced taxes on revenues for companies with annual revenu es of up to 500,000 EUR – 1 per cent and 3 per cent for companies with one full- time employee and or no employees, respectively. 52 Furthermore, since Law No. 22/2022 was passed four years ago, introducing the concept of ‘digital nomad’ in Romania, an increasing number of digital nomads have chosen to relocate through a temporary residence visa due to Romania’s high -speed internet infrastructure and affordable living costs. 53 However, it is rare that partnerships between the public and private sectors are leveraged for technology advancements within Romania’s public system.

49 ibid.

50 ‘Interregional Report on Regional Context Analysis’ (CODIL, October 2024) <https://www.interregeurope.eu/sites/default/files/2024 -10/CODIL_Interregional_report_2024.pdf> accessed 5 November 2025.

51 EkoNews Team, ‘România, hub emergent pentru IT și tehnologie’ (Tech Romania, 25 September 2025) <https://techromania.ro/tech-romania/romania-hub-emergent-pentru-it-si-tehnologie/> accessed 24 March 2026.

52 Accounting studio, ‘Romania IT Companies Taxes in 2025’ (Accounting Studio, 3 January 2025) <https://en.accountingstudio.ro/2025/01/03/romania -it-companies-taxes/> accessed 24 March 2026.

53 ‘“Digital Nomads” in Romania” (Global Law Experts, 1 March 2025) <https://en.accountingstudio.ro/2025/01/03/romania-it-companies-taxes/> accessed 24 March 2026.

As such, through our recommendations, we aimed to tailor digital-ready measures that would fit with the necessities of a fast-paced and continuously transforming system, namely faster processing and transfer of information, collaboration between institutio ns and the private sector, and better preservation of the institutional memory. Additionally, when drafting the proposed solutions, we looked at the alignment with the principles and standards set by the European Commission in the new EU interoperability g overnance framework established by the Interoperable Europe Act (Regulation (EU) 2024/903). 54 Furthermore, for the purposes of this research, the Interoperable Europe Academy was a valuable tool in developing the recommendations’ practical steps by strengthening interoperability skills within public administrations through courses on interoperability, digital government, open data, and digitalready policymaking. 55 The following recommendations are grounded in Articles 15 -17 of the Interoperable Europe Act (Regulation (EU) 2024/903), establishing requirements for interoperability assessments, the reuse and sharing of interoperable solutions, and participation in structured Union-level interoperability cooperation mechanisms. 56 As such, we aimed to facilitate dialogue between the public and private sectors, foster innovation, and accelerate the development process by introducing fair competition practices, in line with Article 107 of the Treaty on the Functioning of the European Union (TFEU, State Aid) 57 and Directive 2014/24/EU governing public procurement procedures. 58

A. Collaboration with external partners

Following Luxembourg’s approach to interoperability, 59 the first recommendation focuses on building the collaboration between the public institutions, in particular the Ministry of Digitalization, Economics, Entrepreneurship, and Tourism, and the Ministry of Investment and European Projects, and the private s ector.

54 Regulation (EU) 2024/903 of the European Parliament and of the Council of 13 March 2024 laying down measures for a high level of public sector interoperability across the Union (Interoperable Europe Act) [2024] OJ L 2024/903.

55 ‘Interoperable Europe Academy’ (European Commission) <https://interoperableeurope.ec.europa.eu/collection/interoperable -europe-academy> accessed 13 June 2026.

56 Regulation (EU) 2024/903 of the European Parliament and of the Council of 13 March 2024 laying down measures for a high level of public sector interoperability across the Union (Interoperable Europe Act) [2024] OJ L 2024/903, arts 15–17.

57 Consolidated Version of the Treaty on the Functioning of the European Union [2012] OJ C326/47, art 107.

58 Directive 2014/24/EU of the European Parliament and of the Council on public procurement and repealing Directive 2004/18/EC [2014] OJ L94/65.

59 ‘GovTech Lab Luxembourg’ (Luxembourg Government Ministry for Digitalisation, 8 December 2025) <https://gouvernement.lu/en/dossiers.gouv2024_mindigital+en+dossiers+2021+govtechlab.html> accessed 25 March 2026.

A first step toward facilitating collaboration is creating the legal and strategic foundation by establishing a national ‘GovTech Partnership Program’ coordinated by the Digitalization Department. 60 The program would be launched as a national strategy, available to all tech companies with a presence in the Romanian market. Although the initiative has previously been proposed in the public space as a Public -Private Partnership (PPP), the governmental initiative has faced several unsuccessful attempts. These difficulties are largely attributed to limited expertise in the preparation and management of PPP projects. As a result, the initiative remains a relatively new area within the Romanian public syste m and may still benefit from further development and improvement. 61 However, recent reviews of the projects, along with the expertise of external actors, such as OECD and the European PPP Expertise Centre, could facilitate a more efficient application of the initiative. 62

In the implementation of the first step, the following actions would be taken by the Ministry of Economy, Digitalization, Entrepreneurship and Tourism, as the leading institution, supported by and in partnership with the Ministry of Investment and European Projects (MIPE), the Authority for the Digitalization of Romania (ADR), the M inistry of Finance, and the Competition Council:

a) The adoption of a National GovTech Partnership Strategy through a Government Decision

b) The creation of a National GovTech Partnership Program coordinated by the Ministry of Economy, Digitalization, Entrepreneurship, and Tourism (MEDAT)

c) The establishment of an interministerial steering committee involving the Ministry of Economy, Digitalization, Entrepreneurship, and Tourism (MEDAT) as the main coordinator, the Ministry of Investment and European Projects (MIPE), the Authority for the Digitalization of Romania (ADR), the Ministry of Finance, and representatives of the private sector and academia, as supporting institutions and parties.

60 European Commission, Guidance on the Introduction of Public -Private Partnerships in Romania (25 October 2024) <https://reforms -investments.ec.europa.eu/technical-support-instrument-0/competitiveness/guidanceintroduction-public-private-partnerships-romania_en> accessed 25 March 2026.

61 ibid.

62 ‘European PPP Expertise Centre (EPEC)’ (European Investment Bank) <https://www.eib.org/en/products/advisory-services/epec/index> accessed 25 May 2026.

d) The development of practical guidelines for public -private cooperation in GovTech projects, based on OECD and European PPP Expertise Centre’s best practices.

Key Performance Indicators (KPIs):

1. The adoption of the GovTech Strategy within six months through a Government Decision.

2. The establishment of the steering committee within six months.

3. A minimum of fifty Romanian tech companies registered in the program during the first year after the official launch of the program.

4. Publication of a national GoTech cooperation practical guideline within the first year after launching the program.

The second step is creating the technological backbone to connect public institutions by developing a platform that uses modular architecture and cloud -based infrastructure. This way, public institutions would use a shared digital space, with personalized access for institutions based on the scope of their activity. 63

In the implementation of the second step, the following actions would be taken by the ADR, in partnership with MEDAT, MIPE, the Special Telecommunications Service (STS), 64 and the National Cybersecurity Directorate (DNSC). 65 Compliance with the Single Digital Gateway Regulation, 66 the General Data Protection Regulation (GDPR),67 and the European Interoperability Framework (EIF) would be ensured throughout the process of: 68

a) Designing and implementing a secure cloud -based interoperability platform using modular architecture

63 European Commission, ‘Interoperability Architecture Solutions’ (Interoperability Archecture Solutions) <https://interoperable-europe.ec.europa.eu/collection/european-interoperability-reference-architectureeira/interoperability-architecture-solutions> accessed 25 March 2026.

64 ‘Official website’ (Special Telecommunications Service) <https://www.sts.ro> accessed 13 June 2026.

65 ‘Official website’ (National Cyber Security Directorate) <https://www.dnsc.ro> accessed 13 June 2026.

66 Regulation (EU) 2018/1724 of the European Parliament and of the Council of 2 October 2018 establishing a single digital gateway to provide access to information, to procedures and to assistance and problem -solving services and amending Regulation (EU) No 1024/2012 [2018] OJ L295/1.

67 Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Da ta Protection Regulation) [2016] OJ L 119/1.

68 European Commission, Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions: European Interoperability Framework – Implementation Strategy COM (2017) 134 final.

b) Integrating existing governmental databases through standardized APIs;

c) Setting up institution-specific access levels and data governance protocols.

Key Performance Indicators:

1. The platform prototype is operational by the end of Year 2 of the implementation;

2. A minimum of five ministries have the prototype integrated by Year 3;

3. The platform prototype is tested in regulatory sandboxes through a minimum of five rounds within Year 3.

4. The platform presents a reduction of interinstitutional data processing time by 30 % at the end of Year 3.

Lastly, the third step is testing, refining, and integrating the system by piloting it in pre-defined ministries. The results from the first trial could be assessed for improvements and further launched to the entire administrative system. 69 The following actions would be undertaken by the ADR, supported by the STS, DNSC, and selected ministries:

a) The implementation of pilot projects within the five preselected ministries (for instance, one possible set could be formed by the Ministry of Economy, Digitalization, Entrepreneurship and Tourism, the Ministry of Investment and European Projects, the Ministry of Finance, the Ministry of Labour, and the Ministry of Internal Affairs);

b) The collection of user feedback and performance of independent evaluations;

c) Refining technical architecture and governance procedures;

d) Gradual expansion across central and local public administration.

Key Performance Indicators:

1. The pilot is completed within 12 months;

2. User satisfaction is rated at a minimum of 75% at the final stage of the refinement;

3. At least 15 central government institutions are integrated by Year 5;

4. The platform presents a 20% average reduction in administrative processing times for selected services.

The estimated costs, based on similar costs showed in Luxembourg’s GovTech Program,70 are between 15 and 25 million EUR for the development and integration of the intergovernmental cloud system, and between 2 and 4 million EUR for the annual maintenance and cybersecurity.

On an administrative level, the implementation of the platform directly targets the shortage of proper technological infrastructure and the lack of institutional coordination, as identified in the empirical findings. Therefore, the main benefits of impleme nting the strategy would be reflected in the internal communication processes and data exchange between institutions. At the economic level, the strategy enhances collaboration between the state and businesses and fosters innovation through fair competitio n.

B. Implementation of common standards for sharing data

A second recommendation is the implementation of common standards for sharing data to achieve easier data exchange and integration between old and new systems, based on the first scope of action from Romania’s 2020 Digital Agenda, targeting eGovernance, Interoperability, Cybersecurity, Cloud Computing, Open Data, Big Data, and Social Media. 71

As part of the “GovTech Partnership Program”, this could be achieved through the implementation an Open Data Catalogue, in addition to the shared platform for public institutions.

The initial phase of the implementation is the development of an execution strategy for the Romanian Interoperability Framework by using open standards, shared APIs, and reusable components. This would consist of the following set of actions taken by the A DR, and in partnership with the Ministry of Economy, Digitalization, Entrepreneurship and Tourism, the Ministry of Investment and European Projects, and the National Cybersecurity Directorate, over the first year of implementation:

a) Mapping the existing interoperability gaps and datasets (months 1 -4);

b) Developing technical standards and API guidelines (months 5 -8);

c) Consultation and formal adoption (months 9-12).

70 ‘GovTech’ (Luxembourg Public Portal) <https://luxembourg.public.lu/en/invest/innovation/govtech.html> accessed 13 June 2026.

71 Government of Romania, Strategia națională privind Agenda Digitală pentru România 2020 (2015) [National Strategy on the Digital Agenda for Romania 2020] (SNADR 2020) 14.

Key Performance Indicators:

1. The execution strategy for the Romanian Interoperability Framework is adopted within the first year of implementation;

2. Common API standards are developed and published on the official page of the ADR in the first 6 months after the adoption of the execution strategy;

3. Participating institutions approve data-sharing protocols;

4. At least ten central institutions commit to the implementation.

The second phase involves building a centralized and user-friendly platform for public data access, integration, and innovation, by inventorying the existing datasets and centralizing them in one Open Data Catalogue. 72 This would consist of the following set of actions over the first three years of implementation:

a) Dataset inventory and classification (Year 1);

b) Development of the catalogue (Year 2);

c) Integration with public institutions (Year 3).

Key Performance Indicators:

1. The Open Data Catalogue is operational by Year 3;

2. At least 500 public datasets are available through the Open Data Catalogue by Year 3;

3. At least 80% of central government institutions migrate their data to the Catalogue by the end of Year 3.

Lastly, in the third phase, the open data practices would be integrated into the public administration culture by embedding them in existing platforms to foster the easy and secure migration of sensitive data from the old systems into the new collaborative system. Monitoring mechanisms and stakeholder feedback would be used continuously to refine the system. Monitoring mechanisms and stakeholder feedback would be used continuously to refine the system.73 This would be performed by implementing the following set of actions:

72 ibid 21.

73 ibid 94.

a) The Open Data Catalogue is piloted in at least 10 central government institutions by the end of Year 3;

b) Within Year 4, the Catalogue is evaluated and optimized;

c) The Open Data Catalogue is fully integrated by the end of Year 5.

Key Performance Indicators:

1. 90% of participating institutions complying with interoperability standards;

2. 50% reduction in duplicate data requests between institutions;

3. 70% reduction in manual data transfers;

4. Annual publication of interoperability and open-data performance reports.

The estimated costs for the Romanian Interoperability Framework and Open Data Catalogue are 8-16 million EUR over the five years of implementation, as it is derived from comparable open-data and interoperability projects implemented at EU level. 74 Main costs concern dataset inventorying, metadata standardisation, API development, platform creation, migration of legacy data, and staff training.

From a social perspective, this initiative would help citizens understand the government’s activity and its efficiency better, and ensure accountability for breaches or lack of results. 75 From an economic perspective, the open data resources would significantly impact the SME’s way of conducting business, as they would be able to easily access public resources and focus on creating value-added services, such as transport apps or civic tech tools for entering the market 76 From a competition law perspective, the Open Data Catalogue contributes to equal and non-discriminatory access to information for businesses.

77

C. Unified Governmental Cloud

The third and last recommendation, inspired by FranceConnect, focuses on different stakeholders’ experience with the public system and involves the development of an authentication system for citizens and businesses, complemented by a unified Cloud for data

74 European Commission, ‘Deployment of an EU Open Data core platform: implementation of the pan -European Open Data Portal and related services (SMART 2014/1072)’ (Funding & Tenders Portal, 2014) <https://digitalstrategy.ec.europa.eu/en/funding/smart-20141072-deployment-eu-open-data-core-platform-implementation-paneuropean-open-data-portal> accessed 13 June 2026.

75 SNADR 53.

76 ibid.

77 ibid.

retention. 78 Based on the Once-Only Principle established under the Single Digital Gateway Regulation 2018/1724, 79 the Cloud would be used for retaining the identifiable data for citizens and businesses that could be accessed by the ministries in conformity with a preset role -based and legally authorized access. 80 The first step in the implementation would focus on establishing the legal, institutional, and technical foundations for a secure cloud environment with embedded digital identity solutions, in line with the EU standards concerning data protection. As such, the following actions would be taken by the MEDAT, as the leading institution of the initiative, supported by the ADR, MIPE, DNSC, and STS:

a) Legal review and alignment with the EU framework on interoperability and data protection (months 1-4);

b) Development of governance and interoperability standards (months 5 -8);

c) Adoption of technical specifications and institutional agreements (months 9 -12).

Key Performance Indicators:

1. Governance framework adopted within 12 months.

2. Interoperability and cybersecurity standards formally approved.

3. Participation agreements signed by at least 10 central government institutions.

4. Digital identity specifications completed.

The second step involves building the cloud infrastructure that would be hosted in certified national data centres, and securing the process by implementing cybersecurity protocol. 81 During the next three years, the following actions would be undertaken:

a) Procurement and infrastructure planning (Year 1);

b) Development of cloud infrastructure and authentication system (Year 2);

c) Integration with participating ministries and agencies (Year 3).

78 Wilfried Kirschenmann, ‘From Cloud Souverain to Cloud de Confiance: a political definition of clouds’ (ANEO, 13 May 2024) <https://www.aneo.eu/en/blog/cloud -souverain-cloud-de-confiance> accessed 20 October 2025.

79 Regulation (EU) 2018/1724 of the European Parliament and of the Council of 2 October 2018 establishing a single digital gateway to provide access to information, to procedures and to assistance and problem -solving services and amending Regulation (EU) No 1024/2012 [2018] OJ L295/1, Recital 17.

80 ibid.

81 ‘Deployment of Government Cloud Infrastructure’ (European Commission) <https://reformsinvestments.ec.europa.eu/projects/deployment-government-cloud-infrastructure_en> accessed 27 March 2026.

Key Performance Indicators:

1. Cloud infrastructure operational by Year 3;

2. Authentication system available for citizens and businesses;

3. At least 10 central government institutions connected;

4. System availability above 99%;

5. Compliance with EU cybersecurity and data-protection requirements.

In the last phase, within Years 3 and 4 of the implementations, the authentication system would be initially piloted, evaluated, and optimised in predetermined institutions based on internal data to avoid data privacy violations and reduce the risk of liab ility. Following the refinement, the authentication system would be made available nationwide.

Key Performance Indicators:

1. Pilot completed within 12 months.

2. User satisfaction rate above 80%.

3. 50% reduction in repetitive data submissions by citizens and businesses.

4. Integration of at least 20 central government bodies by Year 5.

5. Increase in the use of digital public services by at least 30%.

Despite Romania’s estimate of 170 million EUR investment for cloud migration, as stated in the PNRR,82 the costs of the Unified Cloud for public access are rather estimated at 30-60 million EUR over the five years of implementation. This is because, instead of replicating the full Government Cloud infrastructure, the recommendation seeks to develop an authentication layer, interoperability mechanisms, additional integrations, and institutional deployment. The total predicted investment follows FranceConnect’s initial estimation of 46 million EUR, as a nationwide digital identity solution. 83

Lastly, the identified funding sources in support of the implementation of the three recommendations are the European Regional Development Fund (ERDF), 84 Recovery and

82 ‘Investiția 2 – Dezvoltarea cloudului și migrarea în cloud’ (Authority for the Digitalization of Romania) <https://www.adr.gov.ro/investitia -2-dezvoltarea-cloudului-si-migrarea-in-cloud> accessed 14 June 2026.

83‘Programme 129 – FranceConnect project sheet’ (French Ministry of Economy and Finance) <https://www.budget.gouv.fr/files/uploads/extract/2020/PLF/BG/PGM/129/FR_2020_PLF_BG_PGM_129_JPE .html> accessed 13 June 2026.

84 Regulation (EU) 2021/1058 of the European Parliament and of the Council of 24 June 2021 on the European Regional Development Fund and the Cohesion Fund [2021] OJ L231/60.

Resilience Facility (RRF) resources, 85 the Digital Europe Programme, 86 and national cofinancing.

From accessible healthcare to fair distribution of governmental grants, the authentication system would be designed to embed user-centric approaches, aiming to reduce bureaucracy and facilitate smart public services for all individuals and businesses. By supporting user-centric service delivery, the system could improve access to healthcare, social benefits, and public funding schemes. From an administrative perspective, it would facilitate secure data sharing and strengthen institutional coordination. Econ omically, it would reduce compliance costs for businesses, improve administrative efficiency, and contribute to the development of more responsive and data-driven public services.

VII. Final remarks

Looking ahead, effective measures have to be taken at the administrative level to enhance Romania’s digital capacity and improve interoperability. Given the identified gaps within the public system, efforts from the national authorities must target not onl y the financial dimension - prioritizing investments in digital infrastructure - but also the structural and administrative dimension. This therefore creates shared practices of data transfer and communication protocols between the ministries and the priva te sector. By implementing the recommendations outlined in this report, Romania could develop an effective and robust interoperable system that aligns with the principles set forth by the Interoperable Europe Act.

85 Regulation (EU) 2021/241 of the European Parliament and of the Council of 12 February 2021 establishing the Recovery and Resilience Facility [2021] OJ L57/17.

86 Regulation (EU) 2021/694 of the European Parliament and of the Council of 29 April 2021 establishing the Digital Europe Programme [2021] OJ L166/1.

Tri-City Comparison of Interoperability Within the European Union

By Viktor Ninov,(a) Annemarijn de Grijs,(b) and João Colaço.(c)

Abstract

The Interoperable Europe Act (IEA), adopted in 2024, establishes a comprehensive EU framework for cross -border digital public service interoperability. While the Act introduces concrete mechanisms including mandatory interoperability assessments and centra lised governance through the Interoperable Europe Board, its ultimate success depends on effective implementation at the municipal level where public services directly serve citizens and businesses.

This study examines local interoperability practices in three European cities (The Hague, Sofia, and Lisbon) through semi-structured interviews with municipal officials and digital transformation experts, complemented by documentary analysis of national an d municipal digitalisation frameworks. The research reveals three distinct implementation archetypes that demonstrate varying challenges in IEA adoption. The Hague is an example of 'regulatory friction', where administrative compliance burdens restrict an otherwise advanced digital government infrastructure. Sofia represents 'resource dependency', characterised by chronic underfunding, skills shortages, and over-reliance on project-based EU funding, which impedes the development of systematic interoperabili ty. Lisbon illustrates 'complexity fragmentation', where strong national frameworks and political commitment are insufficient to overcome technical silos, legacy systems, and a critical shortage of hybrid technical and administrative professionals.

These findings demonstrate that the IEA's success requires differentiated implementation strategies rather than uniform application: regulatory flexibility for digitally advanced governments, targeted capacity building for developing systems, and enhanced technical governance support for fragmented administrations. Without such tailored approaches, the EU's vision for a seamless digital single market will remain constrained by local implementation realities.

(a) L.L.B. Candidate, International and European Law Programme, The Hague University of Applied Sciences.

(b) L.L.B. Candidate, International and European Law Programme, The Hague University of Applied Sciences.

(c) L.L.B. Candidate, International and European Law Programme, The Hague University of Applied Sciences.

Introduction

Adopted in 2024, the Interoperable Europe Act (IEA) is a landmark EU regulation designed to strengthen cross -border digital public services by promoting the seamless exchange of data and interoperability across Member States. 1 The IEA operationalises interoperability through four key instruments designed to create binding cross -border coordination. First, mandatory interoperability assessments under Article 3 require public sector bodies to conduct ex-ante evaluations of any new or significantly upgraded digital services that impact crossborder data exchange. 2 Second, the Interoperable Europe Board centralises governance, coordinates national interoperability strategies, and monitors Member State compliance. 3 Third, the Interoperable Europe Portal serves as a one-stop platform for sharing reusable solutions, open-source tools, and technical guidelines. 4 Finally, regulatory sandboxes allow Member States and local authorities to pilot innovative, cross -border interoperable solutions in controlled environments prior to full deployment. 5 These mechanisms collectively shift European digital policy from voluntary coordination to binding regulatory compliance.

Although the Act establishes a common EU -wide framework, its success in practice depends on its implementation at the local level, where municipalities deliver public services and interact directly with citizens and businesses. 6 The article investigates the extent to which local interoperability practices in three European cities (The Hague, Sofia, and Lisbon) align with the Act's requirements and principles, identifying the key constraints, needs, and gaps that emerge in each context.

The selection of these cities is justified by three comparative criteria that enable systematic analysis of how different municipal contexts affect IEA implementation. First, they demonstrate varying degrees of digital maturity as measured by the Digital E conomy and Society Index (DESI) and Digital Decade country reports: the Netherlands is classified as a digital frontrunner, Portugal as a strong performer, and Bulgaria continues facing challenges in

1 Regulation (EU) 2024/903 of the European Parliament and of the Council of 13 March 2024 laying down measures for a high level of public sector interoperability across the Union (Interoperable Europe Act) [2024] OJ L 2024/903, art 1.

2 IEA (n 1) art 3.

3 ibid arts 7-8.

4 ibid art 4.

5 ibid art 11.

6 Committee of the Regions, ‘Opinion of the European Committee of the Regions – A simpler and faster Europe’ (Opinion C/2025/4414, 29 August 2025).

basic digital skills and online service adoption. 7 Second, they exhibit distinct administrative traditions. The Netherlands follows a decentralised unitary model with strong municipal autonomy, Portugal operates a centralised administrative system with regional coordination through ARTE, and Bulgaria main tains a centralised state structure where municipalities rely heavily on national frameworks.8 Third, they represent different demographic scales: Sofia (1,205,833),9 Lisbon (596,952), 10 and The Hague (890,068),11 providing grounded comparative perspectives on how local authorities interpret interoperability mandates across varied institutional and resource contexts.

This study uses a qualitative case study methodology combining desk research of relevant policy documents with semi-structured interviews with municipal officials in each city. Examining the technical, legal, organisational, and semantic dimensions of inte roperability, the analysis aims to reveal common and context-specific challenges that local implementers of the Act face. Following the European Commission’s approach to digital -ready policymaking, as analysed by Audrito, Guasch, and Nardin in the ENDORSE proceedings, achieving interoperability requires not only technical standards but systematic integration of digital considerations into policy design from the outset. 12

The findings reveal three distinct implementation archetypes. The Hague is an example of ‘regulatory friction’, where the administrative burden of EU compliance rather than technical shortcomings restricts the development of a digital government. Sofia rep resents ‘resource dependency’, where progress is hindered by chronic underfunding, skills shortages, and reliance on project-based EU funding. Lisbon illustrates ‘complexity fragmentation’, where strong national frameworks and political will are insufficie nt to overcome internal

7 ‘Digital Decade Country Report 2024: Netherlands’ (European Commission, 2024) 2 -4; ‘Digital Decade Country Report 2024: Portugal’ (European Commission, 2024) 3 -5; ‘Digital Decade Country Report 2024: Bulgaria’ (European Commission, 2024) 2-6; See also ‘Digital Economy and Society Index (DESI) 2024’ (European Commission, 2024).

8 ‘Digital Decade Country Report 2024: Netherlands’ (European Commission, 2024) 2 -4; ‘Digital Decade Country Report 2024: Portugal’ (European Commission, 2024) 3 -5; ‘Digital Decade Country Report 2024: Bulgaria’ (European Commission, 2024) 2-6.

9 ‘Sofia Population 2026’ (World Population Review) <https://worldpopulationreview.com/cities/bulgaria/sofia> accessed 17 June 2026.

10 ‘Lisbon Population 2026’ (World Population Review) <https://worldpopulationreview.com/cities/portugal/lisbon> accessed 17 June 2026.

11 ‘The Hague Population 2026’ (World Population Review) <https://worldpopulationreview.com/cities/netherlands/the-hague> accessed 17 June 2026.

12 Publications Office of the European Union, ENDORSE, 3rd European Data conference On Reference Data and Semantics ENDORSE 2025 – Brussels, 8 to 9 October 2025 – Proceedings, 2026, <https://data.europa.eu/doi/10.2830/6167201>.

technical silos, legacy systems, and a critical shortage of hybrid professionals. These archetypes demonstrate that the IEA's success depends not on uniform application, but on tailored support strategies: regulatory flexibility for advanced digital govern ments, targeted capacity building for developing systems, and technical governance support for fragmented administrations.

