Lobbying Activity
Response to Digital Networks Act
11 Jul 2025
On the choice of legislative instrument: The provisions of any regulation should be fully harmonized and clear-cut, otherwise any ambiguities in the regulation would have to be adapted in national laws and may result in the same difficult regulatory patchwork as is the cited undesirable effect of a directive. On cross-border provision of services: We support a unified template for registration with the NRA and a unified data reporting template. On the regulatory framework for network access: The Commission proposes a reasonable approach to deregulation, given the success of liberalization efforts and the technological advances of the last several decades. However, the harmonization of wholesale products is highly undesirable. These would either stifle competition, or stay on paper only. NRAs are best placed to determine the nature of the safeguard access product that best fits the identified market failure, within a commonly defined framework. On copper switch-off: Technologies providing comparable or inferior services to copper in terms of attainable speeds, latency or service availability (such as free band WiFi, LTE/5G fixed wireless access, broadband over satellite) are quite viable in many markets and directly competing with fibre offerings. Switching off only copper in order to provide more headspace for fibre investments is misguided. Instead, direct measures are needed to incentivize roll-out where fibre is not yet available. If cost reduction measures are insufficient, state aid should be considered to address this. On Open internet rules: The open internet rules have been put in place ten years ago under different technological and geopolitical conditions. A simple clarification concerning innovative services by way of a soft law will not sufficiently address these changes and future proof the regulation. The efficient use of available bandwidth for the provision of various services, including ones in public interest, over an internet access service, is a more general issue to be addressed. Any changes should be encompassed into the legislation directly.
Read full responseResponse to Review of the Broadband Cost Reduction Directive (Directive 2014/61/EU)
20 Apr 2023
CETIN is providing comments on the GIA proposal as per the attached file.
Read full response