Positions and publications

A consultation position paper on the draft Commission implementing regulation on the cross-border identification and authentication mechanism for the exchange of electronic health data under EHDS, contributing the perspective of practical IAM implementation in healthcare. It highlights areas needing clarification, such as representation and legal guardianship, attribute protection, proportionality for smaller entities and operational resilience.

A consultation position paper on the draft Commission implementing regulation on MyHealth@EU, assessing the draft positively and offering recommendations in the areas of greatest operational and security significance, such as requirements for national contact points, response to critical incidents, cryptography and proportionality for less mature national systems. Useful for organisations involved in work on cross-border health data exchange.

Position on the composition of the ENISA ad hoc working group on cybersecurity standardisation and the representation of small and medium-sized enterprises.

A position paper contributing to the discussion on the reform of the Cybersecurity Act (CSA2), setting out four principles (proportionality and a risk-based approach, certification as a mechanism that facilitates compliance, consistency of the EU regulatory framework, technological neutrality) from the perspective of SME feasibility. Useful for consultation participants and organisations following the development of European certification frameworks.

A consultation contribution to the draft Cybersecurity Strategy of the Republic of Poland, analysing the draft's provisions regarding the separation of state roles (regulator, integrator, trust operator) and the risk of crowding out the commercial services market, with proposals for instruments strengthening demand and feasibility in the SME segment. It brings the market and SME perspective to the debate on national cybersecurity policy.

Report from a Digital Europe co-funded project: training, phishing tests, maturity assessments and supplier evaluation in six healthcare organisations.