Date: 2025-07-18Category: Not ApplicableState: Union GovernmentCountry: Europe
Commission Implementing Regulation (EU) 2025/1420 of 17 July 2025 laying down rules for the application of Regulation (EU) 2024/903 of the European Parliament and of the Council, as regards the establishment and the operation of the interoperability regulatory sandboxes
Executive Summary:
This Commission Implementing Regulation (EU) 2025/1420 establishes rules for the application of Regulation (EU) 2024/903 regarding the establishment and operation of interoperability regulatory sandboxes. It defines the criteria, procedures, and operational aspects for these sandboxes, which aim to foster innovation and cross-border interoperability of trans-European digital public services. The regulation emphasizes collaboration, risk management, data protection, and reporting obligations for regulatory sandbox coordinators and participants. It enters into force on the twentieth day following its publication in the Official Journal of the European Union.
Key Points / Main Content:
Establishment of Interoperability Regulatory Sandboxes:
* Sandboxes must be established through a specific agreement between at least three Union entities or public sector bodies, or a consortium meeting the same criteria.
* Sandboxes must meet criteria outlined in Article 3 and the Annex checklist, and be notified to the Commission. Authorization from the Commission is needed per Article 114 of Regulation EU 2024/903 and Article 5 of this Regulation.
* The initial period for a sandbox should not exceed three years, with possible renewals following Article 7.
* Agreements must include objectives, scope, governance, risk management, evaluation framework, and data protection measures as specified in Article 114 of Regulation EU 2024/903.
Operation of Interoperability Regulatory Sandboxes:
* Regulatory sandbox coordinators manage operations and projects, facilitate regulatory dialogue, admit participants, select projects, ensure specific plans are in place, and manage risk.
* Coordinators designate a single point of contact for communication with the Commission.
* Participants must contribute to specific plans, ensure legality of solutions, comply with legal requirements and data protection laws, adhere to the risk management framework, and report learnings.
* A risk management process must be established, including a risk management plan for each project and the appointment of a risk manager.
* Periodic reports must be submitted to the Commission and the Interoperable Europe Board at least every six months.
Transparency and Information Sharing:
* The Commission will create a dedicated interface on the Interoperable Europe Portal for information and exchange on interoperability regulatory sandboxes.
* Information on eligibility, selection criteria, and project details must be published on the Interoperable Europe Portal.
Closing and Renewal:
* Sandboxes will be closed upon fulfillment of objectives, reaching the end date, lack of authorization for renewal, or lack of funding.
* A final report must be submitted within three months of closing.
* Renewal requires following the procedure set out in Article 5 and is contingent on achieving objectives and continued authorization.
Project Termination:
* Projects are terminated if objectives are met, regulators request termination, funding is unavailable, or minimum criteria are no longer fulfilled.
* Personal data processed in projects cannot be used operatively outside the projects without a proper legal basis.
* Interoperability solutions and related materials developed during the project should be published on the Interoperable Europe portal, using EUPL or another appropriate open-source license.
Impact Analysis:
Regulatory Sandbox Coordinators:
Impact: Responsible for establishing, managing, and overseeing the interoperability regulatory sandboxes, including ensuring compliance with the regulation's criteria, managing projects, and facilitating communication with the Commission and other stakeholders.
Action Required: Ensure the sandbox meets the criteria in Article 3 and the Annex, notify the Commission, establish a specific agreement, designate a single point of contact, set up a risk management framework, publish information on the Interoperable Europe Portal, and submit periodic reports.
Participants:
Impact: Participate in the interoperability regulatory sandboxes to develop, train, test, and validate innovative interoperability solutions.
Action Required: Contribute to the specific plan, ensure the legality of their activities, comply with applicable legal requirements, adhere to the risk management framework, and report learnings to the regulatory sandbox coordinators.
Commission:
Impact: Oversees the establishment and operation of interoperability regulatory sandboxes, provides guidance and clarifications, and ensures information is available on the Interoperable Europe Portal.
Action Required: Assess the compliance of requests, notify decisions to regulatory sandbox coordinators, create and maintain the single, dedicated interface for information and exchange on interoperability regulatory sandboxes within the Interoperable Europe Portal.
Interoperable Europe Board:
Impact: Receives reports on the progress, outcomes, and challenges of the interoperability regulatory sandboxes.
Action Required: Review periodic reports submitted by regulatory sandbox coordinators.
Regulators:
Impact: Involved in the regulatory dialogue within the interoperability regulatory sandboxes.
Action Required: Engage in discussions around the setup of and the learnings from the projects.
Data Protection Authorities:
Impact: Supervise the operation of interoperability regulatory sandboxes that entail the processing of personal data.
Action Required: Provide oversight and guidance on data protection matters within the interoperability regulatory sandboxes.
Key Entities Referenced
European Union: A political and economic union of member states located primarily in Europe.
European Commission: The executive branch of the European Union responsible for proposing legislation, implementing decisions, and managing the EU's day-to-day operations.
European Parliament: The directly elected parliamentary body of the European Union with legislative, supervisory, and budgetary responsibilities.
Regulation EU 2024/903: A regulation of the European Parliament and of the Council laying down measures for a high level of public sector interoperability across the Union (Interoperable Europe Act).
Interoperable Europe Portal: A dedicated interface for information on the interoperability regulatory sandboxes.
Interoperable Europe Board: An entity established in accordance with Article 15 of Regulation EU 2024/903 to monitor regulatory sandboxes.
Regulation EU 2016/679: Regulation of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation).
European Data Protection Supervisor: An independent supervisory authority responsible for monitoring the processing of personal data by the Union institutions, bodies, offices and agencies.