The findings aim to inform EU and national policymakers about the practical realities of implementing interoperability and highlight areas where supportive measures could enhance the Act's effectiveness, such as providing tailored guidance, building capaci ty, and sharing solutions. The paper begins by outlining the legal and policy context, describing the research methodology, and presenting findings from each city. It then discusses comparative insights and offers recommendations for policy and practice.

I. Legal and policy context

The implementation of the Interoperable Europe Act at the municipal level operates within a multi-layered legal architecture, spanning EU, national, and local governance tiers. 13 At the EU level, the IEA builds upon the European Interoperability Framework, supported by the Data Governance Act and GDPR, creating a regulatory ecosystem for cross -border data exchange. 14 The EIF separates interoperability in four structural layers, which local administrations must navigate:

- Legal interoperability (ensures that organisations operating under different legal frameworks can work together)

- Organisational interoperability (aligns business processes, responsibilities and expectations)

- Semantic interoperability (ensures that precise format and meaning of exchanged data is preserved and understood across all parties)

- Technical interoperability (covers the systems, protocols and hardware interfaces needed to connect services)

13 ICTU, ‘Alignment NORA en EIF’ (NORA Online, 7 November 2025) <https://www.noraonline.nl/wiki/Alignment_NORA_en_EIF> accessed 2 June 2026.

14 NORA, 'Alignment NORA en EIF' (NORA, 7 November 2025) <https://www.noraonline.nl/wiki/Alignment_NORA_en_EIF> accessed 19 November 2025.

The EIF had no legally binding effect, 15 however the adoption of the Interoperable Europe Act has shifted European digital policy from a voluntary framework to a regulation binding all the Member States. The IEA established a formalised governance system with the Interoperable Europe Board. This body is tasked with controlling cross -border digital cooperation, coordinating national initiatives and facilitating multi -level governance. 16 Significantly, this system impacts local administrations through mandatory interoperability assessment under Article 3 of the IEA. This provision mandates public sector bodies to conduct an ex-ante evaluation of any new or significantly upgraded digital p ublic services that impact cross-border data exchange. For municipalities, this introduces a bureaucratic and technical checkpoint, which seeks local demonstration of European alignment prior to deployment. 17

Moreover, the governance system is supported by the Interoperable Europe Portal, which serves as a centralised catalogue. The portal provides municipalities with direct access to open-source, reusable architectural building blocks, data models and software solutions. Conceptually, this is done to enable cities to bypass any costly tailored models in favour of standardised European designs. 18

Finally, it is important to note that the IEA is embedded within the wider EU digital policy ecosystem. The IEA directly synergises with the General Data Protection Regulation (GDPR), which ensures that its technical integration does not compromise data pr ivacy. Furthermore, it operates with the Data Governance Act (DGA) and the Data Act, which collectively regulate data sharing and mandate public sector access to private information under strict conditions. Lastly, to note that the IEA intersects with the AI Act which imposes strict governance, safety and documentation requirements on high -risk AI algorithms, which could be deployed in smart- city public administrations.

A. The Hague

In the Netherlands, the Digital Government Act ( Wet digitale overheid) provides the legal framework for secure digital public services, electronic identification, and the use of

15 European Parliamentary Research Service, 'Interoperable Europe Act' (Briefing EU Legislation in Progress, EPRS 2023) 2 <https://www.europarl.europa.eu/RegData/etudes/BRIE/2023/745711/EPRS_BRI(2023)745711_EN.pdf> accessed 14 June 2026.

16 IEA (n 1) arts 15-16.

17 ibid art 3.

18 ibi art 8.

designated open standards. 19 The national digitalisation agenda NL DIGIbeter sets shared priorities for digital transformation and supports coordination across government levels. 20 The municipal-led Common Ground initiative modernises local information systems by promoting modular architectures, API-based data exchange, and reuse of shared components. 21

The Ministry of the Interior and Kingdom relations (BZK) steers national interoperability and digital-government policy, working with Logius and the Forum Standaardisatie to maintain instruments such as the ‘comply -or-explain’ open-standards list and the NORA (Nederlandse Overheids Referentie Architectuur). 22 Together, these frameworks form a layered governance environment that municipalities such as The Hague must interpret and operationalise, often requiring careful prioritisation among overlapping policy and compliance demands. 23

B. Sofia

Bulgaria’s national digital strategy is formally outlined in the National Interoperability Framework (NIF) 2022, which itself is based on the European Interoperability Framework (EIF). The overarching objectives of the NIF are to foster a service -oriented society, enhance transparency, support joint public sector service development, promote competition in public ICT, reduce costs, and advance cross -border and cross-sectoral interoperability. 24

The Electronic Government Act is the primary legal cornerstone of digitalisation and interoperability in Bulgaria. It sets out the technical and semantic interoperability requirements (referred to as operational compatibility). 25 The central authority responsible for maintaining interoperability registries, standards and overseeing compliance is the Ministry of e -

19 ‘Wet Digitale Overheid’ (Digitale Overheid) <https://www.digitaleoverheid.nl/overzicht -van-alleonderwerpen/wetgeving/wet-digitale-overheid/> accessed 15 November 2025.

20 ‘The Netherlands’ Digitalisation Strategy’ (Digital Government NL, September 2025), <https://www.nldigitalgovernment.nl/netherlands -digitalisation-strategy-nds/> accessed 15 November 2025.

21 ‘Thema-architectuur Common Ground’ (GEMMA Online) <https://www.gemmaonline.nl/wiki/Themaarchitectuur_Common_Ground> accessed 22 November.

22 IOPEU, ‘Report on the Interoperable Europe Roadshow in the Netherlands’ (Interoperable Europe, 2 April 2025) 18.

23 Interview I1 (NORA expert, NORA Beheer ICTU, telephone interview with written email exchange, 22 November 2025).

24 Ministry of e-Governance, National Interoperability Framework (NIF) <https://ros.egov.bg/wps/portal/interoperability-web/strategy/nros> (in Bulgarian) accessed 9 December 2025.

25 Electronic Governance Act [Zakon za elektronnoto upravlenie], promulgated in the State Gazette No. 46 of 12 June 2007, as last amended and supplemented in SG No. 80 of 19 September 2023, arts 43 -46.

Governance.As NIF is based entirely on the EIF, this ensures Bulgaria's digital policies are integrated within the broader EU digital single market and Digital Decade policy landscape

C. Lisbon

The agenda of national digital transformation of Portugal is led by ARTE ( Agência para a Reforma Tecnológica do Estado ), which serves as the authority responsible for interoperability, digital public services and the national interoperability platform (iAP). 26 The digital strategy of Portugal aims to improve API -based data exchange while developing semantic standards and enhancing data management systems in public institutions. 27 National interoperability frameworks and technical guidance establish standards that municipalities, including Lisbon, can use to develop organisational and technical capabilities for digital governance and service delivery. 28 The national frameworks together with EU -wide legislation, which include the Interoperable Europe Act, EIF, GDPR and the AI Act to create new requirements for data protection, transparency, documentation and cross -border system interoperability. Consequen tly, Lisbon operates within a governance system that integrates EU policy objectives with national interoperability requirements while accommodating differing levels of municipal digital readiness.

This multi- layered legal architecture creates different implementation pressures across municipalities. While the framework provides essential coordination mechanisms, its effectiveness depends on how local authorities navigate the intersection of EU manda tes, national frameworks, and municipal capacity constraints. The following analysis examines how three cities with different digital maturity levels, administrative traditions, and resource contexts approach these challenges.

II. Methodology

This study adopts a comparative qualitative case study approach to examine how three European cities, The Hague, Sofia, and Lisbon, are implementing the requirements of the Interoperable Europe Act (IEA). The methodology combines documentary analysis with semi-

26 Agência para a Reforma Tecnológica do Estado (ARTE), ‘Quem Somos’ (ARTE) <https://www.arte.gov.pt/quem-somos/> accessed 2 June 2026.

27 ARTE, ‘Interoperabilidade’ (ARTE) <https://www.arte.gov.pt/interoperabilidade/> accessed 2 June 2026.

28 iAP, ‘Sobre a iAP’ (Interoperabilidade da Administração Pública) <https://www.iap.gov.pt/web/iap/sobre -aiap> accessed 2 June 2026.

structured interviews to capture both formal policy frameworks and practical implementation experiences.

A. Desk research

For The Hague, important sources included the NIFO Factsheet – Netherlands and the supporting document for the European Commission's ‘The Netherlands 2024 Digital Public Administration Factsheet'’ For the Sofia case, documents from Sofia Municipality were utilised, together with supporting facts from the Digital Decade Report and GATE Institute materials. For the Lisbon case, key documents include the European Commission's NIFO 2024 – Supporting Document: Portugal, the Lisbon Council's 'The Interoperability Imperative report', and the UIA Initiative's 'The digitalisation of mobility in Lisbon'.

B. Interviews

The empirical component consisted of semi-structured interviews with municipal officials and experts involved in digital transformation and interoperability. Five interviews were conducted: two in The Hague, two in Sofia, and one in Lisbon. Interviewees we re selected through purposive sampling based on their direct involvement with IEA -relevant topics.

To ensure clarity and reproducibility, each interview has been assigned a unique identifier from I1 to I5. To protect anonymity as agreed with participants, interviewees are referred to by their functional role and organisation only. Specific names and any directly identifying information have been removed from the transcripts.

C. Interview overview

I1 NORA expert NORA Beheer (ICTU) 22 November 2025 Telephone with written email exchange

I2 Smart City Account Manager Municipality of The Hague 15 November 2025 Written exchange

I3 Computer and Software Systems

Architect Ministry of Electronic Governance (Bulgaria)

I4 Chief Expert, Directorate Digitalisation, Innovation and Investment Sofia Municipality

I5 Interoperability

Officer with liaison duties to the municipality ARTE (Agência para a Reforma Tecnológica do Estado)

5 December 2025

Telephone with written email exchange

26 November 2025

7 November 2025

Telephone call

Telephone call

Note that specific dates for interviews I3, I4 and I5, as well as the precise format of video call or written exchange, have been omitted where information is not available. Full details are available in the anonymised transcripts and are on file.

The format and structure of interviews varied depending on the interviewee and researcher conducting the conversation. In The Hague, written question lists were prepared in advance. In contrast, no formal question lists were prepared prior to the interview s in Sofia and Lisbon, which were guided by open thematic exploration of interoperability challenges and practices. Despite these methodological differences, analytical comparability was ensured through post-hoc thematic coding, with all interviews being s ystematically analysed against a common analytical framework of four thematic blocks after data collection, which included national and local interoperability frameworks, implementation obstacles, the use of EU standards and tools, and recommendations for the Interoperable Europe Act. This retrospective approach to analysis enabled consistent comparisons to be made across cities, while also allowing context-specific exploration during data collection.

D. Ethical safeguards and anonymisation

All participants provided written consent after being informed about the purpose of the study and how their insights would be used. Anonymity was ensured by referring to interviewees by their functional role and organisation only, rather than by name. The anonymised transcripts of all five interviews are included in Annex A. In the transcripts, each interviewee is identified solely by their assigned ID (I1 to I5) and functional role. Any references to specific individuals, third parties, or identifiable pro ject details have been redacted. The recordings and transcripts are stored securely.

E. Limitations

The study acknowledges several limitations. The small sample size and the fact that the interview guides were tailored to each city's context mean that the findings are indicative rather than generalisable. Furthermore, time constraints meant that follow -up inquiries could not be conducted in sufficient depth. Despite these limitations, the tri -city comparison provides valuable insights into the practical challenges of local IEA implementation. The full interview consent forms are available in a separate Go ogle Drive folder.

VI. Findings and analysis

A. Interoperability in The Hague

The Dutch digital government is built on a sophisticated, multi -layered architecture designed for interoperability. Although analysis shows strong strategic alignment with European principles, substantial friction emerges in local implementation, highlight ing systemic constraints relevant to the Interoperable Europe Act (IEA).

1. Capacity and legacy: the implementation constraint

Figure 5: NORA.29

29 ‘NORA Familie’ (Digitale Overheid) <https://www.digitaleoverheid.nl/overzicht -van-alleonderwerpen/nora/nora-familie/> accessed 2 June 2026.

The national interoperability framework is robust. The Nederlandse Overheids Referentie Architectuur (NORA) provides the foundational layer upon which sector-specific architectures are built; GEMMA as the foundational government reference architectures for municipalities and PETRA for provinces. 30 A mandatory ‘comply-or-explain’ regime enforces open standards,31 further elaborated through detailed governance models such as BOMOS (Beheer- en OntwikkelModel voor Open Standaarden ), thereby systematising the entire lifecycle management of standards.

However, the number of rules, frameworks and procedures (ranging from NORA and GEMMA to BOMOS and EU regulations) hinders the strategic visibility of municipal implementers, meaning that there is less clarity about how best to achieve the objectives of the EU's policy framework. According to a NORA expert, the volume of rules from national and European levels forces ‘impossible prioritisation’. 32 This concern is widely echoed across European municipal networks: the European Committee of the Regions has warned that overlapping regulations, skills shortages and limited resources risk slowing down innovation and widening the digital divide, leaving municipalities unable to prioritise digital transformation effectively. 33 Upgrading legacy systems is often deprioritised in favour of maintaining core services. 34 Consequently, although national APIs exist, municipalities often rely on parallel, inefficient channels such as email or paper forms because their counterparts are not yet technically aligned. This makes local strategic investments less effective and highlights a persistent gap between design and practice. 35

2. The pre‑standardisation gap: missing frameworks for emerging technologies

Friction is even more obvious in emerging policy areas. The Hague’s Smart City team reports that, for pioneering initiatives such as its smart energy grid, “the necessary technical

30 ‘Architecturen NORA Familie’ (NORA Online) <https://www.noraonline.nl/wiki/Architecturen_NORA_Familie> accessed 19 November 2025; ‘Alignment NORA en EIF’ (NORA Online) <https://www.noraonline.nl/wiki/Alignment_NORA_en_EIF> accessed 19 November 2025.

31 ‘Pas toe leg uit standaarden (verplicht)’ (Forum Standaardisatie) <https://www.forumstandaardisatie.nl/openstandaarden/verplicht> accessed 19 November 2025.

32 Interview I1 (n 23).

33 Committee of the Regions, ‘Opinion of the European Committee of the Regions – A simpler and faster Europe’ (Opinion C/2025/4414, 29 August 2025).

34 Interview I1(n 23).

35 ‘Communicating Smarter via the Message Box for Businesses’ (Digital Government, 8 April 2025) <https://www.nldigitalgovernment.nl/featured-stories/communicating-smarter-via-the-message-box-forbusinesses/> accessed 2 June 2026.

specifications are not yet developed or available” and “the standards are lacking”. 36 This prestandardisation gap is increasingly recognised at the European level: the EU standardisation body CEN, through its Technical Committee 465, is actively seeking to identify the gaps in the standardisation landscape for smart cities, particularly i ts Climate-Neutral Smart Cities and Communities group.37 In response, the city is developing open-source components and sharing its Living Lab Scheveningen System Specification to encourage future standardisation. 38 This highlights a significant shortcoming in the current governance of interoperability: while existing frameworks effectively regulate established services, they are unable to provide timely specifications for new, cross -border innovations. 39 Consequently, cities are frequently compelled to set standards, thereby increasing the risk of early fragmentation across Europe.

3. The core constraint - the procedural burden of EU regulation

The primary issue is not a lack of Dutch architectural will, but rather the nature of the EU's regulatory approach. A senior NORA expert with over fifteen years' experience has observed that EU procedural compliance demands often target issues that do not present real obstacles within member states. 40 This critique aligns with broader policy analysis. 41 The Council of European Municipalities and Regions have found that, although local and regional governments implement over seventy percent of EU policies, they face considerable challenges due to the layering of rules across multiple governance levels. Br oad legislative packages such as the Digital Decade and the Green Deal become fragmented during negotiations, resulting in inconsistent deadlines and responsibilities that are divided between different government departments. The European Commission often issues additional guidance documents during the implementation process, adding further complexity and consuming time that could otherwise be spent on delivery. 42 While EU frameworks provide essential strategic alignment this top-down approach can make complex national and local trade -offs more uncertain. It

36 Interview I2 (Smart City Account Manager, Municipality of The Hague, written exchange, November 2025).

37 CEN/TC 465, ‘How OASC Cities Shape Standards for Climate -Neutral Futures’ (Report of the Ad hoc Group on Climate-Neutral and Smart Cities and Communities, December 2025).

38 Gemeente Den Haag, 'System Specification – Living Lab Scheveningen' (Smart City Den Haag) <https://smartcity.denhaag.nl/en/system-specification/ accessed> 2 June 2026.

39 ‘GEONOVUM - Geo-standaarden’ (Geonovum) <https://www.geonovum.nl/index.php/geo-standaarden> accessed 22 November 2025.

40 Interview I1 (n 23).

41 Council of European Municipalities and Regions, ‘Better Regulation Position Paper’ (Position Paper, 12 June 2025), p.2.

42 ibid 2-3.

creates a dual burden for member states to translate EU regulatory procedures into national law while also navigating existing national rules and competing political priorities.

4. Strategic imperatives for the Interoperable Europe Act

To improve the effectiveness of the Interoperable Europe Act, its implementation should address the practical constraints identified by NORA Beheer. According to NORA Beheer, improvement requires a strong reduction in the volume of legal rules and the prov ision of practical support for transitions prioritised by implementing organisations themselves. 43

Based on the findings presented above, strategic architectural alignment alone is insufficient. The success of the IEA will depend on whether it can address the tensions between legacy capacity and innovation, and between foundational network design and fr agmented political execution.

B. Interoperability in Sofia

As Bulgaria’s capital city and primary economic engine, the Municipality of Sofia possesses distinct digital administrative capacities that set it apart from other Bulgarian local authorities. Divided into 24 districts with a central administrative authori ty, Sofia has outpaced national digitalisation. However, this has introduced significant organisational fragmentation. 44

Until recently, local authorities bore the responsibility of developing their own IT systems or adapting state-mandated templates. Over the past three years, the central municipal authority has initiated a comprehensive mapping endeavour for these systems, attempting to establish a baseline in technical alignment and system compatibility. 45

1. Financial and capacity constraints

Sofia’s transition toward an interoperable digital architecture is severely bottlenecked by a systemic human capital deficit. While the National Classification of Professions and Occupations (2011) maintain a list of available professions and occupations, but several vital positions are missing. 46 The Municipality cannot financially compete with private -sector

43 Interview I1 (n 23).

44 Interview I4 (Chief Expert, Directorate Digitalisation, Innovation and Investment, Sofia Municipality, 26 November 2025, call.

45 ibid.

46 Ministry of Labour and Social Policy (Bulgaria), List of Positions in the National Classification of Occupations and Positions 2011, SG No 105/2011.

salaries. Consequently, specialised legal, technological and architectural experts are drawn to national ministries or private enterprises, which leaves local public bodies understaffed or reliant on inexperienced personnel. 47 This dynamic shows a wider, systemic national deficit. The public sector consistently struggles to compete with the private sector on pay, creating a severe shortage of multidisciplinary experts possessing the complex legal, technological, and architectur al competencies required to implement interoperability frameworks effectively. 48

This lack of personnel is compounded by the budgetary volatility. Over the past two years, dedicated digital infrastructure funding has been deprioritised in favour of qualify of life initiatives in the capital. 49 The only large allocation of the budget the Directorate received has been for archiving, 50 as documentation is still done on paper in most districts. A large mapping endeavour has been undertaken to achieve this. Because of this lack of national and municipal funding, the Directorate relies heavily on the EU for its funding via pilot projects. Despite the Directorate’s efforts to centralise administration horizontally with other Directorates and districts, the main problem remains being underfunded. 51 Compounding these budget constraints are deep-rooted technological barriers. Public bodies are heavily restricted by legacy information systems built on outdated architectures that require substantial resources to modernise and integrate. Furthermore, because funding is distributed across a mosaic of national and European programs, public authorities lack a predictable budget percentage dedicated strictly to interoperability measures.

2. Collaboration with EU

Sofia participates in the European Mobility Data Space (EMDS), a common European initiative designed to facilitate the access, pooling, and sharing of mobility -related data to support efficient, sustainable, and cross -border transportation services. EMDS aims to create a trusted environment where public authorities, transport operators, and service providers can exchange data in a secure, interoperable, and transparent way. While deployEMDS is involved

47 Interview I4 (n 44).

48 Interview I3 (Computer and Software Systems Architect, Ministry of Electronic Governance, 5 December 2025).

49 Interview I4 (n 44).

50 Municipality of Sofia, ‘Appendix No 3: Calculation for Financing Capital Expenditures 2025’ (Excel spreadsheet, 2025).

51 Interview I4 (n 44).

in the preparation of a data infrastructure, which would be an application providing interconnected routes with multimodal transportation from one Member State to another. 52

In the case of Sofia, deployEMDS supports a local pilot to integrate public transport data, shared mobility (e-scooters, bikes, cars), parking and walking data into a unified, multimodal mobility ecosystem. This integration combines different transport mod es with realtime data, a single user profile and payment method, and optimised routing. 53 By doing so, deployEMDS would help Sofia address local challenges such as traffic congestion, air pollution, fragmentation of mobility data and services, and limited multimodal connectivity. 54 While the technical architecture has been mapped out in the project's deliverables, the longterm challenge remains ensuring that private mobility operators uniformly adopt and integrate into this centralised municipal data space. 55

3. Open data and the sandbox framework

The Digitalisation Division at Sofia Municipality has prioritised its work towards the creation of a unified Urban Data Platform. What they are striving to do is to create a database where all credible and useful information can be compiled into a single o pen-source platform to be used by other directorates, businesses and citizens alike. 56

As the municipality has noticed, if data becomes public, innovation thrives. An example is how, after the release of transportation data publicly in September 2025, 57 a month later, students created an application which tracks the city’s transportation amongst the various types of transportation called bpilot253. 58

This shows that if data becomes readily available, then there will be volunteers in creating applications to better the digitalisation of the capital. This also means that it does not require public procurement costing several million euros. Public procure ment is required for every state and public body at every expenditure, which ultimately means that one company

52 deployEMDS, ‘About’ <https://deployemds.eu/about/> accessed 9 December 2025.

53 Dessislava Petrova -Antonova, ‘Sofia Detailed Implementation Plan (Deliverable D4.8)’ (deployEMDS, 30 April 2024) <https://deployemds.eu/wp-content/uploads/2024/07/FINAL-D4.8-Sofia.pdf> accessed 9 December 2025.

54 ibid 15.

55 ibid 4.

56 Interview I4 (n 44).

57 Sofia Municipality, 'Общи

(Order No SOA25 -RD09-3745, 3 September 2025) <https://www.sofia.bg/documents/d/guest/obsi-uslovia-danni> accessed 5th of December.

58 Interview I4 (n 44).

develops an app, a second company maintains it, and a third company updates it. As noted by the Interviewee, this leads to an unstable product, which is constantly under maintenance as the code is difficult to keep consistent. 59 Sofia’s open-source approach mirrors the wider national practices which actively mandate transparency and re -use by maintaining a dedicated GitLab repository to publish the source code of all publicly funded IT projects, alongside operating a national Open Data Portal to supply machine-readable public information. 60

Another project being developed is the Digital Twin of Sofia. A digital twin aims to implement a technical solution that scales to real -world problems, including design, exploration and experimentation of urban environments and processes. While the Directo rate is still in the early stages of development, The Big Data for Smart Society Institute (GATE Institute), an autonomous entity within the Sofia University, has already started mapping the city for different purposes. In its pilot project, they have rele ased different models, testing out solar potential, energy consumption and urban heat islands within Sofia. GATE has already released a 3D model of District Lozenets. 61

Data will be collected from Sofia, and following that, it will be uploaded to the Urban Data Space and utilised for analysis or simulations aimed at increasing digitalisation.

4. Recommendations

59 ibid.

60 Interview I3 (n 48).

61 Dessislava Petrova -Antonova, ‘3D City Model of District Lozenets’ (GATE Institute, January 2021 ) <https://city.gate-ai.eu/projects/3D-Model-Lozenets.html> accessed 8 December 2025.

From the interview with the municipal representative, it is apparent that the biggest obstacle in the way of interoperability is the budget. There is no concrete budget allocation, and in recent years it has fluctuated massively. A fixed percentage of the budget allocated to interoperability would greatly help the Directorate in its work. Additionally, cooperation with universities and academic institutes would not only advance the work done for the digitalisation but would also train and prepare students for the specific needs of the municipality.

Another recommendation would be to further educate citizens on digital services. According to the Digital Decade Country Report 2024, only 35.5 per cent of Bulgaria's population possesses at least basic digital skills, significantly below the EU target of 80 per cent by 2030.62 Although Bulgaria has introduced a range of national initiatives to improve digital competences, including STEM education programmes, adult learning platforms and digital skills training schemes, challenges remain regarding digital inclusion, particularly among older people, residents of remote areas and vulnerable groups. 63 At the municipal level, Sofia could complement these national efforts by promoting digital literacy programmes, supporting community-based training initiatives and increasing public awareness of available digital services. Such measures could help improve the uptake of e-government services and address the lack of trust and awareness of digital tools identified by the European Commission. 64

C. Interoperability in Lisbon

Lisbon demonstrates advanced interoperability implementation through its recognition as one of Europe’s leading municipalities. 65 The city achieved digital environment unity through the European Interoperability Framework (EIF) and its Interoperability Platform (iAP), Portugal’s National Interoperability Platform, which allows the automation of processes, departmental information exchange and open data accessibility. 66 Lisbon maintains a solid interoperability base, although several obstacles, mainly technical, organisational, legal and capacity-related, prevent it from achieving complete Interoperable Europe Act (IEA)

62 European Commission, ‘2024 Digital Decade Country Report: Bulgaria’ (European Commission 2024) 23.

63 Digital Decade Country Report: Bulgaria 22 –24.

64 ibid 22.

65 European Commission, NIFO 2024 – Supporting Document: Portugal (2024) 3–4.

66 Ibid 3, 12–13.

compliance. 67 The analysis demonstrates the major barriers and governance requirements for Lisbon to achieve full accordance with the EIF and the IEA. 68

1. Technical & data management constraints

The city of Lisbon has developed an advanced technical framework through PGIL (Lisbon’s Integrated Management Platform), Lisboa Aberta (Lisbon’s open -data platform) and LxDataLab (Lisbon’s data analytics laboratory), which allow for open data distribution, analytical reporting and instant data sharing. The municipality faces persistent system fragmentation, which continues to hinder full interoperability. 69 Multiple departments maintain outdated legacy systems. These systems prevent full integration with the API -based infrastructure, causing uneven digital-service capabilities and service delays. 70 The deficit of standard metadata, together with different internal database structures and an absent common data framework, creates obstacles for semantic interoperability. 71 The existing limitations demonstrate that funding from the EU is fundamental for technical standardisation and infrastructure modernisation. 72

2. Legal & GDPR-related challenges

The GDPR has a cautious approach, which creates significant legal barriers for data sharing between different municipal departments. 73 The process of data re-use between social protection, mobility and licensing departments becomes more difficult due to the staff not being able to identify appropriate legal ground for processing data, leading to continued departmental division. 74 The AI Act introduces new legal requirements with a strong emphasis on transparency, documentation and risk assessment, creating uncertainty for systems that must comply with two sets of overlapping regulations. 75 The IEA’s mandatory legal interoperability

67 Alexandra Campmas, Nadina Iacob and Felice Simonelli, ‘How can interoperability stimulate the use of digital public services? An analysis of national interoperability frameworks and e -Government in the European Union’ (2022) 4 Data & Policy e19.

