Title: OZG in Federalism: A Support Gap Caused by Unresolved Responsibilities
AI-authored by Reinhard Brückner; reviewed and published under human editorial responsibility.
In 2024, the eGov-MV municipal association stopped supporting municipalities with the implementation of the Online Access Act (OZG). According to a report by Haufe, the reason was the absence of an administrative agreement with the state of Mecklenburg-Western Pomerania. The state later joined the association. A period therefore passed between the end of the support and the accession, during which a necessary institutional link remained unresolved. This is not a technical detail. It shows how a digital state mandate can become stuck in an incomplete chain of responsibilities.
The Decision and Its Effect
The Online Access Act obliges the federal government and the Länder to provide digital access to administrative services; municipalities implement many services within the Länder’s areas of responsibility. The requirement is formulated nationwide. Implementation, however, takes place within a federal structure in which responsibilities, financing, operations and technical support are distributed across several levels. The federal government sets the legal framework. The Länder coordinate and provide support. Municipalities must integrate the services into their own processes and portals.
This division of labour can make sense when it is connected by clear agreements. It becomes an obstacle when one participating level does not sign the necessary agreement and an existing support mechanism consequently fails. That is precisely the gap illustrated by the case of Mecklenburg-Western Pomerania. The municipal association could not place its services permanently on an institutionally unresolved foundation. The state, for its part, remained outside the association until its accession.
This created a typical gap between a decision and its effect. Formally, the mandate to digitise existed. In practice, the architecture needed to translate it into municipal administration was missing. For citizens, however, it does not matter whether a law has been passed or a responsibility divided internally. What matters is whether an application can be submitted, processed and completed digitally.
A Pattern That Repeats
The case does not stand alone. The Bebast FAQ describes the project as divided into modules with distinct responsibilities (source: FAQ, Modul F). This can facilitate the division of labour, but it also makes clear that digital administrative services are not automatically rolled out by a central body. A fragmented implementation without effective central coordination has also been described in Offenbach. A press release from CDU Offenbach describes the practical tension between local requirements, state-level structures and the absence of overarching coordination.
These examples are not identical in every respect. But they show the same mechanism: the federal government formulates a uniform requirement, while implementation depends on agreements between multiple organisations. Each level can formally fulfil its task, while the overall system remains slow. Responsibility is distributed, but dependency remains.
Estonia takes a different approach with X-Road. The platform is not a central database, but shared infrastructure for the secure exchange of data between public authorities and other authorised organisations. Individual bodies retain their data and responsibilities. The exchange, however, follows common technical and organisational rules. As a result, a new fundamental connection between all parties does not have to be negotiated for each individual service.
The qualitative difference lies in the implementation architecture. Estonia does not centralise every administrative function, but it standardises the connections between its parts. Germany, by contrast, often distributes responsibility for those connections as well. When an administrative agreement is not concluded, this creates more than an administrative delay. A load-bearing part of the system is missing.
The Cool Conclusion
The case of Mecklenburg-Western Pomerania does not support the general claim that federalism inherently prevents digital government. It demonstrates something more precise: digital projects in a federal system require binding interfaces because services must function across administrative levels, both technically and organisationally. When that interface is missing, there is no automatic incentive for a rapid solution.
The municipal level bears the pressure to implement, but does not hold all the necessary decision-making rights. A municipal association can offer support, but cannot guarantee it permanently without clarified financing and membership. The state can coordinate, but must commit to a specific operational and cooperation structure. The federal government can set objectives and deadlines, but does not have complete control over municipal implementation.
This produces a structure in which delay is rationally possible. No individual decision has to be spectacularly wrong. It is enough for the agreement to remain unresolved. The digital state then waits not for a technical innovation, but for a decision on responsibilities. Under these conditions, the period between the end of support and accession is not an accidental operational failure. It is the result of an architecture that does not reliably resolve blockages.
Bauplan
The next step would be nationwide, binding OZG governance that regulates not only objectives but also the connections between administrative levels. The federal government and the Länder would have to conclude administrative agreements for every jointly operated infrastructure, with clear responsibility, financing and operational ownership. These agreements could not be treated as voluntary additions after the political decision. They would be the implementation of the decision itself.
This would require an escalation mechanism. If an agreement is not reached within the prescribed process, the matter would have to be automatically referred to a higher-level coordinating body. That body would be tasked with establishing an interim solution so that municipalities do not lose access to support. The mechanism would not have to centralise every decision. It would only have to prevent an unresolved responsibility from interrupting operations for years.
The Estonian X-Road model provides the relevant indication. The aim is not to transfer every register and authority into a central organisation. It is to establish binding common standards for identity, data exchange, security and accountability. Länder and municipalities could retain their specialist processes. But the connection between them would have to be treated as public infrastructure.
Implementation depends on a clean separation. Nationwide governance should standardise common rules and escalation, but should not exclude every local variation. Otherwise, the necessary connection would become a new central bureaucracy. The opportunity lies in a shared foundation that enables local implementation while preventing individual administrative agreements from blocking progress across the entire system.
The problem is not the absence of a digital solution, but the absence of an agreement on who is to bring it into operation nationwide with binding authority. The appropriate perspective belongs in Volume 2 “Überholt.” The quiet channel “Für die Verwaltung” is intended for public administrations.