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Family 5 · ~10 min read

Positive counter-examples

Cases that demonstrate that European open source sovereignty is possible: distributed projects, European foundations, structured public funding, alternative infrastructures.

Theses illustrated 06 · 08 · 11 · 12

European open source sovereignty is possible. The cases documented in the previous families could give the impression that every open source brick is captive to an American capture dynamic; that is not the case. There exist projects, foundations, funding programmes that demonstrate an alternative trajectory is technically, legally and economically viable. The cases that follow document these counter-examples, which inspire the manifesto’s positive programme.

An honest precision is in order at the outset. None of the counter-examples documented here has, to date, the critical mass of what it claims to replace. PostgreSQL is exceptional but near-unique in its model of distributed governance. The Sovereign Tech Fund distributes 17 million euros per year, against the tens of billions invested in the American ecosystem. Codeberg hosts roughly 117,000 projects — against GitHub’s 100 million-plus. The counter-examples demonstrate that this is technically feasible, not that it is already done at the necessary scale. This asymmetry is precisely what the manifesto’s positive programme calls to correct: moving from proof of concept to critical mass.

PostgreSQL — Distributed governance as a guarantee of durability#

Date : project initiated in 1986, current governance stable since ~2000 Status : ongoing, reference model Manifesto theses illustrated : 5, 6, 11

The fact#

PostgreSQL is one of the most widely used relational databases in the world, under a permissive licence close to BSD (PostgreSQL License). Its governance shows several characteristics rare in the modern open source ecosystem:

  • No dominant single sponsor. Contributions come from dozens of companies and individuals, with none reaching more than ~15-20% of commits.
  • Governance carried by the PostgreSQL Global Development Group, a collective without a single legal personality, animated by an international Core Team.
  • Multiplicity of independent commercial vendors: EnterpriseDB (US), Cybertec (Austria), Crunchy Data (US), 2ndQuadrant (UK, acquired by EDB), Ongres (Spain), Percona (US). None controls the project.
  • Geographic diversity of contributors: Germany, Japan, Russia, United States, France, United Kingdom, Argentina — without dominant national concentration.

What it demonstrates#

PostgreSQL is probably the most powerful counter-example available. It proves by example that:

  1. Open source under distributed governance is technically viable, even for globally significant projects of high technical complexity.
  2. No licence flip is possible without the consent of the global collective, which no single actor controls. This is exactly the inverse of the pattern documented in family 1.
  3. Multi-vendor commercial structure disciplines the project: no vendor can impose its roadmap without alienating the others.

PostgreSQL is the example to promote in European public policy: at functional equivalence, choosing PostgreSQL over MongoDB or Redis amounts to choosing a project structurally irrevocable rather than a project whose licence is revocable by a single sponsor.

Sources#

Sovereign Tech Fund (Germany) — The first structured public funding for OSS#

Date created : 2022 Status : operational, scaling up Manifesto theses illustrated : 8, 11

The fact#

The Sovereign Tech Fund (STF) is a German programme funded by the Federal Ministry for Economic Affairs and Climate Action (BMWK), created in 2022. Its mission is to directly fund the maintainers of open source bricks critical to global digital infrastructure, with priority given to projects without a commercial business model but essential to the ecosystem.

Among the emblematic projects funded to date, the Sovereign Tech Agency has publicly documented its support for curl (the HTTP transfer library used in billions of devices, maintained by Daniel Stenberg) and for GNOME (the Linux desktop environment). The STF more broadly targets dozens of structural bricks: cryptographic implementations (OpenSSL, GnuPG, OpenSSH insofar as they qualify as “digital base technology”), build-chain tools (Reproducible Builds), package managers and community foundations. The full list is published on the Sovereign Tech Agency website.

The STF’s annual budget has evolved from €3.5 million in 2022 at launch, to about €11.5 million in 2023, then €17 million in 2025 (source: European Commission). In 2024, the structure was made permanent in the form of a Sovereign Tech Agency, a subsidiary of the German agency for breakthrough innovation (SPRIND). According to the agency, more than 60 technology projects have been funded to date.