68 Interview I5 (Interoperability Officer, ARTE Agência para a Reforma Tecnológica do Estado, video call, 7 November 2025).

69 ‘The Interoperability Imperative’ (Lisbon Council, 2023) <https://lisboncouncil.net/wpcontent/uploads/2023/05/LISBON_COUNCIL_The_Interoperability_Imperative -1.pdf> accessed 12 November 2025, 12–15.

70 Felix Pflücke, ‘Interoperability in the EU: Paving the Way for Digital Public Services’ in Herwig C H Hofmann and Felix Pflücke (eds), Governance of Automated Decision-Making and EU Law (OUP 2024) 265.

71 European Commission (n 66) 14, 16, 5.

72 Interview I5 (n 69).

73 European Commission (n 66) 14–15.

74 Interview I5 (n 69).

75 European Commission, (n 66) 15–16.

evaluations therefore are crucial due to serving as a tool to uphold EU -wide requirements with municipal and national legal frameworks. 76

3. Organisational and governance barriers

The organisational structure of Lisbon maintains a decentralised approach to technical decision-making and data ownership in different departments. 77 Different units within the municipality show different levels of digital maturity, which creates challenges for implementing interoperability standards in a uniform manner. 78 The municipality lacks a unified semantic governance body, which will lead to barriers in effective data sharing and different classification methods between departments. 79 The use of proprietary systems by external mobility operators, especially in mobility, continues to create fragmentation, due to these systems not following EU or municipal standards. 80 The municipality benefits from the partnership with ARTE previously known as AMA, the Portuguese authority for interoperability, but lacks established institutional frameworks to support ongoing governance transformations.81

4. Skills and capacity needs

Lisbon lacks sufficient hybrid professionals with abilities in legal expertise, data management and technical competencies. 82 The current lack of hybrid professionals has become the main obstacle to interoperability, surpassing technological restraints. 83 The partnership with the University of Lisbon enables the development of internal talent, but the demand exceeds availability for these skills. 84 Thus, the municipality faces difficulties in executing interoperability requirements that demand legal, governance, semantic and ICT proficiency.85

76 Interview I5 (n 69).

77 Lisbon Council (n 70) 12

78 Interview I5 (n 69); Jens-Peter Schneider, Johannes Erny and Franka Enderlein, ‘Collaborative Governance Structures for Interoperability in the EU’s New Data Acts’ (2025) 16 European Journal of Risk Regulation 24.

79 Interview I5 (n 69).

80 Josep Maria Salanova Grau, ‘The Digitalization of Mobility in Lisbon’ (UIA Initiative, 29 December 2020) 4 –5 <https://www.uia-initiative.eu/en/news/digitalization-mobility-lisbon> accessed 15 November 2025.

81 Interview I5 (n 69).

82 ibid; Ines Mergel, Noella Edelmann and Nathalie Haug, ‘Defining Digital Transformation: Results from Expert Interviews’ (2019) 36(4) Government Information Quarterly 101385.

83 Interview I5 (n 69).

84 ibid.

85 ibid.

5. Role of national and EU authorities

The path of Lisbon’s interoperability is heavily dependent on decisions made by national and EU-level authorities.86 The IES (Interoperability Evaluation System) and EIF provide standards and evaluation systems which guide Lisbon’s operations, while the Digital Europe Programme gives essential funds for infrastructure development, API construction and semantic standardisation. 87 The city serves as a provider of knowledge to EU networks through its open-data ecosystem and urban platform. 88 The goal of complete interoperability by cities is bound by European and national bodies that can provide financial support, policy coherence and regulatory alignment. 89

6. Recommendations

Lisbon should adopt a coherent interoperability plan to reduce fragmentation between departments, modernise outdated systems and introduced a unified semantic structure, and introduce a unified semantic structure, while strengthening hybrid legal -technical skills to ensure a uniform implementation of national and EU standards. 90 Nationally, ARTE should provide a more comprehensive template, clearer GDPR guidance, an expansion of training programmes, as well as technical assistance to support integration with the iAP and operational challenges. 91 At an EU level, an increase of funds for municipal digital infrastructure and interborder initiatives, together with more explicit instructions of overlapping regulatory frameworks, would allow a more effective understanding of the duties which would mak e interoperability measures more effective. 92

V. Tri-city comparative analysis

A comparative analysis reveals that the IEA’s primary challenge is not a lack of highlevel alignment, but rather a fundamental mismatch between its uniform regulatory approach and the different local implementation contexts. To systematically evaluate how European

86 European Commission, (n 66) 3–4.

87 ibid 3, 11.

88 Lisbon Council (n 70) 10–12.

89 Interview I5 (n 69).

90 European Commission, (n 63) 3–5, 12–16; European Commission, New European Interoperability Framework: Promoting Seamless Services and Data Flows for European Public Administrations (Publications Office of the European Union 2017).

91 Interview I5 (n 69).

92 European Commission, (n 66) 3–4, 11; Jens-Peter Schneider, Johannes Erny and Franka Enderlein, ‘Collaborative Governance Structures for Interoperability in the EU’s New Data Acts’ (2025) 16 European Journal of Risk Regulation 24.

interoperability mandates intersect with local governance realities, the table below maps the distinct national frameworks, technical capacities, and structural barriers characterising the three selected municipal case studies.

The Hague Sofia Portugal

National Framework Multi-layered with NORA, GEMMA and PETRA. Electronic Governance Act.

Technical Maturity

High strategic alignment with national APIs, but local friction forces reliance on parallel channels (email/paper). Suffers from a "prestandardisation gap" for emerging smart- city tech.

Reached state-level digital capabilities; actively mapping district systems. Prioritising an opensource Urban Data Platform and a 3D Digital Twin, but heavily burdened by paper-based processes.

Governance Multi-layered legal architecture. A massive volume of overlapping local, national, and EU rules obscures strategic visibility. Central administrative authority over 24 districts. Opensource culture thrives, though uniform data space integration of private sector mobility operators remains a challenge.

Skills Municipal implementers are overwhelmed by administrative and regulatory complexity, causing them to deprioritise legacy

Critical deficit of legal, tech, and architectural experts due to uncompetitive public sector pay. General population displays low basic

National Regulation for Digital Interoperability.

Advanced infrastructure (PGIL, Lisboa Aberta, LxDataLab) coexists with persistent system fragmentation, outdated legacy structures, and a total lack of standardised metadata.

Decentralised technical decisionmaking and data ownership. Departments exhibit uneven digital maturity and lack a unified semantic governance body.

Severe shortage of hybrid professionals combining legal expertise, data management, and ICT proficiency; this

upgrades to maintain core services.

Funding Local strategic investments are frequently diluted by implementation gaps; funding for upgrading legacy architecture is often sidelined.

digital literacy (35.5 per cent). deficit surpasses technical constraints.

Highly vulnerable; municipal funding cut over the past two years for quality-oflife priorities. Heavily dependent on EU pilot projects.

Highly dependent on external EU mechanisms, specifically the Digital Europe Programme, to finance basic API construction and semantic standardisation.

Main Obstacle

Priority Recommendation

Top-down procedural burdens of translating EU regulations amidst existing national frameworks.

Provide practical deployment support for transitions prioritised by the local implementers themselves.

Severe underfunding combined with a shortage of qualified professionals in the public sector. Departmental fragmentation and a critical shortage of hybrid legaltechnical talent to navigate GDPR and AI Act overlaps.

Establish a predictable, fixed budget percentage for digitalisation; partner with universities to train talent; launch local digital literacy campaigns.

Adopt a unified municipal interoperability plan to bridge departmental silos, mandate a shared semantic framework, and scale up hybrid legal- technical training.

The cases represent three distinct scenarios. For The Hague’s regulatory friction, the regulatory sandboxes under Articles 11 offer valuable experimental flexibility; however, this benefit is offset by the mandatory ex -ante assessments under Article 3, which increase administrative drag for digitally mature cities. For Sofia’s resource dependency, the Interoperable Europe Portal and its solutions catalogue successfully mitigate asset development costs through reusable open-source code, yet they cannot resolve the structural core of the issue: an acute deficit in local infrastructure funding and uncompetitive public sector salaries. Finally, for Lisbon’s complexity fragmentation, the governance framework spearheaded by the

Interoperable Europe Board establishes shared semantic standards but lacks the enforcement mechanisms or direct fiscal leverage required to dismantle deeply entrenched departmental silos and legacy architectures.

VI. Conclusion

Together, these cases demonstrate that the gap in EU digital governance is political and operational as well as technical. The IEA’s success depends on the structural recognition of differing local conditions. A uniform, "one-size-fits-all" application risks worsening regulatory friction in advanced contexts like The Hague, causing administrative stagnation in developing systems like Sofia, or leaving departmental silos unaddressed in fragmented cities like Lisbon. Moving forward, the operationalisation of the Act must transition from high-level mandates to direct, actionable interventions tailored across all tiers of European governance.

To translate the principles of the Interoperable Europe Act (IEA) into functional local realities, specific structural adjustments are required at the European, national, and municipal tiers, these are the following:

A. For the European Commission

It is imperative to streamline the mandatory ex-ante interoperability assessments under Article 3 for digitally mature municipalities by creating a fast -track compliance pathway or a "comply-or-explain" mechanism. This would mitigate or soften the procedur al administrative drag identified by local implementers in The Hague. Additionally, as was illustrated in Sofia, reliance on short-term and small-scale pilot projects for funding would need to be replaced. The Commission should introduce structural funding streams dedicated specifically to baseline API development and the migration of local legacy architectures. Finally, the interrelation between the direct legal and technical intersections of the IEA, the GDPR, and the AI Act would need to be mapped out. This would eliminate the legal uncertainty currently paralysing municipal data sharing.

B. For Member States

National authorities (such as ARTE in Portugal or the Ministry of e -Governance in Bulgaria) must expand their mandates beyond national registries to provide localised, handson technical toolkits and standardised metadata frameworks. The critical public se ctor human capital deficit would need to be addressed establishing national frameworks for "hybrid" legaltechnical public roles. Member States should authorise flexible salary structures or dedicated

educational subsidies to allow local municipalities to financially compete with the private sector for architectural talent.

C. For local authorities (municipalities)

It is imperative to establish centralised municipal data governance bodies to curb internal fragmentation and efficiently integrate the legacy systems into unified urban data platforms. Also, to address the human capital shortages, it would be beneficial to further strengthen the relationships between local universities and institutes. Municipalities should make use of open-source data practices.

D. Further research

As the Interoperable Europe Act advances toward widespread execution, several critical pathways for future empirical inquiry emerge, including but not limited to: (i) quantitative scaling, (ii) expansion of municipal case studies and (iii) monitoring of ma ndatory assessments.

Firstly, future research should expand on this qualitative framework by deploying a large-scale quantitative survey across a wider, statistically representative sample of European municipalities. Secondly, extending this comparative methodology to include secondary cities, non-capital municipalities, and rural administrative bodies would reveal how population scale, demographic density, and varying regional autonomy impact a local authority's capability to comply with EU digital standards. Finally, a vital avenue for subsequent research involves tracking the concrete implementation of the first wave of mandatory interoperability assessments under Article 3 once they enter into force. Assessing these systems over a year will offer critical, evidence-based data on whether ex- ante evaluations successfully cultivate crossborder data continuity or if they inadvertently manifest as permanent administrative bottlenecks.

Towards

the EU

digital single market and next -gen government; identifying and bridging gaps from a local perspective

Aoibhe Murphy,(a) Paulina Jakubiec,(b) Oliva Cojanu, (c) and Micol Battistella.(d)

I. Introduction

The following article explores the practical application of the Interoperable Europe Act (IEA) within the Member States of the European Union. The research was conducted from the perspective of the Member States Poland and Italy. Interviews were conducted with one representative from both of the Member States who has direct experience with int eroperability. The following analysis compares two contrasting approaches between the two Member States, to identify the gaps. This comparison allows for a deeper understanding of implementation challenges and successes across different administrative cont exts.

This analysis is guided by three research questions:

1. How are Poland and Italy implementing the Interoperable Europe Act in practice, and what institutional structures aupport this process?

2. What common barriers and divergent challenges emerge in each country’s pursuit of cross-border and domestic interoperability?

3. What policy recommendations can be derived from these experiences to support broader EU-level implementation?

Interoperability is defined in the Interoperable Europe Act as “the ability of network and information systems to exchange, understand, and use data or information in a secure and correct manner, both across borders and across sector.”. 1 This directly builds on the European Interoperability Framework, which recognises four layers; legal, organisational, semantic, and technical interoperability. 2 In essence, making Europe more interoperable would make citizens lives easier by removing the burden of excessive documentation duplication and errors that can

(a) L.L.B. Candidate, International and European Law Programme, The Hague University of Applied Sciences.

(b) L.L.B. Candidate, International and European Law Programme, The Hague University of Applied Sciences.

(c) L.L.B. Candidate, International and European Law Programme, The Hague University of Applied Sciences.

(d) L.L.B. Candidate, International and European Law Programme, The Hague University of Applied Sciences.

1 Regulation (EU) 2024/903 of the European Parliament and of the Council of 13 March 2024 laying down measures for a high level of public sector interoperability across the Union (Interoperable Europe Act) [2024] OJ L 2024/903.

2 European Interoperability Framework (EIF) Toolbox, European Commission.

occur by replacing it with a smoother data flow through online EU - level data bases used by the EU institutions. 3

The IEA is a regulation created by the European Union to promote interoperability in public services in Europe. 4 The rationale behind this act is to reduce costs and administration burdens on citizens, businesses, and administrators. The main features that are found within this act are the following; governance and cooperation framework, mandatory interoperability assessments, and reusing and sharing interoperability solutions between member states. 5

From the early 2000s, Poland has consistently pursued greater nationawide interoperability. They recognised the benefits early and knew that the change to becoming more interoperable should be pursued. When the Interoperable Europe Initiative was launched in 2022, Poland adapted quickly to the frameworks laid out in the initiative. 6

Italy has also taken interest in increasing its interoperability nation -wide. As of 2022, the e-services have grown due to the adoption of the national platform, Piattaforma Digitale nazionale Dati (PDND). The platform aims to establish complete interopera bility of datasets and essential services between central and local public administrations. This enables the practical implementation of the ‘once-only’ principle, which means that citizens and business will only have to provide information to the public a uthorities once. This approach will reduce the administrative burden on users. Additionally, public administrations will be able to communicate with each other in a simple, fast and secure way, without requesting information that is already held by other entities. 7

The question that follows is how to extend national interoperability across all Member States in order to make the Union as a whole more interoperable. By using empirical data

3 ibid.

4 Regulation (EU) 2024/903 of the European Parliament and of the Council of 13 March 2024 laying down measures for a high level of public sector interoperability across the Union (Interoperable Europe Act) [2024] OJ L 2024/903.

5 European Commission, ‘Interoperable Europe Act’ (European Commission, 30 November 2022) <https://commission.europa.eu/publications/interoperable -europe-act_en accessed> accessed 2 April 2026.

6 Act of 17 February 2005 on the Computerisation of the Activities of Entities Performing Public Tasks (Poland) (Journal of Laws 2005 No 64, item 565); Mariusz Chądrzyński, Kinga Gruziel, Elżbieta Kacperska, Tomasz Klusek and Monika Utzig, Polska w dobie cyfryzacji (Wydawnictwo SGGW 2021), 55

7 Interoperable Europe, ‘EU Open Source Solutions Catalogue - Piattaforma Digitale Nazione DatiInteroperabilità’ <https://interoperable -europe.ec.europa.eu/eu-oss-catalogue/solutions/piattaforma-digitalenazione-dati-interoperabilita> accessed 21 Novembe r 2025.

collected and secondary data found from desk research, recommendations are made to identify and bridge the gaps and move towards smart public services and interoperable union.

A. Scope

The focus of this paper asseses how interoperability can extend across all Member States in Europe. The research dives into the perspective from locals from Poland and Italy, to evaluate how interoperability is implemented in the context of the IEA. In add ition to this, the research will look at challenges faced by the Member States whilst implementing the IEA.

B. Methodology

The information used in this paper was collected through both empirical and deskbased sources. Empirical data was obtained through structured interviews with local administrative officials in Poland and Italy. 8 Desk-based sources, such as relevant EU legislation, national legal frameworks, and current interoperability solutions both at national and European levels, were then used to address the challenges identified in the interviews and to develop actionable recommendations. 9

Interviews were first conducted with field experts who apply the concepts of interoperability and operate in digital public administration daily. This allowed for practical insights into the challenges and needs faced by public entities in both of the Mem ber States studied, and to develop actionable recommendations tailored to each country. Additionally, a

8 Diego Martini, Interview, Municipality of Udine (Annex 2, 2026); Ewa Rogowska, Interview, Kołbaskowo Municipality (Annex 1, 2026).

9 Regulation (EU) 2024/903 of the European Parliament and of the Council of 13 March 2024 laying down measures for a high level of public sector interoperability across the Union (Interoperable Europe Act) OJ L 89, 2024, art 2(15), 3; Decreto Legge 22 sette mbre 2022 su Obblighi e termini di accreditamento alla Piattaforma digitale nazionale dati (PDND), Gazzetta Ufficiale Serie Generale n.273 del 22 -11-2022 [Decree-Law of 22 September 2022 on the Requirements and Deadlines for Accreditation to the National D igital Data Platform]; Act of 17 February 2005 on the Computerisation of the Operations of the Entities Performing Public Tasks (ustawa o informatyzacji działalności podmiotów realizujących zadania publiczne) (Dz U 2005 nr 64 poz 565, as amended); ‘Call: DIGITAL-2023 -EDIH-04 Network of European Digital Innovation Hubs’ (European Commission, 20 November 2023) <https://ec.europa.eu/info/funding-tenders/opportunities/docs/2021-2027/digital/wpcall/2023/call-fiche_digital-2023-edih-04_en.pdf> accessed 21 November 2025; ‘European Union - 2024 Digital Public Administration Factsheet: National Interoperability Framework Observatory (NIFO) Supporting Document’ (European Commission, 2024) < https://interoperable-europe.ec.europa.eu/sites/default/files/inlinefiles/NIFO_2024%20Supporting%20Document_EU_vFinal.pdf > accessed 20 November 2025; ‘EU Open Source Solutions Catalogue - Piattaforma Digitale Nazione Dati – Interoperabilità’ (Interoperable Europe) <https://interoperable-europe.ec.europa.eu/eu-oss-catalogue/solutions/piattaforma-digitale-nazione-datiinteroperabilita> accessed 21 November 2025; Republic of Poland, ‘Informacje o akcie ws. Interoperacyjnej Europy’ (Portal Interoperacyjności i Architektury, 2024) < https://www.gov.pl/web/ia/informacje-o-akcie-wsprawie-interoperacyjnej-europy> accessed 1 November 2025.

broader, more comprehensive recommendation was drafted to address common challenges encountered in both contexts.

Regarding the empirical research conducted for Italy, Udine, a medium -sized municipality in the region of Friuli Venezia Giulia was selected. This municipality currently has a department dedicated to digital transition, and the interview was conducted with the head of this department. The interview was structured and designed around more general questions to first understand which digital systems the municipality manages and the interviewee’s familiarity with the concepts of interoperability and the relevan t Italian frameworks aimed at transposing the objectives of the IEA. The discussion then focused on identifying the challenges the municipality faces daily and determining where support is most needed.

Regarding the empirical research conducted for Poland, Kołbaskowo, a small rural municipality, was selected. The interview was conducted with the Deputy Head of the municipality, who also previously worked in Szczecin, a large urban municipality and the capital of the West Pomeranian Voivodeship. This provided a comparative perspective between smaller and larger administrative contexts. The interview was structured and designed to first understand the municipality’s use of digital systems and the interviewe e’s familiarity with interoperability and relevant national and EU frameworks. The discussion then focused on identifying the main challenges faced in practice, particularly in smaller municipalities, and assessing where additional support and resources ar e needed for effective implementation. The same set of structured questions was used for both the Polish and Italian interviews to ensure consistency and allow for a clear comparison between the two case studies.

Taking into consideration that this study is based on two structured interviews, it limits the scope of the findings. The sample of Udine and Kołbaskowo was chosen on an exploratory basis rather than statistical basis in order to obtain an in -depth insight from officials directly involved in digital public administration. These two municipalities were selected as case studies because they offered relevant institutional access and local administrative context in which interoperability practices could be examined through a local perspective. However, Kołbaskowo has approximately 12,000 inhabitants, whereas Udine has approximately 100,000 which may affect the nature of digital governance structures and the extent to which the challenges of interoperability can be observed. Taking this into consideration, the findings from this study should be understood as context-specific and illustrative of recurring themes rather than a representative of all local municipalities in Italy and Poland.

II. Findings

A. POLAND

1. National Framework

Poland has long been recognized for its proactive approach to building digital government systems. Before the IEA’s implementation, national strategies promoted efficient data exchange, online service delivery, and consistent digital standards. 10 Since the IEA’s launch in 2022, Poland has increasingly aligned with a European model that emphasizes crossborder interoperability, shared governance, and collective technological development. 11 These earlier milestones have created a strong domestic foundation, but the current phase marks a shift toward closer European integration. 12

Poland’s early achievements provided the basis for interoperability and e -government modernization. The Act on Computerisation of Entities Performing Public Tasks from 2005 established the legal framework for electronic data exchange. This was followed by the European Interoperability Framework (PL - Krajowe Ramy Interoperacyjności (KRI)), which introduced technical, semantic, and organizational standards for information sharing. Digital platforms such as ePUAP, Profil Zaufany, and the Gov.pl portal became everyday tools for citizens. 13 ePUAP is an online platform that allows users to send documents and communicate with public authorities without needing to visit offices in person.14 Profil Zaufany serves as a secure digital identity, making it possible to log into government systems and sign documents online. 15 The Gov.pl portal functions as a central website where citizens can access public services and find official information in one place. 16

These systems laid strong foundations, but their strategic focus remained national. The Ministry of Digital Affairs coordinated most initiatives, while the Integrated State

10 Act of 17 February 2005 on the Computerisation of the Operations of the Entities Performing Public Tasks (ustawa o informatyzacji działalności podmiotów realizujących zadania publiczne) (Dz U 2005 nr 64 poz 565, as amended).

11 ‘Standardy Krajowych Ram Interoperacyjności (KRI)’ (Ministry of Digital Affairs) <https://www.gov.pl/web/ia/standardy-krajowych-ram-interoperacyjnosci-kri> accessed 24 March 2026.

12 Act of 17 February 2005 on Computerisation of Entities Performing Public Tasks (Journal of Laws 2005 No 64, item 565).

13 Republic of Poland, ‘Informacje o akcie ws. Interoperacyjnej Europy’ (Portal Interoperacyjności i Architektury, 2024) <https://www.gov.pl/web/ia/informacje -o-akcie-w-sprawie-interoperacyjnej-europy> accessed 1 November 2025.

14 Government of Poland, ‘Załatwiaj sprawy urzędowe przez internet na ePUAP’ (Gov.pl) <https://www.gov.pl/web/gov/zalatwiaj-sprawy-urzedowe-przez-internet-na-epuap> accessed 26 May 2026.

15 ibid

16 ‘Gov.pl’ (Government of Poland) < https://www.gov.pl> accessed 26 May 2026.

Informatization Programme (PZIP) aimed to align state registers and enhance citizen -oriented services. 17

Since 2022, however, the focus has shifted from national improvement to European Union alignment. The IEA urged Member States to adopt shared frameworks for data exchange, standardization, and governance. For Poland, this meant adapting instead of replacing, existing systems to meet EU -wide standards. National tools such as PESEL (Polish national ID number), CEIDG (Polish business register), REGON (Polish business statistics number), and ePUAP (Polish online government platform) are being reconfigured for p anEuropean Union interoperability. This requires harmonized data models, semantic compatibility, and cross-border service access. 18

The most visible transformation lies in governance. Previously, Poland’s digital administration operated largely under domestic hierarchies. Now, it participates actively in panEuropean decision-making through the Interoperable Europe Board and related ex pert groups.19 This marks not only an institutional change, but also a cultural one, because egovernment is now part of a shared European infrastructure.

This integration allows Poland to engage in EU -funded programs and co-develop reusable digital solutions. Shared frameworks promote transparency, accountability, and data reusability. Poland’s adaptation extends beyond just technology, involving harmonized procedures, shared governance models, and open collaboration. The partnership is mutually beneficial because Poland’s experience influences EU standards, while European cooperation provides financial, technical, and legal support.

2. Empirical Findings from the Interview

To understand how national and European policies translate locally, Ewa Rogowska, Deputy Head of the Kołbaskowo Municipality, shared her perspective on interoperability across different administrative contexts. Ms. Rogowska also worked in Szczecin, the capital and largest city of the West Pomeranian Voivodeship in North -western Poland. Having worked

17 ‘Ministerstwo Cyfryzacji’ (Serwis Rzeczypospolitej Polskiej) <https://www.gov.pl/web/cyfryzacja> accessed 2 November 2025; ‘Informacjeo akcie ws. Interoperacyjnej Europy’ (Portal Interoperacyjności i Architektury, 2024) <https://www.gov.pl/web/ia/informacje-o-akcie-w-sprawie-interoperacyjnej-europy> accessed 1 November 2025.

18 ibid.

