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-GSMA position paper on the Cyber Resilience Act

    The Cyber Resilience Act (CRA) proposal comes at a time when European society, its citizens and businesses have been dealing with a crisis period marked by the COVID-19 pandemic and the war in Ukraine. The telecommunications sector has been capable of responding to these challenges and of demonstrating its robustness, by providing secure and reliable infrastructures and services that are essential for the functioning of the EU’s Digital Internal Market. However, telecommunication network operators are still faced with security gaps in their digital value chains that need addressing.

    20 March, 2023 Read more
  • Position papers

    ETNO response on Key performance indicators for the Digital Decade policy programme 2030

    ETNO welcomes the opportunity to provide its comments to the Draft European Commission Implementing Act on the Key performance indicators for the Digital Decade Policy Programme 2030 (DDPP). The telecom industry is engaged in fulfilling the 2025 Gigabit and 2030 Digital Compass objectives.

    14 March, 2023 Read more
  • Position papers

    Edge Cloud and Strategic Capacity Building in the EU Policy Context on Cloud

    The pressures of the pandemic have shown the importance of a reliable and secure digital infrastructure and the need to avoid dependencies in strategic supply chains. Next to communication networks, cloud services form a critical part of the infrastructure that enables the proper functioning of our economies and societies in an increasingly digitized world. For the European Union, access to secure and state-of-the-art cloud infrastructure has therefore become a crucial policy objective to support the Union’s digital ambitions and to facilitate the data economy.
    The increasing attention from policymakers has led to the emergence of what can be described as a first comprehensive set of regulations and initiatives aimed at the cloud market in Europe. Several initiatives with impact on cloud are either already adopted (DMA, NIS-Directive), currently being prepared (IPCEI CIS, EUCS, Data Act) or are yet to be proposed (Cloud Rulebook, Cloud Marketplace, Data Act sector-specific regulations). Amidst this rapidly evolving policy landscape, this paper aims to explain what edge cloud is, why it is relevant, and how it fits into the larger EU policy context. In addition, this paper elaborates on the unique role of European telecommunication providers in delivering an edge-cloud continuum.


    For further questions, please contact Paolo Grassia, Public Policy Director at ETNO (grassia@etno.eu), Ross Creelman, Public Policy Manager at ETNO (creelman@etno.eu) and Xhoana Shehu, Policy Manager at ETNO (shehu@etno.eu).

    10 January, 2023 Read more
  • Position papers

    GSMA-ETNO input to BEREC’s opinion on the Commission Implementing Regulation on the Fair Use Policy and Sustainability of the Roaming Regulation

    GSMA and ETNO welcome the opportunity to provide comments to BEREC’s opinion on the functioning of the Commission Implementing Regulation on the Fair Use Policy (FUP) and Sustainability of the Roaming Regulation.

    The possibility to apply FUP is a fundamental feature of “roam-like-at-home” regime, which enables the operators to prevent losses caused by users using roaming services for purposes other than periodic travel.

    This element of the roaming service conditions will become even more crucial in a M2M scenario, where FUP allows operators to prevent massive use of their M2M solution abroad, which would open up the doors for harmful arbitrage.

    In the view of the GSMA and ETNO, the Fair use policy provisions not only need to be maintained but would benefit from improvements and simplification due to the current high complexity of the existing control mechanism.

    In our view, the Regulation should be defined in a way where any controls are transparent and easy to understand for customers, easy to implement and track for network operators, and based on cost-efficient solutions. We therefore continue to believe that when reviewing the Implementing Regulation, the Fair use policy provisions should be changed concerning open data bundles, limits on voice/SMS, simplification of 4-month window rule, and proof of normal residence or stable links.

    Fair use rules that foresee the (ex post) monitoring of roaming vs domestic presence and traffic are extremely costly and complex to implement. Therefore, in some cases, operators have decided not to use this tool at all.

    The (ex-ante) setting of a fair use limit on open data bundles also present challenges e.g., it:, (i) does not protect operators from providing the service below cost, and (ii) will be watered down in the event of a further reduction of wholesale caps.

