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Liberty Global Corporate B.V.

Liberty Global

Liberty Global is a world leader in converged broadband, video and mobile communications services, connecting 86 million subscribers across Europe and the UK.

Lobbying Activity

Liberty Global calls for technology neutrality and merger reform

9 Jan 2026
Topic — The Commission is reviewing its roadmap for Europe's digital infrastructure and services through 2030.
Message — Liberty Global advocates for technology neutrality that recognizes both fiber and cable networks as valid gigabit solutions. They urge the EU to update merger control policy and encourage cooperation between operators to achieve investment scale. They also demand a stable, predictable regulatory environment to protect long-term infrastructure planning.123
Why — The company would avoid asset devaluation and lower its costs by utilizing existing cable infrastructure and consolidating markets.45
Impact — Consumers may face higher prices or less choice if merger rules prioritize corporate scale over price competition.6
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Liberty Global Urges Deregulation and Support for Market Consolidation

11 Jul 2025
Topic — The Digital Networks Act aims to modernize EU infrastructure for cloud-based services and AI.
Message — The company calls for simplification by removing red tape and overlapping rules. They advocate for a pragmatic approach to enable market consolidation and competitive cooperation. They also want competition policy to prioritize investment and innovation over current frameworks.123
Why — The company would benefit from fewer regulatory restrictions and higher returns on its investments.4
Impact — Consumers could lose out if merger controls prioritize industrial objectives over maintaining low prices.5
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Meeting with Lucrezia Busa (Head of Unit Communications Networks, Content and Technology) and Telefonica, S.A. and

27 Jun 2025 · Implementation details of the inclusion of Ukraine into the EU Roam Like at Home (the ‘EU RLAH’) area

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

13 Jun 2025 · Commission DNA proposal

Meeting with Silke Dalton (Cabinet of Executive Vice-President Henna Virkkunen)

9 Apr 2025 · Upcoming legislation in the Telecom sector

Meeting with Pilar Del Castillo Vera (Member of the European Parliament) and American Tower Corporation

8 Apr 2025 · Telecommunications policy

Meeting with Maroš Šefčovič (Commissioner) and

8 Apr 2025 · State of play on US-EU trade relations

Meeting with Teresa Ribera Rodríguez (Executive Vice-President) and

2 Mar 2025 · Opportunities and challenges in the telecoms sector

Meeting with Teresa Ribera Rodríguez (Executive Vice-President) and

14 Jan 2025 · To hear interest representatives’ view on EU competition and telecom policy, and perspectives on clean, just, and competitive transition policies.

Meeting with Svenja Hahn (Member of the European Parliament) and Google and

23 Oct 2024 · Digital Policy

Liberty Global Urges EU to Allow Telecom Market Consolidation

29 Jun 2024
Topic — This consultation explores strategies to meet Europe's future digital infrastructure needs.
Message — Liberty Global urges regulators to allow market consolidation and operator cooperation to achieve scale. They want a shift from sector-specific rules to competition law to boost network investment.12
Why — Consolidation would improve investment returns and reduce costs by avoiding infrastructure duplication.34
Impact — Consumers risk losing the low prices currently protected by strict merger controls.5
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Meeting with Pernille Weiss-Ehler (Member of the European Parliament, Rapporteur) and Rud Pedersen Public Affairs Brussels and

22 Nov 2023 · Directive on Medicinal products for human use

Response to Review of the Broadband Cost Reduction Directive (Directive 2014/61/EU)

11 May 2023

Liberty Global welcomes the Gigabit Infrastructure Act as result of the revision of the Broadband Cost Reduction Directive (BCRD). We strongly support regulatory policies that facilitate private deployment of Very High Capacity Networks. Such policies should abide by the principles of appropriateness and proportionality and be technology-agnostic, as regulation favoring any specific technology is likely to chill investment. The proposed regulation will help to address the shortcomings caused by the fragmented implementation of the BCRD and to speed up network deployment to achieve the EU 2030 connectivity targets
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Meeting with Paul Tang (Member of the European Parliament) and Google and

26 Feb 2023 · Participant at EIF-GSMA Roundtable discussion: "‘Connecting Europe to its 2030 Digital Decade Targets’"

Meeting with Penelope Papandropoulos (Cabinet of Executive Vice-President Margrethe Vestager), Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager) and APCO Worldwide

20 Sept 2022 · presentation of the company, telecom.

Meeting with Filomena Chirico (Cabinet of Commissioner Thierry Breton)

