EuroISPA signs open letter in response to the Going Dark report

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As part of our response to the High-Level Group on Access to Data for Effective Law Enforcement (HLG “Going Dark”), and following our reaction to their 42 recommendations, we raise our concerns about the HLG’s final report, together with a broad coalition of civil society groups, industry and professional associations,

As a matter of fact, the group recently presented recommendations that could pose a substantial threat to digital security and privacy for the EU and its citizens.

An EU security policy fit for the digital age must address the challenges we face today. Secure communications and legal certainty are imperative for citizens and law enforcement alike. In the light of potential threats by criminals, foreign state-sponsored agencies and even some authoritarian actors within the EU, people expect the institutions to prioritise policies that protect their IT-security and fundamental rights. That is why we recommend:

  • Support a safe, trustworthy and diversified digital ecosystem. Citizens need technology that empowers them instead of putting them at risk.
  • Ensure the security and confidentiality of digital spaces because the possibility for people to exercise their fundamental rights depend on it.
  • Uphold the right to privacy and inviolability of protected information. This is required by the Charter of Fundamental Rights and case law of the Court of Justice of the EU and the European Court of Human Rights.
Read the open letter

Achieving sustainability in Europe’s digital sector

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What steps can be taken so that the telecoms sector is a frontrunner in achieving Europe’s sustainability goals? How can we ensure a sustainable and climate neutral digitalisation in Europe?

EuroISPA puts forward 5 key actions to address sustainability challenges for the digital ecosystem and European economy:

  1. Digital technologies and infrastructures are key to allow the green transition and to achieve greater sustainability.
  2. More can be done to address sustainability challenges.
  3. Sustainability should be embedded in the whole digital supply chain.
  4. Data centres are the cornerstone for untapping the potential of digitalisation to drive decarbonisation.
  5. Promoting investments of data centres located in the European Union would underpin the greening of the EU economy.

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EuroISPA Position Paper

EuroISPA signs joint industry statement on data processing for AI model training

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In a joint statement addressed to the European Data Protection Board (EDPB), EuroISPA and 14 leading European and national trade associations urge the EDPB to adopt a balanced and pragmatic interpretation of GDPR. A thoughtful look into the interplay of the GDPR and the AI Act will be key to make AI “made in Europe” a reality.

Full statement

EuroISPA reacts to the 42 Recommendations of the High-Level Group on Access to Data for Effective Law Enforcement

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EuroISPA welcomes the work and efforts of the European Commission’s High-Level Group (HLG) on access to data for effective law enforcement on promoting a high level of security and an effective approach to fighting
crime and other challenges through the proposed 42 Recommendations.

Earlier this year, the European Commission’s High-Level Group (HLG) on access to data for effective law enforcement out forward 42 recommendations for the further development of EU policies and legislation to enhance and improve access to data for effective law enforcement.

In anticipation of the upcoming discussions of the HLG at the end of the year, EuroISPA would like to take this opportunity to react and give constructive feedback to the recommendations, highlighting some elements that require a careful approach besides further thinking.

EuroISPA welcomes the work and efforts of the Group in promoting a high level of security and an effective approach to fighting crime and other challenges through the proposed 42 Recommendations.

However, EuroISPA is concerned with some proposed recommendations that could weaken encryption, which is a fundamental tool to protect European citizens’ fundamental right to privacy.

Moreover, we underline the need to carefully assess any further measures that can put more burden on European actors, especially the smallest ones.

Finally, any additional measures should take into account the complex value chain that characterises the different ECSs (Electronic Communications Services); any unclear measure might lead to loopholes, further uncertainty when conducting business, as well as threats to the security and the integrity of networks.

Read the full feedback

Joint Industry Request to Extend Deadline for Trustworthy General-Purpose AI Consultation

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Alongside 10 other trade associations, EuroISPA urged the European Commission and its AI Office to extend the deadline for responses to the consultation on trustworthy general-purpose AI (GPAI).

The effective implementation of AI Act rules on GPAI is vital for the future of the European AI and the ISPs ecosystem. However, the original six-week deadline, especially during the summer recess, restricts stakeholders’ ability to offer comprehensive feedback.

