Lobbying by IBM Corporation

IBM Corporation

IBM

IBM is a global technology company providing artificial intelligence and cloud solutions, with over 100 years of investment in Europe.

Focus Areas

2024-2025

2020-2023

2015-2019

Links

Website Transparency Register Profile

ID: 7721359944-96

Lobbying Activity

Meeting with Piotr Müller (Member of the European Parliament, Shadow rapporteur) and Google and

29 Jan 2026 · Simplification of the implementation of harmonised rules on artificial intelligence (Digital Omnibus on AI)

IBM urges EU to avoid "inward-looking" quantum restrictions

15 Dec 2025

Topic — A legislative initiative to accelerate quantum technology research and industrial development across Europe.

Message — IBM recommends avoiding inward-looking EU-only restrictions that risk fragmenting efforts. They urge the Commission to ensure stable, predictable, and harmonized EU rules for export controls.1 2

Why — This would ensure global vendors who invest in Europe are recognized and included.3

Impact — European hardware providers lose protection from global competitors if the EU removes restrictive conditions.4

Read full response

Meeting with Manuel Mateo Goyet (Acting Head of Unit Communications Networks, Content and Technology)

3 Dec 2025 · Exchange of views on upcoming CADA and how it will affect non-European cloud providers

Meeting with Anna Vernet (Cabinet of Executive Vice-President Teresa Ribera Rodríguez), Sean Mernagh (Cabinet of Executive Vice-President Teresa Ribera Rodríguez)

27 Nov 2025 · EU competition policy, Merger Guidelines, Digital Markets Act (DMA), Foreign Subsidies Regulation (FSR).

Meeting with Andi Cristea (Member of the European Parliament) and American Chamber of Commerce to the European Union and

25 Nov 2025 · Recent developments in EU-US trade policy

Meeting with Billy Kelleher (Member of the European Parliament, Delegation chair)

18 Nov 2025 · European Works Council

IBM urges AI grace period to accelerate European energy transition

4 Nov 2025

Topic — A strategic roadmap for leveraging AI and digital technologies within the European energy sector.

Message — IBM requests a 12-month grace period for AI Act compliance once standards are published. They also advocate harmonising data rules and simplifying cybersecurity reporting through a single entry point.1 2

Why — Simplified regulations and delayed requirements would reduce compliance costs and administrative burdens for technology providers.3 4

Impact — Proponents of strict data localization lose as IBM pushes for open markets for non-EU providers.5

Read full response

Meeting with Maroš Šefčovič (Commissioner) and

28 Oct 2025 · Priorities of the EU’s trade agenda

Meeting with Raphaël Glucksmann (Member of the European Parliament, Rapporteur)

15 Oct 2025 · Foreign Investments Screening Regulation

Meeting with Piotr Müller (Member of the European Parliament) and American Chamber of Commerce to the European Union

24 Sept 2025 · EU public procurement reform

IBM urges EU to keep merger rules focused on competition

3 Sept 2025

Topic — The Commission is consulting on updating merger guidelines for digital and green transitions.

Message — IBM urges the Commission to focus merger reviews on competition instead of industrial policy. They advocate for innovation-centric assessments that recognize dynamic market efficiencies in digital sectors. The company also recommends establishing clear thresholds for the review of sub-threshold transactions.1 2 3

Why — This would allow IBM to acquire innovative startups with less regulatory interference.4 5

Impact — National regulators lose the ability to block mergers based on broader public interest grounds.6

Read full response

Meeting with Cornelius Schmaltz (Head of Unit Health Emergency Preparedness and Response Authority)

6 Aug 2025 · WebMethods (IBM tool)

Response to Revision of the Standardisation Regulation

21 Jul 2025

IBM thanks the European Commission for the opportunity of providing feedback to the call for evidence on a revision of regulation 1025/2012. As an active participant in standardisation and open source in Europe and world wide IBM strongly agrees on the importance of the European standardisation system. This includes aiming for improvements, in particular for creating an efficient and attractive environment for standardisation of the IT sector in Europe. Please find IBM's feedback in the document attached.

Read full response

Meeting with Roberto Viola (Director-General Communications Networks, Content and Technology)

14 Jul 2025 · Exchange of views on latest updates on AI, quantum, US-EU trade negotiations and regulatory simplification agenda

IBM urges EU to simplify data rules for AI innovation

11 Jul 2025

Topic — This consultation explores streamlining data rules to create a coherent framework for sharing.

Message — IBM calls for prioritized access to high-quality datasets and synthetic data for AI development. They suggest creating a unified European enforcement authority and repealing the ePrivacy Directive.1 2

Why — This would reduce IBM's legal uncertainty, compliance costs, and heavy administrative burdens.3

Impact — Privacy advocates may lose specific legal protections if the ePrivacy Directive is repealed.4

Read full response

Meeting with Manuel Mateo Goyet (Acting Head of Unit Communications Networks, Content and Technology) and Microsoft Corporation and

26 Jun 2025 · Business Software Alliance and its members consultation on the EU’s upcoming Cloud and AI Development Act.

IBM Urges Standard-Based EU Cybersecurity Certification Rules

20 Jun 2025

Topic — Revision of the EU Cybersecurity Act to improve resilience and certification frameworks.

Message — IBM advocates for a certification framework based on international standards and clear timelines. They request streamlined reporting through single national entry points and liability protections for entities. The company recommends that supply chain security tools focus only on first-level suppliers.1 2 3

Why — These measures would significantly reduce the compliance burden and administrative costs for global businesses.4 5 6

Impact — Proponents of digital sovereignty lose the ability to favor local firms through restrictive requirements.7 8

Read full response

Meeting with Matthias Jorgensen (Acting Director Trade)

5 Jun 2025 · EU-US trade relations

Meeting with Werner Stengg (Cabinet of Executive Vice-President Henna Virkkunen) and Google and

22 May 2025 · GPAI Code of Practice

Meeting with Nicolo Brignoli (Cabinet of Commissioner Valdis Dombrovskis)

20 May 2025 · Simplification

Meeting with Kamil Talbi (Cabinet of Commissioner Dan Jørgensen)

19 May 2025 · Digitalisation, decabornisation

Meeting with Dusan Chrenek (Principal Adviser Climate Action)

19 May 2025 · Chat on AI in a sustainability context

Meeting with Alexandra Geese (Member of the European Parliament) and Deutsche Telekom and

29 Apr 2025 · Event: DACH-Tech

Meeting with Gustav Kalbe (Acting Director Communications Networks, Content and Technology)

1 Apr 2025 · Update on respective quantum activities

Meeting with Anna Banczyk (Head of Unit Employment, Social Affairs and Inclusion)

20 Feb 2025 · Exchange of views on IBM’s activities on digital upskilling and collaboration possibilities with various EU organizations and communities

Meeting with Henna Virkkunen (Executive Vice-President) and

15 Feb 2025 · Private roundtable on transatlantic and global cooperation on tech organised on the margins of the Munich Security Conference

Meeting with Despina Spanou (Principal Adviser Communications Networks, Content and Technology)

14 Feb 2025 · Meeting in the margins of the Munich Cyber Security Conference on EU cybersecurity policies and the role of private sector in EU-level crisis management.

Meeting with Svenja Hahn (Member of the European Parliament) and Microsoft Corporation and

14 Feb 2025 · Exchange on upcoming digital EU legislation

Meeting with Maria Zafra Saura (Cabinet of Commissioner Michael McGrath)

29 Jan 2025 · Artificial Intelligence, data protection, Digital Fairness Act (DFA)

Meeting with Chiara Riondino (Head of Unit Employment, Social Affairs and Inclusion)

28 Jan 2025 · Information exchange on Artificial Intelligence in the workplace

Meeting with Mario Nava (Director-General Employment, Social Affairs and Inclusion) and

22 Jan 2025 · Exchanges on IBM’s skills initiatives and SkillsBuild training platform, as well as ‘Union of Skills’ (UoS).