20 Sept 2022 · Contribution to network investment

Response to Improving access to emergency services through the single European emergency number ‘112’

12 Sept 2022

Liberty Global supports the European Commission’s effort to ensure that emergency communications are equally effective and accessible by end users, including end-users with disabilities, across the EU. End-user rights are an area where there is significant fragmentation and it’s a key goal of the Electronic Communications Code (Code) to create more consistency in the application of consumer protection legislation. Rules laid down in the draft Delegated Regulation will be particularly important to ensure that quality and reliability of emergency communications is maintained, especially during the transition process of national Public Safety Answering Points (PSAPs) from legacy circuit-switched technology to packet-switched technology. The delegated act should be future-proof, securing flexibility to enable innovative developments, and abiding by the principles of appropriateness, proportionality and technology neutrality. A timely communication between end-user and the most appropriate PSAP, and the transmission of contextual information play a crucial role for a prompt intervention of emergency services in times of need. We welcome the parameters identified by the draft Delegated Regulation (Article 3) that Member States should apply when they define the accuracy and reliability criteria for caller location information in fixed and mobile networks. Above all, the ability to locate the end-user has a huge impact on the effectiveness of emergency communications. With regards to access by end-users with disabilities to emergency services through emergency communications in a functionally equivalent manner, the draft Delegated Regulation requires Member States to identify common interoperability requirements to allow routing to the most appropriate PSAP via a mobile application, including in roaming (Article 6). The introduction of such minimum requirements by Member States should be assessed under the principles of appropriateness, proportionality and technology neutrality. Member States should cooperate with the European Commission and ensure that all relevant stakeholders, especially mobile operators, are consulted throughout the process. Ultimately, when setting requirements Member States should try to align as much as possible, in order to help providers in creating a single system that can find application in multiple jurisdictions and promote harmonization across the EU. We welcome the reporting obligations (Articles 7 and 8) on Member States regarding the implementation of caller location information, the routing to the most appropriate PSAP and the means of access to emergency services for end-users with disabilities. Additionally, Member States are required to provide the European Commission with a roadmap concerning the upgrade of national PSAP systems to packet-switched technologies no later than nine months after the entry into force of the Delegated Regulation. Electronic communication services have already largely moved to an all-IP based infrastructure. Even though the draft Delegated Regulation contains no deadline by which the transition process must be completed, the European Commission should ensure the upgrade of PSAPs takes place in a timely manner, so that there is no mismatch between network operators and emergency services. Upgrading and standardizing access to emergency communications is an ambitious process that will require Member States time and effort. The European Commission’s will be essential in coordinating this at the EU level and achieving the objectives of the Delegated Regulation, by ensuring a consistent and timely application of the act. In this context, we urge both the Commission and Member States to keep in mind that all providers in the supply chain, including handset suppliers and providers of mobile application, play a key role and they should all be equally responsible to ensure effective accessibility to emergency communications across the EU.
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Meeting with Thierry Breton (Commissioner) and Google and

6 Sept 2022 · meeting with the Green Digital Coalition - Main topic : state of play on sustainable digitalization

Meeting with Pilar Del Castillo Vera (Member of the European Parliament, Rapporteur) and Cisco Systems Inc. and

6 Jul 2022 · Data Act

Meeting with Walter Goetz (Cabinet of Commissioner Adina Vălean)

15 Jun 2022 · Electrification of transport sector

Liberty Global Argues Current EU Consumer Laws Remain Fit

14 Jun 2022
Topic — A review of whether existing EU consumer laws effectively ensure digital fairness.
Message — Liberty Global maintains that principle-based rules remain fit for the digital sector. They urge officials to evaluate existing laws before proposing new regulations.12
Why — Maintaining the status quo avoids unhelpful administrative burdens and complex implementation timelines.3
Impact — Consumer groups seeking stronger protections against data-driven practices like dark patterns.4
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Response to Cyber Resilience Act

