european competitive telecommunications association
ecta
The European Competitive Telecommunications Association represents competitive communications providers and advocates for market liberalization in EU electronic communications.
Lobbying Activity
Ecta urges EU to prioritize competition in Digital Decade review
19 Dec 2025
Message — The association requests that the Commission maintain pro-competitive regulations and introduce new competition indicators. They advocate for tackling digital skills gaps and removing administrative barriers to network deployment. New metrics should monitor the dominance of non-European hyperscalers in the cloud market.12
Meeting with João Cotrim De Figueiredo (Member of the European Parliament)
18 Nov 2025 · Digital Networks Act
Meeting with Michele Piergiovanni (Cabinet of President Ursula von der Leyen)
12 Nov 2025 · To discuss some important (telecom) files
Response to Digital Networks Act
10 Jul 2025
ecta, the european competitive telecommunications association, welcomes the opportunity to provide feedback on the European Commissions Call for Evidence on the Digital Networks Act. ecta places Europes global competitiveness at the forefront of its concerns. Recognizing the critical role of diverse players in the telecom sector, ecta advocates for an inclusive electronic communications industry that fosters innovation and empowers the entire European economy. EU telecom regulation has, for over three decades, delivered positive outcomes, affordable prices and good quality of networks and services, sustained investment, and continuous innovation. While there are several positive proposals in the Call for Evidence regarding for instance simplification, spectrum and universal service, the section on access regulation and related proposals have the potential to destroy good work done and positive outcomes realized for more than three decades. The access-related policy proposals that the Commission puts forward in the Call for Evidence will structurally and irreversibly negatively impact the future of the EU Single Market of which the telecommunications sector is a fundamental and strategic component. ecta notes that the Call for Evidence fails to address the lack of competition in B2B markets and the advancement of the internal market for B2B. This is regrettable given that most of the technology evolution considered in the Commissions 2024 White Paper concerns the B2B markets. Clearly, the B2B market share of incumbents is at least 50% in the majority of Member States and reaches more than 60-70% in many Member States. ecta kindly requests the Commission, during the drafting of DNA legislative proposal, to place a greater focus in the future on the B2B markets in order to promote competition and increase Europes global competitiveness. Operators need a conjunction of several wholesale access products (civil engineering infrastructure, passive fibre access and active access). Only the sum of all wholesale access products and not isolated wholesale inputs, will allow operators to cover all the needs of consumers, SMEs, large business customers and the public sector. Thus, a single pan-EU wholesale access product neither covers the minimum nor the local needs of customers. In consequence, SMP-based regulation and the existing list of Relevant Markets remain indispensable to ensure that suitable wholesale products are available. The Call for Evidence is the last step of the public consultations proposed by the Commission before the publication of the legislative proposal for a Digital Networks Act. In this sense, it is the last institutional opportunity to make a U turn on the proposals that de-prioritise access regulation and related proposals, which instead of being beneficial, are harmful for the EUs digital competitiveness. ecta in light of the above expressed consideration and concerns, kindly invites the Commission to: i) Abandon its proposed changes to access regulation under the DNA, ii) Preserve the current ex-ante SMP regulatory framework under the EECC, without dilution or reinterpretation by maintaining, inter alia, the current relevant markets recommendation and the two markets listed currently in the annex, and not prioritizing symmetric regulation over proper economic analysis of competition by independent national regulatory authorities, iii) In progressing with all the other proposals including those related to simplification, spectrum and for access regulation proposals, uphold the principles of legal clarity, proportionality, and competition, which have served Europe and its citizens so well, iv) Submit the draft text of the Digital Networks Act to public consultation before presenting it to the European Parliament and the Council, in line with the principles of Better Regulation and transparency.
Read full responseMeeting with Lucrezia Busa (Head of Unit Communications Networks, Content and Technology) and Telefonica, S.A. and
15 Apr 2025 · Implementation details of a possible inclusion of Ukraine into the EU Roam Like at Home (the ‘EU RLAH’) area
Meeting with Michał Kobosko (Member of the European Parliament, Shadow rapporteur)
17 Mar 2025 · Discuss Europe’s digital sovereignty
Meeting with Teresa Ribera Rodríguez (Executive Vice-President) and
15 Jan 2025 · To hear interest representatives’ view on EU competition and telecom policy, and perspectives on clean, just, and competitive transition policies.
Response to How to master Europe’s digital infrastructure needs?
24 Jun 2024
ecta, the european competitive telecommunications association - representing those alternative operators who, relying on the pro-competitive EU legal framework that has created a free market for electronic communications, have made massive investments in network and technology to give EU citizens, businesses and public administrations quality and choice at affordable prices - welcomes the opportunity to provide feedback on the European Commissions consultation on the White Paper. Europe's global competitiveness is at the heart of ecta's concerns. The diversity of players in telecoms is essential. An inclusive electronic communications sector embracing a variety of participants, both large and small, and nurturing a diverse array of products and services, is essential to empower the entire European economy and unleash its innovative potential in the digital realm. For the past three decades, EU electronic communications regulation has delivered a unique European success story. Promotion of competitive markets, combined with effective ex-ante regulatory measures, are driving investments, positive innovation, and consumer benefits in telecoms and will remain so looking forward. Europe excels with respect to its global peers when it comes to combining the deployment of gigabit networks, their adoption by consumers and professional users, as well as affordability and inclusion. Europe, in addition, is well on track to meet the EU 2030 Digital Decade Objectives. ecta acknowledges that the Commissions WP is preparing the groundwork for reviewing the EU legal framework in a way intended to remove any obstacles that are likely to hamper the achievement of those Objectives. ecta therefore responds to the Commissions invitation to provide feedback through its contribution attached. The WPs policy proposals will structurally and irreversibly impact the future of the European single market, of which the telecommunications sector is a fundamental and strategic component to guarantee EUs global competitiveness. Thus, ecta considers important to rebut incorrect assumptions on the alleged: (1) poor state of the European electronic communications markets, and (2) the need for a change in access policy by foreseeing two scenarios that amount to dismantling the EU wholesale access regulatory framework. The assumptions which inform some proposed scenarios in the WP result in policy proposals based on a misdiagnosis of the issues. The EU regulatory framework is like a living organism, it needs to adapt to the evolving market in terms of technologies, use cases and business models. But any need for such adaptation must be supported by incontrovertible empirical evidence. Nonetheless, ecta considers that some of the scenarios included in the WP could help to overcome issues hampering the operators investments in VHCN deployment, and the uptake by European citizens, businesses and public administrations. ecta makes detailed proposals in the attached response. These include: - measures aimed at a more harmonized management of the spectrum to unleash the full potential of 5G deployment and further build on the internal market for telecoms, as suggested by the Commissions WP. - proposals to improve a timely mass adoption of VHCNs by consumers and businesses as the real positive game-changer for upgrading the financial performance of electronic communications operators. - pro-competitive solutions to improve EUs global competitiveness through timely adoption of new technologies such as cloud and edge computing, both upstream and downstream of telecoms markets, accompanied by increased sovereignty of the European providers. Finaly, ecta appreciates the sustainability proposals and makes additional recommendations.