19 ‘The Board: Composition and functioning of the Board’ (European Commission, 2025) <https://interoperableeurope.ec.europa.eu/collection/governance -board/board/> accessed 2 November 2025.

both in a major city and in a rural municipality, she offers a unique comparative view of how digital policies function on the ground. 20

Rogowska noted that interoperability, broadly understood as seamless system cooperation, depends heavily on capacity, scale, and resources. In smaller municipalities, digitalization seeks mainly to simplify paperwork and reduce administrative burdens. Staff rely on national tools like ePUAP and Profil Zaufany for online applications and verification, but permanent IT personnel and stable funding are scarce. Further digital development depends on external support, temporary projects, and clear guidance from higher authorities. 21

Larger cities, in contrast, use interoperability to manage complex administrative ecosystems and enhance service delivery. They run dedicated digital platforms, process high digital service volumes, and continuously expand e -services. Citizens in these cities often handle taxes, applications, and permits online. Still, integration between departmental systems remains challenging. 22

3. Interoperability Constraints

Several enduring barriers emerged from the interview. Fragmented systems that limit technical expertise, GDPR compliance issues, and unstable funding after project completion hinder progress. These challenges are not only technical but also organizational and financial, especially in smaller offices that struggle to maintain digital services after project funding ends. Rogowska observed that municipalities often receive general strategic direction but lack practical examples or implementation tools, slowing their digital advancement. 23

4. Necessities and Recommendations

To strengthen interoperability, Rogowska recommended a ‘starter kit’ approach that provides ready-made software modules, documentation templates, and training materials for small municipalities to reduce entry barriers. Larger cities, meanwhile, would benefit from permanent national competence centres offering technical support, updated standards, and

20 Ewa Rogowska, Interview, Kołbaskowo Municipality (Annex 1, 2026).

21 ibid.

22 ibid.

23 ibid.

expert advice. Rogowska pointed out that maintaining and updating systems, as well as training staff, should be ongoing activities rather than something done once. 24

Poland’s transition toward EU -level interoperability reveals both strengths and disparities within its own administrative landscape. Large urban centres continue developing advanced, resilient e-government systems, while smaller municipalities remain depen dent on national tools and temporary funding. 25 Bridging this digital divide requires ongoing financial support, training accessibility, and coordinated technical guidance. 26

Rogowska concluded that Interoperable Europe’s promise will materialize only if it empowers municipalities of all sizes to participate in a connected, citizen -centred digital future. Consistent standards, collaborative support structures, and sustainable r esources are vital for ensuring that Poland maintains its leading position in digital governance by offering efficiency, transparency, and accessibility to every community. 27

Overall, Poland has built a solid e-government system over time, with strong legal foundations and widely used digital platforms that make public services more accessible. More recently, the focus has shifted toward aligning these systems with EU standards and enabling cross-border cooperation. However, the interview shows that this shift does not work the same everywhere. Larger cities can develop and expand digital services, while smaller municipalities often struggle with limited resources, technical cap acity, and long- term support. This suggests that, despite clear progress, ensuring that interoperabilityworks still requires ongoing investment and more practical support at the local level. 28

B. ITALY

1. Background: From the European Interoperability objectives to the National Framework

The authority responsible for the digital transformation of the country and the implementation of the Interoperable Europe Framework and Act is the National Agency for a

24 ibid.

25 ‘Znaczenie interoperacyjności w projektowaniu inteligentnych miast – smart cities’ (Government of Poland) <https://Gov.pl> accessed 26 May 2026.

26 ‘Będzie europejski portfel tożsamości cyfrowej’ (Przetargach) <https://www.wprzetargach.pl/bedzieeuropejski-portfel-tozsamosci-cyfrowej> accessed 2 November 2025.

27 Ewa Rogowska, Interview, Kołbaskowo Municipality (Annex 1, 2026).

28 ibid.

Digital Italy (AGID).29 The Agency works for the digital transformation of the Italian Public Administration to ensure the achievement of the objectives of the Italian Digital Agenda by coordinating all government agencies nationwide. 30 It also contributes to the widespread adoption of information and communication technologies, fostering innovation and economic growth within the country. 31 The 2024-2026 ‘Three-Year Plan’ for IT in Public Administration is the current framework used for the digital transformation of the Italian Public Administration in accordance with the European Commission Digital Decade Targets. 32

Regarding the public administration’s interoperability and digital public services, the PDND (National Digital Platform for Data) is the core point of reference. The Platform was formally established by the Decreto Legge 22 Settembre 2022 and then developed by AGID to achieve the objectives of the Interoperable Europe Framework as part of the Sub -Investment of the National Recovery and Resilience Plan (PNRR). 33 The platform aims to establish complete interoperability of datasets and essential services between central and local public administrations. This will enable the practical implementation of the ‘once -only’ principle, enhance the information capital of pu blic institutions, and reduce administrative burdens. Ultimately, it will create better services for the Italian citizens and facilitate seamless data exchange between public administrations in the European Union. 34 The platform allows public administrations (PA) to exchange data automatically through Application Programming Interfaces (APIs), following common technical and legal standards. The PDND also provides an API Catalog, which lists all the e-services published by public bodies and through which it is possible to request and exchange public administration data. 35 As of April 2025, over 8,100 entities were registered with the PDND, with 11,700 APIs made available. 36

29 ‘AGID Websit’e (About Agenzia Per L’Italia Digitale (AGID)) <https://www.agid.gov.it/it/agenzia> accessed 20 November 2025.

30 ibid.

31 ibid.

32 AGID, “Piano triennale per l’informatica nella Pubblica Amministrazione” (3year plan for digital Public administration) Edition 2024 -2026; European Commission, ”Digital Decade Policy Programme” (European Commission Website) < https://digital-strategy.ec.europa.eu/en/policies/digital-decade-policy-programme> accessed 23 November 2025.

33 Decreto Legge 22 settembre 2022 su Obblighi e termini di accreditamento alla Piattaforma digitale nazionale dati (PDND), Gazzetta Ufficiale Serie Generale n.273 del 22 -11 -2022 [Decree-Law of 22 September 2022 on the Requirements and Deadlines for Accreditation to the National Digital Data Platform].

34 ibid; ‘EU Open Source Solutions Catalogue - Piattaforma Digitale Nazione Dati – Interoperabilità’ (Interoperable Europe) < https://interoperable-europe.ec.europa.eu/eu-oss-catalogue/solutions/piattaformadigitale-nazione-dati-interoperabilita> accessed 21 November 2025.

35 ibid

36 Michele Nasi, ‘API: cosa sono, a cosa servono e come usarle’ (ilSoftware 2024) <https://www.ilsoftware.it/focus/api-cosa-sono-a-cosa-servono-e-come-usarle/> accessed 2 November 2025.

2. Insights from the empirical research – interview with Diego Martini.

Mr. Martini holds a bachelor's degree in electronic engineering from the University of Padova, and a master's degree in Cloud Management. Mr. Martini has worked for 21 years as an IT Manager at the municipality of Chiampo (Veneto Region, Italy) and has rec ently moved to work in the municipality of Udine (Friuli Venezia Giulia Region, Italy) as head of the department of digital transition of the municipality. 37

From the interview (transcript provided in the annex), the municipality of Udine emerges as well-structured and ready for the digital transformation. A dedicated team of ten professionals is leading the efforts to design new services that are digital -by-default, interoperable-by-design, and user-centric. Mr. Martini’s key priorities concern three principal areas. First, the transformation of Udine into a Smart City through the publication of datasets on the PDND and the release of open data, with the dual p urpose of ensuring transparency and fostering innovation. Second, the improvement of the Municipality's data governance practices, alongside the exploration of innovative applications of Artificial Intelligence. Third, the establishment of digital facilitation points throughout the city, designed to support citizens of varying levels of digital maturity in their daily use of the new digital services.

Overall, as the interview revealed, Udine represents a relatively advanced case within the Italian landscape. Smaller municipalities, which represents the majority of Italian local governments, face substantially greater challenges. These challenges not on ly affect smaller municipalities’ digital transformation efforts but also become a barrier to achieving full interoperability across public administrations at the national level.

(a) Udine’s Interoperability Constraints and Adopted Solutions based on the information gathered in the interview

When exchanging data to create interoperable services, Italian public administrations are required to use the PDND platform and follow common technical standards defined by AGID’s Guidelines.38 The municipality of Udine has an expert team, and it’s already publishing

37 Municipality of Udine website, ‘Digital Transition Service’(Municipality of Udine Website) <https://www.comune.udine.it/Amministrazione/Personale -amministrativo/Martini-Diego/> accessed 15 November 2025.

38 Dipartimento per la Transformazione digitale, “Nuove Linee Guida PDND: l’interoperabilità si arricchisce di funzionalità evolute” [Department for Digital Transformation, “New PDND Guidelines: Interoperability Enhanced with Advanced Features” ] (24 June 20 25) < https://innovazione.gov.it/notizie/articoli/nuove -lineeguida-pdnd-l-interoperabilita-si-arricchisce-di-funzionalita-evolute/> accessed 25 November 2026.

many datasets. However, a limitation that they face is the necessity to collaborate with external technology companies when releasing more complex datasets or digital solutions. When doing so for new services, they ensure ownership of the data. This prevents tech companies from influencing timelines, pricing, and interoperability between the systems of the municipality.

Additionally, when exchanging and storing data through external vendors, the municipality ensures full compliance with GDPR requirements, by requesting them to process and store data according to the GDPR principles before signing any contract. 39 However, the main challenge that the municipality faces is continuous nature of compliance with the GDPR, which is time and resource consuming. To address this onus, the Municipality is creating an automated periodic control system to efficiently fulfil its compliance duties.

Finally, to resolve organisational issues and ensure cohesion toward achieving interoperable digital public services, Mr. Martini’s team will be conducting training sessions for all municipal departments on interoperability and data governance to address t he exchange of high-quality datasets and prevent delays.

(b) Udine’s Necessities to become more interoperable based on the on the information gathered in the interview

The municipality of Udine raises the need for a stronger coordinating role from the national authority (AGID) or the region in guiding the digital transition for smaller municipalities by offering continuous legal and technical expertise for publishing dat a in interoperable formats. As Mr. Martini explained, even with the municipality developing interoperable services and publishing open data and data on the PDND, the impact remains limited if surrounding small municipalities cannot match these standards. This discrepancy creates entirely avoidable delays in quality data gathering that could be resolved if more interoperable databases were made available on the PDND.

Notably, when the PDND was launched through a PNRR call, many municipalities only published APIs to participate, often not publishing any useful datasets or providing follow -ups.

39 European Parliament and Council (EU) Regulation 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection R egulation) [2016] OJ L119/1.

Nevertheless, smaller municipalities are usually understaffed, they often miss a digital transition and face severe budgetary constraints that prevent them from hiring IT specialist. Therefore, if AGID mandates the publishing of key datasets, and the regi on supports small municipalities with technical and legal expertise, the PDND would become an interoperable platform for a digital public administration. 40

In conclusion, the municipality of Udine is well-prepared for the digital transformation. Mr. Martini’s team is successfully transforming Udine into a ‘Smart City’ providing useful services to its citizens by applying the “once-only” principle. In addition, it is publishing datasets on the PDND and simultaneously releasing open data to ensure transparency and foster local innovation.

However, due to the absence of a central authority providing guidance on which databases should be published, as well as financial and technical support for smaller municipalities, the progress made by large and medium -sized municipalities remains insufficient to achieve full interoperability. Small municipalities, which constitute the majority of local governments in Italy in comparison to medium and large municipalities, are unable to keep up with technological development due to a lack of personnel and f inancial resources. Therefore, in order to transform the PDND into a fully interoperable platform, it is necessary to ensure a just transition, one that takes into consideration the different levels of digital maturity and resources across municipalities, minimises the technical burden by developing a central authority responsible for guiding municipalities in the creation of a useful data driven PDND platform; while providing smaller municipalities with the practical means necessary to develop their internal technical and legal compliance capabilities, thereby ensuring that no one is left behind in the digital transition process.

III. Comparative analysis

40 Diego Martini, Interview, Municipality of Udine (Annex 2, 2026) question 5 and 9.

Governance & Coordination

Technical Capacity & Digital Infrastructure

Governance in Poland is relatively centralised, with interoperability and digitalisation guided primarily by national frameworks and standards developed by the Ministry of Digital Affairs. Municipalities rely on national platforms such as ePUAP, Profil Zaufany [Trusted Profile] and Gov.pl, which support more uniform coordination across public administration. 41 Poland also participates in EU -level governance structures under the Interoperable Europe Act, aligning national systems with shared European standards. However, despite this centralised approach, smaller municipalities still face capacity constraints and depend on national guidance and support for implementation. 42

Technical capacity is limited in smaller municipalities due to a lack of dedicated IT staff, with reliance on national platforms and often outdated infrastructure creating additional burdens. Many local administrations depend on external service providers for system maintenance and upgrades, which slows implementation and reduces flexibility. 45 While central

The main authority responsible for the implementation of the Interoperable Europe Act is the National Agency for Digital Italy (AGID), which is the authority in charge of the PDND platform. However, there is limited national coordination on the mandatory publication of specific datasets, which remains largely confined to sector specific obligations.43 Therefore, the publishing of useful datasets on the PDND platform relies largely on the capacity of structured municipalities and on regional coordination. As a result, the quality and quantity of published datasets vary significantly across regions, impacting the overall usefulness of the platform. 44

Technical capacity varies significantly across municipalities, with large municipalities generally better equipped, while smaller ones often rely on external vendors and older legacy systems. Larger municipalities typically have dedicated digital transition teams and are able to design interoperable services and manage data governance more effectively. However, smaller administrations frequently lack specialised staff,

41 ‘Nasze serwisy’ (Ministerstwo Cyfryzacji) <https://www.gov.pl/web/cyfryzacja/nasze -serwisy> accessed 6 April 2026.

42 Ewa Rogowska, Interview, Kołbaskowo Municipality (Annex 1, 2026).

43 Dipartimento per la trasfromazione digitale, ‘Pubblicato l'Avviso PNRR per l'aggiornamento dei numeri civici dei Comuni’ [Department for Digital Transformation, ‘PNRR Notice Published for Updating House Numbers in Municipalities] (30 maggio 2025) <https://innovazione.gov.it/notizie/articoli/pubblicato -l-avviso-pnrr-per-laggiornamento-dei-numeri-civici-dei-comuni/> acessed 25 November 2026.

44 Diego Martini, Interview, Municipality of Udine (Annex 2, 2026).

45 Ewa Rogowska, Interview, Kołbaskowo Municipality (Annex 1, 2026).

Data Management & Exchange

platforms such as ePUAP support interoperability, smaller municipalities often lack the technical expertise and financial resources required to fully integrate and maintain interoperable solutions. 46

Data management in Poland is more standardised due to the use of central registers and national platforms, which promote consistent data formats and structured information exchange. Systems such as ePUAP and national interoperability frameworks provide com mon templates for municipalities, supporting more uniform data handling. 50 However, data quality procedures are not always applied consistently at the local level, and smaller municipalities often lack the capacity to fully implement interoperability standards in practice. 51

Resources & Support National and EU funds are available to aid projects, but they are not the most stable after completion.

which limits their ability to develop and maintain interoperable solutions.47 As a result, despite the availability of national infrastructure such as the PDND, implementation remains uneven and depends heavily on local administrative capacity 48 49

Data management in Italy is very fragmented as there is no list of mandatory datasets to be published on the PDND platform.

Additionally, the publication is carried out through calls for bids, which often results in the publication of datasets that are not particularly useful but are produced mainly to access available funds, undermining the country’s overall data governance. 52

There is very little funding available to help aid the projects in the municipalities. In addition to this, the administrative resources to apply for funding is lacking. This makes it more difficult to organise and create

46 Ministerstwo Cyfryzacji, Krajowe Ramy Interoperacyjności (KRI) (Gov.pl) https://www.gov.pl/web/ia/standardy-krajowych-ram-interoperacyjnosci-kri > accessed 1 December 2026.

47 Diego Martini, Interview, Municipality of Udine (Annex 2, 2026).

48 Agenzia per l’Italia Digitale (AGID), “Piano triennale per l’informatica nella Pubblica Amministrazione” (3year plan for digital Public administration) Edition 2024-2026.

49Diego Martini, Interview, Municipality of Udine (Annex 2, 2026) ; Decreto Legge 22 settembre 2022 su Obblighi e termini di accreditamento alla Piattaforma digitale nazionale dati (PDND), Gazzetta Ufficiale Serie Generale n.273 del 22-11-2022 [Decree-Law of 22 September 2022 on the Requirements and Deadlines for Accreditation to the National Digital Data Platform] Art 3.

50 ‘Serwis ePUAP’ (Ministerstwo Cyfryzacji) <https://www.gov.pl/web/cyfryzacja/serwis -epuap> accessed 6 April 2026.

51 Ewa Rogowska, Interview, Kołbaskowo Municipality (Annex 1, 2026).

52 Diego Martini, Interview, Municipality of Udine (Annex 2, 2026).

Smaller municipalities tend to struggle to upkeep the completed project after the funding ends. There is some support offered through 'strategic direction' but there is a lack of practical examples to help. 53

projects because if there is no one to apply for the funding, they do not have the budget to start the projects. Some guidance is available, but there is nothing centralised for people to look to.54

By comparing the information, we collected about interoperability in Poland and Italy, it is clear that there are some overlapping issues at hand. Nevertheless, there are also some aspects in which both countries excel in, which other Member States within the EU should follow and adapt.

A. The main cross -cutting issues

Comparing and contrasting the data found on both Italy and Poland, there are some clear issues that overlap:

1. Financial Capacity

In both countries, smaller municipalities struggle with limited financial resources. In Poland, projects often depend on temporary national or EU funding, and municipalities face difficulties maintaining systems after funding ends. In Italy, funding exists , but smaller municipalities often lack the administrative capacity to apply for and manage projects, which makes implementation uneven and smaller authorities are disadvantaged. 55

2. Governance and Implementation

Governance is another area in which both countries face the same issues. Although both countries have national frameworks, implementation varies at local level. In Poland governance is more centralised, but smaller municipalities still depend on national g uidance and face capacity constraints. In Italy, coordination relies heavily on regional and local capacity, and the

53 Ewa Rogowska, Interview, Kołbaskowo Municipality (Annex 1, 2026).

54 Diego Martini, Interview, Municipality of Udine (Annex 2, 2026).

55 Ewa Rogowska, Interview, Kołbaskowo Municipality (Annex 1, 2026); ibid; ‘Krajowe Ramy Interoperacyjności (KRI)’ (Ministerstwo Cyfryzacji) <https://www.gov.pl/web/ia/standardykrajowychraminteroperacyjnoscikri> accessed 13 April 2026.

absence of mandatory dataset publication leads to differences in implementation across municipalities. 56

3. Technical Capacity

Both Italy and Poland show strong technical capacity differences between large and small municipalities. On the one hand, smaller municipalities lack dedicated IT staff and rely on national platforms and regional support. On the other hand, larger municipa lities have digital transition teams, which allow the administrations to integrate and maintain interoperable datasets and solutions. This leads to uneven national interoperability implementation and undermines both countries’ data governance. 57

4. Implications

By identifying the cross-cutting issues between both Member States, it can allow for direct and targeted recommendations. Instead of treating Italy and Poland as identical cases, this approach highlights the specific barriers that each of them face while a lso pinpointing where they overlap. This approach makes it easier to suggest solutions that are reasonable and tailored to their needs.

VI. Recommendations

A. Recommendation for Poland - Mandatory Interoperability Assessments in Municipal IT Procurement

1. What does this recommendation involve and how should it be effectively implemented in practice?

This recommendation is designed for Polish municipalities to undertake interoperability assessments in the course of IT procurement processes, wherever there is an intention to link the systems to national registers, reuse it across various departments or where it is anticipated to eventually integrate across borders. 58 This would directly address the issue

56 ibid; Diego Martini, Interview, Municipality of Udine (Annex 2, 2026); A enzia per l’Italia Digitale (AGID), Piano Triennale per l’Informatica nella Pubblica Amministrazione (3year plan for digital Public administration) 2024–2026 (AGID 2024).

57 ibid; Ewa Rogowska, Interview, Kołbaskowo Municipality (Annex 1, 2026).

58 Regulation (EU) 2024/903 of the European Parliament and of the Council of 13 March 2024 laying down measures for a high level of public sector interoperability across the Union (Interoperable Europe Act) OJ L 89, 22.3.2024, arts 2(15), 3.

identified in the interview with Ewa Rogowska, the Deputy Mayor of Kobaskowo Municipality, that fragmented systems are often created or reinforced at the point of procurement rather than inherited from older infrastructure. 59 As Ewa Rogowska mentions, “different departments use separate systems that are difficult to synchronize” even in large cities.60 The problem is not the legacy systems, but rather the new procurement decisions are not taking interoperability into consideration upfront, creating new incompatibilities. 61

It can be adopted by mandating all public sector bodies to include these assessments when changing or gaining new technology systems. Under the Interoperable Europe Act, interoperability assessments are required for all public sector bodies that introduce binding requirements affecting cross -border digital services. 62 Poland can extend its requirements for interoperability compliance to IT investments at the municipal level to align with the more general EU framework and avoid non -interoperable systems.63 It also refelects digital ready policymaking, since any procurement decisions will be made with digital implementation, interoperability and future reuse as underlying considerations from the start. 64

While mandatory interoperability assessments were introduced in the Interoperable Europe Act in 2025 and concern only binding conditions impacting digital public services on a trans-European level, this proposal extends the idea of interoperability assessm ents to procurement at the municipal level to ensure interoperability is considered when systems are first acquired, preventing inconsistencies. Such mandatory assessments will operationalise the

59 Ewa Rogowska, Interview, Kołbaskowo Municipality (Annex 1, 2026)

60 ibid.

61 ibid.

62 Regulation (EU) 2024/903 of the European Parliament and of the Council of 13 March 2024 laying down measures for a high level of public sector interoperability across the Union (Interoperable Europe Act) OJ L89/1, art 5.

63 Regulation (EU) 2024/903 of the European Parliament and of the Council of 13 March 2024 laying down measures for a high level of public sector interoperability across the Union (Interoperable Europe Act) OJ L89/1, art 6; ‘European Union - 2024 Digital Public Administration Factsheet: National Interoperability Framework Observatory (NIFO) Supporting Document’ (European Commission, 2024) < https://interoperableeurope.ec.europa.eu/sites/default/files/inline -files/NIFO_2024%20Supporting%20Document_EU_vFinal.pdf> accessed 20 November 2025; NIFO Roadshow in Poland, with the participation of SEMIC (European Commission,, 2024) < https://interoperable-europe.ec.europa.eu/sites/default/files/news/202407/SC30_D05.01_Roadshow report.pdf> accessed 20 November 2025; Directive 2014/24/EU of the European Parliament and of the Council of 26 February 2014 on public procurement and repealing Directive 2004/18/EC OJ L94/65, art 4, 5.

64 European Commission, ‘Digital-ready policymaking’ (Interoperable Europe Portal, 28 October 2025) <https://interoperable-europe.ec.europa.eu/topic/digital-government/digital-ready-policymaking> accessed 10 June 2026; Publications Office of the European Union, ENDORSE 2025: 3rd European Data conference On Reference data and Semantics (Publications Office of the European Union, 2026) <https://op.europa.eu/en/publication-detail/-/publication/734821ad-edd1-11f0-8d3c-01aa75ed71a1> accessed 10 June 2026.

need, expressed by Ewa Rogowska for “ready -to-use software components, sample documents and manuals and training materials”. 65

2. Benefits:

This recommendation has a high feasibility because the European Commission mandates interoperability assessments EU -wide as of 2025, providing a clear legal and operational basis.66 In addition to this, it ensures that all new systems are designed to comply with the common standards from the outset preventing the creation of any further gaps 67 Over time will reduce costs and time as systems will need less work to become compatible with one another.

The greater policy value of this approach is the fact that it facilitates digital ready policymaking through procurement decisions aligning with the expected digital implementation of public services. 68 At the same time, the strategy avoids the creation of new discrepancies within the public sector, which would be more costly than dealing retroactively with interoperability. 69

3. Potential challenges:

In the beginning, it would be more expensive as there would be a need for testing systems and consultants to conduct the assessments. This makes the initial investment quite high. furthermore, conducting reports and testing would delay implementation of th e new systems by a small period of time.

4. How can other Member States implement this recommendation?

This recommendation would be feasible for all Member States in the EU and should be implemented at the municipal purchasing level. Ultimately, these same benefits would apply

65 Ewa Rogowska, Interview, Kołbaskowo Municipality (Annex 1, 2026).

66 Regulation (EU) 2024/903 of the European Parliament and of the Council of 13 March 2024 laying down measures for a high level of public sector interoperability across the Union (Interoperable Europe Act) OJ L89/1, arts 5-7.

67 ibid art 4(1).

68 Regulation (EU) 2024/903 of the European Parliament and of the Council of 13 March 2024 laying down measures for a high level of public sector interoperability across the Union (Interoperable Europe Act) OJ L89/; Interoperable Europe Board, 'Interoperability assessments are now mandatory' (Interoperable Europe , 12 January 2025) <https://interoperable-europe.ec.europa.eu/interoperable-europe/news/interoperability-assessments-arenow-mandatory> accessed 10 June 2026.

69 Regulation (EU) 2024/903 of the European Parliament and of the Council of 13 March 2024 laying down measures for a high level of public sector interoperability across the Union (Interoperable Europe Act) OJ L89/1; arts 4, 5, 6; Ewa Rogowska, Interview, Kołbaskowo Municipality (Annex 1, 2026).

to all other MS; If every country adopted similar procedures, it would make interoperability across Europe significantly easier to achiveve.

B. Recommendation for Italy - Binding PNRR Calls for Mandatory Dataset

Publication on the PDND with Clear Deadlines for small Municipalities

1. What does this recommendation involve and how should it be effectively implemented in practice?

The publication of information related to the PNRR in Italy must be restructured so that the act of publishing on the PDND stops being merely a discretionary activity and rather becomes a concrete obligation associated with defined datasets, deadlines and follow-up requirements. 70 This will address the issue of some municipalities using APIs and datasets for the purpose of securing funds, while ignoring to check if the data is useful, complete or reusable in practice. 71

By mandating dataset publication on the PDND platform with clear deadlines, the regulatory framework would enhance transparency by facilitating timely access to data. Crucially, the regulatory framework must also address the substance of these disclosures, as the content currently published by public authorities remains qualitatively insufficient . 72 The main issue faced concerns insufficient institutional data published by public authorities, particularly in terms of content. 73 Consequently, it lacks the necessary substance and context for other public authorities to understand and utilize the data effectively. 74

70 European Commission, ‘Italy’s Recovery and Resilience Plan’ (European Commission, 2024) <https://commission.europa.eu/business -economy-euro/economic-recovery/recovery-and-resiliencefacility/country-pages/italys-recovery-and-resilience-plan_en> accessed 21 November 2025; ‘Platform overview PDND Interoperability Operational Manual’ (PagoPA, 5 September 2024) < https://developer.pagopa.it/pdndinteroperabilita/guides/PDND-Interoperability-Operating -Manual> accessed 10 June 2026; Directive (EU) 2019/1024 of the European Parliament and of the Council of 20 June 2019 on open data and the re -use of public sector information (recast) OJ L172/56, arts 3, 5.

71 Diego Martini, Interview, Municipality of Udine (Annex 2, 2026); Regulation (EU) 2024/903 of the European Parliament and of the Council of 13 March 2024 laying down measures for a high level of public sector interoperability across the Union (Interoperable Europe Act) OJ L89/, recitals 8-12; Directive (EU) 2019/1024 of the European Parliament and of the Council of 20 June 2019 on open data and the re -use of public sector information (recast) OJ L172/56, arts 7, 14.

