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OpenForum Europe AISBL

OFE

OpenForum Europe (OFE) is a not-for-profit think tank which was originally launched in 2002 to accelerate and broaden the use of Open Source Software (OSS) among businesses, consumers and governments.

Lobbying Activity

Response to Revision of the Standardisation Regulation

18 Jul 2025

OpenForum Europe (OFE) welcomes the opportunity to contribute to the European Commissions consultation on the revision of the Standardisation Regulation. OFE has been actively engaged in European standardisation policy for over 25 years, advocating for openness, transparency and inclusiveness in support of innovation and technological sovereignty. Our contribution builds on earlier submissions provided as part of this regulatory process and draws on extensive engagement with stakeholders across the open technology and standardisation communities.
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Response to The EU Cybersecurity Act

19 Jun 2025

OpenForum Europe (OFE) welcomes the opportunity to provide input to the public consultation on the revision of Regulation (EU) 2019/881 (Cybersecurity Act). The revision of the Cybersecurity Act presents a timely opportunity to align ENISAs mandate with the realities of the rapidly developing cybersecurity field. OpenForum Europe hopes to bring more attention to how software today is built and maintained -- in particular open source software. ENISA must be equipped to understand, support and secure this evolving reality. Please see our letter attached.
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Response to Interim evaluation of the Strategic Technologies for Europe Platform (2024-2025)

3 Apr 2025

OpenForum Europe (OFE) has submitted the attached proposal for the ongoing MFF Consultation, but it has direct relevance to this consultation as well. We propose a fund to invest in open source base technologies to secure the digital infrastructure all our strategic technologies rely on.
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Meeting with Nicola Danti (Member of the European Parliament, Rapporteur)

10 Nov 2023 · OSS in CRA

Response to Evaluation of Standardisation Regulation (EU) No 1025/2012

24 Sept 2023

OpenForum Europe (OFE) welcomes the opportunity to provide comments and feedback on the European Commissions Roadmap for the evaluation of Regulation 1025/2012. Please see our short feedback attached as a file.
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Meeting with Nicola Danti (Member of the European Parliament, Rapporteur) and Red Hat Limited and Eclipse Foundation AISBL

24 Apr 2023 · Staff-level meeting on open source software in the CRA

Meeting with Nicola Danti (Member of the European Parliament, Rapporteur) and Bureau Européen des Unions de Consommateurs and

27 Feb 2023 · Stakeholder consultation on the Cyber Resilience Act

Response to Cyber Resilience Act

23 Jan 2023

Dear Sir/Madam, Attached is a statement from OpenForum Europe (OFE) aisbl, co-signed by Eclipse Foundation, Open Source Initiative (OSI), APELL, CNLL, and The OSB Alliance. We have very serious concerns regarding some parts of the proposed text in its current form and we look forward to working with the EU institutions on this proposal to strengthen cybersecurity in the EU. We would welcome the opportunity to meet with you or to answer questions by email. ***Please see attached file for our feedback.***
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Response to Cyber Resilience Act

25 May 2022

Please see attached file.
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Response to Standard Essential Patents

23 Apr 2022

Dear Madam or Sir, Attached is the statement from OpenForum Europe (OFE) aisbl. Should you wish to discuss our position and its implications, we would welcome the opportunity to meet with you or to answer questions by email. All the best, Astor Nummelin Carlberg Executive Director, OFE
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Response to Standardisation Strategy

6 Aug 2021

OpenForum Europe thanks the European Commission for the opportunity to submit input to the upcoming Standardisation strategy. Please find our input attached.
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Response to Digital Services Act: deepening the Internal Market and clarifying responsibilities for digital services

