S9+ launches Dublin Statement: Europe needs an open economy and a simple rulebook

The Dublin Statement sets out four guiding principles for European policymakers.

1. Build an open, strong economy

European startups must retain access to state-of-the-art technology, global markets, investment and high-value public data.

Europe should reduce genuine critical dependencies, but security requirements must be based on verifiable, auditable, technical and operational risks. Localisation mandates and automatic “European only” procurement criteria risk leaving European startups with fewer choices and weaker products.

The Coalition also calls for stronger pilot-to-procurement pathways, easier public purchasing from startups and the removal of barriers preventing capital from flowing across the Single Market.

Europe’s late-stage funding gap remains particularly urgent. Institutional investors and pension funds must be able to invest more easily in venture and growth companies across borders, while state aid rules must reflect the realities of startup growth.

The ongoing review of the EU Merger Guidelines should also recognise that mergers and acquisitions are part of a healthy innovation ecosystem. They can give innovative companies access to talent, infrastructure, capital and markets that would otherwise remain out of reach.

2. Create coherence and clarity in the digital rulebook

One European law should not become 27 different regulatory experiences.

The S9+ Coalition calls for one coherent and proportionate implementation of the AI Act across the Union. Guidance from the AI Office should be applied consistently by national authorities, while classification decisions and regulatory sandbox outcomes should be recognised across Member States.

The Digital Omnibus must also remove overlaps between the AI Act, GDPR, the Data Act and product-safety legislation before the AI Act’s high-risk obligations apply.

For startups, regulatory clarity is not a technical detail. It determines whether limited time and capital can be spent on developing products and reaching customers – or must instead be diverted towards navigating conflicting interpretations and duplicative compliance requirements.

3. Ensure easy access to cloud and compute

European AI startups run on cloud infrastructure. Their ability to innovate depends on access to sufficient computing capacity and the freedom to choose the technology that best meets their needs.

The objective of European cloud policy should therefore be to expand capacity, competition and choice – not to decide which providers startups are allowed to use.

The Coalition calls for stronger enforcement of the Data Act’s switching rules before new obligations are introduced. It also proposes a public provider-compliance scoreboard and an EU Cloud Sovereignty Framework that remains voluntary and technology-neutral.

Sovereignty assessments should reward quality, interoperability, open standards and the abolition of switching charges rather than the location of a provider’s headquarters.

European startups should also have a clear route into the EuroHPC AI Factories, while requirements aimed at critical sectors must not unintentionally restrict the infrastructure available to startups and scaleups.

4. End fragmentation through simplification and harmonisation

A founder in Tallinn, Lisbon or Dublin should be able to incorporate, hire, sell and operate across the European Union as if it were one market.

Today, startups still face 27 different regulatory regimes and widely varying national interpretations of common European rules.

The Dublin Statement therefore calls for 2027 to become a year of simplification and implementation. Before proposing new horizontal digital legislation, the Commission should assess the combined burden created by the GDPR, Data Act, AI Act, NIS2, Cyber Resilience Act and DORA.

The Digital Fairness Act should be paused in favour of better enforcement of the existing consumer acquis. At the same time, a genuine risk-based Digital Omnibus should simplify overlapping rules, enable pragmatic consent mechanisms for low-risk activities and provide a clear legal basis for using data in innovation and AI training.

The Coalition also calls for:

– EU Inc. to be adopted as a regulation in 2027, enabling digital incorporation within 48 hours and creating a harmonised framework for employee shares;

– mutual recognition of startup security clearances across Member States;

– a genuine European startup visa;

– and harmonised work permits that allow non-EU talent recruited in one Member State to work from another.