Position papers

ETNO's position papers present its member-companies' views on a wide range of technical, regulatory and trade issues to European Union decision-makers, national governments and the general public.

They are developed either internally by ETNO working groups or, occasionally, in co-operation with third parties such as other industry associations.

Click here for definitions of ETNO Position Papers and Expert Contributions.

  • Position papers

    ETNO Statement on the WACC Notice of the European Commission

    The European Commission issued a notice in November 2019[1] (the Notice) which outlines the methodology for the calculation of the Weighted Average Cost of Capital (WACC) of legacy assets and mandates BEREC to annually calculate the various individual input parameters. Although the Notice is non-binding, National Regulatory Authorities (NRA) within the EU might have little discretion to deviate from it as they would risk a serious doubts procedure under Art. 32 of the European Electronic Communications Code (EECC). Thus, the Notice and the BEREC calculations will directly affect national tariff decisions and, as an important benchmark for fibre returns, will also send strong signals for fibre investments. Therefore, the impact of the WACC notice on investment decisions cannot be underestimated.

    21 January, 2021 Read more
  • Position papers

    ETNO comments to the draft delegated regulation on criteria defining environmentally sustainable activities

    The European Telecommunication Network Operators' Association (ETNO) welcomes the opportunity to provide feedback to the draft Delegated Regulation on a climate change mitigation and adaptation taxonomy.

    Investment towards environmentally sustainable projects and activities will be crucial to meet the EU’s climate and energy targets for 2030, and in general to advance on the content and the ambition of the European Commission’s strategy of the European Green Deal.

    15 December, 2020 Read more
  • Position papers

    ETNO – GSMA joint response to the public consultation document by the OECD/G20 Inclusive Framework on BEPS on the Reports on Pillar One and Pillar Two Blueprints

    ETNO and the GSMA welcome the possibility to provide their comments below in response to the public consultation document by the OECD/G20 Inclusive Framework on BEPS on the Reports on Pillar One and Pillar Two Blueprints.

    15 December, 2020 Read more
  • Position papers

    ETNO position paper on the New IP proposal

    Executive Summary

    In response to the proposal initially introduced in the ITU-T Telecommunication Standardization Advisory Group (TSAG), and further developed within SG11 and 13, whereby the ITU-T would take on a more consequential role in the development of IP protocols, this paper summarises the main reactions, and outlines the position of the European telecommunications sector on this important issue.

    5 November, 2020 Read more
  • Position papers

    ETNO-GSMA position paper on the New Consumer Agenda

    Introduction – telcos and consumers

    A 2019 study conducted for ETNO by Assembly[1] identified the telecoms sector as one which is characterised by evolving service, improved trust, and enhanced customer relationships. A result of strong competition between providers, innovation and considerable ongoing investments in networks and services, consumers derive considerable benefit from our services. As a sector defined by providing services to meet new demands and challenges, and one which develops and makes use of new technologies, we welcome the European Commission’s ambition in its forthcoming New Consumer Agenda: consumers must be at the heart of the Green and Digital Transitions in Europe, responding to the most important challenges of today with a holistic and coherent vision on the role of consumers.

    6 October, 2020 Read more
  • Position papers

    ETNO Position Paper on the Review of the NIS Directive

    Introduction

    ETNO supports the European Commission’s global approach to cybersecurity reaffirmed in the “Shaping Europe’s Digital Future” communication and welcomes the upcoming revised European Cybersecurity Strategy, including a review of the Directive on security of network and information systems (NIS Directive).

    5 October, 2020 Read more
  • Position papers

    ETNO Position Paper on the European Commission's Renewed EU Sustainable Finance Strategy and Green Bond Standard

    Executive Summary 

    The telecommunications industry is a substantial enabler of the transition to the EU Green Deal. Telecommunication companies have invested and continue to invest heavily in the build-out and upgrade of energy efficient and high-speed network infrastructure, as well as in the growth of Digitalisation. They thus play a key role for achievement of the taxonomy’s first and so-far most-defined objective: “Climate change mitigation”.

    30 September, 2020 Read more
  • Position papers

    ETNO Policy Note: Licensing Mobile Spectrum

    Given the ongoing preparatory work by the European Commission and the RSPG on a new  multiannual radio spectrum policy programme and the wider European socio‐economic recovery  context, ETNO would like to provide its views and suggestions on the common efforts to accelerate the development of digital communications. This brief policy note should be considered as an initial contribution towards the future policy framework on licensing mobile spectrum.

    Read the ETNO Policy Paper by clicking the link below. 

    16 September, 2020 Read more
  • Position papers

    ETNO EP letter on internet shutdowns

    ETNO welcomed the European Parliament’s actions to raise the issue of internet shutdowns, more specifically in Belarus. This is a crucial issue for European telecom companies, who are hit hard whenever a government decides to mandate internet shutdowns. As we work on stepping up efforts to discourage such shutdowns, we provide here some important facts on the 2020 shutdowns in Belarus.

    Read more here

    16 September, 2020 Read more
  • Position papers

    ETNO - GSMA Position Paper on a New Competition Tool

    ETNO and GSMA associations, which represent the vast majority of telecom operators in the European Union, welcome the opportunity to provide input to DG Competition on the possibility to introduce a New Competition Tool (NCT). In summary, GSMA & ETNO European mobile and fixed telecom operator’s position on the matter and response to the Commission’s Inception Impact Assessment and questionnaire is as follows:

    9 September, 2020 Read more
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