Digital Decade policy programme

European Commission · Have your Say · Initiative 15514

Review of the
Digital Decade policy programme

Digital Decade 2030 · Statement of 28 October 2026

Statement by GISAD – Global Institute for Structure relevance, Anonymity and Decentralisation · EU Transparency Register No. 244298340978-40

Not every cloud makes you sovereign: the Digital Decade targets must measure independence, not just adoption

The Digital Decade Policy Programme 2030, adopted in 2022, sets measurable targets for Europe’s digital transformation in four areas: digital skills, secure and sustainable digital infrastructures, the digitalisation of businesses and the digitalisation of public services. More than €288 billion have been mobilised through national roadmaps with over 1,900 measures. The programme review was due by 30 June 2026; the Commission has announced a further review of the 2030 targets for 2027.

GISAD – Global Institute for Structure relevance, Anonymity and Decentralisation, the standards institute of the Trusted WEB 4.0 concept – welcomes the review and the choice of its four target areas. Yet the 2026 State of the Digital Decade report confirms a structural problem: the programme measures adoption, not sovereignty. The EU misses its targets precisely where sovereignty is at stake – 9 % instead of 20 % of the global semiconductor market, and significant dependence on non-European providers in cloud services, cybersecurity and other strategic technologies.

1. Make the cloud, AI and big data target for businesses measurable by origin

If 75 % of EU companies adopt cloud and AI services that sit with US hyperscalers – CLOUD Act included – the target is met and sovereignty is lost all the same. GISAD recommends supplementing the adoption targets with a target figure for structural independence – for example, the share of critical infrastructures running on systems without US dependence in their core infrastructure. The European Digital System (EU-D-S), with one trustee per discipline, shows that European providers can carry this alternative: every Digital Decade target can be achieved with European technology.

2. Digital skills are a question of participation, not of training

55.6 % instead of 80 % of adults with basic digital skills – this gap is not closed by courses, but by structures that do not demand proficiency in the ways of a profiling economy. getmySense transfers the principle of participation instead of social welfare into the digital world with 2,500 written languages: those who take part in their own language and in clear categories need no algorithm literacy. Participation lowers the barrier – especially for older people, whose exclusion from digital life is a measurable health risk. The skills target remains important, but it must be complemented by a participation target.

3. Bandwidth is not resilience

Gigabit and 5G measure speed, not survivability. The CrowdStrike outage, the Charité incident, the Baltic cable sabotage and the Starshield throttling show: the bottleneck is not throughput, but central dependence. The review should anchor resilience as a target dimension of its own – decentralised networking that keeps functioning when central infrastructures fail. Decentralised digitalisation does not replace a single cable – but it takes the catastrophic effect out of every cable break.

4. Public services WAN-anonymous instead of state-centred

Today, the digitalisation of public administration means central data pools and a digital identity for everything. The EU-D-S shows the third way: citizens use public services WAN-anonymously, with assignment solely via the trust station – powerful administration without an all-round profile. And the review’s aim of strengthening structured channels for regions, cities and local actors finds its model in the EU-D-S: trust stations as points of contact in disputes are local, citizen-facing structures.

For the announced 2027 target review, GISAD recommends assessing a parallel system for the first time: the European Digital System (EU-D-S) with WAN anonymity, trust stations, participation via getmySense and one trustee in each of 40 disciplines. The EU can participate as a passive member at eye level in accordance with the EU-D-S Constitution of June 2025.

A 2030 horizon that only measures the adoption of the existing network will make Europe more digital – but not more sovereign.

