A legislative proposal for open file formats, consumer choice, and digital sovereignty.
Modern economies run on files. Contracts. Medical records. Architects' drawings. Financial models. Court bundles. The everyday output of every desk worker in the country, all of it sitting in formats designed and controlled by private vendors.
When those formats are proprietary and undocumented, the data inside them belongs, in practice, to the vendor. The customer pays for the licence, creates the content, and still cannot leave.
This isn't a side-effect of software design. It's a deliberate commercial strategy, one that quietly compounds across years until migration costs are catastrophic, switching is unthinkable, and a decade of institutional memory exists only as a binary blob nobody outside the vendor can fully parse.
Markets correct lock-in only when buyers can see and price the cost of leaving at the moment of purchase. They cannot. That is the kind of failure legislation exists to correct.
Hardware sovereignty without format sovereignty is a half-built bridge.The central premise of the Act
Data created by a customer belongs to the customer. The format in which that data is stored should not be a mechanism for asserting a claim over it.
A specification, once published, is a public good. Publishing it costs the vendor little and yields the customer a great deal.
Competition between vendors should turn on the quality of features, performance, support, and price. Never on the inability of customers to leave.
Long-lived records of public, scientific, legal, and cultural value must remain readable beyond the commercial lifetime of any single product.
National sovereignty over data infrastructure requires format sovereignty as a precondition.
Innovation is not threatened by openness. It is sharpened by it.
Any commercial software offered in the jurisdiction must publish a complete, accurate technical specification of every file format it reads or writes. Detailed enough that a competent third party could build a fully compatible reader and writer without reverse engineering.
The specification must be updated at or before the moment any change is shipped to customers. Historical versions stay published for at least fifteen years after a format is retired, so long-lived records remain readable.
Any party implementing a reader or writer in accordance with the specification gets an irrevocable, royalty-free, worldwide patent licence for that purpose. No bait-and-switch through patent enforcement.
End-user licence terms and technical measures cannot be used to prohibit, penalise, or impede customers and third parties from building or using alternative readers and writers. The right of exit is real.
A designated regulator handles complaints, issues notices for non-compliance with reasonable cure periods, and escalates only on persistent or wilful disregard. The objective is publication, not punishment.
Hobbyist developers and small enterprises are exempt below a revenue threshold. Open-source projects with public source already comply. Genuine cryptographic primitives are protected. The targets are commercial moats, not solo builders.
Critics often argue that opening up file formats will harm innovation. The historical record argues the opposite. Every major transition from a proprietary format to an open one has been followed by an explosion of adoption, a wave of new entrants, and a level of interoperability the closed era could not produce. These are not edge cases. They are the foundations on which the modern internet runs.
Vendors compete on the quality of their products, not on how expensive it is to leave them. Better software wins. Lazy software loses.
A clinic can change records platforms. A studio can change CAD vendors. A school can keep twenty years of pupil work in a form any future system can read.
Every great open standard accelerated innovation rather than slowed it. Openness sharpens the edge, it doesn't dull it.
Medical, legal, scientific and cultural records remain readable beyond the commercial lifetime of the product that created them. Files outlive vendors.
Several governments (the United Kingdom, France, Germany, the European Union) have made reducing dependence on a small number of foreign technology providers a strategic priority. Resilience. Jurisdictional control. The ability to enforce domestic law on critical national systems.
None of those goals can be achieved while the file formats underlying public-sector data are proprietary and undocumented. A government may control every layer of its stack and still find itself unable to read its own records without licensing software from a single foreign company.
The Act fixes this without favouring any single vendor. It removes the advantage of market dominance by any single business, and lets sovereignty follow.
Vendors get a reasonable period to comply without disrupting ongoing business operations. The Act doesn't appear overnight; it lands in stages.
Several existing legal instruments touch on related concerns and would benefit from explicit alignment with the proposed Act. The proposal isn't a leap into the unknown; it's the missing piece.
Establishes interoperability obligations for designated gatekeepers. The proposed Act extends a narrower obligation, format disclosure rather than full interoperability, to a wider class of vendors. Where the DMA targets the largest platforms, this Act addresses the long tail.
Provides rights of access and portability for data generated by connected products. Format disclosure is the logical and necessary complement: portability rights mean little if the format the data lands in is itself closed.
Grants data subjects a right to portability of their personal data in a structured, commonly-used, machine-readable format. The proposed Act ensures such formats actually exist and remain readable across vendor boundaries.
It will not. Innovation happens in the visible features customers buy, not in the hidden formats that hold them hostage. Part IV walks through the historical record. Every major open-standard transition in computing, from networking to documents to container runtimes, has accelerated rather than slowed the pace of innovation.
A file format is not a trade secret in any defensible sense. It's the surface across which the product communicates with the data the customer paid to create. The clever algorithms, optimisation techniques, and product designs that constitute genuine intellectual property remain entirely within the vendor's implementation. Publishing how a file is laid out exposes none of this.
Internal format documentation already exists at every serious software company. It has to, or the product could not be maintained. The cost of compliance is principally the cost of cleaning that documentation for publication. For new products, the cost is essentially zero if the discipline is built in from day one.
On the contrary. The Act applies to any vendor offering covered software in the jurisdiction, regardless of where they are headquartered. It levels the field by removing a structural advantage that today accrues disproportionately to incumbents and to vendors with the resources to maintain proprietary moats.
They will not. The Act applies wherever software is sold, and the markets it covers are too large and too lucrative to abandon. The same argument was made before every major consumer-protection law of the last fifty years. Vendors complied, kept selling, and in most cases prospered.
That single requirement, modest as it sounds, restores the basic conditions under which markets work and under which sovereign states can govern their own digital infrastructure.
It returns to citizens and businesses something they assumed they already had: ownership of the data they create.
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Read the full proposal. Share it with legislators, industry bodies, and civil-society organisations. Comments, drafting suggestions, and expressions of support are welcomed during the consultation period.