13 June 2025 | By Marten Männis
Policy & Regulation
What the EU’s 2025 International Digital Strategy Means for Businesses and Legal Departments
The European Union has unveiled a sweeping International Digital Strategy aimed at redefining how the bloc engages with the digital transformations of the wider world. While public communications have focused on the geopolitical framing and the EU’s vision of a “rules-based global digital order,” the practical implications for in-house legal teams within EU-based companies are both immediate and extensive.
A Strategy of Digital Expansion and Alignment
At the heart of the strategy are three pillars: (1) the expansion of international digital partnerships, (2) the deployment of a comprehensive EU Tech Business Offer abroad, and (3) the promotion of global digital governance in line with EU values. These goals materialise through a wide range of bilateral and multilateral initiatives spanning infrastructure, standards, digital identity, AI governance, cybersecurity, and online platform regulation.
The International Digital Strategy identifies the productivity gap between the EU and the U.S. by the latter’s vastly superior tech sector, both in its ability to innovate and also to scale up and conquer markets. Ironically, many of these companies are filled with European graduates, who have moved to the States, as the work there is both exciting enough and financially rewarding enough to justify the move.
Legal departments will need to evaluate their operations not only in terms of regulatory compliance but also strategic positioning. The strategy’s extraterritorial reach and its embedded normative commitments will inevitably influence the environment in which EU-based companies operate, negotiate, and transact.
Digital Identity and Trust Services: Toward Global Mutual Recognition
One of the most immediate areas for attention is the EU’s push toward international mutual recognition of trust services, including electronic signatures, seals, and identification schemes. The strategy outlines plans for interoperability pilots between the European Digital Identity Wallet and similar tools (such as eInvoicing) in Japan, India, and Singapore.
For in-house counsel, this raises concrete questions:
- Are your current e-signature tools aligned with evolving EU trust frameworks?
- Will your cross-border contracts benefit from mutual recognition agreements under negotiation with countries such as Brazil, Japan, and Ukraine?
- How will internal procurement, onboarding, or identity verification processes need to adapt?
The EU is attempting to create a unified legal foundation for digital identity across jurisdictions. This will eventually shape how companies establish identity, consent, and enforceability in cross-border digital engagements.
Digital Public Infrastructure and the Private Sector’s Role
The EU intends to export open-source digital public infrastructure components, including building blocks derived from the eID Wallet framework. These tools are expected to become standards in partner countries. In-house legal teams should anticipate contract provisions that incorporate or refer to these frameworks, especially when dealing with public tenders or digital services abroad.
If your organisation is involved in the design, delivery, or implementation of software systems abroad, there is likely to be an increasing expectation to conform with EU-derived digital public infrastructure specifications. These include requirements around interoperability, data protection by design, and the use of open standards.
Cybersecurity and Product Compliance: From CRA to MRAs
The Cyber Resilience Act (CRA) introduces baseline requirements for the cybersecurity of digital products placed on the internal market. The new strategy outlines the intention to pursue mutual recognition agreements (MRAs) for product compliance with key jurisdictions. This is a foundational step in reducing duplicative testing and certification requirements.
Corporate counsel should prepare for:
- New contract templates that integrate cybersecurity by design principles.
- Procurement clauses referencing CRA compliance or aligned standards.
- Vendor due diligence frameworks requiring documentation consistent with EU expectations, even outside the internal market.
Anticipating the strategy’s trajectory, these provisions will become central to commercial arrangements across sectors such as consumer electronics, IoT services, medtech, and industrial automation.
Data Flows, Platform Regulation, and Expansion Markets
The EU is now actively encouraging partner countries to align with its digital acquis, especially the Digital Services Act (DSA) and Digital Markets Act (DMA). Moldova, Ukraine, and several Western Balkan states are already receiving support for legal and institutional alignment.
In-house teams should monitor regulatory developments in these countries and adjust risk assessments accordingly. For companies looking to enter or expand in these jurisdictions, this alignment creates a more predictable legal environment but also demands immediate compliance.
Additionally, discussions around data sharing, cross-border e-commerce, and online safety standards in dialogues with countries such as China and Brazil will increasingly mirror DSA-style obligations. Companies will need to manage the complexity of multiple regulatory systems converging around EU principles.
AI Governance and International Liability Landscapes
The strategy further operationalises the EU’s role in global AI governance. It includes commitments to joint testing, model evaluation, and cooperation with AI Safety Institutes in the UK, US, Canada, and others. This approach ties into the AI Act’s requirement for comprehensive documentation, risk classification, and post-market monitoring.
For legal departments managing AI deployment, it is no longer sufficient to focus on EU compliance alone. Contracts involving general-purpose AI tools may soon require interoperability with the frameworks adopted by other leading jurisdictions that have partnered with the EU. This includes responsibilities tied to transparency, explainability, and redress mechanisms.
In-house counsel must also assess how AI governance frameworks abroad may affect contractual liabilities, especially where EU-developed systems are licensed or implemented in third countries with parallel legal reforms.
Supply Chain and Vendor Strategy: A Geopolitical Consideration
The EU Strategy makes explicit reference to trusted connectivity and supply chain resilience. It advocates for excluding high-risk suppliers in partner states, with reference to the EU 5G Cybersecurity Toolbox and subsea cable diversification.
This places legal departments at the centre of vendor evaluation and supply chain policy. For instance:
- Are suppliers engaged in public or sensitive infrastructure compliant with EU trust principles?
- Does your vendor selection or tender process include country-of-origin risk criteria?
- Are standard contractual clauses sufficient to cover downstream regulatory misalignment?
These questions move beyond compliance and into the realm of strategic legal risk management. Counsels should develop internal mechanisms to evaluate suppliers not just on performance and price, but also on alignment with EU geopolitical and normative priorities.
Digital Trade Agreements and Market Access
The EU intends to expand its network of Digital Trade Agreements. These include enhanced commitments on data flows, source code protection, and digital taxation principles. Companies that rely on the free flow of data across borders, particularly in cloud-based services or data-driven advertising, must monitor how these agreements evolve.
Trade negotiations may yield both access and limitations. Legal teams should evaluate:
- Whether current data governance frameworks are compatible with upcoming digital trade terms.
- If new access provisions open up legal routes to contest digital market restrictions abroad.
- Whether IP provisions in these agreements require revisions to internal licensing models.
As these agreements often carry direct enforceability provisions, they will also affect dispute resolution strategies and jurisdictional considerations.
Strategic Role of In-House Counsel
The EU’s 2025 International Digital Strategy presents in-house legal teams with a dual mandate. They must ensure short-term compliance with new cross-border obligations while advising leadership on long-term alignment with a reshaped global digital architecture.
It is no longer sufficient to consider EU regulation as a bounded legal domain. The strategy formalises the EU’s intent to export its regulatory standards and tools. Legal departments must anticipate their adoption not only by foreign regulators, but by counterparties, joint ventures, and end users operating in increasingly harmonised digital ecosystems.
This means:
- Adapting internal training materials to reflect legal developments outside the EU.
- Integrating legal input earlier into product, procurement, and partnership design.
- Working cross-functionally with IT, risk, and public affairs teams to map the strategic consequences of digital governance trends.
What to expect
The EU’s International Digital Strategy an operational framework that will shape the conditions under which EU-based companies engage with global markets, regulators, and partners. In-house counsel must approach it with the same diligence afforded to domestic legislative change. This is an opportunity afforded to the corporate legal departments to avoid reactionary compliance and instead position themselves as proactive contributors to the company’s global digital operations. The legal function must evolve not only to defend against regulatory exposure, but to support secure, aligned, and scalable growth within an EU-shaped digital future.
