In January 2026, the European Commission launched a call for evidence for a proposed Open Digital Ecosystems Strategy. The proposal explicitly links open technologies to digital sovereignty and emphasizes the importance of supporting the full lifecycle of open source technologies, from development to market integration.
This marks a significant shift from previous open source-related strategies that were largely internal facing, towards a more strategic approach that looks beyond technical artefacts and licensing and adopts an ecosystem‑level approach. For instance, the 2020–2023 Open Source Software Strategy was explicitly framed as a ‘practical instrument for the digital transformation in the Commission’, focused on internal culture and reuse. In contrast, the new proposal is positioned to support open digital ecosystems across the Union and to address barriers such as access to growth capital and shared infrastructure.
This echoes a diagnosis that Open Future has articulated in the Strategic Agenda for the Digital Commons—around the need for more strategic approaches to scaling open source and public-value based technologies, with an explicit focus on cultivating an ecosystem capable of fostering genuine alternatives to dominant platforms.
The Commission’s new framing has clearly resonated. The consultation received more than 1,600 responses, unusually high for this kind of exercise (the consultation for the Cloud and AI Act, by contrast, received around 190 responses). This indicates both the breadth of stakeholder interest and a degree of convergence around the urgency of this positioning.
Based on a review of the submissions, several themes stand out: calls for EU-level funding to support critical open source components; a push to treat open source as more than just an open licensing requirement; a convergence around the importance of public procurement as a strategic lever; and calls for including various other types of Digital Commons within the scope of the strategy. These themes have been explored through our policy work with NGI Commons. This analysis looks at them in detail.
Europe needs a Sovereign Tech Fund
There appears to be strong and recurring support for establishing an EU-level equivalent of the German Sovereign Tech Agency to fund critical open source infrastructure. The submission from the Sovereign Tech Agency itself makes the case quite clearly: maintenance is “structurally underprovided” and project-based grant funding is not an appropriate instrument. What’s needed is operational, recurring investment analogous to road maintenance. Incidents such as Log4Shell and the XZ backdoor have illustrated the fragility of these foundations when maintainer capacity is limited. The German model has demonstrated that targeted, sustained investment can meaningfully improve maintenance, security, and long-term sustainability. It also strengthens the social foundations of the ecosystem—reducing maintainer burnout and the precarity that compromises long-term resilience. This position is echoed across institutional and individual submissions, with a recognition that this is a shared challenge deserving a coordinated response: digital infrastructure transcends borders, and fragmented national approaches risk duplication and gaps.
At the same time, some questions still remain about how such an instrument could be stewarded. The European Digital Infrastructure Consortium (EDIC) framework—which enables Member State collaboration on cross-border digital infrastructure projects—presents one plausible vehicle. An EDIC specifically focused on Digital Commons has recently been established and could, given a clear mandate and sufficient resources, anchor such an instrument. Compared to ad-hoc project funding, the EDIC model offers shared governance, multi-state coordination, and greater political durability.
Questions about funding sources also remain open. In addition to Member State contributions, some submissions point to mechanisms targeting commercial actors that derive significant value from open source infrastructures. Open Knowledge Sweden, for instance, proposes tax incentives to encourage sustained contributions to open source development. The normative logic appears to be one of reciprocity, signalling a growing recognition of the free-rider problem embedded in open ecosystems.
Open source as a commons, not just a license
One of the key themes visible across submissions is the idea that open source is often a Digital Commons: with projects that are produced, owned or governed in a distributed or communal way. They may also involve access and sharing rules to ensure the sustainability of the resource and the community against exclusive use or asymmetrical value extraction. Wikimedia Germany, in its submission, notes that the number and diversity of contributors should be treated as a key performance indicator.
Several submissions emphasize the importance of open source as Digital Commons. This is more than a shift in language: they conceptualize open source as not merely a question of licensing, but as a shared resource sustained by communities, practices, and norms. The French public agency DINUM argues that Digital Commons are the preferred alternative to open core projects, where open source development is ultimately dependent on a single, commercial actor. In such alternatives, communities are the key asset that allows for sustainable and secure development.
If open source production is seen in this way, additional criteria for public procurement should be considered. For example, the Wikimedia Foundation recommends introducing criteria that ensure that value flows back to the communities actually maintaining the commons, and that procurement processes reward meaningful participation and contribution. Submissions from the Linux Foundation Europe, OpenForum Europe, and the Drupal Association (among many others) advocate for requirements that code developed with public funds is contributed upstream to the central codebase, or that bidders demonstrate meaningful contributions to the development and maintenance of relevant projects. There is a concern that without such conditions, open source commercial actors can free-ride—packaging and reselling open code without contributing proportionally to its sustainability, undercutting actors that invest in maintenance and community work.
This reflects the emergence of an “open source, and” framing: it may not be sufficient to procure open source software, but to also ensure reciprocity with the ecosystem and the communities that maintain it.
