Germany's Deutschland-Stack Sparks Transparency Concerns Over Closed-Door Industry Talks
Germany's Digital Overhaul: How the "Deutschland-Stack" Is Leaving Civil Society Behind
The Deutschland-Stack is the flagship project of Germany's fledgling Federal Ministry for Digital Affairs and Transport—a bold attempt by Minister Karsten Wildberger (CDU) to deliver a long-overdue "digital update" for the country. Described as a "unified IT infrastructure with core components like cloud and IT services, along with clearly defined interfaces," the initiative aims to address the systemic failures that have plagued Germany's sluggish public-sector digitization for years.
The ministry could, in theory, draw on a wealth of expertise from civil society. For decades, activists and organizations have not only documented the stumbling blocks in administrative digitization but have also contributed their knowledge—often on a voluntary basis—to digital projects and sustainable solutions.
When the ministry launched its public consultation last autumn, it initially earned praise. Through the openCode platform, it invited groups, associations, and even individuals to submit feedback on the Deutschland-Stack. The process was designed to be accessible, with contributions publicly visible—a level of transparency that set this consultation apart from previous, more opaque formats.
Yet from the outset, the ministry pursued a dual-track approach. While the open consultation was underway, it simultaneously organized closed workshops with industry stakeholders—startups, academia, IT and digital economy representatives, and business associations. Civil society, however, was conspicuously absent.
What transpired in these workshops remains unknown. A ministry spokesperson told our website that the sessions were "internal working-level meetings with no public reporting."
Government records, obtained via a parliamentary inquiry by Sonja Lemke (The Left), reveal that five workshops were held in November, covering topics such as market integration platforms, startups, and agentic AI. Hosted by organizations like eco, the AI Association, Bitkom, and Databund, the government emphasized that it had sought expertise on "technical standards and technologies for the Deutschland-Stack" but participated only as a "catalyst."
Civil society was shut out entirely—both in the first consultation phase (October 1 to November 30) and the second (January 16 to February 15). Kai Dittmann, who leads advocacy and policy work at the Society for Civil Rights (GFF) and coordinates the F5 Alliance, confirmed that the coalition had requested a meeting as early as last autumn.
The F5 Alliance—a network of Reporters Without Borders, AlgorithmWatch, Wikimedia Germany, the Open Knowledge Foundation Germany, and GFF—advocates for digital policies centered on the public good.
"We had hoped the ministry would proactively offer a consultation workshop on the Deutschland-Stack," Dittmann said, "starting with basic information—what's included, what isn't. It would have made sense to discuss upfront which issues require civil society's active involvement." Key questions, such as the implementation of digital identities, their impact on fundamental rights, and necessary safeguards, went unaddressed. The ministry also missed an opportunity to tap into Wikimedia's expertise on data governance—critical for populating the Deutschland-Stack with meaningful information.
A workshop with the F5 Alliance finally took place in late March—on "AI in Public Administration." Yet according to the ministry, it had "no specific connection to the Deutschland-Stack." This claim is puzzling for two reasons. First, a December government response stated that a civil society workshop was "under consideration," explicitly naming the F5 Alliance—implying the session was meant to be Stack-related. Second, the ministry's revised "overall concept" now explicitly includes AI as a component of the Deutschland-Stack. Even more surprising: the workshop wasn't limited to civil society but also included business representatives.
The ministry's selective engagement raises questions about whose voices truly shape Germany's digital future—and whether its "update" will serve the public or just a few.
AI Agents Set to Streamline—and Partially Take Over—Administrative Tasks
To advance this goal, Germany's Federal Ministry for Digital and Transport (BMDS) has established its own dedicated hub and is funding a series of pilot projects. One of these initiatives deploys agent-based AI in the application process for housing benefit certificates—a highly sensitive area where people's livelihoods are at stake. Errors here could have devastating consequences, as illustrated by the Dutch child benefit scandal.
"Just Do It" Needs Clear Boundaries
"In the workshop, we only began to scratch the surface of these questions," says Dittmann. How should agencies and their staff handle situations when things go wrong? Who bears responsibility if mistakes occur—mistakes that could have serious repercussions? The caseworker, the software developer, the IT service provider, the authority that procured the AI system, or the minister who pushed the initiative forward? And who is accountable if these AI systems fail to deliver the desired results?
What happens if a single caseworker, assisted by AI agents, processes an ever-growing number of applications and overlooks something critical? "Do we risk a diffusion of responsibility in this system?" Dittmann asks. After all, one thing is clear: the machine cannot be held accountable.
These are societal questions that demand discussion and resolution. Yet under the banner of "just get it done," they have so far been sidelined. But moving forward also means deciding "what we choose not to do" and setting clear limits, Dittmann argues.
The BMDS's decision to keep civil society at arm's length within its D-Stack framework is all the more puzzling given that, according to a ministry spokesperson, the AI transformation process explicitly aims to incorporate diverse perspectives.
A Missed Opportunity for Inclusive Engagement
While the ministry's communication has been inconsistent to date, Dittmann views the late March workshop as a potential turning point—a chance to not only involve civil society expertise but to recognize it as a valuable resource. The ministry could make even better use of this expertise by adopting a more proactive approach to participation.
This might mean finding alternative ways to tap into the knowledge of engaged individuals—many of whom work on a voluntary basis and cannot attend workshops scheduled during standard business hours on weekdays. This affects volunteers from organizations like D64 – Center for Digital Progress, the Chaos Computer Club, or InÖG, the Innovation Network for Public Health.
The ministry could allocate research funding or consult academics to identify which individuals or grassroots organizations possess deep expertise on specific issues. For instance, it could seek insights from voluntary digitalization projects in Berlin, at the federal level, or in smaller towns and municipalities. Their firsthand experiences could prove invaluable in shaping responsible AI integration.