25 May 2022

Liberty Global welcomes the opportunity to comment on the European Commission’s call for evidence for an impact assessment of the likely initiative ‘Regulation on horizontal cybersecurity requirements for digital products and ancillary services’ (Cyber Resilience Act). In our view, the Commission’s call for evidence correctly identifies the need to complement the baseline cybersecurity framework formed by the NIS Directive (soon to be succeeded by the NIS2 Directive) and the Cybersecurity Act, with a new horizontal regime for connected products and associated services placed on the internal market. We support the Commission’s first initiative in this direction, the recently adopted Delegated Regulation under the Radio Equipment Directive (RED). That instrument will mitigate the cyber risks posed by unsafe wireless devices to communications networks and protects Europe’s consumers from fraud and privacy infringements. However, its scope – and therefore its effectiveness – is constrained due to the fact that the RED only applies to radio equipment. In our experience and that of our consumers, connected non-radio equipment can pose equal or even greater cyber risks. These risks are currently insufficiently addressed. A horizontal approach, in line with the principles of proportionality and appropriateness, addressing this concern can also level the playing field between products using wireless connectivity and other types of digital products and ancillary services. Liberty Global therefore agrees with the Commission that this proposal should aim to enhance and ensure a high level of security across the digital sector, protect users from unsafe products, incentivise vendors to offer more secure products, and improve the internal market through a levelling of the playing field. We believe the most appropriate and proportionate form of regulatory intervention is option 4 as proposed by the Commission: (i), a mixed approach including mandatory and soft rules, anchored of a horizontal regulatory intervention introducing cybersecurity requirements for a broad scope of tangible digital products. This would replicate the structure and methodology of the successful New Approach Directives. These rules can be credited with the seamless functioning of the internal market for goods, by safeguarding the interests of Europe’s consumers and by ensuring that all entities in the value chain have clearly defined roles and corresponding responsibilities. In line with the New Approach Directives and with a view to preventing the overburdening of economic actors and market surveillance authorities, Liberty Global advises the Commission to opt for conformity self-assessment by default. Third-party conformity assessment should only be mandatory if deemed appropriate and proportional for the product category and risks concerned. Liberty Global notes that the success of the New Approach can be attributed to its use of self-assessment. Additionally, Liberty Global notes that even in cases of self-assessment, it is already customary for economic actors to enlist third party expertise, in those instances where specialist know-how is required. Finally, as regards non-embedded software, Liberty Global is of the opinion that a staggered approach, as proposed by the EC in option 4 (ii), is most appropriate. The vast landscape of software available to some devices entails that a ‘one size fits all’ approach will undoubtedly result in overregulation for many economic operators, whilst at the same time, such generic rules are unlikely to address all relevant risks. A staggered approach will therefore enable a more targeted regulatory intervention, should this be necessary.
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Liberty Global urges stricter limits on data sharing requirements

13 May 2022
Topic — The EU is proposing new rules to regulate how data is shared between businesses and governments.
Message — Liberty Global requests that data sharing remains limited and proportionate to avoid excessive administrative burdens. They argue requests must be specific and granular to protect trade secrets. Furthermore, they demand that public sector bodies avoid “data fishing” by clearly stating their legal basis.123
Why — Narrower requirements would lower administrative costs and protect the company from sharing commercially sensitive information.45
Impact — Public sector bodies would have less flexibility and a higher legal burden when requesting essential data.6
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Meeting with Thierry Breton (Commissioner) and

8 Apr 2022 · Endorsing the Joint statement on Roaming and International calls between EU and Ukraine

Response to Improving access to emergency services through the single European emergency number ‘112’

