Digital Networks Act

215 submissions in the snapshot (202 from organisations), portal total 215. Feedback list on the portal.

202 of 202 organisation submissions analysed; the model reads them as: opposes 3 supports 14 wants changes 104 81 held back for review (low confidence).

• Micro company, IRL NGO, IRL model reads as: supports source
  • Ensure copper switch-off is prioritized as the critical final step in completing the transition away from legacy copper networks.

    Copper switch-off is not the beginning of this journey; it is the step that finishes it.

  • Achieve near-ubiquitous adoption and take-up of high-capacity connectivity, not merely availability alone.

    But availability is not the same as adoption. For individuals, businesses, farms, and communities to fully benefit, near-ubiquitous take-up is required.

  • Establish universal and dependable connectivity to enable Europe to attract remote work opportunities and unlock the associated social, economic and environmental benefits.

    Ireland, with its strong digital infrastructure and talent base, is well positioned to attract a leading share of these roles, but only if connectivity is universal and dependable.

• Micro company, BEL NGO, BEL model reads as: opposes source
  • Prioritize cabled (wired) connections over wireless for stability and health, particularly for children.

    Demands prioritizing cabled (wired) connections over wireless for stability and health, particularly for children.

  • Immediately replace wireless with cables in schools, kindergartens, hospitals, and retirement homes.

    Suggests the immediate replacement of wireless with cables in schools, kindergartens, hospitals, and retirement homes.

  • Conduct a comprehensive health impact assessment regarding RF-EMF radiation before auctioning new frequency bands.

    Demands a comprehensive health impact assessment regarding RF-EMF radiation before auctioning new frequency bands.

• Seznam.cz, a.s. Company, CZE; register: Professional consultancies model reads as: wants changes source
  • Ensure full legal clarity that the DNA will not impose payment obligations for online services, except in strictly limited cases involving Very Large Online Platforms.

    From the perspective of our company, it is essential to ensure full legal clarity that the DNA will not leadeither directly or indirectlyto any obligation for online services to pay for the transmission of content over networks, except, if at all, in strictly limited cases involving Very Large Online Platforms (VLOPs).

  • Include explicit safeguards in the DNA that content providers are not required to pay for the delivery of traffic over networks.

    The DNA should therefore explicitly safeguard the principle that content providers are not required to pay for the delivery of traffic over networks.

  • Prevent any future reopening or extension of network payment obligations beyond Very Large Online Platforms to broader market players.

    Under no circumstances should this discussion be reopened or extended in the future to cover a broader range of market players.

• MAIN ALTERNATIVE TELECOMMUNICATIONS OPERATORS IN SPAIN Other, ESP model reads as: supports source
  • Preserve the three-criteria test and SMP-based ex ante regulation in markets where structural market failures persist.

    The operators therefore strongly support the DNAs explicit preservation of the three-criteria test and SMP-based ex ante regulation in markets where structural market failures persist.

  • Retain this regulatory approach in the final text of the Digital Networks Act.

    This approach should be retained in the final text of the DNA.

  • Apply simplification and deregulation only in markets where effective competition has clearly emerged.

    Simplification and deregulation are appropriate only where effective competition has clearly emerged.

• Verbraucherzentrale Bundesverband e.V. (Federation of German Consumer Organisations - vzbv) Consumer organisation, DEU; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • Adopt the DNA as a directive or, if adopted as a regulation, include explicit opening clauses enabling Member States to impose additional consumer protections.

    The DNA should be adopted as a directive with respect to the persistent heterogeneity of telecommunications markets and therefore the need for Member States to provide solutions for national problems. Should legislators nonetheless opt for a regulation, it must contain explicit opening clauses enabling Member States to impose additional consumer protections or implement tailored regulatory measures.

  • Extend the right to terminate contracts following unilateral amendments from one month to three months after notification.

    To give consumers sufficient time to react, the right to terminate the contract following unilateral amendments should continue to be exercisable within three months of notification, rather than just one month as proposed.

  • Reduce the maximum commitment period for telecommunications contracts to 12 months to enhance consumer flexibility.

    The maximum commitment period for telecommunications contracts should be reduced to 12 months to enhance consumer flexibility and incentivise better customer service.

• NOKIA Company, FIN; register: Companies & groups model reads as: supports source
  • Implement early copper switch-off and migration to fiber to support EU digital network goals, economic growth, sustainability, and innovation.

    advocates for an early copper switch-off and migration to fiber, as a critical enabler for the EU's digital network goals, driving economic growth, sustainability, and innovation.

• DE-CIX Company, DEU model reads as: opposes source
  • Remove or significantly narrow Articles 191-193 of the Digital Networks Act.

    DE-CIX argues that additional regulation is unnecessary and that Articles 191 - 193 should either be removed or significantly narrowed.

  • Keep the Open Internet Regulation and net neutrality safeguards unchanged as they are central to competition, openness, and interoperability.

    DE-CIX also warns that the Open Internet Regulation and net neutrality safeguards should remain unchanged, as they are central to competition, openness, and interoperability.

  • Preserve supporting recitals when integrating the Open Internet Regulation into the DNA framework to avoid legal uncertainty.

    There is also concern that integrating the Open Internet Regulation into the broader DNA framework without preserving its supporting recitals could create legal uncertainty and weaken existing protections.

• CSUC - CATNIX Academic or research institution, ESP model reads as: opposes source
  • Delete or significantly narrow Articles 191-193 of the Digital Networks Act.

    calls for Articles 191 - 193 to be deleted or significantly narrowed

  • Keep the Open Internet Regulation and net neutrality safeguards unchanged.

    and for the Open Internet Regulation and net neutrality safeguards to remain unchanged

  • Avoid additional regulation of IP interconnection as the current market is efficient, competitive, and self-regulating.

