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Revision of the NIS Directive

Digital economy and society

Digital transformation creates opportunities, but also brings threats for our economy and society. Despite progress made with the Directive on Security of Network and Information Systems, cybersecurity capabilities in the Member States remain unequal and the level of protection in the EU is insufficient. As announced in the Communication on shaping Europe’s Digital Future, the ongoing review of the Directive will be accelerated to be ready by end 2020 and possibly propose a new legal act.

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Public consultation

ID: 12475

Lobbying Activity

102 responses

Consultation response

Bureau Européen des Unions de Consommateurs, 28 Jul 2020

BEUC welcomes the current initiative from the European Commission to review the Directive on security of network and information systems (NIS Directive). Recent cyberattacks confirmed the need for strong IT security of critical infrastructure. In June 2019, a cyberattack hit four hospitals in…

Meta urges one-stop-shop reporting for messaging services under NIS2

Meta Platforms Ireland Limited and its various subsidiaries, 18 Mar 2021

Meta requests that messaging services benefit from streamlined reporting to one authority rather than every EU Member State. They want recognition that end-to-end encryption is fundamental to cybersecurity. They seek flexible, outcome-based security standards rather than prescriptive technical requirements.
This would eliminate burdensome multi-country reporting and preserve flexibility for encryption technologies.
National regulators lose direct oversight of cross-border messaging service security incidents.

Consultation response

Microsoft Corporation, 17 Mar 2021

In two centuries, technology has changed the nature of what it takes to defend a nation. A comprehensive and multistakeholder approach through renewed strategies, legislation, global cooperation, and shared values is needed to improve the security posture of organizations across the European…

Microsoft seeks harmonized EU cybersecurity rules and industry participation

Microsoft Corporation, 11 Aug 2020

Microsoft requests harmonized cybersecurity standards across EU Member States using international frameworks like ISO/IEC 27103. They advocate for maintaining current incident reporting thresholds and oppose lowering them. They seek formal industry participation through stakeholder groups advising EU cybersecurity bodies.
This would reduce compliance costs and provide strategic influence over EU cybersecurity policy development.
Citizens lose from fewer incident reports that could reveal cybersecurity vulnerabilities and threats.

Auto industry seeks clarity on NIS 2 cybersecurity rules

Association des Constructeurs Européens d'Automobiles, 17 Mar 2021

ACEA and CLEPA request clearer definitions of which entities qualify as 'essential' or 'important', guidance on how existing sector-specific rules like UN-ECE Regulation 155 interact with NIS 2, and more realistic reporting timeframes. They argue the 24-hour initial notification requirement is unrealistic and question why entities not deemed essential face the same obligations as those that are.
Clearer scope would reduce compliance uncertainty and avoid duplicative obligations with existing automotive cybersecurity rules.
Delayed or weakened reporting could leave cybersecurity threats undetected longer across critical infrastructure.

Consultation response

Bundesverband der Deutschen Industrie e.V., 16 Mar 2021

German industry welcomes the European Commission’s aim to significantly strengthen Europe's cyber-resilience and to create a level playing field for essential and important entities across the European Union. Cyber and IT security are the basis for a long-term secure digital transformation of the…

Consultation response

Bundesverband der Deutschen Industrie e.V., 10 Aug 2020

German industry welcomes the European Commission’s aim to significantly strengthen Europe's cyber-resilience and to create a level playing field for operators of essential services (OES) across the European Union. Cyber and IT security are the basis for a long-term secure digital transformation of…

Consultation response

DIGITALEUROPE, 18 Mar 2021

The review of the Directive on Security of Network and Information Systems (NIS2) is an essential step towards a more resilient Europe, ensuring state-of-the-art risk management of current and emerging cyber threats to vital sectors of the EU economy and society. One of the goals of the 2016 NIS…

Consultation response

DIGITALEUROPE, 13 Aug 2020

As the voice of digitally transforming industries in Europe, DIGITALEUROPE appreciates the opportunity to provide feedback on the European Commission’s roadmap consultation on the review of EU rules on the security of network and information systems. The Directive on security of network and…

Consultation response

Vodafone Belgium SA, 18 Mar 2021

Vodafone welcomes the European Commission’s attempt to achieve a higher level of harmonisation and consistency with other legal instruments in its revised Directive on Security of Network and Information Systems (NIS2). Full feedback in the accompanying attachment.