After the publication of this letter, the European Commission accepted to extend the consultation period until the 18th of September 2024.

Read the joint letter

EU Payments Services Regulation: EuroISPA’s opinion

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EuroISPA’s position on the EU Payments Package

In 2023, the European Commission put forward proposals to bring payments and the wider financial sector into the digital age, including through a proposal for a Payment Services Regulation (PSR).

EuroISPA finds the European Parliament’s position on the PSR worrying, and most notably the contents of Article 59 of the proposed Regulation on the liability of Electronic Communications Operators in the occurrence of impersonation fraud. 

In the context of the discussions on the file currently entering the Council of the EU arena, we are now sharing our opinion concerning Article 59, advocating for the removal of the article altogether, for the strengthened cooperation between all players involved, as well as for the empowerment of consumers to make knowledgeable and safe decisions to better combat fraud.

Read our opinion here

“How to master Europe’s digital infrastructure needs?” – EuroISPA’s feedback to the European Commission’s White Paper

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The European Commission’s White Paper “How to master Europe’s digital infrastructure needs?” analyses the multiple challenges Europe currently faces in the rollout of future connectivity networks. It presents possible scenarios going forward to address those challenges, attract investment, foster innovation, increase security and achieve a true Digital Single Market.

EuroISPA responded to the European Commission’s public consultation on the White Paper in the name of European Internet Services Providers (ISPs).

Here is a summary of our feedback:

  • EuroISPA welcomes the fact that the Commission highlights the critical importance of ISPs for the future of the EU and draws some meaningful scenarios in order to promote connectivity and simplify and harmonise regulations, which is needed to overcome the challenges ahead.
  • However, EuroISPA finds that many proposals require more clarification from the European Commission and need to take account of national specificities / efficient frameworks.
  • EuroISPA also commends the willingness of the EC to address the sustainability and security of networks, which are essential to ensuring a resilient and sustainable Europe.
Find our full feedback here

Joint industry call for protecting encryption in the Child Sexual Abuse Regulation

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Together with other industry associations, EuroISPA is calling on EU Member States to preserve the integrity of end-to-end encryption in the Child Sexual Abuse Regulation, and to protect both safety and privacy in the Council position.

Some worrying suggestions have been put on the negotiating table last week which are highly problematic for the privacy of users and the security of the Internet. In our joint statement, we point at other avenues for improvement, including voluntary detection and prevention.

Read the joint statement

EuroISPA publishes Position Paper on Data Retention

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Data retention frameworks refer to the regulation of what data should be stored or archived, where that should happen, and for exactly how long. The obligation of data storage stems from the possibility of law enforcement authorities to request such data to Electronics Communications Services Providers at any time.

In light of the current discussions within the High-Level Group on access to data for effective law enforcement, EuroISPA has published this Position Paper on Data Retention. This paper is a testament to EuroISPA’s collective dedication to identifying the practical, operational and economic consequences and challenges of data retention at both the national and cross-border level.

Allowing law enforcement authorities to prevent and prosecute serious crimes needs while safeguarding the fundamental rights of users and electronic communications services providers is not an easy task, as shown by several rulings of the Court of Justice of the EU. EuroISPA has put together a list of imperative requirements to provide guidance on how to achieve the right balance between the interests and obligations of all parties involved.

EuroISPA, a pan-European association which represents over 3,300 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.

Read the paper

EuroISPA publishes Position Paper on Artificial Intelligence

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In the wake of the approval of the Artificial Intelligence Act (EU AI Act) by the European Parliament, EuroISPA publishes its Position Paper on Artificial Intelligence. This paper is a testament to EuroISPA’s collective dedication to shaping a future where AI serves as a force for good, and highlights principles that should be considered for current and future regulatory frameworks on AI, including by the European Union.

EuroISPA, a pan-European association which represents over 3,300 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. This paper reflects our commitment to establishing a harmonised and globally accepted framework that encourages innovation, upholds ethical standards, and mitigates potential risks associated with AI deployment.

Read the paper

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EuroISPA

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1000 Brussels

+32 2 789 6618

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