    Additional regulation is therefore unnecessary and risks creating fragmentation, legal uncertainty, and pressure on established peering practices

• EuroISPA-The European Association of Internet Services Providers Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Simplify the regulation through a more cautious, evidence-based approach to preserve stability of existing rules.

    We urge a more cautious, evidence-based approach that preserves the stability of existing rules.

  • Oppose the proposed Office for Digital Networks and maintain the BEREC-led model for regulatory independence.

    We oppose the proposed Office for Digital Networks as duplicative and overly centralising. We recommend maintaining and strengthening the proven BEREC-led model to safeguard regulatory independence and subsidiarity.

  • Set resilience obligations to target maximum achievable resilience rather than unrealistic uninterrupted availability.

    Obligations should target maximum achievable resilience and rapid recovery not unrealistic "uninterrupted availability" and must align with NIS2 and the Critical Entities Resilience Directive.

• European Union of the Deaf NGO, BEL; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • Introduce an unconditional obligation for Member States to ensure native and seamless provision of Total Conversation across all electronic communications and emergency communications services.

    The DNA fails to introduce an unconditional obligation for Member States to ensure the native and seamless provision of Total Conversation (TC) across all electronic communications and emergency communications services.

  • Establish enforceable obligations to guarantee 24/7 availability of video relay services and harmonised minimum EU standards.

    The DNA contains no enforceable obligation to guarantee 24/7 availability of video relay services, nor does it establish harmonised minimum EU standards.

  • Add provisions ensuring accessibility of public warning systems in national sign languages for deaf people to receive life-critical emergency information in their first language.

    The DNA makes no reference to the accessibility of public warning systems in national sign languages.

• EBU-UER (European Broadcasting Union) Other, BEL; register: Trade unions and professional associations model reads as: supports source
  • The DNA should ensure that broadcasters can use spectrum for broadcasting and that services of general interest remain present in cable, satellite, and IPTV networks.

    They ensure broadcasters can use spectrum for broadcasting, services of general interest are present in cable, satellite and IPTV, and broadcast radio is present in car radio receivers.

  • Net neutrality rules should be maintained as a key component of the Digital Networks Act.

    Net neutrality rules are also key in this context.

  • The DNA framework should be recognized and preserved as essential for enabling public service media to fulfill their remit.

    The rules contained in the DNA are essential to enable public service media to fulfill their remit: reach everyone in the country to inform, educate and entertain.

• Ensemble pour le DAB+ Business association, FRA; register: Trade unions and professional associations model reads as: wants changes source
  • Ensure all new vehicles of categories M, N and L are equipped as standard with FM and DAB+ radio receivers.

    Tous les véhicules neufs des catégories M, N et L soient équipés en standard d'un récepteur FM et DAB+ ;

  • Use the Digital Networks Act as the appropriate legislative framework to establish this radio receiver requirement in a harmonized legal context.

    Le DNA constitue l'opportunité législative appropriée pour inscrire cette obligation dans un cadre juridique harmonisé.

• Meta Company, USA; register: Companies & groups model reads as: wants changes source
  • Withdraw the extension of telecom regulatory scope to private networks, content delivery networks, and non-telecom actors.

    Withdraw the extension of scope of the telecom regulatory framework to private networks, content delivery networks (CDNs) and non-telecom actors (Article 9.2-9.4);

  • Clarify that the interconnection regime applies only to public networks and remove the voluntary conciliation facility.

    Clarify that the interconnection regime and related dispute resolution mechanism applies only to relationships between public electronic communications networks, and remove the voluntary conciliation facility which is unnecessary (Articles 65-68, 189, 191-193);

  • Preserve the net neutrality regime by fully incorporating the Open Internet Regulation into the DNA.

    Preserve the net neutrality regime as it stands today by fully incorporating the Open Internet Regulation (OIR) into the DNA including the OIR recitals and maintain BERECs role in developing implementing guidance (Article 93);

• ITI - Information Technology Industry Council Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Address structural and substantive issues in the proposal that risk undermining the stated objectives.

    ITI has identified several structural and substantive issues that risk undermining these objectives if left unaddressed.

  • Reduce reliance on broad definitions and extensive delegation to future guidelines to avoid legal uncertainty and inappropriate extension of telecom obligations.

    the proposal relies heavily on broad definitions and extensive delegation to future guidelines and implementing measures. This approach creates legal uncertainty, expands regulatory discretion, and risks extending telecom-style obligations to actors across the digital value chain without clear legislative intent.

  • Make targeted legislative amendments and clarifications to improve legal certainty, proportionality and Single Market coherence.

    identifies targeted areas where legislative amendments or clarifications would materially improve legal certainty, proportionality and Single Market coherence.

• European Pirate Party NGO, LUX model reads as: wants changes source
  • Remove or significantly limit the Commission's implementing act power under Article 93(6) over specialised services to preserve Parliament and BEREC's independent oversight.

    the new implementing act power granted to the Commission under Article 93(6) over the conditions for specialised services risks shifting key decisions about the open internet away from Parliament and away from BERECs independent oversight

  • Add clearer limits to security and resilience provisions to prevent mass monitoring and data retention without judicial oversight.

    the security and resilience provisions need clearer limits to ensure they cannot be read as authorising mass monitoring of communications or data retention without judicial oversight

  • Provide adequate and enforceable protection for the 10% of users not yet reached by fibre networks under the copper switch-off derogation mechanism.

    it leaves the 10% of users not yet reached by fibre networks without adequate, enforceable protection

• TDC Brands / TDC NET Company, DNK model reads as: wants changes source
  • Limit sector-specific obligations to clear cases of market failure and rely more on horizontal frameworks.

