But the company freely admits the document, which talks exclusively about its Windows client business, does not address key EC concerns.

As creators of an operating system used so widely around the world, we recognize we have a special responsibility both to enhance innovation and to preserve competition, general counsel Brad Smith told an audience at the New America Foundation in Washington DC.

The Twelve Tenets to Promote Competition essentially codify policies that Microsoft had previously indicated it would abide by. Eight of them have their roots in the five-year-old consent decree that resolved the federal antitrust suit in the US, Smith said.

Microsoft will, for example, allow OEMs and end users to install any third party software they want on PCs, to change the Windows defaults to non-Microsoft software, or to completely remove Microsoft software such as Media Player or Internet Explorer.

That will extend to areas not covered by the US consent decree, such as Windows Live, the set of emerging web services that Microsoft is investing heavily in order to head off competition from the likes of Google Inc and Yahoo! Inc.

If a computer manufacturer wants to set a competing web search service… so that service runs by default, they can do so, Smith said. If an OEM wants to go even farther and supply, in the drop-down box in Internet Explorer, only a single internet search service, a service offered by a Microsoft competitor, the OEM is free to do that.

That would seem to address at least one EC concern. Competition Commissioner Neelie Kroes wrote to Microsoft chief executive Steve Ballmer in March, concerned about the possible bundling into Vista of certain products, such as internet search.

In reply, Ballmer had laid out four suggestions for how Vista could be packaged to address these concerns, up to and including removing software from the European versions of the operating system.

But Smith admitted that the 12 tenets, while expanding and extending principles from the US consent decree, will not cover Europe’s demands.

It is not possible, in any single document, to answer all questions, either now or for all time, and we don’t claim for a moment that this document does that, Smith said. They don’t for example address all the conditions of the European Commission’s 2004 decision.

The reason Microsoft got whacked with such a big fine was because it had failed to meet client-server protocol documentation deadlines mandated by the 2004 decision.

There is a now a commitment by Microsoft to license all the communications protocols that it has built into Windows and that are used to facilitate communication with server versions of Windows to rivals on commercially reasonable terms.

For rival software developers, there is a commitment to publish any API in the Windows client that Microsoft’s software uses. It goes beyond the narrower US requirement that the company publish its middleware APIs, but does not cover the server.

We’re committing today that we will document and disclose all the APIs in Windows that are called by any Microsoft application, whether it’s middleware or a standalone application like Office or Windows Live, Smith said.

While Smith did not say a great deal about the fight with the EC, which is headed to the courts, he did say something that suggested he would prefer the Europeans were more in line with the US consent decree.

Issues today are addressed by many, many governments, Smith said. It’s important for us to provide information on a worldwide basis, and it’s also important for regulators to share information and to consult, to coordinate and collaborate more closely.

There are seven parts of the US consent decree that are due to expire next year. Smith said these new commitments will extend those provisions beyond that expiration.

In Europe, Microsoft has vowed to fight the latest non-compliance fine in the courts, and is already in the process of appealing the 2004 decision in the Court of First Instance, where it is arguing that licensing its protocols is unfair.