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Confindustria Servizi Innovativi e Tecnologici

CSIT

Ci rivolgiamo alle principali istituzioni politiche e amministrative italiane, Governo, Parlamento, Ministeri; alle istituzioni europee per promuovere il ruolo del Settore e rafforzare la percezione del valore aggiunto che deriva dal coinvolgimento attivo dei Servizi innovativi e tecnologi in tutti i settori dell’economia.

Lobbying Activity

Response to European Innovation Act

3 Oct 2025

We hereby submit, in the attached document, our contribution to the European Commissions consultation on the European Innovation Act, with proposals to reduce fragmentation, improve access to finance and technology, enhance Europes capacity to attract and retain talent, and strengthen Europes technological and digital autonomy.
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Response to EU Start-up and Scale-up Strategy

17 Mar 2025

Please find attached the document of Confindustria Innovative and Technological Services and its associated organization, Atlas Transatlantic Association for the Internationalization of Startups
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Response to Rules specifying the obligations laid down in Articles 21(5) and 23(11) of the NIS 2 Directive

19 Jul 2024

Some comments follow on document "Commission Implementing Regulation laying down rules for the application of Directive (EU) 2022/2555 as regards technical and methodological requirements of cybersecurity risk-management measures and further specification of the cases in which an incident is considered to be significant with regard to DNS service providers, TLD name registries, cloud computing service providers, data centre service providers, content delivery network providers, managed service providers, managed security service providers, providers of online market places, of online search engines and of social networking services platforms, and trust service providers." NIS2 Directive is based on a risk-based approach. According NIS2, significant incidents have to be related to significant impacts on critical societal or economic activities. In the received documents, the current definitions of significant incidents are instead based on a prescription-based approach, very different from a risk-based approach. For each kind of significant incident there is a list of criteria that seem have no correlation with impacts on critical societal or economic activities and contribute to raise some doubts. Some of them are: 1) Which is the correlation between the financial loss for the relevant entity in case of an incident and the impacts on critical societal or economic activities ? 2) How will be determined the number of potential impacted customers for each kind of service? Is it correct to establish the same percentage (5%) for different services ? Will there be a central register for this information ? 3) Is the unavailability threshold of 10 minutes applicable to different services (content delivery network providers, managed service providers and managed security service provider, trust service providers) ? Should these thresholds be different and correlated to real societal and economic impacts? 4) Which aspects of customer service level agreement are relevant for considering significant incidents with regards to data centre providers ? Response time , computing power, storage capability, unavailability of the whole data centre, ..? Is the 1-hour unavailability duration valid for all the aspects of customer service level agreement ? In other words, some of the proposed criteria are unclear, not very well defined and, last but not least, with no correlation with impacts on critical societal or economic activities. We should move towards a different process, closer to a risk-based approach. This process has to start with a cybersecurity risk analysis made by relevant entities. The first step of this analysis will be the BIA (Business Impact Analysis) that will define the real impacts (both quantitative and qualitative) on societal and economic activitie. Once evaluated these impacts, each relevant entity , depending on delivered services, will share with competent authorities the criteria to accomplish in order to reduce at minimum the risks of these impacts.
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Meeting with Silvia Bartolini (Cabinet of Vice-President Miguel Arias Cañete)

16 Jun 2015 · Energy Union

Meeting with Silvia Bartolini (Cabinet of Vice-President Miguel Arias Cañete)

26 May 2015 · Energy Union