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EuroGeographics

EuroGeographics is an independent international not-for-profit organisation representing Europe’s National Mapping, Cadastral and Land Registration Authorities.

Lobbying Activity

Response to Digital package – digital omnibus

13 Oct 2025

EuroGeographics members have been investing significant money, time and resources to meet the requirements of the Open Data and re-use of PSI Directive, which left them without significant income due to the introduction of the free-of-charge regime for certain categories of datasets. EuroGeographics, as a membership organisation was the lead partner in the Digital Europe-funded project Open Maps for Europe 2 (OME2) which is delivering a new production process, technical specification and prototype for harmonised high-value data from multiple European countries under a single open licence. This project was an opportunity to showcase to policymakers and users the potential and demand for public sector data, with both significantly exceeding initial estimates of user numbers, but also to demonstrate what needs to be improved in the existing frameworks, because our experience is that: - Making trusted public sector data available online does not necessarily make them (re) useable. Useability can only be achieved through additional output at the point of delivery, which requires specialised knowledge and investments. That would be a harmonisation of the data themselves, the access licence harmonised across borders in the correct data format to feed straight into user systems, etc. - There is a need for more consideration for sector-specific specifics, such as in geospatial, taking into account the complexity of data collection and maintenance. - There is a need to acknowledge and support sector umbrella organisations such as EuroGeographics, as it is essential for cross-border communication and coordination beyond the political level, which is vital for seamless data flow and the EU value adding. - Public sector information can contain information protected under the personal data protection rules, which cannot be made open to all. To overcome this, different levels of access to data may be needed, depending on the user type. - By not being able to capture who the users are, we are not able to cater to evolving specific users needs and requirements, which might leave the public sector at the margins of the data market. - The open data concept requires a continuous release of data of at least the same or improved quality and quantity, which incurs a cost for the data provider. Furthermore, datasets must be up-to-date, harmonised, and easily accessible to stakeholders. For EuroGeographics members, the challenge with the Open Data and re-use of the PSI Directive is securing funding to ensure this sustainability. We support this initiative, which targets problems and seeks simplification in the annotated policy areas to reduce compliance costs. It has to be recognised that in practice, each Member State implements the regulation in different ways. In the geospatial domain, in some Member States, even the cadastral parcel number is considered personal data. On the other hand, in some Member States, you can search the national geoportal by address and access full personal details of the owner, including personal identification number, mortgage details, and transaction history. We consider that harmonising the reuse rules under the Data Governance Act and under the Open Data and re-use of PSI Directive in one legal act will increase legal clarity. Having one legal act also minimises the possibility of conflict or contradiction between the two instruments. It contributes to better governance because it assumes one national contact point is accountable. It will also mitigate the risk of uneven implementation in Member States, which is the biggest barrier for cross-border re-use and EU value adding. Still, the anonymisation and other toll costs will remain a challenge. We consider that prioritising legal coherence is the best path towards simplification. The fragmentation prevents the Union and its business and citizens from maximising the benefits from high-value geospatial data collected from official sources.
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Response to European Data Union Strategy

