Saatja: "info - MKM" <
[email protected]>
Saaja: "Justiits- ja Digiministeerium" <
[email protected]>
Teema: Inquiry on Data Embassy Implementation and Legal Frameworks
Kuupäev: 2026-01-13 13:56
Tere
Edastame kuuluvuselt Justiits- ja Digiministeeriumile.
Heade soovidega
Rahandusministeerium
From:
[email protected] <
[email protected]>
Sent: Tuesday, January 13, 2026 1:51 PM
To: info - MKM <
[email protected]>
Subject: [DKIM katki]Inquiry on Data Embassy Implementation and Legal
Frameworks
Importance: High
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Dear madam/sir,
I hope this message finds you well.
On behalf of Curaçao, I would like to express our appreciation for Estonia’s
leadership in digital governance and, in particular, your pioneering work on
data embassies as a mechanism to safeguard digital sovereignty and
continuity of government.
Curaçao is currently exploring, at a policy level, the possibility of
hosting data embassies for foreign states or international institutions. Our
objective is to understand best practices, legal frameworks, and practical
considerations.
In this context, we would greatly value your insights on the following
questions:
1. Initiation of the process
• How did Estonia structure the decision-making
process to establish data embassies?
• Which governmental actors were essential at
the outset (e.g., cabinet, parliament, ministries, cybersecurity
authorities)?
2. Legal foundations
• What legal instruments were used to establish
data embassies (national legislation, bilateral treaties, administrative
agreements)?
• How was extraterritoriality or special legal
status defined in practice?
3. Host–state relationship
• What legal guarantees were considered
indispensable from the host state to ensure data sovereignty and immunity?
• How were conflicts of law and jurisdiction
addressed?
4. Scope and limitations
• What types of data or state functions were
initially considered suitable for data embassy hosting?
• Were there explicit limitations or exclusions
to manage political, security, or reputational risks?
5. Governance and oversight
• How were cybersecurity oversight, audits, and
incident response responsibilities allocated between Estonia and the host
state?
• Which institutional arrangements proved most
effective?
6. Lessons learned
• What legal or institutional challenges emerged
that you would advise other jurisdictions to anticipate early?
• Are there elements you would recommend
approaching differently today?
In addition, as Curaçao operates within the Kingdom of the Netherlands,
where foreign affairs and treaty-making are Kingdom competencies:
• Are there specific considerations when
developing a data embassy framework within such a constitutional structure?
• Would you recommend early involvement of
Kingdom-level authorities in treaty design and agreements?
We would welcome the opportunity for a technical or policy-level exchange,
whether through written correspondence or a virtual meeting, should this be
of interest to you.
Thank you very much for your time and for your continued leadership in
shaping responsible and resilient digital governance.
Yours sincerely,
Kind Regards | Saludos Cordiales | Atentamente | Met vriendelijke groet |
Atenciosamente |
Claudia Ramirez
Senior Policy Officer | Directorate of Foreign Relations
Ministry of General Affairs
Fort Amsterdam no. 4. Curaçao
T: 463-0127
E:
[email protected] <mailto:
[email protected]>
W: www.gobiernu.cw <http://www.gobiernu.cw>