The goal of the paper is to identify the top priorities of public policy of European Union institutions to gain progress in raising e-inclusion so much necessary for digital transformation. E-inclusion is considered a complex phenomenon that depends on constructs: "Access to ICT and the Internet", "Usage of ICT and the Internet", "Empowerment of users" and the "Impact on quality of life" as it follows from General Theoretical Conceptual Model of e-Inclusion (GTCM). The research has included 69 public policy documents, published in the period from 1990 to 2020, in order examine the representation of constructs of GTCM for e-inclusion by content. The results show that "Usage" and "Impact on quality of life" were in the focus of the public policy documents for the most part. The contribution of this research is knowledge about the possibility of using a model approach to create public policies related to e-inclusion of vulnerable population groups. The results of the research could motivate public authorities in planning future activities to support raising the e-inclusion of vulnerable groups, taking into account all four key con-structs of GTCM for e-inclusion.