Meeting with Christiane Kirketerp De Viron (Acting Director Communications Networks, Content and Technology)

17 Jan 2025 · cyber priorities - Hospitals Action Plan

Meeting with Benjamin Boegel (Cabinet of Executive Vice-President Henna Virkkunen)

16 Jan 2025 · Security of open-source; post-quantum cryptography; cooperation with ENISA; NIS2 and CRA implementation

Meeting with Marc Lemaitre (Director-General Research and Innovation)

16 Dec 2024 · Presentation of their research activities in technological areas of mutual interest, such as quantum technologies, semiconductors, cybersecurity, and AI and discussion on participation to projects

Meeting with Ivars Ijabs (Member of the European Parliament, Shadow rapporteur) and Microsoft Corporation and

13 Dec 2024 · European defence industry programme (EDIP)

Meeting with Brigitte Van Den Berg (Member of the European Parliament, Shadow rapporteur)

4 Dec 2024 · social policy: skills, EWC

Meeting with Michael Mcnamara (Member of the European Parliament)

21 Nov 2024 · Introductory meeting and AI Act Implementation

Meeting with Susana Solís Pérez (Member of the European Parliament)

14 Nov 2024 · Data & Digital Regulation

Meeting with Raphaël Glucksmann (Member of the European Parliament, Rapporteur)

8 Nov 2024 · Foreign Investments screening regulation

Meeting with Svenja Hahn (Member of the European Parliament, Rapporteur for opinion)

5 Nov 2024 · Foreign Direct Investment Screening Review

Meeting with Svenja Hahn (Member of the European Parliament) and Google and

23 Oct 2024 · Digital Policy

Response to Rules specifying the obligations laid down in Articles 21(5) and 23(11) of the NIS 2 Directive

25 Jul 2024

We welcome the draft implementing regulation on cybersecurity risk management and reporting obligations for digital infrastructure and ICT service providers. The proposed draft ensures better alignment of NIS2 implementation across the EU and provides a streamlined framework for entities operating across different EU member states. Building on our experience servicing customers both globally and in the EU across the critical sectors, we would like to share some recommendations to clarify and further improve this legislation. Our key focus areas are: 1) Grace period. Industry needs appropriate time to prepare compliance before the new rules start applying. 2) Incident impact. Entities should apply two or more criteria to ensure impact-focused approach to reporting thresholds. 3) Responsibilities in the B2B context. The text should clarify reporting responsibilities between digital service providers and their customers where both are in scope of NIS2 reporting obligations. 4) Risk-based and proportionate approach. The reporting thresholds and risk management requirements should accommodate different types and sizes of entities in scope and therefore different types of risks they are facing. 5) Harmonisation. We ask to streamline the reporting obligations with other EU cyber legislation and to leverage international standards for demonstrating compliance.

Read full response

Meeting with Chris Uregian (Cabinet of Vice-President Margaritis Schinas), Despina Spanou (Cabinet of Vice-President Margaritis Schinas)

14 May 2024 · EU Cybersecurity files

Meeting with Anouk Faber (Cabinet of Commissioner Nicolas Schmit), Christoph Nerlich (Cabinet of Commissioner Nicolas Schmit)

30 Apr 2024 · Skills policies

Meeting with Christos Ellinides (Director-General Translation)

29 Feb 2024 · AI technologies

Meeting with Miriam Lexmann (Member of the European Parliament)

15 Feb 2024 · European Work Council directive

Meeting with Věra Jourová (Vice-President) and

17 Jan 2024 · Digital regulation

Meeting with Mirzha De Manuel (Cabinet of Executive Vice-President Valdis Dombrovskis)

19 Dec 2023 · European Works Council Directive

Meeting with Ana Carla Pereira (Cabinet of Commissioner Nicolas Schmit)

16 Nov 2023 · European Works Councils

Meeting with Maroš Šefčovič (Executive Vice-President) and

15 Nov 2023 · Roundtable for Europe’s Energy Future (REEF)

Meeting with Nicola Danti (Member of the European Parliament, Rapporteur) and Microsoft Corporation and

9 Nov 2023 · Posizione AmCham su CRA

Response to Voluntary cybersecurity certification for ICT products, based on a Common Criteria set of security requirements

31 Oct 2023

IBM welcomes the opportunity to comment on the draft Common Criteria based European candidate cybersecurity certification scheme (EUCC). We support the aims of the EU-level cybersecurity certification, which is to promote the harmonisation and trust in the EU market. We believe that the certification schemes like EUCC can facilitate the EUs broader cybersecurity policies if developed in a transparent and coordinated manner. With these objectives in mind, we urge EU policymakers to strengthen the draft EUCC scheme in five key areas: 1) vulnerability handling and disclosure should follow the EU regulatory framework and international best practices; 2) mutual recognition should apply across all EAL levels; 3) the validity period should be fixed to achieve better harmonisation of the certification framework on the EU level; 4) the requests for information should be proportionate to the goal of demonstrating conformity with the scheme; 5) the implementation of the EUCC scheme should be transparent, evidence-based, and involve industry stakeholders. We provide more detailed recommendations in our paper attached to this submission.

Read full response

Response to Cyber Solidarity Act

20 Jul 2023

IBM welcomes the opportunity to comment on the European Commissions Cyber Solidarity Act. As one of the worlds leading enterprise technology companies and with more than 100 years of business commitment in Europe IBM supports the Cyber Solidarity Acts aims to strengthen capacities in the EU to detect, prepare for, and respond to cybersecurity threats and incidents. We believe open, value-based public-private collaboration can help the EU leverage the best-in-class technologies and expertise to boost the unions cyber capabilities. With these objectives in mind, we recommend that EU policymakers strengthen the proposal in five key areas: 1. Capacity-building through consolidation not isolation. 2. Risk-based and proportionate approach. 3. Global expertise for European market. 4. Continuous feedback loop between governments and private providers. 5. Skilled workforce for ambitious cyber policy. We provide detailed feedback in the attached paper and look forward to engaging in further discussions on the Cyber Solidarity Act proposal.

Read full response

Meeting with Elina Melngaile (Cabinet of Executive Vice-President Valdis Dombrovskis), Zaneta Vegnere (Cabinet of Executive Vice-President Valdis Dombrovskis) and

5 Jun 2023 · Trade & Technology Council, Global Steel and Aluminum Arrangement, Critical Minerals Agreement

Meeting with Josianne Cutajar (Member of the European Parliament, Shadow rapporteur)

27 Apr 2023 · Interoperable Europe Act

Meeting with Deirdre Clune (Member of the European Parliament, Shadow rapporteur) and Google and

14 Mar 2023 · AI Act

Meeting with Anouk Faber (Cabinet of Commissioner Nicolas Schmit), Christoph Nerlich (Cabinet of Commissioner Nicolas Schmit)

6 Feb 2023 · European Year of skills

Meeting with Ana Carla Pereira (Cabinet of Commissioner Nicolas Schmit)

6 Feb 2023 · European Work Councils

Meeting with Nicola Danti (Member of the European Parliament, Rapporteur) and BUSINESSEUROPE and

25 Jan 2023 · Stakeholder consultation on the CRA

Meeting with Johannes Hahn (Commissioner) and

19 Jan 2023 · public sector modernisation and cybersecurity

IBM Urges Risk-Based Cyber Rules for Digital Products

16 Jan 2023

Topic — The Cyber Resilience Act establishes mandatory cybersecurity requirements for products containing digital elements.

