The Law on safeguarding and regulating cyberspace (“Loi SREN”) of 21 May 2024[1] entrusts Arcep with new regulatory responsibilities, in preparation for Europe’s Data Act, and notably the task of establishing the rules and procedures for implementing the essential obligations imposed on APIs to be interoperable, portable and open. It is to this end that, today, Arcep is publishing its draft recommendation on the interoperability and portability of cloud services for public consultation. The Authority is also publishing the contributions it received to the public consultation that ran from 14 October to 16 December 2024.
Making it easier for business customers to switch cloud service providers by defining best practices for providers to implement
Rather than adopting restrictive rules that would only apply for a limited time, as Europe’s new Data Act is due to come into force shortly, and only to cloud service providers operating in France, Arcep considers it more appropriate to define a set of best practices for all cloud service providers, to make it easier for users to switch providers and adopt a multi-cloud approach. This recommendation is likely to inform future European Commission deliberations over the enactment of common interoperability specifications as part of the implementation of the Data Act. It is issued without prejudice to the transparency, interoperability, portability and openness obligations imposed on APIs by the Data Act and by France’s “SREN” Law on regulating and securing cyberspace.
Increasing transparency on cloud services’ degree of portability and interoperability: Arcep recommends that providers publish comparable information in an accessible fashion on their websites, to enable potential customers to make an informed choice.
Drawing on the contents of codes of conduct produced by the cloud ecosystem, Arcep considers it advisable for cloud service providers to publish information on the rules governing the portability and interoperability of their services. To ensure this information is comparable, it is recommended that it be published in a set, uniform order and made available in a machine-readable format.
Guaranteeing API documentation and stability: Arcep recommends the adoption of the OpenAPI specification, and twelve months’ advance notice for updates without backwards compatibility
The Authority recommends the adoption of the OpenAPI specification to standardise API descriptions. This specification provides the ability to generate exhaustive and comparable documentation. To guarantee API stability, Arcep considers it advisable to give users twelve months’ notice before performing updates that do not guarantee backwards compatibility.
The public consultation will run until 18 July 2025. Contributions must be sent to Arcep, preferably by using the form available on the Arcep website (in French).