    The DNA should act as a genuine simplification exercise, limiting sector-specific obligations to clear cases of market failure and relying more on horizontal frameworks to enhance legal certainty and support long-term investment.

  • Prioritise predictable, investment-friendly conditions and ensure greater regulatory consistency across Member States.

    Given the capital-intensive nature of connectivity, the DNA should prioritise predictable, investment-friendly conditions that reflect deployment risks and enable sustainable returns. Greater regulatory consistency across Member States is essential.

  • Improve spectrum policy with longer licence durations, predictable renewal conditions and pricing aligned with sustainable network deployment.

    Spectrum policy must better support investment, with longer licence durations, predictable renewal conditions and pricing aligned with sustainable network deployment.

• Open Fiber Austria Association (OFAA) Other, AUT model reads as: supports source
  • Establish national copper-glass migration plans by 2029 at the latest.

    National copper-glass migration plans by 2029 at the latest.

    machine translation by the Commission, original in DE
  • Focus support on FTTH networks with a mandatory open access obligation.

    Consistently focus support on FTTH with an open access obligation.

    machine translation by the Commission, original in DE
  • Recognize wholesale-only models as a legitimate competitive tool in digital networks.

    Recognise wholesale-only models as a competitive tool.

    machine translation by the Commission, original in DE
• Telefónica, S.A. Company, ESP; register: Companies & groups model reads as: wants changes source
  • Ensure spectrum provisions are robust, predictable and immediately applicable.

    Without substantial improvements ensuring that spectrum provisions are robust, predictable and immediately applicable, the DNA will not meet the needs of the sector

  • Deliver an effective and investment-oriented spectrum framework.

    However, its success fundamentally depends on delivering an effective and investment-oriented spectrum framework.

• freenet AG Company, DEU; register: Companies & groups model reads as: wants changes source
  • Establish a Union-wide, non-discriminatory access right to mobile networks to prevent imbalance between infrastructure development and competition promotion.

    a Union-wide, non-discriminatory access right to mobile networks is essential to prevent an imbalance between infrastructure development and the promotion of competition.

  • Limit the duration of spectrum rights to a maximum of 20 years to ensure the mobile market remains manageable and consumer-friendly.

    the duration of spectrum rights must be limited to a maximum of 20 years to ensure the mobile market remains manageable, sustainable, and consumer friendly.

  • Reverse the burden of proof so that mobile network operators must demonstrate that pro-competitive obligations are not necessary.

    a reversal of the burden of proof is required: mobile network operators must demonstrate that pro-competitive obligations are not necessary.

• Open Fiber SpA Company, ITA; register: Companies & groups model reads as: wants changes source
  • Complete the legislative process rapidly with targeted amendments to ensure investor certainty.

    complete the legislative iter as fast as possible and with targeted amendments to focus on the implementation of the measures providing certainty to investors and undertakings.

  • Accelerate the copper switch-off timeline to realize benefits for investments, security and sustainability.

    accelerate the timeline for the CSO anticipating the benefits in terms of investments, security and sustainability

  • Maintain cost orientation as a relevant remedy for SMP operators during the transition phase following copper switch-off.

    consider that cost orientation may remain as one of the most relevant remedy for SMP operators, particularly during the transition phase, while allowing regulatory approaches to evolve as competitive dynamics develop following copper switch-off.

• Cloudflare Company, USA; register: Companies & groups model reads as: wants changes source
  • Refine the Digital Networks Act to target actual market failures rather than imposing burdens on well-functioning interconnection markets.

    we urge policymakers to refine the DNA to ensure that it targets actual market failures where regulatory intervention is needed rather than imposing burdens on well-functioning and competitive interconnection markets.

  • Do not extend telecommunications-style regulation to cloud and content-delivery sectors.

    Despite the Commissions statement that it does not seek to regulate cloud services, several measures would extend telecommunications-style regulation to the cloud and content-delivery sectors, curtailing the deployment of new innovative services and undermining the EUs effort to be a leader in the digital age.

  • Avoid imposing unnecessary costs and burdens on European end-users and SMEs through the Digital Networks Act.

    To better achieve the Commissions aims and to avoid imposing unnecessary costs and burdens on European end users and SMEs, we urge policymakers to refine the DNA to ensure that it targets actual market failures where regulatory intervention is needed rather than imposing burdens on well-functioning and competitive interconnection markets.

• Micro company, CZE Business association, CZE model reads as: wants changes source
  • Implement real deregulation by shifting from SMP-based ex ante regulation to symmetric regulation as the default approach.

    real deregulation via a shift from SMP-based ex ante to symmetric regulation as default

  • Remove redundant sector-specific and reporting obligations to genuinely reduce administrative burden.

    removal of redundant sector-specific and reporting obligations

  • Ensure technology neutrality and guarantee long-term spectrum access for terrestrial broadcasting.

    technology neutrality, including long-term conditions for terrestrial broadcasting

• WorldDAB Business association, GBR; register: Trade and business associations model reads as: wants changes source
  • Mandate broadcast radio receivers in all new vehicles placed on the EU market across specified vehicle categories.

    ensure broadcast radio receivers are present in all new vehicles placed on the EU market, not only those equipped with a radio tuner, across at least the following categories: passenger cars (M), commercial vehicles (N), light vehicles (L6, L7) and agricultural vehicles (T);

  • Ensure both analogue and digital terrestrial broadcast radio remains available in new vehicles reflecting market practice and public safety objectives.

    ensure that both analogue and digital terrestrial broadcast radio remains available in new vehicles, reflecting current market practice, consumer expectations and public safety objectives.

