Document formats: a mystery to many

Euro-Office’s announcement – which sees IONOS, Nextcloud and other companies coming together to create a European alternative to office productivity software – has predictably sparked a wave of comments. Most of these focus on the issue of licensing: is the code open source? Who controls the repository? What are the conditions for forking, modifying or implementing it?

While these are all valid questions, they fail to address the most important issue. The fact that almost no one is asking the question that matters tells us something significant about how the debate on digital sovereignty has been framed and who benefits from that framing.

A licence tells you who owns the software, while the format tells you who owns the data

A licence can be renegotiated, modified or updated. The history of FLOSS is full of projects that have changed governance models, divided communities, or changed course under new management. Licence terms are important, but they operate at the level of the software artefact.

The native document format operates at a completely different level. It is the encoding level of every document produced, archived, and exchanged by institutions that adopt the software. It is the invisible structure of administrative memory within which public documents exist for years, or even generations. It is the infrastructure.

If Euro-Office is supplied with OOXML as the default native format – even if it is wrapped in an open licence, hosted on European servers or governed by a European legal entity – every document drafted by public administrations, schools and institutions will be written in a format designed around the behaviour of a single vendor’s application.

OOXML is governed by a specification that is so complex and internally inconsistent that it compromises interoperability. As if that were not enough, it is optimised for backward compatibility with Microsoft Office rather than for seamless exchange between systems.

The licensing issue asks: who controls the code? The format issue asks: who controls the data? These are not equivalent situations. The latter has long-term implications for public archives, administrative continuity, and the practical significance of vendor independence.

For thirty years, the FLOSS and digital rights communities have been working on licences based on the fundamental principle that a licence equals freedom. This work has produced enormous value, but it has also created an unintentional blind spot.

Microsoft has spent decades conducting one of the most effective user education campaigns in the history of the software industry. However, what it has taught is dependency. Consequently, a generation of users, administrators, developers and even FLOSS advocates has grown up treating OOXML documents as the natural unit of document exchange — just like water flowing from a tap. OOXML files are not perceived as a lock-in mechanism, but as normal documents.

This is an incredible strategic achievement. Microsoft has managed to transform a proprietary file format, which was designed to replicate the behaviour of its own applications rather than enable transparent content exchange, into an interoperability standard.

Compatibility with the OOXML format is not viewed as a courtesy to the monopoly holder; rather, it has become a feature that alternative software must provide to prove its legitimacy. Lock-in has been transformed into an advantage: users are not trapped in Microsoft’s format; they are simply using the format that everyone else uses.

The FOSS community, which should be particularly vigilant about such dynamics, has often uncritically accepted Microsoft’s approach. Indeed, when evaluating an alternative productivity suite, the first question is often about the ability to open OOXML files rather than about the native format and whether it enables interoperability. Unfortunately, the alternative is judged according to criteria subtly dictated by Microsoft.

Consequently, format policy is treated as a secondary technical issue rather than the major political issue it really is. Meanwhile, Microsoft has pursued a precise and successful strategy of securing OOXML certification as an ISO standard to define it as ‘open’, while ensuring that licensing issues take precedence over format issues.

The result is that “supporting ODF” has become a box to tick rather than a specific commitment. This explains why all office suites today claim to support ODF. The practical implications of this support – such as whether ODF is the native or default format, or the format in which documents are created and stored without user intervention – are rarely considered, let alone addressed.

The test that matters

Euro-Office presents itself as a genuine European alternative: an infrastructure project for digital sovereignty. This claim deserves to be put to the test in terms of whether institutions will manage to free themselves from Microsoft lock-in, or if they will simply reproduce it under a different banner.

The test is simple and admits only one answer: ODF will be the native format of Euro-Office; the format in which documents are created, stored, and exchanged by default without user configuration or technical intervention.

Not: Euro-Office supports ODF because, in a nominal sense, everything supports ODF. Users can save in ODF format because this is a compatibility feature, not a commitment to true digital sovereignty.

If the answer is yes, then Euro-Office represents a significant structural break with the dominant proprietary format. However, if the answer implies “compatibility”, “user choice”, “transition paths” or “broad format support”, then Euro-Office is, regardless of the licence, a server migration that leaves Microsoft’s lock-in on data unchanged.