72 European Commission, ‘Italy’s Recovery and Resilience Plan’ (European Commission, 2024) <https://commission.europa.eu/business -economy-euro/economic-recovery/recovery-and-resiliencefacility/country-pages/italys-recovery-and-resilience-plan_en> accessed 21 November 2025; Italian Ministry of Economy and Finance, ‘The National Recovery and Resilience Plan (NRRP)’ (MEF, 2025) https://www.mef.gov.it/en/focus/The-National-Recovery-and-Resilience-Plan-NRRP/ accessed 21 November 2025.

73 Diego Martini, Interview, Municipality of Udine (Annex 2, 2026).

74 ibid.

The recommendation should be implemented in a phased and proportionate manner. It is essential for smaller cities to have extended periods for adaptation, templates, and support from AGID or other bodies.75 At the same time, it would be expected for more organized municipalities to adapt faster and serve as reference models. 76 This will ensure that the initiative remains realistic while PDND becomes functional. 77

By implementing a clear, structured framework of what is needed to be published on the PDND and the consequences of non -compliance, the level of interoperability in Italy could be strengthened. 78 Furthermore, it reduces the risk of duplication of data collection. 79 This ensures that other public administration can seamlessly access and utilize the collective data, operationalizing what is known as the ‘once-only’ principle. 80

The publication requirement should be linked to basic data quality factors, such as regularity of updates, completeness of metadata, and semantic consistency. The importance of reference data, semantic interoperability, and multilingual knowledge organizat ion is emphasized by ENDORSE 2025 as a factor supporting the claim that published datasets must

75 ‘Published the 2024 -2026 Three-Year Plan for Information Technology in Public Administration’ https://www.agid.gov.it/en/agenzia/stampaecomunicazione/notizie/2024/02/13/published -2024-2026-three-yearplan-information-technology-public-administration (Agency for Digital Italy (AGID), 13 February 2024) accessed 10 June 2026; ‘How to finance cities' and regions digital transformation’ ( Living-in.EU, 25 September 2024) <https://living-in.eu/news/how-finance-cities-and-regions-digital-transformation> accessed 10 June 2026; ‘European Digital Innovation Hubs (EDIHs)’ (European Commission) < https://digitalstrategy.ec.europa.eu/en/policies/edihs> accessed 21 November 2025.

76 ibid.

77 'Piattaforma Digitale Nazionale Dati' (Comune di Udine, October 2022) <https://www.comune.udine.it/Amministrazione/Documenti -e-dati/Progetti/Piattaforma-Digitale-NazionaleDati> accessed 10 June 2026; ‘AgID e i progetti del PNRR’ ( Agency for Digital Italy (AGID), 2021) https://www.agid.gov.it/it/agenzia/attuazione -misure-pnrr accessed 10 June 2026; Camera dei Deputati, 'Mission 1: ‘Digitalisation, innovation, competitiveness and culture’ (Camera IT, 25 March 2021) https://www.camera.it/temiap/2021/03/25/OCD177 -4876.pdf accessed 21 November 2025

78 Directive (EU) 2019/1024 of the European Parliament and of the Council of 20 June 2019 on open data and the re-use of public sector information (recast) OJ L172/56, arts 3, 5; AgID, ‘PDND Interoperability Operating Manual v1.0’ (Pagopa, 5 September 2024) < https://developer.pagopa.it/pdnd-interoperabilita/guides/PDNDInteroperability-Operating-Manual> accessed 21 November 2025.

79 Regulation (EU) 2024/903 of the European Parliament and of the Council of 13 March 2024 laying down measures for a high level of public sector interoperability across the Union (Interoperable Europe Act) OJ L 89, art2; ibid, recitals 8-12; European Commission, ‘EU-wide digital once-only principle for citizens and businesses’ (Publications Office of the European Union, 2017) <https://op.europa.eu/en/publication-detail//publication/4c429e34-e3a6-11e7-9749-01aa75ed71a1> accessed 21 November 2025.

80 ibid.

be usable and not just available. 81 This also reflects digital ready policymaking since it implies that policy tools should take into account the need for digital publication and interoperability. 82

2. Benefits

The proposed recommendation is highly feasible, as the Italian Digital Agency (AgID) has the authority to issue PNRR calls and there is clear precedent in other existing PNRR digital initiatives.83 Building on this foundation, the measure focuses on converting voluntary interoperability into mandatory compliance to ensure all municipalities contribute and the oneonly principle implementation is facilitated, making citizens’ lives easier by only giv ing needed information once. 84 At the same time, it would improve transparency both among public administration and between public administration and the public. Overall, this approach would increase efficiency by reducing duplication, saving time, and lowering the costs associated wit h repeatedly collecting the same data.

If regional authorities were to support small municipalities in publishing certain data in a uniform format, this could establish a functional and interoperable system. Conversely, if the implementation of these concepts remains purely voluntary, larger mu nicipalities would publish their data, whereas smaller entities will lack the capacity to take those necessary steps. Success cannot be scaled from Udine's experience because this is a very proactive digital transition with a team of 10 persons. 85 Binding PNRR calls, together with clear deadlines and consequences, force small municipalities to participate in the journey of becoming

81 ENDORSE, ‘3rd European Data conference On Reference data and Semantics’ (Publications Office of the European Union, 2026) <https://op.europa.eu/en/publication -detail/-/publication/734821ad-edd1-11f0 -8d3c01aa75ed71a1> accessed 10 June 2026.

82 ibid.

83 ‘AgID e i progetti del PNRR’ (Italian Digital Agency (AgID), 2025) <https://www.agid.gov.it/it/agenzia/attuazione -misure-pnrr> accessed 21 November 2025; ‘Home’ (pagoPA) <https://www.pagopa.gov.it> accessed 21 November 2025; ‘SPID - Public Digital Identity System’ (Agenzia per l'Italia Digitale (AgID)) < https://www.agid.gov.it/en/platforms/spid> accessed 21 November 2025; Agenzia per l'Italia Digitale (AgID), 'Electronic InvoicingPEPPOL', https://peppol.agid.gov.it/en/insights/electronic -invoicing/ accessed 21 November 2025.

84 Regulation (EU) 2024/903 of the European Parliament and of the Council of 13 March 2024 laying down measures for a high level of public sector interoperability across the Union (Interoperable Europe Act) OJ L89/1, recitals 1-7; ‘70% of EU citizens used online public services in 2024’ (Eurostat) <https://ec.europa.eu/eurostat/web/products -eurostat-news/w/ddn-20250226-1> accessed 21 November 2025; ‘Surveys detail 2959’ (Eurobarometer) <https://europa.eu/eurobarometer/surveys/detail/2959> accessed 21 November 2025.

85 Diego Martini, Interview, Municipality of Udine (Annex 2, 2026).

interoperable, whilst regional hubs provide the support enabling smaller municipalities success.86

3. Potential challenges:

Potential challenges include difficulties with compliance, as it will take time to implement the necessary systems and ensure that data is properly publicised, which some may perceive as budernsome. Additionally, after publication, monitoring and updating the data must be followed.

4. How can other Member States implement this?

By creating their own platform in which public administrations can upload the necessary data, the same mandatory requirements can be enforced. 87 The same benefits can be applied but it is important to note that some Member States may have more resistant to this change than others.88 However, to ensure a more interoperable Europe, it is crucial that all comply. 89 This also illustrates the value of digital ready policymaking for translating national or regional digital public service goals into operational requirements that can be implemented consistently. 90

C. Joint Recommendation - Closing Municipal Interoperability Gaps by Expanding the European Digital Innovation Hub Network

86 ‘Mission 1: Digitalisation, innovation, competitiveness and culture’ (Camera dei Deputati, 25 March 2021) <https://www.camera.it/temiap/2021/03/25/OCD177-4876.pdf> accessed 21 November 2025.

87 Regulation (EU) 2024/903 of the European Parliament and of the Council of 13 March 2024 laying down measures for a high level of public sector interoperability across the Union (Interoperable Europe Act) OJ L 89, 22.3.2024, arts 3–4.

88 ‘Digital‑ready policies: How interoperability in sharing open data supports digital‑by‑default implementation’ (European Commission, 4 August 2024) < https://data.europa.eu/en/news -events/news/digital-ready-policieshow-interoperability-sharing-open-data-supports-digital> accessed 21 November 2025.

89 ‘Interoperable Europe’ ( European Commission) <https://interoperable-europe.ec.europa.eu> accessed 21 November 2025.

90 ‘Digital-ready policies: How interoperability in sharing open data supports digital transformation’ (European Union, 4 August 2024) <https://data.europa.eu/en/news -events/news/digital-ready-policies-how-interoperabilitysharing-open-data-supports-digital> accessed 13 June 2026; ‘Italy's recovery and resilience plan’ (European Commission, 13 July 2021) <https://reforms -investments.ec.europa.eu/recovery-and-resilience-facility1/country-pages/italys-recovery-and-resilience-plan_en accessed> 13 June 2026; ‘Pub lished the 2024-2026 Three-Year Plan for Information Technology in Public Administration’ (Agency for Digital Italy (AGID), 13 February 2024) <https://www.agid.gov.it/en/agenzia/stampa -e-comunicazione/notizie/2024/02/13/published2024-2026-three-year-plan-information-technology-public-administration> accessed 10 June 2026; ENDORSE 2025: 3rd European Data conference On Reference data and Semantics (Publications Office of the European Union, 2026) <https://op.europa.eu/en/publication-detail/-/publication/734821ad-edd1-11f0 -8d3c01aa75ed71a1> accessed 10 June 2026; Regulation (EU) 2024/903 of the European Parliament and of the Council of 13 March 2024 laying down measures for a high level of public sector interoperability across the Union (Interoperable Europe Act) OJ L89/1, recitals 1-7.

1. What does this recommendation involve and how should it be effectively implemented in practice?

For both countries, the recommendation would be to enhance the functional significance of the European Digital Innovation Hub network in order to assist the municipalities in the implementation of interoperability, data management, and digital services design.91 Instead of establishing another level of institutional infrastructure, this approach builts on the existing EDIHs and adjusts their support functions to better meet the needs of municipalities, particularly small ones with limited staff or digital capabil ities. 92

The monitoring framework for digital transformation regarding public services is established by the European Commission’s 2025 State of the Digital Decade report and the Digital Policy Programme 2030. 93 Although the European Commission monitors the digital performance at a national level, it provides no standardized assessment or support system for interoperability at non- cross border interoperability at municipal level, where the requirements of the Interoperable Europe Act must be ultimately implemented. 94 This gap also illustrates the need for digitally ready policy- making to ensure that digital public services have supportive implementation capacity, not just at the national level of monitoring. 95

91 ‘European Digital Innovation Hubs (EDIHs)’ (European Commission) < https://digitalstrategy.ec.europa.eu/en/policies/edihs> accessed 21 November 2025; ‘The Digital Europe Programme’ (European Commission, 8 October 2025) <https://digital-strategy.ec.europa.eu/en/activities/digital-programme> accessed 10 June 2026; ‘Update on the EDIH Network's activities and impact on Europe's digital transformation’ (European Commission, 26 June 2025) <https://european-digital-innovation-hubs.ec.europa.eu/news/updateedih-networks-activities-and-impact-europes-digital-transformation> accessed 10 June 2026.

92 ‘Characteristics and regional coverage of the EDIH Network: discover the comprehensive report’ ( European Commission's Joint Research Centre (JRC), 18 December 2023) < https://european-digital-innovationhubs.ec.europa.eu/news/characteristics -and-regional-coverage-edih-network-discover-comprehensive-report> accessed 10 June 2026; ‘EXPAND’ (EXPAND EDIH, 31 December 2020); ‘How to finance cities' and regions digital transformation’ (Living-in.EU, 24 September 2024) < https://european-digital-innovationhubs.ec.europa.eu/edih-catalogue/expand> accessed 13 June 2026.

93 ‘State of the Digital Decade 2025 report’ (European Commission) <https://digitalstrategy.ec.europa.eu/en/library/state -digital-decade-2025-report> accessed 21 November 2025; ‘Digital Decade Policy Programme’ (European Commission) <https://digital-strategy.ec.europa.eu/en/policies/digital-decadepolicy-programme> accessed 21 November 2025.

94 ‘State of the Digital Decade 2025 report’ (European Commission) <https://digitalstrategy.ec.europa.eu/en/library/state -digital-decade-2025-report> accessed 21 November 2025; Regulation (EU) 2024/903 of the European Parliament and of the Council of 13 March 2024 laying down measures for a high level of public sector interoperability across the Union (Interoperable Europe Act) OJ L89/1, arts 5 -7, 12.

95 ‘Digital-ready policies’ (European Commission, DG DIGIT , 2023) <https://interoperableeurope.ec.europa.eu/collection/digital-ready-policymaking/digital-ready-policies> accessed 10 June 2026; ‘Digital-ready policymaking’ (European Commission, DG DIGIT , 28 October 2025) <https://interoperableeurope.ec.europa.eu/topic/digital-government/digital-ready-policymaking> accessed 10 June 2026; ‘State of the Digital Decade 2025 report’ (European Commission) <https://digital-strategy.ec.europa.eu/en/library/state -

Instead of creating new frameworks, this recommendation focuses on the existing 151 EDIHs currently funded through the Digital Europe Programme by providing municipal support through additional funds designated specifically for municipal services, a Standa rdized Municipal Digital Maturity Assessment Tool derived from the existing Digital Maturity Assessment Tool enterprise framework, performance metrics requiring a minimum percentage of municipal clients and compliance with the timelines set in the Interope rable Europe Act. 96

This recommendation is built on the existing institutional and legal framework of the Interoperable Europe Act and the Digital Europe Programme. It aims to uphold the principle of subsidiarity through voluntary Member State participation and co -financing while operationalizing Article 7 of the Interoperable Europe Act, which requires Member States to guarantee public sector bodies access to expertise, a requirement currently unmet for municipalities in relation to non-cross border digital services.97 Furthermore, this proposal leverages the already existing budget for digital transformation in less developed areas set up by the Cohesion Policy, which can be expanded to finance implementation. 98 The upcoming digital-decade-2025-report> accessed 21 November 2025; ‘Digital Decade - Policy programme’ (European Commission,16 June 2025) <https://digital-strategy.ec.europa.eu/en/policies/digital-decade-policy-programme> accessed 10 June 2026; OECD, 'Developing skills for digital government: A review of good practices across OECD governments' (OECD 2024) < https://www.oecd.org/en/publications/developing -skills-for-digitalgovernment_f4dab2e9-en.html> accessed 10 June 2026; ‘Digital-ready policymaking’ (European Commission, Joint Research Centre (JRC), 15 November 2020) < https://joint-research-centre.ec.europa.eu/projects -andactivities/innovations -public-governance/digital-ready-policymaking_en> accessed 10 June 2026; European Commission, ‘How to face the implementation of digital -ready policymaking’ (Publications Office of the European Union 2024) < https://op.europa.eu/es/publication-detail/-/publication/529f55c3-c5bd-11f0-8da201aa75ed71a1/language-en> accessed 10 June 2026.

96 ‘The Digital Europe Programme’ (European Commission) <https://digitalstrategy.ec.europa.eu/en/activities/digital-programme> accessed 21 November 2025; ‘Call for proposals DIGITAL-2025 -EDIH -AC-08: European Digital Innovation Hubs - Associated countries (EDIHs with reinforced AI focus)’ (European Commission) <https://ec.europa.eu/info/funding-tenders/opportunities/portal/screen/opportunities/calls -for-proposals?callIdentifier=DIGITAL-2025-EDIH-AC-08&isExactMatch=true&status=31094501> accessed 21 November 2025; ‘Open DMAT - Digital Maturity Assessment tool’ (European Digital Innovation Hubs) <https://european-digital-innovation-hubs.ec.europa.eu/open-dma> accessed 21 November 2025; ‘DIGITAL Monitoring’ (European Commission) <https://ec.europa.eu/digital-buildingblocks/sites/spaces/DIGITAL/pages/684630922/DIGITAL+Monitoring > accessed 21 November 2025; Regulation (EU) 2024/903 of the European Parliament and of the Council of 13 March 2024 laying down measures for a high level of public sector interoperability across the Union (Interoperable Europe Act) OJ L89/1, art 5 -6; Regulation (EU) 2024/903 of the European Parliament and of the Council of 13 March 2024 laying down measures for a high level of public sector interoperability across the Union (Interoperable Europe Act) OJ L89/1, recitals 911.

97 Regulation (EU) 2024/903 of the European Parliament and of the Council of 13 March 2024 laying down measures for a high level of public sector interoperability across the Union (Interoperable Europe Act) OJ L89/1, art 7; Consolidated Version of the Treaty on the Functioning of the European Union OJ C326/47, art 5; ‘State of the Digital Decade 2025 report’ (European Commission) <https://digital-strategy.ec.europa.eu/en/library/statedigital-decade-2025-report> accessed 21 November 2025.

98 ‘Allocation of Cohesion policy funding to Member States for 2021 -2027’ (European Court of Auditors, March 2019) <https://www.eca.europa.eu/lists/ecadocuments/rcr_cohesion/rcr_cohesion_en.pdf> accessed 21 November 2025; Breakdown of Cohesion Policy allocations per Member State’ (European Commission, February 2022) <https://commission.europa.eu/system/files/2022-02/cohesion_policy.pdf> accessed 21 November 2025.

Digital Europe Programme 2028-2034, which is currently under negotiation, also provides for the integration of municipal services as a priority for digital public services. 99 Since the EDIHs network is already formally mandated to service the public sector requires no new legislative or regulatory framework. 100

Examples of this kind of support may range from interoperability assessment to learning about semantic standards and data governance. 101 Furthermore, EDIHs could assist municipalities to test if their data is sufficiently structured for reuse, whether they use common terminology, and whether their services are designed with a view to being implemented digitally. 102 In this way, the support function would be much more relevant to the evidence gathered through interviews as it addresses the issues raised by municipalities rather than abstract policy objectives. 103

2. Benefits:

Three benefits can be identified here. First, EDIHs provide small municipalities lacking IT staff with assessment, training, and technical support. Second, municipalities are prompted to create standardized data sets to facilitate cross -administrative data exchanges. 104 Third, this strategy minimizes the time municipalities spend on redundant documentation. 105

3. Potential Challenges:

The challenges identified are twofold. First, expanding municipal services would require hiring and training more staff, which may place financial and administrative burdens on municipalities. 106 Second, municipalities provide insufficient or non-standardized data sets,

99 ‘European Digital Innovation Hubs (EDIHs)’ (European Commission) < https://digitalstrategy.ec.europa.eu/en/policies/edihs> accessed 21 November 2025.

100 ibid.

101 ibid.

102 ibid.

103 ibid; Ewa Rogowska, Interview, Kołbaskowo Municipality (Annex 1, 2026); Diego Martini, Interview, Municipality of Udine (Annex 2, 2026).

104 Regulation (EU) 2024/903 of the European Parliament and of the Council of 13 March 2024 laying down measures for a high level of public sector interoperability across the Union (Interoperable Europe Act) OJ L89/1, art 2-4; ‘ISA² - Interoperability solutions for public administrations, businesses and citizens’ (European Commission) <https://ec.europa.eu/isa2/> accessed 21 November 2025.

105 Regulation (EU) 2024/903 of the European Parliament and of the Council of 13 March 2024 laying down measures for a high level of public sector interoperability across the Union (Interoperable Europe Act) OJ L89/1, recitals 1-7.

106 ‘The Digital Europe Programme’ (European Commission) <https://digitalstrategy.ec.europa.eu/en/activities/digital-programme> accessed 21 November 2025.

undermining the goal of interoperability by limiting the effectiveness of cross -administrative data exchange. 107

4. How can other Member States implement this recommendation?

The presence of 151 operational EDIHs across all 27 Member States allows this recommendation to scale automatically. 108 Since current hubs would only extend their operational scope, no new infrastructure needs to be constructed.

V. Conclusion

To summarize, this case study documents a critical implementation gap in the EU's digital policy, which mandates municipal interoperability, but does not provide operational support for implementation. 109 After concluding interviews with Polish and Italian municipal officials, the paper confirms the core challenge is a lack of organizational capacity rather than the absence of technical infrastructure. 110 Therefore, the recommendations presented aim to close the identified gaps and achieve true interoperability between the local administration and the broader public sector. In other words, the European Union has created the legal framework, allocated funding, and built supporting infrastructure, but left implementation to municipalities lacking the capacity to execute it. 111 Without targeted intervention, citizens in rural and peripheral regions risk falling persistently behind their urban counterparts in digital service access 112

107 Directive (EU) 2019/1024 of the European Parliament and of the Council of 20 June 2019 on open data and the re-use of public sector information OJ L172/56, arts 7, 14.

108 ‘Characteristics and regional coverage of the EDIH Network: discover comprehensive report’ (European Digital Innovation Hubs, 18 December 2023) <https://european-digital-innovation-hubs.ec.europa.eu/news/characteristics -and-regional-coverage-edih-network-discover-comprehensive-report> accessed 21 November 2025.

109 Regulation (EU) 2024/903 of the European Parliament and of the Council of 13 March 2024 laying down measures for a high level of public sector interoperability across the Union (Interoperable Europe Act) OJ L 89, 22.3.2024, art 3 and recitals 8–12; European Commission, ‘State‑of‑play report on digital interoperability 2023’ (Interoperable Europe, 2023) < https://interoperable-europe.ec.europa.eu/sites/default/files/news/2023 -11/State of play report 2023.pdf> accessed 21 November 2025; Ewa Rogowska, Interview, Kołbaskowo Municipality (Annex 1, 2026); Diego Martini, Interview, Municipality of Udine (Annex 2, 2026).

110 ibid.

111 European Commission, ‘State‑of‑play report on digital interoperability 2023’ (Interoperable Europe, 2023) <https://interoperable-europe.ec.europa.eu/sites/default/files/news/2023 -11/Stateofplayreport2023.pdf> accessed 21 November 2025; ‘Digital Europe Programme’ (European Commission) <https://digitalstrategy.ec.europa.eu/en/activities/digital-programme> accessed 21 November 2025; Regulation (EU) 2024/903 of the European Parliament and of the Council of 13 March 2024 laying down measures for a high level of public sector interoperability across the Union (Interoperable Europe Act) OJ L 89, 22.3.2024.

112 Ewa Rogowska, Interview, Kołbaskowo Municipality (Annex 1, 2026); Diego Martini, Interview, Municipality of Udine (Annex 2, 2026).

Interoperability In Rome: Next-Gen Government: Rome As a Case Study of EU-Compliant Urban Digitalisation

By Giorgia Pizzoferrato,(a) Matteo Ramacci,(b) and Sarah Bozesan. (c)

I. Introduction

Digital transformation has emerged as one of the central drivers of administrative modernization within the European Union. As institutions increasingly rely on digital tools to deliver services, the capacity of public administrations to interoperate (exchange data, coordinate processes and provide seamless cross - border services) has become a defining element of effective governance. Against this background, this research examines how digitalization and technological innovation contribute to the development of interoperable public services through the case of Rome Municipality. The research seeks to identify existing structural gaps, regulatory challenges, and emerging opportunities in the digital transformation of Rome Municipality.

To fully understand the scope of the analysis, it is necessary to clarify that Rome’s administrative structure is composed of several municipalities, each with its own local offices and services. The City of Rome consists of 15 internal municipalities, while the broader administrative framework of Roma Capitale, the Metropolitan City of Rome, encompasses over 120 municipalities, forming a wider governance network. This fragmentation creates the need for systemic coordination: without harmonized standards, integration between offices and procedures and the articulation of the workload encounter difficulties and operational burdens. If data is to be gathered, stored and managed effectively and transparently, while ensuring equal treatment for all citizens, such processes must be implemented coherently across the system. The case of Rome therefore provides an opportunity to examine how administrative fragmentation conditions the implementation of digital transformation policies and the provision of integrated public services.

The analysis is situated within the framework established by the Interoperable Europe Act (IEA), with particular attention to Article 3 concerning interoperability assessments and Article 9 on the reuse of shared solutions. The paper argues that, although digital innovation

(a) L.L.B. Candidate, International and European Law Programme, The Hague University of Applied Sciences.

(b) L.L.B. Candidate, International and European Law Programme, The Hague University of Applied Sciences.

(c) L.L.B. Candidate, International and European Law Programme, The Hague University of Applied Sciences.

has significantly improved administrative capacity, the persistence of fragmented organizational arrangements and uneven levels of technological integration continue to hinder the full realization of interoperable services. At the same time, the study iden tifies opportunities arising from common standards, shared digital infrastructures and collaborative governance mechanisms promoted at the European level. Through the examination of Rome Municipality, the research highlights how local administrative struct ures mediate the implementation of EU interoperability objectives and demonstrate the importance of institutional coordination in achieving an integrated digital public sector.

II. Research Methods

The research adopted a qualitative case study approach centred on Rome Municipality. The data was collected through an interview with a senior official involved in digital transformation initiatives within the administrative framework of Roma Capitale. The interview was conducted on the 11th of November 2025. It was carried out remotely in Italian. The openquestion format in which the interview was carried out allowed for both consistency across thematic areas and flexibility to explore issues emerging dur ing the discussion.

The interview protocol was developed on the basis of key policy and regulatory documents, including the Rome Smart City Plan

1, the Strategic Plan of the Metropolitan City of Rome 2, the Interoperable Europe Act (IEA) 3, and the European Interoperability Framework (EIF). 4 These sources provided the analytical structure for the questions and sub -questions, which focused on the current technological landscape, ongoing digital transformation projects, and the challenges associated with achieving interoperability.

The conclusions to be drawn from this research should be interpreted in light of the limited qualitative data gathered from a single interview. This additionally defines a limitation to the case study. Rather than aiming at statistical generalization, the study seeks to provide an

1 ‘Carta di Identità Elettronica’ (Roma, 2026) <https://www.comune.roma.it/eventiresources/cms/documents/Roma%20Smart%20City_Il%20Piano.pdf> accessed 22 April 2026.

2 Città metropolitana di Roma Capitale, DSsus 1 Digitalizzazione (Urban Intelligence) (Piano Strategico Città Metropolitana, 2024) <https://pianostrategico.cittametropolitanaroma.it/sites/default/files/documenti/digitalizzazione.pdf> accessed 22 April 2026.

3 Regulation (EU) 2024/903 of the European Parliament and of the Council of 13 March 2024 laying down measures for a high level of public sector interoperability across the Union (Interoperable Europe Act) [2024] OJ L 903/1

4 ‘The European Interoperability Framework in Detail’ (Interoperable Europe Portal) <https://interoperableeurope.ec.europa.eu/collection/iopeu-monitoring/european-interoperability-framework-detail> accessed May 28, 2026.

analytically informed understanding of how local administrative structures and governance arrangements shape the implementation of interoperability policies within the broader framework of European digital governance.