17 Jul 2025

EuroGeographics is an independent international not-for-profit organisation representing Europes National Mapping, Cadastral and Land Registration Authorities. We also provide pan-European data produced using authoritative, reliable, comparable and verifiable geospatial data from official national sources. This includes open data, administrative boundaries, topographic mapping and a digital elevation model. Our production system is unique internationally, and a particularly important example of international collaboration in the geospatial area. Access to high-value, large-scale, harmonised, and edge-matched pan-European datasets is a top request from users, in particular policymakers, and the EU-funded Open Maps for Europe (OME2) project has seen higher-than-expected user numbers for all its datasets. By the end of 2024, an average of 491 new users a month were registering on the Open Maps For Europe portal. Since the launch of OME2, the total number of registered unique users has increased by 250% to over 19,000. We are aware that Union priorities have largely changed due to new geopolitical circumstances, which put security, defence, and resilience at the forefront. This urged policymakers to define the critical infrastructure: an asset, a facility, equipment, a network or a system, which is necessary for the provision of essential services. The pan-European geospatial reference data is the foundation for meeting these objectives, as the mapping of locations is the starting point and must be the first action for any coordinated approach addressing any critical cross-border sectors listed in the Resilience of Critical Entities Directive. We strongly suggest that the forthcoming European Data Union Strategy includes a maintained, sustainably funded pan-European geospatial high-value large-scale dataset as a part of the investment in data infrastructure. We believe that without sustainable investment in European value-adding, the large amount of currently available geospatial open data from official national sources will not be usable (serviceable) for cross-border requirements to meet the Commission's political priorities. They will remain fragmentated and disregarded despite the immense amount of national assets, and will challenge the overall concept of public sector open data in the long term. The fragmentation prevents the Union and its business and citizens from maximising the benefits from high-value geospatial data collected from official sources. The European Data Union Strategy should not only focus on the internal market or the digital economy but should also emphasize the potential of data for societal progress. To create value from the potential of the existing reliable data, the accessibility of data and its responsible use must be addressed in the European Data Union Strategy. Regarding legal simplification as another pillar of the Data Union Strategy, we consider that prioritising legal coherence is the best path towards simplification. The fragmentation prevents the Union and its business and citizens from maximising the benefits from high-value geospatial data collected from official sources. The European Data Union Strategy should also explicitly address the role that public service providers play as data-supplying and data-demanding parties in the European data spaces. Public service providers have a different legislative framework regarding data and the provision of data, as well as the various roles that may apply to an organisation from different laws, such as data user, data controller, and data owner. The importance of the role of public service providers in data space initiatives and other data ecosystems should be sufficiently reflected in the European Data Union Strategy, with a good balance between the importance of societal benefits and strengthening the internal market for data.
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Meeting with Gabriela Tschirkova (Cabinet of Commissioner Valdis Dombrovskis)

27 Jan 2025 · European data space

Response to Interim Evaluation of Digital Europe

12 Sept 2024

EuroGeographics is the not-for-profit membership association for the European National Mapping, Cadastral and Land Registry Authorities (NMCAs). As the lead partner in the Digital Europe-funded project Open Maps for Europe 2 (OME2), EuroGeographics offers an evidence-based perspective based on practical experience. This financial support has enabled us to build upon the successful Open Maps for Europe project, which was co-financed by the Connecting Europe Facility. Open Maps for Europe enabled EuroGeographics to provide easy access to free-to-use harmonised data from more than 40 European countries, realising the benefits of the Open Data and re-use of Public Sector Information (PSI) Directive by driving innovation, market development and growth to support the digital economy. Thanks to funding from the Digital Europe programme, we are able to continue and enhance this work in OME2. OME2 addresses the challenge of finding, easily accessing and licensing authoritative pan-European harmonised edge-matched, large-scale, high-value geospatial data. The project is creating a new production process and technical specification for free-to-use- high-value data from multiple European countries under a single open licence. It will release a prototype for harmonised, edge-matched large-scale pan-European datasets covering 10 countries and also enhance the five existing Open Maps for Europe datasets. OME2 is aligned with, and directly supports, the implementation of the European Strategy for Data, which includes various European directives such as the Open Data and re-use of PSI Directive, the opening of the high-value datasets, and the evolution of the INSPIRE Directive towards the GreenData4All initiative. EuroGeographics recognises that organisations have a responsibility to be sustainable following project funding. However, the open data concept is a continuous release of data of at least the same or improved quality and quantity. Furthermore, datasets must be up-to-date, harmonised and easily accessible to stakeholders. The challenge in relation to the Open data and re-use of the PSI Directive is securing funding to remain sustainable. Programmes supporting digital transition, such as Digital Europe, should provide the solution. EU value-adding is not a priority for our members whose remits are to provide national data. Achieving pan-European datasets is therefore not feasible without EU-level financial intervention. We consider that the evaluation of the effectiveness of the Digital Europe funding programme cannot be completed without full information on the practical implementation of the Open data and re-use of the PSI Directive in member states. If the European Commission would like further innovations within the data areas, there must be appropriate funding mechanisms that are directly linked to the policy areas of the European Union. It is disappointing that the future strategic funding is linked to different policy areas; there is no mention of open data or the provision of data for the Data Spaces. As a result, it is difficult for EuroGeographics and its members to link any future activity to the Digital Europe programme. This will stifle innovation, in particular the development of large-scale, high-value pan-European harmonised edge-matched open data from the European NMCAs, which OME2 feedback indicates is a stakeholder requirement. We ask that particular importance is placed on Digital Europes response to stakeholder needs, as well as how it is adapting to the data requirements of business, citizens, and public administrations. EuroGeographics urges particular emphasis on the pan-European data requirements of these groups, which is beyond the national remit of NMCAs EuroGeographics recognises that the development of the Data Spaces is an important activity, however the provision of official data to feed these is as important as the infrastructure that they will be built upon.
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Response to GreenData4All - Revision of EU legislation on geospatial environmental data and access to environmental information

