| Dokumendiregister | Justiits- ja Digiministeerium |
| Viit | 21-4/26/7470-1 |
| Registreeritud | 15.10.2026 |
| Sünkroonitud | 16.10.2026 |
| Liik | Sissetulev kiri |
| Funktsioon | 21 Digiarengu korraldamine |
| Sari | 21-4 Elektroonilise side koostööalane kirjavahetus rahvusvaheliste organisatsioonidega |
| Toimik | 21-4/2026 |
| Juurdepääsupiirang | Avalik |
| Adressaat | Danish Agency for Digital Government |
| Saabumis/saatmisviis | Danish Agency for Digital Government |
| Vastutaja | Tõnu Grünberg (Justiits- ja Digiministeerium, Kantsleri vastutusvaldkond, Digitaristu- ja küberturvalisuse valdkond) |
| Originaal | Ava uues aknas |
| Taotle dokumendi eemaldamist või parandamist |
|
Tähelepanu!
Tegemist on välisvõrgust saabunud kirjaga. |
To The Ministry of Justice and Digital Affairs
I am reaching out from the Danish Agency for Digital Government regarding our ongoing work on digital sovereignty in the area of public-sector mobile applications.
In June, we circulated a non-paper entitled “Strengthening European Digital Sovereignty through an EU-based App Distribution and Verification Framework” between memberstates and observers in the Digital Commons European Digital Infrastructure Consortium(DC-EDIC). The paper outlines the strategic dependencies arising from the reliance on Apple and Google for app distribution and integrity verification, including services such as Apple App Attest and Google Play Integrity. It explores the potential for greater European control over these critical trust mechanisms and identifies opportunities for cooperation between Member States to explore common European solutions.
We would be very interested in learning more about Estonia’s approach to ensuring digital sovereignty in the distribution and verification of public-sector mobile applications. In particular, we would welcome the opportunity to hear about any measures, initiatives or alternative solutions you may be exploring in this area.
Would it be possible to be put in touch with a relevant colleague working in this area?
It would be very beneficial for us to exchange experiences and discuss the topic.
Kind Regards,
Martin
Martin Harvej Jensen
Special advisor
Division for Digital Architecture and Technology
P +45 2129 5477
E [email protected]
_________________________
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Non-paper
Strengthening European digital sovereignty through an EU-
based app distribution and verification framework
June 2026
1. Background
Mobile applications have become critical access points for public digital services across Europe, enabling citizens
to interact with essential functions such as digital identity, healthcare, and social rights. As public services
increasingly depend on these applications, trust in the authenticity and integrity of client software is essential for
security and citizen confidence.
Today, the dominant mechanisms for app verification are Google Play Integrity and Apple App Attest. These
mechanisms offer guarantees that a given app, phone and its hardware is authentic, unmodified, and running in a
trusted environment. Public backend systems uses such attestation signals to protect APIs against fraud, and
unauthorized access.
As it is Apple and Google offer the best services, when a high level of security is needed. While effective, it creates
a sovereignty challenge, when these mechanisms are governed by third-country entities and operate under non-
European jurisdiction. In other words – this creates a strategic dependency that could undermine European digital
sovereignty as mobile apps become core infrastructure for public digital services.
1.1 Structural dependence on non-European platforms
The Danish public administration currently rely on Google and Apple’s verification and distribution mechanisms
when distributing public apps regarding digital mailservice, healthservices and eID. This means the government
lacks control over:
• App distribution
• Integrity verification signals trusted by public backend systems.
The integrity verification pertains to three levels; the app, the operating system and the hardware, which depends
on different technologies for verification. The hardware attestation for example depends on physical chips in the
hardware while the app and operating system can be verified by software solutions,
Dependence on proprietary third-country solutions poses long-term strategic risks. Control over essential trust
anchors – including app verification and integrity attestation – cannot, under current arrangements, be fully
exercised by European stakeholders at the level which is required to maintain sufficient security in some of the
Danish public apps.
The challenge could be equally relevant when discussing the European Digital Identity (EUDI) Wallet where cross-
border digital services require consistent and interoperable trust frameworks. Nevertheless it seems like countries
across EU are applying different solutions to distribution and verification. Without a unified European approach to
app verification and distribution, there might be a risk of fragmentation between Member States, undermining
cross-border interoperability.
3. European need for a sovereign app attestation and distribution framework
The challenges outlined above should be tackled by common European solutions and the DC-EDIC could be a
forum for collaborating in finding a solution that can underpin the security of apps in public-sector digital services.
