Feedback to the European Commission 3.7.2026 (448/03.01.00/2026) Ilona Koto ja Jaana Jormanainen

Feedback to the European Commission’s review of the European Interoperability Framework

How can the future

The Association of Finnish Cities and Municipalities (AFCM) is a national organisation with all 308 municipalities and cities in Finland as its members. Finnish municipalities have extensive responsibilities for public basic services, including education, employment and economic development, environmental matters, and technical infrastructure.

Here are AFCM's answers to the questions asked in the feedback

1. What elements of the previous EIF versions should be kept or strengthened?

  • Reinforcing the importance of semantic interoperability rather than technical specifications. The interoperability of semantic data is emphasized to make the information useful for e.g. cross-border services, EUDIW wallets and to streamline the services offered to citizens with new technologies. 

  • In terms of data sharing and sovereignty, it must be updated to correspond to the current (and future) security situation.

  • We must pay more attention to the development of technology so that we do not lock ourselves strongly around one technology, which happens to be the hype of the moment, because the situation is quickly becoming outdated again. 

2. What are the main barriers for implementing the EIF at EU, national, regional or local level?

  • The principles are good, but they are too far removed from everyday and practical activities. The more we move from central government (EU) to the local level (municipalities), the more we need to translate the principles into practical tools and provide sufficient support for their use. Each level should also build on top of the previous one, not overlapping work.

  • Ensuring interoperability at different levels requires special expertise and resourcing. The work should be integrated into all (digital) development of public administration and not try to push it as a separate requirement.

  • There is no political will to promote the interoperability of data, and thus there is no resourcing and funding for work. Especially the work of the semantic layer requires a lot of experts and time to agree on common metadata. 

3. What additional guidance would facilitate more systematic uptake?

  • From the point of view of the local level, it would be important to have a significantly stronger and clearer NIF in addition to the EIF. For the local level to be able to meet the requirements coming from the EU level, for example in terms of cross-border services, there must be a clear infrastructure at the EU and national level for this.

4. How can the future EIF support the next steps in the digital transformation of public administrations?

  • By means of communication and practical tools and case examples. If we want to find solutions for productivity, technology independence and grow the European digital market, we need to expand the understanding of interoperability and its importance to the public. 

  • The EU's own bodies could serve as model examples for the implementation of the principles. 

5. What changes or improvements would you suggest for the future EIF?

  • It would be good to summarize and/or divide the documentation clearly into different parts, such as long overall documentation, in addition to which summaries and, for example, tools to support practical work.


THE ASSOCIATION OF FINNISH CITIES AND MUNICIPALITIES

Markus Pauni
Director of Strategy and Development

Ilona Koto
Senior Adviser

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