kom (2021) 0118 - Bilag 3: Notat samt høringssvar vedrørende digitalt politikprogram

Europaudvalget 2020-21
KOM (2021) 0118 Bilag 3
Offentligt

The Danish Government’s response to

the targeted consultation on the

2030 Digital Compass

General comments

The Danish Government welcomes the Commission’s communication on

the 2030 Digital Compass. Digitalisation is vital for our economic and so-

cietal development, security and safety and we share the ambition of pur-

suing digital policies that empower people and businesses to seize a human-

centered, sustainable and more prosperous digital future. To achieve this

ambition, we need a common vision and direction which supports and ac-

celerates the digital transformation in Europe, where responsibility, safety

and security go hand in hand with innovation and growth. In parallel, the

transition to a green and sustainable society is a key priority. Therefore, we

find it of utmost importance that the communication’s initiatives support a

climate-neutral and circular economy.

On this basis, we support the ambition of a digitally sovereign Europe that

is self-determined and open. Digital sovereignty is not about shielding our-

selves unnecessarily from the outside world or becoming completely inde-

pendent, but about strengthening our own capacity to develop technology

and digital solutions and ensure that our security and values are the foun-

dation of the EU’s digital future.

A fair and competitive digital single market must be the foundation for

strengthening the EU's digital competitiveness and digital sovereignty. A

more coherent digital single market is a prerequisite for spurring digitali-

sation across Europe and the societal challenges stemming from digitalisa-

tion is best addressed through joint efforts within this remit.

In addition to improving the digital single market, we recognize that there

may be a need for targeted efforts that promote strong technological capa-

bilities and competences in certain critical technologies. The identification

of critical technologies and related high-risk dependencies must be based

on a thorough and transparent analysis with clear criteria. Such thorough

assessment should also assess the available measures at hand in order to

ensure the proportional level of action. Hence, not every sector and tech-

nology can or should be regarded as critical. It must furthermore be ensured

that our actions safeguard key principles in the digital single market and

that the resilience of the EU must be ensured through a strengthening and

diversification of global supply

–

not by phasing out global value chains.

Such systematic assessment must be part of the 2030 Digital Compass.

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In general, we support the four cardinal points covering competences, in-

frastructure, businesses and public services, as these constitute a solid, hor-

izontal starting point for setting an ambitious direction for our digital trans-

formation. It is important that the specific targets are result-based, future-

proof and lead to real value for citizens and companies. Therefore, the spe-

cific targets should concisely describe the end goal, but not the specific

technique, measure nor method as to achieve the target. Furthermore, as the

Digital Compass sets targets for 2030, a midterm evaluation of the targets

must be incorporated in order to make sure that the targets are still relevant

–

also in the light of technological progress.

It is important to have a solid governance structure in place. In this regard,

it is imperative that the governance structure sets the overall strategic di-

rection, but that there should be room for manoeuvre at national level

–

both in terms of the possibility to set a higher level of ambition as well as

to ensure flexibility to make use of the mix of measures that are deemed

most useful in each member state. Furthermore, the division of compe-

tences between the EU and the member states must be respected in the im-

plementation.

As the establishment of the 2030 Digital Compass is a horizontal agenda

covering most aspects of the digital sphere and thereby demands great co-

ordination between different areas, we attach great importance to the close

involvement of member states in order to set the right targets as well as to

ensure co-ownership.

Specific comments

Rolling out high-speed broadband and 5G

Overall, we agree that there is a need for rolling out high-speed broadband

and 5G as broadly as possible. However, before discussing or launching

new initiatives, the ongoing implementation of recently adopted acts and

their effects such as the Electronic Communications Code and its several

common European measures should be taken into account.

When setting new pan-European targets for broadband coverage, it is nec-

essary to take into account the fact that not all households will have reached

access to speeds of 100 Mbit/s by 2025. Therefore, a new broadband strat-

egy should also focus on ensuring that all households get access to the cur-

rent broadband coverage target in order to ensure that all European citizens

have access to a high-capacity broadband connection.

Furthermore, it is important to have national flexibility within the general

EU framework, as this should enable member states to take national cir-

cumstances such as differences in mobile broadband coverage into account.

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In this respect, we do not support a further harmonisation of spectrum ad-

ministration, including the licensing procedures, as this would only benefit

the bigger actors on the European telecom market and risk inappropriate

consolidation and weakened competition.

Fostering digital transformation of businesses

We support the objective of strengthening the digital transformation of

businesses and believes that this should be carried out on the basis of a

comprehensive strategy which strengthens companies' competences and

improves their ability to scale across borders. In this respect, it is further-

more essential that SMEs are able to take advantage of the digital transfor-

mation. Establishing the European Digital Innovation Hubs is one concrete

initiative to ensure broad uptake of digital technologies, but initiatives to

support SMEs in this process must be continuously factored in in the pro-

cess of the Digital Compass.

