Resources · What others have done~4 minutes
More than 20 European countries already have a design system for state services. Romania does not.
The situation in Europe (October 2026):
- More than 20 countries have an official or near-official system: from the very mature ones (the United Kingdom, the Netherlands, Italy, Norway, Germany) to the new ones (Estonia, since 2026).
- A few have no national system (the situation in October 2026): Romania, Bulgaria, Croatia, Slovenia, Malta, Latvia, Lithuania. Others 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).
- The European Union does not impose a common system on member states. The Commission has one only for its own websites.
A few examples, in brief
| Country | What they did | What I take from them |
|---|---|---|
| United Kingdom (GOV.UK) | The reference model worldwide. Each “recipe” (how you ask for an address, a date of birth) is tested with real people. Ministries extend it rather than replace it. | Research-based service patterns |
| The Netherlands (NL Design System) | Shared building blocks, but each municipality applies its own colours. About 45 organisations have their own theme. Components go through maturity stages. | A shared model with themes per institution; the maturity stages |
| Norway (Designsystemet, Aksel) | A national system with a theme for each organisation. The Labour and Welfare Administration (NAV) has a knowledge portal, not just a list of building blocks. | Documentation as a knowledge portal |
| Germany (KERN, KoliBri) | Building blocks built with accessibility first, independent of the technology used. The standard remains voluntary; the law requires service quality, not the system. | Technology-independent components |
| France (DSFR) | Mandatory for state websites, through a Prime Minister’s circular. Prohibited for local authorities. 75 priority websites, the rest being redone. 24 months to adopt a new version. | A list of priority services and the 24-month rule |
| Italy (Designers Italia) | Mandatory guidelines, plus €400 million from the recovery and resilience plan (PNRR) for municipalities, paid only after an external expert checks the adaptation. | Money for municipalities, paid after verification |
| Portugal (Ágora) | Mandatory by decree-law, with timetables per ministry, until 2028. An IT contract without approval is void. Municipalities are not included. | An initial inventory and public timetables |
| Slovakia (ID-SK) | Mandatory by law, with the minimum requirements in an annex to a decree. A new component is assessed within 10 + 10 working days. A feedback bar is mandatory. | Clear minimum requirements; fixed deadlines for new components |
| Hungary (DÁP) | A law and a government decree. Those who build are separate from those who check. Strong levers: stopping funding, suspending the service. | Separating building from checking |
| Finland | The accessibility law requires a reply to complaints within two weeks. | A short response deadline |
| Estonia (TEDI) | A central system, launched in 2026. | Proof that you can still start now |
The closest to us: the Republic of Moldova
Since October 2025, the Republic of Moldova has had the Modelul Unitar de Design (MUD, the Unified Design Model), approved by government decision. It is built in Romanian, has 44 components, and its code is public, under a licence that allows free reuse.
What this means for us: part of the work has already been done, in our language. I propose that the first technical test should check whether this code can be adapted for Romania.
Note: MUD’s documentation and design files have a more restrictive licence than the code. For those, an agreement between the two governments would be needed.
The American lesson: excellent ideas, high risk
The American system (U.S. Web Design System, USWDS) is the most reused government design system in the world. Denmark took it over as the basis for its own system.
What it did very well:
- the trust banner, which helps you recognise an official website;
- colours calculated so that contrast is automatically correct;
- public test pages for each component;
- automatic, public measurement of adoption.
What did not work:
- adoption remained a minority: after 11 years, only about 15–23% of federal websites used it, because the law only recommended using it;
- it depended on a single team. In 2025–2026 the team was cut to almost one person, no version was released for 15 months, and the community announced a fork of the project.
The lesson: a design system needs a permanent team, a protected budget and written rules. Not just good ideas.
Three lessons from all of this
- Build first, require later. All countries that made a design system mandatory built it first.
- Money persuades better than fines. The levers that worked are conditions for funding and for approving projects, not fines.
- Without a stable team, any system dies. Both in Romania (2016–2017) and in the US (2025–2026).
For specialists
- Architecture families: derived from GOV.UK (HTML/CSS, Nunjucks); federated with themes through tokens (NL, NO, DE); a core of web components with adapters (KoliBri, gov.cz, DÁP); a single framework (Suomi.fi, Ireland, Switzerland).
- Licences: EUPL-1.2 is the default European licence (NL DS, KoliBri, KERN, gov.cz, ECL); MIT is the second.
- Legal acts: only Slovakia, Hungary and Portugal have an act with the force of law that explicitly requires the system; Italy, Greece, France and Czechia impose it indirectly; Germany imposes quality, not the system.
- Local government: Slovakia, Portugal and France exclude it; Italy funds it (~6,000 municipalities aligned through PNRR 1.4.1).
- USWDS: CC0; adoption 15–23% of active federal websites (25–28% of page views); none of the 9 GSA standards was “mandatory” in October 2026; Section 508 compliance score of 1.96/5 (FY2025).
- MUD: Moldovan Government Decision (HG) no. 677/2025; code
egov-moldova/design-system(MIT, Stencil, DTCG tokens, texts ro-MD / en-US / ru-MD); documentation on mud.egov.md under CC BY-NC-ND 4.0.
What I base this on
The links lead to the public versions of my research documents; the section number (§) takes you straight to the paragraph cited.
| Statement | Document | Where |
|---|---|---|
| More than 20 countries; those without a system | European rules; Design systems in Europe | §0 (point 4); §1, §9 |
| The country details (GOV.UK, NL, NO, DE, FR, IT, PT, SK, HU, EE) | Design systems in Europe | §1, §3–§6, §11 |
| The legal acts, the levers, local government | EU member states' laws | §1, §2, §3, §5 |
| Finland, 2 weeks | The full proposal; EU member states' laws | §5; §6 |
| What we take over, what we avoid | The full proposal | §5 |
| MUD: MIT code, 44 components, texts in Romanian; the documentation licence | What already exists in Romania | §13 |
| MUD: HG 677/2025, approved in October 2025 | Design systems in Europe | §7 |
| USWDS: adoption, the crisis, what is worth taking over | The American system (USWDS) | §0, §4, §6, §8 |