29 Oct 2021

Liberty Global supports the European Commission’s ambition to harmonize access to emergency communications across the EU. The delegated act should be future-proof – securing flexibility to enable innovative developments, and abiding by the principles of appropriateness, proportionality and technology neutrality. Liberty Global focusses on a number of issues and may address additional points at a later stage. End-user rights are an area where there is significant fragmentation and it’s a key goal of the Electronic Communications Code (Code) to create more consistency in the application of consumer protection legislation. According to the Code, Member States must ensure that all end-users, including those with disabilities and those travelling within the European Union, are able to enjoy an effective access to emergency services. In this context, we understand that the delegated act will provide guidance on technical solutions to help, among other things, the migration from public safety answering points (PSAPs) served by circuit switched legacy communication networks to PSAPs enabled with packed switched communications in 4G and 5G networks. This process will technically allow the deployment of alternative text and video based solutions, such as real time text over Long Term Evolution and video over LTE (ViLTE), deployed in 4G networks. Although these measures seem to affect mostly PSAP services, the support of these new functionalities would depend on mobile network operators. A side effect of this could be that they would be hold to implement ViLTE only for the purpose of allowing emergency services. This would neither be appropriate nor proportionate. It would force mobile operators to incur substantial investments, which they would not be able to recoup commercially. If the European Commission nevertheless would pursue this, they should foresee in a mechanism to reimburse mobile operators for their investment, by the Member State or any third party, unless the mobile operator would deploy ViLTE for its own commercial purposes. Moreover, the roadmap mentions the possibility for the delegated act to set standards and common minimum requirements to ensure equivalent access and similar level of quality of caller location, and allow routing to the most appropriate PSAP throughout the EU, including in roaming. The introduction of such minimum requirements and standards should be assessed under the principles of appropriateness and proportionality – it could significantly limit mobile operator’s commercial freedom and their ability to innovate. Also it could be contrary to the principle of technology neutrality – another cornerstone from the Code. A side effect of this could be that it would require legacy technologies to remain operational far beyond their economic lifespan, e.g. eCall being limited to 2G/3G and not allowing 4G/5G. The impact on the telecommunications sector and the technical and financial feasibility of the initiative are still unclear. Indeed, the study commissioned in Q2 2021 will provide valuable input but, given that the issues the delegated act will seek to address are of technical nature, we urge the Commission to consult all the relevant stakeholder groups to gather technical, operational and commercial expertise. In this context, it’s also important that the Commission will equally weigh the input received from different actors in the industry as to ensure the delegated act balances the interest of the entire industry, not just some. Improving and standardizing access to emergency communications at the EU level is an ambitious process that will require Member States time and effort. A clear indication who will coordinate this at the EU level seems to be missing from the roadmap. A central body would play an important role in achieving the objectives of the delegated act, ensuring a consistent and timely application of the act across the EU.
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Response to Update of the Better Internet for Children Strategy (BIK Strategy)

28 Oct 2021

Liberty Global strongly supports the right of children to be respected, protected and empowered online. We recognise that the development of digital skills, coupled with a safe online environment, can have a transformative impact on children. Increased digitisation brings significant opportunities for children; to avail of these we must ensure we bridge the digital divide and give children the necessary skills to navigate the digital world. A harmonised, EU-level approach, to protecting children online is instrumental and it should reflect the principles of appropriateness and proportionality. Liberty Global's position is set out in more detail in the attached position paper.
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Response to Requirements for Artificial Intelligence

5 Aug 2021

Liberty Global welcomes the opportunity to comment on the European Commission (EC)’s consultation of the proposal for a Regulation laying down harmonized rules on artificial intelligence (the proposal) and its annexes. In previous submissions, Liberty Global supported the EC’s comprehensive evaluation of the regulatory environment applicable to nascent digital technologies such as robotics, Internet of things and particularly AI. Liberty Global agrees with the staged approach taken by the EC towards AI, as well as the EC’s ultimate objective of ‘fostering the development and uptake of safe and lawful AI that respects fundamental rights across the Single Market by both private and public actors while ensuring inclusive societal outcomes’. We also support the twin objective of promoting the uptake of AI and of addressing the risks associated with certain uses of this new technology, as laid down by the EC in its AI White Paper. Striking the right balance is key to achieving an optimal outcome. In Liberty Global’s view, the proposal succeeds in striking the right balance, meeting the principles of appropriateness and proportionality. The success of the proposal depends – to a large extent – on whether the scope is left intact throughout the further steps in the legislative process. The current, broad scope, can ensure a uniform regulatory approach in the EU towards AI and avoid barriers to the single market, arising out of potential regulatory fragmentation. In Liberty Global’s view, the risk-based approach foreseen by the proposal is one of its strengths, and will be a key contributor to the achievement of its objectives. Manipulative and other harmful applications of AI should indeed be subject to a blanket ban. Low-risk AI can benefit from predominantly supporting and voluntary measures. In respect of high-risk AI, Liberty Global notes that the proper identification of high-risk AI and its harmonized regulation are critical to the EC’s twin objectives. The proposal ensures maximum regulatory clarity in this respect. All relevant high-risk AI applications have been identified. Further expansion of the scope is not necessary. Maintaining a clear separation between these different regulatory regimes ensures regulation in line with the principles of appropriateness and proportionality. Liberty Global also agrees with the clear identification of the roles and responsibilities of the different actors in the value chain, as well as how to identify which party has what role and what actions may trigger a role shift. It is clear that, if a party further on in the value chain substantively alters an AI system, or changes its purpose, this party will be subject to the same responsibilities as the original AI provider. This adequately addresses the risks that compliant AI systems are altered, or their purpose is modified, after they have been placed on the market, without subjecting the entire value chain to significant regulatory or administrative burdens where this would not be appropriate, nor proportionate. Liberty Global supports the proposal’s leveraging of the existing principles of EU product conformity law, as well as references made to Union harmonisation legislation based on the New Legislative Framework in order to come to a clear and consistent regulation of products and services. The proposal ensures that the EU can be leading in the development and uptake of ethical AI. As a provider of next-generation connectivity across Europe, Liberty Global will be one of the key contributors to the uptake and accessibility of a broad spectrum of AI applications. Therefore, we would like to emphasize the importance of the completion of the Digital Single Market, also for the democratization and wide-spread deployment of AI in the EU. Finally, as set out in our paper on the role of AI in telecommunications (attached), the Code provides the appropriate framework for the use of AI in our sector.
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Response to Liability rules for Artificial Intelligence – The Artificial Intelligence Liability Directive (AILD)

