Digital Networks Act

Creativity Works! Reply to the European Commission’s Call for Evidence on the Digital Networks Act We, as Creativity Works!, the leading coalition representing Europe’s cultural and creative sectors, welcome the European Commission’s call for evidence for the Digital Networks Act. Creativity Works! members produce, publish, distribute and exhibit a wide range of creative and cultural content in the European Union.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Telefónicas Position on the Digital Networks Act (DNA): A Call for Bold Reform Telefónica welcomes the European Commissions (EC) initiative to establish the DNA. While supporting the ECs ambition to foster investment, innovation, and competitiveness, Telefónica stresses that only a bold and comprehensive overhaul can address the structural and economic challenges facing the sector.

As part of the spusu group, Multiconnect GmbH benefits from a dynamic development in the European internal market. The sister company Mass Response Service GmbH has been active with the spusu brand successfully in Austria for over a decade (more than 700.000 SIM cards), while the group is now present in Italy, Switzerland and the United Kingdom.

Filed in German · English published by the European Commission

The European Commissions proposal outlined in the Call for Evidence for the Digital Networks Act (DNA) envisions a significant shift in the regulatory model, whereby ex-ante regulation would be downgraded to a safeguard mechanism, appli-cable only after symmetric measures - such as those in the Gigabit Infrastructure Act (GIA) - have been tested, and subject to multiple layers of review and veto.

Transatel urges the European Commission to approach the Digital Networks Act reforms with caution and strategic foresight. While we welcome the Commissions goals of full harmonisation and simplification, several proposed changes raise serious concerns.

Transatel urges the European Commission to approach the Digital Networks Act reforms with caution and strategic foresight. While we welcome the Commissions goals of full harmonisation and simplification, several proposed changes raise serious concerns.

VAUNET Association of Private Media thanked for the opportunity to comment on a Digital Networks Act, briefly: Digital Networks Act or DNA. VAUNET is the umbrella association of private audiovisual media in Germany. TV, radio, web and streaming services are among the diverse business areas of the approximately 150 members.

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The European Publishers Council (EPC) is a high-level group of Chairmen and CEOs of Europes leading editorial media groups representing companies which are active in news media, television, radio, digital market places, journals, eLearning, databases and books.

Introduction to Macquarie Macquarie Group ("we" or our) is a global financial services organisation, established in 1969, with 545.3bn billion of assets under management . Our areas of expertise encompass infrastructure, energy, technology, and commodities. We are one of the worlds leading infrastructure investment managers , overseeing approximately 190 infrastructure portfolio companies.

1. We welcome the opportunity to respond to the DNA call for Evidence , as an SME Internet Stakeholder, the author of this response paper, Tom Smyth has been working in the Information Technology field for 24 years and as an ISP Engineer for 18 years. This paper has been drafted on a voluntary basis and has been endorsed by a number SME ISPs in Ireland. 2.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Thanks for the opportunity to feedback One Contact Ltd. an ICT Provider operating in Ireland providing managed IT services for Businesses in Ireland, believe in a fair and open Internet, we would like to endorse the submission both brief and full by Wireless Connect Ltd. we believe spectrum should released as much as possible to the general population for Performant Wi-Fi and FWA connectivity.

We acknowledge the call for evidence on the Digital Networks Act and appreciate the opportunity to contribute to this important debate. While we recognise the ambition to strengthen Europes position in the digital domain, we do not consider a complete overhaul of the current regulatory framework to be either necessary or a priority.

We welcome the opportunity to provide input on the forthcoming Digital Networks Act and acknowledge the intention to enhance Europes strategic role in the digital sphere. However, we believe that a comprehensive restructuring of the current regulatory framework is neither warranted nor should it be seen as a pressing necessity.

GSOA welcomes the European Commissions initiative to shape a Digital Networks Act (DNA) that ensures Europes digital infrastructure is fit for the future. Satellite communications play a strategic and often irreplaceable role in Europes connectivity landscape, providing essential services in hard-to-reach regions, supporting emergency response, providing broadband services to ships and planes, and contributing to…

We support the Commissions ambition to foster a more competitive and digital Europe through a simpler, more investment-friendly regulatory framework. Simplification In principle, we support the deregulation trend, reflecting significant market and technological developments (but in some countries the market may not be mature yet and local conditions justify (continued) ex ante intervention).

