EuroISPA Annual Policy Report 2022 – Brussels Outlook 2023

EuroISPA is delighted to present to you its Annual Policy Report 2022 – Brussels Outlook 2023, which contains an overview of the Association’s main activities of 2022, with dedicated insights on its policy focus areas, as well as a presentation of what’s ahead in 2023.

In 2022, EuroISPA and its committees were busy bringing their work forward on a number of key policy areas for European ISPs, and contributed to shaping the debate around policy files such as the proposed CSAM Regulation, the Digital Services Act, the upcoming Regulation on the online piracy of live events, and more.

But other than EuroISPA’s work in the past work, this report will give a chance to have an outlook on what the EU policy landscape holds in 2023 on a number of relevant areas for the European Internet industry.

Our officers and committee chairs describe the opportunities and the challenges coming up, and the broader vision of the association going forward

Lastly, read the report to dive into EuroISPA’s 25th anniversary celebrations, with a timeline of our dedicated work and expansion during over two decades, and our view for the years to come.

Once again, EuroISPA is happy to have worked alongside our members with the goal of contributing to the development of the sector to ensure its safety and sustainability.

We hope that you enjoy reading our Annual Policy Report 2022 – Brussels Outlook 2023!

EuroISPA and other European Internet industry associations join forces and publish a joint statement on the proposed CSAM Regulation

European industry associations ACT | The App Association, CCIA Europe, CISPE Cloud, Dot Europe, eco, EuroISPA, FiCom, ISPA Austria and ITI have published a joint industry statement in which they call the European Commission to amend some key points of the proposed Regulation laying down rules to prevent and combat child sexual abuse.

The associations and their members, active in the European Internet industry, agreed on the importance of the European Commission’s proposal to ensure the EU is committed to making the digital space safe for everyone, especially for children.

However, they are now together drawing attention to how certain measures contained in the proposed Regulation need to be amended in order to reach the goals the Regulation is set to achieve.

To do so, signatories have formulated recommendations to amend six key aspects of the proposal:

  • The narrowing of the scope and definitions
  • The risk assessment, mitigation and reporting
  • The inclusion of voluntary measures
  • The use of detection, removal and blocking orders
  • The importance of safeguarding encryption
  • The role of the EU Centre

This joint industry statement is the result of a substantial joint effort between the signatories, coordinated by EuroISPA, that shows the unified commitment of several associations with a diverse membership and active in the sector at European level to protect children online.

EuroISPA hosts expert roundtable on privacy and encryption

On Thursday, 23rd of March 2023, EuroISPA hosted an in-person expert roundtable on privacy and encryption, organised in the context of the European Commission’s proposal for a Regulation to prevent and combat child sexual abuse.

The event gathered a distinguished expert panel comprised of Mr Matthew Green, Associate Professor at the Johns Hopkins University and expert on applied cryptography and cryptographic engineering, Ms Arda Gerkens, CEO and founder of EOKM, as well as Ms Ella Jakubowska, Senior Policy Advisor at EDRi.

EuroISPA’s Board member, Thomas Bihlmayer (eco), moderated the discussion and introduced EuroISPA’s views from its position as a constructive contributor to child protection and privacy debates, thanks to its diverse membership (hotlines, ISPs of all sizes, platforms, cloud infrastructure services, etc.) that is at the forefront of the efforts to protect children online.

He highlighted EuroISPA’s commitment with the Commission’s objective to prevent and combat child sexual abuse and noted concerns over several aspects of the proposal. He focused on the operability of the regulation and on the dangers of breaking encryption, which will have a direct impact on the technical Internet infrastructure and impede efforts to create an Internet which enhances trust, user privacy, and freedom of expression.

Professor Matthew Green expressed concerns about the lack of understanding of the technical implications of the Commission’s proposal, and the possible harm that could bring to the security of global communications systems. During his intervention, he stressed the technical limitations of such proposed measures and the issue of over-relying on them, considering encryption is a very young area. For him, the proposal would benefit from an in-depth evaluation by scientists and researchers in Europe, which in his view should be seen as a pre-condition for mandating new technologies. (He shared his intervention in a more extensive version on his blog).

Representing the Dutch hotline, Arda Gerkens highlighted the issues of weakening encryption, compromising the security both for children and adults. She also noted the potential positive points, especially when it comes to the creation of a EU Centre as a centre for knowledge and support in the EU. She further explained how the approach of the Netherlands to fight child sexual abuse is working, noting some of the main elements that could be brought to EU level.

Finally, Ella Jakubowska raised the perspective of civil society. She explained why the proposed measures will lead to unreliable client-side scanning practices, undermining end-to-end encryption and making our devices more vulnerable to attacks from malicious actors, all without addressing the core issues or finding the right solutions to tackle child sexual abuse.