20 Mar 2024

EuroGeographics welcomes this initiative and its overall aim for updating and modernising existing rules on establishing an Infrastructure for Spatial Information in the European Community. Revision of the INSPIRE Directive represents an important milestone for EuroGeographics members. It is an opportunity for an appropriate solution to better govern geospatial data and geospatial knowledge infrastructure, which supports not only Green Deal priority actions on climate change, circular economy, zero pollution, biodiversity, and deforestation, but every single data space annotated in the European Strategy for Data. We support any action towards simplification and modernisation of the technical provisions for data harmonisation, network services, etc. provided that previous investments are respected and solutions are identified to finance new ones, such as APIs. Currently, there is no dependable policy framework (home) for geospatial within the Union. The management of the geospatial sector is fragmented and scattered across various directives including INSPIRE, Open Data and PSI re-use Directive, Implementing Act on HVD, and some other sectorial vertical rules. This occasion of broad public consultations and discussion to make geospatial data functional for the future Green Deal and all other data spaces could be an opportunity to set a pathway towards changing such backgrounds. One of the solutions considered in this Call is refocusing the scope of the INSPIRE Directive on environmental data while leaving non-environmental data (cadastral parcels and agricultural parcels, buildings, road networks, etc.) out of scope to be covered by other sectoral tools. We can understand that data describing the state of the environment and pressures upon it were inadequate in the INSPIRE Directive and this has to be amended. However, geospatial and location information are critical components for environmental monitoring and reporting providing an accurate continuous observation of the territory, which is necessary to deploy the Green Deal actions. By conforming with the INSPIRE Directive, Europes NMCAs have rendered their data discoverable, accessible and interoperable. While INSPIRE is rigid, it provides a clear framework within which to manage geospatial information. The proposal of removing the non-environmental data (cadastral parcels and agricultural parcels, buildings, road networks, etc.) out of the scope of the updated rules to be covered by other sectoral tools without defining which these are, risks having little or no governance in the geospatial sector. We believe that the other sectoral tools should be defined, this cannot be left only to the Implementing Act on HVD which touches only a small segment of the geospatial sector. Suggestions can include for example new Geospatial Regulation; Geospatial Strategy for data spaces; or Guidelines on Geospatial Data for GreenData4All. In any case, we believe a separate chapter of the GreenData4All initiative should refer to the geospatial data component and its role in the Green Deal data space. The absence of a nominated role for NMCAs in many formal procedures means there are shortcomings in existing geospatial data governance, currently fragmented across different policy areas. NMCAs experts are not represented in all relevant committees and expert groups. A coordination mechanism, or integration with the governance structure established under horizontal data legislation, would be a solution with a guarantee for the inclusion of National Mapping, Cadastral and Land Registration Authorities representatives. We are aware that this initiative is an important component of the future Green Deal dataspace based on the European Strategy for Data. Our members' strategic goal is to make their data available for all data spaces. However, we consider the Green Deal Data space a priority since it is understood as a continuation of 15 years of investment in the implementation.
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Meeting with Cristian-Silviu Buşoi (Member of the European Parliament)

18 Oct 2023 · speaker at conference Enchancing the Implementation of the SDGs with Authorative Geospatial Data

Response to Implementing act on a list of High-Value Datasets

20 Jun 2022

EuroGeographics is an independent, international, not-for-profit organisation representing Europe’s National Mapping, Cadastral and Land Registration Authorities (NMCAs). Our strength lies in our extensive membership. We believe in a modern, digital and green society empowered by the use of trusted geospatial and other data from these official national sources, many of which are defined as high-value datasets. EuroGeographics has first-hand experience in supporting the implementation by its members of the Open Data and Public Sector Information Directive. The recently developed “Open Maps for Europe” project connects the user with official national geospatial data sources and provides easy access to free-to-use harmonised maps for Europe from more than 40 countries. To date, 75% of EuroGeographics data providers (members) have agreed to make their datasets open under the harmonised conditions and so deliver the benefits of the Open Data and Public Sector Information Directive. This project is an operational example of how EuroGeographics members are implementing the Regulation based on this Directive. At the same time, the project mitigates the risk of fragmented implementation, which was specifically recognised as a key obstacle to the functioning of the single market for data. EuroGeographics welcomes the proposal wherein data produced and disseminated by NMCAs are recognised as a significant enabler of national and cross-border data applications and services, not only in the geospatial thematic category, but also in earth observation, environment, and mobility. NMCAs’ data are also largely embodied in all other data categories in the HVD list while understanding their roles. EuroGeographics members acknowledge that the value of data lies in its use and re-use, therefore they are keen to effectively implement this Regulation and increase the availability of their data in the single market. Some of our members already have listed datasets as open data, some of which are already available via APIs, some using FAIR principles; some are available at their national portal, through national SDI or INSPIRE services. Our members’ informed opinion is that meeting the Regulation requirements is a substantial challenge, as the Regulation is not “just about” opening the data. In fact, success is not possible without technical, financial and/or organisational support. Our members wish to underline that the goal could be achieved only as a joint vision and action of policymakers, data holders (NMCAs), and data users (so-called “heavy users”). Our members' data serve as a basis for countless policies at national and European levels. We want to make sure that we can continue to serve, in the long term, data policies for the European greater good. Using the occasion of this public consultation, we wish to reiterate our members' key concerns, which are valid for the provision of HVDs and are also applicable more generally when it comes to the need to establish a long-term strategy for the provision of (geo)data. In essence, three levels of concern can be identified: technical, financial, and organisational, as described in the uploaded document.
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Response to Revision of the Intelligent Transport Systems Directive

17 Mar 2022

EuroGeographics is an independent international not-for-profit organisation representing Europe’s National Mapping, Cadastral and Land Registration Authorities. By simplifying access to their data, our members are driving applications to realise a wide range of social, economic and environmental benefits all incorporating the transport component. EuroGeographics’ pan European products, EuroRegionalMap and EuroBoundaryMap, have been used as a backbone data contributing to the EU transport policy developments and implementation. EuroGeographics welcomes the proposal and its overall aim for updating and modernising of existing rules from 2010 in the area of Intelligent Transport Systems (ITS) in the field of road transport and for interfaces with other modes of transport. The proposal offers appropriate solutions for identified problems that should be addressed such as actions required to improve coordination in accessibility of data and the need to improve the availability of data in a digital machine-readable format. Adding the availability of data to the scope and subject matter of the Directive is of high importance to our members, producers, and holders of the road or other modes of transport network datasets used as a basis for ITS development. That affirms the importance of data, and feature their key role in providing intelligent services for citizens, particularly open data from public sector bodies. Addressing the availability, we highlight that EuroGeographics provide pan-European data produced using authoritative data from official national sources. This includes administrative boundaries, topographic mapping and a digital elevation model in machine-readable format fully aligned with Open data and PSI Directive, data protection and privacy requirements. This interface known as “Open Maps for Europe” is a new online service that provides free to use maps from more than forty European countries. Our production system is unique internationally, and a particularly important example of international collaboration in the geospatial area. In addition, some of our members are developing smart mapping or modern mapping platforms fit for the future, and some has developed their own autonomous car and started to research autonomous big data as a possible way to provide road environment data for mapping in the future. We are very proud that our member is National Access Point (NAP) for Belgium making the(geo)information needed for innovative travel information apps accessible in one place. The purpose of NAPs, as introduced in the regulation, is to create a catalogue for open data covering all modalities from all transport actors including transport networks as a basis for creating multimodal travel information services. We are also comfortable with the simple definitions of terms “availability of data” and “accessibility of data” provided in this proposal. We may say that we meet the requirements, as certain categories of data types exist in machine readable format and could be easily obtained for the purpose of sharing at the respective portal. Our datasets are harmonised and only one single licence is needed for the wide geographical coverage. Data sharing is the core of our existence, and the recent flag use sample is a single agreement between EEA and EuroGeographics for the provision of members’ data to the Copernicus service. We are aware that this proposal is an important component of the future common European mobility data space based on European strategy for data we want to be coherent with. It is also supportive to the research and innovation policies in climate, energy and mobility under the Horizon Europe programme. Both are important frameworks for our members too. We shall use this opportunity within ITS scope to facilitate the availability of our members' data to the widest extent feasible to deliver effective and seamless multimodal transport.
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Response to European Digital Identity (EUid)

1 Sept 2021

EuroGeographics is an independent international not-for-profit organisation representing Europe’s National Mapping, Cadastral and Land Registration Authorities (NMCAs). We are a passionate advocate for European geospatial data from official trusted sources, in particular when it is harmonised to standard specifications. Our members are providers of a range of products and services and expertise which supports navigation, automated vehicles management, emergency response, a when it comes to this specific consultation, of reliable and secure land and property market, fiscal and many more government and business decisions and services. As producers and providers of trusted data from the official trusted source our members are very much dependent on an adequate level of security of electronic identification means and trust services. Therefore, we have a special interest to the development of the eIDAS Regulation. Many of our members have embraced new technologies as they were developed and set a goal of full digitalisation of their entire work processes including registering transactions of real property within the European single market. This is a highly sensitive public sector area with a very substantial value at stake. The main concern of our members was on securing cross-border electronic signatures, seals, time stamps, or electronic documents recognised within EU. Some of our members have developed a good system to protect personal data, allowing access to all non-personal data for everybody and ensures that only the “right” person can access it. In parallel, barriers in cross-border transactions are still being experienced as the existing Regulation does not contain any obligation for Member States to provide their citizens with a digital identification system enabling secure access to public services or to ensure their use across EU borders. Having property in one country and fully making use of owners’ rights remotely from another country of residence is a more and more frequent European way of life for many citizens. Transactions of real estate property at the European single market are in full flow. It is currently very complex, if not impossible, for a citizen from a country A (who benefits from an e-identification in that country A) to conclude a real estate transaction with e-identification in country B (where another e-identification system is in place) and we believe that European Digital Identity Wallet as introduced in this proposal will further enhance and secure it. Many other examples could illustrate the ongoing difficulties. As a result, we welcome the principle of users having full control over what data they chose to share to identify themselves with online services and to keep track of such sharing. Giving full control to users to choose which aspects of their identity, data and certificates they share with third parties, and keep track of such sharing matches with principles already adopted and implemented within our membership. We fully support this initiative of building on the existing eIDAS Regulation in order to remove discrepancies between countries in implementing cross-border identification systems. It will make both citizens’ and providers of public sector services reality easier. We express our interest in the further development of this legal debate.
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Response to Requirements for Artificial Intelligence

