CENTR - Council of European Top Level Domain Registries
CENTR
CENTR is the European country code TLD organisation.
ID: 980834014781-65
Lobbying Activity
Meeting with Xavier Coget (Cabinet of Executive Vice-President Henna Virkkunen)
19 Nov 2025 · EU internet governance agenda
Response to Digital package – digital omnibus
14 Oct 2025
CENTR is the association of European country code top-level domain registries (hereinafter ccTLDs). All EU Member States and EEA countries ccTLDs (such as .sk for Slovakia and .ee for Estonia) are members of CENTR. CENTR members are at the core of the public internet, safeguarding its stability and security. The majority of European ccTLDs are non-profit organisations or SMEs, providing an internet infrastructure service in the interest of and in close cooperation with their local internet communities (e.g., end-users, CSIRTs, law enforcement and other competent authorities). CENTR members are responsible for operating and maintaining the technical Domain Name System infrastructure for their top-level domain. CENTR members are considered essential entities under the NIS 2 Directive, they are subject to strict cybersecurity risk-management measures and auditing. As part of the technical internet infrastructure community, CENTR proposes the following key recommendations in response to the call for evidence on the Digital Omnibus. 1) There is no added value in duplicating audits, supervisory powers and minimum cybersecurity risk-management measures across EU legislation affecting essential digital infrastructure. Further simplification and clarification are warranted, including a clear exemption for ccTLD registries from the DORA oversight framework. 2) The number of audits one operator must undergo to demonstrate conformity for the same legislative requirements should be reduced to one, preferably under the main cybersecurity legislation (i.e., the NIS 2 Directive). 3) The European Commission, together with EU Member States, should encourage, and where appropriate facilitate, the development of a single, secure reporting interface at the national level, tailored for each Member State. 4) The European Commission should assess the overlap between different legislative instruments and exempt essential entities from reporting the same incident under multiple legislative frameworks.
Read full responseResponse to Revision of the Standardisation Regulation
18 Jul 2025
CENTR is the association of European country code top-level domain registries (ccTLDs), such as .be for Belgium and .no for Norway. ccTLDs are responsible for operating and maintaining the technical Domain Name System (DNS) infrastructure for their top-level domain. The DNS and other open standards and protocols that are powering the internets infrastructure stack are a prime example of how open standardisation processes have ensured the internets growth and global uptake over many decades since the DNS's inception in 1983. These open standardisation processes have also enabled an industry and market to grow around the DNS alone. Consequently, Europe has the potential to benefit from a meaningful and inclusive standardisation policy that fully embraces and promotes the development and uptake of open standards. To this end, we recommend the following actions: 1) Member States should be encouraged to give preference to open standards in public tenders. 2) Royalty-free open standards must be accepted in the EU public procurement procedures. Consequently, the criteria in Annex II of the Regulation 1025/2012 must accommodate royalty-free standards, as opposed to giving preference to FRAND licensing. 3) The Regulation 1025/2012 should be revised to remove unnecessary obstacles to the approval of open standards for use in public procurement. 4) The EU public sector should increase its active involvement in open standardisation processes at a global level, including in internet standardisation fora.
Read full responseMeeting with Simona Constantin (Cabinet of Commissioner Michael McGrath)
3 Jun 2025 · Digital Information Environment, European Democracy Shield
Response to International Digital Strategy
20 May 2025
CENTR is the association of European country code top-level domain registries (hereinafter ccTLDs). All EU Member State and EEA country ccTLDs (such as .de for Germany and .no for Norway) are members of CENTR. CENTR members are at the core of the public internet, safeguarding its stability and security. The majority of European ccTLDs are non-profit organisations or SMEs, providing an internet infrastructure service in the interest of and in close cooperation with their local internet communities (e.g., end-users, CSIRTs, law enforcement and other competent authorities). CENTR members are responsible for operating and maintaining the technical Domain Name System (DNS) infrastructure for their top-level domain. The DNS is a well-established network protocol at the heart of the internet infrastructure commonly thought of as the phone book of the internet. It provides a navigation function to map user-friendly domain names to numeric IP addresses. As part of the technical internet infrastructure community, CENTR proposes the following key recommendations in response to the call for evidence on Joint Communication on an International Digital Strategy: 1) Open standards and protocols, developed through inclusive and transparent processes, enable internets interoperability, support consumer choice and innovation, and as such should be prioritised by the EU and Member States in public procurement. 2) The EU and its Member States should actively engage in international standardisation processes. This should include participation in multistakeholder standardisation organisations, such as the IETF or W3C, to foster the development of open standards. 3) The EU and its Member States must continue to actively promote the multistakeholder model in the WSIS+20 Review. 4) The EU policymakers must support high data protection standards in the context of international digital governance.