Official Journal EN
of the European Union L series
2025/1420 18.7.2025
COMMISSION IMPLEMENTING REGULATION(EU) 2025/1420
of 17 July 2025
laying down rules for the application of Regulation (EU) 2024/903 of the European Parliament and of
the Council, as regards the establishment and the operation of the interoperability regulatory
sandboxes
THE EUROPEAN COMMISSION,
Having regard to the Treaty on the Functioning of the European Union,
Having regard to Regulation (EU) 2024/903 of the European Parliament and of the Council of 13 March 2024 laying down
measures for a high level of public sector interoperability across the Union (Interoperable Europe Act)(1), and in particular
Article 12(10) thereof,
Whereas:
(1) Regulation (EU) 2024/903 introduced the interoperability regulatory sandboxes as an innovation support measure to
enhance the development of innovative interoperability solutions and the cross-border interoperability of trans-
European digital public services.
(2) In order to address the specific cross-border innovation and interoperability-related needs of public sector authorities,
public sector bodies or Union entities may establish an interoperability regulatory sandbox pursuant to Article 11 of
Regulation (EU) 2024/903. Interoperability regulatory sandboxes are fora to create regulatory learnings that are
informed by data coming from targeted projects aiming to develop, train, test or validate innovative interoperability
solutions. For interoperability solutions this innovation can concern all interoperability layers (legal, organisational,
semantic or technical), where this innovative element can be seen as the introduction of something new or
significantly improved. To assess, if something is new or improved, the context is relevant what is innovative in one
sector or Member State may be commonplace in another. The interoperability regulatory sandboxes can give room
to experiment with a broad range of innovative interoperability solutions that can support better cross-border
interoperability of public services. An interoperability regulatory sandbox evolves around open regulatory questions,
especially in cross-border contexts, that are discussed with the relevant regulators that can come from different
sectors, administrative levels and Member States. In the case that only technical experimentation is needed, such
experimentation can happen in other forms, such as testbeds or innovation labs, and no interoperability regulatory
sandbox is needed. In accordance with Article 11(4) of Regulation (EU) 2024/903, interoperability regulatory
sandboxes are by default joint endeavours of several Union entities and/or public sector bodies that work together
towards more legal certainty in the frame of an interoperability regulatory sandbox. In that sense, interoperability
regulatory sandboxes are established through specific agreements between the different collaborating entities (such
as a Memorandum of Understanding). Cooperation within the interoperability regulatory sandboxes can build on
existing cross-border cooperation mechanisms. For this reason, public sector bodies or Union entities forming a
consortium (e.g. a European Digital Infrastructure Consortium or European Grouping Territorial Cooperation) can
establish an interoperability regulatory sandbox as well.
(3) To foster innovation, several national and Union wide regulatory sandboxes have been established or are in the
process of being established under various Union legislative instruments, such as, but not limited to, the EU
Blockchain Regulatory Sandbox, the setting up of AI regulatory sandboxes under Regulation (EU) 2024/1689 of the
European Parliament and of the Council(2), and the Net-zero regulatory sandboxes to promote innovation in the
field of net zero technologies under Regulation (EU) 2024/1735 of the European Parliament and of the Council(3).
While some regulatory sandboxes may be sectorial, the interoperability regulatory sandboxes established under
(1) OJ L, 2024/903, 22.3.2024, ELI: http://data.europa.eu/eli/reg/2024/903/oj.
(2) Regulation (EU) 2024/1689 of the European Parliament and of the Council of 13 June 2024 laying down harmonised rules on
artificial intelligence and amending Regulations (EC) No 300/2008, (EU) No 167/2013, (EU) No 168/2013, (EU) 2018/858,
(EU) 2018/1139 and (EU) 2019/2144 and Directives 2014/90/EU, (EU) 2016/797 and (EU) 2020/1828 (Artificial Intelligence Act)
(OJ L, 2024/1689, 12.7.2024, ELI: http://data.europa.eu/eli/reg/2024/1689/oj).
(3) Regulation (EU) 2024/1735 of the European Parliament and of the Council of 13 June 2024 on establishing a framework of measures
for strengthening Europe’s net-zero technology manufacturing ecosystem and amending Regulation (EU) 2018/1724 (OJ L,
2024/1735, 28.6.2024, ELI: http://data.europa.eu/eli/reg/2024/1735/oj).
ELI: http://data.europa.eu/eli/reg_impl/2025/1420/oj 1/14EN
OJ L, 18.7.2025
Regulation (EU) 2024/903 specifically focus on innovative solutions for Trans-European digital public services. To
ensure alignment with the objectives of Regulation (EU) 2024/903, these sandboxes must adhere to specific criteria.
Such criteria serve to determine which regulatory sandboxes will be featured on the Interoperable Europe Portal and
monitored by the Interoperable Europe Board, established in accordance with Article 15 of Regulation
(EU) 2024/903. The checklists provided in the Annex to this Regulation and the guidelines and clarifications that the
Commission may issue in accordance with Article 11(3) of Regulation (EU) 2024/903 support public sector bodies
and Union entities in assessing their compliance with these criteria. This enables the Commission to fulfil its task
under Article 12(9) of Regulation (EU) 2024/903 of ensuring that information on the interoperability regulatory
sandboxes is available on the Interoperable Europe portal. The check and authorisation of interoperability regulatory
sandboxes by the Commission does not constitute an assessment of the legality of activities of the participants within
such sandboxes. All participants remain fully liable for their activities as set out in Article 12(5) of Regulation
(EU) 2024/903. The supervisory and corrective powers of competent authorities over these sandboxes remain
unaffected, in accordance with Article 12(4) of Regulation (EU) 2024/903.
