Združenie používateľov Slovenskej akademickej dátovej siete SANET
SANET
Združenie používateľov Slovenskej akademickej dátovej siete SANET je samostatnou právnickou osobou so sídlom v Bratislave.
ID: 139929639150-16
Lobbying Activity
Response to Revision of the NIS Directive
6 Aug 2020
SANET - Slovak Academic Network Association, highly welcomes EC initiative to revise the NIS directive. Its transposition in member states lead to significantly different and sometimes even confusing results, which definitely needs to be addressed shortly. A very good example could be found in Table 4 of Report COM(2019) 546 final, which shows how much different thresholds to identify Operators of Essential Services have been applied in EU members states.
As an example, in Slovakia the threshold for DNS providers was set at 1000 domains, while in other countries it's 50000, 100000 or even 250000 domains. This is huge difference: upto 250-times.
The situation is even worse with Internet Exchange Points (IXPs). In Slovakia, the threshold was set as follows: "Autonomous system (AS) connecting at least two other AS with 2 Gbps". Not only there is again 50 upto 150-times difference compared to other countries (which set the threshold to 100 or 300 AS or 200 Gbps of traffic), but these thresholds lead to situation, where completely unrelated companies (internet service providers, telecom operators or even private networks) were identified as Operators of Essential Service of Internet Exchange Point - even though none of them provides IXP services. All this despite Commision's communication COM(2017) 476 final/2 Annex 1 section 4.1, which explicitly states, that internet service providers & telecom operators shouldn't be identified in this category.
Due to the above serious problems with NIS Directive implementation, we strongly believe that harmonisation and urgent action at EU level is needed, otherwise the competition and prices for end-users could be negatively impacted by excessive regulation in some countries like Slovakia.
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