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European Telecommunications Network Operators' Association



ETNO-GSMA Position Paper on the BEREC Guidelines for the implementation of the Open Internet provisions of the TSM Regulation (2015/2120)

Read full Position Paper here


In addition to the GSMA and ETNO papers delivered to BEREC last December, we would like to share Internet access service providers’ (ISPs) views on the implementation of the open Internet provisions of the Telecoms Single Market (TSM) Regulation and we ask BEREC to consider the following elaborations when drafting guidelines for National Regulatory Authorities (NRAs).

BEREC’s guidelines for NRAs should seek to ensure legal certainty, comparability of networks’ performance and avoid detrimental effects for end-users, ISPs, innovation and investment.

The scope of the Regulation is Internet Access Services (IAS). Services other than IAS (SoIAS) are not governed as such by the Regulation, and the BEREC guidelines should avoid adopting a definition or a restrictive approach to these services, which enable innovation that addresses consumers’ needs.

The provisions within the TSM Regulation can increase end-users’ confidence in the usage of Internet access services (IAS). End-users’ trust is a precondition of demand for the services, which drives ISPs’ businesses. However, the new provisions could, if not properly applied, decrease end-users’ trust, innovation in new services (especially around the Internet of Things or following the launch of 5G services) and ISPs’ incentives to invest in high-speed networks.

The future guidelines should also avoid a systematic or rigid approach to traffic management, as networks can be managed in multiple and innovative ways.

The involvement of ISPs in discussions at EU and national levels is crucial to include specific technical knowledge and a business-driven perspective, based on the experience of consumers’ demands and expectations. To that end, GSMA and ETNO would welcome a further exchange with BEREC, prior to the consultation that will end the BEREC process in June 2016.


Read full Position Paper here

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  • Deutsche Telekom AG
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  • Qualcomm Europe Inc.
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