Read full responseResponse to European Democracy Shield
19 May 2025
CENTR is the association of European country code top-level domain registries (hereinafter ccTLDs). All EU Member State and EEA country ccTLDs (such as .de for Germany and .no for Norway) are members of CENTR. CENTR members are at the core of the public internet, safeguarding its stability and security. The majority of European ccTLDs are non-profit organisations or SMEs, providing an internet infrastructure service in the interest of and in close cooperation with their local internet communities (e.g., end-users, CSIRTs, law enforcement and other competent authorities). CENTR members are responsible for operating and maintaining the technical Domain Name System infrastructure for their top-level domain. They only hold information enabling users to navigate the internet but do not store, transmit or enhance any content online. As part of the technical internet infrastructure community, CENTR proposes the following key recommendations in response to the call for evidence on European Democracy Shield: 1) The EU has an extensive legal framework that prescribes clear obligations on all digital services within the information ecosystem when it comes to responding to harmful content. There is no justification for creating a different set of standards for disinformation, while lowering rule of law safeguards available in democratic society. 2) Only competent public authorities, including judicial authorities, are adequately equipped to judge over the level of harm posed by disinformation campaigns and instruct digital service providers, such as ccTLD registries, to take action, based on a clear legal basis available at national and EU level. 3) Disputes over domain ownership and instances of illegitimate brand impersonations can be resolved in judicial proceedings and Alternative Dispute Resolution (ADR) procedures offered across European ccTLD registries and beyond. 4) In line with the simplification agenda of the European Commission, the EUDS should steer clear of additional burden for digital infrastructure actors and not duplicate existing cybersecurity measures already found in other EU legislation. 5) The EUDS must recognise the importance of and promote voluntary private-public partnerships in educational initiatives aimed at internet safety and increased digital literacy skills.
Read full responseMeeting with Thibaut Kleiner (Director Communications Networks, Content and Technology)
19 May 2025 · Presentation of Centre’s activities and exchange of views on Commission files related to the Internet’s Domain Name System
Meeting with Thomas Schmitz (Cabinet of Executive Vice-President Henna Virkkunen)
23 Apr 2025 · Exchange on Disinformation
Meeting with Xavier Coget (Cabinet of Executive Vice-President Henna Virkkunen)
3 Apr 2025 · Internet Governance
Meeting with Jörgen Warborn (Member of the European Parliament, Shadow rapporteur) and Telenor
25 Feb 2025 · Digital Infrastructure
Meeting with Arash Saeidi (Member of the European Parliament)
28 Jan 2025 · Echange de point de vue
Meeting with Sergey Lagodinsky (Member of the European Parliament)
7 Nov 2024 · Exchange of views Start of the new mandate
Response to Rules specifying the obligations laid down in Articles 21(5) and 23(11) of the NIS 2 Directive
24 Jul 2024
CENTR is the association of European country code top-level domain registries (hereinafter ccTLDs). All EU Member State and EEA country ccTLDs (such as .hu, .eu and .no) are members of CENTR. The ccTLD registries are responsible for operating and maintaining the technical Domain Name System (DNS) infrastructure for their top-level domain (TLD) and are directly targeted by the provisions in the Draft Implementing Regulation, as "essential entities" under the Directive (EU) 2022/2555 (NIS 2 Directive). CENTR members appreciate an opportunity to provide feedback and would like to draw the European Commissions attention to the following areas of concern: 1) In order to provide legal clarity for essential entities, and ensure manageability of handling incident reporting for CSIRTs and competent authorities, CENTR calls for keeping Article 3 as focused as possible. A voluntary reporting mechanism available in NIS 2 Directive will provide necessary leverage for more ambiguous situations and facilitate cooperation between CSIRTs and essential entities. 2) CENTR calls for further clarifications in Articles 5 and 6 regarding disruptions of authoritative domain name resolution service that should only include situations under control of the affected entity, within their managed network systems. 3) In order to avoid the overlap of competence between authorities, CENTR calls for narrowing down a significant incident criteria in Article 6(c) to cover breaches of the integrity, confidentiality or authenticity of stored, transmitted or processed data in relation to technical operation of the TLD under the definition provided in the NIS 2 Directive. 4) CENTR calls for including a reasonable and uniform transition period for compliance with the mandatory cybersecurity risk management measures in Annex. More clarity on conformity with the measures in Annex for essential entities and their interplay with the well-established international standards such as the ISO 27000 family standards is needed, as well as allowing flexibility for operators to be able to conduct risk assessments based on their specific role and risk profile. Please see our full feedback with more details and clarifications attached.
