Bitkom e.V.

Europes circular economy needs a clear, harmonised, and practical framework that drives innovation, simplifies compliance, and ensures consistent enforcement. Bitkom emphasizes aligning regulations, leveraging digitalisation, and promoting product longevity to create a transparent, efficient, and competitive circular economy.

Bitkom welcomes the opportunity to share its perspective on the EUs public procurement directives, which are a key pillar of a well-functioning single market. Overall the directives are in general fit for purpose, they provide an adequate baseline for the core elements of procurements in the EU.

Support for shifting MDR and IVDR to Annex I, Section B of the AI Act: Bitkom supports the proposed transfer, as it can reduce duplicative regulation and avoid unnecessary double burden for AI-based medical devices.

Bitkom welcomed the Commission’s draft. The EU.Inc can make this much easier and faster: fully digital, within 48 hours and uniformly across the 27 Member States. The EU.Inc would, for the first time, introduce uniform rules on employee share ownership and taxation. In addition, fast, digital and low-cost processes make it easier for investors to invest in start-ups and scale-ups.

Filed in German · English published by the European Commission

Bitkom expressly welcomes the Commissions ambition to deepen the Single Market for connectivity and to modernise the legal framework. The Commission rightly recognises the need to strengthen the entrepreneurial scope for innovation, scale, and resilience in a competitive environment. We especially see merit in the proposals intention to strengthen European spectrum policy.

Open source is a key enabler for Europes digital sovereignty, competitiveness, and cybersecurity. To be effective, EU policy must strengthen Europes capacity to sustain, govern, and adopt open technologies as part of a global ecosystem, addressing existing barriers in funding, procurement, maintenance, and market integration. Please see the attached document for the complete statement.

Bitkom e.V. (Germany's digital association) welcomes the efforts of the European Commission to create more transparency in competition when it comes to environmental claims and to avoid greenwashing. However, in our view, the present proposal for a directive on substantiation and communication of explicit environmental claims (Green Claims Directive) does not appear to be suitable for achieving the objectives…

Titel Ref. Ares(2026)4818540 - 12/05/2026 Revision of the EU Cybersecurity Act Position of the German digital industry on the European Commission’s proposal for a CSA-2 1 Cybersecurity Act 2 Content 1 Summary 3 2 TITLE II: THE EUROPEAN UNION AGENCY FOR CYBERSECURITY 5 TITLE III: EUROPEAN CYBERSECURITY CERTIFICATION FRAMEWORK 8 3 Article 71: Objectives and scope of the European cybersecurity certification framework 9…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Position Paper 2026 May NIS-2 Amendments Summary The NIS-2 Directive set the goal to establish a unified legal framework to uphold cybersecurity in critical sectors across the EU. By defining technical and methodological requirements for cybersecurity risk management measures, it aims to create a harmonised baseline level of protection.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Position Paper June 2025 Cybersecurity Act Revision Summary The Cybersecurity Act (CSA) was introduced in 2019 as a central instrument of the European Union to strengthen the cyber security of information and communication technologies. At the time, there were no other European harmonized requirements for products concerning cybersecurity.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

A central issue in the current debate is the ability to analyse lawfully accessible information at scale. A reliable TDM framework is key digital infrastructure, not only for AI development but also for research, cybersecurity, healthcare and broader economic productivity.

Bitkom highly welcomes the EU Commission's intention to prepare a review of the current framework to foster competitiveness, competition and investment in the European telecommunications market. An EU-wide harmonised market improves the conditions for investment and expansion in the telecommunications sector.

Bitkom supports the establishment of Digital Product Passports and welcomes the draft implementing regulation on the DPP Registry as an important step towards a functioning European DPP infrastructure. The draft provides a useful basis for implementation, but several aspects require further clarification to ensure legal certainty, cybersecurity, operational resilience and practical scalability for companies.

Please find Bitkom's five principles for the functioning of the digital economy and fair competition attached: 1.) Retain core competition mechanics: Scope should be based on objective evidence. 2.) Taking diversity into account: Obligations should not follow a one size fits all approach. 3.) Reliable rules: Application and rules must be clear and targeted.

The European Standardisation System (ESS) continues to be a well-functioning framework that ensures Europes global competitiveness by delivering high-quality standards. The New Legislative Framework (NLF) has been pivotal to the success of the Single Market.

Bitkom welcomes the European Commissions initiative to develop the EU Quantum Act. The Act is a key step in implementing the Quantum Europe Strategy and in creating the framework conditions needed for Europe to remain competitive in quantum technologies. The EU Quantum Act should strengthen coordinated and strategic action across Member States.

The EUs digital regulatory framework has expanded rapidly over the past decade, including the GDPR, Data Act, Data Governance Act, Digital Services Act, and Digital Markets Act. While each of these initiatives pursues legitimate objectives, their cumulative effect has created a regulatory framework that is increasingly complex and difficult to navigate.