• Vodafone Group Company, GBR; register: Companies & groups model reads as: wants changes source
  • The Digital Networks Act should be further refined to ensure it delivers a coherent, futureproof and effective regulatory framework.

    further refinement is needed to ensure the DNA delivers a coherent, futureproof and effective regulatory framework

  • The DNA should be strengthened with a focus on supporting investment and ensuring sustainable competition.

    targeted proposals to strengthen the DNA, with a focus on supporting investment, ensuring sustainable competition

  • The framework should be aligned and modernised with technological and market developments to deliver tangible benefits for Europe's digital economy.

    aligning and modernising the framework with technological and market developments, so that it delivers tangible benefits for Europes digital economy

• Czech Association of Electronic Communications Business association, CZE; register: Trade and business associations model reads as: wants changes source
  • Shift from SMP-based ex ante regulation to symmetric regulation as the default approach for electronic communications.

    We call for the DNA to be fundamentally redrafted: (1) real deregulation via a shift from SMP-based ex ante to symmetric regulation as default

  • Remove redundant sector-specific and reporting obligations from the proposal.

    (2) removal of redundant sector-specific and reporting obligations

  • Limit centralised EU-wide spectrum authorisation strictly to satellite networks and preserve Member State competence for spectrum assignment.

    centralised EU-wide spectrum authorisation (Art. 22) must be limited strictly to satellite networks spectrum is a national resource and its assignment must remain with national regulators

• Eurofiber Company, NLD; register: Companies & groups model reads as: wants changes source
  • The DNA should preserve and reinforce established principles of competition, market entry, infrastructure investment, proportionate access regulation and customer choice.

    The DNA should preserve and reinforce the principles that have made European telecoms regulation successful: competition, market entry, infrastructure investment, proportionate access regulation and customer choice.

  • The DNA should not become a vehicle for relaxing competitive discipline on incumbents, imposing excessive harmonization, or replacing evidence-based market analysis with uniform EU-level solutions.

    The DNA should not become a vehicle for relaxing competitive discipline on incumbents, imposing excessive harmonization or replacing evidence-based market analysis with uniform EU-level solutions.

  • The regulatory framework should be predictable, protect efficient infrastructure competition, prevent both excessive and strategically low SMP pricing, ensure regulatory certainty and allow NRAs to tailor remedies to real local market conditions.

    Investment is best supported by a regulatory framework that is predictable, protects efficient infrastructure competition, prevents both excessive and strategically low SMP pricing, ensures regulatory certainty and allows NRAs to tailor remedies to real local market conditions.

• Transatel Company, FRA; register: Companies & groups model reads as: wants changes source
  • Preserve periodic spectrum reviews and reject unlimited or auto-renewing licenses.

    preserve periodic spectrum reviews and reject unlimited/auto-renewing licences (Arts. 2425)

  • Remove the higher threshold and Commission veto powers over pro-competitive spectrum conditions.

    strip out the higher threshold and Commission veto powers over pro-competitive spectrum conditions (Arts. 3132)

  • Delete the Article 85 veto over SMP remedies.

    delete the Article 85 veto over SMP remedies

• Radio France Company, FRA model reads as: wants changes source
  • Make FM and DAB+ radio receivers mandatory as standard equipment in all new vehicles of categories M, N and L.

    All new vehicles of categories M, N and L are equipped with FM and DAB + receivers as standard

    machine translation by the Commission, original in FR
  • Ensure radio is effectively accessible in vehicle interfaces through direct physical access and/or homepage visibility.

    Radio is effectively accessible in in-vehicle interfaces, through direct physical access and/or visibility from the home page of the multimedia console

    machine translation by the Commission, original in FR
  • Use the Digital Networks Act as the legislative framework to enshrine the mandatory radio receiver obligation.

    The DNA is the appropriate legislative opportunity to enshrine this obligation in a harmonised legal framework

    machine translation by the Commission, original in FR
• Micro company, GRC Company, GRC model reads as: wants changes source
  • Exempt kiosks and small retailers from the obligation to issue digital delivery notes, at least for reimbursements.

    We call for the complete exemption of kiosks and small buralistes from the obligation to issue digital delivery notes (at least for reimbursements)

    machine translation by the Commission, original in EL
  • Transfer the responsibility for digital delivery notes exclusively to large wholesalers and suppliers with the necessary infrastructure.

    or at least for this responsibility to be transferred exclusively to the large wholesalers and suppliers with the infrastructure and staff.

    machine translation by the Commission, original in EL
  • Hear the concerns of small retailers regarding the practical feasibility of implementing digital delivery note requirements before enforcement.

    Please listen to the voice of the market before the small retail, which has been supporting the Greek neighbourhood for decades, disappears once and for all.

    machine translation by the Commission, original in EL
• Europeans for Safe Connections NGO, BEL; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • Apply the principle of proportionality when granting rights of use for radio spectrum.

    When granting rights of use for radio spectrum, Member States shall ensure that such rights are subject to the principle of proportionality.

  • Conduct environmental and public health assessments before granting spectrum rights to evaluate whether radio-based infrastructure deployment is objectively justified.

    Before granting new rights of use for radio spectrum intended for the provision of electronic communications services, competent authorities shall assess whether the deployment of radio-based infrastructure is objectively justified in light of: (a) the availability of equivalent fixed wired connectivity solutions; (b) environmental and public health considerations; (c) the principle of minimising unnecessary exposure to electromagnetic fields.

