Organization for the Advancement of Structured Information Systems
OASIS
OASIS Open is a nonprofit global open development consortium where experts come together to solve some of the world’s biggest technical challenges through the development of open source code and open standards.
ID: 114903924021-14
Lobbying Activity
Response to Single Market Strategy 2025
31 Jan 2025
Thank you for the opportunity to comment. This text is an excerpt; please see the additional submission document for more. Transactions are proposed, negotiated, completed and regulated largely by means of their data, whether on paper, electronic form or otherwise. Documents and messages that convey that data should be equally readable and usable by all parties to the transaction, as well as those who finance, facilitate and regulate it. This is why open standards have been a central tool of trade practices for over a century, and why stable, vendor-neutral open data standards have been an essential building block for cross-border trade since the beginnings of the Single Market. OASIS Open, an accredited international open standards consortium, supplies multiple key data standards to European and global trade that provide evidence of the policy imperative that open methods be applied to commercial and public administration. Many of them help power the Single Market, and are mentioned here as evidence of the importance of using open, nonproprietary terms, and simple, known methodologies, wherever possible. These include OASIS UBL (ISO/IEC 19845) for EU e-Invoicing; the EU eDelivery and OOTS building blocks from OASIS standards. including ISO 15000-2; and open standards for securing and directing data in transit such as OASIS SAML (ITU-T Rec. X.1141) and OASIS XACML (ITU-T Rec. X.1144). All have been accredited by global de jure SDO or explicitly identified by the Commission for broad public implementation. Importantly, all of them share several key characteristics that explain their usefulness and successful broad adoption: 1. They are openly published, shared with global standards bodies, and vendor- and platform-neutral. Thus they are suitable for all stakeholders, without lock-in to a specific service or product. Because they are open and royalty-free, they enjoy support from multiple freely-available and open source tools, as well as commercial tools, and by "do-it-yourself" systems created by and for SMEs and LDCs. 2. They are built on simple, well-established coding and markup methods such as XML or JSON. Thus, data tools are widely available, and a minimal amount of expertise is necessary, whereas more complex tech platforms, or computational methods that are unfamiliar to most stakeholders, often are a barrier to broad use. 3. By using well established, accessible data technologies, these methods can readily be used and combined with existing cybersecurity and privacy methodologies that already are widely available. 4. Finally, and importantly, these data standards methodologies are extensible, in the sense that they formats are open to being extended, added to profiles, and allowing augmentation by additional metadata as may be needed or desirable. Extensibility is an important feature for policy reasons. A methodology in place (like UBL or other widely-used formats under EN 16931), with tools and guidance to support it (such as can be seen with PEPPOL and OpenPEPPOL), is an excellent and low-friction opportunity to achieve additional goals with the same or related data. Using widely tooled formats such as XML or JSON, in simple structures, allows the core data associated with transactions, shipments and payments for goods and services to be easily associated with metadata for additional commercial and policy goals, to address issues such as extended source and provenance data, licensing data, and cloud and service provenance for interoperability purposes. The NLF program has triggered multiple instances of need for more metadata about virtual goods, services, and transactions (particularly in the CRA, Data Act, AI Act and Interoperability Act, so far), as has similar regulatory evolution in other regions. This need for regulatory-relevant metadata will only grow. OASIS does not speak for its members' independent views; please note the qualifier in our attached submission document.
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