Bitkom supports the European Business Wallet in principle as an important element of a European trust infrastructure for digital business and administrative processes. However, against the backdrop of the current negotiations on the proposed regulation and the recently discussed amendments, Bitkom sees a need for targeted improvements: Clear and swiftly adopted implementing acts are required, along with ambitious…

In the attached position paper, Bitkom highlights the key challenges organizations face in B2B and B2G contexts and to some extent in B2C, B2M and B2E and outlines essential use cases alongside technical and legal requirements to be integrated into the forthcoming EU legislation on the EUBW.

Bitkom welcomes the European Commissions call for evidence on the development of a Digital Action Plan for the water sector. We consider this initiative an opportunity to align the digital transformation with sustainable water management, resource protection, and European competitiveness.

Bitkom welcomes the opportunity to contribute to the European Commission's Call for Evidence (CfE) regarding the evaluation of the Audiovisual Media Services Directive (AVMSD). In a rapidly evolving media environment, this evaluation represents a crucial moment to assess the effectiveness and relevance of the current regulatory framework.

Bitkom supports the EU Commission's goal of further digitalizing the transport sector and making things noticeably easier for citizens and mobility providers in the EU by digitalizing vehicle registration documents and processes.

Bitkom read the Commissions «Proposal for a [Directive/Regulation] [] as regards the digitalisation and alignment of common specifications» with great interest and would like to provide input. Shortly summarized, we believe: -> Common Specification should be designed as a clearly limited fallback option in alignment of Art. 20 of the Machinery Regulation and developed with industry involvement.

The Digital Decade policy programme has established essential goals and measurable indicators for assessing Europes progress in digital infrastructure, digital skills, the digital transformation of businesses, and the digitalization of public services. It is an important monitoring system that should be promoted and improved.

Bitkom appreciates the opportunity to give feedback on the Proposal for a Regulation on Promoting Fairness and Transparency for Users of Online Intermediation Services, voicing the consolidated opinion of its affected members as stated in the attached position paper.

Zusammenfassung Bitkom unterstützt das Vorhaben der Europäischen Kommission, die Richtlinien über die Zusammenarbeit der Verwaltungsbehörden im Bereich der Besteuerung (DAC) in einer Neufassung zu konsolidieren und zu vereinfachen. Ziel muss eine klarere, effizientere und kostensparende Umsetzung sein.

Bitkom stresses that qualified electronic archiving must be clearly defined in line with eIDAS, with archiving and preservation treated as distinct but complementary services. Moreover, a future-proof framework should build on modern, widely accepted standards that support cross-border recognition and provide clarity for providers and users alike.

The success of the cross-border identification and authentication mechanism is a direct precondition for the value MyHealth@EU is intended to deliver to patients and clinicians. If patients cannot be reliably identified across borders, and if healthcare professionals cannot be securely authenticated in a way that works in clinical practice, the framework will not deliver its intended benefits.

Bitkom highlights the need for greater precision and practicality in the draft Implementing Act on qualified electronic ledgers. Clear and consistent terminology, differentiated definitions, and the correction of technical inaccuracies are essental to avoid ambiguity. At the same time, requirements for supervision must remain workable in practice, particularly in situation where urgent security updates are needed.

From Bitkoms perspective, this initiative amending Commission Implementing Regulations (EU) 2024/2979, 2982, 2977 and 2980 should primarily ensure that highly detailed technical specifications are not statically embedded in the Annexes of the CIRs.

Estimated savings, complexity & duty cycle Industry would caution on the increase of the estimated energy saving potential. Projecting PC usage and energy consumption growth to 2030 is meaningless; projections involving digital technology further than five years ahead provides no degree of accuracy or certainty.

From Bitkoms perspective, clearer provisions are needed on wallet and device binding, closer alignment with established European standards, and a flexible identity proofing approach besides the eID as the reference method for identification that supports fully automated onboarding and hybrid onboarding when strict security requirement are not met in well-defined and secure scenarios.

From Bitkoms perspective, this initiative amending Commission Implementing Regulation (EU) 2025/848 should ensure coherence of scope and legal clarity. Structural adjustments must be transparent and proportionate to avoid interpretative uncertainty. At the same time, the framework should remain technically flexible and avoid rigid legal embedding of rapidly evolving specifications.

Effective and efficient export controls are vital for the European economy, ensuring security and economic stability. At the same time, the experience of recent years, in particular following Russia's illegal invasion of Ukraine, has shown that European export controls need to be adapted. The White Paper highlights the current problems with European export controls and offers an opportunity to solve them.

Bitkom underlines the importance of keeping compliance and security requirements for qualified trust service providers proportionate and practical. Excessive or overly broad notification duties, redundant provisions, and unclear references risk creating legal uncertainty, administrative overload, and operational inefficiencies without adding supervisory value.

Estimated savings, complexity & duty cycle Industry would caution on the increase of the estimated energy saving potential. Projecting PC usage and energy consumption growth to 2030 is meaningless; projections involving digital technology further than five years ahead provides no degree of accuracy or certainty.

From Bitkoms perspective, the draft Implementing Act amending Commission Implementing Regulation (EU) 2025/1569 requires further clarification to ensure legal certainty, interoperability and consistent implementation across Member States.