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FSFE's answers to the European Commission's Public Consultation: Revision of the European Interoperability Framework

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The European Commission is asking for public input with regard to its plans to renew the European Interoperability Framework (EIF). The EIF aims to promote enhanced interoperability in the EU public sector. The document, originally intended as a set of non-binding guidelines for the EU public administration, is going through its third revision since its initial adoption in 2004. The FSFE has prepared its comments for the draft of the revised guidelines.

The FSFE sees some improvement compared to the previous revision, in particular concerning the preferred use of Open Standards (called "open specifications" in the draft revision) in European public services.

However, we need to address several shortcomings. The statement that FRAND (allegedly "fair, reasonable, and non-discriminatory") licensing terms for standards "will foster competition" (according to the Commission) is just plain wrong. FRAND licenses are highly anti-competitive in nature and it is a well-established fact that they make it impossible for a standard to be implemented in Free Software.

The draft also ignores the proven relationship between interoperability and Free Software. Most, if not all, national interoperability frameworks across Europe have based their success on substantial adoptions of Free Software and Open Standards in public services. So much so it is to all effects impossible to implement an interoperability framework without Free Software. For more information, please see our full comments on the revision of the EIF.

The FSFE encourages you to provide your own input to the ongoing consultation. Replies can be submitted by individuals, companies, academic institutions, and public administrations before 29 June. Feel free to reuse the arguments laid out above for your own submission and tell the Commission how Free Software and Open Standards are quintessential for interoperability.