Read full responseResponse to Update of standards for the 112-based eCall in-vehicle systems
21 Nov 2023
ecta, the european competitive telecommunications association, welcomes the opportunity to provide feedback on the European Commissions initiative launched on 27 October 2023 on a COMMISSION DELEGATED REGULATION (EU) amending Regulation (EU) 2015/758 of the European Parliament and of the Council as Regards the Standards Relating to eCall. ecta appreciates that the Commission consults on the full text of the Draft Delegated Regulation and gives the opportunity to all parties that will be impacted to express their views. The full ecta response to the public consultation can be found in the attachment.
Read full responseResponse to Revision of the specifications for the harmonised provision for an interoperable EU-wide eCall
20 Oct 2023
ecta, the european competitive telecommunications association, welcomes the opportunity to provide feedback on the European Commissions initiative launched on 22 September 2023 on a COMMISSION DELEGATED REGULATION (EU) amending Delegated Regulation (EU) No 305/2013 supplementing Directive 2010/40/EU with regard to the harmonised provision for an interoperable EU-wide eCall'. ecta specifies that the full ecta response to the public consultation can be found in the attachment.
Read full responseResponse to Review of the Broadband Cost Reduction Directive (Directive 2014/61/EU)
12 May 2023
ecta, the european competitive telecommunications association, welcomes the opportunity to provide feedback on the European Commissions public consultation launched on 23 February 2023 on the Proposal of a Regulation of the European Parliament and of the Council on measures to reduce the cost of deploying gigabit electronic communications networks and repealing Directive 2014/61/EU (hereinafter The Draft Act). ecta deems measures at the European Union level necessary to facilitate and incentivize the roll-out of VHCNs, by all types of operators, in a pro-competitive manner. The review of the Broadband Cost Reduction Directive (hereinafter BCRD) is one piece of the puzzle to such purpose. In many Member States, the BCRD has not had a real added value in terms of incentivizing roll-out, due to different and sometimes inappropriate transposition of the BCRD in the Member States. The provisions have not always been properly enforced and the effects of the BCRD have been neutralized in some cases by the various local or regional rules that have either extended or made uncertain the times to obtain access or permits to deploy or install networks. ecta welcomes the Commissions proposal to replace the BCRD with a Regulation which, once adopted, will apply without any need of transposition and without being subject to any amendments by the Member States. The Draft Act clearly aims at reducing the Very High Capacity Network (hereafter VHCN) deployment cost for the operators that deploy or intend to deploy VHCN, to a greater extent vis a vis the BCRD, which is an objective that ecta welcomes. However, ecta notes with concern that another very relevant piece of the puzzle, the draft Recommendation on the regulatory promotion of Gigabit connectivity (put forward by the Commission on 23 February 2023), if adopted without significant substantial review, puts at serious risk the beneficial impact that Draft Act would have on the sector. The negative outcomes in terms of significant competitive flaws (pushing inappropriately towards deregulation of the dominant operators; enabling wholesale price increases by dominant operators) that will derive from the adoption of the draft Recommendation would neutralize the potentially positive impact of the draft Gigabit Infrastructure Act. ecta considers that improvements to the aspects of the regulatory regime which are specifically addressed by the proposed Gigabit Infrastructure Act are more than ever timely, necessary and appropriate, and appreciates that numerous suggestions and ideas put forward in previous ecta contributions have been included in the Draft Act. These include inter alia those related to the need for improving the BCRD in relation to permit granting procedures, national consistency on rules governing the conditions and procedures applicable for granting permits, including rights of way, mandating the Commission to specify the categories of deployments that will be exempted from permits, introducing measures aiming to ensure permits, including rights of way, applications are dealt with within the legal deadlines, e.g. a shorter period to consider the application complete, tacit approval or compensation for damages caused by non-compliance with the deadlines and making it more consistent with the EECC. ecta in its attached response, puts forward precise amendment proposals to the articles, aimed at further improving the text of the draft Gigabit Infrastructure Act. Those proposals are submitted for each provision in the form of an amendment proposal preceded by a fully-fledged motivation justifying them. ecta and its members look forward to continuing to constructively contribute towards reaching the final text of the Gigabit Infrastructure Act, also during the currently ongoing co-legislation procedure.
