EuroISPA welcomes the European Commission’s proposals for a revised CybersecurityAct (CSA 2.0) and the accompanying NIS2 Simplification Directive as meaningful steps towards a stronger European cybersecurity framework.
At the same time, we believe further work is needed. Our key priorities:
Certification schemes must remain strictly technical
Reporting obligations must be harmonised across NIS2, CRA, GDPR and DORA, with a single audit principle
Supply chain risk assessments must be objective and evidence-based
Mandatory ICT asset phase-out must remain proportionate and economically sustainable manner
NIS2 simplification measures are essential to support SME and mid-cap operators and preserve competition
Internally developed tools not placed on the market should be exempted from certification requirements
Open source communities, SMEs, and independent developers must be recognised as key contributors to Europe’s cyber resilience
A secure and competitive European digital ecosystem requires a framework grounded in technical evidence, operational feasibility, and proportionality. We look forward to engaging with co-legislators on these important EU policy issues.
https://www.euroispa.org/wp-content/uploads/2020/02/EuroISPA_featured_image25.jpg7201170Secretariathttps://www.euroispa.org/wp-content/uploads/2020/01/logo_euroispa_4c_invers_2-300x127.pngSecretariat2026-05-08 10:22:292026-05-08 10:22:30EuroISPA Contribution to the proposal on CSA 2.0. and the Directive on Simplification Measures and Alignment with the Cybersecurity Act
With the sun setting on 2025, the political focus of the European Commission and the Council is shifting towards simplification and harmonization of the existing regulatory framework, including the rules for Data Protection under the GDPR within the envisioned Digital Omnibus. The Commission, it seems, is finally addressing the lingering question on how to tackle – among other topics – cookie rules and provisions. These were initially intended to be covered within the confines of the ePrivacy Regulation, which was retracted by the Commission approximately eight years after its first presentation and after roughly four years in trilogue.
It remains to be seen whether this new approach for regulating online tracking of users will prove to strike a balance between respecting and safeguarding users’ rights and avoiding overly complex provisions requiring consent forms, which diminish the online experience of users. Additionally, the topic and further elaboration of the term personal data is central to the future of data protection. Here, the ongoing debate will show whether Commission, Parliament and Council will be able to find an accessible and workable definition for personal data and link it to the legal forms for data processing.
While data protection rules are experiencing a fresh approach, another topic is emerging. Data retention has been a recurring concern for European and national lawmakers. The Danish Presidency of the Council has proposed “Future Rules on Data Retention” and consulted them with the Member States, leading to an outcome paper presented in November 2025. The foreseen retention durations in the conclusive document of the Danish presidency range from six months to one year.
These requirements cannot be reconciled with the decisions of the Court of Justice of the EU, which has clearly stated that access to data cannot be pursued through unsolicited, encompassing data storage. And its 2024 decision did not change anything in this respect, but rather specified the conditions under which access is possible.
Politically, 2026 is likely to see recurring cycles of discussions on online tracking and surveillance, with uncertain outcomes for the Internet industry. The Digital Omnibus has yet to pass the European Parliament and the demand for new data retention rules has yet to be put into a Commission draft. However, discussing the streamlining and simplification of rules for online tracking against the backdrop of seamless online surveillance may prove harmful and fuel criticisms, which deride the necessary clarifications in the data protection framework as unsolicited. Navigating this environment will be a priority challenge for the Internet industry in 2026.
Philipp Ehmann
Head of the Capital Office & Head of the Policy, Law and Regulations Division of eco – Association of the Internet Industry
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The 2026 European Commission Work Programme with the code name Europe’s Independence Moment” keeps connectivity and digital infrastructure at the heart of EU competitiveness, but reframes telecoms policy around simplification, enforcement, and technological sovereignty. For ISPs, this would be a year less about new slogans and more about how pending flagship files – above all the Digital Networks Act (DNA) – will actually land in practice.
Strategic priorities affecting ISPs
The Work Programme stresses competitiveness, innovation and collective security, positioning advanced networks as a precondition for AI, cloud, and quantum leadership. Telecom operators gain political recognition as critical enablers for industrial policy and defence readiness, which strengthens their argument for more investment friendly rules and targeted public support.
