This will probably get the same type of response, but i wrote a message today regarding their plans for a new digital wallet app to prove your identity or age, that will only be distributed in the play store or app store. Sent in danish, translated with AI.
Hello,
I have read your memo on the new DKTB app. As it states, the app will only be available via the Apple App Store and Google Play—which requires citizens to create an Apple/Google account and accept their service terms.
I am very concerned about the consequences for citizens’ privacy and for Denmark’s goal of digital independence. At the same time, I see a practical opportunity to strengthen sovereignty without significant cost.
This is problematic for several reasons:
Citizens are forced to accept extensive and changing terms from foreign platforms in order to access Danish public services.
If Apple/Google change policies or remove an app, a large share of Danes could lose access to public services from one day to the next.
It deepens our dependence on U.S. tech giants. The government has just allocated DKK 80 million in the national budget to prioritize digital sovereignty. It makes little sense that brand-new public solutions are simultaneously limited to private, foreign distribution channels.
The parallel with MitID
MitID is distributed only via Apple/Google, and on Android it uses Google Play Integrity during activation. This excludes citizens who do not wish to accept Google’s terms, as well as security-oriented operating systems without Google Play Services, such as GrapheneOS.
There is also an independent and more secure method for this in the Android Open Source Project: Hardware Attestation. It meets the same need without requiring Google services.
Is Google Play Integrity also planned as a requirement for activating the DKTB app on Android?
To be clear, I am not suggesting that you remove your apps from these services; the issue is simply that no alternatives are offered. I struggle to see how this aligns with your ambitions for digital accessibility and protection of individual citizens’ privacy.
You could, in fact, achieve a great deal for little money—specifically:
Make Android apps that you develop or fund available as direct APK downloads via digst.dk (or a similarly trusted domain).
Use Android Hardware Attestation for security checks instead of Google Play Integrity where such checks are deemed necessary.
Require that software developed with your funding must not require an account with a private company in order to be activated or used.