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title: "Intermediaries and Operators"
canonical: "https://archive.dssc.eu/space/bv15e/766065352/Intermediaries%20and%20Operators"
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> Macro (toc)

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# 1. Summary 

A data space needs services that enable and mediate data exchange; these technical services may be self-deployed or provided by service providers. Such service providers can also be participants in the data space. As data space participants, they are also part of the governance framework of a data space and are acknowledged in the data space rulebook. These service providers can either be called operators of the data space or intermediaries within the data space. Using these terms is established within the industry and has legal dependencies. It is also important to distinguish between general infrastructure service providers with no relationship to data space governance and the data services transacted within a data space.  

The term ‘operator’ is usually applied when a single service provider is providing most of the core services for the data space, and the term ‘intermediary’ is usually used when there are multiple service providers who *collectively* provide these services. (See *The Difference Between Intermediaries and Operators* below for more details on this distinction). Intermediaries are broadly considered to be service providers that provide different federated, value creation, and/or participant agent services for the data spaces. 

The core role of intermediaries and operators is to provide federated and participant agent services as described in the technical [section of the blueprint](https://dataspacessupportcentre.atlassian.net/wiki/spaces/bv15e/pages/766067344), but they may also facilitate growth and offer non-technical business services to the data space. For example, they can simplify transactions between participants within a single data space and potentially facilitate connections to other data spaces. This makes it easier for the data space to become more efficient, reliable, and user-friendly, making it easier for the data space to scale. Federated, value creation, and participant agent services can be provided by self-hosting and/or by participants via distributed means. Hence, no specific intermediary or operator is necessary. Often, however, having a specialised provider for these services may be a more practical approach and provide the scalability, efficiency, usability, and reliability benefits for the data space already referred to.

The type of services an intermediary or operator provides significantly impacts whether a service provider falls under the Data Governance Act or some other legal framework. This building block also describes how intermediaries can be categorised as core service providers, agency service providers, and personal data intermediaries. The building block also explains how intermediaries and operators can collaborate within the data space. 

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# 2. Purpose of the Building Block

Overall, common European data spaces are a practical implementation of the European data strategy and a means to enable the objectives of data sovereignty and fair and trustworthy data exchange of that strategy. Technically, it is possible to build data spaces without intermediaries or operators with only self-hosted and/or fully distributed provision of the services that intermediaries and operators provide. An often expressed fear in an arrangement with a single operator is that this operator takes too central a business role within the data space. In such cases, an operator may turn into a gatekeeper, which would ultimately go against the objectives of the sovereignty of data rights holders like companies and people. This building block aims to elaborate and explain how the business benefits of applying operators and intermediaries can be achieved without compromising the data sovereignty of the data space participants or other data rights holders, like natural persons.

In more detail, this building block has four key purposes.

**First, this building block aims to support the designers of individual data spaces in understanding their practical options regarding services that intermediaries and operators can provide.** The primary purpose of this building block is to provide data space designers awareness about the different options, possibilities, and limitations of having intermediaries and operators providing federated services and participant agent services for their data space (as opposed to having these services self-hosted and/or provided by purely distributed means).

**Second, this building block aims to support the data spaces community in aligning on the role of operators and intermediaries conceptually in the context of data spaces in general.** This building block seeks to establish the position of operators and intermediaries among the wider data space community. These actors may eventually provide services for multiple data spaces if their role and use is conceptually aligned across data spaces. Mature and established service providers that focus on providing these services for data spaces may significantly advance the data spaces industry, support cross-data space interoperability, and boost the growth and adoption of individual data spaces.

**Third, this building block aims to clarify the relationship between *****governing *****operators and intermediaries in the context of data spaces and *****regulating *****them in the broader context of the single digital market. **This building block aims to clarify the alignment between the governance of a single data space and the general regulation and legal frameworks related to operators and intermediaries functioning within data spaces. Both data space governance frameworks and legal frameworks aim to enable efficient and trustworthy data spaces, but achieving clarity on the relationship between these frameworks and ensuring their alignment is not a straightforward task. 

**Fourth, challenges and risks are involved in including operators and intermediaries in data spaces. This building block elaborates on how to mitigate these challenges. **Most of these risks are similar to those that any companies have when they acquire services from external providers, such as contractual and pricing risks, vendor lock-in, challenges stemming from switching service providers, sustainability of the service provider, and service provider compliance.

A data space designer can mitigate these risks by establishing good governance, applying and enforcing established standards and technologies that are open and accessible, and designing data spaces that include multiple operators and intermediaries to spread out the risks associated with dependency on a single service provider. 