At the same time, the Commission pledges to cut administrative burdens by around a quarter to a third, with more than half of legislative initiatives carrying a simplification component. For ISPs, this raises expectations of streamlined procedures in areas like permits, spectrum, and security reporting, but also hints at stricter enforcement of already adopted rules rather than a full regulatory reset.
Digital Networks Act and “fair share”
Although initially planned earlier, the DNA proposal is now expected in early 2026 and is described as the main vehicle for modernising EU telecoms regulation. It is intended to update the Electronic Communications Code, tackle fragmentation, and potentially introduce new IP interconnection dispute resolution mechanisms that could operate as de facto network fee tools vis-à-vis large content and application providers.
Incumbent operators see this as a chance to rebalance the value chain, seeking obligations for hyperscale’s to negotiate “fair and reasonable” terms for IP data transport and interconnection. Smaller ISPs and some Member States, however, warn that such mechanisms could entrench large operators, distort competition, and overlap awkwardly with existing frameworks like the DMA and DSA. Final wording of the proposal of DNA and the final version after negotiations will be crucial for the next development of EU telco world.
Beyond the DNA, ISPs are touched by proposals for a pan European critical communication system connecting emergency services across borders, and by acts on cloud, AI and quantum technologies that seek secure, EU controlled infrastructure. These initiatives open new wholesale and managed service opportunities for telecom operators, but also increase their obligations around resilience, cybersecurity, and lawful access.
We are living in interesting times…
Jaromír Novák
Partner for relations with public administration
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Freedom Internet offers a true Dutch alternative and being a member of EuroISPA elevates our company to a European level.
Freedom Internet was created in the context of the demise of XS4ALL, the first consumer internet service provider in The Netherlands. We were able to found Freedom through a very successful crowdfunding campaign in December 2019. After Freedom was established, we started delivering our services in the first half of 2020. This was an interesting time obviously, because during the pandemic people worked from home and the consumer internet connection was used more intensively than ever before.
Freedom firmly believes it is important people have an actual choice when it comes to their communication infrastructure. Not only with regard to the price, but also with regard to the type of company that delivers their internet services. Freedom is crowdfunded as opposed to funded through private equity. The only shareholder with voting rights is a foundation. And to make sure we stick to our mission -a free, open and accessible internet for everyone- we are closely connected to civil society organisation Bits of Freedom.
We support Euroispa’s mission: to help deliver the benefits of the internet to individuals while meeting legitimate concerns around vulnerable members of society as well as the development of a free and open internet. Freedom believes that sharing knowledge and information is the core function of the internet. Together with others around the world we are committed to a responsible stewardship of the internet ecosystem. For example by participating in MANRS.
The EuroISPA membership definitely facilitates our transnational collaborations as well as creates a trusted environment for sharing information regarding national use cases and local political developments .
Bibi van Alphen
Legal and Public Affairs at Freedom Internet
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As Europe navigates the next phase of its digital transformation, the intersection of artificial intelligence and copyright is emerging as a defining issue for policymakers and digital industry stakeholders alike. For Internet Service Providers and digital infrastructure operators at the heart of Europe’s online ecosystem, ensuring a regulatory environment that is both balanced and innovation-friendly is essential.
The ability to train AI systems efficiently and transparently depends on access to large and diverse datasets, many of which include works protected by copyright. In this context a clear, harmonised European approach to text and data mining (TDM), grounded in the principles of legal certainty and technological neutrality is essential. Fragmented national interpretations or overly restrictive licensing requirements risk hindering innovation, undermining Europe’s digital competitiveness, and discouraging smaller players from participating in AI development.
The European Commission’s recent Digital Omnibus proposal—aimed at streamlining overlaps between the GDPR, the AI Act, and other digital regulations—signals a welcome step toward greater regulatory coherence. By recognising AI training as a legitimate basis for data processing, subject to robust safeguards, the proposal also aligns with EuroISPA’s longstanding position that innovation and rights protection are not mutually exclusive. At the same time, coordinated definitions of data use and clearer compliance pathways will help providers across the internet value chain to fulfil obligations responsibly and efficiently.
