Aqua Publica Europea (APE) welcomes the European Commission's Digital Action Plan for the Water Sector as a necessary and timely initiative. Our members publicly owned water utilities managing drinking water and wastewater services for tens of millions of EU citizens have a direct operational stake in getting this right.
This response draws on structured input from APE members across several Member States. APE broadly shares the Commission's diagnosis that fragmentation and uneven digital adoption constrain the resilience and efficiency of European water management.
However, the picture is more nuanced than the Commission suggests. Digital maturity varies enormously: larger urban and regional utilities are often already significantly advanced, while smaller operators particularly in rural areas face compounding deficits in physical infrastructure, connectivity and skills. There is also an important distinction between traditional water functions, where digitalisation is well advanced and newer functions such as stormwater management, where it is not.
Finally, investments are hampered among others - by lack of interoperability, technological lock-in, and regulatory bottlenecks; On the four strategic pillars, APE's position is as follows.
On AI-driven analytics; we support the principle but stress that data quality and human oversight are prerequisites; AI cannot function without reliable, governed field data, and technology alone will not deliver improvement without skilled people to maintain, validate and interpret it.
On large-scale IoT deployment; we support the goal but caution against mandating deployment regardless of context. Reversibility obligations and open data format requirements must be conditions for all publicly funded IoT deployments.
Data from earth observation systems; is a promising field, especially for quantitative management and for improved knowledge of water uses (including illegal abstraction).
Again, common protocols for data use and interpretation at local scale are key to fully seize the potential.
On digital governance, we most strongly support this pillar as the foundational precondition for everything else: common interface standards, data ownership rules, sensitivity classification for water data, and a reformed procurement framework that accommodates open-source software and enforces reversibility for proprietary solutions.
APE members also point out the need to consider risks related to cybersecurity urging full NIS2 implementation as a baseline before addressing sector-specific challenges beyond it as well as geopolitical dependency on non-European platforms. A series of sequenced recommendations follow from this analysis:
Build the governance and interoperability foundation before deploying AI or IoT at scale.
Reform tariff-regulation to address the growing OPEX component of digital investment and target investment support where geographic constraints make unitary investment costs higher.
Develop skills across the full data value chain.
Ensuring consistency of the action plan with NIS2 directive and cybersecurity by establishing a clear, EU-wide classification framework for water data sensitivity, with differentiated access regimes depending on data sensitivity.
Reform public procurement to enable open-source pathways and guarantee data portability.
Throughout, APE's overarching message is consistent: standardise interfaces; treat governance as a precondition not an outcome; protect public operators from lock-in and dependency; and calibrate ambition to the real and highly varied conditions of Europe's water sector.
Read Aqua Publica Europea's position paper that contains the analysis in detail and outlines a series of concrete recommendations at the end.