Furthermore, besides setting targets for businesses’ adoption of

technolo-

gies, we would also underline the need to focus on innovation as well as

the general framework conditions in the digital single market. In order to

implement a truly digital single market, it is therefore important to monitor

its progress with related key performance indicators. Such indicators could

be tracking the development in regulatory barriers within the Digital Single

Market, the amount of cross-border e-commerce or the development of

market shares for European digital businesses.

Digitalisation of public services

Regarding the digitalisation of public services, there must also be a focus

on quality indicators such as privacy, security and user friendliness. Such

indicators should be among the guiding posts towards the targets of the

Digital Compass in order to achieve the Commission's vision of an acces-

sible, easy-to-use, efficient, personalised and highly secure digital public

sector.

It is not a given that any key public service provided online at the national

level is also relevant for cross-border access. We need a more agile, user-

centric and user-driven approach to find an appropriate level of key public

services which is based on user demand and well-functioning technical so-

lutions that enables cross-border interoperability. Furthermore, we are cur-

rently evaluating whether the European Digital Identity Wallet can be a

tool for prioritising cross-border access to high-demand

digital services.”

Semiconductors

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We support the target of strengthening Europe’s capacities to produce sem-

iconductors. The current crisis with businesses all over the world struggling

due to the shortage in supply of semiconductors underlines the essential

role semiconductors play in the modern economy and stresses the need for

enhanced resilience in this area. An ambitious and achievable target regard-

ing Europe’s technological capacities to produce semiconductors could

play an important role in these efforts.

Further elements which should be reflected in the specific targets

The dimensions of cybersecurity and data ethics seem to be missing in the

targets, especially given the importance of this aspect for our digital econ-

omy and society. We would suggest adding key performance indicators

concerning cybersecurity and data ethics respectively in order to monitor

progress as well as to enable a high level of cybersecurity and promote

responsible and human-centered solutions. The key performance indicators

for cybersecurity could e.g. measure the extent to which EU enterprises

implement cybersecurity measures, as well as the extent to which enter-

prises make employees aware of their obligations in cybersecurity issues.

For data ethics, we propose a key performance indicator which measures

the extent to which EU enterprises have formulated a data ethical code of

conduct.

Another area is the synergy between the green and digital transition. This

element figures in the description of the different targets but is not estab-

lished as a self-standing target. In our view, this synergy should have more

prominent place in the Digital Compass and a specific target should be de-

veloped.

Furthermore, given that trust and innovation are two sides of the same coin

as well as a prerequisite for accelerating the digital transformation, we

would like to see a greater reflection of trust in the targets. We support the

annual Eurobarometer exercise dedicated to monitor Europeans’ percep-

tion of digitalisation and how it is serving them in order to monitor the

implementation of digital principles, also refer to the Danish response to

this consultation. However, in our view, such exercise should be coupled

with concrete key performance indicators concerning trust. Both DESI as

well as OCED’s Digital Toolkit contain relevant indicators, for example

individuals experienced abuse of personal information or individuals not

buying online due to payment security concerns.

Multi-country projects should solely address potential gaps

Strengthening the digital single market through the continued focus on

highspeed network as well as stronger capabilities in terms of advanced

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technologies, competences, business transformation and public transfor-

mation should be at the centre of our efforts. We would therefore call for a

holistic approach to strengthening these aspects, where investments are one

part of the recipe, but not the entire recipe.

From our perspective, we have not seen the concrete need for a new specific

mechanism concerning multi-country projects and would emphasize that

financing is provided for within the agreed multiannual financial frame-

work 2021-2027, including through established financing instruments. If

gaps exist in terms of existing instruments and if a new mechanism should

be needed, it would be essential to establish a transparent, structured and

open framework in full compliance of competition and state aid rules as

well as existing instruments.

Establishing a governance structure with flexibility and no “one size fits

all”

The governance structure and its monitoring should focus on the progress

with the targets and principles - rather than compliance with the broader

EU digital policies. The governing objective must be to monitor progress

in the member states, but it would also be beneficial to compare the digital

transition in Europe with other parts of the world such as the US and China

in a systemic manner.

The follow-up exercise concerning annual reporting as well as cooperation

and coordination between the Commission and the member states should

feed into the European semester. Thereby, it should be based on existing

mechanisms as well as competences between the Commission and the

member states. The usage of the well-functioning process of the semester

should furthermore acknowledge the flexibility of member states in terms

on how to achieve the targets, as challenges differ between member states,

thereby leaving a “one size fits all”-model

not appropriate for this follow-

up exercise.

With these points, we stand ready to engage in the discussions actively and

constructively on the 2030 Digital Compass. Furthermore, we reserve the

right to submit further comments at a later stage.