    For further questions, please contact Maarit Palovirta, Senior Director Regulatory Affairs, ETNO (palovirta@etno.eu) or Xhoana Shehu, Policy Manager, ETNO (shehu@etno.eu) and Lotte Abildgaard (labildgaard@gsma.com), Director Public Policy, GSMA. 

    12 December, 2022 Read more
  • Position papers

    GSMA - ETNO response to BEREC Call for input about the Review of the Intra-EU Communications Regulation

    The GSMA and ETNO would like to use the opportunity to contribute to the future BEREC opinion analysing the measures on intra-EU communications.

    In our contribution we reflect on the work done by BEREC collecting the inputs for three consecutive “Intra-EU communications BEREC Benchmark Reports”, and on our own experiences with the market development.

    We would like to point out, first and foremost, that regulation of intra-EU calls is in many ways unprecedented. It covers domestic services, it came in the form of a direct price-cap set at EU level (“BEREC Regulation”)[1] and it was not based on any analysis of individual national markets or considering the adequacy of competition law to resolve the perceived bottlenecks. In our view, the intervention should have been preceded and justified by a proper market assessment to avoid unintended and negative consequences. There was for example no proper reflection on the competitive impacts of the variety of tariff options for intra-EU communications offered by providers of number-based interpersonal communication services; the existence of offers enabling access to the services of alternative operators over the number-based interpersonal communication service, such as call-by-call, pre-select and call-through; or the availability and extensive use of web-based interpersonal communication services provided over the internet (NI-ICS (whatsapp like services)).

    Further, data gathered by BEREC has consistently demonstrated vigorous price competition far below the “safeguard caps” set by the EU rules, and so the rules in themselves did not bring any step change in the state of the market. In our view this strongly indicates that the intervention in this market has not been warranted, as the same results would have been achieved in the absence of any EU rules.

    We are therefore convinced that there is neither a need to prolong nor to modify the current rules beyond their expiration date, as competition on intra-EU communications is proven.

    For further questions, please contact Maarit Palovirta, Senior Director Regulatory Affairs, ETNO (palovirta@etno.eu) or Xhoana Shehu, Policy Manager, ETNO (shehu@etno.eu) and Lotte Abildgaard (labildgaard@gsma.com), Director Public Policy, GSMA.

    12 December, 2022 Read more
  • Position papers

    ETNO position paper on the European Media Freedom Act

    ETNO strongly welcomes the initiative of the European Commission in adopting the proposal for a European Media Freedom Act (EMFA), as a free and open media is a fundamental part of our democracy. Furthermore, as the media and entertainment landscape continues to evolve, it is important that consumers’ possibility to choose from a wide range of media options is protected.

    We wish to highlight, however, a limited number of issues in the proposed EMFA, namely on the content of media service providers on very-large online platforms (VLOPs); the right to customisation of the media offer; and, state-owned entreprises and the implication for state advertising rules, which we consider deserving specific attention in the ensuing legislative debate.

    9 December, 2022 Read more
  • Position papers

    ETNO and EENA's letter to the European Commission on planned electricity network outages and impact on telecommunications network in Europe

    ETNO and the European Emergency Number Association (EENA) call upon the European Commission to work together with Member States to ensure that in the event of planned electricity outages, telecommunications networks be placed on priority lists to ensure continuity of service and thus access to emergency communications.

    Read the letter by ETNO Director General Lise Fuhr and EENA Executive Director Gary Machado to the European Commission below.

    6 December, 2022 Read more
  • Position papers

    ETNO response to the public consultation on BEREC draft Work Programme 2023

    ETNO welcomes the opportunity to provide input towards BEREC’s Work Programme 2023. We believe that BEREC should in general focus on the ongoing tasks as mandated by EU legislation, as defined in the EECC, the Open Internet Regulation, roaming and intra‐EU calls, for example. We support BEREC’s commitment establishing structured cooperation mechanisms with EU institutions and other competent authorities.

