Statement From the Developers Alliance on recent developments in the negotiations of the Digital Contracts Directive


Contact: Claudia Trivilino --


Statement From the Developers Alliance on recent developments in the negotiations of the Digital Contracts Directive

In light of the upcoming debate about the Digital Content Directive at the Justice & Home Ministers Council meeting on 8-9 December, the Applications Developers Alliance wants to re-emphasise our concerns:

The Developers Alliance is the world's leading association representing more than 75.000 developers, many of them contributing to the great success of Europe's booming app economy which has created more than 1.6million jobs in Europe already.

The question on the scope of the proposal needs to be assessed really carefully as it will have tremendous impact on the future success of Europe's app economy. We believe that the proposal fails to understand the huge technical difficulties arising from the requirement to make non-personal data retrievable to consumers. It would require smaller developers to completely restructure their data management systems. We also fear that such a requirement would be in conflict with the General Data Protection Regulation and seriously inhibit the way developers can create data-driven innovations in Europe. All this, while the non-personal data (such as meta data) has practically no added economic value for consumers.

Ian Rumac, lead Android Developer at SuperPopCorn says that "The concept of data as counter-performance ignores the fact that a lot of small and medium businesses use data to optimize and improve user experience and their products. From bringing new features, optimising old ones and fixing faulty content, anonymised data is a vital part of digital products." In order to comply with the rules, developers should abandon anonymisation for pseudonymisation, which is " creates more risks to users privacy and incurs costs in both development time and money to businesses"

Lukas Konior, COO at All In Mobile concludes that "Those regulations are an enormous step back. They'll influence the competitiveness of the UE market and the app developers in a very negative way. Consistency of the rules is very important but the way the regulations are proposed will do more harm than good."


We therefore urge the Council to carefully consider limiting the scope to personal data. This would ensure that the law is in line with the General Data Protection Regulation while practically not limiting the consumer benefit arising from the Digital Content Directive.

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The Developers Alliance is the world’s leading advocate for software developers and the companies invested in their success. Alliance members include industry leaders in consumer, enterprise, industrial, and emerging software development, and a global network of more than 70,000 developers.