Reply to the European Commission’s call for evidence on the Digital Networks Act Ref. Ares(2025)4545535-06/06/2025 Committee of Independent ICT Průmyslu z.s. Mgr. [name removed], MBA, LL.M. [phone removed], [email removed] thanks the Committee of Independent ICT Industry (VNICTP) for giving its opinion on the initiative that should result in the proposal for a new regulation, the Digital Network Act.

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The Digital Networks Act offers a historic opportunity to reshape the regulatory foundation of Europes digital infrastructure for the next decade. As a European-headquartered innovator in satellite-based 5G NB-IoT services, Sateliot strongly supports the Commissions objective to simplify, harmonise, and modernise the legal framework governing connectivity across the EU.

The French Telecoms Federation (Fédération Française des Télécoms, hereinafter FFTelecoms) represents the electronic communications operators in France. FFTelecoms is a member of EuroISPA, the pan-European association of Internet Service Providers, which represents over 2500 companies.

11 July 2025 Internet Society’s response to the European Commission’s Call for Evidence with regards to the upcoming Digital Networks Act (DNA) Summary The Internet Society welcomes the opportunity to contribute to the European Commission’s Call for Evidence on the forthcoming Digital Networks Act (DNA).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

POSITION PAPER on the Call for Evidence for an Evaluation and Impact Assessment on the Digital Networks Act Berlin, 11.07.2025 On June 6, the European Commission published a call for evidence for an impact assessment on the regulation of digital network infrastructure in the European Union.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The "Digital Networks Act" (DNA) initiative presents opportunities for open source in telco modernisation with an increased use of cloud-native applications, GenAI, software-defined networks, and virtualized RAN.

Euroconsumers and its member organisations in Spain (OCU), Italy (Altroconsumo), Belgium (Test Achats/Test Aankoop) and Portugal (Deco Proteste) welcome the opportunity to contribute to the European Commissions call for evidence on the upcoming Digital Networks Act (DNA).

Samsung Electronics (SE) welcomes the opportunity to submit feedback to the European Commissions (EC) public consultation on the Digital Networks Act. SE hopes that this feedback, together with the position already submitted to the previous public consultation on the ECs White Paper How to Master Europes Digital Infrastructure Needs?

POSITION PAPERCONFEDERATION OF SWEDISH ENTERPRISE Ref. Ares(2025)5711470 - 14/07/2025 Call for evidence EU Digital Networks Act Europe’s digital infrastructure is greatly influenced by new technologies and a new geopolitical landscape. It is essential that the infrastructure is secure, reliable, and resilient throughout the EU.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Technology Ireland is an Association within Ibec, which represents the ICT, Digital and Software Technology Sector welcomes this opportunity to provide insights to the European Commission impact assessment on the Digital Networks Act (DNA). Please find attached our response.

United Internet welcomes the opportunity to respond to the public consultation. While we support the Commissions ambition to strengthen Europes digital infrastructure, we fundamentally disagree with the premise that the current regulatory framework is failing.

Creating an oligopoly of a few "pan-European champions" is incongruous with the EU's history and policy of promoting competition as an absolute value. This policy raises a significant concern about a possible employment crisis for thousands of workers in telecommunications sector as well as in the other ones which are strictly connected.

Stellungnahme der Landesmedienanstalten im Rahmen Sondierungskonsultation Digital Networks Act - Stand: 11.07.2025 DLM | Der Koordinator des Fachausschusses Infrastruktur und Innovation ______________________________________________________ 1. Einleitung Die 14 Landesmedienanstalten sind als staatsfern organisierte Aufsichtsbehörden zentral für die Regulierung von privatem Rundfunk und Telemedien in Deutschland.

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

PIIT welcomes the initiative on the Digital Networks Act (DNA). We believe that the current rules for the electronic communication sector do not fully support the goal of building European effective and resilient networks that enhance our digital sovereignty.

The European Commission (EC) has invited comments from ComReg on the Call for Evidence on a proposed Digital Networks Act (DNA), which issued in June 2025. The Call for Evidence seeks the views of stakeholders on the ECs understanding of the problems which the DNA is intended to remedy.