(4) While interoperability regulatory sandboxes can provide a forum for different forms of collaboration between the
interoperability regulatory sandbox coordinators, the respective regulators and other actors, the specific agreement
establishing the interoperability regulatory sandbox serves the purpose to clearly set out which working methods
between the interoperability regulatory sandbox coordinators and other actors are envisioned. The specific
agreement should make transparent which type of other actors are eligible to join the interoperability regulatory
sandbox, specify at which point in the lifespan of the interoperability regulatory sandbox and under which
conditions they can participate. This is necessary to prevent any detrimental factors to the objectives of the
interoperability regulatory sandbox. The specific agreement establishing the interoperability regulatory sandbox
should also create transparency vis-à-vis the planned interactions with actors that have to be involved in the process
pursuant to applicable law, such as Article 11(1) of Regulation (EU) 2024/903, which provides that interoperability
regulatory sandboxes entailing the processing of personal data are to be operated under the supervision of the
national data protection authorities or the European Data Protection Supervisor. The necessary engagement of the
data protection supervisory authorities depends on different factors such as the complexity of the data processing
operations in the envisioned projects in the interoperability regulatory sandbox, the categories and amount of data
concerned as well as the risks associated with the processing. The operation of the interoperability regulatory
sandboxes under the supervision of data protection authorities, where the interoperability regulatory sandboxes
entail personal data processing, should be understood as an additional task for the data protection authorities,
conferred on them by Regulation (EU) 2024/903, and a condition for the proper operation of the interoperability
regulatory sandboxes. Following the application of Union data protection law to any personal data processing in the
context of the implementation of Regulation (EU) 2024/903, data protection authorities should be provided the
necessary resources for the performance of their new tasks. In the case that data protection authorities from
different Member States and from EU level are involved in the interoperability regulatory sandbox, the cooperation
of these authorities can also build on the respective mechanisms, referred to in Article 61 of Regulation
(EU) 2016/679 of the European Parliament and of the Council(4), in Article 61 and Article 62 of Regulation
(EU) 2018/1725 of the European Parliament and of the Council(5).
(5) To ensure that participation in the interoperability regulatory sandboxes is based on a specific plan in accordance
with Article 12(3) of Regulation (EU) 2024/903, the regulatory sandbox coordinators ought to select one or more
suitable projects and ensure the establishment of a specific plan for each of them, containing all elements outlined in
Article 12(3) of Regulation (EU) 2024/903.Whether the specific plan on the projects running in the interoperability
regulatory sandboxes is developed by the regulatory sandbox coordinators or by other actors invited by them will
depend on the governance structure employed for the interoperability regulatory sandbox. What ought to be clearly
established by the regulatory sandbox coordinators throughout the lifespan of the interoperability regulatory
sandbox, is how the specific deliverables will feed into the regulatory learning objectives of the interoperability
regulatory sandbox.
(4) Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with
regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data
Protection Regulation) (OJ L 119, 4.5.2016, p. 1, ELI: http://data.europa.eu/eli/reg/2016/679/oj).
(5) Regulation (EU) 2018/1725 of the European Parliament and of the Council of 23 October 2018 on the protection of natural persons
with regard to the processing of personal data by the Union institutions, bodies, offices and agencies and on the free movement of
such data, and repealing Regulation (EC) No 45/2001 and Decision No 1247/2002/EC (OJ L 295, 21.11.2018, p. 39, ELI: http://data.
europa.eu/eli/reg/2018/1725/oj).
2/14 ELI: http://data.europa.eu/eli/reg_impl/2025/1420/ojEN
OJ L, 18.7.2025
(6) To support such objectives, Article 11(3) of Regulation (EU) 2024/903 foresees that the Commission may issue
guidelines and clarifications. The Commission shall create a dedicated interface for information on the
interoperability regulatory sandboxes, that will make public relevant details regarding the established interoperability
regulatory sandboxes and the projects running within the interoperability regulatory sandbox. To promote broad and
equitable access to the interoperability regulatory sandboxes, information on how to establish an interoperability
regulatory sandbox should be made readily and easily accessible to the potential regulatory sandbox coordinators on
the Interoperable Europe Portal in accordance with Article 12(9) of Regulation (EU) 2024/903. The Interoperable
Europe Portal can also facilitate the networking of stakeholders interested in establishing or joining an
interoperability regulatory sandbox. The Portal will also serve as a critical tool for ensuring effective regulatory
learning outcomes. Final reports and related regulatory insights will be published here, as well as the related
recommendations from the Interoperable Europe Board.
(7) In order to accommodate the specific needs for the development, training, testing and validation of innovative
interoperability solutions, in the interoperability regulatory sandbox, regulatory sandbox coordinators may include
other natural or legal persons, such as other public sector actors, Union entities, research institutions, GovTech
actors including SMEs and Startups, actors from the AI innovation ecosystem, provided they meet the criteria
specified in Article 12(1) of Regulation (EU) 2024/903. This does not entail changes on the responsibilities of the
interoperability regulatory sandbox coordinators, nor of the participants who ought to uphold the specific
agreement conditions upon entering an interoperability regulatory sandbox. The purpose of including the GovTech
actors specified in Article 12(1) is to enable a richer regulatory dialogue within the interoperability regulatory
sandbox, facilitating the sharing of lessons learned, identifying learnings from innovation experimentation, risks,
and best practices on standardisation. The involvement of said other actors in the interoperability regulatory
sandbox could also help to gain sector-specific insight and access support from testing and experimentation facilities
and from the European Digital Innovation Hubs. Innovative procurement approaches can work in synergy with and
support interoperability regulatory sandboxes by enabling timely access to resources, expertise, and technologies for
controlled experimentation. This ensures the flexibility needed to test innovative solutions while remaining aligned
with regulatory goals.