Read full responseResponse to Key performance indicators for the Digital Decade policy programme 2030
13 Mar 2023
ecta, the european competitive telecommunications association, welcomes the opportunity to provide feedback on the European Commissions initiative launched on 13 February 2023 on the Draft Commission Implementing Decision setting out key performance indicators to measure the progress towards the digital targets established by Article 4(1) of decision (EU) 2022/2481 of the European Parliament and of the Council. ecta considers the Commissions initiative necessary and appropriate in order to ensure that effective and appropriate KPIs are defined to measure progress towards the objectives set out. ecta is concerned that the proposed KPIs, in particular those related to connectivity and therefore to electronic communications markets, do not include any direct or indirect reference to the competitiveness of markets. Consequently, it is not possible for stakeholders, including the Commission and Member States, to have a swift tracking of the competitive situation in the different Member States when it comes to monitoring of progress towards each digital target. Therefore, ecta, in relation to the connectivity targets (KPI on gigabit connectivity and KPI on 5G coverage) respectfully asks for the introduction of additional KPIs to allow a straightforward tracking of competition levels in progressing the connectivity targets in each Member State. In relation to the connectivity targets proposed by the Commission, ecta submits amendment proposals to the KPI on Gigabit connectivity and to the KPI on 5G Coverage. In particular, in relation to the Gigabit connectivity KPI, ecta respectfully invites the Commission to extend the draft Implementing Decision to: i) refer directly to the VHC definition criteria and thresholds provided by the BEREC Guidelines and to update the KPI as soon as network types meet those criteria and thresholds. ii) refer explicitly for the households covered definition to the premises passed definition already provided by the Commission in the reviewed Guidelines on State aid for broadband networks. In relation to the 5G coverage KPI, ecta respectfully invites the Commission to replace the proposed definition with the one proposed by ecta which refers not only to a single 5G frequency band but to the 5G networks both on a standalone and not standalone basis, and on the use of various frequency bands together with 5G pioneer bands. The full ecta response to the public consultation can be found in the attachment.
Read full responseResponse to Improving access to emergency services through the single European emergency number ‘112’
12 Sept 2022
ecta, the european competitive telecommunications association, welcomes the opportunity to provide feedback on the European Commission’s initiative launched on 8 August 2022 on a “COMMISSION DELEGATED REGULATION (EU) supplementing Directive (EU) 2018/1972 of the European Parliament and of the Council with measures to ensure effective access to emergency services through emergency communications to the single European emergency number '112'” (hereinafter “The Proposed Delegated Regulation” or “The Proposed Act”).
ecta highly appreciates that the Commission consults on the draft text of the proposed Delegated Regulation and gives the opportunity to all parties that will be immediately impacted by such Act also by bearing significant adaptation, implementation and maintenance costs to comply with the Act’s provisions.
ecta agrees with both the spirit and the content of the Commission’s proposed Delegated Regulation.
In particular, ecta agrees with and appreciates most aspects of the Proposed Delegated Regulation because it provides mostly common sense, and principle-based provisions, and acknowledges the technical feasibility issues, by: i) Adequately defining “effective emergency communication”, “contextual information”. ii)Indicating that by contextual information it is intended either an emergency communication by the end-user or derived and transmitted automatically from the device of the end-user or the relevant network, by affirming that such communication can be transmitted automatically from the relevant network or from the device of the end user (i.e., according to the technical feasibility). iii) Requiring to the Member States to collaborate with the Commission for mobile apps, to jointly identify common interoperability requirements, which would allow routing of app-based emergency communications to the appropriate PSAPs (which is fully in line with ecta proposals to the e-Mercury consortium stakeholder consultation as specified in ecta full response).
However, ecta would like to underline respectfully that there are several issues in the text, as indicated extensively in below paragraphs, that are not defined (i. lack of recommendations for centralization of Public Safety Answering Points; ii. lack of indications and guidance on the impact of 2G/3G switch-off and move to VoLTE/VoNR on eCall) and not adequately clarified (iii. requirement on the contextual information transmission means -network based and end-user device based; iv. Declination of transparency and reliability criteria for cloud-based operators/ NI-ICS providers).
Considering that the Draft Delegated Regulation “shall enter into force on the third day following that of its publication in the Official Journal of the European Union” and “Regulation shall be binding in its entirety and directly applicable in all Member States” it is very important that the final text integrates and clarifies all lacking issues in order to ensure full legal certainty to the parties that will be impacted.
ecta, in its enclosed response, focuses on the Proposed Delegated Regulation and its Explanatory Memorandum related to the following selected items which have direct impact on ecta members’ business but are either not expressed clearly or not included in the draft text and proposes some integrations: i) Centralization of Public Safety Answering Points (hereinafter “PSAPs”) ii) 2G/3G switch-off and move to VoLTE/VoNR and impact on eCall iii) Clarification about the contextual information transmission means (network based and end-user device based) iv) Declination of transparency and reliability criteria for cloud-based operators/ Number Independent Interpersonal Communications Service providers (hereinafter “NI-ICS providers”).
ecta finally specifies that the full ecta response to the public consultation can be found in the attachment.
Read full responseMeeting with Margrethe Vestager (Executive Vice-President) and
7 Sept 2022 · Digital policies.
Response to The Union Position for the World Radiocommunication Conference 2023
26 Jul 2022
ecta, the european competitive telecommunications association, welcomes the opportunity to provide feedback on the European Commission’s initiative to establish a common EU position to be negotiated by Member States on behalf of the EU at the World Radiocommunication Conference 2023.
ecta acknowledges that the RSPG opened a public consultation on the Draft RSPG Opinion on the ITU-R World Radiocommunication Conference 2023. Once the RSPG Draft Opinion will be finalized, it will be sent by the RSPG to the Commission and will be an important element for the Commission to form the EU position to be negotiated by Member States on behalf of the EU at the World Radiocommunication Conference 2023.
ecta therefore responds to the Commission’s invitation to provide feedback by means of its contribution prepared for the RSPG consultation. This is provided in attachment.