31 Mar 2021

EUROPEAN SOFTWARE DEVELOPERS AND USERS RELY ON OPEN SOURCE SOFTWARE DEVELOPMENT PLATFORMS AND CODE REPOSITORIES TO INNOVATE AND COMPETE GLOBALLY Brussels, 31 March 2021 Further to our one-pager on Digital Services Act (8/9/20), OpenForum Europe (OFE) wishes to submit more detailed comments as an active advocate of technological openness and our long-standing collaboration with the Open Source software (OSS) community. OFE welcomes the Commission’s proposal to strengthen protection of consumers’ exposure to harmful and illegal content whilst bolstering Europe’s internet economy. The OSS community relies on online platforms to build and ship software. European companies in all sectors, such as pharmaceuticals, telecoms, banking and manufacturing, rely heavily on OSS development platforms and code repositories to innovate and compete globally. OSS development is at the heart of Europe's digitisation efforts and objective to ensure genuine IT choice and sovereignty across a wide range of key technologies and solutions such as Federated Cloud, HPC, edge computing and so forth. The economic impact of OSS on the EU economy is estimated to be between EUR 65 and EUR 95 billion in 2018. EU countries and EU located companies made significant investments into OSS of Euro 1 billion in 2018, the product of which is available for reuse by the private and public sector and would require 16,000 full time developers to provide the same volume of code. The ecosystem consists of European developers from the public sector, industry, universities and SMEs tackling challenges which no single company or organisation can solve on its own. Due to the integral nature of online platforms to the functioning of the OSS ecosystem, OFE has provided input to earlier legislative dossiers potentially affecting these platforms, in particular the Copyright Directive of 2019. It is important to underscore that many platforms have a more specific user-base or purpose, and thus have a lower risk profile than general purpose platforms. For example, platforms on which software developers rely are often at much lower risk, if not legally irrelevant, to many concerns that policymakers are seeking to address related to online content. It is thus vital that measures taken to address activity conducted by a platform’s users be tailored to the relevant risk so that the rules achieve their intended outcomes without unintended consequences. With this in mind, and in order to safeguard this mode of innovation, on which the European Digital transformation relies, we have a few areas where we would like to see clarifications being added throughout the co-legislative process. Please see our article-specific feedback attached as a file.
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Response to Intellectual Property Action Plan

13 Aug 2020

OpenForum Europe (‘OFE’) agrees with the EU Roadmap’s premise that “well-calibrated and balanced IP policies can build up resilience and boost Europe’s industrial competitiveness, putting the EU on track towards economic recovery” and thereby offers the following suggestion related to the need for the EU’s IP Action Plan to “propose concrete initiatives to improve the IP framework and the way it is used in practice”: i. No single company or government can solve today’s major challenges alone. As reflected in the EU-COVID recovery package collaboration, is key to accelerate digitisation, resilience and climate change solutions. It’s hard to think of another time where the interests of both industry and government are so tied and yet there remains quite a gap in awareness and common understanding of what is happening in practice. By way of example, IPR-intensive industries are working together in fora/consortia governed by long established open source IPR, such as: Linux Foundation’s AGL (e.g. BMW, VW, Mercedes), OpenStack (e.g. Ericsson, CERN), Eclipse’s OpenAdx (e.g. Siemens, Bosch), FIWARE (e.g. Atos, Telefonica), OMP (e.g. ZF Friedrichshafen, Bosch) etc - thereby bringing the best minds together to tackle many of the same objectives as identified by the EU; ii. Open Source Software (‘OSS’) is mainstream technology with enterprise OSS underpinning critical infrastructure in a wide range of sectors such as government, finance, security, telecommunications, healthcare, manufacturing and transport in Europe. Open Innovation is embraced across European sectors and technologies to accelerate co-development and resilience of Federated Cloud, Edge Computing, HPC, Blockchain, 5G, eHealth, Industry 4.0 and so forth; iii. Open Standards constitute another important ingredient to open innovation so as to help prevent lock-in and foster a level playing field between all suppliers of ICT services, whether OSS or proprietary. OFE strongly believes that standards in the area of software interoperability should be available royalty-free allowing for easy implementation in all development models including open source. The leading global IT standards bodies, with the support of all their membership, have long implemented Royalty-free IPR policies or policies with Royalty-free options (e.g. such as OASIS, W3C, IETF, Ecma); iv. In the 2014-19 EU Mandate, policy progress was reflected in better understanding of the importance of open standards and open source to drive European competitiveness - both (a) Regulatory: identification process and MSP within EU Procurement Regulation 1025/2012 and OSS exemption in Copyright Directive 2019/790, and, (b) Guidance: such as the Tallinn Declaration and Commission’s OSS strategy. Indeed, the previous digital Commissioner called for “industry friendly open source licenses to become the norm”. That said, ‘old practices die hard’ and OFE was alarmed to see towards the end of the previous Commission the SEP Communication seemingly reverting to a strategy requiring a ‘balanced’ IPR policy (solely) “based on FRAND terms”. Subsequent discussion with EU Policy makers revealed that this was not the intent given the risk of jeopardising collaboration with a community of 40+ million open source software developers actively designing/implementing similar digital goals being pursued by the EU; v. In this 2019-24 EU mandate, OFE welcomes a number of EU initiatives (e.g. the JRC report on Standards & Open Source and the EC OSS workshop, upcoming Standardisation review as well as this IP roadmap) to further build understanding across the various Commission policy departments as to what is happening in practice across European verticals (as mentioned above) and other IP related initiatives such as patent pledges and the role of organisations such as OIN and LotNetwork to combat patent assertion entities. OFE looks forward to collaborating with the EU over the coming months to finalise a Commission IP vision.
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Response to Digital Services Act: deepening the Internal Market and clarifying responsibilities for digital services