Digital sovereignty is not achieved by changing who hosts the software, but by changing the format in which data is encoded. European institutions, public administrations, and civil society organisations considering Euro-Office deserve a direct and immediate answer to this question before making any further commitments.

ODF has to be native, default, and by design.

Since its foundation, the Document Foundation has supported ODF as an open standard for document exchange. ODF (ISO/IEC 26300) is the only document format standard designed from the outset to ensure interoperability, long-term preservation, and total vendor independence.

Euro-Office: sovereign in name only, or in reality too?

The announcement of the Euro-Office is welcome news. The coalition is credible, the governance is sound and the timing is perfect. Europe needs office software, and The Document Foundation is delighted to see such significant players allocating resources to make it happen.

However, we have a question. It is not meant to be hostile, but it is the only question that matters.

What is the native document format of Euro-Office?

The press release promises full compatibility with Microsoft formats. We are well aware of the logic behind migration: organisations moving away from Microsoft need to be certain that their documents will survive the transition. But “full compatibility with Microsoft formats” is certainly not a definition of sovereignty, but rather the definition of a different kind of dependency.

OOXML is a format designed, controlled and managed solely by Microsoft. Building a European office suite prioritising compatibility with OOXML means ensuring that the European document infrastructure remains subordinate to architectural decisions made in Redmond. The hosting moves to Europe, but the lock-in remains in Redmond.

The alternative exists, is mature and is a law in several European jurisdictions. ODF, the Open Document Format, is an ISO standard developed through an open and transparent process, which is not controlled or managed by a company. The German Deutschland-Stack has made it mandatory, and the EU Commission has approved it. It is not the LibreOffice format, but a European public good.

The Euro-Office press release does not mention ODF even once.

We are not asking Euro-Office to abandon support for Microsoft’s proprietary format. LibreOffice itself reads and writes OOXML: compatibility is a necessity for users, not an ideological concession. We are asking whether ODF will be the native format, the one in which documents are created, archived and exchanged between European public administrations.

This distinction is fundamental, and the time to define the native document format is now, before the architecture is finalised and the implementations take place. If necessary, we are here to help with the deployment of the ODF standard as native document format.

The coalition has the credibility and resources to build something truly innovative. We hope it will use them to build a project of sovereignty and not merely a tool for server migration, flying a European flag but with a lock-in firmly rooted in Redmond.

The Document Foundation is a non-profit foundation and the home of LibreOffice, the world’s leading open-source office suite. LibreOffice implements ODF as its native format and supports a wide range of document formats, including the import and export of OOXML.

Open Letter to European Citizens

The door to digital sovereignty is open, please come in

For decades, a community of developers, activists, researchers and public officials has quietly worked on the idea that free and open-source software based on open standards is not only the best technical choice, but also the only one compatible with democratic governance.

We have created the necessary tools, overseen migrations and provided user training. We have also drafted policy documents and presented them to committees.

We have documented the consequences of public documents being readable only by software developed in a single country, managed by a single company and subject to the laws of a different jurisdiction, as well as the commercial decisions of a board of directors.

The French gendarmerie, the Austrian Ministry of Defence and the German state of Schleswig-Holstein – to name but a few examples – have taken action, alongside regions, provinces and cities across Europe.

We have always been here, and not with a product to sell, but with the knowledge, patience and sincere conviction that public institutions belong to the public, and that this also applies to their digital infrastructure.

Sometimes we were listened to, but far more often we were merely tolerated, at best with a smile that seemed to say: “I know, but what can I do about this?”

And now, suddenly, the situation has changed, and not because the arguments have changed – there was no need for that – nor because the technology has changed, as it was already excellent.

The situation has changed because the geopolitical balance has shifted, and the dependence that once seemed a convenience now appears for what it has always been: a structural vulnerability.

We are glad that this moment has arrived, and we like to think that this clarity – which the evidence never managed to achieve – is also down to us, and not just the geopolitical crisis.

But we ask European citizens, and through them those who govern European countries, to understand one extremely important thing: the door to digital sovereignty does not open simply by choosing different software, but by understanding what sovereignty actually entails.

