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Research · EU member states' laws

How EU countries made a design system mandatory

This is a comparative analysis of the legal acts through which European Union countries have made a government design system mandatory (a design system is a shared set of rules and interface building blocks for state websites and services). The situation is as of 19 October 2026 and covers the other 26 EU member states. Here you will find what the states have adopted, how they enforce the rules and what lessons can be drawn for bill PL-x 300/2026, the Romanian bill on standardising digital design and ensuring the accessibility of digital public services.

Method. For each state I looked for the instruments adopted and in force: laws, ordinances, government decisions and decrees, ministerial orders, mandatory guidelines and circulars. The key quotations for Slovakia, Hungary, Portugal, Italy, Greece, Czechia, France and Germany were checked directly in the official texts. The points I could not confirm at first were re-checked on 19.10.2026 (§8). This document is a public policy analysis, not legal advice.

1. In brief

  1. Only 3 states have an act with the force of law that explicitly requires the design system:
    - Slovakia: a law, a ministerial decree and a mandatory methodology, with fines;
    - Hungary: a law and a government decision (HG), with strong sanctions;
    - Portugal: a decree-law and ministerial orders with deadlines.
  2. Another 5 states impose it through lower-ranking instruments or indirectly:
    - Italy: a law, a mandatory guideline from the Agency for Digital Italy (AgID) and conditions attached to funds from the national recovery and resilience plan (PNRR);
    - Greece: a law and a ministerial decision that makes the gov.gr design guide mandatory;
    - France: a Prime Minister's circular and an approval procedure;
    - Czechia: government decisions and the approval of IT projects by DIA, the state's digital agency;
    - Germany: a law and an ordinance impose the quality of services, but the design system (KERN) remains explicitly voluntary.
  3. A few other states have only partial levers:
    - Belgium (Flanders): a single visual identity, imposed by decree;
    - Denmark: the design system is a condition for being listed on the national portals;
    - Spain, Aragón region: a regional circular;
    - Croatia: the State Information Infrastructure Act (NN 72/2025) requires uniform electronic services, through guidelines adopted by the Government, and penalises the responsible person with fines of €3,000–6,630, applicable from 2027. However, the act does not establish a design system;
    - Lithuania: mandatory publication on a single portal;
    - Bulgaria: mandatory institutional identity rules for websites, approved by ministerial order in 2023.
  4. The rest have a design system without any mandatory act (the Netherlands, Finland, Estonia, Ireland, Cyprus, Poland, Spain at national level) or have no national design system (Slovenia, Croatia, Bulgaria, Latvia, Lithuania, Malta). A few have only part of one: Belgium (only Flanders), Austria (at federal level, only a visual identity), Luxembourg (only a common framework for content), Sweden (only the systems of some agencies). Some of them nonetheless have mandatory rules for visual identity or for websites (§4).
  5. PL-x 300/2026 would put Romania in the strictest group. It would be the only country to impose a design system by law before the system exists. All the others built the system first and only then made it mandatory.
  6. Almost no country relies on fines between public institutions. The exceptions are Slovakia (a fine for the system administrator; I found no fine ever imposed), Hungary (the fine is one of several levers) and Croatia (a fine on the responsible person, from 2027). The levers that work are:
    - project approval;
    - conditional funding;
    - the nullity of contracts concluded without approval;
    - conditional access to the national portal.
  7. Several states exclude local government or fund it. Slovakia, Portugal and France exclude it. Italy brought it on board with €400 million from the PNRR, paid only after compliance had been checked. Hungary, Greece and Germany include it (§2).

2. Overview

State Main instrument Is the design system mandatory? Local government Enforcement lever Fines
Slovakia Act 95/2019 + Decree 78/2020 (Annex 12) Yes (ID-SK) Excluded Approval, annual plan, remedial order €250–25,000
Hungary Act CIII/2023 + HG 322/2024 Yes (the “design framework”) Included Stopping funding, suspension, nullity of contracts Yes
Portugal Decree-Law 49/2024 + orders Yes (gov.pt, Ágora) Excluded Approval for IT investments; contracts without approval are void No
Italy Digital Administration Code + AgID guideline 224/2022 + PNRR Yes (Designers Italia) Included, with funding Withdrawal of PNRR funds Not for design
Greece Law 4727/2020 + Ministerial Decision 38428/2021 Yes (the gov.gr guide) Included Prior approval; criterion in procurement No
France Prime Minister's Circular 6411/SG (2023) Yes (DSFR), for central government Excluded (DSFR is forbidden to them) SIG approval No
Czechia Act 365/2000 + government decisions Yes, through project approval In practice, no DIA approval; budgetary discipline No
Germany OZG Act + OZSV Ordinance (2025) No (KERN is voluntary); only quality is mandatory Included (the shared portal) Presumption of conformity through DIN SPEC 66336 No

The other states are summarised in §4.

