Feedback to ZenDiS Discussion Paper Submitted

As of beginning of April, ZenDiS has requested feedback on its discussion paper on digital sovereignty for Public Administration.

Several stakeholders have submitted their feedback via openCode. The official Digital Sovereignty Criteria and its related discussion paper are only available in German. Accordingly, any submitted feedback is in German too. This also applies to the independent feedback of Frank Ingenrieth as attached to this article. 

ZenDiS is calling for feedback on its first Discussion Paper on Digital Sovereignty Criteria.

Deadline is May 15th, 2026.

Feedback shall be submitted via openCode. Therefore, stakeholders must visit ZenDiS' dedicated website and provide feedback via the implemented feedback form, either overarchingly or per chapter. At time of publishing this news piece, ZenDiS seems to respond without undue delay on each individual feedback, accessibly via openCode.

The Executive Summary concludes the recommendations. Following an inofficial translation of the submitted Executive Summary:

• The subject of this feedback and analysis is the discussion paper in its ‘March 2026’ version. 
• The recommendations cover both general structural aspects (Section 3) and specific aspects relating to the individual dimensions (Section 4).
• Based on the theoretical concepts and objectives of criteria catalogues (Section 3.1.1), it is recommended that the criteria catalogue be expanded into a readiness-profile (Section 3.1.2).
• Specifically, it is recommended that an “open readiness-profile” be developed (Section 3.1.2). Specifically, a closed approach is not recommended for the readiness-profile for digital sovereignty, although a three-tier system (low/basic, essential, high) has become established in many areas. 
• It is recommended that the objectives of the criteria catalogue be clarified and that the dimensions and criteria be strictly designed in accordance with these objectives (Section 3.2).
• To ensure an objective and comparable assessment of the circumstances, the dimensions and objectives would need to be translated into specific criteria. Given the highly dynamic nature of the subject, particular use should be made of supplementary explanations, including examples and recommendations (Section 3.3).
• It should be made clearer how the criteria catalogue complements the aspects of digital sovereignty (Section 3.4).
• Unnecessary redundancies should be avoided, as these ultimately lead to avoidable hurdles in implementation. Redundancies trigger – even unintentionally – conflicts of interpretation, particularly where the redundancy is not identical in wording and context (Section 3.4).
• Where elements of the EU CSG or the BSI C3A are deemed beneficial from the perspective of this discussion paper, and where incorporating the content is both expedient and unavoidable, a (static) reference to the relevant criteria should be made, thereby incorporating them (Section 3.4).
• Where information is already recorded objectively and relevantly on the basis of other criteria catalogues, such as supply chains (vendor management) or applicable jurisdictions including the mitigation measures implemented, the criteria of the discussion paper should enable the public administration to assess whether these existing criteria catalogues are known and used. This may also involve a critical examination of the respective weaknesses of the existing criteria catalogues, with the result that the public administration neutralises these weaknesses through its own, supplementary measures (Section 3.4).
• Risk assessment should constitute a separate dimension (Section 3.5).
• The possibility of individual measures should be maintained (Section 3.5).
• It is recommended that Dimension A focus more strongly on the non-technical aspects of organisational capacity-building, whilst making use of the findings from the other dimensions (Section 4.1).
• It is recommended that any technical aspects be either included on the basis of the additional criteria catalogues already developed, or transferred to separate criteria catalogues yet to be developed, thereby sharpening the objectives of the discussion paper and thus achieving faster and more sustainable effects (Section 4.1). 
• In general, for the other dimensions (B to D), it is recommended to reduce redundancies, refine the objectives of the dimensions, and, as a result, initially focus on referential inclusion in dimension A (sections 4.2, 4.3, 4.4).