The way forward must rest on open standards, proportional obligations, and shared accountability. Intermediaries and service providers play a vital enabling role in Europe’s digital economy but should not be overburdened with copyright enforcement duties that go beyond their technical and legal capacity. Instead, collaboration between rights holders, developers, and policymakers—supported by transparency mechanisms and fair attribution practices—can create a sustainable foundation for both creation and innovation.
Ultimately, Europe has the opportunity to shape a futureproof digital copyright and AI framework that supports creativity, safeguards fundamental rights, and ensures that European networks remain the trusted backbone of digital progress. That balance—between trust, freedom, and innovation—is the cornerstone of a resilient and competitive European internet.
Stefan Ebenberger
Member of the Board of EuroISPA
Secretary General of ISPA Austria
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Europe stands at a pivotal moment in its digital transformation. Connectivity is no longer a convenience – it is the backbone of economic growth, innovation, and societal resilience. As eco – Association of the Internet Industry and EuroISPA, we share a common mission: to ensure that Europe’s digital infrastructure is secure, sustainable, and future-ready. This article outlines our joint vision for the next era of connectivity, addressing technological, regulatory, and societal challenges.
From Copper to Fiber: Building the Foundation
The transition from copper-based networks to fiber-optic infrastructure is essential for Europe’s competitiveness. Fiber offers unmatched bandwidth, ultra-low latency, and resilience – capabilities that copper cannot deliver in an era of cloud computing, IoT, and real-time applications. Accelerating fiber deployment, particularly in rural and underserved regions, is critical to closing the digital divide. Both eco and EuroISPA advocate for investment-friendly policies and streamlined permitting processes to make this transition a reality.
6G: The Intelligent Network of Tomorrow
While 5G rollout continues, 6G research is already shaping the next frontier. Expected by 2030, 6G will deliver terabit-per-second speeds, sub-millisecond latency, and AI-driven network orchestration. It will enable holographic communication, digital twins, and immersive extended reality, transforming sectors from healthcare to manufacturing. To achieve this, Europe must invest in terahertz spectrum, edge computing, and global standards, ensuring interoperability and security.
Quantum Networking: Reinventing Security
Cybersecurity is a cornerstone of trust in the digital age. Quantum networking, through technologies like Quantum Key Distribution (QKD), will make data interception virtually impossible. This is vital for protecting critical infrastructures systems. Europe must lead in quantum research and pilot projects to safeguard digital sovereignty.
Satellites: Bridging the Last Mile
Fiber and terrestrial networks will dominate urban connectivity, but satellite Internet – especially Low Earth Orbit (LEO) constellations – will play a key role in connecting remote regions. Integrating satellite solutions into Europe’s connectivity strategy ensures inclusivity and resilience, supporting economic development and social cohesion
The Backbone: Data Centers, IXPs, and DNS
Behind every digital service lies a robust infrastructure:
Data Centers: The engines of the digital economy. Scaling sustainably with energy-efficient technologies and renewable energy is non-negotiable.
IXPs: Internet Exchange Points reduce latency and strengthen resilience. Expanding Europe’s IXP ecosystem enhances performance and digital sovereignty.
DNS: A stable and secure Domain Name System is fundamental. Implementing DNSSEC and redundancy measures is essential to prevent outages and attacks.
Sustainability and Security: Our Shared Priorities
Both eco and EuroISPA champion green digital infrastructure, aligning with EU climate goals. Energy efficiency, heat reuse, and renewable integration are critical for data centers and networks. At the same time, cybersecurity must evolve with zero-trust architectures, AI-driven threat detection, and strong encryption standards.
Encryption: A Non-Negotiable for Trust
EuroISPA has consistently defended end-to-end encryption as a cornerstone of privacy and security. Proposals to weaken encryption under initiatives like ProtectEU or e-Evidence risk undermining trust and exposing users to cyber threats. Our joint position is clear: encryption must remain robust and uncompromised. Any legislative approach should balance law enforcement needs with fundamental rights and technological realities.