It requires open document formats, not as a preference, but as a legal and technical guarantee that a document produced today will be readable in thirty years’ time, by any compliant application, without the permission of any company. The format is not a detail, but the foundation.

It requires open fonts, because a document displayed differently on different systems is not an interoperable document, regardless of the standard it claims to follow. The display layer is just as important as the data layer.

It requires continuity of expertise: the people and institutions that have carried out this work, often without recognition and sometimes without resources, are not a lobby to be managed but a valuable repository of knowledge to be engaged.

It requires honesty about what “open” means. A coalition that speaks of digital sovereignty but chooses as its default document format one designed to replicate the behaviour of proprietary software is not building sovereignty but a new dependency under a different banner.

We have been here for years, and we will still be here for years to come.

The FLOSS ecosystem did not need a geopolitical crisis to believe in open standards. We have always believed in them, because they are right—technically, legally, and democratically.

Now that Europe is ready, we have just one request: listen to us carefully, unlike what you have done in the past. The lesson is not simply “use free and open-source software”. The lesson is: understand why it is important, and understand it thoroughly.

The tools exist, the knowledge exists, and above all, the community exists.

What happens next will depend solely on you: Europe’s digital sovereignty could become a genuine architectural commitment or remain yet another rebranding of dependency.

We hope, and would like to be sure, that you choose the first option.

Over the coming weeks, four articles will explore these topics in depth: the architecture of document formats, the hidden politics of font rendering, lessons learned from real-world migration experiences, and what a credible European policy on open standards would actually look like. We invite you to read them.

ODF is the future, OOXML is the past

Whenever a user, a government, a school or a business chooses the format in which to store and exchange its digital documents, it is not merely making a technical decision, but is placing a bet on the kind of digital infrastructure on which it will depend in the future.

In this sense, ODF and OOXML are not two equivalent options on the same shelf, but two radically different solutions: one geared towards a future of openness, interoperability and digital sovereignty, and the other towards a past of defending a vendor’s dominant market position through user lock-in.

ODF: designed to be open and transparent

Open Document Format was conceived from the outset to be an open standard. It was designed and developed by the community under the auspices of OASIS, and subsequently ratified by ISO, to be implemented by anyone, on any platform, without royalties, without hidden dependencies and without the permission of any single company.

These are not trivial technical details, but a statement of political and economic strategy embedded within the format itself.

ODF is based on a clean XML schema, easy to read even by non-technical users and reusable. Colour naming follows standard web conventions, and its architecture reuses components from widely adopted open standards. The format was designed to work within an open and transparent infrastructure, not against it.

When a public administration archives a document in ODF format, it can be certain that any future government, any future open-source or proprietary application, and any future platform will be able to read, manage, process and transform that document, because the format specifications are publicly available, and are clear, complete and free from restrictions.

In this sense, the commitment to ODF is a forward-looking one, because it is in line with the evolution of technologies and infrastructure based on open-source software, and with the European agenda on digital sovereignty.

OOXML: designed to preserve the past

OOXML, or Office Open XML, was not designed for interoperability, but to do something very specific: to encode Microsoft Office’s binary formats in XML in such a way as to allow Microsoft to claim compliance with the standard without relinquishing control over users through lock-in.

This origin story is not ancient history, but dates back to the period between 2006 – purely by coincidence, the year the ODF format was approved by ISO – and 2008, the year of the farcical event known as the Ballot Resolution Meeting which led to the approval of OOXML by ISO, and is written into all versions of the specification.

OOXML Transitional, the variant that virtually all Microsoft Office documents use in practice, and the only one available today, is explicitly defined as a compatibility layer with legacy binary formats (the now-forgotten DOC, XLS and PPT, which were nothing more than the saving of working memory to disk), and contains thousands of undocumented elements, format-specific exceptions, and references to legacy Microsoft systems that no third party can fully replicate.

The specification itself acknowledges that Transitional documents may contain elements whose behaviour is ‘legacy’ and whose correct display requires knowledge of Microsoft’s proprietary systems. In short: to implement OOXML Transitional correctly, one must decode thirty years of Microsoft Office history, something that no one except Microsoft can do, and no one ever will.