This represents an important shift: open source is understood not simply as a freely available resource or an input for industrial competitiveness, but as a Digital Commons. Open Future has previously argued for such a shift in our Strategic Agenda for the Digital Commons and Digital Sovereignty. The objective is to bring attention to issues of stewardship, reciprocity, and governance, and the practices of commoning that sustain open source infrastructures.
Towards an ecosystem of varied Digital Commons
A significant group of responses, submitted by European organizations and public institutions, argues for a broader scope of the Open Digital Ecosystem strategy, so that it encompasses other types of Digital Commons, beyond open source code. As the submission from Open Food Facts notes, many of the global Digital Commons were created in Europe and contribute to European soft power—for example, OpenStreetMap, Zenodo, Open Food Facts, Wikidata, or Europeana.
The importance of Open data infrastructure and various types of data commons are highlighted by submissions from the Digital Public Goods Alliance, OpenMined, and Open Knowledge Sweden. This is especially relevant for the development of European public AI solutions, and thus reducing reliance on closed, non-EU AI systems.
The submission from the Coop des Communs expresses well the potential of the Digital commons. They have the capacity to generate high public value, they foster cooperation, and they are resilient. Yet in order for the Digital Commons to be successful, support for the various communities needs to be recognized as an essential public investment.
Therefore, the approach to sustainable development of the commons, developed in relation to open source by initiatives like the Sovereign Tech Agency or NGI, need to be applied more broadly. Open Knowledge Sweden recommends creating a new Open Digital Ecosystems Fund that would support not just open source, but various other digital public goods. This matters because sovereignty is not only about reducing dependence on proprietary software vendors. It is also about safeguarding shared infrastructures that enable pluralism, democratized access, and collective stewardship.
Procurement as a strategic lever
Across submissions (and in the call for evidence), public procurement is seen as a key lever for digital sovereignty, and supporting open digital ecosystems. This focus on sustainable procurement sits within a broader moment of procurement reform. The revision of the Public Procurement Directives is underway, and the forthcoming Cloud and AI Development Act— explicitly framed as complementary to the Open Digital Ecosystems Strategy—is expected to include procurement-related provisions.
Legal clarity is necessary. Contracting authorities need assurance about how they may incorporate strategic objectives related to sovereignty and ecosystem sustainability into award criteria and performance conditions. But legal reform alone may not be sufficient. The Italian Department for Digital Transformation notes that even though the national legal framework mandates the adoption and reuse of OSS software, it does not provide sufficient practical guidance to public administrations.
Capacity, across a highly distributed landscape of public bodies, is a significant constraint if procurement practice must shift towards complex technical criteria related to source code availability, exit, and ecosystem sustainability. Public bodies need capacity and expertise to draft and adopt clear and legally sound criteria; to assess compliance and evaluate competing bids; and to monitor post-contract performance.
Given these complexities, in practice, public bodies tend to default to price, even when the legal framework permits criteria linked to broader policy objectives. At the same time, SMEs may struggle to navigate and absorb the costs associated with complex and fragmented procurement criteria.
Addressing this challenge, and leveraging public procurement as a market shaping tool, points to the importance of greater coordination between public bodies—from developing shared procurement criteria to coordinated implementation support, compliance monitoring, and enforcement. The Commission’s Cloud Sovereignty Framework offers one example of what shared criteria could look like. Certification or labelling schemes, if well-designed and credibly stewarded, could also help address capacity constraints by shifting part of the assessment burden away from individual contracting authorities.
The Open Digital Ecosystems Strategy can be a way to deliver the institutional scaffolding that can complement legislative reform. For instance, GitHub proposes that the European Commission could transform its Open Source Programme Office into an inter-DG unit with the responsibility for the successful implementation of the Open Digital Ecosystems Strategy.
Sovereignty through Digital Commons
Responses to the call for evidence point to recurring concerns about safeguarding the common foundations of critical digital infrastructures, addressing free-riding, sustaining maintainer communities, and overcoming structural capacity constraints. They also propose an expansive understanding of the European Open Digital Ecosystem, that includes various types of Digital Commons, in addition to open source infrastructures.
Taken together, they point to Digital Commons as a response to the digital sovereignty question. In our submission, we state that “Digital Commons support not just a state’s ability to act independently, but also provide individuals and communities with greater control over the digital environments, on which they rely”. In the coming months, we will publish a series of NGI Commons policy briefs, which identify how such an approach can be integrated into the EU’s policy and budgetary framework.
This marks a departure from a purely industrial policy approach to digital sovereignty. Beyond focusing only on scaling European alternatives or strengthening market position, it emphasizes building and sustaining Public Digital Infrastructures, ones that foreground public value. These approaches can be complementary, and the Open Digital Ecosystems Strategy should recognize both: strengthening the EU’s technological capacity while embedding the stewardship mechanisms that make Digital Commons resilient and sustainable.
