> For the complete documentation index, see [llms.txt](https://frameworks.greendealdata.eu/llms.txt). Markdown versions of documentation pages are available by appending `.md` to page URLs; this page is available as [Markdown](https://frameworks.greendealdata.eu/governnace-frameworks/governance-playbook/gdds-governance-authority-and-model/governance-model-for-the-operational-gdds-mvp2.md).

# Governance Model for the Operational GDDS (MVP2)

A future-oriented governance model (MVP2) has been outlined to describe how governance is recommended to function once the GDDS becomes fully operational.&#x20;

Upon completion of the project phase (March, 2028), the GDDS is expected to transition into an incorporated organisational form (e.g., foundation, association, cooperative, or other suitable entity). The exact legal form will be determined before operational launch and can be seen [here](/governnace-frameworks/governance-playbook/gdds-organisational-form.md).&#x20;

MVP2 governance builds upon the institutional foundations established during MVP1 and introduces:&#x20;

* a formal Council of Participants as governance authority,&#x20;
* domain-level governance through Data Sharing Groups (DSGs), and Orchestrators,&#x20;
* an operator responsible for infrastructure and services,&#x20;
* independent oversight bodies ensuring accountability and trust.&#x20;

The Figure below showcases the MVP2 governance model with the recommended structure of governance bodies.&#x20;

<figure><img src="/files/V10gqV5Rm3awMwnnjqRd" alt=""><figcaption><p>Figure XXXXX: MVP2 Governance Model for GDDS Operational Phase</p></figcaption></figure>

***

### Detailed Description of Each Governance Body (MVP2)

Below you can find the detailed description of each body, their responsibilities, limitations, and the resources they require. Click on each extendable tab below to read further.

<details>

<summary><strong>Community of Practice (Advisory &#x26; Participation Layer)</strong></summary>

### Role and Function &#x20;

In the operational phase, the Community of Practice (CoP) continues to function as the open ecosystem engagement layer of the GDDS.

While its basic function remains consistent with the project phase, the Community of Practice evolves into a broader forum supporting knowledge exchange, stakeholder engagement, and cross-domain collaboration across the operational data space ecosystem.&#x20;

The Community of Practice contributes to the long-term legitimacy, transparency, and adaptability of GDDS governance by enabling structured dialogue between the data space and its wider stakeholder environment.&#x20;

### Composition

Participation in the Community of Practice remains open and voluntary.&#x20;

Members may include:&#x20;

* GDDS participants and members,&#x20;
* data providers and data users,&#x20;
* service providers and technology vendors,&#x20;
* representatives of other data spaces and sector initiatives,&#x20;
* public authorities and regulators,&#x20;
* research institutions and domain experts,&#x20;
* ecosystem actors interested in sustainable data sharing.&#x20;

As the ecosystem matures, the Community of Practice may expand to include a broader set of stakeholders participating in or interacting with the GDDS.&#x20;

### Responsibilities & Limitations&#x20;

The Community of Practice contributes to the governance development process through:&#x20;

* The Community of Practice continues to perform an advisory and consultative role, including:&#x20;
  * providing feedback on governance developments and operational practices,&#x20;
  * identifying emerging ecosystem needs, opportunities, and risks,&#x20;
  * contributing sector knowledge and best practices,&#x20;
  * facilitating collaboration with other initiatives and data spaces.&#x20;

Through these activities, the Community of Practice strengthens ecosystem alignment and supports the continuous improvement of the Green Deal Data Space.&#x20;

The Community of Practice does not exercise formal governance authority.&#x20;

It therefore cannot:&#x20;

* take binding governance decisions,&#x20;
* operate or manage GDDS services,&#x20;
* override decisions taken by formal governance bodies.&#x20;

Its influence is exercised through advisory contributions and structured consultation processes.