In this sense, the choice of OOXML is not a gamble but a backward-looking choice, because the format is only open in appearance – but it takes very little, just a bit of goodwill, to realise that it is completely closed – and was designed to be a lock-in mechanism.

Two completely different standardisation paths

OOXML’s path to ISO ratification is a catalogue of everything that should never happen during a standardisation process, starting with the Fast Track method. One comment was: “It will be truly sad if ISO lowers its standards so far that it will accept this monstrosity”.

Another comment, from a member of the ISO Technical Committee that approved OOXML, sums up the format’s problems: “The trouble with OOXML is not just that the document itself is monstrously huge. The current OOXML format has a number of technical problems which have been listed in detail elsewhere. Another problem is that the specification itself is not written as a standard, but more as the sort of technical documentation you’d expect to find for a commercial product. This will cause serious interoperability problems in practice, and since interoperability is the whole point of a standard, that’s not acceptable”.

The market has confirmed what the standardisation process had sought to conceal: OOXML Transitional never delivered the interoperability it promised, and this is confirmed by content loss, rendering differences and various other incompatibilities between Microsoft Office’s implementation and those of third parties, which are persistent and still documented today. A true standard should be perfectly reproducible by following its specification, and should not require reverse engineering or trial-and-error approaches.

ODF, by contrast, has followed the standard ISO standardisation process, and for this reason it is the format recommended by the EU Interoperability Framework, by the German Deutschland-Stack – which mandates it alongside PDF/UA at all levels of public administration – and by a growing number of national frameworks, which have independently concluded that true interoperability requires a genuinely open standard, one that meets the definition of a standard such as ODF.

ODF is “forward-looking”

A forward-looking format is one that reduces future dependency, not one that reinforces it. It is a format that can be used without requiring knowledge of a single vendor’s proprietary technologies. It is a format that a public administration can confidently hand over to its citizens, its archives and its successors.

ODF meets these criteria. Its architecture is transparent, its schemas are clean and its governance is genuinely open. Its various implementations demonstrate every day that it can be implemented fully and faithfully by projects that are very different from one another, not because they have reverse-engineered it but because the specifications are complete and easily understandable.

A “backward-looking” format, by contrast, is one that ties the future to the commercial strategies of a single vendor. In this sense, OOXML Transitional is an archaeological artefact that preserves the past at the expense of the future. Organisations that adopt it as a standard are betting – or perhaps merely hoping – that Microsoft’s roadmap, Microsoft’s pricing and Microsoft’s platform choices will remain unchanged indefinitely.

It is a risk that no government, business or institution – or indeed any individual concerned about the long-term integrity of their data – should feel comfortable taking.

The problem with “alternatives” that aren’t really alternatives

The OOXML-based lock-in has a second, more subtle dimension – and one that is far more dangerous for users – which deserves to be explained: the role of software that presents itself as an alternative to Microsoft Office, but which uses OOXML as its default native format.

This is a biased technical choice. When an office suite, whether proprietary or “nominally” open source, sets OOXML as the default format for documents, it does not offer a way out of the Microsoft ecosystem, but actually reinforces it. Every OOXML file created by a non-Microsoft application is a file that validates OOXML as a standard, which feeds into Microsoft’s narrative on interoperability and makes migration away from the Microsoft format stack marginally more difficult.

The real alternatives—applications that take interoperability and open standards seriously—use ODF as the default and treat OOXML as a compatibility layer for import/export, not as a native format. The distinction is important: it is the difference between supporting the ecosystem of open formats and entrusting one’s format strategy to Microsoft’s legacy architecture, whilst calling it openness.

Germany has chosen

The German mandate on the Deutschland-Stack is the clearest signal in recent times of the direction European policy is taking. By mandating ODF at all federal, state and municipal levels, Germany has institutionalised what advocates have been saying for at least twenty years: that open standards are a prerequisite for digital sovereignty, not an optional preference.