ARUBA COMMENTS TO “CALL FOR EVIDENCE FOR AN IMPACT ASSESSMENT ON THE DIGITAL NETWORKS ACT” Ares (2025) “454553” Aruba S.p.A. (http://www.aruba.it), founded in 1994, is Italy's leading provider of trust services – including qualified e-delivery services, cloud, data centre, hosting, e-mail, domain registration.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

FiberCop welcomes the launch of the long-anticipated initiative concerning the DNA, along with the EECC review, and would like to share its views on the Call for evidence. We are confident that this initiative will pave the way for substantial and effective reforms of the regulatory framework governing the electronic communications sector.

Submission to the “Digital Networks Act” Call for Evidence 11 July 2025 Background on Cloudflare Cloudflare, Inc. is the leading connectivity cloud company. It empowers organizations to make their employees, applications, and networks faster and more secure everywhere, while reducing complexity and cost.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Call for evidence su Digital Network Act Contributo INWIT Luglio 2025 Executive summary INWIT è il primo Tower operator italiano e tra le principali Digital Infrastructure Company. INWIT ha costruito una posizione di leadership nazionale attraverso un modello di business basato sulla condivisione delle infrastrutture tra diversi operatori con un focus sulla sostenibilità della condivisione a seguito di un importante…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Cassa Depositi e Prestiti (CDP) is the Italian National Promotional Institution, with total assets exceeding 450bn. Our strategy, as a patient, long-term investor, prioritises amongst other points the development of hard and digital infrastructures to enhance national economic competitiveness and accessibility, supporting companies on digitalisation and technological innovation.

EWE TEL appreciates the opportunity to provide feedback on the call for evidence concerning the proposal for a regulation with regards to a Digital Networks Act. As one of the largest regional providers of telecommuni-cations in Germany and the leading broadband provider in north-west Germany, we welcome the Commissions initiative to strengthen the European regulatory framework for digital connectivity and…

Arelion welcomes the Commissions initiative to simplify regulation, strengthen the single market and incentivize innovation and investment. However, in doing so, the Commission must focus not only on the most pressing problems (and opportunities), but on those issues where policy and regulation provide the best answer to the problem.

Position regarding Digital Networks Act (DNA): Consultation We are pleased to comment on the recently published consultation of the EU Commission on the planned Digital Networks Act (DNA). We very much welcome the fact that the Commission´s 2024 white paper “How to master Europe's digital infrastructure needs” has already drawn attention to the expansion of digital infrastructures, as these are essential for almost…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

ATTO LEGISLATIVO SULLE RETI DIGITALI Ares (2025) 4545535 RISPOSTA BBBELL La consultazione pubblica avviata dalla Commissione Europea sull’Atto legislativo sulle reti digitali rappresenta un momento cruciale per il futuro delle telecomunicazioni in Europa.

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Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

MOTION PICTURE ASSOCIATION EMEA 11 July, 2025 Subject: MPA submission to call for evidence for an evaluation and impact assessment of the Digital Networks Act Submitted digitally at https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14709Digital-Networks-Act_en Introduction The Motion Picture Association (MPA) represents the interests of major international producers and distributors of film…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Consorzio TOPIX (TOP-IX) TOP-IX believes that the proposed new approach on regulation of network access would jeopardize the development of next-generation services such as cloud computing, edge computing, 6G, and artificial intelligence.

Berlin, 11. Juli 2025 BDEW Bundesverband der Energie- und Wasserwirtschaft e.V. [address removed] www.bdew.de Stellungnahme zum Call for Evidence der EUKommission zum Digital Networks Act Transparenzregister-Nr.: 20457441380-38 Der Bundesverband der Energie- und Wasserwirtschaft (BDEW), Berlin, und seine Landesorganisationen vertreten mehr als 2.000 Unternehmen.

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

https://epicenter.works/content/digital-networks-act-submission-in-the-call-for-evidence This Submission is also supported by the IT-Political Association of Denmark (EU transparency register number: 685809321315-95) and the digital rights NGO Initiative für Netzfreiheit (Austrian registration number: 675848645).

1. Admission: Reports prepared for the European Commission (including: Draghi and Letta report) are based on the assumption that the development of Big Techów from the United States of America (USA) can and should be compared with European telecoms. They also criticise EU telecoms for lack of innovation.

