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:

PRESS RELEASE: EuroISPA welcomes newest member to association, AMS-IX

Brussels, 21 October 2021 – EuroISPA, the pan-European association of Internet Services Providers Associations, welcomes a new Council member, AMS-IX (Amsterdam Internet Exchange), a member-based association that operates interconnection platforms around the world.

Alexandra Laffitte, President of EuroISPA, said: “We are delighted to be welcoming AMS-IX as the newest member of EuroISPA. AMS-IX will play an important role in the association, contributing enthusiastically to our discussions on policy impacting the infrastructure of the Internet. As the digital sphere continues to change in shape and dynamics, we at EuroISPA believe that it is increasingly important to be able to represent the whole Internet value chain and work together to achieve common goals. We extend our wholehearted welcome to AMS-IX.”

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 allow members to regularly exchange ideas and views on specific policy matters and dossiers.

AMS-IX a neutral member-based association that operates multiple interconnection platforms around the world. Its leading platform in Amsterdam plays a crucial role at the core of the internet and has more than 880 connected networks and over 10 Terabits per second (TBps) of peak traffic.

Peter van Burgel, CEO of AMS-IX, stated: “In the coming years, the European Union will have a major impact on the technical functioning of the Internet by means of new legislation and European stimulation programs. By joining EuroISPA, AMS-IX wants to actively participate in the discussions on the future of the Internet and give a voice to the values that have made the Internet such a huge success.”

About AMS-IX

AMS-IX (Amsterdam Internet Exchange) is a neutral member-based association that operates multiple interconnection platforms around the world. Our leading platform in Amsterdam has been playing a crucial role at the core of the internet for more than 25 years and is one of the largest hubs for internet traffic in the world, with over 10 Terabits per second (Tbps) of peak traffic. Connecting to AMS-IX ensures customers such as internet service providers, telecom companies and cloud providers can route their global IP traffic in an efficient, fast, secure, stable and cost-effective way. This allows them to offer low latency and engaging online experiences for end-users. AMS-IX interconnects more than 1000 IP-networks in the world. AMS-IX also manages the world’s first mobile peering points: the Global Roaming Exchange (GRX), the Mobile Data Exchange (MDX) and the Internetwork Packet Exchange (I-IPX) interconnection points.

More information: www.ams-ix.net

mySCCcreator: E-Tool Available on EuroISPA Website

Brussels, 23 July 2021 – With the modernisation of the standard contractual clauses (SCCs) for the international transfer of personal data in June 2021, as foreseen in the General Data Protection Regulation (GDPR), the European Commission hoped to ensure that personal data is properly safeguarded when being transferred to third countries. This means that data controllers or processors in the EU must be up to date and compliant in their related activities.

The mySCCcreator tool offers a simple solution that provides a well-structured Word Document with all the relevant information, following a short questionnaire.

EuroISPA has integrated the tool into its website in order to expand the reach and availability of the tool for data controllers and processors within its membership and partners.

Note: the mySCCcreator is supplied by Fieldfisher on Bryter.io. The information entered is not processed by EuroISPA nor on the EuroISPA servers.

EuroISPA co-signs industry letter on the EU-U.S. adequacy agreement ahead of ‘Schrems II’ anniversary

EuroISPA joins industry members to co-sign a letter to EU Commissioner for Justice Didier Reynders and U.S. Secretary of Commerce Gina M. Raimondo calling for a swifter agreement on secure transatlantic data flows, particularly in the context of the invalidated EU-U.S. Privacy Shield Framework.

Signatories recognise the ongoing efforts to create a new, strengthened EU-U.S. framework for the transfer of personal information, whilst highlighting that it is crucial that this be achieved as soon as possible, so as to ensure the growth and innovation of businesses in both the EU and the US.

Read the letter here:

EuroISPA co-signs letter calling for the preservation of the key principles of the E-Commerce Directive in the DSA

Brussels, 8 July 2021 – EuroISPA joins other industry players in signing a letter calling for the preservation of the E-Commerce Directive principles in the DSA.

The signatories note their support of an ambitious DSA and its objectives to protect consumers, while favouring innovation, growth, and competitiveness. However, the letter also highlights their concern that several Member States have questioned some of the key principles of the E-Commerce Directive, which are crucial elements of the European digital economy.

The letter calls for:

  • A clear distinction between illegal and harmful but legal content
  • The preservation of the limited liability regime
  • The upholding of the prohibition of general monitoring obligations
  • The maintenance of the country of origin principle
  • The limiting of web-blocking obligations

EuroISPA welcomes new member, Cambium Networks

Brussels, 6 July 2021 – EuroISPA, a pan-European association of Internet Services Providers Associations welcomes a new Forum member: Cambium Networks, an infrastructure provider which offers wireless connectivity to people worldwide.

EuroISPA represents Internet Services Providers (ISPs) across the European continent, creating a common voice aimed at promoting and protecting the interests of its members. Active since 1997, EuroISPA acts as un ‘umbrella’ association representing ISP associations on policy and legislative issues and facilitates the exchange of best practices between members. EuroISPA’s Industry Forum allows companies with a legitimate interest in the Internet industry to participate in EuroISPA’s activities, acting in an advisory capacity and providing input on relevant policy issues.

Alexandra Laffitte, President of EuroISPA, stated: “We are delighted that Cambium Networks is joining our community as a new member. EuroISPA represents the common voice of European Internet Services Providers, and the valuable addition to our membership of Cambium Networks strengthens our position as a prominent stakeholder representative body in the sector.”

Cambium Networks provides advanced wireless communication network infrastructure to private network operators in the business, including education and hospitality, local and national government, defense, and industrial markets, in addition to the broadband Internet Service Provider community supported by EuroISPA. Cambium Networks’ end-to-end solutions include Fixed 5G, 60 GHz mmWave networks capable of delivering multiple gigabits of data wirelessly to the edge, and indoor and outdoor Wi-Fi 6, among others. 

Martín de la Serna, Vice President for Europe, Middle East, and Africa of Cambium Networks said: “Cambium Networks is pleased to join EuroISPA as a Forum Member and collaborate with EuroISPA to further its critical mission. Internet Service Providers and policymakers across Europe find themselves at a unique inflection point marked by rapid services evolution, promise and potential and can benefit greatly from EuroISPA’s leadership. Cambium Networks, as a leading technology supplier to wireless internet service providers around the globe, looks forward to supporting EuroISPA and its stakeholders as Europe advances towards its Gigabit Decade goals.”

EuroISPA Annual Policy Report 2020

June 29th 2021 – EuroISPA is delighted to launch its Annual Policy Report 2020, which provides an overview of the principal activities of 2020 and insights into the policy focus areas of the Association.

Whilst the past year presented many challenges and obstacles across the globe and across industries, EuroISPA was able to maintain its momentum on priority files such as the Digital Services Act (DSA), which was unveiled in December 2020, and other issues such as Cooperation with Law Enforcement, Data Protection, Safer Internet, and Cybersecurity, among many others. EuroISPA is happy to have provided members with the key information on the legislative developments at EU level, and to have contributed to the discussions around policies that will have long-lasting impacts on the sector.

We hope you enjoy reading this Annual Policy Report, that it offers useful and interesting insights into the ongoing work of our association, and that it reflects the commitment and passion of our members to help shape sustainable and appropriate policies for the ISP sector.

Happy reading!