Read full responseMeeting with Jana Toom (Member of the European Parliament, Shadow rapporteur)
25 Jul 2023 · Insolvency Law
Meeting with René Repasi (Member of the European Parliament, Shadow rapporteur)
19 Jun 2023 · Exchange of views on "harmonising certain aspects of insolvency law" / Austausch zur "Harmonisierung bestimmter Aspekte des Insolvenzrechts" - Staff Level
Response to Reinforced consumer protection cooperation
21 Dec 2022
CENTR recommendations CENTR fully supports the proportionate and tiered approach enshrined in Article 9(4) of the CPC Regulation concerning the minimum enforcement powers of consumer protection authorities. CENTR calls on the Commission to enshrine that action at domain name registry level should only be available as a measure of last resort as it does not remove the infringing content from the internet, and may have a disproportionate collateral effect on availability of lawful content and services associated with the domain name. CENTR encourages authorities of the CPC Network to increase the use of their cross-border investigation powers, including the alert system to increase the effectiveness of CPC actions in responding to emerging market threats in the EU. Voluntary cooperation agreements with services providers, such as domain name registries, can further support national authorities with their investigations. Competent national authorities should remain the primary enforcing authorities within Member States, when it comes to infringements affecting EU consumers. The European Commission could increase its oversight over investigations regarding traders and service providers established outside of the EU with cross-border impact in two or more Member States, in exceptional circumstances and in close and continuous consultation with national consumer protection authorities.
Read full responseMeeting with Álvaro Amaro (Member of the European Parliament, Shadow rapporteur)
9 Sept 2022 · A reforma das Indicações Geográficas - Proteção intelectual
Response to Fight against counterfeiting
28 Feb 2022
CENTR is the association of European country code top-level domain registries (ccTLDs). All EU Member State and EEA country ccTLDs (such as .si, .no, and .fr) are members of CENTR. CENTR members are at the core of the public internet, safeguarding the stability and security of the internet. The majority of European ccTLDs are non-profit organisations, providing an internet infrastructure service in the interest of and in close cooperation with their local internet communities (e.g. registrars, end-users, rightsholders, CSIRTs, law enforcement authorities).
ccTLDs are responsible for operating and maintaining the technical Domain Name System (DNS) infrastructure for their top-level domain. The DNS is a well-established network protocol at the heart of the internet infrastructure – commonly thought of as the “phone book of the internet”. It provides a navigation function to map user-friendly domain names to numeric IP addresses. ccTLDs only hold information enabling users to
navigate the internet but do not store, transmit or enhance any content online.
CENTR welcomes the European Commission’s call for evidence in the context of the EU Toolbox against counterfeiting and wishes to submit the following recommendations to support fact-based and informed policymaking, in line with the principle of proportionality:
1) For the sake of consistency with existing EU legal framework, and to maintain legal clarity when it comes to targeted action against counterfeiting, CENTR members recommend maintaining the proportionality standard established in the CPC Regulation.
