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Réseaux IP Européens (RIPE) Network Coordination Centre (NCC)

RIPE NCC

The RIPE NCC is a not-for-profit organisation that works to support the RIPE (Réseaux IP Européens) community and the wider Internet community.

Lobbying Activity

Response to International Digital Strategy

21 May 2025

We thank the European Union for the opportunity to contribute to its external digital policy strategy. As one of the five Regional Internet Registries (RIRs) that allocate and register Internet number resources, the RIPE NCC welcomes and supports the EUs efforts aimed at safeguarding the interoperability, availability and integrity of the global Internet, especially in the context of the World Summit on the Information Society review (WSIS+20) taking place throughout 2025. As part of WSIS+20, the EU can reinforce its support for bottom-up multistakeholder governance by ensuring that the WSIS Action Lines remain technology-neutral and inclusive. Strengthening collaboration with Internet technical bodies in shaping the post-WSIS agenda will help advance the EUs strategic goals for a secure, open, and globally interoperable digital future. As the backbone of digital transformation, the Internet must remain a stable and unified platform. Preserving its core architectural elements is essential for enabling digital innovation, advancing Human Rights and achieving the UNs Sustainable Development Goals (SDGs). WSIS+20 provides the opportunity to reflect on, and reinforce, the foundational principles of the Internet and its open, distributed, and globally interoperable architecture, which has enabled innovation and connectivity for billions of users. To safeguard these principles, Internet governance must be truly inclusive, integrate bottom-up processes, and guarantee the impartiality and interoperability necessary to ensure a well-functioning Internet globally. We also encourage the EU to support the Internet Governance Forum (IGF), an institution created by WSIS, as a stable and inclusive platform for continued dialogue and shared responsibility, which will allow for strong alignment across other frameworks such as the Global Digital Compact (GDC) and SDGs. To this end, we call on the EU to support a renewed and permanent mandate for the IGF with a sustainable funding model, alongside a reinforced UN mechanism aligned with the technology-neutral WSIS Action Lines. The RIPE NCC supports the EU's efforts and aspirations to become a leader in digital innovation and enhance its security and competitiveness on the global stage. For this, we encourage the EU to further align its regulatory policy approach and digital diplomacy tools with these strategic goals. We also support the strong emphasis placed by the EU on public policy principles and objectives geared towards respecting and promoting human rights, enhancing information security and privacy, and fostering economic development and social inclusion. With this in mind, we encourage the EU to prioritise engagement and capacity building with key international partners and organisations, including well-established technical bodies such as the IETF, ICANN, the RIRs. Supporting the Internets technical development in underserved regions through capacity building, measurement tools, and infrastructure development is essential to closing the global digital divide. In an era where digital protectionism and Internet fragmentation are gaining ground, the EUs leadership is crucial for defending the global, end-to-end nature of the Internet. We encourage the EU to actively counter initiatives that lead to fragmentation by reinforcing its support for globally coordinated, interoperable technical governance frameworks. To ensure that the Internet continues to serve as a catalyst for innovation, growth, and empowerment worldwide, we encourage the EU to strengthen its multistakeholder approach and prevent governmental initiatives that would undermine the foundational principles of an open, inclusive, and secure Internet. Finally, recognising the role of, and enhancing collaboration with, established Internet standards-setting and policy development bodies will be key to strengthening the EUs endeavour and leadership in Internet and digital governance on the global stage.
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Response to Rules specifying the obligations laid down in Articles 21(5) and 23(11) of the NIS 2 Directive

25 Jul 2024

Please find the comments from the RIPE NCC in the document attached.
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Response to Cyber Resilience Act

23 Jan 2023

As the Regional Internet Registry for Europe, the Middle East and parts of Central Asia, the RIPE NCC welcomes the opportunity to give feedback on the European Commission's proposed Cyber Resilience Act. In the attached document, we explain how we foresee the Cyber Resilience Act impacting the RIPE NCC's own operations and services, and areas in which we believe further clarity is needed. In addition, we include viewpoints from the wider RIPE community, which is made up of technical operators, open-source developers and others responsible for maintaining much of the Internet's technical infrastructure within Europe and beyond.
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Response to Enhancement of European policy on critical infrastructure protection

