Public data exchange infrastructures, such as X-Road, are essential to data-intensive digital public services and the EU digital economy. Their next generation requires advanced data usage control (DUC) mechanisms that address emerging requirements, including privacy by design, to mitigate privacy threats inherent in large-scale automated data exchange. Although research within the individual disciplines already addresses many of the emerging requirements, significant practical challenges arise at the intersection of the disciplines. This paper analytically examines the practical challenges and requirements of data usage control in public data exchange infrastructures. We examine the Estonian X-Road system and emerging use cases through an interdisciplinary lens that integrates formal verification and monitoring of usage control, requirements engineering, and digital governance research. We formulate key requirements and propose a conceptual vision for developing usage control in public data-exchange infrastructures to enable future digital-governance systems to comply with privacy requirements by design.

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