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Colt Technology Services

Colt

Colt put the power of the digital universe in the hands of our customers wherever, whenever and however they want.

Lobbying Activity

Meeting with Pablo Arias Echeverría (Member of the European Parliament)

4 Dec 2025 · Telecommunication networks and the future Digital Networks Act

Meeting with Kamila Kloc (Director Communications Networks, Content and Technology)

23 Oct 2025 · Review of regulatory framework and upcoming DNA

Meeting with João Vareda (Head of Unit Competition)

3 Sept 2025 · Digital Networks Act (DNA)

Response to Digital Networks Act

10 Jul 2025

5 key messages 1. The only regulatory tool that boosts investment in connectivity is access regulation. 2. The only form of regulation that the DNA cannot remove is wholesale access to the civil infrastructure of the incumbent and, where applicable, physical network of the SMP. 3. The DNA should focus exclusively on the advanced part of the network, and should maintain the wholesale access regulation to the civil infrastructure. 4. The coming Impact Assessment should make a specific analysis to the needs of business customers. 5. The DNA entails in the risk of creating a Europe of 2 speeds. The network can be split into 2 layers: - One is the advanced (service) layer of the connectivity to provide connectivity services. - Below is everything underlying it (the non advanced layer), which are the civil infrastructure and cables constituting the physical network. If we take into consideration incontrovertible facts such as: 1. Incumbent operators control a clear and natural monopoly over the civil infrastructure. 2. It is simply impossible to replicate the civil infrastructure of the incumbents. 3. Innovation occurs primarily in the advanced part of the connectivity and not so much in the underlying civil infrastructure and cables. 4. The Commission estimated that the cost of civil infrastructure represents 60-80% of the entire network investment. Avoiding such costs, investor operators will move investment into the advanced layer of connectivity. 5. Regulated wholesale access to the civil engineering infrastructure is the second most profitable product for incumbent operators, so it represents relevant revenues for them. Then, the DNA should focus exclusively on the advanced part of the network, and should maintain the wholesale access regulation to the civil infrastructure of the incumbent operators and, where applicable, physical network of the incumbents under the SMP. Europe will never have a smooth transition from legacy networks to fibre, 5G/6G and cloud-based infrastructures if the DNA does not address the monopoly over civil engineering infrastructure. Access Regulation is essential for Colt to be able to match the national incumbents geographic footprint. It should not be weakened or removed in the name of simplification or cutting red tape. Doing so, would promote the interests only of the dominant market player. SO, the Commission should not propose to remove the Relevant Markets List, and the SMP model remains essential to providers, investors, and the public interest, and that the DNA should not lead to its weakening or replacement. GIA was NEVER designed as an instrument to address SMP and should not be considered in isolation or out of context. In fact, the GIA explicitly recognises the primacy of regulation aimed at addressing SMP. However: 1. There is no guarantee in the GIA that duct access will be granted, because grounds for refusal are incorporated in the text, and there are no provisions or alternative foreseen mechanisms in the GIA to redress the deeply entrenched market power and its negative consequences (in particular, there is no cost-orientation and no non-discrimination obligation for duct access, there are no provisions to ensure quality, nothing on the need for rapid repair times required by those serving B2B customers, etc.). 2. Relying on the GIAs ambivalent open access provisions is likely to ultimately result, at best, in the provision of Layer-3 bitstream, which does not allow innovation and differentiation, and could be provided on economic terms that fail to promote competition, and consequently fail to also promote meaningful innovation and investment. Ultimately, if regulations are shaped only to the benefit of the incumbents, we will create an imbalanced and inequitable Europe of 2 speeds: One fast speed in those countries (3) where the incumbents having benefitted by the DNA will have an interest for investment, and the 27 remaining countries.
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Meeting with Kamila Kloc (Director Communications Networks, Content and Technology)

31 Jan 2025 · - 2025 Code regulatory overview/DNA. - Security in submarine cable / backbone / metro networks. - Retail B2B electronic communications markets.