The mandate is not against Microsoft, but in favour of sovereignty, because it asserts that government documents belong to the state, and not to a single vendor. Citizens’ data must remain readable forever, and cannot in any way be subject to a software licence. Therefore, the document format must allow public administrations to make an independent choice, and to migrate without the format itself posing an obstacle.

The path forward is clear

ODF is the format of digital sovereignty, and of an open, transparent and interoperable public infrastructure. It was designed for a future in which no single vendor can control the documentary level of civilisation.

OOXML is a format closely tied to Microsoft’s corporate history, translated into XML and ratified amid controversy. It was designed to ensure that the future remains compatible with Microsoft’s past, dramatically reducing freedom of choice for governments, organisations, businesses and individuals, and limiting ownership of their documents.

The Brazilian law that changes everything for schools, and why LibreOffice is the right answer

Brazil’s Lei 15.211/2025, also known as the Estatuto Digital da Criança e do Adolescente (EDCA), came into force on 17 March 2026. It is one of the world’s most comprehensive digital child protection laws, with profound implications for the Brazilian education system.

School administrators, IT managers, and education policymakers now have a legal obligation to consider every technology product deployed in classrooms. LibreOffice, the FOSS office suite developed and maintained by The Document Foundation, is uniquely positioned to meet these obligations by design.

What the law actually requires

The EDCA establishes that every IT product or service directed at children and adolescents – or “likely to be accessed” by them – must guarantee their integral protection, prioritise their best interests and maintain the highest level of privacy and data security (Art. 3). Among the law’s key requirements are:

  • Privacy by default and by design. Products must operate at the highest available level of data protection as a default setting, and any reduction in protection must require explicit, informed consent (Art. 7).
  • No behavioural profiling. Any form of automated or manual profiling of minors based on behaviour, preferences, economic status or location is subject to strict limitations (Arts. 2(V) and 26).
  • No predatory commercial exploitation. Techniques that profile children for advertising purposes are explicitly prohibited, as are design patterns intended to encourage prolonged use (Arts. 22, 17).
  • Digital citizenship education. The promotion of the safe, responsible and critical use of technology is listed as one of the foundational principles for all IT products used by minors (Art. 4, VIII).
  • Transparency and accountability: Technology providers must be auditable and have a legal representative in Brazil, as well as publishing transparency reports (Arts. 31 and 40).

Educational software is not exempt from this law. Any office suite, productivity tool or learning application running on school devices is an IT product as defined in Art. 1, and the access standard is deliberately broad.

Why LibreOffice fits natively

LibreOffice was not designed to exploit the attention of its users. It is not a cloud service. It does not collect usage telemetry by default. It does not profile users. It does not display adverts. There are no engagement algorithms optimised to keep students on the platform.

In the language of the EDCA, it is a product whose architecture embodies the principle of privacy by design (Art. 7), and not because it has been retrofitted to comply, but because there is no commercial incentive for it to do otherwise.

Specifically:

No data leaves the classroom without explicit configuration. LibreOffice runs locally on the desktop, and documents are stored wherever the school chooses. There is no background synchronisation with a vendor’s cloud and no automatic transmission of usage patterns to a third party. It is the school, and not a foreign corporation, that controls the data environment.

It is auditable to the source code. According to the EDCA, technology products must be evaluated for their potential impact on the health and safety of children and adolescents (Art. 8, I). LibreOffice’s source code is publicly available under the Mozilla Public Licence, and can be inspected by any school, researcher or public authority. There is no black box.

There are no manipulative design patterns. The law explicitly prohibits features that artificially extend or sustain product use by minors, such as autoplay, reward programs, non-essential notifications and personalised recommendation systems (Art. 17, §4). LibreOffice has none of these features. It opens a document, it helps the user to work with it, and then it closes. This is what neutral, instrumentally focused software looks like.

It supports digital citizenship education. Art. Article 4, Section VIII of the EDCA establishes the promotion of “digital citizenship and critical thinking for safe and responsible technology use” as a foundational principle. Using LibreOffice in schools is a pedagogical act in itself as it teaches students that software is a tool and not a service that monitors them; that their documents belong to them and are stored in open standard formats (ODF), which any compatible application can read; and that technology infrastructure can be based on transparency rather than restriction.