Filed in Polish · English published by the European Commission

TDF welcomes the opportunity to provide feedback on the forthcoming Digital Networks Act (DNA). Please find attached the full contribution, sharing its views on several policy options. Overall, TDF fully supports the ambition of the DNA to ensure a digital network infrastructure that delivers high-quality, reliable, and secure connectivity across the EU.

We welcome the ECs initiative to establish the DNA. We believe that the current regulatory landscape for ECN does not fully align with the EUs objectives of enhancing digital sovereignty. The fragmentation, along with the special treatment given to domestic telecom operatorsparticularly in consumer protectionposes significant obstacle to technological progress and market growth.

BusinessEurope welcomes the opportunity to contribute to the Call for Evidence on the future legislative initiative Digital Networks Act (DNA). First we would like to remind that in September 2024, we published a high-level reaction to the White Paper: How to master Europes digital infrastructure needs?.

EDF input to the European Commission’s call for evidence on the Digital Networks Act ............................................................................................................................ 11 July 2025 Link to the call for evidence Submitted by Daniel Casas, EDF Accessibility Policy Officer EDF feedback to the call for evidence The European Disability Forum (EDF) is an umbrella organisation of…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Call for evidence on the Digital Networks Act (DNA) eir response European telecom operators need to be able to rely on a stable, predictable, and consistently applied regulatory environment. The European telecoms sector has brought high-performance connectivity to all, at attractive prices that drive take-up. Many European countries are world leaders in fibre coverage and adoption.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

As the European Union moves forward with the deployment of 4G and 5G networks, significant concerns arise regarding the phase-out of legacy 2G and 3G infrastructure, particularly for the continuity and availability of vital security services. Verisure addresses these concerns in this position paper, contributing to the Call for Evidence for a Digital Networks Act.

‭ itle:‬‭i2Coalition Position on the Proposed Digital‬‭Networks Act (DNA)‬ T ‭Submitted via:‬‭Have Your Say Portal‬ ‭From:‬‭Christian Dawson, Executive Director, Internet‬‭Infrastructure Coalition (i2Coalition)‬ ‭July 11, 2025‬ ‭ he Internet Infrastructure Coalition (i2Coalition), representing companies that build and operate‬ T ‭the Internet’s core technologies—including web hosting providers, data centers, domain‬…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Please find enclosed Amazon's response to the call for evidence on the Digital Networks Act (DNA) and the related survey on the European Electronic Communications Code and the Digital Single Market. To accurately explain how specific proposals in the DNA would affect Amazon's separate and distinct businesses, we have divided our response into (i) Amazon Web Services, (ii) Amazons content businesses, and (iii) Amazon…

Call for evidence – Digital Networks Act – 11 July 2025 Priorities of the Czech Republic For DNA design several possible elements are suggested in the Call for Evidence in several areas. Focusing on these, this contribution summarizes the main priorities of Czechia.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Before addressing the individual objectives (in the file attached), I-Com deems it essential to highlight that the current EU digital regulatory framework is already very complex, articulated (and sometimes poorly harmonized), and largely still in its initial implementation phase (e.g., DSA and DMA, Data Act).

Please find MVNO Europes detailed response in the attached document. A key element of MVNO Europes feedback, based on the very nature of its membership, is that MVNOs - already today - successfully develop their activities within Member States as well as across Member State boundaries.

InfraNum, the French federation for digital infrastructure, welcomes the European Commissions call for contributions for an evaluation and impact assessment runof the Digital Networks Act, and thanks the Commission for the opportunity to respond to this consultation. We fully support the objective of modernising and simplifying European legal framework, to better address new technological challenges.

We set out the main demands and reservations about the proposed DNA Regulation, stressing the need to reduce excessive regulatory obligations and to improve the efficiency of the rules. We have set out in detail the following requests in the annex.

Filed in Polish · English published by the European Commission

The Estonian Information Technology and Telecommunications Union (ITL) hereby presents its views and suggestions in response to the European Commission’s call for feedback on the Digital Networks Act (hereinafter: DNA) on: 1. Communications services play a very important role in today’s society.

Filed in Estonian · English published by the European Commission

vzbv would like to thank the European Commission for the opportunity to comment on the initiative. However, vzbv regrets the short consultation period and the absence of any further opportunity for public input on what is likely to be a farreaching legislative proposal, which aims to create a new regulatory basis for a future proof digital infrastructure in the European Union.