    ETNO would like to have the possibility to contribute to the BEREC work for 2023 and the coming years in the best way possible. Thus, we would like to stress the importance to have longer consultation periods to provide comments to reports and reply to consultations. We think setting consultation periods of 6 to 8 weeks would allow for a more efficient process and enrich the input provided.

    In addition, ETNO deems of the utmost importance stakeholders are always involved and properly consulted; in fact, we note with disappointment that for some BEREC studies (such as for instance the one on the evolution of competition dynamics of tower and access infrastructure companies not directly providing retail services and the external study on the trends and policy/regulatory challenges of cloudification, virtualisation and softwarisation of telecommunications) no consultation with stakeholders is planned.

    For questions and clarifications regarding this position paper, please contact Xhoana Shehu (shehu@etno.eu).

    7 November, 2022 Read more
  • Position papers

    ETNO Position Paper on the European Commission’s proposal for a Regulation laying down rules to prevent and combat child sexual abuse

    ETNO welcomes the initiative taken by the European Commission to prevent and combat child sexual abuse material online. ETNO members have been actively engaged in numerous initiatives to this end, including collaboration with law enforcement agencies, and the implementation of blocking lists.

    The Commission’s proposal is highly relevant and timely, given the prevalence of this serious issue, and telecommunications network operators have long been – and will continue to be – committed to playing our part in ensuring the safety of the digital ecosystem. Nevertheless, we believe there are some aspects of the proposed Regulation which require improvement, in order for the final rules to form part of a holistic and effective set of instruments to strengthen capacities and combat this type of crime.

    Each player in the internet ecosystem, and indeed law enforcement agencies, government and society, has an important and distinct role. In order to develop a strong response to the prevalence of child sexual abuse online, the resources and capacities of appropriate national authorities must be reinforced. By way of example, when it comes to blocking known CSAM, it is important that law enforcement agencies be responsible for the identification of the URLs and guarantee their accuracy, and private operators carry out the implementation of blocking lists.

    Above all, the guiding principle of this important piece of legislation must be that illegal content – in this case CSAM – should be removed as close to the source as possible. Not only does this protect the confidentiality of communications, ensuring a more targeted and proportionate legal framework, but it also improves the efficacy of the measures. In the case of solicitation, the place where the first contact is made (often social media / online platform) is the place where a timely and effective intervention should take place.

    For questions and clarifications regarding this position paper, please contact Ross Creelman (creelman@etno.eu).

    18 October, 2022 Read more
  • Position papers

    ETNO response to the Scientific Committee on Health, Environmental and Emerging Risks (SCHEER) Preliminary Opinion on Radiofrequency

    ETNO would like to welcome this opportunity to comment on the preliminary Opinion on the need of a revision of the annexes in the Council Recommendation 1999/519/EC and Directive 2013/35/EU, in view of the latest scientific evidence available with regard to radiofrequency.

    ETNO supports revision of the annexes in the EU Council Recommendation 1999/519/EC and Directive 2013/35/EU based on the updated ICNIRP guidelines (2020). In addition, we propose that each Member State applies them and does not impose more stringent limits, nor other conditions, than defined in the annexes.

    More specifically, ETNO strongly urges that each Member State and municipality aligns with the EMF limits defined by ICNIRP. Stricter limits, not based on scientific evidence, confuse the citizens of the Member States. They also lead to worse network capacity, and even difficulties fulfilling coverage obligations and deploying new technologies. They limit cell range and limit possibility to deploy new bands per site. This leads towards much denser networks, which may be challenging due to deployment restrictions. Moreover, higher number of network equipment leads to higher energy consumption and carbon emissions in manufacturing and in operation. The need to keep single antenna site emissions below stricter limits may also slow down the migration from a “stable” technology to an emerging one, due to the need to ensure the continuity of legacy services.

    For questions and clarifications regarding this position paper, please contact:
    - Maarit Palovirta (palovirta@etno.eu), Senior Director of Regulatory Affairs at ETNO.
    - Xhoana Shehu (shehu@etno.eu), Policy Manager, ETNO.

    30 September, 2022 Read more
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