28 Jul 2021

Liberty Global welcomes the opportunity to comment on the European Commission (EC)’s IIA of a possible initiative aimed at addressing a number of shortcomings identified in the evaluation of the Product Liability Directive 85/374/EEC (the Directive) and at those challenges posed by the circular economy and new emerging technologies for the application of liability rules. In previous submissions, Liberty Global supported the EC’s comprehensive evaluation of the regulatory environment, including liability regimes, applicable to nascent digital technologies such as robotics, Internet of things and particularly AI. Liberty Global notes that the current initiative forms part of the EC’s staged approach to developing an ecosystem of trust for AI and will complement the proposed Regulation on a European approach for AI. Liberty Global supports this staged approach and the EC’s ultimate objective of ‘fostering the development and uptake of safe and lawful AI that respects fundamental rights across the Single Market by both private and public actors while ensuring inclusive societal outcomes’. In our response to the EC’s AI White Paper, we gave our support to the EC’s twin objective of promoting the uptake of AI and of addressing the risks associated with certain uses of this new technology, noting that striking the right balance between the two is key to achieving an optimal outcome. Striking such a balance is also key when considering the development of a liability regime applicable to these technological developments. Liberty Global agrees with EC’s identification of the elements of intangibility of digital products, of connectivity and cybersecurity and of complexity, as elements which are addressed by the Directive with insufficient clarity and consistency. Regulatory and legal uncertainty increase the cost of doing business, hampering innovation and investment. Liability rules form a key component of the regulatory environment that businesses have to take into account. Now is the time to update these rules, to prevent regulatory fragmentation from slowing down the pace of innovation. Liberty Global is pleased that the EC recognises the importance of the circular economy and of business models in which products are repaired, recycled, refurbished or upgraded. In order to foster the internal market, harmonisation of and regulatory clarity on the responsibilities and liabilities for all relevant entities in the value chain, is paramount. As regards the policy options, Liberty Global recommends a strong, harmonized approach to address the aforementioned challenges through balanced and principled rules. In our perspective, the digital economy should not be subject to an entirely separate liability regime. Instead, the general liability regime and its case law are applicable. If some form of specific liabilities should apply, Liberty Global would support policy option 1.a. Extending the range of damages to non-material damages (option 1.b) is neither appropriate nor proportionate at this stage and would deviate from the general regime. As regards the potential reduction of obstacles to getting compensation, Liberty Global again is of the opinion that a deviation from the general regime is neither appropriate nor proportionate. However, if such sector-specific rules would be adopted, only policy option 2.1.a should be considered. Lastly, as regards addressing proof-related challenges posed by AI to national liability regimes, Liberty Global is of opinion that only policy option 2.2.b could provide a viable instrument. Relying on AI-specific obligations in EU safety legislation (and the associated safety documentation) would also improve the effectiveness of the market access regime. The other options are contrary to the principles of appropriateness and proportionality and would result in further fragmentation.
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Response to Digital Services Act package: ex ante regulatory instrument of very large online platforms acting as gatekeepers

