We welcome the opportunity to provide comments on the draft report. Please consider the following suggestions from the UN Conference on Trade and Development (UNCTAD):

• The outcome document of the Africa eCommerce Week (Nairobi Manifesto on the Digital Economy and Inclusive Development in Africa)  provides a number of specific recommendations related to seven policy areas of relevance to strengthening the readiness of African countries to engage in and benefit from ecommerce and the digital economy. The report may wish to refer to these recommendations, especially as the Africa eCommerce Week was co-organized by UNCTAD, the African Union and the European Union. The report does cite some numbers from that document but it does not recognize the source.
• On page 34, there is a proposed action to develop a holistic continental mapping of ecosystems. We would like to draw the attention of the DETF to the Rapid eTrade Readiness Assessments that have been undertaken by UNCTAD precisely to provide a basic analysis of the situation in least developed countries. To date, the following African countries have been assessed: Burkina Faso, Liberia, Madagascar, Senegal, Tanzania, Togo, Uganda, Zambia and the following countries are in the process: Benin, Lesotho, Mali and Malawi. Requests have also been received from: Burundi, Comores, Cote d’Ivoire, Djibouti, DR Congo, Niger, Tunisia and Zimbabwe. The DETF could recommend that all African countries should benefit from such an assessment, as this would help develop a continental-wide understanding of key barriers and possible solutions to them for all African countries. A preliminary assessment of the first set of African assessments can be found here.
• The DETF may also wish to recommend that policy recommendations made in the Rapid eTrade Readiness Assessments could serve as a basis for a discussion on what actions to prioritize by national governments and by the European development partners.
• On the discussion on how to boost digital entrepreneurship in African countries, we would recommend the DETF to consider the recommendations contained in the report from the Broadband Commission’s working group on digital entrepreneurship, which was chaired by VP Andrus Ansip.
• We would recommend that the DETF stresses the need to improve the availability of relevant statistics on e-commerce and the digital economy. While Africa has a rapidly growing digital economy, and is at the forefront of the use of technologies such as mobile money, the availability of statistics based on which future policy-making can be informed is very limited. Improving this situation requires concerted efforts by ministries, statistical offices and development partners, including international organizations. A conspicuous and important gap exists in the availability of statistics related to e-commerce. Concrete suggestions on how to improve the situation are available in the Nairobi Manifesto cited above.
• We welcome the proposal to establish a trust fund to support the strengnthening of the legal and regulatory frameworks in Africa. As shown in the UNCTAD Cyberlaw Tracker, many African countries still lack baseline legislation in key areas such as e-transaction, consumer protection online, cybercrime and data protection. UNCTAD’s E-commerce and Law Reform programme could help support the EU-AU collaboration in this area.