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# 3. Elements and Their Key Functions

## The Difference Between Intermediaries and Operators

For the purposes of this building block, we refer to actors in a single service provider scenario as operators and actors in multiple service provider scenarios as intermediaries.

In other words, we use the term ‘operator’ when a single actor provides the core services of a data space. Operators usually have direct control over the data space they manage and are responsible for its operation, ensuring functionality and reliability. In contrast, we use the term ‘intermediaries’ when there are multiple service providers within a data space, each providing only one or some of the core services or functions for a data space. They facilitate transactions but do not have direct control over the systems involved.

In practice, the terms ‘operator’ and ‘intermediary’ are used interchangeably; for example, “data space orchestrator” is sometimes used in single service provider scenarios. 

## Three Types of Intermediaries

The term ‘intermediary’ is applied broadly, and depending on the perspective, the reader might have specific orientations. (See section “Regulatory and Legal Compliance” for the relationship between the term ‘intermediary’ as we use it and the legal concepts of, for example, the DGA “data intermediation service provider” and the DSA “online intermediaries”.) Also, big internet platforms such as Google and Meta can be referred to as intermediaries, which, yet again, is not aligned with the definition we are promoting in this building block. We use the ‘intermediary’ term generically to refer to entities that act between participants and facilitate transactions. It is important to understand that in data spaces, intermediaries may focus on facilitating interaction in the control plane instead of intermediating the physical transaction of the data.

Intermediary classification is important since it is the foundation for how the different service providers can be acknowledged in the governance framework of a data space and in the rulebook that documents it. We recognise three different types of intermediaries in data spaces: 

1. **Core Intermediaries and an Operator.** These actors *collectively* provide [federated services](https://dataspacessupportcentre.atlassian.net/wiki/spaces/bv15e/pages/766067401) that are common for all data space participants and defined as necessary in the governance framework and rulebook of the data space. The procuring entity is often the data space governance authority, but individual data space participants may also have commercial relationships with these intermediaries for services used in the context of the data space. If all these services are provided by a *single* actor and not by a set of *multiple* actors, that actor would be referred to as an ‘operator’.
2. **Agency Intermediaries.** These intermediaries provide services for the data space participants. Therefore, the participants are customers of these service providers. These services are listed in [Participant Agent Services](https://dataspacessupportcentre.atlassian.net/wiki/spaces/bv15e/pages/766067472), but it should be noted that these intermediaries may also provide other services that further ease the exchange and application of the data products and value creation services. While the service-providing agreement is bilateral between the participant and agency intermediary, there is also the contractual relationship between the data space (governance authority) and agency intermediary through the rulebook, which gives the data space control over the intermediary or collaborative business models between the data space governance authority, operator or core intermediaries, and agency intermediary.
3. **Personal Data Intermediaries.** These can be considered a subclass of agency intermediaries since individuals are also essential stakeholders in the data space if their personal data is exchanged in the data space. Personal data intermediaries focus mainly on providing consumer-facing, B2C services such as consent management, but they may also provide other individual-related data management services such as dashboards, personal wallets, and other data storage solutions that may be essential for the success of the data space. For example, a skills data space is built by using personal data intermediaries.

Different types of intermediaries should be subject to governance involving rules and roles within the data space and its governance framework, in addition to being subject to different kinds of EU and national regulations. The sections “Governance of Intermediaries and Operators” and “Regulatory and Legal Compliance” below discuss these two aspects of intermediaries and operators in more detail.

## Common or Core Intermediaries

All data spaces have a set of functionalities essential for the operation of that specific data space. These are classified as [federation services](https://dataspacessupportcentre.atlassian.net/wiki/spaces/bv15e/pages/766067401). Whichever functionalities this set includes, a data space has three options for ensuring them: 1) It can have all these functionalities self-hosted by participants and/or delivered by purely distributed means, 2) it can have a single operator provide all these functionalities as a set of services, or 3) it can have these functionalities provided as discrete services by a set of common or core intermediaries.

## Participant Agency Intermediaries

Participant agency intermediaries (or agency intermediaries for short) are not compulsory elements for data space design. These intermediaries focus on providing [participant agent services](https://dataspacessupportcentre.atlassian.net/wiki/spaces/bv15e/pages/766067472), that help data providers and data users connect to the data. A data space may recognise such service providers as optional roles, or they might enforce the application of recognised service providers. The rationale behind a data space wanting to mandate the use of certified agency intermediaries may be related to the business model of the data space or the transparency requirements. 