4 May 2021

Liberty Global welcomes the opportunity to provide feedback on the European Commission’s proposal for a Digital Markets Act (DMA). Liberty Global also provided feedback to the proposal for a Digital Services Act. Our position on some key items is below - our response is attached. Liberty Global remains of the view that Articles 101 and 102 TFEU – along with timely and adequate use of interim injunctions – are suitable to enable the Commission and national competition authorities to intervene in instances of anti-competitive conduct by big tech firms, including unfair practices and the raising of entry barriers. To date, ex ante market intervention has been generally limited to structural market power issues in specific sectors – such as telecommunications and energy – in order to facilitate the transition from state-owned monopolies to competitive markets. Copying the learnings from the SMP regime to the DMA proposal, whilst Liberty Global recognizes the different set of objectives sought to be achieved by the DMA, the impact of such ex ante regime on incentives for investment and innovation cannot be understated. This seems to be even more relevant for the DMA that would create perpetual ex ante regulation as no gradual replacement by ex post competition law is foreseen. It is essential that any intervention in the digital sector is necessary, appropriate and proportionate to the identified harm, in a manner that balances the benefits against the costs and impact on investment and innovation. Similarly, legal certainty is integral to ensuring continued innovation and investment in the digital sector, and to ensuring the competitiveness of European services and operators. Liberty Global believes that market intervention under the DMA should therefore be based on established competition law practice, which is designed to minimize intervention and is assessed on case-by-case basis.
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Response to Initiative for reviewing and prolonging the “Roaming Regulation”

4 May 2021

Liberty Global welcomes the opportunity to provide feedback on the European Commission’s proposal for an extension of and revisions to the Roaming Regulation. Below is a summary of our positions - our full position is attached. We consider that the wholesale roaming markets are functioning well and that the current caps have been effective as a backstop in the negotiation of wholesale roaming rates. We agree with the objective of the Regulation to give customers a genuine roam-like-at-home experience in terms of quality of service (QoS) while roaming. We are investing heavily in high quality mobile (and fixed) networks, and have a strong desire for our customers to experience a similar service quality while roaming. However, other MNOs have different levels of network coverage and quality – countries across Europe diverge. They make independent investment, innovation and upgrade choices. It is therefore practically impossible to ensure the same quality of services across Europe. The proposals should respect the principle of legal certainty, contractual freedom and the principle of appropriateness and proportionality. We are however concerned that the proposals may have negative consequences on the flexibility of mobile service providers to enter into roaming agreements with partners of their choice. Additionally, the QoS transparency obligations are likely to give rise to significant practical difficulties in their current form. Specifically we refer to Article 9(3)(c) where mobile service providers will be required to specify in their retail contracts the QoS that end-users can reasonably expect when roaming in the EU, including the expected level of QoS. Given the limited control that mobile service providers have over the quality of service experienced by end-users over third-party networks, we can likely provide only high-level contractual information on the QoS that our customers can expect while roaming, as well as information regarding the factors that affect performance. Providing easily understandable and relevant information throughout the entire contractual relationship is essential for customers - the addition of large amounts of redundant information to consumer contracts will ultimately not benefit consumers in the manner intended. We also note that inclusion of warnings in the ‘welcome SMS’ regarding the costs associated with value-added services will further increase the length of the message.In our view, a complex and highly detailed SMS is likely to be counterproductive as it will reduce its usefulness and cause further confusion or result in end-users stopping to read the message altogether. Here, we consider that the Regulation could be clearer on the specific information to be included, and the level of detail required to ensure that the ‘welcome SMS’ retains its utility. We support the proposal for the 10 year duration as it promotes legal certainty and would also strongly support a six (6) month period for companies to implement the changes set out in the Regulation.
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Response to Modification of the General Block Exemption Regulation for the Green Deal and the Industrial and Digital Strategies

5 Apr 2021

Liberty Global welcomes the opportunity to respond to the consultation on the roadmap on the modification of the General Block Exemption Regulation for the Green Deal and the Industrial and Digital Strategies. Liberty Global supports policies that encourage private investment and ensure the efficient and appropriate use of EU and state funds. Private investment is key to achieve the objectives of the Commission’s Green New Deal and the Industrial and Digital strategies. The current General Block Exemption Regulation has been effective in minimising market distortion. It has provided clear rules, which have contributed to regulatory certainty and increased harmonisation of State aid provision across the European Union. We are broadly supportive of the continuance of the current regime. Changes to the General Block Exemption Regulation should be focused on ensuring that State aid is used efficiently, specifically targeting areas and projects where private investment is not viable. Changes to the General Block Exemption Regulation should also align with existing legislation which is seeking to fulfil the aims of the Digital Strategy, including but not limited to the Broadband Cost Reduction Directive and the European Electronic Communications Code. Liberty Global's position is set out in more detail - the EU survey functionality to attach files did not work. We will separately send our position.
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Response to Digital Services Act: deepening the Internal Market and clarifying responsibilities for digital services

