Subject: Inquiry on Data Embassy Implementation and Legal Frameworks
From: "info - MKM" <[email-masked]>
To: "Justiits- ja Digiministeerium" <[email-masked]>
Date: Tue, 13 Jan 2026 15:56:47 +0200

Tere

Edastame kuuluvuselt Justiits- ja Digiministeeriumile.

Heade soovidega

Rahandusministeerium

From: [email-masked] <[email-masked]>
Sent: Tuesday, January 13, 2026 1:51 PM
To: info - MKM <[email-masked]>
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-masked] <mailto:[email-masked]>

W: www.gobiernu.cw <http://www.gobiernu.cw>