13 Jul 2021

EuroGeographics is an independent international not-for-profit organisation representing Europe’s National Mapping, Cadastral and Land Registration Authorities (NMCAs). We are a passionate advocate for European geospatial data from official trusted sources, in particular when it is harmonised to standard specifications. We are providers of a range of products and services and expertise which supports navigation, automated vehicles management, emergency response, a reliable and secure land and property market, fiscal and many more government and business decisions and services. NMCAs developments of AI systems is still very much at proof-of-concept stage. However, our sector has proved its ability to embrace new technologies and we reckon that what is new now will certainly go mainstream soon. At this stage, EuroGeograpphics members are both, AI users and providers of data that are very widely feeding AI services and business. AI is used for processing geospatial information, in particular for increasing the efficiency of their quality assurance and management – the calling card of NMCA data. For example, some of our members have been combining high-resolution elevation analysis with deep learning techniques, to provide policy-makers with vital information for the transition to solar energy, exploring how to use AI for a wide range of activities including land cover mapping and the creation of 3D data is high on the agenda. Furthermore, our members have fully embraced the European strategy for data, and they already contribute substantially to make it a success story. The crucial contribution is primarily by implementing the Open data and PSI directive, which will establish trusted mechanisms and services for the re-use, sharing and pooling of data that are essential for the development of data-driven AI models of high quality. The Regulation proposal confirms that some areas of AI deployment will fall under existing legislation and will be fully coherent with the Commission’s overall digital strategy. This is a strong stir for our members, since the stable governance principles and data protection established thereof, encourages our members to create and test high–risk AI systems, for example in the transport field. This possibility will provide many opportunities for NMCAs to contribute to the digital single market. The development of programmes, research, projects, or support, that will allow the growing of the diffusion of AI within our member organizations, will be highly welcomed. We are aware that this Regulation applies to providers placing on the market or putting into service AI systems and we are not there yet. Nevertheless, our members' authoritative data, high quality datasets, are back bones to many of the critical infrastructures as defined in the proposed Regulation. In recent years, we have seen an explosion in location-based AI systems. Some of our members are already in the testing phase of geospatial data-based AI applications, and this regulatory framework is the supportive direction for that, which is considered a good start. The Regulation proposal has positively raised awareness of AI and is intended to balance very sensitive issues such as fundamental rights, public safety, and innovation. It is highly desirable to have definitions in a flexible manner, not to hamper innovations. Legal certainty, risk assessment levels, regulated use, and concept of trust by increasing the trust for EU made AI products are the main benefits of the proposal from Eurogeographics members’ point of view.
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Response to Data Act (including the review of the Directive 96/9/EC on the legal protection of databases)

24 Jun 2021

EuroGeographics is an independent international not-for-profit organisation representing Europe’s National Mapping, Cadastral and Land Registration Authorities, responsible for a large set of public sector datasets including high value geospatial datasets that are defined in the Open data and PSI directive. Making authoritative data as accessible as possible for further use by business and governments is at the core of our members’ public task. Since the early days of the COVID -19 pandemic, governments and researchers have been making use of highly visual geospatial tools and applications to record and report the virus’ spread – from local to global levels. Our members’ have been greatly involved, and the use of privately-held data was indispensable to support them in the development of different applications for the public interest varying from a geospatial recording and monitoring system for COVID-19 cases, establishing publicly available Health Surveillance Monitor Dashboard for the Department of Health, or creating Corona Spatial Risk Analysis maps. Proven experience had further raised our awareness of the importance of business to government data sharing to make use of its full potential. We fully support this initiative to provide rules governing reliable data sharing functions and transparent production of information from privately held data. This opens many possibilities to many of our members, especially those dedicated to research and innovation programmes. However, our view is that the application of the Database directive does not pose an obstacle to the access and use of machine generated data. It might need slight modernisation or additional clarification on its relation to Open data and PSI Directive, but it has provided welcome certainty for EuroGeographics members and their users about the rights associated with geospatial information held in databases. It achieves a good balance between the rights and interests of the rightsholders and users. The geospatial data industry has moved rapidly from paper maps to the use of geospatial data in database form to support an increasing variety of software applications, striving towards artificial intelligence and machine learning nowadays. While in some cases maps themselves may be considered within the scope of copyright protection as artistic works, digitisation and advances in technology have increased the use of standardised database structures and interoperability tools to such an extent that the scope to demonstrate creativity is markedly reduced. Geospatial databases thus exemplify the need for protection under the sui generis right, which alone protects the investment in acquiring, managing and presenting data to meet users’ needs. The question has arisen as to whether the detailed content of a published map qualifies for protection under the sui generis right. The CJEU judgment in Case C-490/14 (Verlag Esterbauer) affirmed that it does. The protection offered by the Database Directive remains fit for purpose and relevant for the machine readable data. Application of the sui generis right is appropriate when it comes to databases produced by public sector bodies or financed with public funds. Sui generis protection is also important to all governmental bodies who are using CC4.0 BY licenses. They need to inform open data users what is the source of open data since originality/authority is a significant requirement in building trust in the single market for data. In conclusion, EuroGeographics’ opinion is that public sector bodies should not be excluded from the scope of the sui generis right of the Database Directive.
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Response to Europe’s digital decade: 2030 digital targets