III. How was the interview conducted?

As per the modalities decided through the informed consent form, the identity of the interviewee is not disclosed. The interview was conducted as part of our study, to deepen our knowledge about initatives on Digital Innovation, Service Innovation and Digi tal Transformation. The stakeholder was selected as the most appropriate interviewee, because of their involvement with projects treating Digital Innovation in Italy. We chose Rome as the area of focus for the research which, as the capital of Italy, is expected to remain aligned with technological progress and to respond effectively to the growing needs of both residents and visitors.

Engaging with participants of such initiatives is therefore essential to gain an overview of the proposed solutions encapsuled in the city’s digitalization strategy. For these reasons, a series of questions concerning several aspects of digitalization was submitted to our interviewee, such as the relationship between digitalization and citizens’ needs, the persistence of Rome’s digital gap, the city’s data management practices, and potential innovations to align with the EU’s 2030 digital goals. These questions help explore how Rome can evolve into a smart, connected and inclusive city.

The anonymization entails that the citations provided in this paper do not disclose the interviewee’s identity and the interview is referred to as IT_RM, indicating Italy and the Municipality of Rome, followed by the specific question related to the inform ation cited.

IV. Digitalization and citizen’s needs

The starting point of the analysis explores how digitalization responds to the concrete needs of Rome’s citizens. According to the information provided by the interviewee, digitalization plays a dual role: it facilitates interaction between citizens and the administration and promotes transparency, ensuring that public procedures are non -discriminatory and accessible to individuals, regardless of their abilities or their individual conditions. 5 Having outlined the general benefits of transparency and accessibility, it becomes necessary to further

5 IT_RM, 1A.

investigate the extent to which digitalization can act as a tool for social equity.

In this regard, a second question was introduced, aimed at exploring this potential, specifically how digitalization may contribute to reducing social inequalities and ensuring inclusivity for vulnerable groups. In a city like Rome (vast, complex, and mark ed by deep social and territorial inequalities), digitalization can significantly reduce barriers for citizens. For example, people living far from public offices or in areas with poor public transport can access civic services online, removing these constraints, making services available anywhere, anytime. This not only enhances efficiency but also improves traceability, transparency, and fairness in the treatment of citizens.

In this context, a further question naturally emerges concerning the ways in which digitalization contributes to economic growth. The digital transition would also support local enterprises in their development. Digitalization is not merely a matter of access; it is also a driver of economic development. It represents one of the most dynamic industrial sectors, even in a city like Rome, which historically plays a strategic role in public and private innovation. To foster this process, Roma Capitale has introduced initiatives such as the Casa delle Tecnologie Emergenti, 6 which is a technological hub supporting startups developing solutions responding to innovation needs often identified within the public administration itself. Thus, digitalization connects people, strengthens inclusion and drives the city’s economic development, enabling Rome to position itself as a place where innovation and social progress advance together.

V. Connectivity and Data Management Matters

A. Digital Inequalities in Rome: Challenges and solutions

The analysis of the documentation used as the baseline for this research highlights a persistent connectivity gap 7 in several areas in Rome, particularly in peripheral neighbourhood. The Grande Raccordo Anulare acts as a dividing circle: 8 central areas enjoy high-speed internet

6 ‘Roma Capitale’ (Comune Roma) <https://www.comune.roma.it/web/it/casa -delle-tecnologie-emergenti.page> accessed 26 May 2026; Here, an overview of the initative can be found, which consists in the description of the spaces and the uses of the hubs.

7 ibid; “Piano Degli Obiettivi 2022 - 2024 di Roma Capitale” (Allegato 2.2 al Piano Integrato di Attività e Organizzazione 2022-2024 di Roma Capitale, 2022) <https://www.comune.roma.it/web-resources/cms/documents/2.2Allegato_al_PIAO_rev.pdf> accessed 26 May 2026

8 This refers to the main street in Rome which divides the city center from the hinterland.

access, whereas many peripheral zones face significant deficits.9 Therefore, we asked the interviewee which strategies the municipality has adopted (or plans to adopt) to address this challenge.

From their response, it becomes clear that connectivity is primarily regulated by the European Electronic Communications Code, 10 which establishes harmonized rules for electronic communications networks and telecoms services. 11 Furthermore, the sector is largely market driven. Public administrations such as Roma Capitale may intervene when they can improve essential services, generating clear benefits for citizens. In this context, Roma Capitale proposes current investments in 5G, fibre networks and the enhancement of WI -FI coverage across municipalities. Among the most significant initiatives, the ‘ 5G small- cell densification project’ stands out. 12 This plan aims to provide full network coverage across Rome and to offer free public Wi- Fi in one hundred squares in the city. The project was developed through a publicprivate partnership, with Roma Capitale not only overseeing the concession but also contributing with 22 per cent of the total investment as public funding. This demonstrates the municipality’s concrete effort to reduce infrastructural disparities. However, several challenges emerged during the implementation path. For example, the interviewee highlighted that the telecommunications operators initially viewed the municipality’s involvement as interference in a free-market sector, partly due to previous administrations’ resistance or reluctance to 5G technology deployment and other digitalization measures.

In order to progress towards the goal of making Rome a ‘ Smart City’, 13 the interviewee emphasized the need to maintain a stable, transparent approach characterized by open and

9 “Roma Capitale” (Roma Capitale) “Piano Degli Obiettivi 2022 - 2024 di Roma Capitale” (Allegato 2.2 al Piano Integrato di Attività e Organizzazione 2022 -2024 di Roma Capitale, 2022) <https://www.comune.roma.it/webresources/cms/documents/2.2Allegato_al_PIAO_rev.pdf> accessed May 26, 2026

10 Directive (EU) 2018/1972 of the European Parliament and of the Council of 11 December 2018 establishing the European Electronic Communications Code (Recast) (Text with EEA relevance) [2018] OJ L 321/36.

11 ‘European Electronic Communications Code’ (European Commission, 2023) <https://eur-lex.europa.eu/EN/legalcontent/summary/european-electronic-communications-code.html> accessed 22 April 2026; Directive (EU) 2018/1972 of the European Parliament and of the Council of 11 December 2018 establishing the European Electronic Communications Code (Recast) [2018] OJ L 321/36.

12 ‘Roma Capitale’ (Roma Capitale) <https://www.comune.roma.it/web/it/attivitaprogetto.page?contentId=PRG1173170> accessed 26 May 2026; this source describes the proposal of Roma Smart City, providing the vision, strategies, benefits, reasoning and steps that the municipality is planning to undertake in different areas of development.

13 There is no universally accepted definition of what constitutes a ‘Smart City’. A widely recognized and authoritative definition is offered by the European Comission which considers Smart City a “place where traditional networks and services are made more efficient with the use of digital solutions for the benefit of its inhabitants and business. […]”; ‘Smart cities and communities’ (European Commission, 4 November 2025) <https://commission.europa.eu/eu-regional-and-urban-development/topics/cities-and-urban-development/cityinitiatives/smart-cities> accessed 22 April 2026.

continuous dialogue among all actors. The way this initiative was handled can serve as a model for future cooperation between public and private entities: based on fairness, trust and shared commitment.

B. Modernizing Rome’s Data Ecosystem

Another central theme of the empirical research concerns data management. According to the Municipality statement, 14 many systems still operate ‘siloed’, as in vertically and isolated from other service systems. This approach conflicts with the EU objective of building horizontal, interoperable systems enabling seamless data exchange. 15 Roma Capitale, like most public administrations, currently operates within a hybrid environment. Some platforms (such as PagoPa for payments) are fully integrated at regional or national level, while others operate as siloed services. 16 This difference stems from the complexity of the administrative ecosystems, the presence or absence of national coordination initiatives and varying quality of systems developed over time. 17

The city’s long-term objective is to establish a centralized ‘ City Data Platform’, ensuring interoperability among public bodies. The platform is still being progressively implemented and is intended to connect existing information systems rather than replace them. Its development is also linked to national digital infrastructures and interoperability frameworks promoted by AgID, ensuring consistency between local and national digital policies. The City Data Platform is aligned with broader European objectives, particularly the creation of common data spaces envisaged by the Data Gover nance Act and the Data Act. In this sense, the project forms part of a wider effort to strengthen data sharing and interoperability across the European Union. The platform also applies the European ‘once-only’ principle, while respecting the European regulatory framework and maximizing benefits for citizens. 18 The principle is mentioned in the Interoperable Europe Act, and its main legal basis is Article 14 of Regulation (EU)

14 ‘Roma Capitale’ (Roma Capitale) “Piano Degli Obiettivi 2022 - 2024 di Roma Capitale” (Allegato 2.2 al Piano Integrato di Attività e Organizzazione 2022 -2024 di Roma Capitale , 2022) <https://www.comune.roma.it/webresources/cms/documents/2.2Allegato_al_PIAO_rev.pdf> accessed 26 May 2026 83.

15 Regulation (EU) 2024/903 of the European Parliament and of the Council of 13 March 2024 laying down measures for a high level of public sector interoperability across the Union (Interoperable Europe Act) [2024] OJ L903/1 preamble 53.

16 ‘Home – pagoPA’ (PagoPA S.p.A.) <https://www.pagopa.gov.it> accessed 27 May 2026; PagoPa is the national platform that allows individuals to choose, according to their habits and preferences, how to pay taxes, fees, or charges to Public Administrations and other participating entities that provide services to citizens.

17 ‘Mission 1: Digitalisation, Innovation, Competitiveness and Culture’ (Camera Dei Deputati) <https://www.camera.it/temiap/2021/03/25/OCD177 -4876.pdf > accessed 28 May 2026, 6.

18 To reduce the administrative burden on the citizens.

2018/1724 establishing the Single Digital Gateway. The Regulation promotes the cross-border exchange of information between Member States, while the Interoperable Europe Act provides the governance framework and tools necessary to support its implementation. The main obstacle is that such transformation occurs slowly. Rome has invested for decades in digital infrastructures that now handle highly sensitive data and millions of active users. 19 This makes modernization a gradual and complex process. Another obstacle, indirectly highlighted is the lack of uniform datasets format, 20 which prevents the achievement of “semantic interoperability”. 21

As part of its modernization strategy, Roma Capitale also plans to create a ‘Smart Control Room’ 22 This is not merely a software initiative but a broader commitment to building solid data-management policies. 23 A concrete example of this direction can already be seen in ‘ Julia’, the city’s virtual assistant, which integrates data from the municipality, public companies, and external partners such as Regione Lazio, Aeroporti di Roma, Trenitalia, Italo. ‘Julia’ highlights a clear step towards a connected and data- driven administration. 24

Given this evolution, questions of liability arise. To address them, Roma Capitale created in 2022 a dedicated Department of Cybersecurity and Privacy, working side by side with the Department of Digital Transformation. 25 Together, they ensure compliance with Data Protection and Security regulatory frameworks, 26 an increasing requirement in light of the growing number of cyberattacks.27

19 Catarinozzi G, ‘Italy Digital Public Administration Project’ ( Minsait, 2025) <https://www.minsait.com/en/italydigital-public-administration-project> accessed May 28, 2026

20 ‘Roma Capitale’ (Roma Capitale) “Piano Degli Obiettivi 2022 - 2024 di Roma Capitale” (Allegato 2.2 al Piano Integrato di Attività e Organizzazione 2022 -2024 di Roma Capitale , 2022) <https://www.comune.roma.it/webresources/cms/documents/2.2Allegato_al_PIAO_rev.pdf> accessed 26 May 2026, 83; It is discovered a lack of activities to standardize data format.

21 ‘The European Interoperability Framework in Detail’ ( Interoperable Europe Portal) <https://interoperableeurope.ec.europa.eu/collection/iopeu-monitoring/european-interoperability-framework-detail> accessed 28 May 2026 One of the layers covered by European Interoperability Framework to ensure the use of precise format and meaning of exchanged data.

22 ‘Roma Capitale’ (Roma Capitale) “Synergy of integrated sensors and technologies for urban secured environment” (Municipality of Rome perspective on the project : Synergies with the Smart City Plan ) <https://www.comune.roma.it/webresources/cms/documents/System_workshop_presentazione_Roma_Smart_Ci ty.pdf> accessed 28 May 2026.

23 ibid.

24 IT_RM, 3B.

25 Ibid.

26 Regulation (EU) 2024/903 of the European Parliament and of the Council of 11 April 2024 laying down measures for a high level of public sector interoperability across the Union (Interoperable Europe Act) [2024] OJ L903/1; Ensuring the alignment with the EIF Principle 8 – Security and Privacy which requires to guarantee privacy confidentiality in order to create a secure and trustworthy environment full compliant with the relevant laws.

27 “Cyber Security Report 2025” (Cyber Security Report 2025 , 2025) <https://www.gruppotim.it/en/innovation/innovation-news/Cyber-Security-Report-2025.html> accessed 28 May 2026; This report is produced by Gruppo TIM, one of the major providers of digital platforms in the country.

Rome’s digital transformation is guided by three strategic pillars: bridging the connectivity gap, integrating data for smarter governance, and ensuring that innovation aligns with security and transparency. 28 Through public-private partnerships, strong data policies, and a sustained focus on citizens’ needs, Roma Capitale is building a more connected, efficient, and inclusive urban ecosystem.

As a recognition of the commitment demonstrated by the public administration, Roma Capitale was awarded as the best ‘Smart City ’ at the 2025 World Smart City Award.29 By presenting the strategic framework: “ Rome: The City is Transforming ”, Roma Capitale demonstrated a strategic vision illustrating the city’s ongoing evolution and the policy measures adopted to support this digital transformation. The plan particularly focuses on implementing the city’s level of digitalization and fostering 5G infrastructu re, with the broader goal of enhancing the accessibility and efficiency of public services. This initiative, recognized with the award received in Barcelona in November 2025, represents Rome’s effort to redefine and modernize its urban characteristics, aligning institutional capacities and technological investments with the emerging needs and expectations of the citizens.

VI. Digitalization of Public Services

Shifting to Roma Capitale’s plans on innovation, the next research question concerns the current initiatives that Rome welcomes in their agenda and how ideas are being put forward.

By 2026, Rome plans on rendering AI-powered services available for citizens to improve the efficiency of digital services and facilitating the harmonious functioning of services across the municipalities included in the territory of Roma Capitale.

The use of AI systems also raises important regulatory considerations. In particular, Regulation 2024/1689 EU provides the legal framework for the deployment of artificial intelligence within the European Union. If AI agents are used to interact with citiz ens or support administrative decision-making processes, such applications may fall within the category of high-risk AI systems under Annex III, point 5 of the AI Act. Consequently, the introduction of

28 “Roma Capitale” (Roma Capitale) “Synergy of integrated sensors and technologies for urban secured environment” (Municipality of Rome perspective on the project: Synergies with the Smart City Plan) <https://www.comune.roma.it/webresources/cms/documents/System_workshop_presentazione_Roma_Smart_Ci ty.pdf> accessed May 28, 2026.

29 Čad G, “Rome Selected as Smart City of 2025 at Smart City Expo World Congress” ( KONGRES – Europe Events and Meetings Industry Magazine - New Europe Events and Meetings Industry Magazine , November 6, 2025) <https://kongres -magazine.eu/2025/11/rome-selected-as-smart-city-of-2025-at -smart-city-expo-worldcongress/> accessed 28 May 2026

AI-based services in Roma Capitale will need to comply with requirements concerning transparency, human oversight, accountability and risk management. Therefore, technological innovation in public services must be accompanied by adequate safeguards to ensu re that efficiency gains remain consistent with European standards for transparent and responsible implementation of AI-powered services.

A. Integration and lack of interoperability

Harmonization is central to interoperability: in Rome it is difficult to access and independently use digitalized services, to the extent to which users generally are led to refer to assistance from public officials, which often lacks in efficiency and use fulness.30 This difficulty not only constitutes a deterrent for users to approach services with ease and trust but also adds burdens of time and efficiency to the cooperation and interoperability of services in Rome.

31

Our interviewee shared that in the context of Rome, constraints are mostly of an organizational and technical nature. Poor internal coordination, organizational complexity, and heavily outdated procedures slow down the development of digital services. Administrations carry the responsibility of ensuring users the right of access and efficient practice of their services and correlated procedures. In a fragmented bureaucratic system, especially in wide contexts as the one in Rome, the alignment of guiding priorities and tangible methodology are crucial. 32

About 67 per cent of public institutions report that a lack of ICT training is the main barrier to digitalization, and 66.7 per cent admit they don’t have sufficiently qualified ICT staff.33 Meanwhile, interoperability remains weak: many administrations still ask for citizens’ data even though other offices already hold that information, violating the ‘once‑only’ principle and causing wasted time and resources. 34 Finally, despite rising ICT spending, nearly 66.8 per cent of institutions cite the high cost of acquiring and implementing digital technologies as a

30 IT_RM, 1A, 4A, 4B.

31 IT_RM, 4A, 4B.

32 IT_RM, 1A

33 Me F, “PA Digitale, Per il 67% Degli Enti La Mancanza di Formazione Blocca La Svolta” ( CorCom, December 15, 2021) <https://www.corrierecomunicazioni.it/digital -economy/pa-digitale-per-il-67-degli-enti -la-mancanzadi-formazione-blocca-la-svolta/> accessed May 28, 2026

34Tironi A, “Perché La PA Continua a Chiedere Dati Che Già Ha, in Barba al Principio ‘Once Only’” ( Agenda Digitale, July 7, 2022) <https://www.agendadigitale.eu/cittadinanza -digitale/interoperabilita-perche-la-pacontinua-a-chiedere-dati-che-gia-ha-in-barba-al-principio -onceonly/> accessed May 28, 2026

major obstacle to modernization. 35

B. Approach towards digitalization

The purpose of digitalization services is not to remove the role of assisted services. Harmonization is eased through common data practices and procedures. Involving AI in the automation process through AI Agents which perform independent tasks and promote timely and effective procedures and creating digital platforms that serve as cloud infrastructure for data storage and treatment are changes that should be prioritized towards digital transformation.36

VII. Citizens needs regarding digitalization

As previously mentioned, the unique context present in Rome highlights the necessity of simple services: simplification entails multiple correlated concepts. Speed, accessibility, intuitiveness, directness, and transparency of services are all priorities that should be designed in line with the user’s perspective when engaging with digitalization. 37

A. Relevant skills and approach to digitalization

Shifting towards digital culture and interoperability in a broader European context implies a continuous expansion of the digital and regulatory skills required by both users and public administration staff. The interview highlights the importance of train ing and awareness for those interacting with digital services, particularly in relation to correct usage practices and the ability to navigate multiple platforms. Public administrations are increasingly expected to possess competencies in service delivery, design, monitoring, and support of digital systems, ensuring that users are guided across procedures and platforms appropriately.

At the same time, this skills -oriented approach presents both strengths and limitations. While it supports the effective use of digital services, it may also place a significant burden on administrative personnel and risks uneven implementation across diff erent municipal units.

35 Compagnucci S and others, “DON’T STOP ‘IT’ NOW Le Politiche Per Muovere La Trasformazione Digitale dell”Italia Tra Bussola UE E PNRR” ( Rapporto Osservatorio Reti E Servizi Di Nuova Generazione , 2022) <https://www.i-com.it/wp-content/uploads/2022/10/Rapporto_Ores_2022.pdf> accessed May 28, 2026 .

36 IT_RM, 4C.

37 IT_RM, 5A, 5B, 5C.

From a regulatory perspective, these developments must be assessed in light of multiple overlapping EU legal frameworks. In particular, the Interoperable Europe Act introduces in Article 3 a mandatory interoperability assessment for public sector bodies. 38 For an administration such as Roma Capitale, this requirement is closely linked to existing obligations under the GDPR, especially the Data Protection Impact Assessment under Article 35, 39 and may also intersect with the Artificial Intelligence Act, notably the Fundamental Rights Impact Assessment under Article 27 and Annex III point 5 when AI systems are deployed in public service contexts. 40 A coordinated approach to these assessments would be necessary to avoid fragmentation between legal compliance procedures and to ensure coherent risk governance.

However, the interview material does not fully demonstrate whether such integrated assessment practices are systematically implemented in Rome’s digital transformation strategy, indicating a potential gap between regulatory requirements and administrative practice. Further relevant provisions of the IEA, such as Article 9 on shared solutions and the interoperability solutions catalogue, as well as Articles 11,12 and 13 on regulatory sandboxes relevant for AIpowered services and Articles 15, 16 and 17 on th e Interoperable Europe Board, remain underexplored in the current local implementation context. 41 This suggests that while Rome’s approach shows partial alignment with the EU interoperability framework, its operationalisation may still be uneven and dependent on project - level initiatives rather than fully institutionalised governance mechanisms.

B. Principle of intuitiveness of services

On the design of services, the interviewee emphasized that the more transparent, accessible, and straightforward a system is, the less users would tend to distrust and voluntarily approach digitalization. 42 The interviewee considers that when developing and deploying digital services, the wide-ranged and diverse demographic found in Rome’s citizens must be kept in mind alongside other factors in matters of shared responsibility. In the private sector of digital service providers, strong, secure and efficient technical infrastructure is needed, while

38 Regulation (EU) 2024/903 of the European Parliament and of the Council establishing measures for a high level of interoperability of public sector systems across the Union (Interoperable Europe Act) art 3.

39 Regulation (EU) 2016/679 of the European Parliament and of the Council (General Data Protection Regulation) art 35.

40 Regulation (EU) 2024/1689 of the European Parliament and of the Council laying down harmonized rules on artificial intelligence (Artificial Intelligence Act) art 27 and Annex III, pt 5.

41 Interoperable Europe Act (Regulation (EU) 2024/903) arts 9, 11 –13, 15–17.

42 IT_RM, 5.

the public administration’s efforts showcase availability towards change and innovation. 43

Roma Capitale has developed partnerships through the “Casa Digitale del Cittadino ”,44 a technological hub for the incubation of innovative startups. This project took off in relation with the EU-funded project of National Operational Program Metropolitan Cities 2014/2020, as a way of contacting municipalities, providing information to citizens, following the status of procedures, and reporting issues with the digital services present on the platform. 45 This however remains not automated and is a cloud -based platform that groups services and practices, facilitating access for citizens: it is the municipality’s plan to welcome Evoluzione della Casa Digitale del Cittadino before 2028, which brings a more user-centric approach and facilitates automation of services through the integration of AI agents. 46 Rome also has a consultancy body, part of the Roma Smart City Plan, with an assistive role regarding the proposal and development of initiatives and projects, coordinated and enabled by governance bodies part of the project: Consulta Roma Smart City. 47 The Consulta includes more than 200 members, representing universities and companies operating within the Rome Area. 48

VIII. Rome as a model of EU-compliant urban digitalization

A coherent analysis of Rome’s digital transformation also requires examining the city’s initiatives within the broader EU regulatory and policy framework. 49 In this regard, Rome’s strategy not only appears effective in reaching digitalization objectives, but it also aligns closely with the core aims established by the main European regulatory framework. These govern interoperability, cybersecurity, data protection, connectivity and user-centric public services.

Rome’s development of a shared data platform and its planned Smart Control Room directly reflect the principles behind the Interoperable Europe Act, especially the transition to the ‘once-only’ principle for data access and exchange among public administration, including

43 IT_RM, 5B.

44 “Roma Capitale” (Roma Capitale, 2021) <https://www.comune.roma.it/web/it/informazione -di-servizio/nascela-casa-digitale-del-cittadino-il-nuovo-canale-di-dialogo-con-lamministrazione.page> accessed 28 May 2026 Here information can be found on the practical uses of the services of communication with the administration of the Municipality of Rome.

45 ibid.

46 IT_RM, , 4C, 5A.

47 ‘Roma Capitale’ (Roma Capitale) <https://www.comune.roma.it/web/it/consult-smart-city.page> accessed 28 May 2026 For more information on the composition, role and functions of the Consulta Roma Smart City; IT_RM, 5C.

48 ibid

49 ‘Roma Smart City’ (Roma Capitale) <https://www.comune.roma.it/eventiresources/cms/documents/Roma%20Smart%20City_Il%20Piano.pdf> accessed 28 May 2026, 9-10.

cross-border operations. The city’s commitment to strengthening internet infrastructure and 5G coverage, especially in peripheral areas, reflects the Act’s aim to ensure robust digital infrastructure and remove digital gaps.50

Furthermore, Rome’s broadband expansion, user - centric portals and digital skills enhancement initiatives directly support the EU Digital Decade 2030, 51 targets of universal connectivity, 52 and full online availability of public services. 53 Initiatives such as La casa del Cittadino, designed as a user-centric service portals and a digital inclusion program, directly reinforces the objectives mentioned earlier.

Rome’s governance model ensures compliance with regulatory laws governing data protection and cybersecurity, particularly with the General Data Protection Regulation (GDPR) principles.54 Rome implements data minimization practices across municipal platforms, 55 adopts lawful processing framework and integrates system - level anonymization. 56 Additionally, the city enforces explicit user consent mechanisms across all digital services. Complementing this, the city’s cybersecurity structures reflect the standards required by the NIS2 Directive on network resilience, 57 risk management and incident response readiness for critical public infrastructures. These measures strengthen the city’s capacity to prevent, detect and mitigate cyber threats in line with EU requirements.

Finally, Rome’s actions align with the European Interoperability Framework (EIF),

50 Regulation (EU) 2024/903 laying down measures for a high level of public sector interoperability across the Union (Interoperable Europe Act) [2024] OJ L903/1recital 6.

51 ibid, Recital 4; European Commission, Communication: A long-term Vision for the EU's Rural Areas –Towards stronger, connected, resilient and prosperous rural areas by 2040 COM (2021) 345 final <https://eurlex.europa.eu/legal-content/EN/TXT/?uri=celex:52021DC0345> accessed 22 April 2026; Decision (EU) 2022/2481 of the European Parliament and of the Council of 14 December 2022 establishing the Digital Decade Policy Programme 2030 (Text with EEA relevance) [2022] OJ L 323/4.

52 Decision (EU) 2022/2481 of the European Parliament and of the Council of 14 December 2022 establishing the Digital Decade Policy Programme 2030 (Text with EEA relevance) [2022] OJ L 323.

53 ibid, art. 3 (1) (e).

54 Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) [2016] OJ L 119/1.

55 ibid, art. 3 (1) (g).

56 Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) [2016] OJ L 119/1 art 6.