8 Apr 2021

The RIPE NCC has contributed to the development of the Internet in Europe for nearly thirty years and provides a number of technical services that support the functioning of the global Internet, including operating one of the world’s 13 global DNS root servers (K-root) and acting as the Regional Internet Registry for Europe. As such, we welcome the opportunity to share our feedback on the European Commission’s adoption of the proposed Critical Entities Resilience (CER) Directive. We believe the CER Directive has the potential to affect not only our own operations and those of a large number of other digital service providers, but the European Union’s fundamental approach to Internet governance. The RIPE NCC fully understands the European Commission’s need to update the existing European Critical Infrastructure (ECI) Directive and expand the breadth of sectors under scope to include digital infrastructure, as the healthy functioning of European societies and economies has undeniably become reliant on digital infrastructure, services and operators. However, as we stated in our response to the European Commission’s adoption of the proposed NIS 2 Directive (https://www.ripe.net/participate/internet-governance/multi-stakeholder-engagement/ripe-ncc-response-to-nis-2-directive_march-2021.pdf), we believe that including root server operations under the CER Directive’s scope (via the definitions used in NIS 2) could in fact threaten, rather than strengthen, the resiliency of those operations that form the backbone of the global domain name system (DNS) and, by extension, the healthy functioning of the European digital single market. In our response to NIS 2, the RIPE NCC urged the European Commission, Parliament and Council, as well as EU member states, to heed the concerns of the DNS operator community regarding the far-reaching and unintended consequences that the current proposal would have on DNS operations in the EU. We will not repeat those concerns in full here; however, we believe they threaten DNS operations to such an extent that we asked for root server operators to be excluded from the NIS 2 Directive’s scope in order to allow them to continue to operate according to the proven bottom-up, multistakeholder model of self-governance that has strengthened the resiliency of the DNS throughout the Internet’s history. If root server operators are indeed excluded from the NIS 2 Directive’s scope, we would urge the European Commission to maintain complete consistency between the NIS 2 and CER Directives in order to ensure that member states do not subsequently identify root server operators as critical entities under the CER Directive. Any divergence between the two directives would only cause confusion and lead to further de-harmonisation among member states. We appreciate the European Commission’s efforts throughout its proposed CER Directive to ensure consistency between the two directives. However, we question whether and how the CER Directive would come into force in the event that the NIS 2 Directive had not yet been agreed on, and would ask for further clarification on that matter, as the proposed CER Directive is heavily reliant on the definitions set out in the proposed NIS 2 Directive. The RIPE NCC also appreciates the emphasis on taking a holistic view of the interactions between different sectors and the impact that disruptions in one sector might have on others. However, we note the importance of extending this holistic view to compliance, in ensuring that compliance measures taken in one sector do not negatively impact providers in other critical sectors who are governed under other (potentially conflicting) directives or regulations. As always, the RIPE NCC remains committed to working with the European Commission, Parliament, Council and EU member states to share its technical expertise and facilitate knowledge sharing between those institutions and the European technical community.
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Response to Digital Services Act: deepening the Internal Market and clarifying responsibilities for digital services

31 Mar 2021

As an organisation that has contributed to the technical operation and development of the Internet in Europe for nearly 30 years, the RIPE NCC appreciates the opportunity to give its feedback on the adoption of the European Commission’s proposed Digital Services Act (DSA). Overall, the RIPE NCC believes that the Commission’s proposal is balanced and that it takes into consideration the need to protect the public core of the Internet and to establish proportionate thresholds for interfering with core functions, infrastructure and service providers, which was the paramount goal we put forward in our response to the open consultation on the DSA last September (https://www.ripe.net/participate/internet-governance/multi-stakeholder-engagement/ripe-ncc-position-paper-on-digital-services-act.pdf). We happily note that the DSA proposal preserves key principles of the E-Commerce Directive, including the limited liability regime for online intermediary service providers, a prohibition on general monitoring obligations, and the country of origin principle. The proposal also addresses the concerns we raised in our previous response by placing an emphasis on targeting the service providers who are best able to satisfy notice and takedown obligations while minimising the potential for collateral damage to other services or operations. As explained in our previous response, we felt that expanding the scope of the DSA to include harmful content, along with the inclusion of a voluntary own-initiative investigations clause, could easily have paved the way for intentional abuse by bad actors. We are therefore pleased to see that the proposal makes a distinction between “harmful” and “illegal” content, and stresses the importance of protecting fundamental rights online. Similarly, we are pleased that the proposal’s inclusion of a voluntary own-initiative investigations clause stresses that content or access removal should be carried out with freedom of expression in mind, and that any notice and action requests must be “sufficiently precise and adequately substantiated” to allow the service provider to assess for themselves whether to take action against illegal content. We believe this will significantly mitigate the potential for abuse. In reading the Commission’s proposal, the RIPE NCC has identified one aspect that could benefit from further clarification, which is the definition of online platforms as those that make information available to a “potentially unlimited number of persons”. This would seem to include all manner of websites, blogs, online fora, etc. that allow for user-generated content (e.g. comments). It remains unclear to us, for example, whether an online forum with a defined, targeted audience would fall under scope. We also believe that more clarity is needed around the level of editorial responsibility that an online platform can have over content in terms of its obligations under the DSA. For example, if a forum allows users to post articles (and comments on those articles) and provides an editorial review of that content but does not check its accuracy, it is unclear whether that platform would be considered an online platform under the DSA's scope and whether the liability exemption would apply in these circumstances, given the limited nature of this level of editorial oversight. In that regard, further clarification around specific use cases would be helpful. In conclusion, the RIPE NCC commends the European Commission in drafting a balanced proposal, including important provisions to protect the public core of the Internet and ensure that it can continue to operate, innovate, and serve the needs of European citizens. We urge the European Parliament and Council to maintain these safeguards as they develop their respective positions on the DSA.
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Response to Revision of the NIS Directive

18 Mar 2021

As an organisation tasked with operating one of the world’s 13 global DNS root servers (K-root), the RIPE NCC appreciates the opportunity to share its views on the proposed text of the European Commission’s NIS 2 Directive and to express some concerns about how we understand the proposed legislation would affect global domain name system (DNS) operations. We believe the directive, as proposed, could have unintended consequences due to overreach, that it risks reducing the resiliency of the global Internet, and that it would undermine the goal of the IANA stewardship transition by once again subjecting the DNS root zone distribution to government oversight. Please see our full response, attached, for an explanation of these points and links to supporting information sources. We strongly urge the European Commission, Parliament and Council, as well as EU member states, to listen to the concerns of the DNS operator community regarding the far-reaching, unintended consequences that the current proposal would have on DNS operations in the EU. For our part, the RIPE NCC proposes that the root server operators should be exempt from the scope of the NIS 2 Directive.
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