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Beltug vzw/asbl

Beltug

With over 2500 members from 500 companies, Beltug is the largest Belgian association of CIOs & Digital Technology leaders.

Lobbying Activity

Response to Cloud and AI Development Act

3 Jul 2025

Input from business users associations for new Cloud and AI Development Act On behalf of the associations of Chief Information Officers (CIOs) in Belgium (Beltug), France (Cigref), Germany (Voice) and the Netherlands (CIO Platform Nederland), we would like to share our views and concerns regarding the new Cloud and AI Development Act. Our associations represent a wide range of European companies and public organizations that use digital technologies and cloud services. We are business users of digital technologies. We all agree on the diagnostic of the situation: European companies and public organisations are deeply dependent on US cloud providers that make extensive use of data centers. In May 2025 Cigref published a study on the economic consequences, estimating that the EU companies annual purchases of cloud and software services that benefit the US economy amount to 264 billion. (Technological dependence on American software and cloud services : an assessment of the economic consequences in Europe - Cigref) This means a lot of value creation is lost for Europe and (nearly) no taxes are paid in Europe. The Business users associations support the Eurostack initiative. By creating sovereign AI platforms and federated data spaces, the EuroStack initiative aims to reduce dependencies on foreign providers, protect intellectual property, and position Europe as a leader in public interest AI. The Cloud & AI Development Act to increase digital infrastructure in the EU is one piece of the puzzle. The Business user associations want to insist on additional important actions. A. Reduce current identified dependencies 1. Implement the new rules defined in the Data Act about cloud switching cloud service providers have not made necessary changes Business users are locked-in by their cloud service providers, which leads to an unbalanced relation in favour of the strong provider. Already in 2022 the four associations published 11 fair principles to unleash the potential of the cloud market. We are in July 2025 and we notice that the Providers have so far NOT made changes in their contracts to align with the Data Act, even for new contracts negotiated and signed in 2025. 2. Oblige European and Member States institutions spending public money to invest in Europes economic future. 3. Continue to work to reach a real European single market We will just point out 3 essential pitfalls on the European market: - Fragmentation on the demand side - A shortfall in large scale European investments. - Many EU acts and initiatives are implemented in different ways or with a different timeline in the Member States. 4. Keep enforcing GDPR compliance to protect personal data 5. Start a qualitative analysis based on the DMA to consider the big cloud providers as gatekeepers on the cloud market. 6. Avoid abuse of dominant position by addressing the complaints in case of explicit abuse, for example the Broadcom/VMware case. 7. Promote EU sovereign cloud initiatives 8. Reduce dependency on proprietary software solutions and strengthen EU open software ecosystem B. New dependencies should mandatory be avoided Avoiding new dependencies is as important and probably more important than addressing existing dependencies. This includes: 1. Protect company data, including commercial secrets from access by cloud providers and/or by AI systems owned by these cloud providers. 2. Set an obligation to use EU technology providers for the implementation of the EUDI wallet by the EU Member States institutions with a very strong push for EU companies to do the same. 3. Make EU an attractive place to practice AI C. Rapoport, President Beltug E. Sardet, President Cigref M. Koning, President CIO Platform Nederland H.-J. Popp, MOB, Public Affairs, VOICE e.V.
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Meeting with Manuel Mateo Goyet (Acting Head of Unit Communications Networks, Content and Technology) and Veolia Environnement and

3 Jul 2025 · Exchange on cloud policies

Response to How to master Europe’s digital infrastructure needs?

30 Jun 2024

With over 2500 members from 500+ organisations, Beltug is the largest Belgian association of CIOs & Digital Technology leaders. We cover their priorities such as vendor and software asset management, 5G, hybrid IT, cyber security, artificial intelligence, the hybrid workplace, IoT, privacy, data governance, and many more. Beltug represents the business ICT users at the European and international levels, in close cooperation with organisations in other countries. www.beltug.be We consider the ideas put forward in the white paper a valuable starting point for future discussions. We believe that an ambitious industrial policy is needed to guarantee the European Unions strategic independence in the future. We have no argument with the COMs stated wish that todays connectivity providers become tomorrows providers of collaborative connectivity and computing, capable of orchestrating the different computing elements. However, we find it paramount to stress the importance of the role of the cloud services providers in the current analysis. Cloud in its various forms, including edge, is and will be an important part of the digital infrastructure. We are open to further discussing the practices we have observed in the market and the 11 fair principles we have put forward to rebalance the cloud market and ensure European businesses continue to innovate and remain leaders in their respective industries. We highlight the need to focus on the implementation of the various digital policies, directives and regulations. In that sense, we agree with the COM on the need for standards and certifications. We call on the COM to include the European Cybersecurity Certification Scheme for Cloud Services(EUCS) in further discussions. We also strongly encourage the idea that to achieve workable regulations, new legislation should be accompanied by implementation guidance. We look forward to additional information on the need to abolish access regulations, as the liberalised telecommunications market has brought affordable, reliable and innovative telecommunications services. We prefer to tackle possible market failures when rolling out fibre and 5G. We note that the white paper does not include much reference to, or analysis of, the needs and market trends of the B2B market. The analysis of this market is partial, and the dynamics of the B2B market ill-described. We appreciate that the COM attempted to put forward several possible future scenarios for the digital infrastructure needs. We feel nevertheless that next to Network as a Service (NaaS), the slowly starting edge computing ecosystem will have also a profound influence. The combination of 5G/fibre networks, AI and cloud will change the game.
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Response to Report on the application of the General Data Protection Regulation