57 Directive (EU) 2022/2555 of the European Parliament and of the Council of 14 December 2022 on measures for a high common level of cybersecurity across the Union, amending Regulation (EU) No 910/2014 and Directive (EU) 2018/1972, and repealing Directive (EU) 2016/1148 (NIS2 Directive) [2022] OJ L333/80.

reflecting fundamental principles of subsidiarity, 58 openness,59 inclusion and accessibility,60 reusability, 61 and data portability. 62 The subsidiarity principle requires EU decisions to be taken as closely as possible to the citizen, open data refers to the idea that all public data should be freely available for use and reuse by others. 63 Reusability means that public administrations confronted with a specific problem seek to benefit from the work of others by looking at what is available, assessing its usefulness or relevance to the problem at hand, and where appropriate, adopting solutions that have proven their value elsewhere. 64 Our interviewee explained that, in any focus area or region that wishes to implement digitalization and improve the current administrative processes, to ensure alignment and compliance of the digital transformation with the EI framework, the public administration must prioritize sharing its interoperability solutions, concepts, frameworks, specifications, tools and components with others. 65 Inclusion is about enabling all parties to take full advantage of the opportunities offered by new technologies to access and make use of European public services, overcoming social and economic divides and exclusion. 66 Accessibility ensures that people with disabilities, the elderly and other disadvantaged groups can use public services at service levels comparable to those provided to other citizens. 67 Lastly, data portability is the ability to move and reuse data easily among different applications and systems , which becomes even more challenging in crossborder scenarios. 68 These principles guide the city’s efforts to design interoperable, accessible, and high-quality public services that facilitate seamless data exchange and promote administrative efficiency.

IX. Conclusion

58 Regulation (EU) 2024/903 laying down measures for a high level of public sector interoperability across the Union (Interoperable Europe Act) [2024] OJ L903/1 principle 1.

59 ibid, principle 2.

60 ibid, principle 7.

61 ibid, principle 4.

62 ibid, principle 5.

63 ‘Underlying Principles of European Public Services’ ( Interoperable Europe Portal) <https://interoperableeurope.ec.europa.eu/collection/iopeu-monitoring/2-underlying-principles-european-public-services> accessed 28 May 2026, 2.2 Underlying Principle 1.

64 ibid, 2.5 Underlying Principle 4.

65 ibid; IT_RM, 4B, 5A.

66 ‘Underlying Principles of European Public Services’ ( Interoperable Europe Portal) <https://interoperableeurope.ec.europa.eu/collection/iopeu-monitoring/2-underlying-principles-european-public-services> accessed 28 May 2026, 2.8 Underlying Principle 7.

67 ibid.

68 ‘The European Interoperability Framework in Detail’ ( Interoperable Europe Portal) <https://interoperableeurope.ec.europa.eu/collection/iopeu-monitoring/european-interoperability-framework-detail> accessed 28 May 2026

The evidence from the interview and EU frameworks shows that interoperability is a practical requirement for a fragmented metropolitan area such as Rome. The city aims to build a governance model that integrates technologies, institutions, and users within a coherent digital system.

Roma Capitale’s initiatives, including the City Data Platform, the Smart Control Room, and 5G expansion, broadly align with EU digital priorities and the Interoperable Europe Act. However, their impact depends on whether they are embedded in stable, cross -departmental governance structures rather than implemented as isolated projects.

At the policy level, three priorities emerge. For Roma Capitale, interoperability governance should be strengthened and Article 3 interoperability assessments under the IEA should be systematically applied. For AgID and the Department for Digital Transform ation, better coordination between local and national infrastructures is needed through shared standards and reusable solutions. At EU level, the Commission and the Interoperable Europe Board should support implementation with clearer guidance and more acc essible shared tools for metropolitan administrations.

Rome is therefore a relevant case of urban digitalisation in the EU, where administrative complexity meets technological reform. However, the study is limited by its single -case design and reliance on one interview, which restricts generalisability.

Towards the EU digital single market and next -gen government:

Identifying and bridging gaps from a local

perspective

By Alexandra Albei,(a) and Tamay Kalkan (b)

Abstract

This study examines the readiness of EU Member States to implement the Interoperable Europe Act through a local-level lens using the Municipality of Bucharest, Romania as a case study. While Romania has made formal progress in digital legislation and techn ological infrastructure, public administration remains fragmented, paper -based and insufficiently coordinated, limiting practical interoperability. Bucharest’s readiness is assessed across key dimensions, including governance structures, legal frameworks, technological infrastructure, data management practices, organisational capacity, and service design. The study finds that the main barrier is not technological capacity, but insufficient digital governance, institutional alignment, and operational readiness. Methodologically, the research combines desk analysis of EU, OECD, and national policy documents with an empirical component based on citizen interviews, capturing both institutional constraints and lived user experiences, highlighting persistent issues such as limited data exchange, low uptake of digital public services, bureaucratic inefficiencies, and uneven digital skills among public servan ts. The findings demonstrate that Romania, and specifically Bucharest, is still in a foundational phase of digital transformation, where the primary challenge is not implementing interoperability but building the governance, coordination and capacity prerequisites that make it feasible. The study contributes by mapping the gap between theoretical compliance with the IEA and practical readiness and by proposing foundational recommendations to strengthe n governance, interoperability, institutional capacity, and user-centred digital service delivery. Ultimately, it argues that interoperability must be approached as a long -term socio-institutional transformation rather than a technical exercise, with Bucha rest positioned to play a central role in Romania’s transition toward a citizen-centred, interoperable digital state within the EU Digital Single Market.

(a) L.L.B. Candidate, International and European Law Programme, The Hague University of Applied Sciences.

(b) L.L.B. Candidate, International and European Law Programme, The Hague University of Applied Sciences.

I. Introduction

The European Union’s Digital Single Market (DSM) vision relies on the seamless interaction between public administrations (EU and national), businesses, and European citizens. 1 This vision is formalised through the Interoperable Europe Act (IEA), which establishes a framework for cross -border digital cooperation. 2 However, for Member States like Romania, the gap between EU -level policy and local reality remains vast. Romania is one of the fastest growing technology hubs in Eastern Europe, benefiting from a highly skilled developer base and a growing start-up cultur e. 3 Despite this, its public administration remains highly fragmented and paper based. 4 Romania’s digital future depends on turning paper promises into tangible results. Citizens need to experience services that raise their expectations, while top digital talents must be empowered to lead transformation. 5 These steps are not optional. 6 Without them, digital transformation will remain an empty rhetoric, whereas with them, Romania can move toward a truly citizen -centric digital state.

Against this backdrop, our research has identified that the digital maturity gap is often so wide that the practical application of the IEA cannot yet begin. 'Digital maturity' refers to ‘adapting the organization to compete effectively in an increasingly digital environment', which entails transforming processes, culture, skills and decision -making so that technology is used in a coordinated, strategic way. 7 The digital maturity gap, therefore, is the difference between government and public institutions that have made this organizational adaptation and those that still treat digital transformation as merely a technology update rather than a broader shift in how they operate, serve citizens, and compete in the digital public sphere. 8

1 ‘The Ubiquitous Digital Single Market’ (European Parliament, 2026) <https://www.europarl.europa.eu/erpl -apppublic/factsheets/pdf/en/FTU_2.1.7.pdf> accessed 24 April 2026, 1.

2 ‘New European Interoperability Framework’ (European Commission , 2017) <https://interoperableeurope.ec.europa.eu/collection/iopeu-monitoring/european-interoperability-framework-detail> accessed 4 November 2025.

3 Nicolae Sfetcu, Information and Communications Technology in Romania: Comparative Analysis with the EU, Social Impact, Challenges and Opportunities, Future Directions (MultiMedia Publishing 2024) 6–7.

4 Digital Nation, ‘Digital Governance Framework for Romania’ ( Edge Institute, October 2025) <https://edgeinstitute.ro/wp-content/uploads/2025/10/Digital-Governance-Framework-for-Romania-by-DigitalNation.pdf> accessed 24 December 2025, 6 -15.

5 ibid 5.

6 ibid.

7 Kemal Özkan Yılmaz, Mind the Gap: It’s About Digital Maturity, Not Technology (Managerial Issues in Digital Transformation of Global Modern Corporations , IGI Global 2021) 3-4, 11.

8 ibid.

Per our research findings, the foundational challenge lies in laying the groundwork: building the core enablers and governance frameworks that make interoperability possible. Therefore, the aim of this research is to analyse the readiness of the Municipality of Bucharest to embark on a digital transformation process and to identify the foundational, legal, institutional, governance and technical conditions necessary to support future interoperability under the IEA. To achieve this objective, the research seeks to answer the followin g questions:

1. To what extent is the Municipality of Bucharest institutionally, legally and technically prepared to support the future implementation of the IEA?

2. What governance, infrastructure and capacity gaps currently hinder the development of interoperable and citizen - centred digital public services in Bucharest and Romania?

3. Which lessons can be drawn from more mature European interoperability models, such as Amsterdam and Tallinn, and how can these be adapted to the Romanian context?

Particularly relevant to this research are the interoperability assessments required under Article 3, which seek to ensure that new digital public services are designed with interoperability in mind; the Interoperable Europe Board (Article 15 -17), which supports coordination and governance across Member States; the Interoperable Europe Portal (Article 9), which facilitates the sharing and reuse of interoperability solutions; and the Interoperable Europe Academy (Chapter IV), which promotes capacity building . 9 These mechanisms extend beyond technical interoperability and require adequate governance structures, institutional capacity, coordination mechanism and digital capabilities at national and local levels. Assessing whether such preconditions exist in Bucharest forms a central objective of this research.

As the capital and largest local authority in Romania, Bucharest concentrates many of the institutional, technical, and human-capacity barriers that impede digital transformation nationwide. 10 At the same time, its scale and visibility in Romania make it a potential catalyst

9 Regulation (EU) 2024/903 of the European Parliament and of the Council of 13 March 2024 laying down measures for a high level of public sector interoperability across the Union (Interoperable Europe Act) OJ L 2024/903 [2024] Article 3, Article 9, Articles 15-17, Chapter IV.

10 OECD, Digital Government Review of Romania: Towards a Digitally Mature Government (OECD Digital Government Studies 2023) 12–18, 32–34, 43–45.

for change if effective digital foundations can be established. 11 To address these questions, this research adopts a structured approach that combines policy analysis, assessment of institutional readiness and comparative case study evaluation. The study is motivated by the gap between EU-level interoperability ambitions and the current administrative and technical realities in Romania, particularly at municipal level. 12 By focusing on Bucharest as a case study, the research seeks to understand both the constraints and opportunities for implementing interoperability in practice and why foundational governance and infrastructure challenges must first be addressed.

The analysis proceeds in four steps. First, it outlines the European Interoperability Framework (EIF) and Interoperable European Act (IEA) to establish the relevant policy context. Second, it examines Romania’s current level of digital maturity and institu tional capacity, identifying key structural barriers to implementation. Third, it assesses Bucharest’s readiness for digital transformation, with a focus on governance, infrastructure and service delivery. Fourth, it draws comparative insights from Amsterd am and Tallinn to identify alternative interoperability models within the EU. Finally, the study translates these findings into practical recommendations for strengthening Romania’s interoperability capacity and enabling the future implementation of the IEA.

II. Context & Background

A. The National Digital Landscape

Romania’s digital transformation has stalled. 13 Although significant progress has been made on paper through legislation and scattered initiatives such as the national law of interoperability and the creation of the Authority for Digitalization of Romania (ADR), citizens continue to encounter fragmented, isolated and low -quality public services.14 Similarly, foundational enablers such as the eID, the legal equivalence of digital and handwritten signatures, and data exchanges between agencies, exist mainly in theory. 15 In reality, they

11 ibid 17–24, 101–108.

12 Regulation (EU) 2024/903 of the European Parliament and of the Council of 13 March 2024 laying down measures for a high level of public sector interoperability across the Union (Interoperable Europe Act) OJ L 2024/903 [2024], arts 1–4; OECD, Digital Government Review of Romania: Towards a Digitally Mature Government (OECD Digital Government Studies 2023) 12–18.

13 ibid.

14 ibid.

15 ibid.

remain underused or limited to individual institutions. 16 The root issues are the lack of customer-centric, whole-of-government vision, no clear accountability for its implementation, and no delivery capacity to make it happen. 17 This stagnation is reflected in Romania’s performance on the Digital Economy and Society Index (DESI) which measures the extent to which key government services are accessible and fully usable online. 18 The DESI indicator for Digital Public Services for Citizens evaluates whether citizens can complete administrative procedures digitally across seven major life events: family matters, career and employment, education, health, transport, moving residences and small claims procedures. 19 The index assesses several dimensions of online public service delivery, including the availability of fully online services for both national and cross -border users, the provisions of online information, and the extent to which services are integrated th rough centralised digital portals.20 Together, these factors provide an indication of how accessible, user-friendly and digitally integrated public services are within a country. 21 As shown in Figure 1, Romania continues to rank last with a score of 62.75 per cent in 2025 for digital public services for citizens. 22 While notable progress has been made, as shown in the DESI score in the recent six years. For example, the establishment of the Authority for Digitalisation of Romania and the adoption of interoperability-related legislation are steps forward, however, ov erall performance regarding interoperability remains weak. 23 Romania’s continued low DESI ranking suggests that these reforms have not yet translated into effective, widely accessible and interoperable digital services in practice. The DESI data further indicates that only around one quarter of Romanian internet users (26.91 per cent) interact online with public authorities (Figure 2), reflecting limited uptake of digital public services. 24

16 ibid, 40-48.

17 ibid.

18 DESI, ‘Digital Decade DESI Visualization Tool’ (European Commission, 2025) <https://digital -decadedesi.digital-strategy.ec.europa.eu/datasets/desi/charts/desiindicators?indicator=desi_egov_users_anys&breakdown=ind_total&unit=pc_ind_ilt12&country=EU,RO,EE,NL &period=desi_2025> accessed 28 December 2025.

19 ibid.

20 ibid.

21 ibid.

22 ibid.

23 Digital Nation, ‘Digital Governance Framework for Romania’ ( Edge Institute, October 2025) <https://edgeinstitute.ro/wp-content/uploads/2025/10/Digital-Governance-Framework-for-Romania-by-DigitalNation.pdf> accessed 24 December 2025, pages 6 -15.

24 DESI, ‘Digital Decade DESI Visualization Tool’ (European Commission, 2025) <https://digital -decadedesi.digital-strategy.ec.europa.eu/datasets/desi/charts/desiindicators?indicator=desi_egov_users_anys&breakdown=ind_total&unit=pc_ind_ilt12&country=EU,RO,EE,NL &period=desi_2025> accessed 28 December 2025.

1: Digital Public Services

Citizens European

25

Figure 2: e-Government users of individuals aged 16-74 European Commission ‘Digital Decade DESI Visualization Tool’ (DESI 2025).26

Romania’s low level of digitalisation is caused by inadequate data exchange between public institutions, a low prioritisation of data infrastructure development, and a persistent reliance on paper-based bureaucratic processes. 27 Together, these issues undermine efforts to digitalise public services and contribute to the failure of many initiatives. Both local and national authorities lack the necessary capacity, funding, and organisational readiness to implement digital policies and guidelines effectively. 28

25 ibid.

26 ibid.

27 OECD, Digital Government Review of Romania: Towards a Digitally Mature Government (OECD Digital Government Studies 2023) 17-18

28 ibid.

Despite Romania’s strong, growing IT workforce, a substantial share of the population lacks the basic digital skills required to participate in an increasingly digital economy, per the DESI 2026 index, only 31.84 per cent of the entire population between 16 and 74 have basic digital skills 29 Many individuals struggle with basic digital tools, restricting their ability to access online public services, engage in remote work or participate fully in digital social life. 30

1. Digital infrastructure disparities between rural and urban areas

Romania has made substantial progress in internet infrastructure over the past decade and now ranks among the countries with the fastest internet speeds in Europe. 31 However, this progress has been uneven as technological infrastructure in rural areas remains significantly underdeveloped, creating a persistent digital divide that limits the equitable spread of technology-driven opportunities. 32 While major urban centres such as Bucharest benefit from robust connectivity and digital infrastructure, many remote areas continue to lack reliable broadband access and adequate hardware support. 33

Rural communities, which account for nearly half of Romania’s population, often lack the essential technological infrastructure required for economic and social development. 34 According to Eurostat, across the EU, more than 85 per cent of urban households have access to high-speed broadband, compared to less than 60 per cent in rural areas. 35 This urban-rural gap in broadband access is driven by geographical constraints, insufficient public and private investment, and limited incentives for telecommunications providers to expand networks into

29 DESI, ‘Digital Decade DESI Visualization Tool ’ (European Commission, 2025) < https://digital-decadedesi.digital-strategy.ec.europa.eu/datasets/desi/charts/desiindicators?indicator=desi_dsk_bab&period=desi_2026&breakdown=ind_total&unit=pc_ind&country=RO> accessed 19 June 2026.

30 Nicolae Sfetcu, Information and Communications Technology in Romania - Comparative Analysis with the EU, Social Impact, Challenges and Opportunities, Future Directions (MultiMedia Publishing 2024) 5.

31 Eurostat ‘Urban-rural Europe’ (Digital Society, 2024) <https://ec.europa.eu/eurostat/statisticsexplained/index.php?title=Urban-rural_Europe_-_digital_society> accessed 29 December 2025.

32 ibid.

33 ‘Romania Country Commercial Guide’ ( International Trade Administration , 2 June 2026) <https://www.trade.gov/country-commercial-guides/romania-digital-economy> accessed 21 June 2026 ; as referenced in Nicolae Sfetcu, Information and Communications Technology in Romania - Comparative Analysis with the EU, Social Impact, Challenges and Opportunities, Future Directions (MultiMedia Publishing 2024) 4

34 Nicolae Sfetcu, Information and Communications Technology in Romania - Comparative Analysis with the EU, Social Impact, Challenges and Opportunities, Future Directions (MultiMedia Publishing 2024) 4

35 Eurostat ‘Urban-rural Europe’ (Digital Society, 2024) <https://ec.europa.eu/eurostat/statisticsexplained/index.php?title=Urban-rural_Europe_-_digital_society> accessed 29 December 2025.

sparsely populated regions.36 In Romania, similar dynamics contribute to digital exclusion that restricts local economic potential and deepens the urban -rural divide. 37

This imbalance is also reflected in the geographical concentration of Romania’s IT sector. The Bucharest region alone generates approximately 63 per cent of national IT revenue, followed by the North-West (18%), Central (6%), West (5%) and North -East (5%) regions. 38 This concentration of economic activity and digital investment within a limited number of urban centres contributes to uneven digital development across the country, leaving rural and peripheral regions with fewer technological resources, lower investment leve ls, and reduced institutional capacity.

2. Bureaucratic issues

Romania’s technological progress is further constrained by persistent bureaucratic barriers. The regulatory environment remains challenging for technology companies, with complex administrative procedures, unclear or inconsistent tax rules, and limited ins titutional support for start-ups frequently cited as obstacles to growth. 39 The slow adaptation of policies supporting digital innovation and streamlined administrative procedures has created additional challenges for new firms seeking to comply with regulatory and administrative requirements. 40

Romania’s public administration systems continue to rely on complex and outdated processes that actively discourage digital transformation by reinforcing paper-based administration and fragmented institutional practices. 41 Bureaucracy has been widely identified as a critical impediment to the adoption of new technologies in both the public and private sectors.42 Despite ongoing efforts to digitise government services, many administrative

36 Irina Marica, ‘Nearly 1000 remote Romanian localities to get high -speed internet in EUR 94 mln Project’ (Romania Insider, 6 March 2025) <https://www.romania -insider.com/internet-remote-localities-romania-pnrrmarch-2025> accessed 29 December 2025.

37 Nicolae Sfetcu, Information and Communications Technology in Romania - Comparative Analysis with the EU, Social Impact, Challenges and Opportunities, Future Directions (MultiMedia Publishing 2024) 4.

38 ‘Romania Country Commercial Guide’ (International Trade Administration, 12 January 2024) <https://www.trade.gov/country-commercial-guides/romania-information-communications-technology-ict> accessed 29 December 2025.

39 Nicolae Sfetcu, Information and Communications Technology in Romania - Comparative Analysis with the EU, Social Impact, Challenges and Opportunities, Future Directions (MultiMedia Publishing 2024) 5.

40 ibid.

41 ibid.

42 OECD, Digital Government Review of Romania: Towards a Digitally Mature Government (OECD Digital Government Studies 2023) 97-98

procedures still require in-person visits and physical documentation, leading to inefficiencies and the low uptake of digital solutions. 43

B. Bucharest: The Microcosm of Transformation

Bucharest plays a central role in Romania’s digitalisation efforts and represents a distinctive administrative case.44 Bucharest operates under a two-tier decentralized municipal system. It is divided into six administrative sectors, each possessing its own independent local government. 45 This hierarchical structure creates significant opportunities for digital connectivity, particularly through the exchange of data and services across sectors, making interoperability both a challenge and a catalyst for innovation. 46

As the capital city, Bucharest is a highly relevant case study for understanding how citizens interact and expect to interact with digital public services. With an estimated population of 1.71 million, the city is also at the forefront of Information and Communication Technology (ICT) adoption in Romania, benefiting from relatively advanced digital infrastructure and strong broadband coverage. 47 Bucharest has additionally engaged with broader EU ‘smart cities’ initiatives, which promote the use of digital technologies and interoperable solutions to improve urban governance, public services, sustainability and citizen participation. 48

III. Methodological Approach

A. Desk Research

A comprehensive review of policy documents was conducted to establish the theoretical and legal framework of the study. This included an analysis of the European Interoperability Framework (EIF) and its six layers: governance, legal, organisational, semant ic, technical and integrated public service governance. National sources included reports from the Authority for

43 ibid.

44 ibid, 12–13.

45 ‘Despre Bucuresti’ (INS) <https://bucuresti.insse.ro/despre-bucuresti/> accessed 28 December 2025.

46 ibid.

47 'Date provizorii ale recensământului: România a pierdut 1,1 milioane de locuitori în 10 ani' ( Ș tirile ProTV, 30 December 2022) <https://stirileprotv.ro/stiri/social/date-provizorii-ale-recensamantului-romania-a-pierdut-1-1milioane-de-locuitori-in -10-ani-document.html> accessed 19 June 2026.

48 ‘Smart Cities and Communities ’ (European Commission, 4 November 2025) < https://digitalstrategy.ec.europa.eu/en/policies/smart-cities-and-communities> (European Commission, 4 November 2025) accessed 27 April 2026.

Digitalisation of Romania (ADR) and Law 242/2022 on interoperability. This is the official data exchange and national interoperability law in Romania, adopted in 2022.

B. Empirical Research

To capture the “lived reality” of citizens interacting with digital services, the research team used primary qualitative methods, specifically qualitative interviews. Qualitative methods were selected because they are particularly well suited to exploring perceptions, experiences and attitudes that may not be captured through quantitative indicators alone. 49

1. Sampling Strategy

Participants were selected through purposive sampling, a non -probability sampling technique commonly used in qualitative research to identify individuals who can provide relevant insights into the research topic. 50 The sample consisted of six participants residing in Bucharest and represented a range of backgrounds, including a student, working professional (not as a Romanian public service professional), a retiree, a government employee, a business owner and an add itional interviewee who requested to be left anonymous. These interviewees all interacted with various fields of Romanian public administration, digitally and/or in person. The aim was not statistical representativeness but rather to capture diverse perspe ctives on the accountability and quality of digital public services from the viewpoint of citizens using these services.

2. Interview Protocol and Administration

A common semi-structured interview guide with 10 questions was used for all participants. Semi-structured interviews were chosen because they provide consistency across interviews while allowing respondents the flexibility to discuss issues, they considere d particularly important. 51 The questions aimed to capture the level of clear and accurate information provided, the time it took to finalise a request and the functionality of the (online) service. Interviews were conducted primarily online with one interview taking place in person

49 Ozlem Isik, ‘Qualitative Research Approaches and Data Collection Methods’ [2025] 7 Journal of Humanities and Education Development 27.

50 Michael Quinn Patton, Qualitative Research & Evaluation Methods (3rd ed., Sage Publication 2002) 235-238. 51Steinar Kvale and Svend Brinkmann, InterViews: Learning the Craft of Qualitative Research Interviewing (SAGE 2009) 25 -26.

All interviews were conducted in Romanian and subsequently translated into English for analysis.

3. Data Collection and Analysis

Interview notes were taken analyzed using thematic analysis. The study adopted a deductive (top-down) analytical approach, whereby themes were derived from the existing literature, the EIF and the research questions guiding the study. Deductive thematic an alysis was considered appropriate because the research sought to assess local experiences against established concepts of interoperability, digital governance and public service delivery. 52

Thematic analysis is a qualitative method that identifies, analyses and interprets recurring patterns with textual data. 53 Its flexibility makes it widely used in public policy and governance research. 54 In this study, thematic analysis enables the research team to systematically examine citizen experiences while connecting individual observations to broader institutional and interoperability challenges.

4. Ethical Considerations

All participants provided informed consent prior to participation through a standardized consent form. No identifying personal information is disclosed in this study and data is stored securely and is accessible only to members of the research team for th e purposes of conducting this research.

5. Limitations

Several limitations should be acknowledged. First, the study is based on a small sample of six interviews and therefore cannot be considered representative of the broader population. Second, all participants were residents of Bucharest, limiting the abilit y to capture the experiences from other Romanian regions. Third, no public officials were interviewed directly, meaning that findings primarily reflect citizen perspectives rather than administrative viewpoints. However, this focus aligns with the study’s objective of capturing lived experiences of citizens interacting with (digital) public services. It is our opinion that the interviews are a

52 Virginia Braun and Victoria Clarke, ‘Using thematic analysis in psychology’ [2006] 3 Qualitative Research in Psychology 6-9.

53 ibid.

54 ibid.

valuable source for understanding how citizens experience (digital) public services in practice and for identifying barriers that may not be fully visible through official performance indicators alone.

IV. Comparative Perspectives: Tallinn & Amsterdam

This chapter establishes a benchmark for Bucharest by comparing its digital maturity to two European cities selected for their specific strategic relevance to the IEA.

To provide a balanced perspective and frame Bucharest (and Romania) within the broader context of interoperable cities, this section adopts a comparative approach. Bucharest serves as the primary case study and is examined alongside two comparator cities, Amsterdam and Tallinn, to identify shortcomings in Romania’s implementation of the EIF that are less evident in more mature digital ecosystems. By examining Bucharest alongside two European comparator cities (Amsterdam and Tallinn), it becomes possible to identify shortcomings in Romania’s implementation of the EIF that are less evident in more advanced systems. This comparison highlights broader structural issues, particularly the importance of effective governance models in enabling interoperability. The comparisons are not intended to suggest that Bucharest should directly duplicate these models. Rather, they serve to identify areas for improvement and to highlight elements that could realistically be adapted within the Romanian context.

Looking at Bucharest in isolation provides only a partial understanding. A comparative perspective allows for a more robust assessment by placing Bucharest alongside more mature digital ecosystems. All three cities are members of the European Union as well as the European Interoperability Framework (EIF).55 To provide a robust assessment, Bucharest is placed alongside more digital ecosystems. Tallinn and Amsterdam were selected as comparator cases. Tallinn offers a relevant comparison as an Eastern European capital that has successfully implemented interoperable digital public services, while Amsterdam provides an example of a mature, decentralised but highly coordinated interoperability model.