What it demonstrates#

The STF is the first public programme in the world to concretely recognise that the maintenance of software infrastructure is a public-interest mission justifying structured public funding. It demonstrates:

  1. Operational feasibility. The STF actually disburses funds, the maintainers concerned produce verifiable results, and the programme is renewed.
  2. The relative modesty of cost. For a few million euros annually, one secures the maintenance of bricks underpinning hundreds of billions of euros of global economic activity. The cost-benefit ratio is extraordinarily favourable.
  3. The model is reproducible. Nothing prevents France or the European Union from creating an analogous programme, with an equivalent or larger budget. The manifesto’s positive programme explicitly takes up this idea (axis 1).

Sources#

NLnet Foundation and NGI Zero — Distributed European funding#

Date created : NLnet 1997, NGI Zero programme since 2018 Status : operational Manifesto theses illustrated : 8, 11

The fact#

The NLnet Foundation is a Dutch foundation whose origins go back to the pioneers of the European internet in the 1980s. Since 1997, after the sale of the NLnet internet operator, the foundation has supported the development of the open internet through grants. Since 2018, it has administered the European NGI Zero funds (Next Generation Internet Zero), themselves funded by the European Commission via the Horizon 2020 and Horizon Europe programmes.

NGI Zero funds hundreds of European open source projects through modest grants (5,000 to 50,000 euros per project), with a philosophy radically different from traditional Commission programmes: little paperwork, fast selection, direct funding of developers without an institutional intermediary. The funded projects cover topics such as encryption, decentralised communication protocols, sovereign digital identity, accessibility tools, DNS security, and alternatives to dominant services.

A few emblematic projects funded: Tor, GnuPG, Wireguard (in its early days), Element / Matrix, PeerTube, Mastodon, Briar, Pixelfed.

What it demonstrates#

NGI Zero is the European distributed equivalent of the Sovereign Tech Fund, with a complementary philosophy: where the STF targets under-maintained critical bricks, NGI Zero funds the renewal of the ecosystem through many small innovative projects. Together, these two models sketch the architecture of European support for open source sovereignty. They prove that:

  1. Europe knows how to fund open source when it decides to. The brake is neither technical nor institutional, it is political.
  2. The models are already designed and operational. The manifesto’s positive programme proposes not to invent, but to scale up and make permanent these arrangements.

Sources#

Forgejo and Codeberg — The European alternative to GitHub#

Date : Codeberg founded in 2019, Forgejo created in December 2022 Status : operational, growing Manifesto theses illustrated : 7, 11, 12

The fact#

Codeberg is a source code forge hosted in Germany by the non-profit association Codeberg e.V., founded in September 2018 by seven founding members and whose codeberg.org platform was launched in January 2019. It offers a European alternative to GitHub for hosting open source projects, on infrastructure entirely controlled by a German organisation, with a registered office in the European Union explicitly chosen to escape requisitions linked to the US DMCA.

Forgejo is the software engine that powers Codeberg. It is a fork of Gitea, announced on 15 December 2022 under the auspices of Codeberg e.V., in reaction to the unilateral transfer of Gitea’s domains and trademarks to the commercial company Gitea Ltd. in October 2022. Forgejo became in February 2024 a hard fork of Gitea (diverging codebases), and benefits from funding by NLnet’s NGI Zero programme. The Fedora project announced in December 2024 its migration to Forgejo.

The combined Forgejo + Codeberg ecosystem provides a complete alternative to GitHub: code hosting, issues, pull requests, CI/CD (via Forgejo Actions), static pages, package registries. Several tens of thousands of projects are hosted there.

What it demonstrates#

Codeberg + Forgejo proves that an alternative distribution infrastructure to GitHub is technically and legally viable in Europe, without depending on a foreign actor. This infrastructure directly addresses the concerns raised by families 2 and 3 (foreign jurisdiction, captivity of distribution chains).

It also illustrates the mechanism of defensive fork: Forgejo was not born of a desire to duplicate, but as a reaction to a risk of commercial capture of Gitea. It is a model case showing how the community can react collectively when an open source project is under threat of flip.

