LibreOffice: Request to the European Commission to adhere to its own guidances

Source: Hacker News

Update

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.

Note: The remainder of this message is now archived and the call for action is no longer required.

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 3 March 2026, the Commission published a request for feedback on the guidances to be provided in relation to the CRA. The feedback had to be submitted through a 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. It is a structural bias built into the process which sends a clear message: full participation in EU policymaking requires a Microsoft licence.

We ask the European Commission to lead by example by following its own guidances on interoperability and, at a minimum, to provide, alongside the proprietary format generated by the software they use, an Open Document Format (ODF) file – an actual interoperable and internationally recognised standard.

While the Commission evaluates plans to upgrade its infrastructure and services to open‑source solutions, with the aim of improving resiliency and reducing risky dependencies, it should implement in its standard procedures the release of documents in ODF format to allow all citizens, organisations, and institutions to participate in democratic processes.

#CyberResilienceAct #OpenStandards #DigitalSovereignty #OpenSource #LibreOffice #ODF

Call for Action

Dear Commission representatives,

We are writing to provide feedback on a procedural matter that, while perhaps appearing minor at first glance, carries significant implications for the principles underpinning EU digital policy — in particular the commitments to open standards, interoperability, and vendor neutrality that the Commission itself has championed in multiple legislative and strategic contexts.

The stakeholder‑feedback template for the Cyber Resilience Act Guidance document has been made available exclusively in Microsoft Excel format (.xlsx). This choice is, respectfully, difficult to reconcile with the Commission’s own stated commitments.

• The .xlsx format is a proprietary format defined and controlled by Microsoft Corporation, a private entity incorporated in the United States. Although OOXML (ISO/IEC 29500) has been approved as a standard, its implementation has never fully complied with the specifications of that standard, as widely documented in the literature on interoperability. Requiring participants to use this format as the sole vehicle for structured data entry effectively conditions participation in a public consultation on the availability or willingness to use software produced by a single supplier.

This stands in direct contradiction to several principles the EU has advanced:

• European Interoperability Framework (EIF) – recommends the use of open standards in public‑sector digital services and the avoidance of lock‑in to proprietary technologies.
• Open Source Software Strategy 2020‑2023 (and its successor) – promotes the use of open‑source software and open standards across EU institutions.
• The spirit, and arguably the letter, of the Cyber Resilience Act itself – which seeks to reduce systemic risk arising from dependency on unaccountable or opaque technology components.

A consultation process that requires respondents to use a proprietary format creates a structural bias: it disadvantages individuals, organisations, and public administrations that have made the entirely legitimate and EU‑endorsed choice to operate on open‑source software and open formats. A citizen or small organisation using LibreOffice, for instance, may encounter compatibility issues when working with the provided .xlsx template. A government body that has migrated to ODF‑based workflows faces an unnecessary obstacle.

The remedy is straightforward. Feedback templates of this kind should be provided in at minimum two formats:

1. One open format – an ODF spreadsheet (.ods), an ISO‑standardised format with no proprietary ownership.
2. One widely‑used proprietary format – for those whose environments require it.

Ideally, a plain‑text or web‑based form would supplement both, removing the spreadsheet dependency entirely for respondents who prefer it.

The Commission’s credibility on digital sovereignty, open standards, and vendor‑independent infrastructure is undermined — symbolically but meaningfully — if it continues to rely solely on proprietary formats for public consultations.

Letter to the European Commission

Each time its own processes rely exclusively on proprietary formats from non‑European technology vendors. The CRA is precisely the kind of legislation where procedural consistency with stated principles matters most.

We respectfully urge the Commission to review its template distribution practices and to adopt a format‑neutral approach to stakeholder consultation as standard policy going forward.

Yours faithfully,

Board of Directors

The Document Foundation

Berlin, March 5, 2026