### Coordination and Information Flows&#x20;

The Community of Practice interacts with other governance bodies through consultation and information exchange.&#x20;

It may provide insights and recommendations to:&#x20;

* the Council of Participants, and&#x20;
* the Supervisory Board.&#x20;

It receives ecosystem updates from:&#x20;

* the GDDS Operator, and&#x20;
* The Council of Participants, where appropriate.&#x20;

### Resources &#x20;

To function effectively, the Community of Practice requires:&#x20;

* a collaborative engagement platform,&#x20;
* periodic engagement sessions such as workshops or consultations,&#x20;
* light coordination support,&#x20;
* transparent access to relevant documentation.&#x20;

</details>

<details>

<summary><strong>Council of Participants (Governance Authority)</strong></summary>

### Function and Role&#x20;

Under MVP2 governance, the Council of Participants becomes the primary Governance Authority of the GDDS.&#x20;

It represents the collective interests of formally admitted participants and ensures that governance decisions reflect the needs and responsibilities of the ecosystem.&#x20;

The Council establishes the direction of the data space, proposes governance rules, and ensures that the GDDS operates in accordance with its Rulebook and guiding principles.&#x20;

### Composition&#x20;

The Council of Participants is composed of representatives of organisations formally admitted to the GDDS.&#x20;

Representation is designed to ensure balanced participation across stakeholder categories and domains of activity.&#x20;

Membership may include:&#x20;

* representatives of participating organisations in GDDS that also fulfil some of the ecosystem roles (data providers, data consumers, service providers, intermediaries, etc),&#x20;
* Data Sharing Group Orchestrators representing domain clusters,&#x20;

### Responsibilities & Limitations&#x20;

The Council of Participants performs strategic governance functions for the data space.&#x20;

Its responsibilities include:&#x20;

* approving and amending the GDDS Rulebook,&#x20;
* defining participant rights and obligations,&#x20;
* approving governance policies and cross-domain rules,&#x20;
* establishing onboarding and participation frameworks,&#x20;
* defining the strategic direction and priorities of the data space.&#x20;

The Council, therefore, acts as the highest governance authority of the operational GDDS.&#x20;

While the Council defines governance policies and strategic direction, it does not perform operational execution. Operational implementation of governance decisions is carried out by the GDDS Operator.&#x20;

### Coordination and Governance Delegation&#x20;

The Council of Participants may delegate certain governance responsibilities to the Supervisory Board, enabling efficient governance management between Council meetings.&#x20;

It also interacts with:&#x20;

* Data Sharing Groups through the Data Sharing Group Orchestrators, which provide domain-level input,&#x20;
* The GDDS Operator, which implements governance decisions.&#x20;

### Operational Support&#x20;

Effective functioning of the Council requires:&#x20;

* a structured representation framework,&#x20;
* formal consultation and voting procedures,&#x20;
* governance documentation systems,&#x20;
* secretariat support.&#x20;

This body evolves conceptually from the MVP1 General Assembly, ensuring continuity of governance principles across phases.&#x20;

</details>

<details>

<summary><strong>Data Sharing Group Orchestrators (DSGOs)</strong></summary>

## Domain-Level Governance (Subsidiarity Principle)&#x20;

Data Sharing Groups (DSGs) are domain-specific constituencies within the GDDS ecosystem, each bringing together the participants active in a given sector, use case, or thematic area (for example, data providers, data consumers, service providers, and relevant domain stakeholders). A DSG is not itself a governance body: it does not hold decision-making authority and does not exercise governance powers in its own right. Rather, it is the domain community whose needs, priorities, and proposed adaptations are surfaced, coordinated, and represented through its Data Sharing Group Orchestrator. Where this section describes the governance of domain-level activity, that governance is exercised by the Orchestrator (below) on the DSG’s behalf and within the framework defined by this Rulebook.&#x20;

{% hint style="warning" %}
*Note: It's important to clarify what a "use case specific decision" is and to what extent the decision is left to the UC. Are such decisions related to operations or to rules/roles (See also principle 5)? If we're uncertain, we risk jeopardising rules across UCs*&#x20;
{% endhint %}

## Data Sharing Group Orchestrators (DSGOs)&#x20;

### Function and Role&#x20;

The Data Sharing Group Orchestrator (DSGO) acts as the coordination and facilitation role for a Data Sharing Group.&#x20;

The DSGO ensures that the domain-level governance activities remain aligned with the broader GDDS governance framework and facilitates communication between the DSG and the key governance bodies, like the Council of Participants or the Supervisory Board.&#x20;