2) It is essential to provide a legal basis for actions at DNS level, alleviating concerns in cases of wrongful actions and ensuring the right to remedy. Therefore, in the case of counterfeiting, only public competent authorities should be able to mandate action from ccTLDs.
3) Where appropriate and depending on local jurisdiction, European ccTLDs should be able to continue carrying out voluntary measures to contribute to the overall safety of their domains.
4) European ccTLDs are ready to share their practices with other TLD operators to contribute to creating a safer online environment.
5) Competent authorities should remain the main point of contact for any personal data disclosure request targeted at ccTLDs to ensure consistency with the overarching data protection legislation.
6) Any “Know-Your-Customer” (KYC) requirements should be in line with the basic data protection principles, such as purpose limitation and data minimisation, enshrined in the EU GDPR.
For more information, please refer to the attached document.
Read full responseResponse to Digital Services Act: deepening the Internal Market and clarifying responsibilities for digital services
30 Mar 2021
CENTR is the association of European country code top-level domain registries (ccTLDs). All EU Member State and EEA country ccTLDs (such as .de, .ch, and .pt) are members of CENTR. CENTR members are at the core of the public internet, safeguarding the stability and security of the internet as we know it today. The majority of European ccTLDs are SMEs or non-profit organisations, providing an internet infrastructure service in the interest of and in close cooperation with their local internet communities.
ccTLDs are responsible for operating and maintaining the technical Domain Name System (DNS) infrastructure for their top-level domain. The DNS is a well-established network protocol at the heart of the internet infrastructure – commonly thought of as the “phone book of the internet”. It provides a navigation function to map user-friendly domain names to numeric IP addresses. ccTLDs only hold information enabling users to navigate the internet but do not store, transmit or enhance any content online.
CENTR welcomes the aims set out by the European Commission in the DSA proposal, such as ensuring the best conditions for the provision of innovative digital services in the internal market, contributing to online safety and the protection of fundamental rights, and setting up a durable governance structure for the effective supervision of providers of intermediary services by public competent authorities. CENTR also welcomes the attention the European Commission gives to the variety of 'providers of intermediary services', their different roles and size in the DSA Proposal.
In order to further strengthen the aims set out by the DSA Proposal and to reinforce the aimed-for provision of innovative digital services without hampering the provision of the core digital infrastructure which is essential for the functioning of the internal market, CENTR members would like to share the following feedback with the European Commission and the co-legislators:
1. CENTR calls for an explicit liability exemption for the technical auxiliary function performed by DNS service providers, in the context of the provision of neutral DNS-related services for the functioning of other intermediary services.
2. CENTR calls for a clarification in the definition of illegal content. The current definition includes the vague wording ‘by its reference to’. This inclusion could affect lawful reporting activities and even hamper the provision of technical auxiliary functions and, as such, could have a crippling effect on the functioning of the internet.
3. CENTR calls for an alignment of the powers given to Digital Services Coordinators with the criminal procedural law in the respective Member States, and an obligation for Digital Services Coordinators to demonstrate due diligence before resorting to exceptional powers under the Proposal.
For more information please refer to the CENTR comment attached.
Read full responseResponse to Strengthening of Europol’s mandate
26 Jun 2020
CENTR is submitting the following feedback on the Inception Impact Assessment on the Europol Regulation that aims to revise the mandate of Europol.
CENTR is the association of European country code top-level domain (ccTLD) registries. All EU Member State and EEA country ccTLDs (such as .de, .no, and .nl) are members of CENTR.
CENTR members represent the industry that is at the core of the public internet, safeguarding the stability and security of the internet as we know it today. The majority of European ccTLDs are SMEs or non-profit organisations, providing an internet infrastructure service in the interest of and in close cooperation with their local internet communities (incl. law enforcement authorities).
CENTR welcomes the goal of increased operational police cooperation as expressed in the Inception Impact Assessment and further operational support Europol could provide for EU law enforcement authorities.
As “private parties” responsible for managing WHOIS database who are directly affected by the planned reform, CENTR members ask the European Commission to take into consideration and adequately assess the impact of the anticipated legislation on ccTLD operators.
