EuroISPA welcomes the European Commission’s proposal on the Digital Networks Act (DNA), which aims to modernise the EU regulatory framework for electronic communications and strengthen the competitiveness and resilience of the sector.

We support the overall objectives of greater harmonisation, simplification, and futureproofing of the regulatory framework. However, EuroISPA considers that the proposal does not yet fully achieve these objectives.

Our targeted recommendations to co-legislators focus on:

• Ensuring the stability and effectiveness of existing rules while avoiding unintended regulatory consequences
• Ensuring resilience obligations are defined through performance-based standards that are technically sound and economically proportionate
• Maintaining a proportionate scope for the General Authorisation Regime
• Improving long-term spectrum frameworks and safeguarding proportionality in numbering resources
• Completing the consistency framework and targeting consumer protections at their intended beneficiaries
• Adopting a technology-neutral, outcomes-based approach within end-user protection against fraud, setting clear objectives while empowering providers to deploy the most effective solutions available at any given time
• Ensuring that horizontal legislation remains the primary vehicle for security and sustainability obligations
• Maintaining and strengthening the current BEREC-led governance model
• Modernising the Open Internet rules to reflect the evolution of networks while preserving the aim and the spirit of the original net neutrality rules

EuroISPA looks forward to engaging with co-legislators on these important matters. For more details on EuroISPA’s position, we invite you to read our full contribution below.