The DSGO’s mandate is bound to a single Data Sharing Group and to domain-level coordination within the framework established by this Rulebook. Its authority is facilitative and representative rather than legislative: the DSGO operationalises and applies GDDS baseline governance rules within its domain and may propose domain-specific adaptations, but it does not set or amend those baseline rules. Cross-domain matters, and any decision with implications beyond the DSG’s domain, fall outside the DSGO’s scope and are escalated to the Council of Participants.&#x20;

### Composition&#x20;

A DSGO is typically a domain expert appointed or elected by the participants of the Data Sharing Group.&#x20;

The role requires neutrality and the ability to coordinate across different stakeholders within the domain.&#x20;

### Responsibilities&#x20;

The DSGO performs several coordination and governance support functions, including:&#x20;

* coordinating participant onboarding within the DSG,&#x20;
* facilitating implementation of domain governance rules,&#x20;
* maintaining relevant domain registries and attestations,&#x20;
* supporting dispute resolution processes,&#x20;
* escalating systemic governance issues to higher governance bodies.&#x20;

### Limitations&#x20;

The DSGO operates within the governance framework of the GDDS and therefore: &#x20;

* cannot modify or override the GDDS baseline governance rules, nor override decisions taken by the Council of Participants or Supervisory Board. &#x20;
* It holds no operational authority over shared infrastructure or registries, which remain the responsibility of the GDDS Operator, and its facilitative role does not extend to acting on behalf of individual participants in their own admission, certification, or contractual matters.&#x20;

### Coordination and Escalation&#x20;

The DSGO interacts with several governance actors, including:&#x20;

* The GDDS Operator for operational coordination,&#x20;
* The Council of Participants through representation and consultation processes,&#x20;
* The Supervisory Board in cases of governance escalation.&#x20;

### Operational Support&#x20;

To perform this role effectively, DSGOs require:&#x20;

* access to governance and administrative tools,&#x20;
* registry management capabilities,&#x20;
* structured dispute resolution mechanisms.&#x20;

</details>

<details>

<summary><strong>DSGA - TBD</strong></summary>

</details>

<details>

<summary><strong>Operator</strong></summary>

The GDDS Operator (evolved from the MVP1 Operations Team) becomes the professional operational entity responsible for:&#x20;

* Running shared infrastructure&#x20;
* Maintaining registries and trust services&#x20;
* Executing governance decisions&#x20;
* Providing onboarding tooling&#x20;

The Operator has operational authority but does not define governance rules.&#x20;

It is also foreseen that there are specific working groups under the Operator, such as Technical, Business, Legal, Change Management, etc. This could be derived from the working groups of MVP1. &#x20;

See more about the Operational Framework [here](/operational-frameworks/introduction.md).

</details>

<details>

<summary><strong>Supervisory Board (Oversight)</strong></summary>

### Function and Role&#x20;

The Supervisory Board provides strategic oversight of the operational GDDS.&#x20;

It acts as a delegated governance body of the Council of Participants and ensures that the data space operates in accordance with its governance framework, principles, and strategic objectives.&#x20;

The Supervisory Board ensures accountability of the GDDS Operator and safeguards the fairness and transparency of governance processes.&#x20;

### Composition&#x20;

The Supervisory Board consists of a limited number of members selected to ensure balanced expertise and preferably independence.&#x20;

Members may include:&#x20;

* independent experts in governance, data sharing, or digital infrastructure,&#x20;
* representatives of key stakeholder groups,&#x20;
* individuals with experience in regulatory, technical, or ecosystem governance matters.&#x20;

Members preferably do not hold operational roles within the GDDS to ensure independence of oversight.&#x20;

### Responsibilities & Limitations&#x20;

The Supervisory Board is responsible for:&#x20;

* overseeing implementation of governance decisions,&#x20;
* supervising the activities of the GDDS Operator,&#x20;
* monitoring fairness, inclusivity, and transparency of the data space together with the Ethics & Compliance Committee,&#x20;
* reviewing performance indicators, audits, and system evaluations,&#x20;
* assessing the continued fitness of governance mechanisms.&#x20;