Consultation response

ENEL SpA, 18 Mar 2021

Dear Members of European Commission, DG CNECT Unit H.2; Enel SpA, a multinational company in the energy sector highly appreciates the EC prompt revision of the Directive on the security of network and information systems (EU) 2016/1148. Please find the Enel Group feedback in the attachment.

Consultation response

ELECTRICITE DE FRANCE, 18 Mar 2021

EDF welcomes the European Commission proposal for a revised Directive on Security of Network and Information Systems (NIS 2 Directive) that will improve the EU’s overall cybersecurity, including in a strategic sector such as energy. The inclusion of new sub-sectors of the power system in the scope…

Consultation response

ENEL SpA, 5 Aug 2020

Dear Members of DG CNECT H2, Enel SpA, a multinational company in the energy sector highly appreciates the EC initiative to review the Directive (EU) 2016/1148. The first suggestion to revise the future legislation relates to the provisions allowing Member States to define essential services and…

Consultation response

Fédération bancaire française, 6 Aug 2020

Bonjour, Je vous prie de trouver la réponse FBF dans le fichier joint. bien cordialement

Consultation response

IBM Corporation, 18 Mar 2021

In a time of turmoil, and with recent unprecedented cyber breaches such as Solarwinds, the EU’s revision of the NIS Directive certainly is a timely one. As a leading cybersecurity services provider, IBM believes the Revision should focus on increasing collaboration between government and industry…

Consultation response

Insurance Europe, 18 Mar 2021

Insurance Europe welcomes the opportunity to provide feedback on the proposal for a revised NIS Directive. Insurance Europe's position can be found attached.

Consultation response

Orange, 10 Jul 2020

Orange Comments on the European Commission’s Initiative for reviewing the NIS Directive Orange welcomes the Commission’s initiative to review the Network and Information Systems (NIS) Directive in light of current technological, market and regulatory developments and to provide an effective…

Consultation response

Deutsche Industrie- und Handelskammer, 18 Mar 2021

Companies themselves have a vital interest in the security of the data, applications, systems and infrastructures. Accordingly, the obligations which it is intended to introduce for companies should take greater account of the principle of appropriateness. The planned additional obligations are…

Consultation response

ENGIE, 18 Mar 2021

ENGIE welcomes the proposal for a directive on cybersecurity. We believe it is important to give the entities targeted by NIS2 the ability to define which essential services and activities need to be better protected and which are the most important computer systems and networks that support them.…

Consultation response

European Association Automotive Suppliers, 17 Mar 2021

CLEPA – European Association of Automotive Suppliers and ACEA – European Automobile Manufacturers Association welcome the opportunity to provide feedback on the Commission’s proposal for a Directive on high common level of cybersecurity across the Union (NIS 2 Directive). The proposal is timely and…

Consultation response

European Banking Federation, 10 Aug 2020

The European Banking Federation (EBF) shares the European Commission’s opinion that the different approaches of Member States in implementing the NIS Directive have led to significant inconsistencies and fragmentation in the regulatory landscape, which are in turn undermining the level playing…

Consultation response

MedTech Europe, 18 Mar 2021

We welcome the NIS 2 Directive proposal as an improvement over the current NIS Directive. Relevant sectoral guidance could promote further harmonisation and clarity on how to act when cyberincidents are putting healthcare and patient safety at risk. RECOMMENDATIONS * An adequate level of…

Consultation response

UNIFE, 8 Mar 2021

UNIFE – the association of the European rail manufacturing industry – acknowledges that a revision of the ‘’Network and Information Security’’ Directive (‘’NIS’’) is nowadays necessary to make it fitter vis-à-vis current cyber-risks. Unprecedented pace in digitalisation, including a huge rise in…

