Bitkom is calling for a legal right to digital public services

The Act on Improving Online Access to Administrative Services – known as the Online Access Act (OZG) for short – came into force in 2017 and aimed to make all administrative services available digitally via administrative portals by the end of 2022.

This deadline has now passed, and the objectives of the Online Access Act could not be met within the specified timeframe. As a result, only a fraction of the nearly 600 administrative services due to be digitised are currently available to members of the public and businesses.

The Federal CIO and State Secretary Dr Markus Richter describes the OZG as “[…] the starting point for a sustainable transformation of the public administration.”

To accelerate this transformation of public administration, the Online Access Act is to be amended. To this end, the Federal Ministry of the Interior published a draft bill in January 2023 setting out the planned amendments to the Act.

In March 2023, Bitkom e. V., the trade association for the German information and telecommunications sector, published a landmark position paper in which it commented on the draft bill published by the Federal Ministry of the Interior and Homeland: Act Amending the Online Access Act and Other Regulations

Bitkom recommends the following amendments to the draft bill:

1. Increase the pressure to implement by establishing a legal entitlement to key digital administrative services
2. Accelerate end-to-end digitalisation and establish links with the modernisation of registers
3. Provide greater support to local authorities in implementing the OZG
4. Promote the use of eIDAS tools and take eIDAS requirements into account
5. Promote the use of core components
6. Strengthening uniform standardisation and regulation
7. Enable the application wizard to be designed as a user interface that is open to innovation
8. Integrate further key features
9. Further enhancing user-friendliness and accessibility

All nine points listed are important from Deutsche Telekom’s perspective and have its full support. In particular, points 2 (end-to-end digitalisation) and 7 (designing the application wizard as a user interface open to innovation) are of particular note from Deutsche Telekom’s perspective.

On the subject of end-to-end digitalisation and its link to the modernisation of registers, Deutsche Telekom highlighted the following key points in its position paper:

• "Comprehensive end-to-end digitisation as part of the implementation of the OZG can only succeed if the German register system is modernised swiftly and comprehensively. Against this background, we welcome the fact that Section 1a(4) explicitly establishes the link between the OZG and register modernisation by creating a legal framework for simple, cross-state data exchange, with the involvement of local authorities. To increase the pressure to implement these changes, we propose that fully digital processes be made mandatory via the portal network."
• "In order to speed up the modernisation of registers and to implement the ‘once-only’ principle – which is enshrined in the Federal Government’s coalition agreement – as quickly as possible, a binding deadline should be set for the provision of OZG services, after which users will no longer be required to provide data that is already available in public registers and is therefore already held by the administration. Implementing the ‘once-only’ principle can significantly reduce the administrative burden on citizens and businesses. A binding timeframe would also provide the administration with greater planning certainty.”

Furthermore, in point 7 of the position paper, Telekom advocates renaming the term ‘application assistant’ used in the OZG 2.0 draft bill to something more open to innovation, such as ‘user interface’. This would pave the way for all types of modern data collection technologies (such as chatbots, voice- and AI-based input, and support assistants) and would cater much more effectively to the usage behaviour of citizens and businesses in future.

The recommendations set out in point 10 of the position paper regarding greater consideration of the government cloud strategy can only be emphasised once again at this point.

Since early 2022, Telekom’s Public Innovation Lab has provided a modular, high-performance real-world lab for practical use by Telekom customers and partners. It offers the opportunity to implement end-to-end digital administrative processes – including interfaces and back-end integration – in a real-world setting and to put them into practice as part of proof-of-concepts or MVPs. This enables OZG processes to be designed and tested in practice up to maturity level 4. The Telekom Public Innovation Lab is particularly well-suited to providing technical and practical support for agile projects, as it is essentially based on two low-code platforms that enable ongoing, project-accompanying prototyping. The Public Innovation Lab is based on an ecosystem of various components and platforms, all of which are in practical use by customers and for which there are explicit references and expertise available at Deutsche Telekom and among its partners.

The Public Innovation Lab can be directly integrated into the agile workshops and labs aimed at developing the draft bill for the OZG 2.0/Future of Public Administration Act. In this way, legislative proposals can be discussed and tested from a technical and practical perspective, thereby ensuring that the text of the bill is geared towards and optimised for practical implementation from the outset.