  • Prioritize fixed wired electronic communications infrastructure over radio-based infrastructure in designated sensitive public health zones.

    In such zones, competent authorities shall give priority to fixed wired electronic communications infrastructure where technically and economically feasible.

• Internet Society NGO, USA; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • Avoid creating mechanisms like the proposed voluntary conciliation mechanism that could undermine the Internet's decentralised model of interconnection and revive sender-pays approaches.

    The Internet Society recommends that the Digital Networks Act preserve the Open Internet and avoid creating mechanisms that could undermine the Internets voluntary, decentralised model of interconnection. In particular, the proposed voluntary conciliation mechanism risks establishing the regulatory infrastructure for future intervention in IP interconnection and could revive, in practice, sender-pays or network-usage-fee approaches.

  • Include clear safeguards for small, local, non-profit, municipal, cooperative, and community operators in spectrum management and copper network switch-off provisions.

    Provisions on spectrum management and copper network switch-off should include clear safeguards for small, local, non-profit, municipal, cooperative, and community operators, especially in rural, remote, and underserved areas.

  • Amend Article 27 to enable flexible spectrum sharing and leasing rather than allowing incumbents to block shared use.

    Article 27 should be amended to enable flexible spectrum sharing and leasing rather than allowing incumbents to block shared use.

• EWIA - European Wireless Infrastructure Association Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Improve the practical implementation of small cell rules.

    improving the practical implementation of small cell rules

  • Address key cross-sector dependencies, particularly by ensuring timely access to electricity grids for network deployment.

    the proposal does not sufficiently address key cross-sector dependencies, notably timely access to electricity grids, which is a critical prerequisite for network rollout

  • Reduce reliance on implementing and delegated acts to prevent regulatory uncertainty and maintain investment confidence.

    the extensive reliance on implementing and delegated acts risks creating regulatory uncertainty and undermining investment confidence

• VATM Business association, DEU model reads as: supports source
  • The framework should strengthen investment and innovation while maintaining effective competition and regulatory predictability across the Single Market.

    VATM supports a framework that strengthens investment and innovation while maintaining effective competition and regulatory predictability across the Single Market.

• The Bulgarian Entrepreneurial Association (BESCO) NGO, BGR model reads as: supports source
  • Reduce regulatory fragmentation and strengthen the Single Market for electronic communications.

    modernise Europes connectivity framework, reduce regulatory fragmentation and strengthen the Single Market for electronic communications

  • Ensure the final framework combines investment incentives and regulatory simplification with clear safeguards for equal and non-discriminatory access.

    The final framework should combine investment incentives and regulatory simplification with clear safeguards for equal and non-discriminatory access.

  • Accompany investment in connectivity with strong protection of the open internet.

    investment in connectivity must be accompanied by strong protection of the open internet

• University Of Malawi Academic or research institution, MWI model reads as: wants changes source
  • Include robust, enforceable protections for net neutrality and equal traffic treatment in the DNA.

    So what I'd ask for, plainly, is this: the DNA should include robust, enforceable protections for net neutrality and equal traffic treatment.

  • Do not prioritize infrastructure investment incentives at the expense of fair competition.

    Incentivising network operators to invest is a legitimate goal, but not at the price of fair competition.

  • Preserve equal internet access as the foundation for enabling innovation and competition.

    That equality has been the quiet engine behind a lot of genuine innovation.

• AMETIC Business association, ESP; register: Trade and business associations model reads as: wants changes source
  • Avoid additional regulatory burdens, duplication of existing regulations, and obligations that do not add value.

    AMETIC therefore advocates avoiding additional regulatory burdens that create uncertainty, duplicate existing regulations or introduce obligations that do not add value.

    machine translation by the Commission, original in ES
  • Regulate cloud, content distribution networks, and private networks while respecting their specificities and avoiding unnecessary market distortions.

    Technologies such as cloud, content distribution networks and private networks play an essential role and should be regulated respecting their specificities, avoiding unnecessary market distortions or cost overruns.

    machine translation by the Commission, original in ES
  • Base regulatory interventions on evidence to avoid measures that could deteriorate the competitiveness or resilience of the European ecosystem.

    Experience shows that the IP interconnection market functions efficiently and that regulatory interventions need to be evidence-based, avoiding measures that could deteriorate the competitiveness or resilience of the European ecosystem.

    machine translation by the Commission, original in ES
• Shanghai International Studies University Academic or research institution, UGA model reads as: wants changes source
  • Provide empirical justification for the conciliation mechanism or demonstrate a market failure warranting intervention.

    the conciliation mechanism lacks empirical justification BEREC has found no market failure warranting intervention

  • Protect the interpretive independence of the Open Internet Regulation to maintain net neutrality protections when the framework is adopted by third countries.

    embedding the Open Internet Regulation inside the DNA undermines its interpretive independence over time and will weaken net neutrality protections as the framework is adopted by third countries

  • Include community-centred connectivity operators in the spectrum framework and ensure copper switch-off continuity provisions protect vulnerable users.

    community-centred connectivity operators are structurally excluded from the spectrum framework and the copper switch-off continuity provisions leave the most vulnerable users unprotected

• COLT Technology Business association, ESP; register: Companies & groups model reads as: wants changes source
  • Amend Article 72 to require NRAs to systematically assess differences in competitive conditions between B2C and B2B connectivity services and define separate relevant markets where justified.

    Amending Art. 72(1) to require NRAs to take due account of differences in competitive conditions between B2C and B2B connectivity services, and to define separate relevant markets where justified

  • Clarify Article 77(1) to ensure commercial agreements are only considered where they reflect genuine market-driven outcomes, not where materially influenced by existing regulatory obligations.