Consultation response

UNIFE, 13 Aug 2020

UNIFE – the association of the European rail supply industry – welcomes the Commission’s initiative to review the Network and Information Security (NIS) Directive, in the framework of the ‘’Shaping Europe’s digital future’’ masterplan. The NIS Directive in 2016 marked one of the most important…

Consultation response

Mouvement des Entreprises de France, 18 Mar 2021

MEDEF welcomes this European cybersecurity strategy because it seems today, more than ever, necessary to strengthen the level of cybersecurity of the entire European ecosystem, be it companies, but also and above all States and public authorities. However, it is necessary to ensure consistency at…

Consultation response

Community of European Railway and Infrastructure Companies, 17 Mar 2021

The Community of European Railway and Infrastructure Companies (CER aisbl) supports the overall intention of the proposed NIS-2 Directive. In our opinion it is fully justified that the EU and the entities in the critical sectors pay more attention to and harmonise the efforts for cyber security.…

Consultation response

Connect Europe, 11 Aug 2020

ETNO Comments on the European Commission’s Inception Impact Assessment on the Review of the NIS Directive July 2020 ETNO welcomes the European Commission’s (EC) initiative to review the Network and Information Systems (NIS) Directive in light of current technological, market and regulatory…

Huawei urges technical standards over country-of-origin restrictions in cybersecurity

Huawei Technologies, 18 Mar 2021

Huawei advocates for a strong focus on technical measures to enhance the cybersecurity of ICT products, systems and services. They want certification based on industry standards rather than country-of-origin assessments. The company argues that recent cyber attacks demonstrate trust-based approaches imposing restrictions based mainly on country-of-origin are ineffective and dangerous.
This would prevent restrictions based on their Chinese origin and maintain market access.
Member states lose flexibility to exclude vendors deemed security risks by intelligence agencies.

Consultation response

Huawei Technologies, 13 Aug 2020

Huawei welcomes the Commission's approach to review the Directive on Security of Network and Information Systems (NIS). We take into account that now is a timely opportunity to review the NIS Directive with consideration for state-of-the-art technology and cybersecurity, industry and regulatory…

Consultation response

SGI Europe, 18 Mar 2021

SGI Europe generally welcomes the opportunity to provide feedback to the recently adopted Directive on security of network and information systems (NIS 2 Directive) by the European Commission that introduces in our point of view significant and problematic changes compared with the first version of…

Consultation response

ITI - The Information Technology Industry Council, 18 Mar 2021

Dear Madam or Sir, We are pleased to share ITI's views on the proposal for a revision of the NIS Directive. Please find our detailed comments in the submission attached. Kind regards, Vivien Witt on behalf of ITI, the Information Technology Industry Council

Consultation response

ITI - The Information Technology Industry Council, 13 Aug 2020

The Information Technology Industry Council (ITI) appreciates the opportunity to submit the attached comments to the European Commission on the NIS Directive combined evaluation roadmap/inception impact assessment. ITI is the global association of the tech industry. Our membership comprises over 73…

Consultation response

GSMA Europe, 20 Jul 2020

The GSMA welcomes the Commission’s initiative to review the Network and Information Systems (NIS) Directive, agrees that it needs to be reviewed in light of current technological, market and regulatory developments and shares its objectives. The Covid-19 pandemic has highlighted the criticality of…

Consultation response

APPLiA (Home Appliance Europe), 19 Mar 2021

APPLiA appreciates the opportunity to provide this feedback. While a condensed version of our comments is below, please see the attached document for our full comments. APPLiA understands the need for comprehensive rules for a high level of cybersecurity within the European Union. APPLiA’s first…

Consultation response

AIM - European Brands Association, 18 Mar 2021

AIM, the European Brands Association, thanks the Commission for the specific inclusion of domain name registration data in this draft Directive. We fully agree with Recital 59, that “maintaining accurate and complete databases of domain names and registration data (so called ‘WHOIS data’) and…

Consultation response

eBay EU liaison office, 18 Mar 2021

eBay thanks the European Commission for the opportunity to provide feedback on the draft Revised Directive on Security of Network and Information Systems (NIS2). Our contribution can be found in the attachment.