The challenge is multifaceted and there is not one solution, which is why we invite all members, observers and the
DC-EDIC itself to join in further analysing the depth of the issue as well as sharing best experiences and possibly
developing concrete solutions together.
Such a solution could provide app attestation, ensuring that every application accessing public services can be
verified without reliance on proprietary third-country hardware and software. This in turn will grant sovereign
control over the trust anchors that backend APIs depend on, allowing European governments to manage the root
of trust in authenticity of apps directly. Finally, a common solution would deliver European-operated capacity for
distributing public-sector applications across the mobile ecosystems, guaranteeing that citizens receive secure,
trustworthy software regardless of the platform they use. Together, these capabilities would create a more
resilient digital infrastructure that aligns with Europe’s strategic digital sovereignty.
4. Next steps
We propose that interested countries and the DC-EDIC join us in exploring alternatives to the Google and Apples’
appstores’, delivery mechanisms and verification. The specific framework for the analysis would have to be
decided jointly by the participating countries, but it could include the following:
• Explore different governance, legal, and technical models for how a European appstore would function.
• A market research to find existing European open source solutions. And find what solutions are missing in
the market.
• Joint development or procurement of European solutions that are not currently accessible in the market.
Non-paper
Strengthening European digital sovereignty through an EU-
based app distribution and verification framework
June 2026
1. Background
Mobile applications have become critical access points for public digital services across Europe, enabling citizens
to interact with essential functions such as digital identity, healthcare, and social rights. As public services
increasingly depend on these applications, trust in the authenticity and integrity of client software is essential for
security and citizen confidence.
Today, the dominant mechanisms for app verification are Google Play Integrity and Apple App Attest. These
mechanisms offer guarantees that a given app, phone and its hardware is authentic, unmodified, and running in a
trusted environment. Public backend systems uses such attestation signals to protect APIs against fraud, and
unauthorized access.
As it is Apple and Google offer the best services, when a high level of security is needed. While effective, it creates
a sovereignty challenge, when these mechanisms are governed by third-country entities and operate under non-
European jurisdiction. In other words – this creates a strategic dependency that could undermine European digital
sovereignty as mobile apps become core infrastructure for public digital services.
1.1 Structural dependence on non-European platforms
The Danish public administration currently rely on Google and Apple’s verification and distribution mechanisms
when distributing public apps regarding digital mailservice, healthservices and eID. This means the government
lacks control over:
• App distribution
• Integrity verification signals trusted by public backend systems.
The integrity verification pertains to three levels; the app, the operating system and the hardware, which depends
on different technologies for verification. The hardware attestation for example depends on physical chips in the
hardware while the app and operating system can be verified by software solutions,
Dependence on proprietary third-country solutions poses long-term strategic risks. Control over essential trust
anchors – including app verification and integrity attestation – cannot, under current arrangements, be fully
exercised by European stakeholders at the level which is required to maintain sufficient security in some of the
Danish public apps.
The challenge could be equally relevant when discussing the European Digital Identity (EUDI) Wallet where cross-
border digital services require consistent and interoperable trust frameworks. Nevertheless it seems like countries
across EU are applying different solutions to distribution and verification. Without a unified European approach to
app verification and distribution, there might be a risk of fragmentation between Member States, undermining
cross-border interoperability.
3. European need for a sovereign app attestation and distribution framework
The challenges outlined above should be tackled by common European solutions and the DC-EDIC could be a
forum for collaborating in finding a solution that can underpin the security of apps in public-sector digital services.
The challenge is multifaceted and there is not one solution, which is why we invite all members, observers and the
DC-EDIC itself to join in further analysing the depth of the issue as well as sharing best experiences and possibly
developing concrete solutions together.
Such a solution could provide app attestation, ensuring that every application accessing public services can be
verified without reliance on proprietary third-country hardware and software. This in turn will grant sovereign
control over the trust anchors that backend APIs depend on, allowing European governments to manage the root
of trust in authenticity of apps directly. Finally, a common solution would deliver European-operated capacity for
distributing public-sector applications across the mobile ecosystems, guaranteeing that citizens receive secure,
trustworthy software regardless of the platform they use. Together, these capabilities would create a more
resilient digital infrastructure that aligns with Europe’s strategic digital sovereignty.
4. Next steps
We propose that interested countries and the DC-EDIC join us in exploring alternatives to the Google and Apples’
appstores’, delivery mechanisms and verification. The specific framework for the analysis would have to be
decided jointly by the participating countries, but it could include the following:
• Explore different governance, legal, and technical models for how a European appstore would function.
• A market research to find existing European open source solutions. And find what solutions are missing in
the market.
• Joint development or procurement of European solutions that are not currently accessible in the market.