Briefly stated, the ecta positions are the following:
- for WRC-23 Agenda Item 1.2 (IMT mid-band identifications) ecta endorses option 1 which consists in identifying 6 425-7 125 MHz for IMT with appropriate conditions as from the RSPG proposal also clarifying, for the avoidance of doubt, that the allocation to IMT of the band includes both mobile and fixed wireless access uses. On this matter, ecta would like to underline that Fixed Service (FS) is a national matter and should be addressed on a case-by-case basis due to different usage across Europe. ecta underlines that a protection and allocation toolbox of solutions can help administrations address their specific circumstances.
- for WRC-23 Agenda Item 1.3 (MS 3 600-3 800 MHz) ecta supports the draft RSPG proposal to upgrade the 3 600 MHz - 3 800 MHz band and the conditions proposed. However, that RSPG final Opinion should specify that the upgraded allocation conditions should in no way amend negatively the conditions already established for the primary allocation in Europe.
- for WRC-23 Agenda Item 1.5 (UHF Review) ecta endorses option 2, by recommending to the Commission to propose an EU position supporting a co-primary mobile allocation of the 470-694 MHz band in Region 1 and IMT identification of the whole band, or parts thereof, for the countries of Region 1 wishing to do so.
- for WRC-23 Agenda Item 1.16 (Non-GSO ESIM Ka-band) ecta recommends to the European Commission that if a new international regulatory framework allowing non-GSO ESIMs to use, among others, the 27.5-29.1 GHz band is established by WRC-23 under AI 1.16, the technical and operational conditions under such a framework should ensure an adequate protection and the continued operation of FS systems which are operating on a co-primary basis within the band.
- for agenda Item on the Studies in relation with RR Article 21, post allocation of 26 GHz to 5G, ecta underlines the need that in studying the applicability and notification of Art.21.5 to IMT stations using an antenna with an array of active elements in the 26 GHz band, the following factors are taken into due account: i) the power delivered to a transmitter should be interpreted as “the conducted power from a transmitter” to the antenna, coherently with the letter of the Article; ii) there is no bandwidth reference in RR Article 21.5; any definition of a reference bandwidth should be supported by specific studies concerning the coexistence with satellite systems. In addition, any solution should not impact the protection of satellite reception and at the same time should not impose too constraining restrictions as those may impair the development of 5G/IMT.
-In relation to Agenda Item 10 regarding the recommendations on next WRC-27 agenda items, ecta supports the adoption of WRC-23 resolutions that would invite the ITU-R to conduct and complete studies of the technical, operational and regulatory issues pertaining to the possible use of IMT systems in: i) the essential frequency range 7.125-24 GHz, and, ii) the complementary sub-THz range 92-300 GHz.
Read full responseResponse to Policy Program - Digital Decade Compass
10 Dec 2021
ecta, the european competitive telecommunications association, welcomes the opportunity to provide feedback on the European Commission’s initiative launched on 16 September 2021 on a proposal for a Decision of the European Parliament and of the Council establishing the 2030 Policy Programme “Path to the Digital Decade” (hereinafter “The Proposed Decision”). ecta considers the Commission’s initiative necessary and appropriate.
ecta agrees with the objectives posed for european digitalization and Commission’s findings on their progress. ecta considers that to reach successfully the 2030 digitalisation objectives, the measures already in place, such as DESI reporting mechanism, should be integrated with a common coordination mechanism.
ecta deems the Policy Programme “Path to the Digital Decade” and related monitoring and cooperation mechanism one of the most relevant actions put forward by the Commission as the programme and its outcome will significantly impact the future of European businesses, consumers, economy and social spheres.
ecta firstly notes that the proposal does not contain any reference to competition, its preservation and improvement in the implementation of the policy programme.
ecta recalls that competition is the main driver of investment and of innovation. As such, it has been at the very heart of the Union’s industrial policy. ecta therefore respectfully invites the Commission to explicitly acknowledge in the “Path to the Digital Decade” policy programme the importance of the competition.
Given the utmost importance of the competition as the main driver of investment and innovation, ecta respectfully asks the Commission to make sure that the relevant competitiveness KPIs are introduced also in the new set of KPIs mentioned by the art.5(1) in a way to allow swiftly the tracking of the competitive situation in the different member states when it comes to monitoring of the progress of each digital target.
With respect to the measures, actions and recommendations that the European Commission would provide the Member States in order to reach the targets by filling the gaps and flaws, provided in the art. 6(30), 9(1), 9(4) and 9(5) of the Proposed Decision by the European Commission,
ecta respectfully requests the Commission to avoid that such requirements interfere directly or indirectly with the ex-ante regulation and alter the regulatory provisions applied in such member state.
ecta highly appreciates the specific focus in the Proposed Decision (recitals (21) and (22)) on the timely availability of and access to radio spectrum for reaching the targets: the predictability, certainty and the flexibility (based on the evolving needs) for the planning of milestones for spectrum availability with inclusion in the member states reporting of policies and measures adopted to use radio spectrum for existing users and prospective investors and operators, are core requirements.
In this regard, ecta notes that in addition to the timely availability of and access to radio spectrum, also the guarantee of pro-competitive spectrum assignment procedures is key in reaching the targets.
To this end, the art. 35 of EECC already foresees a peer review process between the RSPG and NRAs. ecta believes that this relevant voluntary tool should become more transparent to ensure by the governance tools pro-competitive assignment procedures in EU.
ecta finally specifies that the full ecta response to the public consultation can be found in the attachment and welcomes the consultation activities announced by the initiative.
ecta and its members look forward to continuing to constructively contribute to the final version of the Proposed Decision of the Commission as specified also by the art. 11 of the Proposed Decision regarding cooperation between the Commission and private stakeholders for the purposes of the implementation of this decision.