    Clarifying Art. 77(1) to ensure that commercial agreements are only taken into account where they reflect genuine market-driven outcomes, and not where they are materially influenced by existing regulatory obligations

  • Remove the proposed rigid hierarchy of remedies and the requirement for NRAs to provide additional substantiated justification before imposing certain access obligations.

    Removing the proposed rigid hierarchy of remedies and the requirement for NRAs to provide additional substantiated justification before imposing certain access obligations.

• Wi-Fi Alliance NGO, USA; register: Trade and business associations model reads as: wants changes source
  • Sufficiently recognise Wi-Fi's strategic role as a key enabler of European connectivity and competitiveness.

    we note that it does not yet sufficiently recognise its strategic role as key enabler of European connectivity and competitiveness

  • Adopt a genuinely technology-neutral approach to spectrum policy in the DNA.

    We therefore encourage the co-legislators to adopt a genuinely technology-neutral approach to spectrum policy

  • Ensure licence-exempt RLAN technologies, including Wi-Fi, are fully recognised as complementary and essential to Europe's digital future.

    ensuring that licence-exempt RLAN technologies, including Wi-Fi, are fully recognised as complementary and essential to Europes digital future

• DIGITALEUROPE Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Ensure the Single Passport operates as a genuinely self-contained system preventing host Member States from recreating notification, registration or equivalent procedural requirements.

    The Single Passport should operate as a genuinely self-contained system, preventing host Member States from recreating notification, registration or equivalent procedural requirements.

  • Preserve long-term investment incentives by maintaining very long or unlimited licence durations and a strong presumption of spectrum renewal.

    The DNA should preserve long-term investment incentives by maintaining very long or unlimited licence durations and a strong presumption of renewal.

  • Clearly define conditions for specialised services in the primary legislative text rather than relying on future implementing acts.

    The conditions for specialised services should be clearly defined in the primary text.

• European Utilities Telecom Council Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Explicitly recognize utility communication infrastructures as critical connectivity and integrate them into coverage objectives, resilience benchmarks and funding mechanisms.

    the DNA should explicitly recognise utility communication infrastructures as critical connectivity underpinning essential services and fully integrate them into coverage objectives, resilience benchmarks and relevant funding mechanisms

  • Establish flexible spectrum access mechanisms including local licensing and geographical sharing for utility communications, particularly in frequencies below 1 GHz.

    EUTC supports flexible access mechanisms, such as local licensing, geographical sharing and lightly licensed approaches, particularly in frequencies below 1 GHz, while safeguarding incumbent users

  • Ensure spectrum assignment models reflect the public service nature of utilities and avoid imposing cost structures designed for commercial mobile operators.

    spectrum assignment models must reflect the public service nature of utilities and avoid imposing cost structures designed for commercial mobile operators

• Micro company, FRA Business association, FRA model reads as: wants changes source
  • Make FM and DAB+ radio receivers mandatory standard equipment in all new vehicles of categories M, N, and L.

    All new vehicles of categories M, N and L are equipped with FM and DAB + receivers as standard;

    machine translation by the Commission, original in FR
  • Ensure radio is effectively accessible in in-vehicle interfaces through direct physical access and/or visibility from the multimedia console home page.

    Radio is effectively accessible in in-vehicle interfaces, through direct physical access and/or visibility from the home page of the multimedia console.

    machine translation by the Commission, original in FR
• Vantage Towers AG Company, DEU; register: Companies & groups model reads as: wants changes source
  • Recognize access to electricity as a strategic enabler of connectivity on the same level as spectrum.

    We emphasise that access to electricity has become one of the main bottlenecks for telecom deployment and should be recognised as a strategic enabler of connectivity alongside spectrum.

  • Implement targeted improvements to rights of way, small-cell deployment, infrastructure sharing, EMF assessments and fee transparency.

    We also propose targeted improvements to rights of way, small-cell deployment, infrastructure sharing, EMF assessments and fee transparency to make deployment faster, more predictable and more efficient.

  • Avoid duplication with other regulatory frameworks, particularly the future Cybersecurity Act 2.

    Finally, we recommend avoiding duplication with other regulatory frameworks, notably the future Cybersecurity Act 2, in line with the DNAs simplification objectives.

• CECAPI - European Committee of Electrical Installation Equipment Manufacturers Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Provide clearer provisions regarding advance notification of network technology migrations.

    highlights the need for clearer provisions

  • Establish more realistic transition timelines for network technology migrations.

    more realistic transition timelines

  • Ensure continuity of connected building systems, access control technologies, and EV charging infrastructure during network transitions.

    to ensure the continuity of connected building systems, access control technologies, and EV charging infrastructure that depend on long-life communication networks

• NBI Infrastructure DAC Company, IRL; register: Companies & groups model reads as: supports source
  • Include ambitious copper switch-off provisions in the final Digital Networks Act legislation.

    with a particular focus on the positive impact of including ambitious copper switch-off provisions in the final legislation

  • Ensure the DNA promotes investment in and take-up of high-capacity fibre networks.

    NBI supports a Digital Networks Act which promotes investment in and take up of high-capacity fibre networks

  • Use the DNA as an opportunity to incentivise investment in gigabit networks to support innovation and EU competitive position.

