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EU Open Source Policy: good analysis, missing concrete next steps


On Wednesday the EU Commission published its new Open Source Strategy. We are pleased that the Commission recognises the benefits of Free Software and the four freedoms to use, study, share, and improve, but the Commission lacks concrete targets and indicators to implement the strategy. Without these, we worry that the strategy will end up accomplishing too little!

After the Commission's previous Open Source Strategy expired in 2017, we have waited three years for a new one. Instead of the hoped-for major step, which would reflect current developments around the debates on digital sovereignty and state of the art administration, the Commission has presented only a fig leaf. The benefits of Free Software are fully emphasised and the Commission is ambitious in its future use of Free Software. But concrete goals are rare, and a clear commitment to the use of Free Software is lacking. A failure of the strategy is foreseeable at this stage as the objectives are ambitious but the measures merely establish the status quo. Therefore, we call upon the Commission to present and implement concrete measures and activities in the coming weeks and months.

A fig leaf
European Commission presented only a fig leaf

Apart from the establishment of a "small (sic!) Open Source Programme Office” and the definition and promotion of the "inner source" approach, which is not even connected to a publication under a Free Software license, there are no real changes to the Commission's working methods. Of course, the Strategy indeed states: "The title of this strategy, ‘Think Open’, points to a change in mindset whereby the development of software solutions takes account of openness, sharing and reuse, security, privacy, legal considerations and accessibility." But it is doubtful whether anything will happen simply by clarifying the change in thinking without having verifiable goals and by working on "inner-source" software. We believe that changes have to be implemented and lived, not just put on paper.

The strategy mainly repeats previous commitments and activities; whereas sustainable and verifiable approaches are sought in vain. It says: "The use of open source software is already common practice in the Commission and a kind of open source culture already exists in large parts of the organisation. We simply have to do more and become better". Concrete terms of the plans for how to do this more and better are however not clear. The activities of the FOSSA2 project are also mentioned, but it is not clear why this project is not being continued or why new concrete projects are not being launched. There are also still strong dependencies on Microsoft, for its desktop operating system, office applications and mail programs. These vendor lock-ins are still a big issue, but it appears that there is no plan currently on how to end these dependencies. (There is also a documentary on YouTube in English and German on that)

It is also striking that concrete indicators to measure the success of the activities are absent. The Strategy therefore seems to pay mere lip service, which is explicitly limited by vague formulations and loopholes. For example, the Commission intends to continue "to choose non-open technologies where there are good reasons to do so" and wants to publish software under a Free Software licence only "wherever it makes sense to do so”. What these reasons are and when something makes sense remain undefined and unclear.

In many places the Commission leaves it at problematic descriptions such as: "The principles and actions of the new open source strategy will make it easier to obtain permission to share code with the outside world.". At the same time, it is clear to the Commission that "[c]urrently, the paperwork involved in this process takes time to complete and this holds back many of our in-house projects. This situation needs to change." - without proposing concrete solutions, such as a proposal for reforms.

This also raises the question of how the Commission wants to “contribute to the knowledge society” in tangible terms. For example, instead of calling for Free Software to be made the default in the Horizon Europe research programme and following programmes and research activities funded by the EU, the Commission argues that "[t]his strategy therefore aims to enable the Commission to share software using a process comparable to that for its documents.” - again without a concrete proposal on how to achieve this.

Although the Commission's wording about interoperability, security, reusability and cooperation possibilities repeatedly aims at the use of Free Software and repeatedly emphasises the advantages of Free Software, we feel that the Strategy lacks concrete plans to achieve these aims. How the development of a “world-class public service" can succeed this way remains questionable. Free Software is still not part of the EU budget, so it is not surprising that Commission online-meetings are still held with the proprietary software Zoom although there are viable Free Software solutions for this. With this approach, we fear that this situation will not improve.


What the European Commission presented is simply too little for a strategy. There is a lack of clear task descriptions and processes, concrete guidelines for the implementation of wholehearted statements and indicators to monitor success. Additionally, existing problems and how to address them concretely, like dependencies on single vendors, are missing. So it is not surprising that even the Commission itself, in the document, expresses doubts as to whether their strategy will be a success and identifies difficulties in its implementation: "Properly implemented (sic!), the strategy, its governing principles and its action plan will help us build and deliver better ICT solutions and services, to leverage the innovative and collaborative power of open source."

It is therefore all the more important that we continue to critically monitor the work of the Commission and promote our "Public money? Public Code!" campaign. The "Public Money? Public Code!" initiative aims to establish Free Software as a standard for publicly funded software. Public administrations that follow this principle can benefit from numerous advantages: cooperation with other government bodies, independence from individual vendors, potential tax savings, promotion of innovation and a more solid basis for IT security.

The "Public Money? Public Code!" initiative of the Free Software Foundation Europe is supported by over 180 organisations and administrations from several countries, including Sweden, Spain and Germany. To find out more, please visit: publiccode.eu/

A woman asking for Public Money? Public Code!
Public Money? Public Code!