Read full responseResponse to Improving access to emergency services through the single European emergency number ‘112’
29 Oct 2021
ecta, the European competitive telecommunications association, welcomes the opportunity to provide feedback on the European Commission’s initiative launched on 1 October 2021 on a roadmap on emergency communications – improving access through the single European emergency number ‘112’.
ecta considers necessary and appropriate the Commission’s initiative to ensure effective access to emergency services in the Union.
ecta believes that the achievement of the three objectives indicated in the initiative (the information on caller location, the access for disabled people, directing communications to the most appropriate public safety answering point) is significantly impacted by technology. Art.(109) of the EECC obliges Member States to ensure access to emergency services for all end-users by routing to the most appropriate PSAP and by providing the caller location information. However, in line with the technological neutrality, it does not indicate the specific technical solution, architectures or technologies. This can create coordination issues in a context of technological migration such as the current one from circuit switched technology to IP/based communication technologies.
ecta agrees on the need to ensure coordination, including by means of a harmonized set of protocols and standards that would guarantee the compatibility, interoperability, reliability and continuity of the emergency communications across the EU through a delegated act.
The Commission poses many extremely ambitious objectives for such delegated act, including the indication of most appropriate standards to provide a similar level of quality of caller location, accessibility and routing to the most appropriate PSAP across the EU, even in roaming, and states that it could introduce a list of common minimum requirements for equivalent access to emergency services for disabled end-users, coherent implementation of accurate caller location, including the obligation to adopt a next generation emergency communications architecture. The act could also mandate the implementation of Pan-European Mobile emergency App specifications to enable a single platform communication for roaming end-users. ecta therefore agrees with the proposed support study that would aim at assessing the technical feasibility of the solutions, identifying possible improvements, assessing the technical and financial impact on the stakeholders and the set-up of various PSAP systems. ecta notes that the principle of proportionality, one of the main pillars of the EECC, should definitely guide all the administrative process regarding the preparation and introduction of the delegated act. In particular, the recital (91) states that "Any Commission decision to ensure the harmonised application of this Directive should be limited to regulatory principles, approaches and methodologies. For the avoidance of doubt, it should not prescribe any detail normally required to reflect national circumstances, and it should not prohibit alternative approaches which can reasonably be expected to have equivalent effect. Such a decision should be proportionate".
Since the delegated act aims at making sure the implementation of art. (109) of EECC, ecta respectfully calls on the Commission to ensure that any measures included in such act, are first subjected to a full cost-benefit analysis. The telecommunications operators who may have to bear such costs and are the best suited to assess the technical, operational, financial costs related to the change/upgrade of those elements should be actively involved in the process.
ecta finally specifies that the full ecta response to the public consultation can be found in the attachment and welcomes the consultation activities announced by the initiative.
Read full responseMeeting with Margrethe Vestager (Executive Vice-President)
11 Oct 2021 · EUs digital ambition for 2030
Response to Revision of the Broadband Guidelines
16 Sept 2021
ecta, the european competitive telecommunications association, welcomes the opportunity to comment on the roadmap for the revision of State aid guidelines on Broadband Networks.
ecta represents those alternative operators who, relying on the pro-competitive EU legal framework that has created a free market for electronic communications, have helped overcome national monopolies to give EU citizens, businesses and public administrations quality and choice at affordable prices. ecta represents at large those operators who are driving the development of an accessible Gigabit society, who represent significant investments in fixed, mobile and fixed wireless access networks that qualify as Very High Capacity Networks and who demonstrate unique innovation capabilities.
ecta welcomes the Commission’s initiative to revise the State aid rules for broadband infrastructure deployment. In view both of technological progress as well the objectives set in the European Gigabit Society and the 2030 Digital Compass, this is both a necessary and appropriate initiative.
ecta refers to its response to the public consultation on the evaluation of the State aid rules for the deployment of broadband networks, dated 5 January 2021 and provides its response to the Roadmap consultation in the attached file.
ecta and its members look forward to the launch of the public consultation on the basis of a draft of the revised guidelines and a stakeholders meeting. ecta will provide input on those occasions.
Read full responseResponse to Declaration of Digital Principles
9 Jun 2021
1. ecta, the european competitive telecommunications association, welcomes the opportunity to comment on the Roadmap for the Declaration of Digital Principles – the ‘European way’ for the digital society.
2. ecta represents those alternative operators who, relying on the pro-competitive EU legal framework that has created a free market for electronic communications, have helped overcome national monopolies to give EU citizens, businesses and public administrations quality and choice at affordable prices. ecta represents at large those operators who are driving the development of an accessible Gigabit society, who represent significant investments in fixed, mobile and fixed wireless access networks that qualify as Very High Capacity Networks and who demonstrate unique innovation capabilities.
3. ecta welcomes the European Commission’s proposal for a set of digital principles that should shape Europe’s digital society in the European way in the form of a joint interinstitutional solemn declaration of the European Commission, the European Parliament and the Council.
4. ecta agrees that digital principles should be understood as essential concepts based on common European values serving as the foundation for a human-centred, secure and open digital environment.
5. ecta suggests considering two supplementary principles, in addition to the examples mentioned in the Digital Compass Communication:
i. Empowering end-users to reduce their carbon footprint in the online space;
ii. Transparency of algorithms of dominant digital platforms.
6. ecta welcomes the upcoming broad consultation process with all relevant stakeholders. Transparency and stakeholder consultation are not only a pillar of European democracy but are also essential to ensure people's trust and buy-in to the European project. To this end, we call on the European Commission to improve its consultation practices as, for several recent files (e.g. the Recommendation on Relevant Markets Susceptible to Ex Ante Regulation), the European Commission failed to properly consult and no consultations on draft texts were organised. This does not constitute, in ecta’s view, good practice and is not in line with the objectives of better regulation.
7. Representing competitive leaders in closing the digital infrastructure divide in Europe, ecta, with its members, looks forward to providing targeted input to the relevant consultations and will be equally pleased to provide for bespoke participation to the Commission's upcoming events in this context.