Agency intermediaries are directly incentivised to acquire new customers, and while doing this, they are primarily inviting new participants to the data space. This facilitates the growth of the data space. In the case of multiple agency intermediaries, they have an incentive to differentiate and develop more value for their customers, which may lead to a better value proposition for the entire data space. There are multiple options on how agency intermediaries are financially related to the data space. There might be scenarios when agency intermediaries pay a fixed participation fee, but there are also rationales for charging dynamic and subscription or transaction-dependent fees to the agency intermediaries. There may also be cases, such as the case of personal data intermediaries, in which some agency intermediaries get compensated when providing services for the data space. This is a relevant case when considering that there is no clear motivation for individuals to pay to be participants in the data space, and the data space has a significant motivation to provide good usability and other personal data management services for individuals participating in the data space. An example of one of these services might be providing consents needed in the data exchange. 

## Personal Data Intermediaries

A personal data intermediary can be considered a category within participant agent intermediaries since an individual participates in the data space. However, a personal data intermediary may be used to provide common consent management services, which is one of the federated services under policy information point services acknowledged within the data space. Also, since people are unique types of participants with unique roles in data spaces, we consider personal data intermediaries to be an independent element.     
A data space may have a design with one federated personal data intermediary or a model where individuals can choose their own personal data intermediaries which compete against each other. Currently, there are multiple personal data intermediaries on the market, but for practical reasons, the interoperability between personal data intermediaries is not well-established; for example, consent management data spaces often decide on a single personal data intermediary. Emerging European digital wallets are expected to provide identification and credentials storage capabilities for individuals, and there are established patterns on how multiple wallet providers can interoperate. Personal data intermediaries facilitating consent management in data spaces are generally expected to be within the scope of the Data Governance Act. Wallet providers that act within the European Digital Identity are subject to legal requirements by the eIDAS2 legislation.   
Personal data intermediaries may also provide the means for individuals to collect and share their data directly. For example, they may use personal data storage and pods to facilitate data collection and sharing within data spaces. In this kind of situation, the individual may also become a data provider and not just a participant who is a data rights holder within the data space. Also, personal data intermediaries may provide dashboards and other analytical services for individuals to use their data. In this situation, an individual may also become a data consumer within the data space.     
Personal data intermediaries should act in the best interest of individuals to help them protect their personal data. This includes helping individuals understand who is using their data and the consequences of providing consent. In this way, the personal data intermediary functions as a medium that enhances individuals' comprehension and, ultimately, trust in data exchange. This may be a critical element in achieving successful data exchange of personal data in data spaces.

## Service Providers Who Are Not Intermediaries or Operators

There are examples of technical service providers that are not participants in a data space and, therefore, not subject to the data space governance framework. This is relevant, especially for cases of participant agency service, where the procuring customer is the participant, not the governance authority. For example, large cloud service providers are exploring the possibility of providing data space connectors in their general cloud services offering. In this case, the data space governance authority does not have any means to enforce its specific governance rules on, for example, transparency or acceptable financial models for this service provider since there is no contractual relationship between the governance authority and the service provider. However, the service provider is providing purely technical means to the user of this service. Hence, the business participant, who is either a data consumer or provider, is responsible for all governance aspects related to these services. Also, in this case, the service provider and data space do not have a business relationship, which may impact the data space business possibilities since it cannot introduce, for example, fees for the service providers. 

## Governance of Intermediaries and Operators

The governance framework of a data space is an essential way to manage how intermediaries provide value for the data space and how a data space manages the risks associated with using intermediaries and operators. The first step is to include the governance of intermediaries or an operator in the overall governance framework and to document it in a rulebook.  
A data space may and, in many cases, should have a registry of the intermediaries participating in the data space. The data space may use this registry to indicate who the compliant service providers are for the participants. This function is analogous to many platforms' functions for compliant service providers that can intermediate access to the platform. A data space governance framework may require that intermediaries and operators undergo audits and/or adhere to certain transparency requirements if they wish to participate in the data space to provide services within it. Additionally, the governance framework may impose certain fees or revenue-sharing obligations on intermediaries and operators as part of the business model of the data space as a whole (and in contrast to the business model of any individual actor in the data space). Finally, a data space governance framework can have rules that declare switching between the services of different competing intermediaries or operators must be allowed in order to avoid dependency on a specific business or vendor lock-in issues. In practice, however, the fungibility of providers of federated services may be limited by the lack of other fitting options available on the market.

## Regulatory and Legal Compliance

In addition to being subject to the internal governance of a given data space in which they participate, intermediaries and operators are also subject to laws and regulations that apply more widely to all data spaces and the actors within them, such as competition and intellectual property laws and regulations.