Policy and Collaboration: The Road Ahead
The future of connectivity requires coordinated action. Policymakers must create frameworks that encourage investment, innovation, and sustainability without imposing disproportionate burdens. Industry associations like eco and EuroISPA play a vital role in shaping balanced regulations, from the Digital Networks Act to cybersecurity standards. Public-private partnerships will be the cornerstone of Europe’s digital success.
Conclusion: A Connected, Secure, and Sustainable Europe
Connectivity is not just about speed – it is about enabling opportunity, resilience, and trust. From fiber to 6G, from satellites to quantum networks, and from data centers to DNS, every component matters. Together, eco and EuroISPA are committed to driving this transformation and ensuring that Europe remains a global leader in digital innovation.
Lars Steffen
Vice-President of EuroISPA
Head of International, Digital Infrastructures & Resilience of eco – Association of the Internet Industry
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EU Digital Agenda for 2026: from strategy to action
The time for action has arrived. Over the last months, the European Commission has defined broad policy guidelines for the current mandature (2024-2029): simplification, competitiveness, and innovation. The European executive has learned from the Mario Draghi and Enrico Letta reports – a welcome shift toward pragmatism for Internet Service Providers.
In 2026, the Commission will translate these priorities into concrete proposals. Its work program directly impacts EuroISPA members across connectivity, data protection, cybersecurity, AI and platform regulation – making active engagement essential.
KEY LEGISLATIVE PRIORITIES
The future Digital Networks Act is one of the major priorities for EuroISPA members. As Europe recasts its Electronic Communications Code, the stakes could not be higher: ensuring sustainable investment models while meeting connectivity demands for decades ahead. We expect the Commission to deliver a framework that balances regulatory certainty with technological evolution, incentivizing investment in digital infrastructures.
EuroISPA welcomed the October 2025 Digital Omnibus Package. Aligning e-Privacy with GDPR is critical – reducing administrative burdens while clarifying legal obligations. Ensuring AI Act implementation is innovation-friendly similarly heads in the right direction. For our members, simplification here means tangible operational relief.
On the revision of the Cybersecurity Act, EuroISPA supports a targeted revision of the Regulation.
On the Digital Fairness Act: while we support strong consumer protection, creating new legislation risks regulatory fragmentation. Existing frameworks can achieve these goals more efficiently.
On online piracy of sports and other live events, following its evaluation of the 2023 Recommendation, the Commission has concluded that this non-binding instrument is insufficient to tackle this illegal phenomenon. It is likely that a new legislative initiative is being considered to harmonise cooperation tools and EuroISPA will carefully follow how the issue may evolve, ensuring any framework respects technical feasibility and fundamental rights.
COOPERATION BETWEEN INTERNET SERVICE PROVIDERS AND JUDICIAL AUTHORITIES
EuroISPA remains committed to ongoing discussions on the CSAM regulation which is at the final stage of negotiations. It welcomes the Council’s general approach adopted under the Danish Presidency, which excluded detection obligations from the scope of the future regulation.
The August 2026 e-evidence regulation implementation presents significant operational challenges, particularly the decentralized IT system. EuroISPA will facilitate dialogue between members and the Commission to ensure workable compliance pathways.
On metadata retention, we await the early 2026 impact assessment. Any legislative initiative must avoid imposing requirements that compromise EU competitiveness, digital sovereignty, or cybersecurity – outcomes that benefit neither security nor innovation.
Finally, encryption remains paramount. As the Commission launches its expert group, EuroISPA’s co-signed global statement underscores our position: encryption is foundational to digital trust and economic security. Proposals weakening encryption to facilitate law enforcement access would fundamentally undermine these objectives – a tradeoff Europe cannot afford.
EuroISPA’s strength lies in our diverse membership – representing the full value chain from infrastructure providers to content platforms. Our established relationships with European institutions (Commission, Parliament, Council) and agencies (EUIPO, BEREC) position us to effectively advocate for balanced, evidence-based policies. As 2026’s legislative agenda unfolds, our collective voice will be essential in shaping Europe’s digital future.
Romain Bonenfant
President of EuroISPA
Managing Director of FFTélécoms – Fédération Française des Télécoms