Consultation response

Deutsche Börse AG, 18 Mar 2021

Dear Sir or Madame, please see the feedback of Deutsche Börse Group on the proposal for the review of EU rules on the security of network and information systems (NIS 2.0) attached. Best regards Jan Doser

Consultation response

Business Software Alliance, 17 Mar 2021

BSA | The Software Alliance (BSA) welcomes the opportunity to comment on the Commission’s revised Directive on security of network and information systems (herewith “NIS 2.0 Directive”). BSA is the leading advocate for the global software industry. BSA members are at the forefront of…

Consultation response

Business Software Alliance, 13 Aug 2020

BSA | The Software Alliance (BSA) welcomes the opportunity to provide input to the Commission’s evaluation roadmap/ Inception Impact Assessment on the NIS Directive. BSA is the leading advocate for the global software industry. Our members are at the forefront of software-enabled innovation that is…

Consultation response

Verband Kommunaler Unternehmen e.V., 18 Mar 2021

Sehr geehrte Damen und Herren, die Bundesvereinigung der kommunalen Spitzenverbände (BV) und der Verband kommunaler Unternehmen e.V. (VKU) begrüßen, dass die NIS 2-Richtlinie die Cybersicherheitsstandards in der gesamten Europäischen Union erhöhen soll. Die Sicherheit und Integrität der Systeme…

Consultation response

Computer & Communications Industry Association, 13 Aug 2020

CCIA represents a wide range of suppliers and users of Digital Services and Essential Services, and we welcome the opportunity to contribute to the review of the Network and Information Security (NIS) Directive. The NIS Directive has contributed to a higher level of security of network and…

Consultation response

European Coordination Committee of the Radiological, Electromedical and healthcare IT Industry, 18 Mar 2021

COCIR welcomes the opportunity to provide feedback to the European Commission’s proposal for a Directive on measures for a high common level of cybersecurity (hereafter the NIS 2 Directive proposal). COCIR appreciates that the NIS 2 Directive approval builds upon the strengths of the original…

Consultation response

European Coordination Committee of the Radiological, Electromedical and healthcare IT Industry, 12 Aug 2020

COCIR welcomes the opportunity to provide feedback to the combined roadmap and inception impact assessment on the revision of the Directive on Security of Network and Information Systems (NIS Directive) as published by the European Commission. Please refer to attached document for COCIR's…

Consultation response

Liberty Global Corporate B.V., 11 Aug 2020

Liberty Global welcomes the opportunity to comment on the European Commission (Commission)’s roadmap for the review of the Union’s rules on the security of network and information systems (the roadmap). This is a valuable step towards a comprehensive evaluation of the NIS Directive. Equally…

Consultation response

Suomen Yrittäjät ry, 13 Aug 2020

The review of the Directive on Security of Network and Information Systems (the NIS Directive), passed in 2016, is in our mind welcome, given the rapid pace of the digital transition which keeps increasing the amount of cyber threats in essential sectors of the European societies and economies. The…

Consultation response

NXP Semiconductors Netherlands B.V., 18 Mar 2021

Please see uploaded position paper.

Consultation response

FEPORT, 18 Mar 2021

Please find in the attached document FEPORT's feedback to the EU Commission proposal for a NIS 2 Directive.

Consultation response

DIN Deutsches Institut für Normung e. V., 17 Mar 2021

DIN, the German national standardization body, welcomes and supports the proposal for an update of the directive on measures for a high common level of cybersecurity across the Union (NIS2 Directive) that seeks to improve resilience and incident response capacities of public and private entities as…

Consultation response

ZVEI e.V. - Verband der Elektro- und Digitalindustrie, 18 Mar 2021

The ‘ZVEI, the German Electrical and Electronic Manufacturers’ Association’ appreciates the opportunity to comment on the EU Commission’s proposal for a Directive on measures for a high common level of cybersecurity across the Union, repealing Directive (EU) 2016/1148. We understand and support the…

Consultation response

ZVEI e.V. - Verband der Elektro- und Digitalindustrie, 31 Jul 2020

Strengthening cyber-resilience is an important goal, so that all stakeholders involved can live and work peacefully with each other in an increasingly networked and digitalised world. Cyber incidents cause considerable damage to both companies and private individuals and are therefore a threat for…