Message — IBM recommends a risk-based approach to remediating vulnerabilities rather than an impossible bar. They also request the exclusion of services from the scope, such as SaaS.1 2

Why — Excluding cloud services would prevent unnecessary complexity that might deter businesses from using software.3

Impact — Public authorities lose access to complete information on the design and development of products.4

Read full response

Meeting with Stephen Quest (Director-General Joint Research Centre)

29 Nov 2022 · Exchange of views on technology and innovation

Meeting with Danuta Maria Hübner (Member of the European Parliament)

28 Nov 2022 · EU-US trade relations, Trade and Technology Council

Meeting with Geneviève Tuts (Cabinet of Commissioner Didier Reynders), Lucrezia Busa (Cabinet of Commissioner Didier Reynders)

15 Nov 2022 · data protection

Meeting with Maximilian Strotmann (Cabinet of Commissioner Johannes Hahn)

8 Nov 2022 · Technology developments, data and interoperability

Meeting with Christian Ehler (Member of the European Parliament)

25 Oct 2022 · Chips Act

Meeting with Deirdre Clune (Member of the European Parliament, Shadow rapporteur)

12 Oct 2022 · Artificial Intelligence Act

Meeting with Thierry Breton (Commissioner) and Google and

6 Sept 2022 · meeting with the Green Digital Coalition - Main topic : state of play on sustainable digitalization

Meeting with Dennis Radtke (Member of the European Parliament, Rapporteur)

31 Aug 2022 · European Works Councils Directive

Meeting with Antoine Kasel (Cabinet of Commissioner Nicolas Schmit)

30 Aug 2022 · Digital skills - AI and employment - platform work - EC plans for rest of mandate.

Meeting with Paul Tang (Member of the European Parliament) and Nokia and

21 Jul 2022 · European Internet Forum MEP visit to New York

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

21 Jun 2022

IBM welcomes the European Commission’s proposal for an Implementing Act on a list of High-Value Datasets. It will contribute to the effective implementation of the Open Data Directive, through making high-value public datasets available in a machine-readable format via APIs. Please read our full contribution in the attached file.

Read full response

Response to Cyber Resilience Act

25 May 2022

IBM welcomes the opportunity to contribute to the European Commission’s consultation on the Cyber Resilience Act (CRA) and to offer our views on how we believe the EU can build a strong cybersecurity environment and increase its resilience against a continuously evolving and more complex cyber threat landscape. IBM welcomes the Commission’s plans to consider horizontal rules introducing cybersecurity requirements for connected products and ancillary associated services. We believe that improving products and software development practices and transparency will allow businesses and consumers to benefit from more secure and trusted systems. In this regard, we respectfully submit the following views (more details in the document attached) on how we believe the CRA could best achieve these objectives: - Understanding that cybersecurity is an ongoing process and should not be seen as an end state: today's increasingly complex cybercrime ecosystem and threat landscape require the CRA’s regulatory framework to remain flexible enough and focused on risk-based security practices to allow businesses to evolve products quickly to address ever-changing cyberattacks. - Providing clarity in scope and definitions, taking into account differences in the development, functionality and use of these digital products, and applying proportionate rules following a risk-based approach (leveraging the NLF mechanism as a basis for this approach). - Ensuring consistency with existing and upcoming legislation as the current EU regulatory framework already covers many digital products, in order to avoid overlaps and conflicts: the CRA should provide baseline cybersecurity requirements for connected products, while avoiding the introduction of mandatory cybersecurity certification schemes replacing existing harmonised standards. - Focusing on reducing fragmentation by introducing horizontal, risk-based rules, enabling self-assessment as the default conformity assessment procedure (with the possibility to have third party assessments for certain categories of high risk products). - Aligning European standards with international standards and ensuring continuous engagement of industry in strategic committees for the development of standards. - Differentiating B2C and B2B products, particularly for software, considering the context in which a piece of software is developed, integrated and utilised, when defining cybersecurity requirements. Products designed for B2C and B2B markets have different lifecycles, potential risks and intended purposes: in a B2B environment, products are integrated into highly complex systems, and the supplier typically has little control over what their business clients do with the software and might be limited to intervene by contractual agreements. We share the EU’s objective to protect citizens and businesses from cyber incidents and cyberattacks in an increasingly interconnected world. The CRA provides an opportunity for the EU to achieve this goal by adopting clear, harmonised rules following a risk-based approach, aligned with internationally recognised standards and which avoids overly prescriptive requirements and inconsistencies with other EU legislation. We look forward to contributing to the debate in the months ahead.

Read full response

Meeting with Catharina Rinzema (Member of the European Parliament)

18 May 2022 · Trade & Consumer Policy

IBM advocates for open standards and balanced cloud switching rules

13 May 2022

Topic — Regulation facilitating data access and fairness across the European data economy.

Message — IBM wants rules for sharing business data to match personal data rules. Providers should share responsibility for moving data instead of just the original host. Global technical standards should be used to make moving between clouds easier.1 2 3

Why — Reducing switching barriers benefits IBM's hybrid and multi-cloud service business model.4

Impact — Incumbent providers face high costs if forced to guarantee performance on other networks.5

Read full response

Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur)

1 Apr 2022 · AI Act

Meeting with Maite Pagazaurtundúa (Member of the European Parliament)

31 Mar 2022 · Artificial Intelligence Act

Meeting with Kim Jorgensen (Cabinet of Executive Vice-President Margrethe Vestager), Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager)

29 Mar 2022 · Data Act, Artificial Intelligence Act

Meeting with Miapetra Kumpula-Natri (Member of the European Parliament, Shadow rapporteur for opinion) and Workday

3 Feb 2022 · Meeting on AI Act

Meeting with Roberto Viola (Director-General Communications Networks, Content and Technology)

2 Dec 2021 · R&D technology, opportunities for technology development in digital - AI, quantum, flagship programmes

Meeting with Mikuláš Peksa (Member of the European Parliament, Rapporteur)

29 Oct 2021 · Digital Operational Resilience Act

Meeting with Monique Pariat (Director-General Migration and Home Affairs)

14 Oct 2021 · mtg with IBM as EES contractor for EU-Lisa (together with ATOS and Leonardo

Response to Standardisation Strategy

6 Aug 2021

IBM welcomes the European Commission’s initiative for a standardisation strategy for Europe. As a major contributor to standardisation in Europe we appreciate the ability to provide feedback to the Roadmap for the standardisation strategy. In our response we roughly follow the structure of the three questions proposed as the outline for further stakeholder consultation. We consider the European standardisation system (ESS) overall fit for purpose, with clear processes and a regulatory approach with the New Legislative Framework (NLF) at its core. The following elements are proposed to further strengthen the ESS: The scope of the ESS should be expanded to Open Technologies comprising both standardisation and open source. Open Technologies drive innovation and trust in technology. They are key for supporting the strategic objective of technological sovereignty by allowing access to technology and preventing lock-in situations. Policy makers should strongly consider embracing OSS that has broad international ecosystem support, such as "Kubernetes" and "containerd". The development of the standardisation strategy for Europe is a timely opportunity for including open source and for leveraging the full potential of Open Technologies for the twin digital and green transition. IBM welcomes the focus the European Commission gives on improving the NLF and solving issues that have impacted the processes in the last years. We highly value the NLF and support its use for new technologies where regulation is deemed necessary as with the draft regulation on AI. We share the points that standardisation requests should not be too prescriptive and that timely citation of harmonised standards is of utmost importance. A major strength of the ESS is its close link to international standardisation which includes the adoption of international standards as European ones. This has been of major relevance for the competitiveness of Europe. It is also a major motivation for European stakeholders to participate in international standardisation. We propose to further strengthen this international link and promote the use of international standards. In addition, international standardisation may be leveraged in the context of the renewal of the transatlantic partnership. Standardisation in formally recognised standards bodies is complemented by activities in global fora/consortia like OASIS, W3C, Ecma, IETF or IEEE. In fact, no ICT infrastructure is possible without standards from fora/consortia. The twin transition will also have to rely strongly on fora/consortia standards. The European standardisation should recognise this fact and include fora/consortia more into the scope of the ESS. Again, including and putting some policy focus on fora/consortia may provide a trigger for European stakeholders to get more engaged in fora/consortia, as well. Moreover, some fora/consortia have taken major steps in integrating standardisation and open source and bring this expertise and potential for innovation to the European market. The EU Multi-Stakeholder Platform for ICT Standardisation (MSP) is a milestone for an inclusive approach towards ICT standardisation with its membership including the leading global fora/consortia. IBM highly values this expert group and strongly supports further strengthening its role for providing high-quality and first hand advice on ICT standardisation in relation to policy needs. Similarly the Rolling Plan for ICT standardisation is a powerful tool for bridging between EU policy objectives and ICT standardisation. Both, the MSP and the Rolling Plan are unique in the world and should further be promoted with the EU standardisation strategy. IBM does not see a need for amending Regulation 1025/2012 but propose to focus on improvements at the operational level. We believe that the upcoming standardisation strategy can set the right directions for effective incremental improvements to the ESS.