31 Mar 2021

Liberty Global welcomes the European Commission’s proposal for a Digital Services Act (DSA) to update the horizontal rules that define the responsibilities and obligations of providers of digital services. The eCommerce Directive was adopted two decades ago and, since then, major market and technological changes have taken place – including the growth of platforms driven by user-generated content and online advertising. This period has also seen a proliferation of the availability of illegal content online, which have given rise to the need to harmonise the rules on removal of illegal online content. The horizontal regime introduced by the eCommerce Directive has worked well and we support the maintenance of this regime within the DSA proposal. Liberty Global prefers a harmonised approach to regulation which ensures a level playing field. However, we recognise that, in some circumstances, it may be appropriate and more proportionate to introduce rules which only apply to those providers where the risk is greatest. These measures should be proportionate and appropriate, to ensure that they do not create excessive regulatory burdens. Liberty Global supports the proposed adoption of a Regulation, rather than a Directive, as it will ensure the desired uniformity across the EU and also ensure legal certainty. Liberty Global's position is set out in more detail in the attached.
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Response to Revision of the NIS Directive

11 Aug 2020

Liberty Global welcomes the opportunity to comment on the European Commission (Commission)’s roadmap for the review of the Union’s rules on the security of network and information systems (the roadmap). This is a valuable step towards a comprehensive evaluation of the NIS Directive. Equally valuable, in our view, is the report assessing the consistency of the approaches in the identification of operators of essential services (OES) published by the Commission in October of 2019 (OES report). The NIS Directive clearly foresees to create a regime adjacent to that applicable to providers of electronic communications networks/services (ECN/ECS). However, the implementation of the NIS Directive has resulted in regulatory fragmentation abolishing this key principle, due to the fact that Member States opted for very different approaches, particularly with regard to the identification of OESs. The Commission correctly concludes that this led to significant inconsistencies, such as diverging security and incident reporting regulatory regimes. Liberty Global welcomes the Commission’s finding that such divergence not only amplifies cybersecurity risk, because parties with critical societal and economic activities remain out of scope, it also undermines the level playing field. This divergence creates a significant additional administrative burden for parties who are – erroneously – regarded as OESs, such as ECN/ECS providers, as recognised by the OES report. Also, the regulatory requirements applicable to OESs not only differ from those applicable to ECN/ECS providers, but also differ between countries, as the roadmap acknowledges. Concurrent application of both regimes is particularly egregious now that some parties with similarly critical societal and economic activities remain wholly out of scope. Liberty Global affirms the Commission’s finding that the growing importance for the society and economy of services of digital service providers (DSPs)’ merits an assessment of the regulatory approach applicable to these services. This is in the interest of the European end-users, who expect resilient and secure networks and services, and for whom the semantic distinction between different types of providers is irrelevant. As we held in previous submissions to the Commission and to ENISA, the importance of regulatory clarity, technological neutrality and a level playing field is paramount to ensure innovation and investment in the digital sector. Innovation and investment are key for consumer welfare. Closely aligning the rules for OESs with those applicable to ECS/ECN providers (and where appropriate to DSPs) will help regulatory oversight and lead to efficiencies. Standardisation can play a key role in achieving a common, high level of security and resilience and further regulatory clarity through the adoption of clear and objective benchmarks. Liberty Global supports the work of ENISA and the European standards development organisations in this field. Concretely, Liberty Global recommends the Commission to focus on policy options 2 and 3, with a view to adopting a mix of non-legislative measures and targeted changes to the NIS Directive. Guidelines can foster the consistent application of the current rules, whereas targeted changes would be appropriate to secure a consistent application of key definitions in the process of OES identification. Also, targeted changes can ensure a level playing field is applicable to DSPs, OESs and providers of ECN/ECS, where these provide services of similar economic and societal criticality. To maintain regulatory stability, Liberty Global opposes a full overhaul of the NIS Directive (option 4). Liberty Global looks forward to engaging further with the Commission on potential changes to the regulatory framework in the context of the roadmap.
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Meeting with Anthony Whelan (Cabinet of President Ursula von der Leyen)

24 Jun 2020 · Ongoing merger proceedings; jurisdiction & substance.

Meeting with Roberto Viola (Director-General Communications Networks, Content and Technology) and Telefonica, S.A.