Read full response4 Apr 2021
ecta, the european competitive telecommunications association, welcomes the opportunity to comment on the Roadmap for the Modification of the General Block Exemption Regulation for the Green Deal and the Industrial and Digital Strategies.
ecta represents those alternative operators who, relying on the pro-competitive EU legal framework that has created a free market for electronic communications, have helped overcome national monopolies to give EU citizens, businesses and public administrations quality and choice at affordable prices. ecta represents at large those operators who are driving the development of an accessible Gigabit society, who represent significant investments in fixed, mobile and fixed wireless access networks that qualify as Very High Capacity Networks and who demonstrate unique innovation capabilities.
ecta welcomes the objective to amend the GBER, in parallel to the revision of the respective Guidelines, to ensure that the European Green Deal as well as the Industrial and Digital Strategies, including the ambitions for secure, performant and sustainable digital infrastructures are taken into account. ecta believes that one of the most important challenges for the review will be to ensure that with the adoption of amendments it can be guaranteed that funding initiatives, review decisions and regulation of those markets all act together to provide a sustainable basis for competitive, inclusive and affordable connectivity solutions in the EU.
ecta considers that State aid policy in the field of digital infrastructure deployment needs to incorporate a set of foundational cornerstones for successful policy design and market impact, as follows:
• Ensuring focus on future-proof network deployments;
• Excluding aid being awarded in areas where such deployments have already or are imminently likely to take place;
• Avoiding overbuild of recently deployed networks with state resources, especially where these deployments themselves have been funded with state resources;
• Contributing to a procedural framework for the granting of aid that is predictable, efficient and open to participation by all operators, including small and medium-sized enterprises;
• Enabling private initiative, including in cases where despite aid being available, deployment is not taking place;
• Achieving the maximum degree of coherence between sectoral regulation and State aid law and practice.
• Focus aid on passive network elements.
• Obligation for aided undertakings to provide access to civil engineering assets as well as passive access for the lifetime of the asset.
• Reporting obligations on use of aid.
Considering examples of public authorities opting to conclude agreements on infrastructure deployment with incumbent operators despite having received invitations by competitive operators to collaborate on deployment in the same areas concerned by these agreements, ecta is convinced that open, competitive selection must be guaranteed.
ecta further refers to its responses to the following public consultations:
- ecta response to the PC on the evaluation of the State aid rules for the deployment of broadband networks, 5 Jan 2021;
- ecta response to EC PC on the Targeted Review of the General Block Exemption Regulation, 27 Sep 2019
ecta takes note of the upcoming public stakeholder consultation on the draft text of the regulation. Transparency and stakeholder consultation are not only a pillar of European democracy but are also essential to ensure people's trust and buy-in to the European project. To this end, we call on the European Commission to improve it practices as, for several recent files (e.g. the Recommendation on Relevant Markets), the European Commission failed to properly consult and no consultations on draft texts were organised. This does not constitute, in ecta’s view, good practices and is not in line with the objectives of better regulation.
ecta looks forward to providing input to the relevant consultations.
Read full responseResponse to Europe’s digital decade: 2030 digital targets
9 Mar 2021
ecta, the european competitive telecommunications association, welcomes the opportunity to comment on the European Commission’s Roadmap Communication on Europe’s digital decade: 2030 digital targets.
ecta represents those alternative operators who, relying on the pro-competitive EU legal framework that has created a free market for electronic communications, have helped overcome national monopolies to give EU citizens, businesses and public administrations quality and choice at affordable prices. ecta represents at large those operators who are driving the development of an accessible Gigabit society, who represent significant investments in VHC networks and who demonstrate unique innovation capabilities.
ecta agrees with the European Commission that Europe’s future is determined by the successful achievement of the twin digital and green transitions. ecta further shares the view that digital technologies are critical to recover from the COVID-19 crisis. No-one can be left behind, and digital technologies are essential to achieve the EU’s overarching sustainability goals.
ecta is pleased to provide it full feedback on: Europe’s digital decade – 2030 digital targets in the attached file.
Representing competitive leaders in closing the digital infrastructure divide in Europe, ecta, with its members, looks forward to providing its input to the relevant consultations, public and targeted, to be launched during the first semester of 2021. ecta will be equally pleased to provide bespoke participation to the Commission's upcoming events in this context.
Read full responseResponse to Voice call termination rates in the EU (Eurorates)
22 Sept 2020
Please find attached herewith the response of the european competitive telecommunications association (ecta) to the consultation on the draft delegated act to be adopted pursuant to art. 75(1) EECC.
Thank you for your consideration.
Read full responseResponse to Evaluation of State Aid rules for broadband infrastructure deployment
11 Aug 2020
ecta, the european competitive telecommunications association, welcomes the Commission’s initiative to evaluate the State aid rules for broadband infrastructure deployment. In view both of Europe’s broadband needs as well as the transition to a new set of rules for electronic communications in the EU, this is both a necessary and appropriate initiative.
ecta further shares the continued commitment to maintain technology neutral guidance on the application of State aid rules to the deployment of broadband infrastructure. Not technology choice, but deployment and performance improvements relative to the status quo must be the criteria that decide whether aid schemes can stand up to EU competition scrutiny.
Such an approach matches the regulatory philosophy underpinning the EU’s unique set of rules for the promotion of competition in electronic communications markets. ecta believes that one of the most important challenges for the review will be to ensure that with the adoption of new guidance it can be guaranteed that funding initiatives, review decisions and regulation of those markets all act together to provide a sustainable basis for competitive, inclusive and affordable connectivity solutions in the EU.
Especially coherence should therefore be thoroughly assessed in both backward- and forward-looking perspectives. Without close examination of the interaction between relevant instruments from outside and within the State aid context, ecta believes that the evaluation results will be unable to provide a sound foundation for designing future policy, including in the formulation of appropriate objectives.
Both the new European Electronic Communications Code and the Broadband Cost Reduction Directive seek to contribute to the establishment of infrastructure-based competition. The effects of these instruments should be considered in reviewing the guidance for the grant of State aid to further infrastructure deployments, including how rule changes have thus far shaped market participants’ decisions whether or not to deploy.
In the interest of ensuring targeted interventions going forward, the evaluation of the current State aid regime should also assess whether existing guidance and exemptions have resulted in effective prioritisation of spending, timely disbursement and sustainable deployments. ecta agrees that particular attention in this context should be had to the avoidance of local monopolies and attendant customer lock-in as well as the effective promotion of service competition.
As a last element to be highlighted at this initial stage of the evaluation process, ecta also encourages enquiry into the institutional settings for the administration, including the review, of State aid schemes for broadband. This should notably have regard to the effective participation by and protection of the interests of smaller market participants, taking into account the need for appropriate procedural frameworks.
Representing competitive leaders in closing the digital infrastructure divide in Europe, ecta, with its members, looks forward to providing targeted input the to relevant consultations, public and targeted, to be launched this autumn and will be equally pleased to provide for bespoke participation to the Commission's upcoming events in this context.
Read full responseResponse to Review of the Broadband Cost Reduction Directive (Directive 2014/61/EU)
17 Jul 2020
ecta welcomes the Commission’s initiative to review the Broadband Cost Reduction Directive (BCRD). This initiative comes at a key moment in the evolution of EU communications infrastructure to a new stage.
ecta shares the vision of moving Europe to an era of very high capacity networks, as foreseen under the European Electronic Communications Code. To achieve this, it is critical that measures under the Code and the functioning of the BCRD evolve in a coordinated manner.
ecta Is concerned that such coordination has been lacking and that virtually all Member States failed to ensure timely implementation of the directive. Furthermore, there has been neither adequate, nor coherent reporting on its actual functioning and benefits. Nevertheless, certain Member States have relied on the directive to remove access obligations relating to physical infrastructure controlled by undertakings with significant market power (SMP).
It is essential that a future-proof EU level framework for building the networks on which the Gigabit society can rely, is consistent, mutually reinforcing and effective. Only in this manner will it be possible for such a framework to aspire to successfully address further challenges, such as the sustainability of much-needed deployments.
A thorough evaluation is needed to establish how far the best practices on which the directive was built have effectively spread and today shape administrative practice in the Member States. Such information is especially important given the lack thereof in the Commission’s implementation report of 2018. This assessment should notably focus on countries without prior legislation and discount positive findings that simply reflect pre-existing national practices.
Where administrative practices have not evolved, and where overlaps in regulation exist between the Code and the BCRD, all options must be thoroughly considered, including a repeal, whether full or partial, of the BCRD.
ecta and its members are ready to contribute to this work, and will provide detailed responses to relevant upcoming public and targeted consultations.
We consider the following issues and questions as requiring close scrutiny during the review:
Cross- and intra-sectoral use:
How many operators of networks other than public communications networks have availed of the right to offer access to their physical infrastructure? What share of network deployment relies on the BCRD? What impact has co-deployment between providers of public communications networks had on investment levels?
Institutional complexity and administrative burdens:
Has the Single Information Point (SIP) been implemented in a unified or distributed manner? Where SIPs are distributed, are cooperation processes in place and efficient? Has implementation effectively reduced time and effort to access relevant information and obtain relevant permits? How has pricing affected SIP use? Are all relevant procedures ‘fit for digital’?
Permit granting:
Are permits effectively granted within four months? How often have exceptions been invoked, and is information about delays and costs readily available via the SIP(s)? Are comparison tools available?
Effectiveness of dispute settlement procedures:
Are disputes settled efficaciously and timely, and has a predictable practice, including relevant guidance, evolved? What are the associated costs, and have these prevented operators from seeking settlement?
Interplay between SMP regulation and the BCRD:
Have SMP obligations mandating physical infrastructure access been rescinded invoking the BCRD? How has this influenced deployment and the number of disputes? Have SMP operators demonstrably cooperated fully and in good faith with national dispute settlement bodies? What is the share of access requests from SMP operators to competitive operators relative to the requests among providers of public communications networks, and in relation to all requests under the national transposition?
Read full responseMeeting with Margrethe Vestager (Executive Vice-President)
10 Dec 2019 · Competition and regulatory issues in the telecom sector
Response to Contract summary template for electronic communications service providers
9 Sept 2019
Please find attached ecta's contribution to this consultation.
Read full responseResponse to Cooperative, Connected and Automated Mobility (CCAM)
16 Nov 2018
ecta appreciates the opportunity to provide feedback on the Commission`s roadmap for a Recommendation to support the introduction of Cooperative, Connected and Automated Mobility (CCAM).
ecta represents more than 100 competitive telecommunications operators and digital solutions providers. The biggest pan-European association of its kind, it is a founding member of the European Automotive & Telecoms Alliance (EATA) and has been centrally involved in policy discussions on Connected and Automated Driving and CCAM.
CCAM defines a new space of development opportunity for both the transport and telecommunications sectors. ecta therefore considers that there may be benefit to the development of a guidance instrument to facilitate realisation of this development potential within, between and across sectors.
According to the roadmap, this instrument will be developed at a very swift pace. While it is welcome to institute a framework as conducive as possible to the promotion of CCAM sooner rather than later, ecta believes that too great speed in developing the Recommendation may be detrimental to achieving this objective.
The fact that a public consultation on the Recommendation itself has already been launched might suggest that the roadmap will have only limited impact on its elaboration. ecta does not believe that the roadmap convincingly specifies reasons to justify this approach. Indeed, by limiting the possibility to consider remarks on the roadmap in designing and scheduling this initiative, the rule-making may become less targeted, substantiated and, ultimately, effective.
These risks are illustrated by the complexity and diversity of the subject matters to be addressed, the narrow delivery timeframe envisaged, and the lack of a concrete intervention logic. ecta believes that these combined factors underline the importance of an impact assessment to ensure that the recommendations to be adopted can really drive CCAM development. When the roadmap suggests that no assessment is needed because the instrument would have no significant economic, environmental or social impacts, this seems not to correspond to the catalytic effect it is clearly expected to have.
Depending on their content, the recommendations may have lasting effects on business plans and strategic choices. These impacts do not disappear or become irrelevant because they might only concern transitional arrangements, such as the choice of 5G pioneer testing bands. Indeed, they might be augmented by artificially creating a window of opportunity for only some market participants. The roadmap, by its very form, cannot alleviate these concerns. In fact, the text of the roadmap raises a number of questions (for example, on the relationship between 5G pioneer and 5G pioneer testing bands) that, after a first consultation round, could have been addressed when consulting on the Recommendation itself.
Finally, ecta considers that the roadmap tends to overstate the level of stakeholder preparedness when pointing out that `various other consultations have already taken place´. ecta does not consider that study workshops, which are limited in their accessibility, timing and feedback opportunities, can replace public consultations. Moreover, the roadmap refers to events that already have taken place as still forthcoming. Thirdly, the topics to be dealt with in the Recommendation seem not to have previously been subject to consultation.
Overall, ecta would therefore encourage the Commission to ensure that development of the Recommendation, going forward, becomes appropriately inclusive and subject to impact appraisal, and that key elements such as the envisaged principles of data governance and aspects of 5G pioneer testing bands are themselves submitted to public consultation.
Read full responseMeeting with Linsey Mccallum (Cabinet of Commissioner Margrethe Vestager)
15 May 2018 · Digital Single Market
Meeting with Filomena Chirico (Cabinet of Vice-President Jyrki Katainen)
27 Oct 2017 · Electronic communication code
Meeting with Kamila Kloc (Cabinet of Vice-President Andrus Ansip)
26 Oct 2017 · Electronic Communications Code
Meeting with Eric Peters (Cabinet of Commissioner Mariya Gabriel)
23 Oct 2017 · ECTA Conference
Meeting with Mariya Gabriel (Commissioner)
5 Sept 2017 · European Electronic Communications Code
Meeting with Jyrki Katainen (Vice-President) and
28 Jun 2017 · Competition, innovation & investment
Meeting with Kamila Kloc (Cabinet of Vice-President Andrus Ansip)
4 Apr 2017 · Telecom review
Meeting with Günther Oettinger (Commissioner)
21 Dec 2016 · Telecom review, state of competition in Europe
Meeting with Günther Oettinger (Commissioner)
31 May 2016 · Telecom review
Meeting with Bodo Lehmann (Digital Economy)
14 Apr 2016 · connected and automated driving
Meeting with Michael Hager (Digital Economy)
14 Apr 2016 · telecom policy
Meeting with Pauline Rouch (Cabinet of President Jean-Claude Juncker)
18 Mar 2016 · Digital Single Market
Meeting with Andrus Ansip (Vice-President) and
12 Jan 2016 · EU telecoms review
Meeting with Kamila Kloc (Cabinet of Vice-President Andrus Ansip)
2 Dec 2015 · Telco review
Meeting with Anna Herold (Digital Economy)
18 Nov 2015 · copyright
Meeting with Margrethe Vestager (Commissioner)
16 Nov 2015 · Telecoms markets and policy
Meeting with Eric Mamer (Digital Economy)
8 Oct 2015 · Telecom review
Meeting with Roberto Viola (Director-General Communications Networks, Content and Technology)
25 Sept 2015 · Annual ECTA Conference in November 2015
Meeting with Linsey Mccallum (Cabinet of Commissioner Margrethe Vestager)
21 Sept 2015 · Presentation of Analysis Mason study
Meeting with Anna Herold (Digital Economy)
8 Jul 2015 · Telecom review
Meeting with Eric Mamer (Digital Economy)
7 Jul 2015 · connected mobility
Meeting with Kamila Kloc (Cabinet of Vice-President Andrus Ansip)
30 Jun 2015 · TSM & review
Meeting with Fabien Dell (Cabinet of Commissioner Pierre Moscovici)
1 Jun 2015 · DSM
Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen)
1 Jun 2015 · Digital Single Market
Meeting with Alfredo Sousa De Jesus (Cabinet of Commissioner Carlos Moedas)
1 Jun 2015 · Meeting with Aurélie Bladocha
Meeting with Adrienn Kiraly (Cabinet of Commissioner Tibor Navracsics)
27 May 2015 · Digital Single Market
Meeting with Kevin O'Connell (Cabinet of Commissioner Věra Jourová)
4 May 2015 · Digital Single Market strategy
Meeting with Carl-Christian Buhr (Cabinet of Commissioner Phil Hogan)
27 Apr 2015 · Digital Singe Market Strategy, investment in rural broadband
Meeting with Andrus Ansip (Vice-President) and
16 Feb 2015 · Investments, regulatory framework, competition in telecoms sector
Meeting with Pauline Rouch (Cabinet of President Jean-Claude Juncker)
20 Jan 2015 · Digital Single Market
Meeting with Heidi Jern (Cabinet of Vice-President Jyrki Katainen)
13 Jan 2015 · Telecom infrastructure investments
Meeting with Eric Mamer (Digital Economy)
17 Dec 2014 · Telecom Single Market
Meeting with Juhan Lepassaar (Cabinet of Vice-President Andrus Ansip), Kamila Kloc (Cabinet of Vice-President Andrus Ansip)
16 Dec 2014 · Telecoms Single Market: broadband, access, spectrum
Meeting with Juhan Lepassaar (Cabinet of Vice-President Andrus Ansip), Kamila Kloc (Cabinet of Vice-President Andrus Ansip)
16 Dec 2014 · To discuss policies for the completion of the connected Digital Single Market