(8) To ensure that all projects running in the interoperability regulatory sandboxes respect data privacy, the regulatory
sandbox coordinators and the other actors have to set out a well-defined approach towards further processing of
personal data in the interoperability regulatory sandbox, that is to say, personal data initially lawfully collected for
other purposes. This approach should be compliant with all requirements set out in Regulation (EU) 2024/903 and
all other obligations pursuant to Union data protection law. The specific agreement on the establishment of the
interoperability regulatory sandbox should already specify, where appropriate, the elements set out in Article 11(4)
of Regulation (EU) 2024/903. The approach should give specific attention to following a hierarchical approach to
the use of personal data, ensuring that the data processed is limited to what is necessary for the functioning of the
interoperability solution to be developed or tested in the interoperability regulatory sandbox, and that functioning
cannot be effectively achieved by processing anonymised, synthetic or other non-personal data, as set out in
Article 12(6)(b) of Regulation (EU) 2024/903. Where personal data processing may lead to new inferences about
data subjects, regulatory sandbox coordinators and also the other actors involved in the interoperability regulatory
sandbox must demonstrate a valid legal basis for the operational use of sandbox results. This legal basis shall be
included in the specific plan pursuant to Article 12(3)(g) of Regulation (EU) 2024/903, and all conditions under
Article 12(6) must be met. Without such legal basis, operational personal data from the sandbox cannot be further
processed. This limitation prevents the use of interoperability regulatory sandboxes primarily for data exchange or
comparison between authorities without proper legal grounds.
(9) A structured approach to evaluation and monitoring is essential for fostering a safe and productive environment for
innovation, while maintaining accountability and regulatory integrity within the interoperability regulatory sandbox.
For this purpose, pursuant to Article 12(8) of Regulation (EU) 2024/903, regulatory sandbox coordinators are to
provide regular reports to the Commission and the Interoperable Europe Board summarising progress, outcomes,
and challenges. The reporting should also cover the evaluation of data quality aspects, such as the accuracy and
fairness of assessments, data, or inferences generated during the sandbox’s operation. This evaluation is crucial to
ensure the reliability and trustworthiness of the sandbox’s outputs to be used operationally (e.g. for fraud detection,
subsidy allocation, or civil status registration). Experimentation in interoperability regulatory sandboxes can also
serve as an opportunity to evaluate the sustainability, energy and resource efficiency of the innovative
interoperability solutions developed, trained, tested or validated in the context of the interoperability regulatory
ELI: http://data.europa.eu/eli/reg_impl/2025/1420/oj 3/14EN
OJ L, 18.7.2025
sandbox. To ensure continuous oversight, the process should require establishing a mechanism for ongoing data
collection from individual projects, allowing for regular tracking of progress, risk management, and adherence to the
sandbox’s standards. Templates and examples provided by the Commission and available on the Interoperable Europe
Portal can in the future support the streamlining of reporting, to make it easier for all parties to fill out and
comprehend the results of the interoperability regulatory sandboxes.
(10) The specific agreement on the interoperability regulatory sandboxes may need to be renewed in cases of substantial
changes to the original specific agreement. Such changes may include, among others, modifications regarding the
number and the identity of the regulatory sandbox coordinators, or the extension of the initially agreed timeframe
necessary to achieve the sandbox objectives.
(11) In the case that regulatory dialogue and the experimentation in the interoperability regulatory sandboxes has
provided enough evidence on the safe use of an interoperability solution, those interoperability solutions should be
shared through the Interoperable Europe portal, where applicable, with non-restrictive licensing terms, such as the
European Union Public Licence (EUPL), in compliance with Article 4 Regulation (EU) 2024/903).
(12) Any significant risks identified during the development and testing of interoperability solutions in an interoperability
regulatory sandbox should result in adequate mitigation and, failing that, in the suspension of the development and
testing process. The requested multi-level risk management approach, balancing the role of risk managers and the
oversight by the regulatory sandbox coordinators and competent authorities, should ensure a safe environment for
the testing, training, development or validation of interoperability solutions in the interoperability regulatory
sandbox. Regulatory sandbox coordinators should decide on the risk management process, managing
communication between competent authorities and risk managers, and ensure that each project within the
interoperability regulatory sandbox complies with the established risk management plan. The risk management
should build on and ensure full compliance with other applicable risk management procedures, e.g. in the field of
cyber security or personal data protection. Guidelines and clarifications on the Interoperable Europe Portal can in
the future help regulatory sandbox coordinators to find the appropriate set-up.
(13) The European Data Protection Supervisor was consulted in accordance with Article 42(1) of Regulation
(EU) 2018/1725 and delivered an opinion on 25 March 2025.
(14) The measures provided for in this Regulation are in accordance with the opinion of the Committee established by
Article 22(1) of Regulation (EU) 2024/903,
HAS ADOPTED THIS REGULATION:
CHAPTER I
GENERAL PROVISIONS
Article 1
Definitions
For the purpose of this Regulation, the following definitions shall apply:
(1) ‘project’ means a specific set of actions aiming to develop, train, test and validate innovative interoperability solutions,
running in the controlled environment of an interoperability regulatory sandbox according to a specific plan and
involving participants as referred to in Article 12(3) of Regulation (EU) 2024/903;
(2) ‘regulatory sandbox coordinators’ means Union entities or public sector bodies that jointly establish and manage an
interoperability regulatory sandbox, including overseeing their setup, coordinating participation, monitoring
progress, reporting on the activities and termination;
4/14 ELI: http://data.europa.eu/eli/reg_impl/2025/1420/ojEN
OJ L, 18.7.2025
(3) ‘specific agreement’ means a formal instrument concluded between at least three Union entities or public sector
bodies that outlines the terms, roles, responsibilities, and working methods for the creation, governance, and
operation of an interoperability regulatory sandbox;
(4) ‘regulator’ means regulatory bodies or authorities that oversee and enforce compliance within specific sectors at
Union, Member States, regional or local level relevant for the projects in an interoperability regulatory sandbox;
(5) ‘specific plan’ means a specific plan on the development, training, testing and validation of innovative interoperability
solutions in an interoperability regulatory sandbox, as referred to in Article 12(3) of Regulation (EU) 2024/903.