29 May 2020 · Telefonica Liberty Gobal agreement (virtual)

Meeting with Alina-Stefania Ujupan (Cabinet of Executive Vice-President Margrethe Vestager)

19 May 2020 · Connectivity and mitigating measures during the Covid-19 crisis

Meeting with Bernardus Smulders (Cabinet of First Vice-President Frans Timmermans)

6 Dec 2018 · e-privacy, Digital Services Tax, Foreign Direct Investment, Competition Policy

Meeting with Andrea Almeida Cordero (Cabinet of Commissioner Mariya Gabriel)

13 Apr 2018 · Women in Digital

Meeting with Manuel Mateo Goyet (Cabinet of Commissioner Mariya Gabriel)

9 Jan 2018 · Copyright

Meeting with Marlene Madsen (Cabinet of Vice-President Jyrki Katainen)

11 Oct 2017 · Innovation, Industrial Strategy and Digital Single Market

Meeting with Anthony Agotha (Cabinet of First Vice-President Frans Timmermans)

11 Oct 2017 · Exchange of views on the future of Europe

Meeting with Kamila Kloc (Cabinet of Vice-President Andrus Ansip)

11 Oct 2017 · Telecom review framework

Meeting with Mariya Gabriel (Commissioner) and Telenet Group Holding

6 Sept 2017 · Digital policy

Meeting with Kamila Kloc (Cabinet of Vice-President Andrus Ansip)

20 Mar 2017 · Telecom review

Meeting with Andrus Ansip (Vice-President) and

27 Feb 2017 · 5G, roaming, spectrum, investment consolidation

Meeting with Andrus Ansip (Vice-President) and

19 Jul 2016 · Market developments and telecom review

Meeting with Markus Schulte (Digital Economy)

7 Jul 2016 · Telecom policy

Meeting with Fabrice Comptour (Cabinet of Commissioner Elżbieta Bieńkowska), Kaius Kristian Hedberg (Cabinet of Commissioner Elżbieta Bieńkowska) and

6 Jul 2016 · Broadband speeds & needs

Meeting with Adrienn Kiraly (Cabinet of Commissioner Tibor Navracsics), Szabolcs Horvath (Cabinet of Commissioner Tibor Navracsics)

22 Apr 2016 · Digital Single Market

Meeting with Anna Herold (Digital Economy)

17 Dec 2015 · copyright

Meeting with Eduard Hulicius (Cabinet of Commissioner Věra Jourová), Simona Constantin (Cabinet of Commissioner Věra Jourová)

17 Nov 2015 · Digital single market issues

Meeting with Nele Eichhorn (Cabinet of Vice-President Cecilia Malmström)

16 Nov 2015 · Copyright & content portability

Meeting with Szabolcs Horvath (Cabinet of Commissioner Tibor Navracsics)

16 Nov 2015 · Digital Single Market

Meeting with Markus Schulte (Digital Economy)

23 Sept 2015 · DSM

Meeting with Kamila Kloc (Cabinet of Vice-President Andrus Ansip)

23 Sept 2015 · Review of telco framework including access and consolidation

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

22 Jul 2015 · Telecom, copyright

Meeting with Markus Schulte (Digital Economy)

22 Jul 2015 · Telecommunication Policy

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

22 Jul 2015 · Digital Single Market

Meeting with Michael Hager (Digital Economy)

16 Apr 2015 · DSM

Meeting with Anna Herold (Digital Economy)

6 Mar 2015 · Telecoms

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

5 Mar 2015 · Broadband telecom, copyright

Meeting with Günther Oettinger (Commissioner) and Telefonica, S.A. and

3 Mar 2015 · DSM, TSM

Meeting with Jasmin Battista (Cabinet of Vice-President Andrus Ansip)

29 Jan 2015 · Innovative digital TV services

Meeting with Frans Timmermans (First Vice-President)

22 Jan 2015 · Better regulation

Meeting with Aare Järvan (Cabinet of Vice-President Andrus Ansip), Kamila Kloc (Cabinet of Vice-President Andrus Ansip)

4 Dec 2014 · Telecoms Single Market, broadband, consolidation

Meeting with Michael Hager (Digital Economy)

3 Dec 2014 · Regulatory framework

Meeting with Heidi Jern (Cabinet of Vice-President Jyrki Katainen)

3 Dec 2014 · Investments and innovations in the digital sector