As the European Union advances towards next-generation connectivity with the deployment of 4G and 5G networks, the organisation of the ongoing phase-out of legacy 2G and 3G infrastructure raises significant concerns for the continuity and availability of critical security-related services, including private security services.

DE-CIX welcomes the opportunity to provide feedback to the European Commission's call for evidence on the Digital Networks Act. Europes economic competitiveness depends on a modern digital infrastructure with secure, high-performance connectivity to support strategic sectors and leadership in AI.

EFHOH (European Federation of Hard of Hearing People) welcomes the opportunity to contribute to this Call for Evidence on the future Digital Networks Act. We attach our written comments outlining the accessibility needs of hard of hearing people, particularly regarding digital infrastructure, communication services, and AI systems, and the importance of enforcing the European Electronic Communications Code (EECC)…

The European Energy Information Sharing and Analysis Centre (EE-ISAC) welcomes the European Commissions initiative to develop a unified Digital Networks Act (DNA). EE-ISAC recognises the DNAs potential to modernise Europes digital infrastructure through harmonisation, resilience measures, and regulatory simplification, while ensuring alignment with sectoral needs such as energy systems security and operational…

Open TV, a group formed by the main players of Digital Terrestrial Television (DTT) in Spain, reflecting a global and pluralistic impetus of all those who contribute to universal, free and free television access, thanks the European Commission for the opportunity to contribute to this important consultation to develop the Digital Networks Act (DNA).

Filed in Spanish · English published by the European Commission

ARTICLE 19, an international human rights organization, submitted critical feedback to the European Commission on the proposed **Digital Networks Act (DNA)**. The submission raises three key concerns about the current framing of the DNA and its potential negative impact on human rights, regulatory independence, and digital inclusion within Europe. #### **Main Concerns:** 1.

PPC, the leading electricity utility in Southeast Europe, welcomes the opportunity to provide feedback on the upcoming Digital Networks Act. Through its fiber optic subsidiary, PPC FiberGrid, the Group is investing significantly in Greeces digital transformation by deploying a nationwide FTTH network.

BoR (25) 101 BEREC Input to the European Commission’s Call for Evidence on the Digital Networks Act 11 July 2025 BoR (25) 101 Contents 1. Introduction.................................................................................................................................. 3 2. BEREC views on part A: the problems that the initiative aims to tackle ..................................... 3 3.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Alliance of Telecommunications Terminal Equipment Manufacturers (VTKE) would like to thank you for the opportunity to comment on the Call for Evidence in connection with the upcoming Digital Networks Act. The VTKE’s feedback is attached as a PDF document.

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The German Broadband Association (Bundesverband Breitbandkommunikation e.V. (BREKO) welcomes the possibility to provide feedback to the call for evidence in the frame of the upcoming Digital Networks Act. As the leading German fibre-optic association, BREKO advocates for fair competition in the German telecommunications market.

AMETIC’s position on the Digital Networks Act Ref. Ares(2025)5711371 - 14/07/2025 Feedback to the European Commission July 2025 Final version AMETIC’s position on the Digital Networks Act – Feedback to the European Commission AMETIC is the Multisectorial Association of Electronics, Information and Communication Technologies, Telecommunications, and Digital Content Companies.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Qualcomm welcomes the opportunity to contribute to the European Commissions consultation on the future of digital networks in the EU. Qualcomm is a world leading wireless technology developer and chipset provider headquartered in San Diego, California.

BNE strongly supports the Commissions objective to foster a more integrated, competitive, and future-proof digital infrastructure across the EU. In this context, BNE would like to highlight the essential role that terrestrial broadcast networks play in Europes digital ecosystem. Terrestrial broadcasting networks, an essential European infrastructure, recognized in the RSPP, UHF Decision, and EECC.

We welcome the opportunity to respond to this Call for Evidence and to express our views on the future Digital Networks Act. The availability of high-quality, reliable and secure connectivity is essential for an entertainment service like Netflix - our business depends both on partnerships with creators and a well-functioning internet.