The Supervisory Board provides oversight and governance supervision but does not perform operational management. Operational execution remains the responsibility of the GDDS Operator.&#x20;

### Coordination&#x20;

The Supervisory Board:&#x20;

* oversees the GDDS Operator,&#x20;
* receives advice from the Council of Participants and ecosystem actors,&#x20;
* interacts with the Compliance & Ethics Committee on compliance matters. &#x20;

### Operational Requirements&#x20;

To ensure independence and effective oversight, the Supervisory Board requires:&#x20;

* access to governance and operational audit information,&#x20;
* an independent operating budget,&#x20;
* analytical and governance support capacity.&#x20;

</details>

<details>

<summary><strong>Ethics &#x26; Compliance Committee (Independent Oversight)</strong></summary>

### Function and Role&#x20;

In the operational phase of the GDDS, ethical and legal oversight is provided through a Compliance & Ethics Committee, designed as a permanent independent body supporting the governance of the operational data space.&#x20;

This committee ensures that the functioning of the GDDS, its governance framework, and its operational activities remain aligned with applicable regulatory requirements, ethical standards, and responsible data sharing principles.

### Composition&#x20;

The Compliance & Ethics Committee is foreseen to consist of five independent experts, ensuring a balanced representation of relevant expertise.&#x20;

The committee is composed of:&#x20;

* one expert in data protection law,&#x20;
* one expert in open data and data governance regulation,&#x20;
* one expert in data spaces and data sharing governance,&#x20;
* two experts in ethics and responsible data use.&#x20;

Members must be independent from other governing bodies of the GDDS in order to safeguard neutrality, credibility, and impartial oversight.&#x20;

### Responsibilities & Limitations

The Compliance & Ethics Committee acts as an independent advisory and escalation body responsible for:&#x20;

* safeguarding legal and ethical compliance within the operational data space,&#x20;
* issuing independent assessments and recommendations on legal and ethical matters,&#x20;
* reviewing governance decisions and operational practices for compliance risks,&#x20;
* supporting responsible data governance across the GDDS ecosystem.&#x20;

In cases of serious non-compliance or systemic ethical risk, the committee may issue binding compliance opinions, subject to the escalation procedures defined in the governance framework.&#x20;

The committee does not take strategic governance decisions and does not execute operational functions.&#x20;

The committee performs the following functions:&#x20;

* conducting legal and regulatory compliance assessments,&#x20;
* reviewing governance and operational proposals for ethical and compliance implications,&#x20;
* issuing compliance reports and risk opinions,&#x20;
* recommending governance improvements to strengthen legal and ethical robustness,&#x20;
* supporting dispute resolution processes involving ethical or regulatory concerns,&#x20;
* managing escalation pathways in cases of systemic or unresolved compliance issues.&#x20;

### Coordination&#x20;

The Compliance & Ethics Committee receives input from:&#x20;

* the Council of Participants,&#x20;
* the Data Sharing Groups and their orchestration bodies through the council of participants&#x20;
* the GDDS Operator.&#x20;

The committee may provide opinions or recommendations to:&#x20;

* the Council of Participants,&#x20;
* the Supervisory Board where issues concern systemic governance risks&#x20;

In cases of unresolved compliance concerns, escalation may occur to the Supervisory Board in cases of structural or systemic governance risks.&#x20;

### Operational Requirements&#x20;

To ensure effective functioning and independence, the committee requires:&#x20;

* full access to relevant governance, audit, and compliance documentation,&#x20;
* clearly defined escalation and arbitration procedures,&#x20;
* appropriate financial support ensuring independent professional operation.&#x20;

In more mature stages of the data space, the oversight framework may be strengthened through:&#x20;

* structured compliance monitoring tools,&#x20;
* dedicated compliance reporting and auditing systems.&#x20;

</details>

{% hint style="warning" %}
*This section might be updated based on the latest developments in the SAGE consortium, specifically considering the WP4 Governance working group. Since the project runs till 2028, the final GDDS deliverable is expected to have additional information on these sections.  For example, governance bodies appointment, suggested procedures for voting etc.*&#x20;
{% endhint %}