55 ‘Interoperable Europe Act: member states agree common positions to deliver more efficient digital public services across the EU’ (European Council 6 October 2023) <https://www.consilium.europa.eu/en/press/pressreleases/2023/10/06/interoperable -europe-act-member-states-agree-common-position-to-deliver-more-efficientdigital-public-services-across-the-eu/> accessed 30 December 2025.

A. Tallinn (The Eastern European Gold Standard) :

Tallinn has developed rapidly in digital interoperability over the years. 56 Estonia has the national X-Road infrastructure, which is a data exchange layer. 57 This layer is able to connect almost all of the public and many private sector information systems. 58 Citizens and businesses can interact with the government through a unified interface. 59 The system is able to exchange data between ministries, municipalities, healthcare providers and private institutions.60 X-Road is reinforced by legal and organisational frameworks, which define data ownership and access rights. 61 It opens up options digitally, such as voting, residency programs and cross-border interoperability with Finland. 62 The country provides a relevant point of comparison as another Eastern European capital that has undergone significant digital transformation, allowing for a more context-sensitive evaluation.

For Bucharest, Tallinn demonstrated how a unified interface and strong legal frameworks can eliminate the “paper silos” currently hindering Romanian administration.

B. Amsterdam (The Citizen -Centric Western Model):

Amsterdam has been chosen due to its rapid evolution in digital interoperability, offering insights into a decentralised yet well-coordinated system. Amsterdam operates within the Generic Digital Infrastructure of the Netherlands (GDI), which is standardised and federalised. The GDI provides options such as the DigiD for citizens authentication, eHerkenning for business.63 Digikoppeling is also part of the GDI and enables data exchange between public sector originations. 64 The Diginetwork enables a communication environment between government entities.65 NL API Strategy promoted service interoperability; it does this by having modern and open interfaces.

56 Tarmo Kalvet, ‘Innovation: a factor explaining e -government success in Estonia’ [2012] 9 Electronic Government, an International Journal 142 143-150.

57 X-Road Technology Overview’(X-Road) <https://x-road.global/x-road-technology-overview> accessed 21 November 2025.

58 ibid.

59 ibid.

60 ibid.

61 ibid.

62 ibid.

63 ‘eHerkenning’ (eHerkenning) <https://www.eherkenning.nl/nl> accessed 21 November 2025.

64 ‘GDI Programmeringsplan 2023’ (Digitale Overheid, 25 April 2024) <https://www.digitaleoverheid.nl/document/gdi-programmeringsplan-2023/> accessed 21 November 2025.

65 ibid.

Bucharest is a case that shows future potential. Romania has invested more in a coherent interoperability framework, which is accelerating. Romania has adopted Law 242/2022 on interoperability and established the National Interoperability Platform. 66 The ROeID, which is a national electronic identity system, has also been implemented. 67 Romania is also aiming to develop a cloud platform for the government to host interoperability services. 68 However, Bucharest’s digital interoperability is still lacking. Many of the municipal services still use old legacy systems. The databases used by the municipalities still do not use automated data exchange. The interoperability between the resident and c ity departments remains limited. 69

Putting it all together, applying the EIF lens to Romania and Bucharest shows that the country is still laying foundations rather than fully implementing the interoperable, citizencentred digital state that the EIF envisions. The comparison between Tallin n and Amsterdam illustrates that interoperability is not achieved through technology alone but depends on the presence of clear legal frameworks, well -defined governance structures, and effective coordination mechanisms. 70 In both Tallinn and Amsterdam, digital infrastructure such as XRoad and the GDI are underpinned by strong legal and organisational arrangements that regulate data exchange, define responsibilities, and ensure accountability. 71

By contrast, although Romania has adopted interoperability -related legislation, implementation remains fragmented, and coordination across institutions is limited. 72 The city shows that interoperability cannot merely rely on existing technology but that strong legislation as well as coherent coordination is needed to create a coherent network.

66 Legea nr. 242/2022 din 20 iulie 2022 privind schimbul de date intre sisteme informatice si crearea Platformei nationale de interoperabilitate, Monitorul Oficial n. 752/27 July 2022. This is the official data exchange and national interoperability law in Romania, adopted in 2022.

67 ‘ROeID’ (Authority for the Digitalization of Romania ) <https://roeid.ro/en/home >accessed 21 November 2025.

68 ‘Romania Digital Transformation: Major Procurement for Government Private Cloud Migration’ (US Commercial Service, 11 February 2025) <https://www.trade.gov/market -intelligence/romania-digitaltransformation-launch-major-procurement-government-private> accessed 21 November 2025.

69 OECD, Digital Government Review of Romania: Towards a Digitally Mature Government (OECD Digital Government Studies 2023) 11-18.

70 Tarmo Kalvet, ‘Innovation: a factor explaining e -government success in Estonia’ [2012] 9 Electronic Government, an International Journal 142 143-150.

71X-Road Technology Overview’(X-Road) <https://x-road.global/x-road-technology-overview> accessed 21 November 2025.

‘GDI Programmeringsplan 2023’ (Digitale Overheid, 25 April 2024) <https://www.digitaleoverheid.nl/document/gdi-programmeringsplan-2023/> accessed 21 November 2025.

72 Legea nr. 242/2022 din 20 iulie 2022 privind schimbul de date intre sisteme informatice si crearea Platformei nationale de interoperabilitate, Monitorul Oficial n. 752/27 July 2022. This is the official data exchange and national interoperability law in Romania, adopted in 2022.

V. Empirical Findings and Analysis

A. The Reality of Public Interaction

The insights gathered from our participants reveal a series of persistent structural issues within Romania’s public service ecosystem, particularly regarding digital interoperability and administrative coherence. Across all six interviews, participants con sistently described a system that remains heavily dependent on paper-based procedures, directly impacting the local application of the IEA.

B. The Persistence of “Analog Loops” in a Digital Age

Despite the push for digitalisation, the ‘physical file’ remains the primary unit of administration. Participants noted that electronic documents and signatures are frequently rejected. 73 Institutions prioritise signatures in person, effectively nullifying the efficiency of online portals. Additionally, a common theme was the requirement for citizens to provide a “handwritten index” of the documents they are submitting. 74 This forces the user to perform the administrative task of cataloguing, which in an interoperable system, would be handled by metadata tagging.

C. Violation of the “once-only” Principle

A core pillar of the IEA is the “once-only” principle where the citizens provide data to the state only once 75. Our research shows the exact opposite. Participants reported being asked for three or four different documents to provide a single fact (e.g. providing a National Agency for Fiscal Administration certificate, a salary slip and a notarised statement all t o prove income status).76 Another issue identified was the inter- institutional silence. The lack of a “backend” exchange between the Municipality, the Tax Authority and Educational institutions forces the citizen to act as a physical courier of data, moving paper from one building to another. 77

73Interview with Anonymous #2 (The Hague, Netherlands, 10 November 2025).

74 ibid.

75 Directorate-General for Digital Services ‘The Once Only Principle System: A breakthrough for the EU’s Digital Single Market’ (European Commission, 5 November 2020) <https://commission.europa.eu/news -andmedia/news/once-only-principle-system-breakthrough-eus-digital-single-market-2020-11-05_en> accessed 27 April 2026.

76 Interview with Anonymous #1 (The Hague, Netherlands, 6 November 2025).

77 ibid.

D. The Digital Divide

The research highlighted a growing form of “digital friction” that disproportionately affects individuals with lower digital literacy or complex requests. One participant described difficulties navigating automated customer support systems and reported bei ng unable to resolve their issues through the available digital channels. 78 These experiences were accompanied by a perception that automated systems acted as a barrier rather than a facilitator of access through supported AI assistance. 79 This raises broader questions regarding the accessibility of AI supported channels and the extent to which these perceived accessibility barriers may discourage citizens from seeking assistance. This can be underscored by the DESI findings which show that only 31.84 per cent of the population has basic digital skills. 80 Accessibility is further complicated by linguistic barriers. One participant noted that the language used on municipal websites was “tough” and “legalistic”. 81 This may act as a further difficulty for certain groups of citizens.

E. Inconsistent information and “Moving Goalposts”

Our interviews found a lack of overall consistency, specifically conflicting instructions and changes mid process. Information on the official website often contradicts the requirements given by staff in person per our interviewee. 82 In the case of student grants, mandatory document lists were updated after the application period had started, leading to missed deadlines and administrative chaos.83

1. Interoperability Gaps

These findings suggest that Romania and in turn, the Municipality of Bucharest currently operate in “digital silos”. While individual departments may have a website, there is no interoperable layer that allows these systems to talk to each other. The syste m relies on citizens to extract data from one silo (e.g. the university) to manually input it into another (e.g.

78 Interview with Anonymous #4 (The Hague, Netherlands, 8 November 2025).

79 ibid.

80 DESI, ‘Digital Decade DESI Visualization Tool’ (European Commission, 2025) <https://digital -decadedesi.digital-strategy.ec.europa.eu/datasets/desi/charts/desiindicators?indicator=desi_egov_users_anys&breakdown=ind_total&unit=pc_ind_ilt12&country=EU,RO,EE ,NL &period=desi_2025> accessed 28 December 2025.

81 ibid.

82 Interview with Anonymous #2 (The Hague, Netherlands, 10 November 2025).

83 Interview with Anonymous #1 (The Hague, Netherlands, 6 November 2025).

the secretariat). 84 Even when digital reforms are passed, the bureaucratic workers often lack the digital competence or the institutional mandate to trust electronic records over physical ones. 85

2. Comparative Summary of Interviews

The below table shows a comparative summary of the interviews. The ‘Domain’ refers to the area of public service that the interviewees had to interact with. ‘Digital Maturity’ represents the perceived level of maturity of the domain they interacted with an d ‘Key Interoperability Barriers’ refers to the issues they had that are relevant for the topic of the research as identified by the individuals interviewed. All of the data featured is based on the interviewees perception and encounters and as such is not representative of the overall population.

Participant Domain the Interviewees interacted with Digital Maturity Perception Key Interoperability Barrier as perceived by interviewee

#1 Education/Grants Low Difficulty in accepting digital signatures/online-only steps.

#2 Archive/Grants Very Low High redundancy; archives are entirely non-digital.

#3 Certification Medium Information fragmentation; ‘scattered’ digital instructions.

#4 Municipal/Legal Low Difficulty in using AI systems and understanding technical/ legal language.

#5 Digital Streamlining and Cross Border Comparison High The participant noted that while simple tasks are improving in Romania, the system struggles as requests become more complex

#6 Licensing/Transport Low Extreme scheduling lag; dependence on physical mail.

84 ibid.

85 Interview with Anonymous #4 (The Hague, Netherlands,8 November 2025).

VI. Policy and Theoretical Analysis

The focus of this research is to assess the readiness to implement the Interoperable Europe Act (IEA); however, the evaluation is carried out using the European Interoperability Framework (EIF). This method was chosen since EIF provides a comprehensive ana lytical framework for assessing interoperability across governance, legal, organisational, semantic, and technical aspects at the local level. In turn, while it is the IEA that represents the legallybinding EU Regulation that established obligations and m echanisms to strengthen interoperability across Member States, the EIF is a non -binding European Commission framework that sets out principles, recommendations and conceptual guidance for achieving interoperability in practice. 86 As the IEA builds upon and uses many of the interoperability principles articulated in the EIF, the latter serves as a useful tool for evaluating Bucharest’s current level of readiness and identifying the foundational conditions required for future compliance with the objectives of the IEA.

The EIF highlights key principles including openness, user-centrism, reusability, technological neutrality and administrative simplification, as essential to building interoperable and citizen-oriented digital services.87 These principles promote shared standards, prevent duplication and enhance efficiency, allowing Member States to scale digital solutions across the EU.88 Furthermore, it defines six layers of interoperability: governance, legal, organisational, semantic, technical and integrated public service governance. 89 Together, they form the foundation of digital cooperation. 90 By harmonising legislation, aligning institutions and ensuring data compatibility, these layers make cross -border services possible. In sum, interoperability and digital transformation are strategic prerequisites for achieving the Digital Single Market.

86 Regulation (EU) 2024/903 of the European Parliament and of the Council of 13 March 2024 laying down measures for a high level of public sector interoperability across the Union (Interoperable Europe Act) [2024] OJ L 903/1 [2024], art 6; European Commission, New European Interoperability Framework: Promoting Seamless Services and Data Flows for European Public Administration (Publication of the European Union, 201) <https://ec.europa.eu/isa2/sites/default/files/eif_brochure_final.pdf> accessed 9 June 2026 5

87 European Commission, New European Interoperability Framework: Promoting Seamless Services and Data Flows for European Public Administration (Publication of the European Union, 201) <https://ec.europa.eu/isa2/sites/default/files/eif_brochure_final.pdf> accessed 9 June 2026 13-18.

88 ibid 14, 18, 22.

89 ibid 22, 25, 27-30

90 ibid 22-30

A. Governance & Legal Interoperability

The EIF emphasizes that governance interoperability (shared vision, leadership, coordination) and legal interoperability (harmonised rules, mutual recognition) are foundational enablers for cross-border and cross institutional digital public services. 91 In Romania, the recent Authority for Digitalisation of Romania (ADR) was created in 2020 to lead digital government efforts. However, the OECD review notes that ADR faces limited legitimacy and coordination capacity across the public sector, resulting in fragmented efforts and duplicated initiatives. 92 Moreover, while legal frameworks such as the national interoperability law and data exchange law have been adopted, 93 guidelines and standards to support implementation are still perceived as insufficient. 94 For Bucharest municipality, this means the structural governance environment remains weak. Without strong mandates, coordination mechanisms and clear legal interoperability across local, regional and national levels, efforts to adapt interoperable service risk remaining isolated rather than scaled.

B. Organisational, Semantic and Technical Interoperability

In Romania, the OECD review highlights that while key digital infrastructure initiatives exist (e.g. government cloud, national interoperability platform, digital identity), many public institutions are at varying levels of maturity, operate in silos and l ack consistent data sharing and reuse practices. 95 For example, Romania publishes relatively few “high -value” open datasets and many institutions lack -data management capacity. 96 For Bucharest this suggests that even at the local level, success will depend not merely on installing infrastructure, but on aligning organisational processes, training staff in data/semantic interoperability and adapting common technical standards with national systems and other municipalities.

91 ibid 22, 25, 27.

92 OECD, Digital Government Review of Romania: Towards a Digitally Mature Government (OECD Digital Government Studies 2023) 21-30.

93 Legea nr. 242/2022 din 20 iulie 2022 privind schimbul de date intre sisteme informatice si crearea Platformei nationale de interoperabilitate, Monitorul Oficial n. 752/27 July 2022. This is the official data exchange and national interoperability law in Romania, adopted in 2022.

94 OECD, Digital Government Review of Romania: Towards a Digitally Mature Government (OECD Digital Government Studies 2023) 21-30.

95 ibid, 70-90.

96 ibid.

C. Service Design and Delivery, User Centricity

The EIF stresses user centrism, integration and reusability of services, meaning public services should be designed around citizens and businesses, delivered seamlessly across institutional borders and built on reusable building blocks. 97 The OECD review of Romania remarks that despite digital advances, the service -design and delivery landscape remains disjointed: many services will still rely on paper or physical interaction as there is no shared strategic approach to service design acros s institutions and guidelines/standards for agile procurement, service-design and user-research are limited. 98 In our opinion, in Bucharest, this translates into a critical first step: before attempting to roll out full interoperable, crossinstitutional digital services, the municipality needs to adopt a user centric approach, map citizens/business journeys, acquire reusable service-building blocks and ensure interoperability with national frameworks.

D. Implications for Local Focus: Bucharest & Romania

Putting it all together, applying the EIF lens to Romania and Bucharest shows that the country is still laying foundations rather than fully implementing the interoperable, citizencentred digital state that the EIF envisions. Our analysis in Section A, ha s shown that the key steps involve strengthening Romania’s governance structures by elevating the ADR’s role and improving both vertical coordination (national authority – local authority) and horizontal coordination (across public agencies). At the same t ime, we find that Romania and Bucharest need to advance data and infrastructure interoperability through the development of shared registries, APIs and semantic alignment, while ensuring technical standards across levels. In this context, Bucharest should take a leading role in pioneering integrated and user-centric digital services by reusing interoperable building blocks and deliver visible ‘quick wins’ capable of building public trust and institutional momentum for broader digital transformation. Without these foundational steps, full compliance with and benefits from the interoperable ecosystem envisaged by the EIF (and the broader Digital Single Market) will remain out of reach.

97 European Commission, New European Interoperability Framework: Promoting Seamless Services and Data Flows for European Public Administration (Publication of the European Union, 201) <https://ec.europa.eu/isa2/sites/default/files/eif_brochure_final.pdf > accessed 9 June 2026, 15-16.

98 OECD, Digital Government Review of Romania: Towards a Digitally Mature Government (OECD Digital Government Studies 2023), 70-90

In our analysis, the city must operate within a national context marked by limited readiness for change and weak implementation capacity. If digital reforms cannot be successfully implemented in Romania’s most advanced and digitally mature city, their viab ility in less developed regions becomes highly questionable. At the same time, Bucharest’s position as Romania’s largest city, its capital and its primary digital hub gives it a unique strategic advantage. This concentration of institutional capacity, user s and digital infrastructure positions the city to act as a catalyst for rapid digital transformation. If leveraged effectively, Bucharest can serve as a testing ground and Firestarter for scalable reforms, setting standards and practices that can be replicated across the rest of the country.

VII. Recommendations and Outputs

This section provides policymakers and other stakeholders engaged in Romania’s interoperability journey with concrete recommendations derived from the research presented above. It outlines a set of actionable options for consideration while also highlighti ng technological interoperability as a relatively underdeveloped ‘grey area’ within Romania. In doing so, it emphasizes the significant opportunities for technological, economic, and institutional growth associated with advancing interoperability in this d omain. Bucharest’s current ecosystem remains constrained by fragmented systems and limited coordination. Our findings reveal that the capital’s digital transformation is not hindered by a lack of ambition or technology, but by the absence of a coherent, strategic and operational foundation on which interoperability can meaningfully operate.

The output of this research therefore contributes to the broader study in bridging interoperability gaps in Europe, specifically Bucharest, in two crucial ways. First, it maps the gap between the EU’s interoperability expectations and Bucharest’s on -the-ground readiness. Second, it formulates realistic, phased recommendations for how the municipality, and implicitly Romania as a whole, can build a digital ecosystem capable of supporting the IEA in the future.

A. Key Recommendations for Foundational Readiness

1. Strengthen and Empower the Authority for Digitalisation of Romania (ADR) and Local Governance Structures

Romania already has a central body (the Authority for Digitalisation of Romania) mandated to coordinate national digital transformation. However, the OECD review highlights that the ADR currently lacks the authority, resources, and legitimacy to enforce its strategies across ministries and local administrations. 99 In our opinion, in Bucharest, this institutional weakness translates into fragmented projects, unclear mandates, and duplicated digital efforts. To address this, the ADR’s coordination and enforcement powers should be strengthened through a formal mandate to oversee and approve municipal -level digital projects, ensuring alignment with national and EU interoperability standards. In addition, clear vertical coordination mechanisms between the ADR and local governments such as Bucharest are needed to ensure consistent data governance, shared infrastructure, and interoperability frameworks across administrative levels. A t the municipal level, Bucharest should also establish dedicated digital coordination units that act as direct counterparts to the ADR, ensuring that national strategies are adapted and implemented effectively at city level. Without such institutional empowerment and coordination, Romania’s digitalisation will remain a collection of isolated projects rather than an integrated, interoperable ecosystem, in our view.

2. Strengthen Data Infrastructure and Interoperability Standards

We are of the opinion that, Bucharest should prioritise the development of a unified data governance and management framework capable of supporting data sharing across municipal departments and between local and national authorities. This includes the adop tion of common technical semantic and organisational standards to ensure that information can be exchanged, interpreted and reused consistently across systems. Investments in shared registers, interoperable data bases, open APIs and secure data architectur es is essential to reduce institutional isolation and support the delivery of integrated public services. Aligning local systems with national interoperability platforms and European standards would further enhance scalability, facilitate cross -institutional cooperation and reduce duplication of administrative processes. By establishing a robust and standardised data infrastructure, Bucharest can create the foundations for user-centric digital services and future compliance with the IEA.

3. Adopt a User-Centric and Integrated Service Design Approach

99 OECD, Digital Government Review of Romania: Towards a Digitally Mature Government (OECD Digital Government Studies 2023) 13-14.

Before expanding digital services, we recommend that Bucharest should redesign existing administrative processes from the citizen’s perspective. The EIF identifies usercentricity as a core principle of digital government, emphasising that services should be organised around user-centricity as a core principle of digital government. 100 This emphasises that services should be organised around user needs and delivered seamlessly across administrative boundaries rather than reflecting internal bureaucratic structures. 101 The OECD similarly argues that effective digital transformation requires governments to adopt service design approaches that place users at the centre of policy development and service delivery, ensuring that services are accessible, intuitive and respons ive to citizen’s needs. 102

In practical terms, it is our opinion based on our research that Bucharest should prioritise the creation of an integrated service journey and could perhaps establish a municipal “one -stopshop” platform through which citizens can access multiple public se rvices via a single digital interface. Drawing inspiration from the Netherlands’ General Digital Infrastructure, such a platform could consolidate access to municipal services, reduce administrative burdens and build citizens’ trust in digital government w hile minimising the need for repeated data submission. Particular attention should be paid to accessibility, plain -language communication and support mechanisms for users with lower levels of digital literacy. By reducing fragmentation and creating a more coherent digital experience, Bucharest could increase citizen trust in digital government while laying the foundations for interoperable and citizen - centred public services consistent with both the EIF and the objectives of the IEA.

4. Invest in Human and Institutional Capacity

We believe that digital literacy and institutional readiness are required in order for the technical systems to work, regardless of how high -tech they are. Therefore, it is essential that all civil servants, from top to bottom, receive training programs an d timely data and information to gain the interoperability and digital skills needed. Bucharest and other municipalities in Romania and Europe, could utilise the Interoperable Europe Portal and the Interoperable Europe Academy as much as possible, to gain access to MOOC trainings where completion of the training provides certification, exch ange knowledge and encourage the usage of reusable

100 European Commission, New European Interoperability Framework: Promoting Seamless Services and Data Flows for European Public Administration (Publication of the European Union, 201) <https://ec.europa.eu/isa2/sites/default/files/eif_brochure_final.pdf> accessed 9 June 2026 15-16. 101ibid.

102 OECD ‘The OECD Digital Government Policy Framework’ ( Public Governance Policy Papers No. 02 , 2020) 28-29

interoperability solutions. 103 Additionally, Bucharest could integrate the Digital-ready Policymaking (DRPM) framework in their own policymaking processes. This would enable them to consider digital implementation and interoperability when creating policies. If this were done early enough in the process, then all digital projects and new regulations created by the city government would be interoperable and compatible with both Romania's and the European Union's current goals. The Interoperable Europe Act also provides a basis for this a pproach, especially since it enables assessments on interoperability and cross -administration cooperation. 104 Romania already has national legislation for interoperability which suggests that alongside the IEA, there is also a domestic Romanian legal basis that may support implementation of interoperability policies and cross -administration cooperation. 105 Article 14 Section 2(b) of Law 242/2022 could possibly serve as a vehicle for implementing further interoperability policies, in our view. 106

5. Modernize the Legal and Procedural Framework

It is our conviction that Romania’s existing legislation on interoperability should be complemented with local-level regulations and clear data-sharing guidelines to facilitate lawful, secure exchange of information between institutions locally. Legal ambi guity must be addressed to ensure compliance and confidence in digital processes.

6. Pilot Scalable Local Projects

We believe that Bucharest can serve as a national testbed for interoperability pilots, projects such as digital identity integration, interoperable transport systems, or digital archiving. Successful pilots can then inform nationwide rollout and policy ref inement.

B. Why this Research is Relevant

This study adds value by addressing the “grey area” that most policy discussions overlook, the space between theoretical compliance and practical readiness. Rather than

103 ‘Interoperable Europe Academy’ (European Commission) <https://interoperableeurope.ec.europa.eu/collection/interoperable -europe-academy> accessed 9 June 2026.

104 Regulation (EU) 2024/903 of the European Parliament and of the Council of 13 March 2024 laying down measures for a high level of public sector interoperability across the Union (Interoperable Europe Act)

OJ L 2024/903 [2024] arts 3, 6–8.

105 Legea nr. 242/2022 din 20 iulie 2022 privind schimbul de date intre sisteme informatice si crearea Platformei nationale de interoperabilitate, Monitorul Oficial n. 752/27 July 2022. This is the official data exchange and national interoperability law in Romania, adopted in 2022.

106 ibid, article 14, section 2(b).

assuming the IEA can be implemented on an unprepared foundation, our research acknowledges the structural and cultural realities that shape Romania’s digital landscape. By identifying the concrete first steps needed before interoperability can take root, t his study bridges the divide between EU-level aspirations and local-level feasibility. Furthermore, this research adopts a bottom-up empirical research approach, combining citizen perspectives with institutional analysis. In doing so, it reveals how digital reform is not merely a technical process but a socioinstitutional transformation requiring trust, coordination, and inclusivity.

Ultimately, the relevance of this work lies in its pragmatic vision: Bucharest can become the cornerstone of Romania’s digital renewal if it focuses first on building durable, interoperable, and citizen-oriented foundations.

VIII. Conclusion

This paper investigated the extent to which Bucharest was ready to support the execution of the Interoperable Europe Act (IEA). The findings revealed that Bucharest's greatest challenge in supporting the IEA is not about technology; it is about institutional preparation. While Romania has made significant progress in digital law-making, infrastructure and digital identity projects, there are still many gaps remaining in some areas. Areas such as governance, coordination and cooperation, data-sharing and services offered by government agencies. Many of the current limitations facing the actual implementation of interoperability in the public sector are due to those shortcomings.

Using Bucharest as a model provides evidence of the disconnect between Romania formally agreeing to meet the European Union's digital objectives versus the operational foundation needed to actually do so. Bucharest is the largest and most digitally developed city in Romania, as such it is trying to become a leader in implementing digital reform and can provide an environment where digital reforms can be tested at scale. The original contribution of this research is its focus on readiness as a condition for achieving interoperability. Instead of seeing the IEA as an obligation that needs to be fulfilled immediately, this research demonstrates that this can only be done through developing robust governance structures. This means improving interagency collabora tion, designing public services from a citizen perspective and increasing the capabilities of public administrations which will allow sustainable interoperability to be achieved.

Therefore, interoperability should be seen as a long -term social and institutional transformation rather than a technological objective. Once Bucharest and Romania address their underlying preparatory conditions, they will be able to develop a much more in tegrated, effective and citizen-focused digital public sector.