eco – Association of the Internet Industry welcomes the criteria catalogue and maturity model for the Germany Stack presented by the German Federal Ministry for Digital Transformation and Government Modernisation (BMDS), but sees a significant need for improvement. In order for the Germany Stack to become a sovereign, interoperable and future-proof infrastructure, criteria must be clearly defined and applied consistently.
“The Germany Stack is one of the central digitalisation projects of this legislative period. The goal is to build a secure, interoperable and European-compatible technology platform for the German federal government, federal states and municipalities. For it to succeed, the criteria must be clearly defined, consistently designed and applied in a technology-neutral manner,” emphasises eco Chair Oliver Süme.
- Clear definitions and consistent operationalisation of all criteria required
From the association’s point of view, all criteria lack clear definitions and a common frame of reference. Without clear target metrics, there is a risk of arbitrary or contradictory evaluation of technical components. eco therefore calls for precise conceptual distinctions and a transparent maturity model.
- Digital sovereignty needs a realistic target vision
The criterion of “digital sovereignty” is currently too vaguely formulated. Digital sovereignty encompasses legal, data-related and technological control as well as aspects of supply chains – and cannot be translated into imprecise stages such as “design capability” or “technology leadership”.
“Digital sovereignty must not be confused with technological autarky. Sovereignty arises through freedom of choice, competition and open interfaces,” says Süme.
- Interoperability as a central foundation
Interoperability is a prerequisite for scalability and European compatibility. eco criticises the fact that it makes too little reference to existing administrative landscapes in Europe, at the German federal government, federal states and municipalities, and does not contain any objectively measurable indicators. Technical standards must be formulated in such a way that allows individual components or applications to be replaced at any time in the future.
Further clarifications needed
The Internet industry also sees a considerable need for clarification with regard to the criteria of “trustworthiness”, “future-proof”, “market relevance” and “sustainability”. For example, interactions with existing regulations – such as in the area of cybersecurity certifications – remain unconsidered, conflicting objectives unresolved, and the wording of the maturity levels is inconsistent.
At the same time, it must be ensured that all criteria are designed to be technology-open and that there is no implicit preference for specific providers, architectures or licensing models. “Only a technology-open, clearly structured and realistically designed criteria model enables genuine freedom of choice and an innovative provider ecosystem,” Süme concludes.