Consultation response

ACT | The App Association, 16 Mar 2021

Please find attached the feedback of ACT | The App Association (Transparency Reg. # 72029513877-54) to the European Commission’s Directorate-General for Communications Networks, Content and Technology on its proposal for a directive on measures for a high common level of cybersecurity across the…

Consultation response

FIGIEFA - Fédération Internationale des Grossistes, Importateurs & Exportateurs en Fournitures Automobiles / International Federation of Automotive Distributors, 10 Aug 2020

FIGIEFA, the European Federation of Automotive Aftermarket Distributors, is part of Europe’s substantial automotive aftermarket and mobility value chain, accounting for over 4,5 million jobs in the wider ‘automobile use’, most of them being employed in over 500.000 SMEs. This sector plays a vital…

Consultation response

CSC – IT CENTER FOR SCIENCE LTD., 17 Mar 2021

CSC welcomes the Commission’s proposal and especially its ambition to further harmonise the level of cybersecurity across the EU by expanding the scope of the Directive, spelling out many of its requirements in more detail and equipping the Member States with more stringent supervision and…

Consultation response

Palo Alto Networks Inc., 29 Jul 2020

NIS roadmap recommendations Palo Alto Networks is the global cybersecurity leader with a strong and continuously growing presence throughout Europe and around the world across the private, public, and Critical National Infrastructure sectors. We support the European Commission’s intention to…

Consultation response

European Federation of National Associations of Water Services, 3 Aug 2020

EurEau welcomes the review of the NIS Directive and appreciates the possibility to input the process though the feedback to the Roadmap. Since the NIS Directive transposition period ended in May 2018, EurEau members think it is challenging to assess the provisions and how they have worked in…

Consultation response

Fédération Française de l'Assurance, 18 Mar 2021

The French insurance sector welcomes the European Commission’s willingness to strengthen the level of cybersecurity across the Union as it has been identified by our industry as a major challenge. A clarification of the interaction between NIS2 and DORA is however needed to allow for a harmonised…

Consultation response

UNION FRANCAISE DE L'ELECTRICITE - UFE, 18 Mar 2021

A high level of cybersecurity across the EU can only be achieved through a systemic approach UFE supports the extension of the scope to more (sub)sectors. The introduction of a new distinction between essential and important entities with identical risk management and reporting obligations is a…

Consultation response

CLECAT - European association for forwarding, transport, logistic and Customs services, 18 Mar 2021

CLECAT, the European Association for Forwarding, Transport, Logistics and Customs Services, considers that it is of key importance to ensure the security of logistics supply chains at all times and supports measures in the field of cybersecurity which can assist companies to become more resilient…

Consultation response

DEKRA e.V., 3 Aug 2020

ELEMENTS TO BE INCORPORATED IN A REVISED NIS DIRECTIVE DEKRA recommends incorporating three major elements when revising the NIS Directive. Please find them outlined in the following: 1. UNIFICATION OF EVALUATION METHODOLOGIES, LIMITATION OF GRANULARITY Under the flexibility of the current NIS…

Consultation response

European Internet Services Providers Association, 18 Mar 2021

The European Internet Services Providers Association (EuroISPA) is the world's largest association of Internet Services Providers (ISPs), representing over 2,000 ISPs across the EU and EFTA countries. EuroISPA is recognised as the voice of the EU ISP industry, reflecting the views of ISPs of all…

Consultation response

Japan Business Council in Europe, 18 Mar 2021

Japan Business Council in Europe (JBCE) welcomes the opportunity to provide our feedback on the proposal for the Revised Directive on Security of Network and Information Systems (NIS2). The proposal is very important and timely as it supports the Commission’s efforts to address new challenges in…

Consultation response

Związek Pracodawców Business & Science Poland, 18 Mar 2021

Business & Science Poland welcomes and appreciates the European Commission’s efforts in strengthening the European cybersecurity system. We see an urgent need for the improvement of cyber threats awareness and the technical adaptation to current digital threats and challenges. In our opinion, the…