CHAPTER II
ESTABLISHMENT OF AN INTEROPERABILITY REGULATORY SANDBOX
Article 2
General provisions
1. An interoperability regulatory sandbox shall be established through a specific agreement between at least three Union
entities or public sector bodies. Legal entities forming a consortium may establish an interoperability regulatory sandbox,
provided that the consortium involves at least three Union entities or public sector bodies and complies with the
conditions set out in this Regulation.
2. Before formalising the specific agreement, the Union entities or public sector bodies establishing the interoperability
regulatory sandbox shall ensure that:
(a) the interoperability regulatory sandbox meets the criteria set out in Article 3 and specified in the checklist set out in
the Annex to this Regulation;
(b) the interoperability regulatory sandbox was notified to the Commission and, where applicable, authorised by the
Commission pursuant to Article 11(4) of Regulation (EU) 2024/903 and Article 5 of this Regulation.
3. An interoperability regulatory sandbox shall be established for an initial period that should not exceed three years. An
interoperability regulatory sandbox may be renewed, following the procedure set out in Article 7. Participation in the
interoperability regulatory sandbox has to be started and terminated within the lifespan of the interoperability regulatory
sandbox, not exceeding the maximum duration of participation in an interoperability regulatory sandbox set out in
Article 12(2) of Regulation (EU) 2024/903.
Article 3
Criteria for the establishment of interoperability regulatory sandboxes
1. Any public sector body or Union entity may take part in establishing an interoperability regulatory sandbox, subject
to the conditions laid down in this Regulation.
2. The goal of an interoperability regulatory sandbox should contribute to the objectives set out in Article 11(2) of
Regulation (EU) 2024/903.
3. Public sector bodies or Union entities shall assess the possibility to join an existing interoperability regulatory
sandbox with the same scope or to link to existing regulatory sandboxes with an overlapping scope before establishing a
new interoperability regulatory sandbox.
ELI: http://data.europa.eu/eli/reg_impl/2025/1420/oj 5/14EN
OJ L, 18.7.2025
4. The regulatory sandbox coordinators shall conclude a specific agreement on the establishment of an Interoperability
regulatory sandbox that shall, at least, contain the following elements:
(a) a description of the interoperability regulatory sandbox objective, scope and deliverables, in particular how the
interoperability regulatory sandbox, effectively contributes to the objectives set out in Article 11(2) of Regulation
(EU) 2024/903, the innovative interoperability solutions that may be developed, trained, tested or validated in the
interoperability regulatory sandbox and the open regulatory issues covered in the interoperability regulatory
sandbox, as well as its planned duration;
(b) a governance plan outlining how the interoperability regulatory sandbox will operate, including the management of
projects in the interoperability regulatory sandbox, setting out clear and transparent arrangements for collaboration
between the participants, regulatory authorities, and any other actor involved in the interoperability regulatory
sandbox, and outlining roles and responsibilities of the participants entering or exiting the interoperability
regulatory sandbox; the regulatory sandbox coordinators may agree on the division of the tasks set out in Article 9
of this Regulation among them;
(c) description of a risk management mechanism to supervise, monitor, and mitigate risks, ensuring the protection of
fundamental rights, health, safety and personal data protection supported by clear policies and procedures to address
potential violations of these fundamental rights, health and safety standards and personal data protection;
(d) description of a framework for evaluation and reporting across the interoperability regulatory sandbox and on the
projects running within the interoperability regulatory sandbox, including mechanisms for monitoring progress,
addressing challenges, documenting lessons learned and potential follow-up, and ensuring alignment with regulatory
objectives;
(e) where the processing of personal data in the projects running in the interoperability regulatory sandbox is envisioned,
specifying the information referred to in in Article 11(4) of Regulation (EU) 2024/903.
5. The regulatory sandbox coordinators shall agree on initiating at least one project subject to the conditions set out in
the specific agreement, and Chapter III of this Regulation by establishing a draft specific plan.
Article 4
Single point of contact
The regulatory sandbox coordinators shall designate among themselves, a single point of contact for the purposes of
communication with the Commission throughout the entire lifespan of the interoperability regulatory sandbox.
Article 5
Notification and authorisation of an interoperability regulatory sandbox
1. In the case that public sector bodies or Union entities want to establish an interoperability regulatory sandbox, they
shall send a joint request through the Interoperable Europe Portal.
2. The joint request shall include all information necessary for the Commission to assess the compliance of requests by
only public sector bodies with the criteria set out in Article 3 of this Regulation.
3. The Commission shall notify the single point of contact of its decision on the request referred to in paragraph 1. In
case of a negative decision, the regulatory sandbox coordinators may submit a reasoned review request within 30 days of
receiving the Commission’s decision. The Commission shall examine the review request within 30 days and shall notify
the single contact point of its decision on that review request.
4. The start date of an interoperability regulatory sandbox set out in the specific agreement shall not be before receiving
the notification referred to in paragraph 3.