Open Document Format is digital sovereignty. ODF, LibreOffice’s native format, is an ISO-certified open standard. Documents created by Brazilian students today will be readable ten years from now by any application that respects the standard without requiring vendor permissions or subscription fees, and data being routed through a foreign corporate infrastructure. This is not an incidental feature but a material expression of the EDCA’s guarantee of meaningful access to digital technologies (Art. 5, §2).

In plain terms, schools deploying LibreOffice do not need to read a 200-page data processing agreement to understand what happens to their students’ data. They do not need to complete a vendor questionnaire and wait for a legal team in the US to respond, or to negotiate a contractual carve-out for LGPD (Lei Geral de Proteção de Dados) compliance, or worry about whether a new product feature silently changes the default privacy configuration.

The architecture answers the question. Local software, open code, no telemetry, no profiling and no engagement design are not compliance claims that need to be verified. They are structural properties that can be confirmed by any competent system administrator.
Under the EDCA, transparency is not optional. It is what the law demands.

A Call to Action for Brazilian Education

The EDCA came into force on 17 March 2026. Schools and municipalities that have not yet reviewed their technology stack now have a legal obligation, rather than just a policy recommendation, to do so. The Document Foundation invites Brazilian educators, school administrators and public procurement officers to:

  1. Audit existing deployments of proprietary cloud platforms against the EDCA’s requirements for privacy by default, data minimisation and prohibition of behavioural profiling.
  2. Evaluate LibreOffice as a classroom productivity solution, including the enterprise-ready LibreOffice Technology ecosystem for schools requiring centralised administration and support.
  3. Adopt the OpenDocument Format (ODF) as the institutional open standard for document formats to ensure that student work remains portable, open and free from vendor dependency.
  4. Engage with the community. LibreOffice is developed by a global community of active contributors, including many in Latin America. Brazilian schools that adopt LibreOffice are not just consumers, but they can help to shape the tool that their students use.

The Lei da Criança e do Adolescente is a law that protects children in digital environments, and LibreOffice is a software that was never designed to exploit children. This is not a coincidence, but the consequence of a shared understanding of what technology should be in a democratic society: a tool for users, not the other way around.

The Document Foundation is the non-profit organisation behind LibreOffice. LibreOffice is free to download, deploy and use. For information on enterprise deployments and certified support providers, visit https://www.libreoffice.org or write to info@documentfoundation.org.

Dear Europe: Germany has shown the way forward

Germany has made ODF mandatory as the standard format for documents within its sovereign digital infrastructure. The decision is incorporated into the Deutschland-Stack, the framework governing the development, procurement and management of digital systems for public administration at all levels. This is neither a pilot project nor a recommendation from a working group, but a mandate backed by the federal government and the coalition agreement.

The official document has been published by the IT-Planungsrat, the central political steering body comprising the federal government and state governments, which promotes and develops common, user-oriented IT solutions for efficient and secure digital administration in Germany: https://www.it-planungsrat.de/beschluss/b-2026-03-it.

At this point, the question for all other European governments is clear: what are you waiting for? With this decision, the distinction between those who care about digital sovereignty and those who do not becomes stark.

There are no more excuses

Over the years, public administrations in Europe have accumulated a series of tired excuses, long since overtaken by the facts, for not making standard and open document formats mandatory. Let’s examine them one by one.

ODF isn’t mature enough. ODF has been an ISO standard since 2006. It is now at version 1.4, with active development, a broad ecosystem of implementations and adoption by numerous national governments, the European Parliament and major public administrations worldwide. The maturity argument has long been superseded.

Changing the document format requires staff retraining. The explicit principle of Germany’s sovereign stack is to reduce the effects of lock-in. If the objection is the cost of retraining, you are saying that the commercial interests of the dominant supplier outweigh those of citizens and institutions. This is an acceptable position in the private sector, but inadmissible in the realm of public policy.

The market standard format guarantees interoperability. The market standard, adopted uncritically by public administrations without any verification of its characteristics, is a proprietary format designed for lock-in rather than interoperability, to the extent that it was approved by ISO under the name OOXML Transitional because it contains proprietary elements. ODF, by contrast, is interoperable by definition, and as such has evolved over the years.