GISAD – Global Institute for Structure relevance, Anonymity and Decentralisation (in formation) · registered in the European Commission Transparency Register, No. 244298340978-40 · www.gisad.eu

Sources: European Commission – Initiative 15514 (Review of the Digital Decade policy programme) · European Commission – 2026 State of the Digital Decade package · European Commission – Digital Decade Policy Programme · EU-D-S Constitution (June 2025)

Statement of 28 October 2026 · Concept: Trusted WEB 4.0 · Target system: European Digital System (EU-D-S)

Audiovisual Media Services

European Commission · Have your Say · Initiative 15752

Audiovisual Media Services:
Evaluation and Update of EU Rules

AVMSD Review · European Democracy Shield · Statement of 28 October 2026

Statement by GISAD – Global Institute for Structure relevance, Anonymity and Decentralisation · EU Transparency Register No. 244298340978-40

Diversity needs structure, not just regulation: the AVMSD review should think the media transition structurally

The European Commission is evaluating the Audiovisual Media Services Directive (AVMSD) and preparing its review, due by 19 December 2026 under Article 33 of the Directive. The consultation process – a call for evidence (November/December 2025) and a public consultation (February to May 2026) – is complete; the evaluation report and, where appropriate, legislative proposals are now being drawn up. The review is part of the Commission’s commitments under the European Democracy Shield.

GISAD – Global Institute for Structure relevance, Anonymity and Decentralisation, the standards institute of the Trusted WEB 4.0 concept – welcomes the evaluation and its declared objectives: simplification of the rules, a level playing field between traditional and digital players, better protection of young viewers, and the strengthening of media pluralism. These objectives are right. But the debate largely treats the symptoms of the platform logic instead of questioning its cause.

1. Recommender algorithms are the cause, not the frame, of the problem

Systems optimised for watch time and personalisation inevitably produce sensory overload, bias and an attention economy. Advertising as the dominant financing model reinforces this mechanism, because every profile has a market value – including the profile of a child. The European Digital System (EU-D-S) demonstrates the alternative: use by categories instead of personality profiles. The Finder-Suche with around 1,000 categories – derived from the category system of a video rental library, not from an advertising network – preserves diversity because users follow categories, not data streams. Those who want diversity must structure diversity: 40 disciplines, each with its own trustee, are a more lasting economic and cultural guarantee than any quota.

2. Protecting minors without profiling

The protection of young viewers is currently being discussed inside a system that seeks to measure them. WAN anonymity reverses this logic: a system that profiles nobody – including children – and governs assignment exclusively via the trust station needs no filter architecture built on profiles, because there are no profiles. Structural personality protection is more effective than any downstream filter.

3. Disputes belong before trust stations, not before platform courts

Article 18 of the European Media Freedom Act shows the dilemma: media content is removed or downgraded by platforms, and media providers fight against arbitrariness. In the EU-D-S, trust stations are the points of contact in disputes – a conciliation structure with a defined procedure instead of autonomous gatekeeper decisions. This is media pluralism as a procedural guarantee, not as an algorithm parameter.

On the three policy options under consideration: Option 1 – leaving the AVMSD unchanged – underestimates the transformation under way. Option 2 – targeted adjustments on influencers, prominence rules, advertising and the protection of minors – is a viable intermediate step. Option 3 – transformation into an EU content directive or regulation – carries centralisation risks that can run counter to the very objective of pluralism. GISAD recommends anchoring the examination of a structural alternative in all three options: a cross-media category order with trustees, WAN-anonymous use and trust stations as conciliation bodies – as a parallel system alongside the existing media order, with the EU participating as a passive member at eye level in accordance with the EU-D-S Constitution of June 2025.

The European Democracy Shield wants resilient democracies. Democratic resilience does not arise from regulated platforms, but from structurally diverse media – and the structure for this is ready.

Sources: European Commission – Initiative 15752 (AVMSD evaluation and update) · European Democracy Shield (IP/25/2660) · European Commission – Revision of the AVMSD · EMFA Art. 18 – Guidelines on protecting media content · EU-D-S Constitution (June 2025)

Statement of 28 October 2026 · Concept: Trusted WEB 4.0 · Target system: European Digital System (EU-D-S)

Simplification digital package and omnibus

GISAD · Statement

Global Institute for Structure relevance, Anonymity and Decentralisation

Have your Say · European Commission | Digital Society / Digital Systems

Initiative 14855 – „Simplification digital package and omnibus“ (Digital Omnibus) · 28 October 2026