6/14 ELI: http://data.europa.eu/eli/reg_impl/2025/1420/ojEN
OJ L, 18.7.2025
Article 6
Transparency
1. The Commission shall create a single, dedicated interface for information and exchange on interoperability regulatory
sandboxes within the Interoperable Europe Portal, including:
(a) general information and guidelines for Union entities and public sector bodies interested in establishing an
interoperability regulatory sandbox, including features that help interested stakeholders to exchange information,
requests and best practices;
(b) dedicated information on each of the established interoperability regulatory sandboxes, including eligibility and
selection criteria for participation in the interoperability regulatory sandboxes and information on running and
closed projects in the interoperability regulatory sandbox.
2. The single contact point shall collect any missing information, specified in paragraph (1)(b), at least 10 days before
the starting of the operations of the interoperability regulatory sandbox and share it with the Commission. The single
point of contact shall regularly update the information on projects within the interoperability regulatory sandbox.
Article 7
Renewal of the interoperability regulatory sandbox
1. Regulatory sandbox coordinators may decide to renew the interoperability regulatory sandbox under the following
conditions:
(a) the objectives of the interoperability regulatory sandbox have not yet been achieved;
(b) the interoperability regulatory sandbox is not closed pursuant to Article 8.
2. In the case that the regulatory sandbox coordinators decide to renew the interoperability regulatory sandbox, they
shall follow the procedure set out in Article 5.
3. In the case that the regulatory sandbox coordinators want to make substantial changes to the specific agreement,
referred to in Article 2(1), including, among others, modifications regarding the number and the identity of the regulatory
sandbox coordinators, or the extension of the initially agreed timeframe necessary to achieve the sandbox objectives, then
the regulatory sandbox coordinators shall start the renewal procedure as set out in paragraph 2.
Article 8
Closing of an interoperability regulatory sandbox
1. Regulatory sandbox coordinators shall close the interoperability regulatory sandbox in one of the following cases:
(a) the interoperability regulatory sandbox has fulfilled its objectives;
(b) the interoperability regulatory sandbox has reached its determined end date pursuant to Article 2(3) and the
regulatory sandbox coordinators have not reached an agreement on its renewal;
(c) the Commission has not authorised the renewal pursuant to Article 7;
(d) the necessary funding to continue the activities of the interoperability regulatory sandbox is not available.
2. Upon closing of the interoperability regulatory sandbox, the regulatory sandbox coordinators shall ensure that all
projects in the interoperability regulatory sandbox are properly terminated, as set out in Article 15.
3. Regulatory sandbox coordinators shall submit the final report referred to in Article 12(8) of Regulation
(EU) 2024/903 within three months following the closing of the interoperability regulatory sandbox.
ELI: http://data.europa.eu/eli/reg_impl/2025/1420/oj 7/14EN
OJ L, 18.7.2025
CHAPTER III
OPERATION OF INTEROPERABILITY REGULATORY SANDBOXES
Article 9
General rights and obligations of the regulatory sandbox coordinators
1. Regulatory sandbox coordinators shall manage the operations in the interoperability regulatory sandbox and its
related projects throughout the lifespan of the interoperability regulatory sandbox.
2. Regulatory sandbox coordinators are specifically responsible for the following tasks:
(a) to invite regulators to the interoperability regulatory sandbox;
(b) to steer the regulatory dialogue with the regulators involved around the set-up of and the learnings from the projects;
(c) to decide on the number of projects running sequential or in parallel during the lifespan of the interoperability
regulatory sandbox;
(d) to publish calls for participation in the interoperability regulatory sandbox on the Interoperable Europe Portal and
admit participants to the interoperability regulatory sandbox, as referred to in Article 10;
(e) to select projects to run in the interoperability regulatory sandbox, while verifying that each projects remains in the
scope of the interoperability regulatory sandbox with particular attention to the following aspects:
— to support the cross-border interoperability of trans-European digital public services involving participants
from at least two different Member States, or from at least one public sector body and one Union entity,
— to contribute to the development, testing and validation of an innovative interoperability solution, and
— to identify the specific regulatory issues at stake and the guidance that is expected from the authorities
supervising the interoperability regulatory sandbox;
(f) to ensure that participation is based on a specific plan;
(g) to determine a time-limit for participation in a project;
(h) to decide on extension of a project, as referred to in Article 12(2) of Regulation (EU) 2024/903;
(i) to end a project, as referred to in Article 15;
(j) to ensure periodic and final reporting to the Commission and the Interoperable Europe Board;
(k) to set up a risk management framework, as referred to in Article 12.
3. In case it is necessary to process personal data in the context of projects running in the interoperability regulatory
sandbox, regulatory sandbox coordinators shall take the necessary measures to allow for the competent data protection
authorities to effectively carry out their supervision tasks, as provided for in Article 11(1) of Regulation (EU) 2024/903.
8/14 ELI: http://data.europa.eu/eli/reg_impl/2025/1420/ojEN
OJ L, 18.7.2025
Article 10
Admission of participants and other actors
1. Regulatory sandbox coordinators shall publish on the Interoperable Europe Portal information on the eligibility and
selection criteria for participation in the interoperability regulatory sandbox. Those criteria shall include the provision of
information on the possibility for GovTech actors, including national or European standardisation organisations, notified
bodies, research and experimentation labs, innovation hubs and companies wishing to test innovative interoperability
solutions, in particular SMEs and start-ups, to be involved in the interoperability regulatory sandbox, as provided for in
Article 12(1) of Regulation (EU) 2024/903.
2. Regulatory sandbox coordinators shall decide on requests from other Union entities, public sector bodies or GovTech
actors seeking to join the interoperability regulatory sandbox as participants or other actors, based on the rules for the
respective interoperability regulatory sandbox, published on the Interoperable Europe Portal according to paragraph 1.
3. The participants or other actors shall submit a declaration of commitment to the regulatory sandbox coordinators
that provides for the assumption of obligations and the commitment for the candidate to meet financial, organizational,
human resources and any other conditions that are relevant for this purpose.