The panel discussion was followed by a Q&A session were participants had the opportunity to exchange about the compatibility of these measures with privacy legislation, the potential for improvement of scanning technologies as well as other solutions to allow fighting child sexual abuse without hindering privacy safeguards and fundamental rights.

This session is one of the different actions that EuroISPA is taking around encryption, privacy and the Commission proposal to fight Child Sexual Abuse Material online.

If you would like to know more about EuroISPA’s work on the topic, you can contact [email protected].

To read our Position Paper on the proposed CSAM Regulation, click on the button below.

EuroISPA Annual Policy Report 2021

January 17th 2023 – EuroISPA is delighted to launch its Annual Policy Report 2021, which contains an overview of the Association’s main activities of 2021, as well as dedicated insights on its policy focus areas.

The year 2021 was a busy and eventful one, with EuroISPA working on several important policy areas. Our Association has continuously worked on files dealing with intermediary liability, cybersecurity, safer internet, innovation, and data protection. EuroISPA was able to progress on priority files such as the Digital Services Act (DSA), and the Directive on Child Sexual Abuse and Exploitation, among many others.

In the year of its 25th anniversary, EuroISPA is happy to have worked alongside our members and to have actively participated in the discussions of key files and followed the legislative developments at EU level. Our mission is to contribute to the development of the sector to ensure its safety and sustainability.

We hope that you enjoy reading our 2021 Annual Policy Report, that it offers you some interesting insights into the ongoing work of EuroISPA and, finally, that it reflects the commitment of our membership to promote a sustainable approach in the ISP sector.

Happy reading!

PRESS RELEASE: EuroISPA elects new Officers during November General Meeting

Brussels, 28 November 2022 – EuroISPA announces the appointment of new Officers following an election held during the General Meeting on November 24th and 25th in Brussels.

EuroISPA is the world’s largest association of Internet Services Providers Associations, representing over 3,300 Internet Services Providers (ISPs) across the EU and EFTA countries. After two years of dedicated work, two of the former Officers have stepped down. New Officers have been elected following a vote by the EuroISPA members; Alex de Joode and Elina Ussa will share the Presidency mandate, serving one year each, Michel Combot will join as Vice-President, and Thomas Bihlmayer is to continue as Treasurer.

Alex de Joode, stated: “I would personally, and on behalf of the Board, like to thank Alexandra Lafitte for her guidance and leadership of EuroISPA in engaging with the EU and international institutions. A heartfelt thank you also goes to Innocenzo Genna, for his strong contributions to the organisation and its impact on policy issues including data protection, cybersecurity, and intermediary liability.”

Elina Ussa, who will take up her role as President at the end of 2023, said: “It is estimated that up to 80 per cent of the legislation in the field originates from the EU. It is important to be closely involved in influencing various legislative projects as early as possible. EuroISPA’s excellent lobbying is wide-ranging. It’s great to get the opportunity to be in its core, and to bring expertise from Finland, the Europe’s leading country in digital development.”

Taking up his role as Vice-President, Michel Combot said: “Our industry and our ecosystem are at the heart of the daily lives of businesses and our fellow citizens. While the very nature of the Internet is sometimes called into question, EuroISPA carries the voice of ISPs in Europe, gathers all stakeholders, and provides a forum for cooperation amongst its members.” Thomas Bihlmayer, continuing as Treasurer, stated: “I’m very proud and grateful to have been re-elected for a second term as EuroISPA Board member. During its 25 years, the Association has been an important voice for the Internet industry and I’m looking forward to continuing this active participation. Technology continuously develops, and with it new challenges arise.”

The final General Meeting of 2022 gathered members in person at EuroISPA’s office in Brussels. The two-day programme Committee meetings, general administration and updates about the Association, as well as the election of the new Officers. EuroISPA welcomed contributions by guest speakers, including representatives from the European Commission and the Swedish Permanent Representation to the EU.

Former EuroISPA President Alexandra Laffitte said: “After serving for four exciting years as a member of EuroISPA’s Officers, I am thrilled to welcome the new Officers: Alex de Joode, Elina Ussa, Michel Combot, and Thomas Bihlmayer. This renewed Board of Officers will bring an exciting new perspective to the association, and I wish them all the best as EuroISPA continues to engage on crucial issues for our society, such as digital rights or encryption. I would like to thank everyone involved in EuroISPA for their trust, cooperation and guidance over the last years, and their ongoing contributions this organisation.” Vice-President Innocenzo Genna, who is stepping down after 16 years on the Board,  stated: “It was a long journey serving EuroISPA as an Officer in a multitude of relevant policy and governance matters. I remain committed to the Association and to supporting its activities going forward, and thank my fellow members for your support over the years.”

