Why we Need a Data Exchange Board to Improve the EU Data Governance Act

Missing Puzzle piece

In this blog, aNewGovernance, iSHARE, INNOPAY, International Data Spaces Association, Meeco, MyData Global, SITRA and The Chain Never Stops -  eight organisations of the Data Sovereignty Now movement – explain why the recently published proposal for the EU Data Governance Act is a very good step forward. They also outline their suggestions for further elaboration in order to accelerate the development of a governance framework that will provide true control over personal, business and public data.

Supported by the European Data Strategy, the EU is striving to create a digital single market for the data economy and data sharing that benefits society as a whole. This will be based on European ‘data spaces’ that allow data to flow freely within the EU and across sectors whilst staying true to EU values such as privacy, transparency, self-determination, security and competition.

As part of implementing the data strategy, the European Commission published its proposal for a regulation on European data governance, known as the Data Governance Act. As member organisations of the Data Sovereignty Now (DSN) movement, we applaud this proposed legislation because it contains several essential elements for enabling data sovereignty, including:

Definition Data Sovereignty and Soft Infrastructures
  • People, businesses and public-sector bodies should have control over data about them.
  • Data and data spaces need to become interoperable across sectors.
  • Recognition of current and future data intermediaries (called ‘data sharing services’ in the regulation) such as data operators, gateways and platforms within data ecosystems.
  • Balanced pan-European governance, under the leadership of the so-called Data Innovation Board.

The data sharing services or data intermediaries have to comply with still-to-be-defined binding requirements. Once created, the requirements for data sharing services will offer a basic level of compliance, legal conditions and last but not least a unified and inclusive data experience across data spaces, for all people, businesses and governmental users of data services. The data intermediaries thus ensure that the rights of data subjects (in case of personal data) and other rightsholders are respected and that people, businesses and governments in the various data spaces are empowered to re-use data about themselves.

Hidden Gem: Data Innovation Board

Chapter VI of the proposed Data Governance Act mentions the establishment of a Data Innovation Board that will assist and advise the Commission on the strategic matters in data governance, such as enhancing interoperability and developing the actual requirements applicable to data sharing providers. We regard this Data Innovation Board as a ‘hidden gem’ in the proposed regulation since it could act as a launching pad for many critical developments of soft infrastructure in the future.

Furthermore, in our view, the Data Innovation Board – with its strategic focus – should be complemented by another governance body focusing on the more tactical and operational aspects of enabling data sharing and interoperability in practice. This combination of strategic guidance and operational efficiency would ensure accomplishment of the real aims: to create trust in data sharing, and to co-create, organise and stimulate adoption of decentralised access to and exchange of data while maintaining transparency, security and interoperability.

This operational governance body could be called the Data Exchange Board. It should be tasked with agreeing upon the initial requirements for the data sharing services and updating the requirements going forward, driven by the needs of people, markets and public-sector use cases. We recommend building upon the existing science, research and practical experience from interoperable data sharing (e.g. IHAN, IDSA, Data Sharing Coalition, iSHARE and MyData Operators, to name but a few) and merging best practices to organise this on a pan-European scale. The Data Exchange Board would create the living link between the aims of the regulation and the means and best practices that are emerging in the real-life use cases. We believe that this connection will be essential to drive large-scale adoption of the data sharing services in the coming decade.

The relationship between the strategic Data Innovation Board and the proposed operational Data Exchange Board, with the European Commission on one side and the practitioners on the other.
Figure 1 – The relationship between the strategic Data Innovation Board and the proposed operational Data Exchange Board, with the European Commission on one side and the practitioners on the other.


We believe that the European data governance framework must be designed to establish and provide continuity to the soft infrastructure for data sharing. The still-to-be-established Data Innovation Board will be elemental in achieving this aim. We recommend that this should be further complemented by a Data Exchange Board that will focus more on the tactical and operational level, both in the sunrise of the soft infrastructure and in the future operational growth and innovation phase of the decades ahead.

Our vision on the key steps to achieve data sovereignty through soft infrastructures:

  1. Soft infrastructure for data sharing: Develop functional, legal, technical and operational agreements that support the most pressing use cases of people, businesses and governments in the various data spaces.
  2. Based on existing best practices: Much of the groundwork on soft infrastructure for data sharing has already been done in the past decade by researchers and business practitioners around the world. The initial version of the requirements for data sharing services should include these best practices.
  3. Living form of standardisation: The soft infrastructures are a living form of standardisation and should be allowed to evolve over time; the common way of dealing with data must continuously respond to market needs and applications.
  4. Operational governance: To include the best practices from the practitioners and enable the continuous evolution of the standardisation, a sound governance model should be set up which represents public-sector, private-sector and people’s interests.
  5. Initial implementation: The organisations that have created the agreements should roll out and implement the first version of the soft infrastructure. This will provide referenceable integrations and, importantly, validate market adoption.
  6. Roll-out and adoption: The soft infrastructure should then be extended across all sectors over the coming decade.

We are keen to start the dialogue with policymakers and politicians to achieve this together. Feel free to contact us for more details or to reflect on or discuss how a governance framework can help to achieve data sovereignty and advance the European digital economy.


INNOPAY supports the Data Sovereignty Now campaign which underlines the importance of self-control over data (‘data sovereignty’) by organisations and individuals


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