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The European Commission has accepted our request, and starting from today – Friday March 6 – has added the Open Document Format ODS version of the spreadsheet to be used to provide the feedback. We are grateful to the people working at DG CONNECT, the Commission’s Directorate-General for Communications Networks, Content and Technology, for responding to our request within 24 hours. At this point, the rest of this message is no longer relevant, and the call for action is no longer necessary. ARCHIVED MESSAGE The European Commission has spent years advocating for open standards, vendor neutrality, and digital sovereignty. The European Interoperability Framework explicitly recommends open formats for public sector digital services. The EU’s own Open Source Software Strategy calls for reducing dependency on proprietary technologies, and the Cyber Resilience Act itself is designed to address systemic risks from unaccountable technology dependencies. On March 3rd, 2026, the European Commission published a request for feedback on to the guidances to be provided in relation to the CRA, which must be provided through the linked spreadsheet in .xlsx format, a proprietary format that makes interoperability extremely difficult due to its ever changing and undocumented features. This is not a minor procedural oversight.

This is the third and final post on the topic of the artificial complexity of the OOXML format. This complexity is the result of careful design aimed at preventing interoperability. Developers have to deal with a veritable “maze” of tags, even for the simplest content. This binds users to the Microsoft ecosystem, providing the first example of standard-based lock-in. The PPTX case To demonstrate the difference in complexity between Impress and PowerPoint XML schemas in ODF and OOXML formats, I created a simple eight-slide presentation summarising the most common types: title and subtitle, centred text, bulleted list, table, vector image, photo, colour graphics and video. I created the same file using both software programmes, starting from a basic template without a background to prevent interference with the slide format and, consequently, the XML schema. This is the PDF file of the presentation (the first seven slides are identical, while the video on the last slide is replaced by a static image): To perform the analysis, I duplicated and renamed the two files, replacing the original extension with ‘ZIP’, and then unzipped them to create two folders containing all the files from their respective XML schemas. The LibreOffice folder is very

The complexity of the OOXML format is linked to its design and was deliberately created to make the format more difficult for non-Microsoft software developers to implement. Compatibility issues are caused by a veritable “maze” of tags used even for the simplest content, which binds users to the Microsoft ecosystem in the first example of standard-based lock-in. The DOCX case To demonstrate the difference in complexity between the XML schemas of Writer and Word text documents in the ODF and OOXML formats, I used two classic English theatre plays: William Shakespeare’s Hamlet and Oscar Wilde’s The Importance of Being Earnest. I downloaded the text versions of these works from Project Gutenberg — a library of classic texts for which US copyright has expired — and deleted the introductions and conclusions added by Project Gutenberg, without making any other changes. I then repeated this process for both documents. I copied all the text and pasted it, without any formatting, into two newly created blank documents. For Writer, I used the template that I usually use for unstructured documents; for Word, I did not use a template. This means that, in Writer, the XML schema contains information about the template (margins, paragraph