FiCom ry

FiCom

FiComin tehtävä on edistää jäsenistönsä liiketoimintamahdollisuuksia ja parantaa kilpailukykyä vaikuttamalla alaa koskevaan sääntelyyn, edistämällä alan teknistä kehitystä, hallinnoimalla alan tilastoja ja tunnuslukuja, ylläpitämällä kattavaa ICT-alan tietopankkia, viestimällä avoimesti alan ajankohtaisasioista eri kohderyhmille sekä vaikuttamalla alan julkiseen kuvaan. Lisäksi FiCom kehittää yhdessä toimialan yritysten kanssa tietoverkkoalan toimintavarmuutta sekä edistää alan varautumista vakavien häiriöiden ja poikkeusolojen varalle.

Lobbying Activity

Meeting with Sirpa Pietikäinen (Member of the European Parliament)

18 Nov 2025 · Digital policies

Meeting with Eero Heinäluoma (Member of the European Parliament)

14 Nov 2025 · Ajankohtaiset digiasiat

Meeting with Sebastian Tynkkynen (Member of the European Parliament)

7 Nov 2025 · FiCom 25 vuotta

Meeting with Thomas Schmitz (Cabinet of Executive Vice-President Henna Virkkunen)

17 Oct 2025 · FiCom ry presentation

Meeting with Katri Kulmuni (Member of the European Parliament)

17 Oct 2025 · EECC-uudistus, Digital Networks Act, tekoälylainsäädäntö

Meeting with Sebastian Tynkkynen (Member of the European Parliament)

17 Oct 2025 · Digiasiat

Meeting with Peter Stuckmann (Head of Unit Communications Networks, Content and Technology)

15 Oct 2025 · Exchange of views on the upcoming Digital Networks Act

Response to Digital package – digital omnibus

24 Sept 2025

The EU has finally taken the right direction: digital regulation is being simplified through omnibus initiatives. This is essential. For example, the current regulatory framework for telecommunications has become far too complex compared to the pace of technological development. Legislation must keep up with the times and promote Europes competitiveness, not hinder it. Regulation should act as an enabler, oriented towards supporting investment, growth, and technological neutrality. Streamlining and simplifying regulation creates a fairer environment that better addresses the sectors challenges of investment and innovation. Unnecessary and overlapping rules must be removed, with regulation in the future focusing only on essential areas. Attention must also turn to GDPR and AI regulation. Excessive detail and divergent national interpretations slow growth and make rules difficult to apply. If we want European companies to succeed in global competition, the rules must be predictable and clear. The core principle is simple: every new regulation must be preceded by an impact assessment. This benefits not only Finland but the entire European business community. Regulation must provide the framework and a truly level playing field but growth comes from companies. If they are buried under administrative burdens, the whole of Europe will fall behind.
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Response to Digital Networks Act

10 Jul 2025

FiCom's comments are in the attached statement. However, here are FiCom's main messages: FiCom emphasizes the importance of simplifying, harmonizing, and ensuring fairness in regulation. The current regulatory framework is complex and does not adequately respond to market and technological changes. FiCom supports reducing reporting obligations and eliminating unnecessary administrative burdens. Regarding universal service obligations (USO), FiCom advocates for focusing on affordability, but at the same time USO regulation must be significantly simplified. It should transition from ex ante regulation to ex post regulation and rely on case-by-case assessments rather than market analysis. Net neutrality regulation should guarantee internet access services in line with its purpose, requiring a narrow interpretation and case-by-case assessments. The Current BEREC guidelines are very detailed and act as de facto regulations, which can hinder technological development and weaken the competitiveness of European companies. In spectrum management, FiCom supports longer license durations, easier renewals, and flexible spectrum usage. FiCom stresses the significance of equitable regulation that treats all stakeholders fairly and promotes investment. Access regulation should move from ex ante to ex post regulation or leave this to national discretion. Regulation should also better consider local competitive conditions and substitute products brought by technology. A Pan-EU harmonized access product may be problematic and difficult to implement because network solutions differ across member states. Furthermore, pre-defined technical characteristics may limit technical innovation, technological development, and product competition. Regarding governance regulation and EU governance, entities such as the RSPG must continue to consider national market differences, especially in spectrum issues.
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Meeting with Silke Dalton (Cabinet of Executive Vice-President Henna Virkkunen)

18 Feb 2025 · Upcoming Digital Initiatives

Meeting with Aura Salla (Member of the European Parliament)

8 Oct 2024 · CSAM

Response to How to master Europe’s digital infrastructure needs?