Confartigianato Imprese is the most representative Italian organisation for craft businesses and micro and small and medium-sized enterprises (SMEs) and one of the most important social partners in Italy. At national level, it has 104 local associations, 21 regional federations, 1,206 offices and 10,700 employees, offering various types of services to over 1.5 million artisans and small entrepreneurs and almost…

European citizens rely on electronic communications networks to stay safe in emergencies, by contacting 112, or receiving public warnings with advice during crises. Without these networks, it would be impossible to provide timely support to individuals during crises, underlining their key role in EU resilience and preparedness.

DigitalES Response to the European Commission Public Consultation on the Digital Networks Act (DNA) DigitalES, as the leading association representing Spain’s digital and telecommunications sector, welcomes the European Commission’s initiative to launch a comprehensive review of the regulatory framework for digital networks. In this context, we would like to share the following key positions.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

An die Fachverband der Telekommunikations- und Rundfunkunternehmungen Europäische Kommission Wiedner Hauptstr. 63 | A-1045 Wien T 05 90 900-3020 E [email removed] http://wko.at/telekom-rundfunk Directorate-General for Communications Networks, Content and Technology (Unit B1 - Electronic Communications Policy, Implementation and Enforcement) [eingesandt über das Eingabeformular auf der Website der Europäischen…

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

CEOE Response to the European Commission's Call for Evidence on the Digital Networks Act INTRODUCTION Recognizing the broad and overarching role of the Digital Networks Act on telecommunications regulation in Europe, we strongly appreciate the opportunity to give its feedback in and provide input to contribute to a more efficient and effective regulatory framework.

We support the goals of the European Commission to ensure connectivity for all, accelerate digital transformation, and maintain a competitive and resilient digital ecosystem. As an active contributor to European initiatives, including through our presidency of ELFA, we welcome the DNA as a necessary step toward harmonized, future-proof digital legislation.

The Three Group’s response to the Commission’s call for evidence on a proposed Digital Networks Act This paper provides the Three Group Europe’s response to the Commission's call for evidence on a proposed Digital Networks Act. This follows the Three Group Europe’s response to the 2024 white paper.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

HAKOM thanks the Commission for the opportunity to comment on the proposed policy options and potential EU actions aiming at providing a simplified legal framework for regulation of digital infrastructures. As a long-term electronic communications regulator on a Croatian national market, we believe that our perspective could benefit further process of reviewing EECC and defining new legislative proposal, Digital…

Please find attached EWIAs full contribution to the call for evidence and below a summary of this contribution. Out of the topics to be primarily addressed in the DNA according to the call for evidence, EWIA supports the objective of simplification and would like to share more detailed views on access regulation.

Digital Networks Act - call for evidence for an impact assessment Transparency Register ID: 20586492362-11 Executive summary • The relationship between ISPs and CAPs1 such as video game publishers is symbiotic: demand for content drives demand for Internet access, and this in turn facilitates online content delivery.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

AER - the Association of European Radios, represents commercial radios across Europe. AER welcomes the opportunity to respond to the Commissions call for evidence. The upcoming revision of the EECC and proposal for a DNA offer a unique opportunity to secure the future of radio in cars and the long-term spectrum availability for broadcast radio. Our contribution can be viewed in the attached document.

The European Broadcasting Union is the worlds leading alliance of public service media (PSM). EBU Members are entrusted with the mission to reach all the people on their territory with high quality content to inform, educate and entertain. To do so, they rely on both broadcast and broadband infrastructures: terrestrial and satellite, fibre and 5G.

To unlock the full potential of the EUs digital single market for its citizens, a comprehensive and ambitious modernisation of the EUs telecoms regulations is essential. The DNA should stimulate innovation, investment and harmonisation across the EU.

AT&T is pleased to submit comments to the European Commission call for evidence and Impact Assessment run in parallel on the Digital Network Act. AT&T commends the European Commission for its initiative to advance the debate on tackling the European Single Market fragmentation, removing barriers for cross-border operators to allow them to scale up as well as to simplify and modernize regulatory frameworks.

The Programme Making and Special Events (PMSE) sector is a vital but under-recognised part of Europes digital and cultural ecosystem. It supports professional-grade content creation for broadcasting, live performance, film, sports, political events, and moreall reliant on professional wireless audio systems like wireless microphones, intercoms, and in-ear monitors designed for real-time use.