Further, some regulations apply the specific language of ‘intermediation’. The most notable of these is the Data Governance Act (DGA), but this language is also featured in other EU legislation, e.g., in reference to online intermediaries as regulated under the Digital Services Act (DSA).

The DGA regulates a specific kind of data intermediary, namely data intermediation service providers (DISPs) and establishes a procedure and a register for DISPs. DISPs act as neutral intermediaries between data providers and users, ensuring secure and efficient data exchange. The DGA provides a binding legal framework for DISPs with requirements to gain recognition, ensuring transparency, security, and fairness and non-discriminatory access. It regulates the types of uses that an intermediation service provider can make of the data and obliges a strict separation between data intermediation services and other services. It also sets a fiduciary duty for personal data intermediation providers.

The DGA aims to facilitate data sharing across the EU, promoting a single market for data. It is a compliance element for intermediaries and operators, which implies restrictions, duties, and transparency but also enables recognition and differentiation. The DGA seeks to enhance data accessibility, foster innovation, and ensure compliance with data protection regulations. It is designed as enabling legislation for trusted data exchange and trusted intermediaries.

The DGA should be perceived as an enabler for trusted data exchange and data space in general, and intermediaries that are DISPs provide an additional trust element for this kind of service provider. 

## Intermediary Collaboration and Interoperability

Intermediary collaboration is an important design aspect when creating resilient and scalable data spaces. The collaboration between intermediaries and operators can be divided into the following types.

1. Collaboration between core intermediaries that provide different federated services.
2. Collaboration between core intermediaries that provide the same federated services.
3. Collaboration between agency intermediaries.

Collaboration between intermediaries that provide different federated services, for example, one providing registry services and another observability service, requires that the different intermediaries must be compatible with each other by conforming to the use of the open standards and frameworks that are explained in the DSSC blueprint such as DCAT, ODRL or Gaia-X.  

Collaboration between intermediaries that provide the same federated services may occur, for example, in the context of having multiple connected registry services (e.g., country-specific registries) or multiple credential-issuing services. In theory, at a functional level, the collaboration between service providers can be explained and analysed case-by-case, but in practice, the collaboration topic is more complex, especially if the federated services are provided by an operator.

In practice, operator collaboration and interoperability becomes a topic of federation and collaboration between data spaces since a data space with a single operator does not scale as easily as a data space with multiple operators. Still, collaboration can be achieved by interoperation between data spaces. The evolution of a data space from a single-operator model to something else should be considered in the early development phases of the data space and is a core design choice.

For participant agency intermediaries the topic of interoperability and collaboration is different. If there are multiple recognised agency intermediaries in the data space, and participants can freely choose their services, then the data space is following a four-corner model. Generally, the four-corner model, which resembles organisations in the banking and teleoperator sectors, provides the most freedom for participants. In practice, the business significance of the four-corner model depends on whether data space mandates the use of agency intermediaries and whether agency intermediaries have a common business model. 


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# 4. Co-Creation Questions

> ℹ️ - Which parties will offer what services?
> ℹ️ - Which functionalities of the data space could or should be provided by dedicated intermediary service providers?

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# 5. Links to Other Building Blocks

Some of the services that intermediaries could provide are described in the **technical building blocks**. These services enable **data transactions** for the **transaction participants** and data space operations for the **governance authority**. Deciding which of these data space-enabling services an intermediary provides and how is an important design choice.

The following building blocks are important to consider when looking at the intermediary:

**[Participation Management](https://dataspacessupportcentre.atlassian.net/wiki/spaces/bv15e/pages/766065896)****:** Participation Management has technical and governance elements that relate to the intermediaries in two ways. Also, the participation of intermediaries must be managed, and intermediaries may play a significant role in producing services for participant management, including enrolment and participant attraction.

Intermediaries may contribute significantly to defining and developing a data space [use case](https://dataspacessupportcentre.atlassian.net/wiki/spaces/bv15e/pages/766064885) and act as an orchestrator of the data space.

**[Business Model Development](https://dataspacessupportcentre.atlassian.net/wiki/spaces/bv15e/pages/766064638)****:** Intermediaries may provide services in multiple data spaces. Working with many data spaces can provide them with more business opportunities and support easier interoperability. Depending on the data space design, various intermediaries may also substitute for each other and compete. Together, data spaces can be perceived as a market for intermediaries, especially if there are collaboration arrangements between intermediaries.