27 Jun 2024

Please see the attached file for all comments. Some key points: The white paper provides a fairly good overview of the communication markets and their associated challenges at the EU level. FiCom supports simplification, harmonization, and fairness in regulation. This detailed, burdensome, and complex regulation targeting telecommunications companies should be reduced, clarified, and simplified, which would create a more equitable regulatory environment and help better respond to investment and innovation challenges. FiCom supports the level playing field of regulation, but by lightening the existing regulation and applying it to all players who offers same services. Regulation should be fair and balanced on existing and new players in the industry. Regulation should not promote a planned economy, but a market economy. Consolidation cannot primarily be promoted through regulation, but market-based consolidation should not be unjustifiably prevented by regulation either. The current strict European regulation related to corporate merger control should be re-evaluated. Proposals of the European Core Network Operator market or the country- of-origin legislative principle should be approached with considerable caution, so they are not the primary solutions to address the challenges faced by Europes communication markets. Regulation must continue to take into account the national differences in markets and national security, as if they are not considered, the proposals could lead to an unequal competitive environment at national level. Such structural changes implemented by legislation could also lead to differentiation in service and infrastructure levels, and thus to the loss of the benefits that have been, and can be, achieved. There should be a restraint from additional regulation and focus on the consistent and predictable implementation of regulations. Some harmonization problems would be solved by Commissions more efficient supervision of the implementation of regulation. The existing EECC directive is very complex and should be renewed, simplified and move towards general competition law and consumer law. The existing SMP-regulation does necessarily not promote investments anymore; instead, it can slow down investments by traditional operators. According to EECCs and its predecessors original aim, SMP regulation should move from ex ante regulation to ex post regulation or at least leave this to national discretion. If SMP-regulation were considered necessary in some respects, its use should be an exception in the future, not the rule. SMP-regulation could only be used when there is a justified national reason. The views presented in the white paper centralizing frequency management and harmonizing conditions are not entirely in Europes interest. Excessive harmonization can slow down the most advanced member states. Decision-making power regarding spectrum should remain national, as Finland has practiced excellent spectrum policy. The Finnish spectrum model serves as an excellent example for other EU member states as well The views of the White Paper that spectrum auction prices should not become excessive and that frequencies should be distributed quickly can be considered commendable. Harmonization could occur through nationally issued licenses with sufficiently long minimum license durations (e.g.20 years). Harmonization would be possible also with satellite spectrum issues. The current heavy and administratively burdensome USO-regulation should transition from ex ante regulation to ex post regulation and rely on case-by-case assessments rather than market analysis. Scenario 11(submarine cables). The proposals related to easing national and international licensing, as well as promoting financing and maintenance and repair capacity, are commendable. FiCom does not support the collection and submarine cable location other technical information to EU administrative bodies or any entity outside national security authorities.
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Meeting with Eleonora Ocello (Cabinet of Commissioner Thierry Breton)

5 May 2023 · Telecoms policy

Meeting with Arto Virtanen (Cabinet of Commissioner Jutta Urpilainen)

29 Mar 2023 · Current affairs and regulation in electronic communications sector

Meeting with Miapetra Kumpula-Natri (Member of the European Parliament, Shadow rapporteur)

28 Oct 2022 · Meeting on Data Act

Meeting with Didier Reynders (Commissioner) and

18 Feb 2020 · Presentation of the company's activities & issues relevant for JUST portofolio

Response to Fairness in platform-to-business relations

22 Nov 2017

Finnish Federation for Communications and Teleinformatics, FiCom is a co-operation organisation for the ICT industry in Finland. FiCom's members are companies and other entities that operate in the communications and teleinformatics sector in Finland. FiCom makes the following submission on assessment on regulation of the platforms. Underlying reason for ongoing assessment is the observation that platforms play a central role in digital economy. However, unlike the case with early telecom regulation, new ex-ante regulation is not the way to create or drive the market among platforms. As the business evolves on a very fast pace a crucial issue for the regulator is to maintain level playing field for established and new market players. In terms of EU acquis, this predominantly transfers to moving away from sector-specific regulation, towards more general approach. General Data Protection Regulation, EU competition law and proposed regulation on Free Flow of Data will form the general, non-sector-specific basis for data-driven European digital economy. There are several challenges for scenarios that incorporate new regulatory measures. The definition of platform is so broad that it encompasses all possible platforms – not regarding their market power. When developing digital economy it is crucial for the regulator to maintain a steady and predictable regulatory environment. Vague definitions will lead to unpredictable practice. Market of platforms is still developing and users and businesses alike may carry out quick migrations among different platforms depending on various variables. In FiCom’s opinion it is still too early to burden this sector with extensive regulation. Hastily drafted sector-specific platform regulation may seriously set back the development of European services needed to boost European digital economy. It is advisable to wait and see the effects of the regulation already passed, namely GDPR and possible Free Flow of Data as well as practice from general competition law. Only after these implications have been carefully analysed the need for further regulation can be assessed.
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