8 Mar 2021

EuroGeographics is the independent international not-for-profit organisation representing Europe’s National Mapping, Cadastral and Land Registration Authorities (NMCAs). Our members provide a vast range of geospatial services, expertise, research supporting navigation, emergency response, reliable and secure land and property market and many more government and business decisions and services as long as they are formally located somewhere or have a localisable impact. Authoritative public sector data, in our case geospatial data, is a key building block for digital transformation, a block which supports applied research and innovation and the range of legal, fiscal, security and other public administrative purposes. Authoritative geospatial data plays an important role in helping to achieve the commitment of the 2030 Agenda. It addresses the key global and regional issues that affect society and the planet, such as poverty, climate change, sustainable development, a digital economy, migration, security, health and many others. By providing online public services including cross-border public services, the NMCAs of Europe are an integral part of the eGovernment which involves deploying and using technology. As such, EuroGeographics welcomes the Commission’s effort to create the clear vision for the Europe’s Digital Decade: 2030 digital targets. It is very much appreciated that this vision will complement and build on existing policies, budget programmes and strategies which NMCAs have already embraced and invested in. Coherence is indispensable for the success story of the digital transition. Eurogeographics members are fully aware of the constant and dramatic growth of data volumes, and that these data tend to move to the clouds and to be shared through data spaces. As such NMCAs welcome overall European Strategy for Data and the transparent governance tools proposed in the Data Governance Act. These initiatives will represent an important milestone aiming to underpin reaching the goals of the Digital Decade. European NMCAs fully support a digital transition anchored in fundamental rights and common EU values. Our members pay particular attention for the respect of data privacy (GDPR), Intellectual Property Rights (IPR), legal protection of databases and other rights. Trust is essential in providing online services for citizens and supporting public administration. Being producers and users of data, the NMCAs are welcoming the idea of opening some privately held data for public interest, i.e., business to government data sharing as it will boost service developments, especially in the AI domain. EuroGeographics is built on international cooperation. We are eager to share the lessons and experience acquired while engaging in multi -country projects. We would appreciate any programme to support this effort aiming to mitigate the fragmentations as a key obstacle towards digital decade. From our viewpoint, a successful digital transformation would result in a society empowered by the use of trusted public sector data and services. Knowing that reliable sources of geospatial data exist, and where to obtain them, is essential for governments and decision-makers making critical decisions that affect all our lives. Digital infrastructures and capacity, digital education and skills, digital government are fundamental requirements of modern state and economy and are subject to our highest attention for keeping pace with digital transitions. Demand for trusted authoritative geospatial information from official national sources will continue to grow into the next decade, with quality, value, reliability and ease of re-use remaining key requirements for users. We look forward to being able to make a significant contribution to the success of Europe’s Digital Decade and the 2030 digital targets, and will welcome being part of the conversation on how best we might do this.
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Response to Legislative framework for the governance of common European data spaces