Article 11
General rights and obligation of participants
1. Participants that have been admitted to an interoperability regulatory sandbox according to Article 10 shall have the
following obligations:
(a) to contribute to the specific plan;
(b) to assume full responsibility, as set out in Article 12(5) Regulation (EU) 2024/903, for the legality of the
development, training, testing and validation of the interoperability solution;
(c) to ensure that the interoperability solutions tested within the interoperability regulatory sandboxes comply with all
applicable legal requirements and have obtained any necessary authorisations or approvals from competent
authorities before they start the projects or that the competent authorities are involved in the interoperability
regulatory sandbox;
(d) to ensure, if personal data is processed within an interoperability regulatory sandbox, that such processing is in full
compliance with applicable data protection law and to agree with the relevant data protection authorities, referred to
in in Article 12(1) of Regulation (EU) 2024/903, on their expected involvement in the interoperability regulatory
sandbox and its projects;
(e) to adhere to the risk management framework, as set out in Article 12;
(f) to regularly report on learnings in the interoperability regulatory sandbox, as specified in Article 13;
(g) to ensure lawful handling of personal data processed in the projects as specified in Article 15(3).
2. Participants may exit the interoperability regulatory sandbox under the conditions set out in Article 14.
ELI: http://data.europa.eu/eli/reg_impl/2025/1420/oj 9/14EN
OJ L, 18.7.2025
Article 12
Risk management
1. Regulatory sandbox coordinators shall establish the risk management process for the interoperability regulatory
sandbox covering the risk management process referred to in Article 12(3), point (d), of Regulation (EU) 2024/903.
Regulatory sandbox coordinators shall define, implement, and monitor overarching risk management objectives for the
interoperability regulatory sandbox, including specific risk management standards applicable to all projects therein, with
due consideration of any mandatory risk management requirements pursuant to other applicable law. Regulatory sandbox
coordinators shall ensure effective communication on risk management between participants, competent authorities, and
other stakeholders.
2. Regulatory sandbox coordinators shall develop a specific risk management plan for each project that follows the risk
management process referred to in paragraph 1.
3. Regulatory sandbox coordinators shall appoint one among them as risk manager for each project. The risk manager
shall ensure that the project complies with the specific risk management plan referred to in paragraph 2 of this Article.
Where risks are identified, the risk manager shall ensure that appropriate mitigation measures are taken.
4. In the case where appropriate risk mitigation is not feasible, the risk manager may temporarily suspend any project or
participant’s involvement within the interoperability regulatory sandbox as an immediate safeguard. The risk manager shall
promptly inform the regulatory sandbox coordinators and the relevant authorities. The single point of contact shall report
this temporary suspension to the Commission.
5. The risk manager shall maintain records of risk management activities for the respective projects and make those
records available for review by all regulatory sandbox coordinators and the Commission.
Article 13
Reporting obligations
1. Regulatory sandbox coordinators shall establish a mechanism for periodic reporting that covers at least the topics
referred to in Article 12(8) of Regulation (EU) 2024/903. In the case of processing of personal data in the projects, the
reporting shall include metrics assessing the effectiveness of the innovative interoperability solution in qualifying personal
data, along with the accuracy and fairness of the output and usability of the results produced by the solution for the
relevant authorities.
2. The mechanism shall include collecting data from all projects on an ongoing basis that ensures that progress is
tracked, risks are managed, and compliance with the interoperability regulatory sandboxes’ objectives and legal
requirements is maintained. The mechanism shall cover reporting on the learnings from the dialogue with the regulators.
3. Regulatory sandbox coordinators shall submit the periodic reports to the Commission and the Interoperable Europe
Board referred to in Article 12(8) of Regulation (EU) 2024/903 at least once every six months from the date of
establishment of the interoperability regulatory sandbox.
4. All reports shall be published on the Interoperable Europe Portal. The reports shall not contain confidential
information.
10/14 ELI: http://data.europa.eu/eli/reg_impl/2025/1420/ojEN
OJ L, 18.7.2025
Article 14
Exiting of participants
1. If a participant wants to exit the interoperability regulatory sandbox before the termination of the project that the
participant is involved in, as referred to in Article 15, or the termination of the assigned task in the specific plan, the
participant shall provide a detailed explanation to the regulatory sandbox coordinators and to the Commission of the
reasons for exiting.
2. Participants exiting an interoperability regulatory sandbox shall have the following obligations:
(a) to complete any outstanding requirements linked to the monitoring and reporting of their activity;
(b) to ensure that the data collected and any interoperability solutions developed during the lifespan of the
interoperability regulatory sandbox are managed in accordance with the applicable legislation, and with the
conditions for admission to the interoperability regulatory sandbox, as defined by the sandbox coordinators; and
(c) to take all necessary steps to mitigate potential risks for the success of the interoperability regulatory sandbox project
and for public services and their delivery linked to the exiting the interoperability regulatory sandbox and its specific
projects.
3. Upon the exiting of a participant from an interoperability regulatory sandbox, the regulatory sandbox coordinators
shall assess the necessary measures with regard to the obligations set out in Article 9.
Article 15
Termination of a project
1. Regulatory sandbox coordinators shall terminate a project in the interoperability regulatory sandbox in any of the
following cases:
(a) the project has fulfilled the objectives before the maximum initial duration is reached;
(b) the regulators involved in the interoperability regulatory sandbox or other competent authorities have requested the
termination of the project and no mitigation is possible;
(c) the necessary funding to continue the activities is not available;
(d) the project no longer fulfils the minimum criteria in terms of scope and participation set out in its specific plan and
no mitigation is possible.