Simplification, yes – weaker personality protection, no: the Digital Omnibus regulates the wrong web

On 19 November 2025, the European Commission proposed its Digital Omnibus, the simplification package for the EU’s digital rulebook. It consists of two proposals: the Digital Omnibus on AI, which amends the AI Act, and a horizontal Digital Omnibus, which amends the GDPR, the ePrivacy Directive, the Data Act and the NIS2 Directive while repealing the Data Governance Act. The declared goal is to cut administrative burden by at least 25 % – and 35 % for small and medium-sized enterprises. The AI part has been in force as Regulation (EU) 2026/1744 since 27 July 2026. The GDPR and data part is still in first reading – and it is the most contested.

GISAD – Global Institute for Structure relevance, Anonymity and Decentralisation, the standards institute of the Trusted WEB 4.0 concept – welcomes the declared objective of simplification. Bureaucracy reduction, consolidation of contradictory rules and relief for smaller companies are overdue. But in two central points the proposal confuses cause and effect.

1. Weakening the concept of „personal data“ is the wrong path

The proposal softens the definition of personal data, in particular for pseudonymised data, extends the use of „legitimate interest“ as a legal basis for AI training, and relaxes breach notification from 72 to 96 hours. Consent fatigue is not a protection-standard problem – it is an architecture problem. A web that relates every movement to the person inevitably produces consent banners, whether with one click or with three. Trusted WEB 4.0 demonstrates the alternative: WAN anonymity, no cookies, no privacy settings, and assignment only via trust station key sets. Those who structurally avoid personal reference do not need a de facto deregulation of the GDPR protection level. The European Data Protection Board and the European Data Protection Supervisor have strongly urged the co-legislators not to adopt the proposed GDPR changes – GISAD concurs with this position.

2. Postponing high-risk AI obligations while incidents are rising is risky

Under the adopted amendments, stand-alone high-risk AI systems are not subject to binding obligations until 2 December 2027, and systems embedded in regulated products not until 2 August 2028 – while incidents involving autonomous AI agents continue to accumulate. The Hugging Face attack of 2026 showed where this leads. AI security needs binding breakout and control mechanisms – not an extension of self-regulation. The Finder-KI-Escape switch of the European Digital System (EU-D-S) proves that breakout protection is technically feasible: step-by-step release for critical actions, signed instance numbers issued by the trust station, measurement outside the manipulable area, supplemented by an event-driven, read-only concept-fidelity audit under GISAD standards.

3. The package centralises where decentralised structures are needed

„Once only“, central data pooling, a single reporting entry point and expanded central powers of the EU AI Office all increase single points of failure. The CrowdStrike outage and the Charité incident showed what a single central failure can do to an entire economy and a hospital. Decentralised networking does not replace a single cable – but it takes the catastrophic effect out of every cable break.

GISAD welcomes the consolidation of the data rules into two central laws and the declared intention to give European AI companies preference – this shares the goal of digital sovereignty. But sovereignty does not arise from re-regulating the old web; it arises from building a parallel system: the European Digital System (EU-D-S) with WAN anonymity, trust stations, participation via getmySense in 2,500 written languages, and standardisation by GISAD. The EU can participate as a passive member at eye level – the EU-D-S Constitution of June 2025 provides for exactly this form of participation.

The Digital Fitness Check, which the Commission is currently using to examine the cumulative impact of all EU digital rules, would be the right place to assess this alternative systematically for the first time. Re-regulating the centralised, person-related web will not deliver digital sovereignty. A trust-based, structurally anonymous and decentralised architecture can.

GISAD – Global Institute for Structure relevance, Anonymity and Decentralisation (in formation) · registered in the European Commission Transparency Register · www.gisad.eu

Sources: European Commission – Initiative 14855 (Digital Omnibus) · Regulation (EU) 2026/1744 (Digital Omnibus on AI) · COM(2025) 837 (Digital Omnibus proposal) · EU-D-S Constitution (June 2025)

Statement of 28 October 2026 · Concept: Trusted WEB 4.0 · Target system: European Digital System (EU-D-S)