De Joode concluded: “We believe that a diversity of Board members will bring fresh energy to the Association. The renewed board brings new expertise to EuroISPA from different domestic legal cultures and experiences, as well as management experience, as two of the new board members run two member associations themselves. In order to retain some continuity, Thomas Bihlmayer stays on as Treasurer and I pick up the role as President after a two year hiatus. I’m looking forward to engage with the EU on various policy dossiers as President, but also in my capacity of Chair of the Safer Internet Committee to ensure there is an effective CSAM regulation that builds towards an open and free internet in Europe.”

PRESS RELEASE: Freedom Internet becomes EuroISPA Industry Forum’s newest member

Brussels, 13 October 2022 EuroISPA, the pan-European association of Internet Services Providers Associations welcomes its new Forum member, Freedom Internet BV, a Dutch Internet, television and telephone services provider. With Freedom Internet’s addition, EuroISPA’s Industry Forum can now rely on nine companies active in the Internet industry to participate in the association’s activities under an advisory competence.

Alexandra Laffitte, President of EuroISPA, said: “We are delighted to be welcoming Freedom Internet as the newest addition to the EuroISPA Industry Forum. Freedom Internet will provide valuable advice to EuroISPA Council members, actively contributing to our discussions on the policy issues impacting the European Internet industry. At EuroISPA, we value the input and advice of companies, and we believe that Freedom Internet, with its focus on open and safe Internet, will bring a fresh perspective and represent a great addition to the works of the Forum.”

EuroISPA is the representative body of Internet Services Providers (ISPs) across the European continent. Founded in 1997, EuroISPA functions as an ‘umbrella’ association representing ISP associations on policy and legislative issues and facilitates the exchange of best practices between members. The association is structured around different, topical Committees, which allows members to regularly exchange ideas and views on specific policy matters and dossiers.

Freedom Internet BV is an Amsterdam-based company that serves both private and business customers by providing services over the Internet, including fiber optic or DSL Internet, television and telephony. Their activity has a special focus on user privacy and online security as they fight for safe and free Internet access by working closely with digital rights foundation Bits of Freedom.

Bibi van Alphen, Public and Legal Affairs at Freedom Internet, stated: “We are very glad to join EuroISPA and are looking forward to a fruitful collaboration with the other members. Together we will ensure that important principles like net neutrality, privacy and freedom of speech will always be considered at the EU level while discussing the future of the Internet.”

About Freedom Internet BV

Established in 2019, Freedom Internet BV is a Dutch provider of Internet services to business and private customers that relies on over 30 networks in the Netherlands. Freedom Internet BV pledges to provide its users with free and open Internet and to safeguard their privacy and security online.

Position Paper on the Proposal for a Regulation laying down rules to prevent and combat child sexual abuse

14 September 2022EuroISPA publishes its Position Paper expressing concerns about the Proposal for a Regulation laying down rules to prevent and combat child sexual abuse. The document highlights risks of inoperability and technical unfeasibility, concerns around compatibility with the GDPR, DSA, ePrivacy Directive, NIS2, and the Open Internet Regulation, as well as emphasising worries about excessive administrative burdens on SMEs.

EuroISPA, a pan-European association which represents over 3,000 Internet Services Providers (ISPs), works to advocate for the needs both of the wider industry and of users. This position paper is one example of how the association’s members work together to draft recommendations for EU policy makers that can be implemented by the industry in order to tackle the issue at hand.  EuroISPA members are at the forefront of the efforts to protect children online and have a longstanding relationship with law enforcement authorities to assist them in the fight against child exploitation.

Download the Position Paper here.

PRESS RELEASE: EuroISPA voices concerns regarding CSAM proposal’s impact on user privacy

Brussels, 18 May 2022EuroISPA, the pan-European association of Internet Services Providers Associations, highlights concern about privacy, freedom of speech, and overbearing obligations in relation to the recently proposed Regulation to prevent and combat child sexual abuse.  

Alexandra Laffitte, President of EuroISPA, noted: “Our members share the view that obligations in relation to detecting, reporting, removing, and blocking of content in this proposal raise questions about intrusion into user privacy and potential surveillance by authorities or malicious actors, as well as about operational viability. Furthermore, in order to ensure consistency across the ecosystem and a proper balance with regards to fundamental rights and freedoms, the proposal needs to be aligned with the DSA and the GDPR. This is particularly important with regards to principles such as non-general monitoring and the confidentiality of electronic communications. Encryption tools are part of the framework which allows Internet and online services to be trusted and ensure ongoing cybersecurity and data protection. The weakening of end-to-end encryption would damage the economy as well as damaging efforts to create an Internet which enhances trust, user privacy, and freedom of expression”. 