2. In case the regulatory sandbox coordinators plan to terminate a project before the initially scheduled ending date, the
regulatory sandbox coordinators shall inform all participants in due time.
3. Personal data that was exceptionally processed in order to reach the objectives of a projects shall not be used as
operative data outside the projects, unless there is a proper legal basis authorising a change of purpose.
4. Within three months following the termination of the projects, regulatory sandbox coordinators shall:
(a) publish on the Interoperable Europe portal or a portal, catalogue or repository connected to the Interoperable Europe
portal the interoperability solutions and related materials developed during the project, including documentation,
version history, documented source code and references to open standards or technical specifications used, if such
solutions and material are in line with the applicable quality criteria for the Interoperable Europe Portal;
(b) where solutions are issued as open source, use the EUPL or another appropriate open source licence;
(c) clearly indicate, if sharing restrictions apply due to:
— intellectual property rights held by third parties,
— sensitive critical infrastructure protection,
— protection of defence interests or public security.
ELI: http://data.europa.eu/eli/reg_impl/2025/1420/oj 11/14EN
OJ L, 18.7.2025
CHAPTER IV
FINAL PROVISIONS
Article 16
Entry into force
This Regulation shall enter into force on the twentieth day following that of its publication in the Official Journal of the
European Union.
This Regulation shall be binding in its entirety and directly applicable in all Member States.
Done at Brussels, 17 July 2025.
For the Commission
The President
Ursula VON DER LEYEN
12/14 ELI: http://data.europa.eu/eli/reg_impl/2025/1420/ojANNEX
Checklist for an interoperability regulatory sandbox (referred to in Article 2(2), point (a))
No Criteria Description Description
1 Participants have — Please list the name and contact information for each participating public entity that Please provide the required information.
been adequately will be involved in the interoperability regulatory sandbox.
Keep in mind that the interoperability regulatory sandbox must be
specified — Specify the designated role for each public entity within the interoperability
established by at least three regulatory sandbox coordinators, either public
regulatory sandbox (regulatory sandbox coordinator, observer, or regulator).
sector bodies and/or Union entities.
— Please specify the single contact point.
2 Scope, objectives Scope: Please provide the required information.
and deliverables
— legislation and sector(s) covered by the interoperability regulatory sandbox,
have been
— if not EU wide scope, cross-border region covered by the interoperability regulatory
adequately
sandbox,
specified
— duration of the interoperability regulatory sandbox,
— please show links with existing regulatory sandboxes, if any.
Objectives:
— list the interoperability regulatory sandbox objectives,
— specify how the interoperability regulatory sandbox effectively contributes to the
objectives set out in Article 11(2) of Regulation (EU) 2024/903.
Deliverables:
— clearly identify the specific regulatory issues that the interoperability regulatory
sandbox should help to clarify,
— specify the innovative interoperability solutions that the interoperability regulatory
sandbox should help to develop, train, test or validate,
— specify the number and timeframe of the projects that are envisioned under the
interoperability regulatory sandbox,
— provide a draft specific plan for at least one project.
3 Governance has — Please set out how the interoperability regulatory sandbox will operate: Please provide the required information.
been adequately — detailing clear and transparent arrangements for collaboration between the
The description should demonstrate that relevant regulators and other
specified participants, regulatory authorities, and any other actor involved in the
stakeholders have been clearly identified and considered, and, where
interoperability regulatory sandbox and its projects, and
applicable, include evidence of their readiness to participate in the
— outlining roles and responsibilities of all participants entering or exiting the
interoperability regulatory sandbox.
interoperability regulatory sandbox.
ELI:
http://data.europa.eu/eli/reg_impl/2025/1420/oj
13/14
OJ
L,
18.7.2025
ENNo Criteria Description Description
— Please specify which type of other actors are eligible to join the interoperability
regulatory sandbox, at which point in the lifespan of the interoperability regulatory
sandbox and under which conditions.
— Please be specific on the involvement of actors with supervisory or advisory
capacity, such as national data protection authorities, regional or local supervisory
bodies, and other relevant regulatory authorities.
— Please specify if the involvement of other GovTech actors is foreseen.
4 Risk management — Please list the initial potential risks identified for the interoperability regulatory Please provide the required information.
has been sandbox.
adequately — Please list the risk management objectives for the interoperability regulatory
specified sandbox, including specific risk management standards applicable to all projects
therein.
5 Evaluation and — Please specify when the periodic reports and final report will be available. Please provide the required information.
reporting — Please specify the topics to be covered by the report.
Keep in mind: the mechanism should include collecting data from
requirements have
individual projects on an ongoing basis to ensure that progress is tracked,
been adequately
risks are managed, and compliance with the framework’s objectives and
specified
legal requirements is maintained.
6 Further — If the interoperability regulatory sandbox allows for the set-up of projects that entail Please provide the required information.
processing of further processing of personal data, please, confirm that the competent data
personal data has protection supervisory authorities are adequately involved.
been adequately — Please specify the information set out in Article 11(4), second sentence, of
specified Regulation (EU) 2024/903:
— in case the further processing falls within Directive (EU) 2016/680, the legal
basis of further processing pursuant to national or Union law,
— why the further processing of personal data in the interoperability regulatory
sandbox is necessary,
— the concrete purpose of the further processing of personal data,
— the actors involved and their roles,
— the categories of personal data intended to be further processed in the
interoperability regulatory sandbox,
— the envisaged retention period for the personal data, ensuring that data is not
kept longer than necessary for the specified purposes.
— Please set out, how the alignment of the regulatory sandboxes with the conditions
set out in Article 12(6) of that Regulation will be ensured.
14/14
ELI:
http://data.europa.eu/eli/reg_impl/2025/1420/oj
EN
OJ
L,
18.7.2025