On 3 June 2026, the European Commission published its Technological Sovereignty Package. APELL welcomes the Commission's renewed commitment, and increased ambition with regard to the Open Source ecosystem. However, some of the proposed measures may not do what it says on the tin.
Open Source Strategy
APELL welcomes that the revised OSS Strategy figures as a strategic element to the Tech Sovereignty Communication, and the ecosystem approach laid out therein.
APELL has previously outlined that it should be a priority for the European Commission, EU governments and public authorities to leverage the power of the Open Source business ecosystem for digital sovereignty and European competitiveness, to raise awareness for how Open Source increases digital sovereignty, including by institutionalising knowledge and capability in Europe, and through public procurement of Open Source solutions from vendors that invest into the ecosystem upstream, to stimulate growth and competitiveness of the Open Source sector, and the European digital sector at large.
Excessive technological dependencies have created international strategic liabilities
The Communication on European Tech Sovereignty and Open Source Strategy are remarkably clear on the "strategic liabilities" that "excessive technological dependencies" have created for the EU. APELL shares in particular the Commission’s assessment that dependencies on proprietary IT products and services, lock-ins and capture effects are “increasingly weaponised”, “strategic liabilities” that Open Source avoids.
We agree that "a rapid shift of the EU's posture … [and] an assertive and proactive approach grounded in technological sovereignty" are needed.
Open Source is the way forward and allows the EU not only to reduce dependencies and increase technological sovereignty, but to effectively invest in an ecosystem that proactively not only advocates, but implements change and guarantees the absence of lock-ins and capture effects.
Maintenance, business accelerators, and increased visibility
The OSS Strategy proposes to create an Open Source Maintenance Instrument to "support the maintenance and security upkeep of essential components, creating a European capacity and capability to fork projects". The strategy also highlights the need for increasing Open Source skills and awareness.
APELL underlines that the technical infrastructure proposed by the instrument needs to be complemented by an active investment in education, skill building in management and workforce, and institutional knowledge.
The strategy further proposes the creation of "Open Source business accelerators" that should deliver mentoring, consulting, and even legal support to Open Source communities that want to explore growing their project into a commercial undertaking.
As part of the NGI0 Commons Fund “Business Circle”, APELL already delivers mentoring and consulting for Open Source projects that are interested in a business direction, or want to grow their community. As such we appreciate the business accelerators.
Open Source catalogues figure prominently in both the Open Source Strategy and Cloud and AI Development Act, demonstrating the crucial need for more visibility of the many success stories of Open Source procurement or public sector-Open Source cooperations. Going forward, it will be important to clarify how solution providers can participate and benefit from added visibility afforded by the European catalogues, in particular where businesses have not yet been selected in projects with Union entities and public sector bodies.
Open Source in the Cloud and AI Development Act
The Cloud and AI Development Act is the Commission's instrument to increase trusted computing and data centre capacity in Europe. In line with the Tech Sovereignty Strategy, it also creates an obligation for the Member States to assess the risk and subsequent required security level of different digital infrastructure they operate.
Four so-called "Union Assurance Levels" are created that essentially lay down the sovereignty level of such infrastructure.
The Commission has dedicated an entire chapter in CADA on Open Source. The four Articles make sure the already existing EU Open Source Solutions Catalogue becomes a permanent resource, create a Network of Open Source Programme Offices between public sector entities in Europe, outline provisions on the sharing and reuse of software created in or procured by the public sector, and the promotion of Open Source solutions in Europe.
Unfortunately, from the perspective of the Open Source business ecosystem that APELL represents, the chapter does not currently fulfil its stated objective. It will be important to work closely with lawmakers in the European Parliament and the Member States to increase the level of ambition of the law with regard to leveraging the power of the Open Source ecosystem.
About the Tech Sovereignty Package
The Tech Sovereignty Package consists of two legislative proposals, the proposed Cloud and AI Development Act, and the proposed Chips Act 2.0 (complementary to the already existing Chips Act, it is supposed to operate on the demand side, rather than development side of semiconductors), as well as the Communication on Technological Sovereignty with the revised Open Source Strategy, and a Strategic Roadmap for Digitalisation and AI in the Energy Sector.
(Title photo credit: Schachuhr mechanisch: Michael Hofmann, CC BY-SA 3.0, via Wikimedia Commons)