28 Jan 2021

EuroGeographics is an independent international not-for-profit organisation representing Europe’s National Mapping, Cadastral and Land Registration Authorities. Our members are responsible for a large set of public sector datasets including high value geospatial datasets that are defined in the Open data and PSI directive and that play an important part of the overall European Strategy for data. Making available authoritative data for use and re-use by others across all data spaces is at the core of our members’ public task. EuroGeographics fully supports the European strategy for data and therefore we are openly receptive to the recently published proposal for a “Data Governance Act”. We see many opportunities for our Members in the proposal but also some areas may prove difficult for some of our members. Such difficulties may arise in areas around third party IPR, personal data and increased costs. Notwithstanding these reservations EuroGeographics will of course work in an open positive manner with the EU institutions towards a workable governance regime. We are aware that Data Governance Act complements the Open data and PSI directive by addressing data that cannot be made available as open data. EuroGeographics members hold significant range of such data. Hence, we very much appreciate this effort as well as the main principle of the digital age policy framework: “Share if you want”. Lawful processing and trustworthiness are a must in our task. Cadastral parcels, addresses, house numbers, buildings, owners of the properties, titles, etc. have always been of interest not only for the internal market players, but overall society and individuals. However, very often, they are considered as personal data which cannot be open for re-use under the provisions of Open data and PSI directive. More specifically, attributes of these categories of data that directly concern personal information cannot be open for re-use. GDPR Regulation allowed Member States to maintain or introduce more specific provisions to adapt its application with regard to processing of personal data held by a public sector body. As a result, in some countries even the parcel numbers or coordinates are considered as personal data as they could be related to individuals by only crossing this type of data with another one. On the other hand, in some countries, all above mentioned data are easily accessible via click online cadastral map connecting it to ownership details including the mortgage and other personal data of the owner. Some NMCAs are creating topographic maps in public – private partnership and have concern on third party intellectual property rights protection including the legal protection of database. The introduction of use and re-use philosophy, and the will to open data should take into account the difficulties thereof. NMCAs are more and more frequently moving from such models, but the difficulties remain. It is important that they remain fully respected. The same applies to the data restricted on the commercial or statistical confidentiality ground. Our members have a keen interest to contribute in the expert group i.e., ‘European Data Innovation Board’ and would highly welcome observer status of EuroGeographics to support the representation of NMCAs with its expertise and long-term experience in cross border data sharing. Single information and data-sharing point at member state level is also of interest to some of our Members, where our Members have the potential, and in some cases the experience and expertise, to take a leading role. Finally, our attention goes to costs incurred to implement novelties introduced by the Act. We do believe that they will be foreseen in the new cycle funding programme supporting Member States to create single market for data, data spaces, the (re-)use of authoritative data for as much purposes as possible genuinely being in the public interest.
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Response to Setting up an Infrastructure for Spatial Information (INSPIRE) - Evaluation of the Directive

15 Oct 2020

Better regulation – Have your say portal – INSPIRE inception roadmap Submitted by Mick Cory Organisation EuroGeographics TR Number 51080067776-74 EuroGeographics is the Association of members that are the National Mapping, Cadastre and Land Registry Authorities in Europe. They provide a range of geospatial information which supports the environment and many more policy areas for government and business. Most of them have, through their national transposition or international framework programmes, expended significant resources in the implementation of the INSPIRE Directive over the last twenty years. Many also consider INSPIRE as being based on a great vision, one that is important but also complex to implement. Along with our role of assisting our members in implementing INSPIRE, the Association has been involved in a range of projects, supported by funding from the European Union, aimed at developing access to European geospatial data and services from authoritative providers, many of which are based on INSPIRE specifications. We have shared our experiences and the lessons learned widely*, and we would welcome the opportunity to continue to do so during this initiative, as set out in this roadmap, and on any other appropriate occasion. There remain a number of obstacles preventing the creation of pan European datasets and services that support a European digital data economy. We believe INSPIRE has gone a long way to address these, but more remains to be done. Fragmentation remains a challenge to full interoperability from different national approaches resulting in no representative pan-European use case to demonstrate the value of the Directive. This can be addressed by more dialogue and coordination with stakeholders. This roadmap represents an important milestone for Eurogeographics’ members. Our strategy is aligned to the newest EU political priorities particularly to Green Deal and Digital Age packages. That is why we will need to have a shared understanding of where INSPIRE fits in these policies and globally, including future trends. Accessible and interoperable authoritative data** are at the heart of data-driven society. Reliable, comparable and verifiable information recognised as authoritative data plays an important part of the single market for data, and should be at the heart of European data spaces. Geospatial public sector data were identified as being an enabler in every single data space and used cross-sector. We believe that as the digital data spaces are agreed and developed, a renewed and refreshed INSPIRE directive should be fit for purpose, aligned with this current data policy and governance mechanisms, which enable our members to contribute in providing and sharing their authoritative geospatial data for all authoritative public purposes including meeting environmental needs. * For our experiences and the lessons learned see, for example, presentations made at the Helsinki INSPIRE workshop https://tinyurl.com/yxrkdoyj ** About authoritative data See joint report by EuroSDR and EuroGeographics here: https://eurogeographics.org/news/new-report-identifies-key-components-of-authoritative-geospatial-data/ which defines Authoritative data as “…. data that is provided by or on behalf of a public body (or authority) which has an official mandate to provide and sustain it, that is based on a set of criteria to ensure known quality, and that is required to be used and reused by the public sector and society as a whole”. The provision of authoritative data is part of our members’ public task.
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