Open-Xchange AG

Open-Xchange would like to thank the Commission for the opportunity to participate in its call for evidence on the digital package on simplification. We would like to deal more specifically with the "cookie popups" issue, as we find it not just important in itself, but an example of what can go wrong in digital regulation.

Open-Xchange would like to thank the Commission for the opportunity to participate in its call for evidence on the revision of European public procurement rules. Given our expertise, we focus our contribution on the digital sector. We think the European dependence on foreign suppliers and platforms in the Internet sector is unbearable, and we must act now to promote European alternatives.

Open-Xchange would like to thank the Commission for the opportunity to participate in its call for evidence on the functioning of public procurement directives. We think that the current framework has not ensured that public money is spent strategically to contribute to Europe's digital autonomy.

Open-Xchange would like to thank the Commission for the opportunity to participate in its call for evidence on open digital ecosystems in Europe. We think the open-source paradigm naturally aligns with Europe's objectives of digital autonomy. As a European open SME, we face problems such as market entrenchment by global proprietary vendors and a lack of venture capital.

Open-Xchange would like to thank for the opportunity to provide comments on the Commission’s proposed text for the new Data Act. We generally support the Commission’s objectives and the current proposal, but we would like to address the issue of data sharing obligations for software and hardware products operating in the homes of European consumers, such as browsers, smartphone apps, smart TVs, IoT products etc…

Open-Xchange would like to thank for the opportunity to provide comments on the Commission’s proposal for the new Digital Services Act. We generally support the Commission’s objectives and stand in favour of enacting a new regulation building on the draft.

Open-Xchange, as the leading European open source software company in the email and DNS space, commends and supports the Commission's effort to address the issues related to illegal and harmful online content. We generally agree with the inception impact assessment as published, and we stress the importance of bringing services without legal establishment in the EU into the scope of the upcoming rules, to ensure…

Open-Xchange would like to thank for the opportunity to provide comments on the Commissions proposal for a Cyber Resilience Act, specifically from the viewpoint of the European open-source software industry. While we support the objective of increased security in digital products, we think that the proposal suffers from a misunderstanding of the nature of software.

Open-Xchange would like to thank for the opportunity to provide comments on the Commission’s proposal for the new Digital Markets Act. We generally support the Commission’s objectives and stand in favour of enacting a new regulation building on the draft. We nonetheless raise some issues building on our first-hand experience in one of our core fields of activity, Internet email and messaging in general.

Open-Xchange, as the leading European open source software company in the email and DNS space, commends and supports the Commission's effort to address the gatekeeping power of big Internet platforms and the threat it poses to competition, digital sovereignty and individual rights.

Open-Xchange, as the leading European open-source software company in the email and DNS space and the service provider of choice for some of the largest Internet access providers in Europe, would like to thank the Commission for the opportunity to participate in its consultation on the guidance on how to apply the Cyber Resilience Act (CRA).

Open-Xchange would like to thank for the opportunity to provide comments on the Commission’s proposal for a new directive enhancing cybersecurity measures, replacing the previous NIS directive. Given our field of expertise and market experience, we will be focusing our comments on the following topics: A. Cybersecurity requirements for email, including end-to-end encryption; B.

Open-Xchange would like to thank for the opportunity to provide comments on the Commission’s proposal for a regulation on fighting child sexual abuse. We generally support the Commission’s objectives, as long as encryption is not weakened, but we are also fully committed to the privacy of our users; we will accept regulatory requirements imposed upon us through a democratic process, but they should be restricted to…

Open-Xchange welcomes the Commission's initiative to strengthen the fight against CSAM-related content online. We attach to this submission our full contribution to this consultation, but for ease of reading, we would like to summarize here our main points.

Open-Xchange would like to thank the Commission for the opportunity to participate in its call for evidence on the review of the Digital Decade programme. We think that the current targets and objectives remain relevant, but they lack coverage of the newly emerging need for European digital sovereignty.