3. Detailed profiles of the relevant models

3.1 Slovakia: the closest model

What it provides. Act 95/2019 (amended by Act 301/2023, in force since 1.08.2023) requires institutions to use the design manual when they create or change the interface of an electronic service or their main website (§13a(6), checked in the official text). Decree 78/2020, through Annex 12 (replaced in full in 2026), sets the minimum requirements: colours, the font, the header, the footer, forms, errors and a mandatory feedback bar (“Was this information helpful?”). The full library is on idsk.gov.sk. Mandatory methodology no. 051024/2026 of the responsible ministry (MIRRI) governs new components.

What could be adopted in PL-x 300/2026: the minimum requirements in an annex to a published legal act; the definition of “substantial modification”; the 10 + 10 day procedure; the feedback bar and the annual plan; transition based on the contract date; excluding local government in the first stage.

3.2 Hungary: a framework law and a government decision with strong levers

What it provides. HG 322/2024 requires providers of digital services to apply the design framework published by the service design centre (§3(2), checked). Since 1.12.2025 the centre has moved to a state agency (DMÜ, HG 365/2025). Act CIII/2023 on the digital state also applies to local authorities, courts and notaries.

What could be adopted: financial and contractual levers instead of fines; mandatory notification of projects; a design centre separate from the authority that imposes sanctions.

3.3 Portugal: a decree-law with gradual migration and public timetables

What it provides. Decree-Law 49/2024 requires state bodies to update their digital channels gradually to the reference design system of the gov.pt portal (Art. 3, checked). The timetables come through joint orders (Portaria 345/2024/1 and the sector orders): deadlines between December 2026 and December 2028 at the latest, published on digital.gov.pt.

What could be adopted: the initial inventory; public timetables by sector; checking through the prior approval of IT investments, which in Romania could be the approval of the Technical and Economic Committee for the Information Society (CTE), the body that reviews public IT projects; the nullity of contracts without approval.

3.4 Italy: a law, a mandatory guideline and money

What it provides. The Digital Administration Code (DLgs 82/2005) refers to guidelines adopted after public consultation, with the opinion of representatives of the state, the regions and local authorities. The design guideline of the Agency for Digital Italy (AgID, 2022) requires the use of design models where they exist and includes a standard contract clause (checked). The notice of publication in Italy's Official Gazette was not found; the guideline is published on the AgID website.

What could be adopted: adopting the standard through a public procedure, instead of the opinion of the National Council for Digital Transformation (CNTD), an advisory body of Romania's digitalisation authority; the standard clause; conditional funding for town halls.

3.5 Greece: a single portal and a mandatory design guide

What it provides. Law 4727/2020 requires all digital services to go through gov.gr. Ministerial Decision 38428/2021 requires all public bodies, including local ones, to use the design guide guide.services.gov.gr (Art. 7, checked).

What could be adopted: compliance as a selection criterion in procurement; a direct reference to the published guidelines. Tacit approval was tried and abandoned, so it is not a safe model.

3.6 Czechia: government decisions and budgetary control

What it provides. Act 365/2000 requires the approval of the DIA digital agency for designated IT projects; carrying out a project without approval is a breach of budgetary discipline (§5 and §5c, checked). No law names the design system: the obligation comes from the approval form and from government decisions, which make the single visual identity mandatory from 30.04.2026.

What could be adopted: compliance linked to project approval and to budgetary discipline, instead of a fine.

3.7 France: a circular, approval and a ban for local authorities

What it provides. Prime Minister's Circular 6411/SG of 7.07.2023 makes the design system (DSFR) mandatory for any new website or application of central government (checked). The 75 priority websites had to migrate by 1.07.2025 or 1.01.2026; the rest at their next redesign. Any creation or redesign requires the approval of the government information service (SIG).

What could be adopted: the list of priority services; “at the next redesign” for the rest; the 24-month rule; the design lead.

3.8 Germany: a law for quality, a voluntary standard

What it provides. The Online Access Act (OZG) and the OZSV Ordinance (in force since 1.10.2025, checked) require new systems to follow the recognised rules of technology. Conformity is presumed if the service standard DIN SPEC 66336 is met. Existing systems have a transition period until 31.03.2030. The KERN design system becomes a joint product of the federation and the Länder from 2027, but the 2026 decision states explicitly that its use is not mandatory.

