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Please find attached our detailed feedback. Summary: The development of high-value datasets (HVDs) in specific fields will have major positive consequences for society. Such datasets offer significant potential for citizens and businesses, to help address societal challenges and to develop innovative services and products.

The Ministry of Finance of Finland welcomes the long-expected draft and the opportunity to comment on it. Interest in Finland towards the draft has been high and we have encouraged Finnish stakeholders to provide their own comments. Innovations and new types of business can be encouraged by providing high quality open data, free of charge, via APIs.

We very much support the Commission’s plan to organize public consultation, to inform citizens and stakeholders as well as to ensure an opportunity to provide feedback. As regards to the policy options, we would like to stress that the market effort has not yet been sufficient, therefore we would support more active role to be taken by the policy makers.

DIGITALEUROPE believes the baseline policy option detailed in the inception impact assessment is the most suitable to advance instant payments today in Europe. At this stage, monitoring the market evolution and assessing the effects of voluntary efforts is the most sensible decision to foster the growth of instant payments, while the industry works to address their challenges. Please see attached our response.