A limit worth noting: the scale of Codeberg remains very modest compared to GitHub. This is precisely what the manifesto’s positive programme calls to correct, through massive European institutional and industrial support for this kind of alternative.

Sources#

Eclipse Foundation — A successful jurisdictional shift#

Date of the event : transition announced in May 2020, completed in 2021 Status : confirmed, operational Manifesto theses illustrated : 4, 11

The fact#

The Eclipse Foundation is a foundation historically hosting more than 400 open source projects, including the Eclipse IDE, Jakarta EE (formerly Java EE), and many projects for the automotive and IoT industries. On 12 May 2020, it announced its jurisdictional shift: it left its US status (501(c)(6) based in Delaware) to become a Belgian AISBL (international non-profit association), based in Brussels.

The new entity, Eclipse Foundation AISBL, was formally created and publicly announced on 14 January 2021. To note: the transition is not a complete relocation; the US entity Eclipse Foundation Inc. continues to exist in parallel during a transition period, and new members now join the Belgian AISBL. Membership fees were restated in euros from 1 October 2020.

What it demonstrates#

The Eclipse case is unique: it is to date the only documented example of a major open source foundation’s jurisdictional shift from US law to European law. It concretely proves that:

  1. Jurisdictional shift is legally possible. A foundation can migrate its seat, its operations, its intellectual property to another jurisdiction, without disruption to the projects it hosts.
  2. The cost and complexity are manageable. Eclipse accomplished this transition in about 8 months between announcement and formalisation, with no visible operational crisis.
  3. Other foundations could follow. No technical obstacle prevents Apache, the Linux Foundation or the CNCF from migrating to a European jurisdiction. The obstacles are political and cultural.

A nuance: the US entity Eclipse Foundation Inc. continues to exist in parallel during a transition phase, and the move is not an elimination of the link to the United States but a shift of centre of gravity.

This is the most operational counter-example available to defend a policy of incentives for migrating strategic foundations to a European jurisdiction, as proposed in axis 2 of the manifesto’s positive programme.

Sources#

NeoNephos and IPCEI-CIS — The coordinated European cloud-edge effort#

Date : IPCEI-CIS approved December 2023, NeoNephos launched 2024 Status : under construction Manifesto theses illustrated : 4, 11

The fact#

NeoNephos is an open source initiative hosted by Linux Foundation Europe, aligned with a broader European effort named IPCEI-CIS (Important Project of Common European Interest on Next Generation Cloud Infrastructure and Services). IPCEI-CIS, approved by the European Commission in December 2023, mobilises an estimated public/private budget of €3.5 billion to build a sovereign European cloud-edge continuum.

NeoNephos is the open source dimension of this effort: building a coherent set of software bricks for European cloud and edge service operators, with European governance, European contributions, and independence from the dominant American stacks.

What it demonstrates#

NeoNephos / IPCEI-CIS is the first European effort of this scale to explicitly recognise the need for cloud-edge infrastructure under European governance. It demonstrates that:

  1. The European Union knows how to mobilise significant budgets when the diagnosis is shared.
  2. European open source under European governance is an assumed political objective, not merely a declarative posture.

A limit to flag: the project is still recent and its success is not guaranteed. Linux Foundation Europe, which hosts NeoNephos, is itself an emanation of the US Linux Foundation — its true legal independence is to be watched. But the very existence of this coordinated effort is a positive signal.

Sources#

Opening: the Chinese contrast#

For the record, and without making it a model to follow, it is instructive to note that China has built in a few years a complete parallel open source ecosystem: the OpenAtom Foundation (June 2020) hosting OpenHarmony, openEuler, OpenAnolis; the host Gitee (12 million users); projects in EDA and the RISC-V architecture. This mobilisation capacity, set against European fragmentation, shows that the obstacle to European open source sovereignty is not technical feasibility — China has demonstrated it — but political coordination. Chinese models are to be studied methodologically, without sharing their political assumptions.

Sources#

→ Related operational commitments#

The counter-examples documented above did not emerge spontaneously: they are the product of explicit commitments — financial, organisational, political. The device translates them into concrete proposals that European actors can take up.

Full catalogue of commitments →

Read the manifesto →