    The DNA is an important opportunity for the EU to incentivise investment in gigabit networks and, in turn, support innovation and strengthen the competitive position of the EU

• Altice France-SFR Company, FRA; register: Companies & groups model reads as: wants changes source
  • The company wants the proposed changes to be more complete and adequately adapted to sector challenges, particularly regarding investment framework, spectrum management, and regulatory governance.

    several of the proposed changes appear incomplete or insufficiently adapted to the current challenges of the sector, particularly with regard to the investment framework, spectrum management, and regulatory governance

  • The company wants the European Commission to address key regulatory issues including simplification of the regulatory framework, spectrum management, the balance between asymmetric and symmetric regulation, net neutrality evolution, end-user rights, anti-fraud mechanisms, universal service, and environmental impact.

    wishes to draw the attention of the European Commission to several key issues, including the simplification of the regulatory framework, spectrum management, maintaining the balance between asymmetric and symmetric regulation, the evolution of the net neutrality framework, end-user rights, anti-fraud mechanisms, universal service, and environmental impact

  • The company wants telecom networks and their financing to be prioritized at the heart of European policy, as highlighted in the Draghi and Letta reports.

    The Draghi and Letta reports have nevertheless highlighted the need to place telecom networks and their financing back at the heart of European priorities

• Isiline Company, ITA; register: Companies & groups model reads as: wants changes source
  • Competition should be restored as a full objective of the framework.

    competition is restored as a full objective of the framework

  • Access regulation must remain effective and adaptable to local market conditions.

    access regulation remains effective and adaptable to local market conditions

  • The fibre transition should not entrench dominant positions.

    the fibre transition does not entrench dominant positions

• Micro company, SWE NGO, SWE model reads as: wants changes source
  • Establish a functional national legal remedy for Member States that actively delay, complicate, or obstruct implementation of the DNA Regulation's implementing acts.

    However, a Regulation with centralized criteria from the EU Commission can only remain effective and accessible to the most vulnerable members of society if there exists a functional national legal remedy for instances where a Member State actively delays, complicates, or obstructs the implementation of these new implementing acts.

  • Address systemic issues that arise when Member States consistently and intentionally delay or incorrectly transpose and apply articles into national law.

    It is MyndighetsUpprorets position that the proposal for the new DNA Regulation, at the very least, addresses the systemic issues that arise when a Member State, such as Sweden, consistently and intentionally delays or incorrectly transposes and applies certain articles of the EECC Directive into national law.

  • Ensure that low-income earners and socially vulnerable individuals benefit from the full effect of fundamental rights through the new DNA Regulation.

    to ensure and guarantee that low-income earners and socially vulnerable individuals benefit from the full effect of fundamental rights through the new DNA Regulation

• The Polish Chamber of Information Technology and Telecommunications Business association, POL; register: Trade and business associations model reads as: wants changes source
  • The proposal should include solutions to reduce regulatory burdens and create real incentives for infrastructure investment and technology deployment.

    we see few solutions that would genuinely address the problems raised for years by market participants and described in the reports of M. Draghi and E. Letta, particularly as regards reducing regulatory burdens and creating real incentives to increase infrastructure investment and deploy the latest technologies.

  • The level of ambition of the Digital Networks Act should be increased.

    In PIIT's opinion the level of ambition of the Digital Networks Act is insufficient.

  • Risky and potentially harmful proposals in the draft should be removed or substantially revised.

    the draft contains numerous proposals that we perceive as risky and, in some areas, even potentially harmful.

• HOP-Stop Planned Obsolescence NGO, FRA; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • Strengthen public authority governance and oversight of telecommunications network shutdowns to prevent uncontrolled technological renewal cycles.

    The Higher Commission for Digital and Postal Services therefore concludes in its April 2025 analysis that the governance of the 2G and 3G network shutdown must be strengthened.

  • Establish clear regulatory guarantees regarding the lifespan of telecommunications networks to prevent recurring structural obsolescence.

    The absence of clear guarantees regarding the lifespan of the 4G network fuels fears that these same difficulties will recur in the future.

  • Establish regulatory frameworks to curb structural obsolescence caused by network shutdowns and ensure alignment with the Digital Networks Act's sustainability and resilience objectives.

    This is why we call for this case to serve as a precedent, to curb this structural obsolescence.

• Onivia [Pentacom Investments Spain OPCO SL] Company, ESP model reads as: wants changes source
  • Ensure the Digital Networks Act provides a predictable and investment-friendly regulatory framework.

    A predictable and investment-friendly regulatory framework is therefore essential.

  • Reconsider elements of the proposal that could undermine investment incentives and weaken competition in markets with structural bottlenecks.

    However, certain elements of the proposal should be reconsidered to avoid unintended consequences that could undermine investment incentives and weaken competition in markets where structural bottlenecks continue to exist.

  • Ensure the regulatory framework supports the substantial investment required in digital infrastructure for Digital Decade objectives and strategic autonomy.

    Achieving the Digital Decade objectives, supporting AI-driven growth, strengthening cybersecurity and ensuring Europe's strategic autonomy will require substantial additional investment in digital infrastructure.

• Bundesarbeitskammer Österreich Consumer organisation, AUT; register: Trade unions and professional associations model reads as: wants changes source
  • Maintain or strengthen existing consumer protection rules including duration periods, notice periods, and information obligations.

    There must be no deterioration in the level of consumer protection; many existing rules in the interests of consumers (duration periods, notice periods, information obligations, etc.) should be maintained.

    machine translation by the Commission, original in DE
  • Preserve Member States' discretion to regulate national markets and develop consumer law provisions.

    Member States should continue to have a margin of discretion in regulating national markets, in particular to be able to further develop consumer law provisions.

    machine translation by the Commission, original in DE
  • Prevent mandatory switch-off of copper networks and ensure migration remains voluntary.

