Blogpost | 04 June 2024

Bridging Digitalisation and Sustainability

Key Demands for the Upcoming EU Term
Sinnbild: Digitales Netz breitet sich über Landschaft aus

The climate crisis and democracies under pressure – just two of the EU’s many challenges that the two-edged sword of digitalisation both alleviates and aggravates. On the one hand, the production, use, and disposal of data centres and digital devices is causing a sharp rise in greenhouse gas emissions and raw material consumption worldwide. On the other, digitalisation is required to build decentralised renewable energy systems or to transition to a circular economy. Certainly, digitalisation opens up a wide range of opportunities for democratic transparency and participation. At the same time, we witness digitalisation being used as a vehicle of election manipulation, disinformation, and hatred, for example on social media.

During the 2019–2024 term, EU Institutions have introduced various strategies and regulations that ought to shape Europe’s digital and sustainable future. The ‘twin transition’, the interlocking of the ecological and digital transformation, became a buzzword under EU Commission President von der Leyen. In the Digital Decade 2030, the EU commits to ‘empower businesses and people in a human-centred, sustainable and more prosperous digital future’. The Commission’s emphasis on both digitalisation and sustainability has manifested with regulations such as the AI Act, the Ecodesign for Sustainable Products Regulation (ESPR), the Digital Service Act (DSA), and the Digital Markets Act (DMA). Notwithstanding, the EU’s regulation efforts fail to prove that the Union approaches the two megatrends of digitalisation and sustainability together. Almost halfway through the Digital Decade, the EU still lacks a holistic approach to implement sustainability in digital policies and vice versa. Three observations support this assessment:

  1. The Digital Decade Policy Programme and other EU strategic documents on digitalisation show that the EU mainly aims to increase its economic competitiveness and independence. Although environmental and social sustainability are considered at certain points, they do not serve as the starting point for defining and designing the purpose of digitalisation.
  2. When the EU does address sustainable digitalisation, sustainability is not conceptualised as a complex system of social, economic, and ecological aspects, but is rather focused on ecological aspects alone (which sidelines diversity, inclusion, social equity, and participation, or investments, business models respectively).This becomes evident in the chapter on sustainability of the European Declaration on Digital Rights and Principles. It primarily addresses energy consumption of digital devices rather than issues of resource use, ownership, and distribution, or the urgency of a profound transformation of business models.
  3. Altogether, sustainability is not anchored in EU digital strategies in a systemic and binding way (although sustainability is addressed in some, e.g. 2030 Digital CompassDeclaration on A Green and Digital Transformation of the EU). Instead of binding targets, we find mere declarations of intent. Binding, and verifiable, targets have so far only been formulated in the Digital Decade Policy Programme. 

Our key demands for the EU Parliament and Commission

We have explained that the EU’s strategies and the steps it has taken towards an interlocked sustainable and digital future are not comprehensive enough and lack adequate measures to realise its stated intentions. We therefore call on the new EU Commission and Parliament to align the objectives of EU digital policies on a holistic understanding of sustainability, to close regulatory gaps, and to promote ambitious implementation and enforcement of existing policies on sustainability and digitalisation. In particular, we urge EU officials to meet the following demands, moving towards a sustainable and digital future:

  • Align the objectives of EU digital policies to a holistic understanding of sustainability

    The EU lacks guiding principles for a digital future in line with a multidimensional concept of sustainability. Policy makers need a holistic understanding of sustainability based on the premise that its social, economic, ecological, informational, and democratic aspects are intertwined. This would offer a common ground on how to approach digital policies and assess their sustainability impact. At the moment, there is too much room for divergent definitions of sustainability that solely focus on one of sustainability’s aspects, ignoring or even obstructing others. Digitalisation must systematically contribute to sustainability goals. Committing beyond mere declarations of intent, the EU should introduce a measurable objective for the ‘twin transition’ in the Digital Decade 2030 policy programme. This objective should be regularly monitored and reviewed, the results be published in the annual Report on the State of the Digital Decade. Existing digital laws should be subjected to sustainability assessments (where this has not already been done). Furthermore, the EU should asses the social, climate, and environmental impacts of digitalisation, publicise its findings and thus make it available to research.


  • Make digitalisation work for people and society: Rethink tracking-based online advertisement

    The EU has created strong regulations to address the problems of market concentration (DMA) and societal risks (DSA, GDPR, ban of political advertisement) to protect online users, fair digital markets, and democracy. However, an important regulatory gap remains to be closed: The EU has so far not adequately addressed the dominant business model for financing digital services: advertising based on surveillance of people’s online behaviour. Firstly, large companies introducing pay-or-ok models (offering tracking-free access to social media platforms against payment) can be seen as an evasion strategy against legal regulation. They exploit that users usually prefer a cost-free alternative and hence put up with tracking. Secondly, the online advertisement market encompasses not only platform companies but also data brokers, ad tech companies, advertising agencies, and publishers – to whom the new EU regulations such as the DSA do not apply. The negative social effects of tracking-based online advertisement outweigh individual marketing profits. This form of advertisement can be used in ways that harm democratic processes and social cohesion and curtail informational self-determination, while using excessive amounts of energy for tracking, profiling, data trading, and AI applications. A paradigm shift is thus needed in the online advertising market. The upcoming EU term should bring EU citizens freedom from manipulative practices in the digital space. With a new legal act to ban tracking-based advertising, the new Commission would incentivise business models built on privacy-by-design. Already existing alternatives (e.g. context-based) advertising models open up more climate-friendly options that comply with fundamental rights and go beyond the ubiquitous practices of tracking and targeting. 


  • Link digitalisation and environmental protection: Make the ESPR and the DPP a game changer for resource-efficient digitalisation and circular economy

    The recently adopted ESPR can be a genuine reform for the sustainability of digital devices and infrastructure. This rather indefinite framework regulation aims to improve the durability, recyclability, reparability, and environmental compatibility of almost all products. For this purpose, eco-design requirements are to be defined by the Commission. The ESPR additionally provides for Digital Product Passports (DPPs) for a wide range of product groups to improve the transfer of information between different actors in the value chain, thus supporting the transformation to a circular economy. Currently, it is common business practice to make products obsolete by not providing software updates, reducing performance through updates, or ensuring that repairs are hardly possible or too expensive. With stringent regulation, the EU can incentivise companies to depart from this business model. However, before the ESPR is actually applied, the Commission will have to define specifications for the respective products in the coming years. However, the regulation urgently needs to counteract the rapid increase in e-waste and to mitigate associated environmental impacts such as water contamination and resource waste. Information and communication technology products, such as laptops, smartphones, and servers, therefore need to be regulated swiftly and with a high level of political ambition. To this end, the Commission should not only consult with major industry associations but also frontrunners of the circular economy as well as consumer protection organisations and environmental associations. Finally, the EU should lead the way on sustainable software development. The ESPR makes limited and insufficient reference to the environmental and climate impacts of software, but needs to impose eco-design requirements on software life cycles.


Johanna Graf, Lena Stelzner, with contributions from Luca Lorenz (intern German and European Climate Policy)


Graf, J., Stelzner, L., Bridging Digitalisation and Sustainability: Key Demands for the Upcoming EU Term.


Real name

Policy Advisor – Digitalisation and Climate Protection, Co-ordinator – Digitalisation

Real name

Head of Division – German and European Climate Policy