In order to support the role of ccTLDs as technical operators in a proportionate and adequate manner, CENTR calls for European Commission to assess the following points in its future legislative work:
• It is necessary to consider the negotiations on the e-Evidence proposal as a priority, before enlarging the scope to a supranational law enforcement authority’s ability to request direct access to personal data from private parties, like ccTLD registries.
• Europol could take on a role of “accreditation authority” of EU law enforcement authorities across the EU in cross-border investigations of serious crime in order to facilitate access to the WHOIS database in time-sensitive cases.
• Any additional direct data collection from private parties by Europol, if deemed to be necessary and proportionate in a democratic society, should be conducted in cooperation with the national law enforcement authorities, under judicial oversight according to the limits of national jurisdiction of the affected Member State.
• It is necessary to make sure that any data access request from a law enforcement authority, including Europol, directed towards private parties, like ccTLDs, should only concern the information that is strictly necessary to achieve legitimate purpose. Blanket, vague and broad data access requests directed towards private parties, like ccTLDs, affect technical operators disproportionately, creating organisational overload and a burden on the operators.
For further information, please refer to the attached document.
Read full responseResponse to Modernisation of the regulations establishing a .eu top level domain name (REFIT)
16 Jul 2018
CENTR is submitting the following comments on the Proposal for a Regulation of the European Parliament and of the Council on the implementation and functioning of the .eu Top Level Domain name and repealing Regulation (EC) No 733/2002 and Commission Regulation (EC) No 874/2004 (COM(2018)231).
CENTR is the association of European country code top-level domain (ccTLD) registries. All the ccTLDs of EU Member States (including .eu) and EEA countries are members of CENTR.
While some EU CENTR members are operated by public sector organisations, many are private companies, independent of government, and do not have sector-specific regulation. CENTR members are aware that EU legislation can influence national regulatory trends (both within and outside the EU), and therefore wishes to raise a few issues which may have an impact on CENTR members (other than the .eu TLD) if adopted by national legislators or regulators.
Areas of concern to CENTR members:
* The definition of the term “Registry” (Article 2(a)) includes the wording “[…] and dissemination of the TLD zone files”. The language is ambiguous, and could be interpreted as compelling the registry to publish its zone file. Most ccTLDs in the CENTR community do not publish their zone files for privacy and cybersecurity reasons. The drafting of the definition should clarify that publication of the zone file is not required.
* Article 4(5) states that “Where a domain name is considered by a court of a Member State to be defamatory, racist or contrary to public policy, it shall be blocked by the Registry upon notification of a court decision and shall be revoked upon notification of a final court decision. The Registry shall block from future registration those names which have been subject to such a court order as long as such order remains valid”. CENTR cautions against possible confusion between blocking a domain that is considered illegal in and of itself vs. blocking a domain because the related website includes illegal content. In the latter case, the permanent blocking of the domain is unnecessary and would prevent the use of the domain for legitimate purposes. In this context it is worth reminding that blocking or deleting a domain name has no impact on the availability of the content.
* CENTR members object to provisions (Recital 16, Article 11(f)) aimed at competent authorities to have access to registry data for the purposes of prevention, detection and prosecution of crime without proper safeguards in place. The current drafting suggests that law enforcement authorities may have unfettered, indiscriminate access to
registration data. Any legal obligation for cooperation with competent authorities should also highlight checks and balances and limitations on such obligations.
* Article 12(1) states that “The Registry shall set up and manage a WHOIS database facility for the purpose of providing accurate and up to date registration information under the .eu TLD”. CENTR members are familiar with the challenges of data accuracy in the Domain Name System (DNS), where data is entered by multiple parties over which the registry has little effective control. While some registries implement before-the-fact and after-the-fact checks for data accuracy, it is not feasible for any domain name registry to commit that data in the WHOIS is 100% accurate or up-to-date. There is a risk that such a provision could set unrealistic expectations and require an unachievable level of accuracy.
Read full responseResponse to Proposal for a Regulation on Enforcement and Compliance in the Single Market for Goods (Goods package)
16 Mar 2018
Please find in attachment the CENTR feedback and comments on the proposal for a Regulation on Enforcement and Compliance in the Single Market for Goods.
Read full response