8 Feb 2024

Consultation European Commission - Report on the General Data Protection Regulation 1 Reporting obligations are burdensome 2 Application of the GDPR in non-EU States 3 Unbalanced responsibility of the data holder 4 Unclear provisions leading to interpretation 5 Application of the GDPR and the different legislatives texts About Beltug With over 2300 members from 500+ organisations, Beltug is the largest Belgian association of CIOs & Digital Technology leaders. We cover their priorities such as vendor and software asset management, 5G, hybrid IT, cyber security, artificial intelligence, the hybrid workplace, IoT, privacy, data governance, and many more. We defend the interests of our members, develop positions, and support knowledge exchanges between our members. Each year, we organise more than 50 events for sharing experiences. Beltug also represents the business ICT users at the European and international levels, in close cooperation with organisations in other countries. Within Beltug there is an active Privacy Council gathering privacy experts from different sectors.
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Meeting with Alin Mituța (Member of the European Parliament, Shadow rapporteur) and Banco Santander, S.A. and

20 Sept 2022 · Data Act

Response to Cyber Resilience Act

25 May 2022

Beltug, the Belgian association of CIOs and digital technology leaders represents business users of digital technologies in Belgium. We have 500 members from all secotors of the economy, including government agencies, universities, hospitals as well as companies from all sectors of the economie. As representatives of business users, we firmly support the need for mandatory horizontal cybersecurity requirements for all digital products and services as is envisioned by the Cyber Resilience Act (CRA). We fully support the goals that the CRA envisages and we gladly support the Commission in shaping the text of the CRA. Specifically, we urge the following points to be taken into account: 1. The CRA should regulate the cybersecurity of digital technologies throughout their life cycle, from design to integration, administration, operation and configuration in a mandatory, EU wide, approach. 2. The CRA should cover digital technologies in products, services and processes, irrespective of use by individual consumers or business users, and during the whole economic life cycle from a user perspective. Vulnerabilities in the current software are increasingly impacting business users, leading to high direct costs and indirect opportunity costs as the security specialist’s skills are turned towards addressing the vulnerabilities. It is important that the cybersecurity risks of non-embedded software products are clearly addressed. 3. The CRA must be complementary to regulations in specific sectors 4. Compliance with CRA should be monitored and enforced in such a way that the uniform and effective application of cybersecurity requirements is ensured at EU level . 5. Enforcement of CRA should be gradual, starting with providers of critical components in enterprise-level information systems and large digital solution providers. Business users of digital technology welcome the opportunity to provide input on the process to come to a Cyber Resilience Act. We consider that essential ingredients for cyber resilience allow for a flourishing European economy and society; ingredients such as clear norms and standards, assurance of compliance by public authorities, fair competition and equitable liability rules.
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Meeting with Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager)

4 Feb 2022 · Data Act

Response to Requirements for Artificial Intelligence

6 Aug 2021

Beltug - VOICE - Cigref - CIO Platform NL - We are the Belgian, Dutch, French and German CIO-associations; the communities of Chief Information Officers (CIO’s) and other senior leaders that are responsible for digital technologies and digital transformations within private or public organisations. We do not represent ICT providers and consultants. Business users of digital technology are a key link in the digital transformation of society and economy: including the use of AI systems. To reap the benefits of Artificial Intelligence in Europe, the position of business users - companies and government organisations - of digital technology must be taken into account. Business users also play an influential role in the development of AI systems that comply with European standards and values through their joint purchasing power in the market for AI systems. Therefore, we are a main stakeholder in the establishment of the AI Act. We have identified five points that we believe require additional attention or should be re-evaluated. Taking into account these aspects would help create an AI-Act that enables business users to effectively contribute to European economy and society by using AI systems. General overview of AI and the proposed AI Act Companies and governments use AI systems to an increasing extent in essential business processes. With that, the impact of AI on the daily life, health, mobility, and safety of EU citizens grows. AI systems enrich and expand the possibilities of the digital domain through their ability to process (large amounts of) data in order to gain insights or execute actions (with or without human intervention). By these means, AI systems can improve business processes for both companies and government organisations and create value for organisations, the economy and society. For example, in healthcare AI systems make diagnoses by comparing images of a patient with a gigantic database of images. Another example, AI systems are used to prevent the failure of factory lines by timely signalling the wear off of parts outside their “regular” patterns. Furthermore, AI technology is and will increasingly be a necessary component in cyber security solutions because of its great strength in for instance pattern recognition. Consequently, we support: 1. The appropriate framework that the AI Act introduces for the safe, responsible, and sustainable use of AI systems in Europe, essential for the full exploitation of AI systems in the years to come. 2. The risk-based approach of the AI Act by establishing classes of AI systems for which the intensity of requirements increase with the risk that an AI system poses to the health and safety of EU citizens and their fundamental rights. The risk-based approach provides clarity and oversight, without creating unnecessary market entry barriers for low-risk applications of AI systems. 3. The application of the AI Act to all AI systems that are placed on the market or have their output in the European Union. We would like to express our serious concerns about five aspects of the proposed AI Act: 1. Scope and risk classifications should keep pace with evolution of AI technologies and market situations 2. The need for guidance for developers of AI and users 3. The fairness of the balance in the responsibilities of providers and users 4. The assurance of compliance and harmonised approach to oversight 5. The scope and application of the sandbox environments to stimulate innovations The aspects mainly concern high-risk AI systems. We elaborate on the five aspects in the file attached to our answer.
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Meeting with Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager)

1 Jul 2020 · To discuss challenges faced by business users of digital technologies