Consultation response

International Trademark Association, 17 Mar 2021

The International Trademark Association (INTA) is pleased to provide the following comments and suggestions to the Proposal for a Directive of the European Parliament and the Council on measures for a high common level of cybersecurity across the Union, repealing Directive (EU) 2016/1148 or…

Consultation response

NaTran, 18 Mar 2021

GRTgaz is fully committed to the Paris Agreement and as a leading gas infrastructure operator, we are ready to assume our responsibility and put our infrastructure to good use in service of the energy and ecological transition. The objective of climate neutrality goes hand in hand with the need for…

Consultation response

CurrENT Enabling Network Technology throughout Europe E.E.I.G., 18 Mar 2021

currENT is an industry association that represents the voice of Europe’s innovative grid technology companies. currENT welcomes the Commission´s initiative to review the existing Network and Information Security (NIS) Directive. Safe and reliable electric service has long been understood to be a…

Consultation response

Internet Corporation for Assigned Names and Numbers, 18 Mar 2021

ICANN org welcomes the opportunity to submit comments to the consultation on the Proposal for a Directive on Measures for a High Common Level of Cybersecurity Across the Union, repealing Directive (EU) 2016/1148 (NIS 2 Directive). Please find attached our contribution.

Consultation response

Bureau Brussels Consulting, 18 Mar 2021

European Data Centre Association (EUDCA) represents the European data centre (DC) operator community. EUDCA is happy to submit feedback on the revision of EU rules on the security of network and information systems and wants to draw attention to three main remarks that it identified concerning the…

Consultation response

Bureau Brussels Consulting, 11 Aug 2020

The European Data Centre Association (EUDCA) represents the European data centre operator community. The EUDCA is happy to submit feedback on the the revison of the Network and Information Security Directive (NIS Directive) and wants to draw attention to the following key points: • There is…

Consultation response

Federation of European Risk Management Associations, 18 Mar 2021

The Federation of European Risk Management Associations (FERMA) is pleased to have the opportunity to provide the Commission with its comments on the proposal for NISD 2.0. Broadly speaking we see it as a step forward that could benefit with some clarification and additional guidance in some…

Consultation response

Numeum, 18 Mar 2021

L’accélération de la transformation numérique dans les entreprises a entrainé la mise en place de nouveaux systèmes d’information ou de nouvelles briques sur les systèmes existants, ce qui a conduit à un accroissement des potentiels vulnérabilités et d’une plus grande surface d’exposition aux cyber…

Consultation response

Fédération Française des Télécoms, 18 Mar 2021

Established on the 24th September 2007, the French Telecoms Federation (Fédération Française des Télécoms, hereinafter “the FFTélécoms”) represents the electronic communications operators in France. Its missions are to promote an innovative and responsible industry with respect to society, the…

Consultation response

eco - Verband der Internetwirtschaft, 10 Feb 2021

Über eco Mit über 1.100 Mitgliedsunternehmen ist eco der größte Verband der Internetwirtschaft in Europa. Seit 1995 gestaltet eco maßgeblich das Internet, fördert neue Technologien, schafft Rahmenbedingungen und vertritt die Interessen seiner Mitglieder gegenüber der Politik und in internationalen…

Consultation response

eco - Verband der Internetwirtschaft, 12 Aug 2020

Über eco: Mit über 1.100 Mitgliedsunternehmen ist eco der größte Verband der Internetwirtschaft in Europa. Seit 1995 gestaltet eco maßgeblich das Internet, fördert neue Technologien, schafft Rahmenbedingungen und vertritt die Interessen seiner Mitglieder gegenüber der Politik und in internationalen…

Consultation response

Comité Colbert, 16 Mar 2021

The Comité Colbert welcomes the Commission’s proposal for the NIS2 Directive, which will enhance the EU citizens’ security in the digital environment. Article 23 which addresses the importance of maintaining the accuracy and accessibility of domain name registration data for the upholding and…

Consultation response

Kaspersky Labs Limited, 5 Mar 2021

Kaspersky welcomes the Commission’s new proposal (further – proposal) on measures for a high common level of cybersecurity across the Union, which revises Directive 2016/1148 on the security of network and information systems (NIS Directive). We are glad to see that many recommendations made by…

