Interoperability, switchability and portability: Implications for the Cloud

Cloud computing is an important enabler for the digital economy. In addition to reducing costs, cloud computing can improve access to advanced IT solutions, boosting innovation and productivity across a wide range of sectors. As cloud computing has gained momentum, there has been an increasing focus on the need to ensure that customers can make use of multiple services and are not locked into their cloud provider(s). The concepts of interoperability and portability are not new, even in the emerging cloud computing ecosystem, and have been well-described through ISO/IEC standards. Furthermore there are well-established examples of regulatory requirements relating to interoperability and portability in other sectors, notably telecoms and banking, as well as interoperable services that have emerged “by design” such as email. However, the application of regulatory requirements on interoperability and portability to the cloud requires further analysis as the services and possible scenarios for interoperability and porting are significantly more complex than in the cases where these concepts have been mandated in the past and the problems, causes and implications of specific solutions to address lock-in concerns linked to cloud computing (including unintended consequences) may not have been adequately described. This study seeks to provide guidance on what is meant by cloud computing services, and what is meant by interoperability and portability. We describe how these concepts have been applied in other sectors, in which circumstances they may be relevant to cloud computing, the benefits and risks (including potential implications for differentiation and innovation) and what might be the implications for the ongoing review of the Data Act.