We are bound by existing procurement contracts. Contracts come to an end, whilst regulatory frameworks are renewed, and today, faced with the need to ensure European digital sovereignty, the time has come to integrate open standards into them, without waiting another decade for the next renewal cycle, whilst continuing to pay for access to documents that administrations have created using public money.

Today, none of these objections hold water anymore. Germany’s decision demonstrates that even a large and complex federal government can take an important step in the right direction. The obstacles are political, not technical.

The European policy framework

The transition from proprietary formats to standard, open formats for documents, incidentally, is not a radical choice, but an alignment with decisions already taken by European institutions, contained within various laws or regulations that have already been approved.

The European Interoperability Framework (EIF) – the reference document for interoperability in public services – requires the use of open standards and calls for the avoidance of formats that create dependency on a single supplier. The EIF does not explicitly mention Open Document Format, but the logic of the document leads to the choice of ODF.

The Cyber Resilience Act (CRA), the Network Information Security 2 (NIS2) and the Digital Operational Resilience Act (DORA) state that European digital infrastructure must be built using controllable technologies. Documents are the means by which decisions are recorded and communicated, and form part of the infrastructure; they should therefore be in a standard, open format that is easy to control. This is another example of legislation that does not explicitly mention the Open Document Format, but whose logic leads to the choice of ODF.

Finally, the Interoperable Europe Act (IEA), which came into force in 2024, defines the legal framework for interoperability between EU public administrations and explicitly cites open standards, which – in the context of documents – means ODF and not OOXML, which, even if considered a standard (by a stretch of the imagination), is certainly not open.

Germany has linked these three points. The Deutschland-Stack identifies ODF not as an ideological choice but as a key element of a sovereign, interoperable digital infrastructure aligned with Europe. Other EU governments operating within the same regulatory and political context should apply the same logic.

The current situation in EU countries

Germany is not the only country to have taken steps towards open document standards, although the Deutschland-Stack is the most comprehensive and structurally integrated commitment seen at national level.

France made ODF mandatory in the 2009 Référentiel Général d’Interopérabilité, with subsequent updates strengthening this requirement. The French public administration has a legal obligation to use open formats in its dealings with citizens and between agencies.

The Netherlands, Sweden, Norway and Denmark have all, at different times, adopted policies recommending or requiring open document formats in public administration. In 2014, the United Kingdom made ODF mandatory for government documents, and the decision has never been revoked.

Even the Guidelines for the Digital Administration Code, issued in 2023 by the Italian Government’s Agency for Digital Italy (AGID), would define open standards for documents in such a way that only Open Document Format is included in the list, but these are almost always disregarded without reason by public administrations.

Thus, EU governments that seriously examine the issue tend to reach the same conclusion: ODF is the appropriate standard document format for a sovereign and interoperable public administration. What varies are the levels of implementation, and the willingness to see it through when proprietary vendors put up resistance through intense lobbying.

The Deutschland-Stack raises the bar, integrating the choice of ODF into a comprehensive, cross-cutting sovereign infrastructure framework, based on explicit architectural principles and supported by coordinated decisions at every level of the federal system. This is the model to follow.

Our call to action, which should be that of all EU citizens

If you are a government official, a digital policy advisor, the CIO of a public administration, or a minister responsible for digital transformation in any EU country, this post is for you.

You do not need to invent a new policy, but to apply the logic you already accept (on sovereignty, interoperability, reducing dependence on suppliers, and building a public digital infrastructure that serves citizens rather than Big Tech shareholders) to the documents in your stack.

Germany has done so with determination. France, Italy and other countries have done so clearly, though not quite as resolutely. The European regulatory framework demands it, and the open-source ecosystem – with software that properly supports ODF, which today consists solely of solutions based on the LibreOffice Technology stack – is ready to support it.

The only thing standing between your administration and the ODF mandate is the decision to adopt it. We are ready to help you, not only to make this decision but also to turn it into a successful project.

The Document Foundation is the home of LibreOffice, and one of the leading advocates of open document standards in public administration across Europe and the world. For information on adopting LibreOffice and ODF in public administration, please write to info@documentfoundation.org.