Consultation response

Kaspersky Labs Limited, 22 Jul 2020

Kaspersky strongly supports the EU in its efforts to substantially and sustainably strengthen the resilience of networks and systems against cybersecurity risks. We also see the need to harmonize the European Digital Single Market and to reduce the fragmentation that has resulted from different…

Consultation response

The Alliance for Safe Online Pharmacy in the EU, 18 Mar 2021

Please find attached the ASOP EU submission with additions to the original submission.. Thank you Mike Isles Executive Director ASOP EU mike.isles@asop.eu www.asop.eu Mobile +44 7540 462867

Consultation response

The Alliance for Safe Online Pharmacy in the EU, 18 Mar 2021

ASOP EU submission is attached as a file. PDF Thank you Mike isles Executive Director ASOP EU mike.isles@asop.eu www.asop.eu

Consultation response

Bundesrechtsanwaltskammer, 3 Mar 2021

s. Stellungnahme in der Anlage

Consultation response

UNION DES FABRICANTS, 18 Mar 2021

UNIFAB - Union des Fabricants is the French association for the promotion and defense of intellectual property rights. It represents business from all economic sectors, and provides them with an association umbrella for promoting intellectual property and fighting against counterfeiting. Today,…

Consultation response

European Cultural and Creative Industries Alliance, 17 Mar 2021

ECCIA welcomes the Commission’s proposal for the NIS2 Directive, which will enhance the EU citizens’ security in the digital environment. Maintaining the accuracy and accessibility of domain name registration data for the upholding and preservation of a reliable, resilient and secure domain name…

Consultation response

EUROSMART, 13 Aug 2020

The NIS Directive has been instrumental in increasing the cyber-resilience of the EU. As the first piece of legislation concerning EU-wide cybersecurity, the NIS Directive is the acknowledgment that incidents in one Member State can have significant cross-border impacts, hence requiring a common…

Consultation response

Fédération Nationale de l'Automobile, 10 Aug 2020

Federation of Craft Businesses in the automotive sector and in mobility services (FNA) would like to thank the authors of the Evaluation Roadmap on Directive (EU) 2016/1148 concerning measures for a high common level of security of network and information systems across the Union (the NIS…

Consultation response

Asociación Española de la Economía Digital, 18 Mar 2021

Please find attached the Spanish Association on the Digital Economy (Adigital) contribution to the consultation on the proposal for a Directive on measures for a high common level of cybersecurity across the Union, repealing Directive (EU) 2016/1148.

Consultation response

Eesti Infotehnoloogia ja Telekommunikatsiooni Liit, 18 Mar 2021

Eesti Infotehnoloogia ja Telekommunikatsiooni Liit (ITL), kes esindab Eesti info- ja kommunikatsioonitehnoloogiaga tegelevaid ettevõtteid ja organisatsioone, esitab Euroopa Komisjoni uue võrgu- ja infosüsteemide turvalisuse direktiivi ettepaneku (NIS 2) kohta järgmised kommentaarid ja…

Consultation response

Rettighedsalliancen/Danish Rights Alliance, 18 Mar 2021

The Danish Rights Alliance is pleased to refer to the submissions by the Coalition for Online Accountability as attached. We will further recall the Danish model as Denmark has determined that the public interest in accessible WHOIS data for its .dk ccTLD merits that such information be publicly…

Consultation response

Open-Xchange AG, 17 Mar 2021

Open-Xchange would like to thank for the opportunity to provide comments on the Commission’s proposal for a new directive enhancing cybersecurity measures, replacing the previous NIS directive. Given our field of expertise and market experience, we will be focusing our comments on the following…

Consultation response

Alliance for AI, IoT and Edge Continuum Innovation IVZW, 11 Mar 2021

On behalf of the Alliance for Internet of Things Innovation, please find enclosed our feedback to the draft proposal of the revised Network and Information Security Directive.