What could be adopted: separating the quality obligation, set by law, from the tool that delivers it, with a presumption of conformity; a long transition; joint funding.

4. The other states, in brief

State What exists What could be learnt
Spain (Aragón) Regional circular (2022): non-compliant websites do not receive approval or a subdomain The official domain made conditional on compliance
Spain (national), Poland Only principles (Spain) or only the government logo (Poland) —
Flanders Single visual identity by decree; anyone using the shared web platform is automatically compliant Automatic compliance through the shared platform
Denmark Listing on the Virk and borger.dk portals requires the DKFDS design system Portal access made conditional
The Netherlands The law allows a standard to be designated by government decision; the power has not been used for NL Design System A law that delegates the designation of the standard
Cyprus Obligation only through guidelines and framework contracts Making it mandatory through framework contracts
Finland Act 306/2019: replies to accessibility complaints within 2 weeks A fixed deadline, compared with „dacă consideră” (“if it considers it necessary”, Art. 5(2)) in PL-x 300/2026
Estonia, Ireland Feedback (Estonia); approval of IT projects above €25,000 (Ireland) The approval lever
Croatia Act NN 72/2025: uniformity through government guidelines; fines of €3,000–6,630 on the responsible person, from 2027. The adoption of the guidelines could not be verified The law requires uniformity and delegates the details; the fine falls on the person
Lithuania Mandatory publication on the single portal “Mano Vyriausybė” for the government and ministries A single portal instead of separate websites
Bulgaria Institutional identity rules for websites, by ministerial order (2023) Minimum rules approved by order
Slovenia Since 2019, GOV.SI has been the single website of the administration A single central website
Austria, Latvia, Luxembourg, Sweden, Malta Visual identity, voluntary platforms or nothing; no mandatory design system —

5. PL-x 300/2026 compared with the closest models

Dimension PL-x 300/2026 (as adopted by the Senate) Slovakia Hungary Portugal Italy France
Rank of the act Law Law + decree Law + HG Decree-law Law + mandatory guideline Circular
Did the system exist when it was adopted? No Yes (ID-SK, existing before the 2023 obligation) Yes (the design framework) Yes (Ágora) Yes (Bootstrap Italia) Yes (DSFR)
Where the requirements are set out Documents of the Romanian Authority for Digitalisation (ADR), approved by CNTD Annex to the decree + online library Framework published by the design centre The shared reference model “Mosaico” + gov.pt Guideline adopted after consultation DSFR + the SIG note
Legitimacy of the standard CNTD opinion (unclear legal basis) Published ministerial decree HG + supervisory decision Decree-law + orders Public consultation + the Unified Conference (state, regions and local authorities) + the data protection authority Prime Minister's circular
Local government Included (timetable by HG) Excluded Included Excluded Included, with PNRR funding Excluded (forbidden)
Deadline for existing services Fixed date: 1.01.2028 On substantial modification Compliance from 1.07.2025 (§118(2)); projects are notified Sector timetables, up to 12.2028 No general deadline 75 priority sites + at redesign
Rule for new versions Missing Transitional provisions in the decree — — — 24 months
New components and exceptions ADR exemption of 12 months, without extension 10+10 working day procedure The centre sets the method and extent Authorisation of new portals “Where models exist” Adaptations proposed to SIG
User feedback Discretionary („dacă consideră”, “if it considers it necessary”) Mandatory bar + annual plan + UX lead UX analysis centre — Legal right + publication of data + ombudsman for digital matters Feedback button + 8/10 target
Main lever Fine of 7,500–10,000 lei Approval + fine of €250–25,000 Stopping funding, suspension, nullity IT approval + nullity of contracts Withdrawal of PNRR funding Approval
Public procurement Mandatory clause, not checked Through project approval Decision with requirements for procurement Prior approval of investments Standard clause imposed Terms of use annexed to contracts
Funding Each from its own budget — Central budget — €400 million for town halls —
Open source Yes, in the law Yes (methodology) The source code belongs to the state — Open licence Restrictive

6. Lessons for PL-x 300/2026

Each problem below is discussed in the Analysis of the bill. The proposals are possible amendments, drafted on the basis of the models above.