Read full response

Response to Requirements for Artificial Intelligence

6 Aug 2021

IBM welcomes the opportunity to provide comments to the European Commission's draft Artificial Intelligence Act. We welcome the Commission’s risk-based approach to regulating specific uses of AI systems, not the AI technology itself. IBM believes certain aspects of the Regulation could be clarified, especially to better delineate AI tools and AI systems and outline the resulting obligations of the various actors involved in supplying, training, deploying and using AI systems. IBM's detailed comments are attached.

Read full response

Response to Data Act (including the review of the Directive 96/9/EC on the legal protection of databases)

25 Jun 2021

IBM welcomes the opportunity to comment on the policy options that the European Commission is examining and contemplating for the ‘Data Act’. Creating and promoting more fairness in the data economy, with the aim to increase legal certainty for data sharing in Europe, is a laudable objective and one we support. We encourage the European Commission to take into account the following recommendations: 1) B2B and B2G data sharing: • Contractual freedom and a voluntary approach should remain the basis for B2B and B2G data sharing. • Mandating data sharing should take into account the processor versus controller differentiation, whereby processors do not own and control their customers’ data, and any forced data sharing on processors could lead to a breach of contract with the customer. • The promotion of Open Data Agreements, such as, the Community Data Licence Agreements can help reduce barriers to data sharing, and in some cases ensure that downstream recipients of data can freely use, modify, and analyse data. • A B2B fairness test for contracts and model contract terms should be drafted with input from relevant stakeholders. We recommend that the Commission takes into account existing precedence and best practices that draws from experiences and working-methods established in other communities, such as the open source community. • Any review of EU IP legislation should not undermine trade secrets, confidential business information, or IP rights and protections. • Adequate compensation schemes for B2G data sharing should be contemplated and what constitutes “public interest” must carefully be balanced against the costs and risks this may entail, and be context-specific. 2) Portability obligations for Cloud Services Providers (CSPs): • Legislative action may be premature in this area, given the many ongoing industry-led efforts, notably industry code of conducts (SWIPO) and standardisation (ISO 19441). • EU policymakers should support industry-driven efforts on guaranteeing portability for the purposes of creating market awareness and generating more trust in the cloud market. • Open source technologies continue to improve data and application portability in Europe and we encourage the Commission to continue engaging with relevant stakeholders to facilitate wider use of open APIs, specifications and software components. 3) Government access to data: • Any policy options on government access to data must take into consideration differences in cloud service provider business models, specifically the differences between cloud service providers and their data handling practices, and consider these against potential policy options on safeguards for non-personal data scenarios. • Policy options should carefully consider the different risks and dimensions in practice related to non-personal data lawfully disclosed to third-country law enforcement, which are entirely different than the risks pertaining to government requests to personal data. • Further discussions between the European Commission, CSPs, and Cloud User Groups, to shape sound and proportionate obligations related to technical, legal and organisational measures are welcome.

Read full response

Meeting with Thierry Breton (Commissioner) and

10 Jun 2021 · - Semiconductor - Quantum Computing

Meeting with Svenja Hahn (Member of the European Parliament, Shadow rapporteur) and Bureau Européen des Unions de Consommateurs and Bitkom e.V.

27 May 2021 · Artificial Intelligence Act (AIA)

Response to Digital Services Act package: ex ante regulatory instrument of very large online platforms acting as gatekeepers

5 May 2021

IBM welcomes the Commission’s Digital Markets Act (DMA) proposal and the opportunity to provide feedback. IBM agrees that action is needed to ensure fairness and contestability of certain digital markets, especially those that are data-driven. We believe that the Digital Markets Act contains the right mechanisms to restore both fairness and contestability in those digital markets. To achieve the DMA’s objectives, however, its scope should be clarified and be better aligned with the types of digital services it seeks to regulate. This will not only improve the DMA’s efficiency but also create the necessary legal certainty for all stakeholders. As per the Commission’s press release accompanying the DMA proposal, the DMA is meant to be well targeted to large, systemic online platforms and sets out to use narrowly defined objective criteria to determine when such platforms are Gatekeepers. The scope of the DMA should indeed be focused to ensure it addresses the right issues and avoids unintentionally capturing players who do not negatively impact the contestability of digital markets. Specifically, the precise nature of what constitutes “an important gateway to reach end users” should be further detailed to reflect that a Gatekeeper acts an essential go-to-market channel, enabling businesses to access markets where they connect with end users. For example, some of the proposed Core Platform Services include services which do not constitute such a go-to-market-channel. For instance, cloud services and in particular Infrastructure as a Service Cloud (“IaaS”) does not allow business users to establish a connection with their end-users but only enables them to rent virtual hardware whereas physical hardware – computers – are not in scope.

Read full response

Meeting with Jean-Eric Paquet (Director-General Research and Innovation)

4 May 2021 · Commission's Research agenda, in relation to the technology sector

Meeting with Valdis Dombrovskis (Executive Vice-President)

26 Apr 2021 · The EU's trade agenda, particularly in relation to the technology and ICT sector, incl. the transatlantic relationship - transatlantic data flows, Trade and Technology Council initiative, also - digital part of the Recovery and Resilience Facility

Meeting with Axel Voss (Member of the European Parliament) and Forschungszentrum Jülich GmbH

23 Apr 2021 · Exchange of views on transatlantic EU-US cooperation in quantum computing.

Meeting with Margrethe Vestager (Executive Vice-President) and

22 Apr 2021 · Digital sovereignty, Cloud strategy, Digital Markets Act and Digital Services Act, Artificial Intelligence

Response to Digital Services Act: deepening the Internal Market and clarifying responsibilities for digital services

31 Mar 2021

IBM welcomes the opportunity to give feedback on the Commission’s proposal for a Digital Services Act (DSA). As a global Business-to-Business (B2B) technology company with a significant European footprint, IBM plays a key role in the digital transformation of Europe’s industry, enabling our clients to benefit from the power of data. IBM believes that digital services providers should be responsible for the societal impact of their platforms: this has become an even greater imperative at a time when the use of digital technologies has accelerated amidst the ongoing COVID-19 crisis and will be an essential part in the recovery of our society and economy. Therefore, IBM welcomes the proposal for a DSA. We fully support the Commission’s targeted approach requiring different rules for different categories of services to tackle illegal content online, particularly when content is disseminated to the public, something IBM has long called for. We believe this proposal is an important starting point to build greater trust in technology and can offer an opportunity for Europe to champion online responsibility and accountability, while allowing digital businesses to continue to grow and innovate. Please find attached our full contribution to this feedback process.