30 Jun 2020

OpenForum Europe (OFE) welcomes the opportunity to give input to the public consultation on the Roadmap on ‘DSA package: Deepening the Internal Market and clarifying responsibilities for digital services’. The Digital Services Act’s broad set of objectives means that many different kinds of services fall within its scope. The open source software community relies heavily on platforms that allow developers to collaborate, by developing, reusing and sharing software. These platforms may be relevant for certain elements of the DSA and we thus would welcome and encourage you to use us as a resource in understanding how proposed rules may achieve their intended objectives, as well as unintended consequences. For example, during the negotiations of the Directive on Copyright in the Digital Single Market, the open source software community helped the EU Commission, Parliament, and Council to understand the implications of the proposal as initially drafted on developers’ ability to access code they need to build and maintain software. In addition, we can also serve as a resource on current practices or standards within the industry that could help guide the design of new rules or inform ways to implement or measure them. OpenForum Europe is a not-for-profit, independent European based think tank which focuses on openness within the IT sector. OFE draws its support from a broad range of stakeholders committed to openness: Among them leading global IT technology providers, European SMEs, user organisations, the openness academic community represented by the OpenForum Academy and the wider openness community. Tapping into this broad basis for support provides OFE with expertise across all major ICT topics, including applying its knowledge to the evolving technologies such as artificial intelligence, blockchain, cloud computing and IoT. Views expressed by OFE do not necessarily reflect those held by all its supporters.
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Meeting with Maximilian Strotmann (Cabinet of Vice-President Andrus Ansip)

14 Feb 2019 · Open Source

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

10 Sept 2018 · Copyright

Response to Review of ENISA Regulation and laying down a EU ICT security certification and labelling

6 Dec 2017

OpenForum Europe (OFE) welcomes the ongoing debate about cybersecurity at the EU policy level. Cybersecurity is of utmost importance for digitisation, for the Digital Single Market and for the societal acceptance of digital transformations and the uptake of new technologies in general. However, OFE has concerns about the European Commission’s proposal for a Cybersecurity Act, specifically with the approach taken in the second part (Article 42 onwards) which defines a regulatory framework for the cybersecurity certification of ICT products and services. At its core, the European Commission’s proposal fails to place key emphasis on risk-based management, which is essential to effective cybersecurity practices and policy. Furthermore the proposal ignores the well-established practice of a clear separation of standards from conformity assessment and certification; it devalues standardisation and cybersecurity standards; it also ignores European Union principles under the New Legislative Framework, which provides a clean separation between legislation, standards, and conformity assessment. Cybersecurity schemes adopted under this proposal would conflate aspects of legislation, standardisation, and certification/conformity assessment. OFE’s full position is outlined in the position paper attached
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Meeting with Maximilian Strotmann (Cabinet of Vice-President Andrus Ansip)

9 Oct 2017 · standards, open innovation

Response to Review of ENISA Regulation and laying down a EU ICT security certification and labelling

4 Aug 2017

Security is a core priority for the Information Communication Technology (‘ICT’) sector, in order to prevent abuse, cyber crime, and attacks on critical infrastructure, to protect personal information, and thereby to mitigate related socio-economic cost. The ICT sector has a vested interest in supporting these aims in terms of bolstering trust, which translates into high levels of market acceptance and increased uptake of innovation. Moreover, such adoption plays a major role in the context of Europe’s digitisation and global competitiveness. OpenForum Europe (‘OFE’) has long addressed this topic, and runs a cybersecurity task force, which investigates needs and best practices as well as on strategic and technical directions for improving cyber security, educates around the key issues, promoting the use of standards and providing input into policy discussions and analyses. Therefore, OFE wishes to contribute by responding to the latest Impact Assessment, and appreciates the Commission’s invitation to stakeholders to provide further input and comments. OFE would like to offer the attached thoughts and recommendations as inputs for further discussion and exchanges. We believe that further discussion and analysis are required before any decision as to the best methods for further improving cybersecurity is taken. Especially, decisions about whether certification should be mandatory, whether trust labels would help, and whether regulation – and if so, in what respect – would be a promising way to pursue an in-depth analysis on the expected benefits and on innovation in the area of cybersecurity.
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Meeting with Maximilian Strotmann (Cabinet of Vice-President Andrus Ansip)

30 May 2017 · Standardisation, innovation

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

4 Jul 2016 · standardisation, e-government, data

Meeting with Stephen Quest (Director-General Informatics) and Free Software Foundation Europe e.V.

12 Dec 2014 · IT procurement and open source strategy