The problem in PL-x 300/2026 How someone else solved it Possible amendment
The legal nature of the requirements is not defined, and the fines refer to ADR documents that can change Slovakia: the minimum requirements are in Annex 12 to a published decree; the rest of the library is on the website. Italy: the guideline is adopted after public consultation The minimum requirements would be approved by a Government Decision (HG) or an order published in the Official Gazette (Monitorul Oficial), after public consultation. The detailed library would stay on the ADR platform. Sanctions would refer only to the published versions
There is no deadline for building the system, although institutions have a fixed deadline All the states built the system first A deadline for publishing the first version; obligations would run from that publication
The fixed date of 1.01.2028 Slovakia: on “substantial modification”, defined concretely. France: 75 priority websites, the rest at redesign. Portugal: timetables by ministry, 2028 at the latest. Germany: transition until 2030 The inventory (Portugal) and the list of priority services with their own deadlines (France), set in the law and not only in the implementing rules (Art. 11(3)(f) leaves them to the HG), then the rest at the first „modernizare majoră” (“major modernisation”), defined as in Slovakia
“Major modernisation” has only a general definition (Art. 2(h)), with the criteria left to the implementing rules Slovakia: typography, colours, header and footer Objective criteria written directly into the law
The moving target (new versions of the system) France: a major version is integrated within 24 months. Slovakia: transition based on the contract date The 24-month rule plus transitional provisions for ongoing contracts
The right to give feedback is discretionary Slovakia: mandatory bar, annual plan, UX lead, remedies ordered by the ministry. Finland: reply within 2 weeks. Italy: publication of satisfaction data and an ombudsman for digital matters. France: a satisfaction target and an improvement plan Removing the wording „dacă consideră” (“if it considers it necessary”); a mandatory feedback component, a reply deadline, a public report, a UX lead in every institution; ADR could order remedies
The main lever is a fine between institutions, which overlaps with OUG 112/2018 (the Government Emergency Ordinance on the accessibility of public websites) Portugal: IT approval and nullity of contracts, with liability for the decision-maker. Hungary: stopping funding, suspension, nullity. Czechia: breach of budgetary discipline. Italy: withdrawal of funds (about 6,000 town halls aligned). France: approval. Denmark: portal access. Croatia: a fine on the responsible person Compliance would become a condition of the CTE approval for IT projects; contracts without approval would be void; no public or European funds for non-compliant projects. If the fine stays: on the responsible person (Croatia), after a formal notice with a deadline, as in OUG 112/2018, and coordinated with the accessibility fine, so that there are not two fines for the same offence
Procurement is not checked Italy: a standard clause with fixed wording. Greece: compliance is a selection criterion. Aragón: a requirement in the tender specifications The wording of the standard clause in the implementing rules; checking it when the project is approved
The CNTD opinion (an advisory body of ADR, with members from the private sector, whose decisions have „caracter consultativ și rol de recomandare, nefiind obligatorii pentru ADR” (“an advisory character and the role of a recommendation, not being binding on ADR”), according to HG 89/2020, Art. 17(7)) No state requires the opinion of a forum with industry participation. Italy: public consultation and the opinion of local government representatives. Slovakia: fixed deadlines for assessment (10+10 working days). Greece: tacit approval after one month, abandoned in 2026 Public consultation and the opinion of the associations of local authorities, only for major versions. For components, fixed assessment deadlines, not tacit approval
Exemptions (12 months, without extension) Slovakia: a 10+10 working day procedure, with open source. Czechia: documented requests for exceptions. France: “disproportionate burden” A procedure with deadlines for ADR, the possibility of extension and published reasons
Local government, an obligation without funding Slovakia, Portugal and France excluded it in the first stage. Italy funded it (€400 million, lump sums, external checking) Either a first stage for central government only, or a funding programme (for example, the Smart Growth, Digitalisation and Financial Instruments Operational Programme, PoCIDIF), with payment conditional on checking compliance
Everything depends on the HG Portugal: the orders with timetables appeared within 4 months. The Netherlands: the law only delegates the designation of the standard Realistic deadlines, with consequences if they are missed, for example the Government reporting to Parliament
ADR's roles overlap Hungary: the design centre is separate from the supervisory authority. France: SIG builds, the ministries appoint design leads ADR (or a dedicated unit) would build the system; checking and sanctioning would fall to another body

7. What no other country has done

By 19 October 2026, no other EU state had done any of the things below, which PL-x 300/2026 would do:

8. Additional checks (19 October 2026)

I re-checked in primary sources all the points I had not confirmed at first. The main corrections:

I confirmed the official texts for Portugal (DL 49/2024, DL 107/2012), Czechia (Act 365/2000) and Bulgaria (the 2023 order). The Italian notice in the Official Gazette is missing from all issues from 07.2022 to 10.2026.

Still unverified: the articles of the Slovenian decree; the consolidated Lithuanian text after 1.03.2026; the adoption of the Croatian guidelines; the current version of the Bulgarian rule; the exact date on which the Slovak methodology was published.

Sources

Slovakia

Hungary

Portugal

Italy

Greece

Czechia

France

Germany

Croatia

Other states

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