Read full response

Response to Revision of the NIS Directive

18 Mar 2021

In a time of turmoil, and with recent unprecedented cyber breaches such as Solarwinds, the EU’s revision of the NIS Directive certainly is a timely one. As a leading cybersecurity services provider, IBM believes the Revision should focus on increasing collaboration between government and industry and global industry-led initiatives, prioritise fixing a cyber breach over reporting it, positively incentivise companies with a commercial rationale instead of sanctions, increasing clarity in the reporting process, and establishing global standards with clear technical requirements. We strongly believe these are important steps in increasing the cybersecurity resilience of European governments and organisations. In the attached, we have provided further comments on the aspects mentioned above.

Read full response

Meeting with Mariya Gabriel (Commissioner)

15 Mar 2021 · Commission's Research agenda, particularly in relation to the technology sector, as well as on the forthcoming technological developments

Response to Legislative framework for the governance of common European data spaces

1 Feb 2021

The goal of the European Commission’s proposal for an EU “Data Governance Act”(DGA) is to foster the availability of data, in particular non-personal data, for (re-)use by increasing trust in novel data intermediary services and strengthening data-sharing mechanisms across the EU. IBM welcomes this goal as more and better data responsibility will generate more trust, which goes hand-in-hand with creating a better culture of data sharing in Europe. IBM is committed to trusted data-sharing through its Principles of Trust and Transparency and by championing a high degree of privacy and security standards to cross-border data flows. With this contribution, IBM would like to share perspectives and recommendations to shape a regulatory data governance framework that promotes a legally certain, trusted and innovation-friendly data ecosystem for Europe. Our views and recommendations are laid out in detail in the attached document.

Read full response

Meeting with Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager)

17 Dec 2020 · DSA, DMA

Meeting with Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans)

27 Oct 2020 · Online event "Egmont and the European Green Deal"

Meeting with Lucrezia Busa (Cabinet of Commissioner Didier Reynders)

28 Sept 2020 · Data protection

Meeting with Didier Reynders (Commissioner) and

11 Sept 2020 · Exchange of views on data protection and Artificial Intelligence

Meeting with Nicolas Schmit (Commissioner) and

10 Sept 2020 · Videoconference meeting on recovery and skills.

Meeting with Alina-Stefania Ujupan (Cabinet of Executive Vice-President Margrethe Vestager), Kim Jorgensen (Cabinet of Executive Vice-President Margrethe Vestager), Michele Piergiovanni (Cabinet of Executive Vice-President Margrethe Vestager)

9 Sept 2020 · Discussion on digital issues

Meeting with Věra Jourová (Vice-President)

9 Sept 2020 · EC in green and digital transitions, Data flows

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

25 Aug 2020

IBM supports the European Commission’s proposal for an Implementing act on a list of High-Value Datasets as a contribution to the effective implementation of the Open Data Directive 2019/1024. We agree with the objective to make specific high-value public datasets available, where appropriate, as there is significant potential in its re-use in new products and services. We stress that the data shared should be available for commercial use by commercial entities. This also offers an opportunity for public sector bodies to lead by example by making available more public datasets to further support innovation and research for stakeholders of all sizes in Europe. We recommend that public sector data and government data be licenced under recognised open data agreements, for example the Community Data Licence Agreements (see The Linux Foundation Projects, Community Data License Agreement, https://cdla.io/). With the proper emphasis on data standards, reliability, and sound data governance, the foreseen data spaces represent an ideal environment for EU member states to release public data sets. Therefore, we believe that the data spaces should also be advanced as a practical means of achieving the goals of the Open Data Directive. We fully support that the implementing act emphasises that the publication and re-use of high-value datasets have to be compatible with open standards licences. In this context, open standards for software interoperability need to be implementable in open source. Against this background and as a starting point, data spaces can begin with creating open data environments, including high-value data sets and government data released under open data agreements, to develop a culture of data sharing and free exchange among participants. By having public sector data as a common data layer in the data spaces, this could also aid in further incentivising data coming from the private sector to be fed into the data spaces. Moreover, in order to encourage participation in the data spaces by commercial entities, we stress that private sector data sharing should remain of a voluntary nature and be subject to IP rights, protect sensitive commercial data and take into account concerns around privacy or security issues. Moreover, we welcome making available specific high-value data in machine-readable formats, provided via standardised and open APIs to incentivise access and re-use of such datasets. Technical measures such as standards at global or European level can also aid to increase the interoperability and readability of such high-value data sets, which in turn will contribute to increasing the re-use of these data sets. However, we note that datasets, as mentioned under Annex I to the Open Data Directive, presently appear to be highly dispersed. An ongoing dialogue with all relevant stakeholders to define and identify specific high-value datasets at EU level is recommended. Moreover, and where high-value data sets incorporate private sector information and concerns arise related to IP rights, sensitive commercial data or any privacy or security issues, we caution the legislator to carefully assess and consult with the private sector before disclosing such datasets and to balance against the costs and risks this may incur.

Read full response

Response to Requirements for Artificial Intelligence

19 Aug 2020

IBM welcomes the opportunity to respond to the Commission’s Inception Impact Assessment on the proposed legislative initiative on AI. We welcome the policy Objective and Aims of the initiative, in particular the intent to ensure coherence and complementarity with other possible initiatives, e.g. affecting the Machinery Directive, the General Product Safety Directive or the product liability regime. We support targeted policies that address companies’ accountability for developing and operating trustworthy AI. Below are our comments on the legislative options outlined. Option 1: “soft law” approach. We support this Option for low-risk AI applications. Option 2: legislation setting up a voluntary labelling scheme. Voluntary labelling schemes can be helpful to consumers or end-users in some markets but we do not believe a single, one-size-fits-all labelling scheme would be effective across such a broad field as AI, given the hugely diverse range of products and services that will be deployed across all sectors. Option 3a: legislation establishing mandatory requirements for a specific category of AI applications only, notably remote biometric identification systems. We support the need for a public dialogue on the use of facial recognition technologies, which could lead to targeted legislation. Option 3b: legislation establishing mandatory requirements for “high-risk” AI applications. Legislation should focus on high-risk applications, particularly applications where human autonomy or judgment are substantially ceded to an AI system. There should be a single risk assessment framework to identify high-risk AI, regardless of sector and without lists of exceptions. Any mandatory requirements for high-risk AI systems should be addressed to the actors best placed to address the risks. Similarly, liability is best allocated to the actor closest to the risk, as liability is highly context-specific. In a B2B context, contractual liability works well and should be maintained, allowing parties negotiate an efficient allocation of risk that takes account of the specific use case. Option 3c: legislation covering all AI applications. We do not support this option as it would significantly hamper the uptake and development of AI in the EU, against the stated Objective and Aims of the initiative. Option 4: A combination of the options above taking into account the different levels of risk that could be generated by a particular AI application. We believe the Objective and Aims can best be met with a combination of Options 1, 3a and 3b, implemented through a co-regulatory approach and supported by globally recognized standards and industry-led codes of conduct. In relation to a European governance structure on AI, we believe that in sectors where established structures already exist (medical devices, aviation etc.) these existing bodies are best placed to cover high-risk AI in their sectors, having the necessary sectoral expertise, operational relationships and track-record with relevant stakeholders. There may be value in a new European mechanism that provides best practice sharing and guidance across sectors, but its scope must be limited and its relationship to existing regulatory bodies clearly defined, so as to avoid fragmentation, inconsistency and the risk of stifling innovation. In summary, we agree with the need for a consistent EU-wide regulatory framework for trustworthy AI. This will be essential to give stakeholders the confidence to develop and adopt AI-based solutions and realize the enormous benefits they offer. Building trust requires acknowledging valid concerns that exist regarding accountability, transparency, fairness, privacy and security, and putting in place appropriate regulatory mechanisms to manage those risks, while continuing to promote ongoing innovation and experimentation – getting that balance right requires a precision regulation approach that is clear and targeted.

Read full response

Response to Intellectual Property Action Plan

13 Aug 2020

In general, whilst IBM supports the Commission’s review of the EU IP frameworks, due to the far reaching impacts of policy and legislative changes, particularly in the fields of Artificial Intelligence (AI) and data, before any changes are made, IBM urges the Commission to ensure that legal and technical definitions and context are agreed upon upfront; relevant legislation and policy efforts from across jurisdictions are consistent and any changes in legislation are left predominantly to the responsible legislative bodies. With reference to Problem 1 ["and the protection of inventions generated or implemented using artificial intelligence (AI)"], a number of relevant activities from other bodies and from across jurisdictions are taking place. For example, the World Intellectual Property Organization [WIPO] is currently reviewing a wide ranging list of relevant issues in their Conversations on Intellectual Property [IP] and Artificial Intelligence (AI), notably around “autonomously generated” inventions and “AI assisted inventions”. Further examples include two Federal Register Notices issued by the United States Patent and Trademark Office [USPTO] and non-binding Guidelines issued by the European Patent Office [EPO], which cover patentability of AI inventions. With reference to Section B, IBM supports review of the implementation of the Copyright Directive, particularly with respect to the commercial exceptions for Text and Data Mining (TDM), a tool used in AI solutions. It is critical that any legal and technical requirements in national implementation are flexible, to ensure that commercial entities are able to fully support and engage in commercial take up of TDM in Europe. Further, with regards to data sharing, whilst IBM supports initiatives, such as, the EU Data Strategy , we urge the Commission to place emphasis on data standards, reliability, and sound data governance; ensure that any data made available is applicable for commercial use (e.g., training AI) and that any data sharing is rooted in voluntary approaches.

Read full response

Response to Legislative framework for the governance of common European data spaces

30 Jul 2020

IBM shares the European Commission’s vision that Common European Data Spaces shall create an enabling environment, empowering market participants to capture the data that they generate. At the heart of the data spaces are the users of data who need the certainty that their data is handled in a responsible manner. The success of the EU data strategy depends on setting up data governance mechanisms and structures that foster an open and inclusive approach, built on a value-driven approach to data sharing. We are convinced that data responsibility is the key to developing a better culture of data sharing in Europe, ultimately contributing to boosting its data economy and data sovereignty. The following should be taken into account: A legislation should first and foremost provide market participants with the needed flexibility and legal certainty when participating in data spaces. High-level rules for open, transparent and structured stakeholder involvement and decision-making processes are more suitable than prescriptive rules. The focus should also be on participatory and compatibility issues around data spaces, while also clarifying in the scope of the law what type of data will feed into the data spaces. We believe that the development and adoption of the contemplated data spaces can and should be implemented in phases where government data released under open data licences can serve to advance as a practical means of achieving the goals of the EU Open Data Directive. As data held by the public sectors have immense innovative potential for businesses, capturing the value of such data for commercial purposes will significantly contribute to the uptake of innovative technologies that can help tackling society’s most pressing challenges, such as climate change. We stress that the quality and accuracy of such data are key for businesses to spur innovation. COVID-19 has demonstrated the importance of the value of data and data sharing. We emphasize that data altruism mechanisms must benefit all stakeholders. Privacy, security and transparency are core to creating trust and data altruism. IBM commits itself to this approach with our Principles of Trust and Transparency. We stress that mandatory data sharing obligations when there is a “public interest” element must be carefully balanced against the costs and risks this may incur. This should also be defined based on a context-specific approach, through a continuous dialogue with all relevant stakeholders and across sectors. Furthermore, at technical level we believe that Europe must take into account work done by international and European standardisation bodies, but also by fora and consortia. Significant work on interoperability, portability, data formats etc. are already underway. If the goal is to lower the cost of data use through technical means and standards, then any new body at European level established in the context of the data governance legislation should cooperate closely with these entities. In this context, open source can be a differentiating factor for Europe and many initiatives are already European-driven. Moreover, while positive, the topic of data intermediaries necessitates more discussions at EU level to foster common understanding about their nature, role and objectives. A data intermediary can for instance be a platform such as the TradeLens platform, which offers an enabling environment for stakeholders to share data in a highly secure, privacy-friendly platform. This standards-based approach greatly facilitates easier exchange of data, while also significantly decreasing the costs of data sharing. We highlight that Open Data Agreements - such as the Community Data Licence Agreements - can also contribute to lowering transaction costs in data sharing. Standardised data licence agreements can facilitate new collaborative approaches for sharing data resources and EU policymakers should support by raising awareness when setting up data spaces.

Read full response

Meeting with Janusz Wojciechowski (Commissioner) and

15 Jul 2020 · Security of the food supply chain

Meeting with Anthony Whelan (Cabinet of President Ursula von der Leyen)

20 Feb 2020 · Cloud & data portability,, artificial intelligence (outcome oriented approach, standards), open 5G standards

Response to Evaluation of the Electromagnetic Compatibility Directive

11 Feb 2020

IBM welcomes the opportunity to provide feedback on the roadmap for an evaluation of the EMC Directive. For IBM as a manufacturer of server and storage hardware the EMC directive is one of the major regulatory tools against which to assess the conformity of our products. From our perspective the Directive is still fit for purpose. It is effective, efficient and coherent and its EU scope provides added value for manufacturers and users alike. From a horizontal perspective it is properly aligned with the NLF since its last revision in 2014 as part of the NLF alignment package. As a matter of principle, the NLF-aligned directives have a substantial amount of redundancy originating from the reference clauses laid down in Decision 2008/768/EC. Nevertheless, we appreciate the current modularity of EU product legislation and we fear that any kind of merger of product laws would lead to confusion or even disruption. As for the sector specific aspects we are aware of the discussions in the EMC Working Party about cables (more specifically ‘ready-made connecting devices’ or RMCD). Cables (except for the special case of active cables) are inherently benign. Therefore, the statement in Article 2(2)(d) indicating that such equipment is outside the scope of the EMCD should remain in the directive. Imposing legal EMC characteristics on cables itself would be counter productive. To summarize, we do not see a compelling reason to act at this time regarding a revision of the EMC Directive. We will be happy to make additional contributions to the ongoing evaluation process and stand ready for further discussions.

Read full response

Meeting with Adrienn Kiraly (Cabinet of Commissioner Mariya Gabriel)

11 Dec 2019 · Horizon Europe - Digital Industry and Digital Education

Meeting with Phil Hogan (Commissioner) and

11 Dec 2019 · Presentation of IBM’s point of view on digital trade and the priorities of the new Commission

Meeting with Daniel Braun (Cabinet of Vice-President Věra Jourová)

11 Dec 2019 · Conference on Digital Europe

Meeting with Roberto Viola (Director-General Communications Networks, Content and Technology)

25 Nov 2019 · Low power processors & microprocessors for AI.

Meeting with Andrus Ansip (Vice-President) and

26 Nov 2018 · AI (ethical principle), trust in the DSM (GDPR, free flow of data, access to data)

Meeting with Cecilia Malmström (Commissioner)

26 Nov 2018 · digital competitiveness

Meeting with Roberto Viola (Director-General Communications Networks, Content and Technology)

26 Nov 2018 · EU AI Strategy, Quantum, HPC

Meeting with Věra Jourová (Commissioner) and

26 Nov 2018 · GDPR, Privacy Shield

Meeting with Wojtek Talko (Cabinet of Commissioner Věra Jourová)

15 Nov 2018 · GDPR, e-privacy

Meeting with Marie Frenay (Cabinet of Vice-President Andrus Ansip), Stig Joergen Gren (Cabinet of Vice-President Andrus Ansip)

12 Oct 2018 · Data & Artificial Intelligence

Meeting with Gertrud Ingestad (Director-General Informatics)

4 Oct 2018 · Handshake with Mr Sebastian Krause

Response to Environmental impact of enterprise servers and data storage products

31 Jul 2018

See comments in attachment.

Read full response

Meeting with Joost Korte (Director-General Employment, Social Affairs and Inclusion)

28 Jun 2018 · Meeting to discuss future of work

Meeting with Roberto Viola (Director-General Communications Networks, Content and Technology), Roberto Viola (Director-General Communications Networks, Content and Technology)

28 Jun 2018 · HPC

Meeting with Mariya Gabriel (Commissioner)

12 Jun 2018 · Visit of CEBIT exhibit (AI, Cloud, Blockchain, Quantum Computing)

Meeting with Stephen Quest (Director-General Taxation and Customs Union)

6 Apr 2018 · Exchange of views on IT architecture

Meeting with Rodrigo Ballester (Cabinet of Commissioner Tibor Navracsics)

7 Feb 2018 · Digital Education

Meeting with Lucie Mattera (Cabinet of Commissioner Pierre Moscovici)

14 Dec 2017 · Independent worker's access to social protection

Meeting with Piet van Nuffel (Cabinet of Commissioner Marianne Thyssen), Vasiliki Kokkori (Cabinet of Commissioner Marianne Thyssen)

13 Dec 2017 · European Pillar of Social Rights, New Skills Agenda for Europe, Revisions to the ‘written statement’ Directive, IBM internal policies for HR management ( work force retention, skills forecasting, training)

Meeting with Kaius Kristian Hedberg (Cabinet of Commissioner Elżbieta Bieńkowska) and BUSINESSEUROPE and

7 Dec 2017 · Data Flows in Trade Agreements

Meeting with Julian King (Commissioner)

21 Nov 2017 · Cyber security

Response to 2nd Data Package

30 Oct 2017

We welcome the opportunity to share views on the proposed Regulation creating a framework for the free flow of non-personal data in the EU. We support the European Commission’s objective to put and end to the spread of data localisation rules, which are an obstacle to free trade and are contrary to the EU Single Market principles. Eliminating data localisation is beneficial to all companies trying to scale up and do cross-border trade. Article 2 – Scope The Regulation applies to data localisation measures that are based on reasons other than the protection of personal data as covered by the GDPR. This significantly limits the scope of the proposal. Some data localisation measures, such as those governing health and HR data for example, may not be covered at all except in relation to non-personal data like machine data or aggregate numbers. Also, the fact that this Regulation only applies to non-personal data raises questions around datasets which combine personal and non-personal data. It is often difficult or too costly to unbundle such data, therefore the Regulation should also apply to datasets which include both personal and non-personal data that cannot be unbundled. Article 3 – Definitions The definitions of “draft acts” and “data localisation requirement” cover “administrative provisions”, but public procurement rules are not explicitly mentioned. Also, the definition of “data localisation requirement” covers laws and administrative provisions of the Member States, but it is not clear if laws and other rules adopted by regional or local authorities are also covered. This is important in the context of data localisation requirements in regional and local public procurement rules. It should be clarified in the text of the Regulation that public procurement rules are covered. Article 4 - Free movement of data across borders within the Union The exception limited to national security should not be broadened, or lead to any interpretation as to which data localisation measures could be justified on public security grounds. Regarding the oversight mechanism, if the procedures under the Transparency Directive do include back and forth communications between Member States and the Commission on the validity of draft rules, it is not clear if the Commission actually has the power to block a draft act which it would consider to be unjustified. In the case of data localisation, a notification procedure should be extremely robust and give clear blocking powers to the Commission in order to be effective. We fully support transparency obligations on Member States regarding justified data localisation measures. Article 5 - Data availability for regulatory control by competent authorities National authorities should be able to carry out regulatory control as if the data was stored on their territory. It is important that the scope of this provision is not broadened beyond access for regulatory control. Article 6 - Porting of data We support the view that portability is best ensured via industry-led initiatives rather than mandatory rules, thus codes of conduct are more suitable. Nevertheless, the one-year deadline for all data service providers to effectively implement these codes of conduct seems particularly short, considering the time that is usually needed for the drafting of such self-regulation.

Read full response

Meeting with Daniel Braun (Cabinet of Commissioner Věra Jourová), Monika Ladmanova (Cabinet of Commissioner Věra Jourová) and Svaz průmyslu a dopravy ČR

17 Oct 2017 · Robotics/AI, ePrivacy, Cybersecurity

Meeting with Věra Jourová (Commissioner) and

11 Oct 2017 · Privacy shield, GDPR, data flows, artificial intelligence, robotics, encryption, women in IT sector

Meeting with Roberto Viola (Director-General Communications Networks, Content and Technology)

11 Oct 2017 · progress on potential strategic partnership for HPC in Europe

Meeting with Cecilia Malmström (Commissioner)

11 Oct 2017 · Future of Transatlantic Relationship and Data flows in FTAs

Meeting with Carlos Moedas (Commissioner) and

10 Oct 2017 · European Research, IBM participation in Horizon 2020 and the future Research Framework Programme

Meeting with Eric Peters (Cabinet of Commissioner Mariya Gabriel)

10 Oct 2017 · DSM, Cybersecurity, Artificial Intelligence, the Free Flow of Data legislative proposal and e-skills

Meeting with Andrus Ansip (Vice-President) and

10 Oct 2017 · Free flow of data, e-health, cybersecurity, D4D

Meeting with Mariya Gabriel (Commissioner)

10 Oct 2017 · DSM and the EU Cybersecurity Strategy

Meeting with Jean-Philippe Gammel (Cabinet of Commissioner Tibor Navracsics)

6 Oct 2017 · Digital education

Meeting with Jean-Philippe Gammel (Cabinet of Commissioner Tibor Navracsics), Szabolcs Horvath (Cabinet of Commissioner Tibor Navracsics)

31 Aug 2017 · TopTeam Sports of IBM

Meeting with Günther Oettinger (Commissioner)

23 Jun 2017 · diversity

Meeting with Rodrigo Ballester (Cabinet of Commissioner Tibor Navracsics)

20 Jun 2017 · Digital skills

Meeting with Julie Fionda (Cabinet of Commissioner Marianne Thyssen)

20 Jun 2017 · Skills

Meeting with Günther Oettinger (Commissioner)

7 Jun 2017 · DSM

Meeting with Roberto Viola (Director-General Communications Networks, Content and Technology)

11 May 2017 · Digital Single Market - Update of the Watson Health Center of Excellence Project -General discussion about the discussion ongoing in Italy concerning the main relevant Dossiers (DSM, Industry 4.0) - Digital transformation in Italy: priorities and activities

Meeting with Laure Chapuis-Kombos (Cabinet of Vice-President Andrus Ansip)

30 Mar 2017 · e-privacy review directive

Meeting with Aare Järvan (Cabinet of Vice-President Andrus Ansip)

21 Mar 2017 · Blockchain Technology

Meeting with Andrus Ansip (Vice-President) and

17 Feb 2017 · Digital Single Market, free flow of data

Meeting with Michel Servoz (Director-General Employment, Social Affairs and Inclusion)

26 Jan 2017 · EU’s Quality Framework for anticipation of change and restructuring

Meeting with Andrus Ansip (Vice-President) and

18 Jan 2017 · Copyright, data, text and data mining

Meeting with Kevin O'Connell (Cabinet of Commissioner Věra Jourová)

