The role of digital sovereignty in the development of national digital identity systems
Digital sovereignty is an emerging concept at the heart of the global development of national digital identity systems (Zulkifli et al., 2023). Yet, as governments around the world increasingly pressure policymakers to pursue digital sovereignty through these systems, competing and often inconsistent definitions (Fratini et al., 2024) have led to significantly different approaches to controlling the infrastructure, governance processes, implementation strategies, and data that support them (Musoni et al., 2023). With over 164 countries operating national digital identity systems at varying stages of maturity (DPI Map, 2025), these divergent approaches have created a compelling — and often contradictory — mix of geopolitical tensions, systemic complexities, and policy challenges (Musoni et al., 2023).
In the context of the rapid proliferation of national digital identity systems, each country's social, economic, and political environment is shaping how — and why — it approaches digital sovereignty (Musoni et al., 2023). This has led to varied interpretations and policy implications (Fratini et al., 2024), most visibly reflected in the contrasting models of the United States' unregulated, market-oriented approach to the free flow of data; China's strict state-centric data regime; the European Union's emphasis on individual rights and privacy; and emerging, less-discussed discourses in the Global South. These foundational differences have the potential to influence the design and direction of national digital identity systems worldwide (Musoni et al., 2023) — shaping critical decisions around citizens' data rights, privacy and surveillance, interoperability, and the development of digital infrastructure.
With national digital identities at a crossroads (Naghmouchi et al., 2023), there is a clear need to better understand how digital sovereignty is shaping their development globally. While existing literature focuses either on broad frameworks of digital sovereignty or digital identity systems in isolation, few studies systematically examine how different approaches to sovereignty actively influence the technical design, governance, and implementation of these systems across national contexts — a gap this REA seeks to address.
The remainder of the paper is organised as follows: Section 2 summarises research objectives and questions. Section 3 describes the study's methodology, including search strategy, results, and characteristics of eligible studies. Section 4 presents findings, followed by Section 5, which concludes the REA.
The objective of this REA is to systematically examine how competing approaches to digital sovereignty are impacting the global development of national digital identity systems. By critically exploring how these divergent approaches influence infrastructure and technology choices, governance processes, data management, and citizen adoption, this REA aims to build a clearer understanding of the implications of different policy choices for policymakers — addressing the knowledge gap identified and surfacing potential harms and consequences.
The analysis of this REA is guided by a central research question and three theme-related sub-questions, structured around the broad understanding of digital sovereignty as three interconnected layers: "the physical layer (infrastructure and technology), the code layer (standards, rules, and design), and the data layer (ownership, flows, and use)" (Musoni et al., 2023):
Central research question
How are global approaches to digital sovereignty shaping the development of national digital identity systems?
Theme related sub-questions:
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References
Fratini, S., Hine, E., Novelli, C., Roberts, H., & Floridi, L. (2024). Digital sovereignty: A descriptive analysis and a critical evaluation of existing models. Digital Society, 3(59). https://doi.org/10.1007/s44206-024-00146-7