Consultation response

Hangzhou Hikvision Digital Technology Co., Ltd., 13 Aug 2020

Hangzhou Hikvision Digital Technology Co., Ltd is a leading provider of innovative security products in the EU, ranging from public security to smart home security solutions. We welcome the opportunity to respond to the European Commission’s public consultation on the revision of the EU’s Network…

Consultation response

ECPAT Belgium, 18 Mar 2021

I am making the attached submission on behalf of ECPAT International. This is a global NGO based in Bangkok, Thailand, with national chapters in over half of the EU's Member States. You will see that we address issues connected with the inaccuracy of WHOIS data. The high levels of inaccuracy…

Consultation response

Internet Infrastructure Coalition, 18 Mar 2021

See attached.

Consultation response

European Energy Information Sharing and Analysis Centre, 18 Mar 2021

European Energy - Information Sharing and Analysis Centre (EE-ISAC) welcomes the opportunity to provide feedback on the proposal for a revised NIS Directive. The EE-ISAC position can be found enclosed.

Consultation response

DENIC eG, 18 Mar 2021

DENIC eG, founded in 1996, is the DNS registry for .de, Germany’s country code top level domain (ccTLD). DENIC operates most of the DNS name servers for .de and provides name service for other TLDs, within and outside the European Union. DENIC welcomes the Commission’s proposal for an enhanced NIS…

Consultation response

Verband der öffentlichen Wirtschaft und Gemeinwirtschaft Österreichs, 18 Mar 2021

The feedback can be found in the attachment.

Consultation response

Arthur's Legal B.V., 18 Mar 2021

Arthur Strategies & Systems is part of Arthur’s Legal. It has handpicked experienced interdisciplinary experts to focus on ability to navigate, enable, facilitate as well as execute and systemize. Our core team consists of attorneys at law, senior legal counsels, governmental advisors,…

Consultation response

Netnod AB, 18 Mar 2021

Netnod have in the attached PDF comments on the proposed directive. A summary: Regarding CSIRTs Netnod believe it is not only the reporting to a CSIRT that is important, but also what a CSIRT produces with the help of that information. The directive because of this should include requirements for…

Consultation response

Verband der Auslandsbanken in Deutschland e.V. / Association of Foreign Banks in Germany, 18 Mar 2021

Dear Sir or Madam, We highly appreciate the opportunity to provide input to the review of the EU rules on the security of network and information systems. Please find enclosed our position paper on the following topics: (A) Classification of small and non-complex credit institutions as…

Consultation response

Aktionskreis gegen Produkt- und Markenpiraterie e.V., 18 Mar 2021

Der Aktionskreis gegen Produkt- und Markenpiraterie e.V. (APM) setzt sich seit mehr als 20 Jahren als branchenübergreifender Verband für den Schutz geistigen Eigentums ein. Gegründet als Gemeinschaftsinitiative des Deutschen- Industrie- und Handelskammertages (DIHK), des Bundesverbandes der…

Consultation response

Réseaux IP Européens (RIPE) Network Coordination Centre (NCC), 18 Mar 2021

As an organisation tasked with operating one of the world’s 13 global DNS root servers (K-root), the RIPE NCC appreciates the opportunity to share its views on the proposed text of the European Commission’s NIS 2 Directive and to express some concerns about how we understand the proposed…

Consultation response

Asociación para la Defensa de la Marca, 18 Mar 2021

From ANDEMA, we celebrate the proposal for a NIS 2.0 Directive that includes a new strategy on cybersecurity with the aim of provide legal measures to boost the overall level of cybersecurity in the Union. The Article 23 about databases of domain names and registration data is fit for purpose. We…

Consultation response

, 16 Mar 2021

VDMA, the German Mechanical Engineering Association, appreciates the opportunity to comment on the legislative proposal for a directive on measures for a high common level of cybersecurity across the Union. As producers of connected and digitized machines and industrial equipment, our sector is one…

Consultation response

Združenie používateľov Slovenskej akademickej dátovej siete SANET, 6 Aug 2020

SANET - Slovak Academic Network Association, highly welcomes EC initiative to revise the NIS directive. Its transposition in member states lead to significantly different and sometimes even confusing results, which definitely needs to be addressed shortly. A very good example could be found in…