25 Nov 2016 · e-privacy directive a Privacy Shield

Meeting with Rodrigo Ballester (Cabinet of Commissioner Tibor Navracsics)

23 Nov 2016 · ICT in education

Meeting with Juhan Lepassaar (Cabinet of Vice-President Andrus Ansip), Maximilian Strotmann (Cabinet of Vice-President Andrus Ansip)

8 Nov 2016 · Copyright (text and data mining), Free Flow of Data Iniative

Meeting with Roberto Viola (Director-General Communications Networks, Content and Technology)

7 Nov 2016 · DSM related issues and IBM's latest business developments in Europe

Meeting with Bernd Biervert (Cabinet of Vice-President Maroš Šefčovič)

22 Sept 2016 · Digitalisation of Energy Sector

Meeting with Kaius Kristian Hedberg (Cabinet of Commissioner Elżbieta Bieńkowska), Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska) and

16 Sept 2016 · digital trade

Meeting with Nele Eichhorn (Cabinet of Vice-President Cecilia Malmström) and DIGITALEUROPE

12 Sept 2016 · digital trade

Meeting with Rudolf Strohmeier (Director-General Publications Office)

14 Jun 2016 · Digital Innovation

Meeting with Bernardus Smulders (Cabinet of First Vice-President Frans Timmermans) and BUSINESSEUROPE and

14 Jun 2016 · Digital single market

Meeting with Robert-Jan Smits (Director-General Research and Innovation)

7 Jun 2016 · Brief update on IBM Research in Europe

Meeting with Günther Oettinger (Commissioner) and Intel Corporation and

1 Jun 2016 · DSM

Meeting with Bodo Lehmann (Digital Economy) and Oracle and

1 Jun 2016 · cPPP

Meeting with Pauline Rouch (Cabinet of President Jean-Claude Juncker)

31 May 2016 · Digital Single Market

Meeting with Friedrich-Nikolaus von Peter (Cabinet of Commissioner Violeta Bulc)

26 Apr 2016 · Connected vehicles

Meeting with Cecilia Malmström (Commissioner)

20 Apr 2016 · Trade for All

Meeting with Maroš Šefčovič (Vice-President)

20 Apr 2016 · Energy Union

Meeting with Věra Jourová (Commissioner) and

19 Apr 2016 · Privacy Shield, Diversity at the workplace, Women in decision making

Meeting with Andrus Ansip (Vice-President) and

19 Apr 2016 · Free flow of data, cloud, standardisation, internet of things, EU-US Privacy Shield

Meeting with Lee Foulger (Cabinet of Vice-President Valdis Dombrovskis)

16 Feb 2016 · Test

Meeting with Bernardus Smulders (Cabinet of First Vice-President Frans Timmermans) and DIGITALEUROPE and

14 Jan 2016 · AECA Round-Table on “Dealing with Regulatory Burden

Meeting with Roberto Viola (Director-General Communications Networks, Content and Technology)

11 Jan 2016 · Digitisation of industry - Safe Harbour - The data economy in Europa

Meeting with Inge Bernaerts (Cabinet of Commissioner Marianne Thyssen), Julie Fionda (Cabinet of Commissioner Marianne Thyssen)

11 Jan 2016 · Skills, employment and social conditions

Meeting with Eric Mamer (Digital Economy)

21 Dec 2015 · Automated and Connected Cars

Meeting with Julie Fionda (Cabinet of Commissioner Marianne Thyssen)

15 Dec 2015 · Skills, Pact for Youth

Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen)

9 Dec 2015 · Investment opportunities and digital single market

Meeting with Günther Oettinger (Commissioner) and Google and

20 Nov 2015 · Digital transformation of the European industry

Meeting with Jyrki Katainen (Vice-President) and

17 Nov 2015 · Roll-out of Investment Plan

Meeting with Andreja Kodrin (Cabinet of Commissioner Violeta Bulc)

10 Nov 2015 · Meeting IBM Slovenia respresentatives

Meeting with Günther Oettinger (Commissioner)

30 Oct 2015 · Digitising Industry

Meeting with Robert-Jan Smits (Director-General Research and Innovation)

14 Oct 2015 · IBM's research activities in Europe

Meeting with Alfredo Sousa De Jesus (Cabinet of Commissioner Carlos Moedas), Antonio Lowndes Marques De Araujo Vicente (Cabinet of Commissioner Carlos Moedas)

13 Oct 2015 · Horizon 2020, FP7, Industry 4.0

Meeting with Hanna Hinrikus (Cabinet of Vice-President Andrus Ansip)

21 Sept 2015 · Digital Trade

Meeting with Markus Schulte (Digital Economy)

17 Sept 2015 · Digitisation of Industry

Meeting with Andrus Ansip (Vice-President) and

17 Sept 2015 · DSM, IoT, free flow of data, data protection, e-health, e-payments

Meeting with Markus Schulte (Digital Economy)

3 Sept 2015 · DSM

Meeting with Kaius Kristian Hedberg (Cabinet of Commissioner Elżbieta Bieńkowska) and DIGITALEUROPE

14 Aug 2015 · Digital Trade

Meeting with Markus Schulte (Digital Economy)

7 Jul 2015 · DSM

Meeting with Eric Mamer (Digital Economy), Laure Chapuis-Kombos (Cabinet of Vice-President Andrus Ansip), Michael Hager (Digital Economy)

16 Jun 2015 · DSM

Meeting with Hanna Hinrikus (Cabinet of Vice-President Andrus Ansip), Juhan Lepassaar (Cabinet of Vice-President Andrus Ansip), Laure Chapuis-Kombos (Cabinet of Vice-President Andrus Ansip)

16 Jun 2015 · Transatlantic relationship in the context of the DSM

Meeting with Sebastian Kuck (Cabinet of Commissioner Jonathan Hill)

2 Jun 2015 · Digital Single Market (DSM),

Meeting with Violeta Bulc (Commissioner) and

2 Jun 2015 · Transport

Meeting with Laure Chapuis-Kombos (Cabinet of Vice-President Andrus Ansip)

27 Apr 2015 · Consumer cloud

Meeting with Günther Oettinger (Commissioner)

26 Mar 2015 · Digital Policy

Meeting with Stephen Quest (Director-General Informatics)

17 Mar 2015 · Executive dialogue

Meeting with Robert Madelin (Director-General Communications Networks, Content and Technology) and BASF SE and

12 Feb 2015 · Digital Single Market, Innovation

Meeting with Andreja Kodrin (Cabinet of Commissioner Violeta Bulc)

9 Feb 2015 · IBM meeting Smart cities Nicholas Hodac; Katrien Hoogwijs and Yves van Seters

Meeting with Maximilian Strotmann (Cabinet of Vice-President Andrus Ansip)

2 Feb 2015 · Digital Single Market - IoT - interoperability

Meeting with Kevin O'Connell (Cabinet of Commissioner Věra Jourová)

22 Jan 2015 · Data protection

Meeting with Rodrigo Ballester (Cabinet of Commissioner Tibor Navracsics)

21 Jan 2015 · ICT education policy

Meeting with Nele Eichhorn (Cabinet of Vice-President Cecilia Malmström)

21 Jan 2015 · Data Flows, Data Protection, Safe Harbour, TTIP

Meeting with Věra Jourová (Commissioner) and Microsoft Corporation and

16 Jan 2015 · Round Table on Gender Diversity

Meeting with Rodrigo Ballester (Cabinet of Commissioner Tibor Navracsics)

15 Jan 2015 · ICT Skills

Meeting with Valdis Dombrovskis (Vice-President) and

11 Dec 2014 · Presentation of the Annual Growth Survey 2015 outlining the main priorities for the jobs and growth agenda /in the context of the flagship conference ‘Reinvigorating the European Economy: Policies to Foster Jobs, Growth and Innovation’.