    Copper networks may not be switched off to the (financial) detriment of consumers. Migration should be voluntary.

    machine translation by the Commission, original in DE
• Wireless Broadband Alliance Inc. NGO, USA model reads as: supports source
  • Ensure the Digital Networks Act strengthens Europe's digital infrastructure, promotes innovation, encourages investment, and supports greater convergence between fixed, wireless, and Wi-Fi connectivity ecosystems.

    We believe the Digital Networks Act represents an important opportunity to strengthen Europe's digital infrastructure, promote innovation, encourage investment, and support greater convergence between fixed, wireless, and Wi-Fi connectivity ecosystems.

• Consorcio Localret Public authority, ESP model reads as: wants changes source
  • Regulatory and administrative simplification measures should incorporate protection of regional and local authority interests in town planning, environment, and public safety.

    measures aimed at achieving regulatory and administrative simplification should incorporate the reference to the protection of other interests which are the responsibility of regional and local authorities (relating to town and country planning, the environment, public safety, etc.).

    machine translation by the Commission, original in ES
  • Infrastructure deployment measures should protect other legal interests given the clear territorial impact.

    in so far as the deployment of advanced infrastructure will have a clear impact on the territory, measures should also be taken to ensure the protection of other interests and legal interests at stake.

    machine translation by the Commission, original in ES
• France-IX Services Company, FRA model reads as: wants changes source
  • Delete or strictly narrow the ecosystem cooperation and voluntary conciliation mechanism in Articles 191-193, with explicit exclusion of Internet Exchange Points, peering, and settlement-free interconnection from its scope.

    The ecosystem cooperation and voluntary conciliation mechanism (Articles 191 to 193) should be deleted or, at a minimum, strictly narrowed. Internet Exchange Points, peering and settlement-free interconnection should be explicitly excluded from its scope.

  • Redraft Recitals 164, 403 and 404 to remove the sender pays rationale that contradicts the Commission's evidence base and creates legal uncertainty for the IP interconnection market.

    Recitals 164, 403 and 404 should be redrafted. As currently worded, they embed a sender pays rationale that goes beyond the operative provisions, contradicts the Commission's own evidence base and creates lasting legal uncertainty for the IP interconnection market.

  • Recognize Internet Exchange Points as neutral facilitators of interconnection, positioned outside the scope of telecom-type obligations and dispute resolution mechanisms.

    The DNA should recognise Internet Exchange Points as neutral facilitators of interconnection, outside the scope of telecom-type obligations and dispute resolution mechanisms.

• Micro company, PRT NGO, PRT model reads as: supports source
• Allied For Startups Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Preserve and protect net neutrality as a foundational principle for startup competition and equal market access.

    Net neutrality therefore remains the most important issue for startups in the DNA.

  • Include stronger safeguards in the legislative text for specialised services provisions and require mandatory startup impact assessments.

    AFS calls for stronger safeguards in the legislative text and mandatory startup impact assessments.

  • Reconsider the necessity of the cooperation and voluntary conciliation framework in Articles 191193 to avoid creating additional barriers for startups.

    It also questions the need for the cooperation and voluntary conciliation framework in Articles 191193, warning that additional negotiation and regulatory layers could increase barriers for startups.

• Free Modem Alliance Other, ITA; register: Other organisations, public or mixed entities model reads as: wants changes source
  • Codify in Union law the principle of a passive network termination point that classifies modems and routers as terminal equipment, consistent with BEREC Guidelines.

    codify in Union law the principle of a passive network termination point, which implies that modems and routers should, in general, be considered terminal equipment, in line with BEREC Guidelines, without prejudice to the possibility for national regulatory authorities to allow exceptions where duly justified by objective technological necessity

  • Ensure consistent implementation of terminal equipment rules across Member States within a clear timeframe.

    ensure consistent implementation across Member States within a clear timeframe

  • Support interoperability and user choice in line with internal market objectives.

    support interoperability and user choice, in line with internal market objectives

• Asociace komerčních televizí, z.s. Business association, CZE; register: Trade unions and professional associations model reads as: wants changes source
  • Delete Articles 191, 192, and 193 to prevent hidden network charges on audiovisual content providers.

    The ACPC therefore calls for the deletion of Articles 191, 192 and 193 and rejects the introduction of direct or indirect network access charges.

    machine translation by the Commission, original in CS
  • Keep Article 113 unchanged to maintain the must-carry scheme and subsidiarity principle for media regulation.

    The ACPC therefore calls for Article 113 to be kept unchanged and for the subsidiarity principle to be maintained in its application.

    machine translation by the Commission, original in CS
  • Maintain strong and unequivocal net neutrality protections to prevent commercial fast lanes and prioritized content distribution.

    The ACP therefore calls for the strong and unequivocal maintenance of net neutrality.

    machine translation by the Commission, original in CS
• APDC - Digital Business Community Business association, PRT model reads as: supports source
  • Promote investment in advanced connectivity infrastructure and integrate the Digital Single Market.

    The APDC sees the Digital Networks Act as a strategic opportunity to further integrate the Digital Single Market, promote investment in advanced connectivity infrastructure and strengthen the competitiveness of the European economy.

    machine translation by the Commission, original in PT
  • Implement regulatory simplification and reduce regulatory fragmentation.

    regulatory simplification, governance and reduction of regulatory fragmentation

    machine translation by the Commission, original in PT
  • Recognize connectivity as critical infrastructure and strengthen the European digital backbone.

    recognition of connectivity as a critical infrastructure and strengthening of the European digital backbone

    machine translation by the Commission, original in PT

61 more analysed submissions on the consultation page.