EuroISPA represents Internet Services Providers (ISPs) across the European continent, creating a common voice aiming to promote and protect the interests of its members whilst working towards a safer Internet for all.  

Within EuroISPA, the Safer Internet Committee aims to contribute to the shaping of policies on child sexual abuse material (CSAM) online and cooperates with law enforcement authorities by sharing practical experience and infrastructure control. Several EuroISPA members also manage national level hotlines which contribute to the tackling of illegal content online.  

“This proposal puts forward a new approach to combatting child sexual abuse, a crucial issue that we have been dedicated to for many years. However, it is important to note that the proposal only focuses on the Internet ecosystem, without considering and supporting the existing local-level schemes which have proven their efficiency in fighting and preventing child sexual abuse. EuroISPA is analysing the text in detail to ensure that the future framework will effectively help prevent child sexual abuse, and that the obligations on intermediaries do not have a burdensome effect on smaller players in the sector, as SMEs are at the core of EuroISPA’s membership and play a vital role in the Internet sector as a whole. We hope our voice and the voices of fellow industry players will be taken into account as discussions continue about the proposal, in order to protect all the fundamental rights of users whilst tackling the very real concern of CSAM online at an operational level,” added Asko Metsola, Chair of EuroISPA’s Safer Internet Committee. 


PRESS RELEASE: EuroISPA welcomes progress on the DSA

Brussels, 20 January 2022: EuroISPA, the pan-European association of Internet Services Providers Associations, welcomes today’s plenary vote on the Digital Services Act (DSA) in the European Parliament, paving the way for interinstitutional negotiations and a potential final agreement in 2022.

Malcolm Hutty, Chair of EuroISPA’s Intermediary Liability Committee, said: “We commend the work of the Rapporteurs and the Shadow Rapporteurs to create a regulatory framework ensuring a safe online environment for users while fostering innovation and competitiveness within the Single Market. The preservation of key principles of the E-Commerce Directive, such as the limited liability regime and the prohibition of general monitoring obligations, will ensure that the Internet industry can continue to thrive for the benefit of all Europeans.”

At the same time, further work in the interinstitutional negotiations will be needed to guarantee a truly future-proof framework. For instance, a clearer distinction between online platforms and pure hosting services providers is needed in order to grant legal certainty for all parties. Provisions on orders to take down content and to provide information to authorities should respect the country-of-origin principle and should be in line with existing and upcoming legislation such as the e-evidence package.

Alexandra Laffitte, President of EuroISPA, shared the association’s views on the upcoming interinstitutional negotiations: “We encourage policymakers to keep the DSA a horizontal framework, to avoid creating obligations which would result in primary liability for service providers, and to ensure that the upcoming rules are balanced and proportionate, especially taking into account the type and size of businesses. We stand ready to support the co-legislators in their efforts to formulate a future-proof framework for the online environment.”

PRESS RELEASE: EuroISPA Calls for Robust Regulatory Digital Framework for the EU and a Timely Decision on the Digital Services Act

Brussels, 12 November 2021 – EuroISPA, the pan-European association of Internet Services Providers Associations, co-signed a letter calling on the European Parliament to develop a robust regulatory digital framework for the EU with the Digital Services Act (DSA), as part of a broader coalition of leading start-ups and SMEs, alongside technology, advertising, and media organisations of different sizes.

The letter highlights the key areas the signatories believe should be focused on in order to ensure a timely co-legislative process, which will be crucial to strengthening the EU internal market. The letter comes in light of the upcoming Internal Market and Consumer Affairs Committee (IMCO) vote on the matter and notes the need to:

  • Maintain the horizontal approach of the Digital Services Act
  • Preserve and build on the cornerstones of the e-Commerce Directive
  • Build a workable, balanced, future-proof Regulation
  • Ensure consistency with the EU’s existing legal framework

Alexandra Laffitte, President of EuroISPA, commented: “EuroISPA is in a unique position to represent the needs of European Internet Services Providers, so we feel it is particularly crucial to highlight that the DSA should maintain the e-Commerce Directive principles at its core while remaining horizontal in its scope; it should not address issues that are best left to specific, vertical legislation. Along with our fellow signatories, we hope that this letter will emphasise our willingness to bring expertise to the discussions at any point and that it will help policy makers tackle the DSA in a timely and relevant manner.”

EuroISPA represents over 2,000 Internet Service Providers of all sizes across Europe and is an advocate for the needs of the wider internet industry. The Association aims to ensure that policymakers are aware of the needs of EuroISPA’s members in order to make informed decisions.

Read the letter in full here: