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European Internet Services Providers Association

EuroISPA

The European Internet Services Providers Association represents over 3000 internet service providers across Europe on policy issues.

Lobbying Activity

Meeting with Emmanuelle Du Chalard (Head of Unit Communications Networks, Content and Technology)

18 Nov 2025 · Monitoring and follow-up of the Commission Recommendation on combating online piracy of live events Main points

EuroISPA urges EU to simplify rather than add digital rules

24 Oct 2025
Topic — A consultation on closing consumer protection gaps regarding online commercial practices.
Message — The association argues current laws provide a comprehensive framework and should be enforced before proposing rules. They recommend conducting impact assessments to identify gaps and prioritize amending existing instruments.123
Why — This approach prevents new legal uncertainty and reduces potential compliance burdens for providers.45
Impact — Consumers lose out on mandatory tools like cancellation buttons that simplify ending subscriptions.6
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EuroISPA warns against overregulation in Digital Networks Act

9 Jul 2025
Topic — The consultation explores ways to modernize EU digital infrastructure for AI.
Message — They request that default access products remain optional for providers. The association opposes a fixed EU-wide date for copper network decommissioning. They want enterprise services exempted from consumer protection rules.123
Why — Streamlining administrative reporting would reduce high compliance costs for internet service providers.45
Impact — Citizens in remote areas risk digital exclusion from a rigid infrastructure transition.67
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EuroISPA Urges Technical Focus for EU Cybersecurity Certification

20 Jun 2025
Topic — The European Commission is reviewing the Cybersecurity Act to improve resilience and certification.
Message — Certification schemes should remain exclusively technical and avoid sovereignty-based requirements. Small companies should have simplified pathways like self-assessment to lower regulatory barriers. Legislators should harmonize reporting across frameworks and create single reporting points.123
Why — Exempting internal software from certification would significantly lower administrative costs for providers.4
Impact — National authorities lose the power to impose sovereignty-based criteria and localization requirements.5
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Meeting with Alexandra Geese (Member of the European Parliament)

16 Jan 2025 · Digital policies

EuroISPA warns EU against rigid digital infrastructure regulations

28 Jun 2024
Topic — European Commission consultation on future digital infrastructure needs and connectivity rollout strategies.
Message — EuroISPA advocates for flexible, technology-neutral regulation that respects national differences rather than universal rules. They urge a shift away from cumbersome requirements and oppose the centralization of radio spectrum management.123
Why — These recommendations would protect internet providers from increased compliance costs and new regulatory burdens.45
Impact — Centralized EU bodies lose the power to unify spectrum management across the continent.67
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EuroISPA urges pragmatic GDPR guidance and reduced SME complexity

8 Feb 2024
Topic — Evaluation of the General Data Protection Regulation six years after its application.
Message — Simplify user information and ensure data protection authorities provide more pragmatic guidance. The association advocates for a risk-based approach to support innovation and new technologies.123
Why — Clearer rules would reduce compliance costs and encourage investment in digital technology.45
Impact — Privacy groups could face higher risks if authorities move away from strict standards.6
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Response to Fighting against online piracy of live content

8 Feb 2023

Please find attached EuroISPA's contribution to the Commission's initiative on Combating online piracy of live content.
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Meeting with Paul Tang (Member of the European Parliament, Shadow rapporteur) and Meta Platforms Ireland Limited and its various subsidiaries and

5 Dec 2022 · Child Sexual Abuse Regulation

Meeting with Marcel Kolaja (Member of the European Parliament, Shadow rapporteur for opinion)

29 Sept 2022 · discussion about protection of children on-line with European Internet Services Providers Association member CZ.NIC

Meeting with Marcel Kolaja (Member of the European Parliament, Shadow rapporteur for opinion)

27 Sept 2022 · discussion about protection of children on-line with European Internet Services Providers Association member CZ.NIC

EuroISPA warns child safety rules threaten encryption and privacy

9 Sept 2022
Topic — This consultation covers a new EU regulation to detect and report child sexual abuse online.
Message — EuroISPA demands that end-to-end encryption remains intact and that number-based services be excluded. They advocate for a cascade approach to removals and the elimination of mandatory grooming detection.123
Why — The association would avoid implementing technically unfeasible systems and minimize their legal liability.45
Impact — Law enforcement agencies would lose access to encrypted communications for investigating online crimes.6
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Response to Fight against counterfeiting

3 Mar 2022

EuroISPA is the voice of the European Internet industry, representing over 2,000 Internet Services Providers across Europe, all along the Internet value chain. We welcome the opportunity to provide feedback on the Commission’s plans to create an EU toolbox against counterfeiting, strengthening EU-wide action and cooperation between key stakeholders, with a view to tackling the issue of counterfeiting in both the online and offline world. Regarding the type of instrument, EuroISPA would urge that the toolbox is proposed as a collection of best practices enriched by the work of the Commission and the EUIPO, as practices varies in each Member State in accordance with cultural and market differences. In this context, the effects and impact of the Directive on Copyright in the Digital Single Market 2019/790 needs to be properly assessed before pursuing further legal instruments. This notion also extends to forthcoming instruments, such as the Digital Services Act and its due diligence obligations, which strive to effectively tackle counterfeit products and address piracy online. Any new practices or tools developed should be tailored according to the type of online intermediary, factoring in its technical capacities and the legal frameworks with which it must comply. As an overarching principle, internet intermediaries are subject to a prohibition of any kind of general monitoring as defined in Article 15 of the e-Commerce Directive 2000/31/EC. In more specific cases, internet access providers must abide by the provisions of Article 3 of the Net Neutrality Regulation 2015/2120, and they cannot block websites without the involvement of legislative, judicial or administrative authorities. Moreover, country code top-level domain registries (ccTLDs), for example, do not have the technical capacity to directly target unlawful content online and can only suspend the underlying technical infrastructure, i.e. the domain name, which disrupts the functioning of all associated services (such as website or email hosting). In sum, any obligations arising from the toolbox must be consistent with existing Union law; otherwise, they run the risk of having disproportionate and undesirable effects on fundamental rights and the internet’s infrastructure. EuroISPA would like to stress real caution when exploring options to mandate web-blocking to tackle intellectual property infringements and to highlight the importance of removal at source. In this context, we recommend adopting a principle of “subsidiarity.” In first instance, competent authorities should always take action against the provider (the user) of the IP infringing content or products, the hosting provider, or the online platform. Where possible, removal at source should always be preferred and prioritised. Only in the case that there is no action from the content provider or platform should the competent authority request the access provider to intervene as ultima ratio. Furthermore, we would like to emphasise that blocking at the level of the access provider is in principle neither effective nor proportionate, and national legislation mandating this must satisfy certain criteria. Mandatory blocking should be mandated by a court order or a public authority, in full respect of fundamental rights and their safeguards. In addition, requests to block access should be accompanied by cost reimbursement for the affected online intermediaries. EuroISPA would like to underline that the development and use of any automated content recognition tools by trusted flaggers, rightsholders, law enforcement, and intermediaries to identify and remove online piracy should be accompanied by appropriate safeguards, such as human review, to avoid erroneous removals and to ensure that the fundamental rights and legitimate interests of users are best protected.
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Meeting with Monika Maglione (Cabinet of Commissioner Ylva Johansson)

12 Oct 2021 · Digital policies of DG Home

Meeting with Wojtek Talko (Cabinet of Vice-President Věra Jourová)

4 Oct 2021 · Digital policies

Meeting with Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager)

16 Sept 2021 · Digital Services Act, NIS2, ePrivacy

EuroISPA Urges Narrower Platform Definitions and SME Exemptions

26 Mar 2021
Topic — The Digital Services Act updates regulations for online platforms and digital services.
Message — EuroISPA wants narrower definitions for online platforms to protect infrastructure providers. They also advocate for wider exemptions for medium-sized firms and a twelve-month implementation deadline.1234
Why — This would shield infrastructure providers and mid-sized companies from expensive regulatory requirements.56
Impact — Public authorities would find it harder to use internet-blocking orders against illegal content.7
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Response to Revision of the NIS Directive

18 Mar 2021

The European Internet Services Providers Association (EuroISPA) is the world's largest association of Internet Services Providers (ISPs), representing over 2,000 ISPs across the EU and EFTA countries. EuroISPA is recognised as the voice of the EU ISP industry, reflecting the views of ISPs of all sizes from across its member base. You will find our contribution attached. For more information about EuroISPA or questions on our contribution please contact us in secretariat@euroispa.org.
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EuroISPA urges voluntary reporting and protection of encryption

22 Dec 2020
Topic — Proposed EU rules mandate detecting and reporting online child sexual abuse material.
Message — EuroISPA argues that end-to-end encryption must be preserved to ensure cybersecurity and user privacy. They propose prioritizing voluntary measures and excluding internet infrastructure companies from the scope. Reporting to a central EU authority should be optional to avoid complexity for businesses.123
Why — This would lower compliance costs and protect existing business models from interference.45
Impact — Law enforcement authorities lose the ability to access communications for criminal investigations.6
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Response to Commission Implementing Decision on standard contractual clauses for the transfer of personal data to third countries

10 Dec 2020

To whom it may concern, please find attached EuroISPA's feedback on the draft standard contractual clauses for transferring personal data to non-EU countries.
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Response to Strengthening of Europol’s mandate

9 Jul 2020

Please find attached EuroISPA's contribution to the consultation on the Inception Impact Assessment of the Future Europol Regulation.
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Response to Report on the application of the General Data Protection Regulation

29 Apr 2020

To whom it may concern, Please find attached EuroISPA's feedback to the European Commission's report on the General Data Protection Regulation. Kind regards, Mauro Sanna Policy Executive EuroISPA - European Internet Services Providers Association Rue de la Loi 38 - 1000 Brussels T : +32 (0) 289 665 83 M: +32 (0)491 258 232 www.euroispa.org
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Meeting with Geneviève Tuts (Cabinet of Commissioner Didier Reynders), Lucrezia Busa (Cabinet of Commissioner Didier Reynders)

19 Feb 2020 · Presentation general of activities of the Group

Meeting with Marie Frenay (Cabinet of Vice-President Věra Jourová), Renate Nikolay (Cabinet of Vice-President Věra Jourová)

19 Feb 2020 · Digital Services Act

EuroISPA: Anti-terror rules threaten small European internet companies

7 Nov 2018
Topic — The consultation seeks to improve the effectiveness of fighting illegal terrorist content online.
Message — EuroISPA requests exemptions for small businesses from expensive monitoring requirements and data storage duties. They argue for removing the one-hour deadline to prevent the over-removal of legitimate content.12
Why — This would prevent high compliance costs from forcing smaller providers out of the market.3
Impact — Large tech companies would lose the market advantage gained from smaller rivals facing high costs.4
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EuroISPA urges monitoring before proposing new illegal content legislation

29 Mar 2018
Topic — This consultation evaluates further measures for tackling illegal online content across Europe.
Message — EuroISPA supports the baseline option, prioritizing the monitoring of current recommendations over new legislation. They urge the Commission to finalize pending legislative revisions before assessing outcomes in 2020. They express concern regarding automated filtering and prescriptive timeframes leading to over-removal.123
Why — Maintaining the baseline prevents new regulatory costs and administrative burdens for providers.4
Impact — Users risk losing access to legal online material through automated filtering mechanisms.5
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Meeting with Andrus Ansip (Vice-President) and

30 Jan 2018 · GDPR, e-privacy

Meeting with Laure Chapuis-Kombos (Cabinet of Vice-President Andrus Ansip)

19 Jun 2017 · e-privacy directive

Meeting with Andrus Ansip (Vice-President) and

24 May 2017 · GDPR Implementation and Privacy Shield

Meeting with Andrus Ansip (Vice-President) and

19 Dec 2016 · Discussion with industry on general data protection regulation implementation

Meeting with Michael Hager (Digital Economy) and DIGITALEUROPE and

27 Sept 2016 · DSM

Meeting with Andrus Ansip (Vice-President) and

30 Jun 2016 · Privacy shield, data protection

Meeting with Anna Herold (Digital Economy), Kilian Gross (Digital Economy), Michael Hager (Digital Economy)

25 May 2016 · platforms

Meeting with Michael Hager (Digital Economy) and DIGITALEUROPE and

3 May 2016 · DSM

Meeting with Michael Hager (Digital Economy) and DIGITALEUROPE and

23 Feb 2016 · DSM

Meeting with Andrus Ansip (Vice-President) and

8 Feb 2016 · EU-US Privacy Shield

Meeting with Andrus Ansip (Vice-President) and

14 Oct 2015 · Meeting with tech businesses after Safe Harbour ruling

Meeting with Stig Joergen Gren (Cabinet of Vice-President Andrus Ansip)

18 Mar 2015 · Platforms

Meeting with Markus Schulte (Digital Economy)

4 Feb 2015 · Telecoms Single Market

Meeting with Eric Mamer (Digital Economy), Heidi Jern (Cabinet of Vice-President Jyrki Katainen)

4 Feb 2015 · Digital Single Market

Meeting with Pauline Rouch (Cabinet of President Jean-Claude Juncker)

3 Feb 2015 · Digital Single Market

Meeting with Michael Hager (Digital Economy) and DIGITALEUROPE and

20 Jan 2015 · Digital Agenda