**[Regulatory Compliance:](https://dataspacessupportcentre.atlassian.net/wiki/spaces/bv15e/pages/766066158)** Intermediaries may be subject to the Digital Governance Act (DGA). This topic is also elaborated on in the regulatory compliance building block.

The building block actively refers to the concepts of federated services and participant agent services, which are explained in [Services for Implementing Technical Building Blocks](https://dataspacessupportcentre.atlassian.net/wiki/spaces/bv15e/pages/766067344).


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# 6. Future Topics

This version of the building block was revised to better align with the [service categorisation and functional overview of the software components.](https://dataspacessupportcentre.atlassian.net/wiki/spaces/bv15e/pages/766061351)

The building block will be further developed with more examples and concrete guidelines, particularly in the following areas:

- More detail on how data spaces should advance the notification and certification of intermediaries as data intermediation services under the Data Governance Act.
- Elaboration on business models for the intermediaries.

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# 7. Further Reading

- Bobev, Tervel et al. 2023. “White Paper on the Definition of Data Intermediation Services.” doi:[10.2139/ssrn.4589987](https://doi.org/10.2139/ssrn.4589987).
- “Data Intermediaries and the DGA: Understanding and Complying with the DISP Label.” *European Big Data Value Forum*. [https://european-big-data-value-forum.eu/session/data-intermediaries-and-the-dga-understanding-and-complying-with-the-disp-label/](https://european-big-data-value-forum.eu/session/data-intermediaries-and-the-dga-understanding-and-complying-with-the-disp-label/).
- “European Data Governance Act | Shaping Europe’s Digital Future.” 2024. [https://digital-strategy.ec.europa.eu/en/policies/data-governance-act](https://digital-strategy.ec.europa.eu/en/policies/data-governance-act).
- Gras, Nora. 2023. “IDSA Position Paper Explores Data Governance Act and Data Intermediaries.” *International Data Spaces*. [https://internationaldataspaces.org/idsa-position-paper-explores-data-governance-act-and-data-intermediaries/](https://internationaldataspaces.org/idsa-position-paper-explores-data-governance-act-and-data-intermediaries/).
- Langford, J., Poikola, A., Janssen, W., Lähteenoja, V., & Rikken, M. (2020). [Understanding MyData Operators. ](https://www.mydata.org/wp-content/uploads/2022/07/Understanding-MyData-Operators-2022-1.pdf)*[MyData Global.](https://www.mydata.org/wp-content/uploads/2022/07/Understanding-MyData-Operators-2022-1.pdf)** *
- Micheli, Marina et al. 2023. “Mapping the Landscape of Data Intermediaries.” *JRC Publications Repository*. doi:[10.2760/261724](https://doi.org/10.2760/261724).
- “Peppol Interoperability Framework.” *OpenPeppol*. [https://peppol.org/learn-more/peppol-interoperability-framework/](https://peppol.org/learn-more/peppol-interoperability-framework/).

## Documents and Guidelines to Implement the Building Blocks

For the Data Governance Act:

- “European Data Governance Act | Shaping Europe’s Digital Future.” 2024. [https://digital-strategy.ec.europa.eu/en/policies/data-governance-act](https://digital-strategy.ec.europa.eu/en/policies/data-governance-act).
- Micheli, Marina et al. 2023. “Mapping the Landscape of Data Intermediaries.” *JRC Publications Repository*. doi:[10.2760/261724](https://doi.org/10.2760/261724).
- For understanding personal data intermediaries read Understanding MyData Operators.
- Langford, J., Poikola, A., Janssen, W., Lähteenoja, V., & Rikken, M. (2020). [Understanding MyData Operators. ](https://www.mydata.org/wp-content/uploads/2022/07/Understanding-MyData-Operators-2022-1.pdf)*[MyData Global.](https://www.mydata.org/wp-content/uploads/2022/07/Understanding-MyData-Operators-2022-1.pdf)** *

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# 8. Glossary

| **Term** | **Definition** |
| --- | --- |
| **Operator** | **Service** provider that provides most of the **federation services** that are common to all **participants** of the data space.<br>---<br>*Explanatory text:*<br>*We use the term ‘operator’ when a single actor has more or less direct control over the data space they manage and when it is responsible for the operation of the data space, ensuring functionality and reliability. Compare with “Common intermediary”.* |
| **Common intermediary** | A party who provides **federation services** that are common to all **participants** of the data space. |
| **Participant agent intermediary** | A party who provides **participant** **agent** **services** for the data space** participants** as defined by the data space **governance framework**. |
| **Personal data intermediary** | A specific **participant agent intermediary** that is focused on providing **services** for natural persons. |