ITI welcomes the European Commissions intent to foster a resilient, modern, and competitive telecom sector and explore regulatory reform through the forthcoming Digital Networks Act (DNA) to enable this. As the leading global advocate for technology companies, we fully support the goal of ensuring robust digital infrastructure to meet Europes growing connectivity and innovation demands.

BSA | The Software Alliance is the leading advocate for the global software industry before governments and in the international marketplace. Our members are at the forefront of software-enabled innovation that is fueling global economic growth, including cloud computing and AI products and services. BSAs membership includes many of the world's leading enterprise software providers to organizations of all sizes.

HE European telecommunications sector is a success story for its 450 million consumers, offering them competitive plans, innovative solutions, and extensive fiber-optic and mobile network coverage. The European model is not only market- and consumer-friendly, but also enables operators to grow and develop profitable businesses.

Filed in Italian · English published by the European Commission

APELL The European Open Source Software Business Association and its members represent hundreds of Open Source businesses with a collective turnover in the order of several tens of billions of euros each year, as well as public administrations, research institutions, and individuals throughout Europe.

The Associação para a Promoção e Desenvolvimento da Sociedade da Informação (APDSI) welcomes the European Commissions initiative and strongly supports the overarching objectives of the proposed Digital Networks Act. We recognize the urgent need to strengthen the Digital Single Market and create the conditions for a more competitive, resilient, and innovative digital services ecosystem in Europe.

The European telecommunications sector is a success story for its 450 million consumers, offering them competitive plans, innovative solutions, and extensive fiber-optic and mobile network coverage. The European model is not only market- and consumer-friendly, but also enables operators to grow and develop profitable businesses.

Filed in Italian · English published by the European Commission

We welcome the opportunity to contribute to the public consultation on the Digital Network Act, recognizing the importance of establishing a modern, simplified, and coherent legal framework for digital networks across Europe. Our observations are based on our direct experience as a local telecommunications operator active in the Italian market for nearly three decades.

OIV (https://oiv.hr/en/about-us/) welcomes the opportunity to provide feedback on the call for evidence on the Digital Networks Act. OIV is a Croatian broadcast network operator for digital terrestrial television (DTT) and radio (FM and DAB+), covering more than 99 % of population. Please see the attached document for OIV's feedback.

Digital Business Ireland (DBI) is Ireland's national representative body for the e-commerce, digital and tech sectors. Digital Business Ireland welcomes the Digital Networks Acts proposed strengthening of EU telecommunications networks to provide for the effective rollout of key technologies such as cloud and AI. DBI has outlined suggestions for effective implementation.

A./A. - COMISIÓN EUROPEA Asunto: Comentarios y sugerencias sobre la Convocatoria de Datos de la Digital Networks Act I. Que la Asociación de Operadores de Telecomunicación Empresariales (“ASOTEM”, en adelante) es una agrupación española que representa los intereses de las principales operadoras alternativas de telecomunicaciones radicadas en España y especializadas en el mercado corporativo. II.

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Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Spettabile Commissione Europea Oggetto: Contributo di Assoprovider al DNA Digital Networks Act. Introduzione Il DNA è la proposta di regolamentazione di prossima pubblicazione da parte della Commissione Europea, la cui consultazione pubblica è stata avviata il 6 giugno 2025 e si concluderà l'11 luglio 2025.

Filed in Italian · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Stellungnahme der ADDIX GmbH zum Digital Networks Act (DNA) eingereicht im Rahmen der öffentlichen Konsultation der Europäischen Kommission Die europäische Digitalpolitik steht an einem Wendepunkt. Mit dem Digital Networks Act (DNA) möchte die Europäische Kommission zentrale Weichen für die digitale Infrastruktur der kommenden Jahre stellen.

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Introduction The Association of Electronic Communications Operators (APRITEL) is the association for the institutional representation of undertakings in the electronic communications industry in Portugal. Our mission is: – (a) to contribute to the promotion and development of the electronic communications sector in Portugal through the use of studies, seminars, dissemination activities and other activities; (b)…

Filed in Portuguese · English published by the European Commission

Finnet Association (later Finnet) is representing group of Finnish fibre operators and is a associate member of FTTH Council Europe (later FCE) and Finnet share FCEs statement in many part of this consultation. Find below Finnets additions or replacement to FCEs statement.

1. We welcome the opportunity to respond to the DNA call for Evidence , as an SME Internet Stakeholder, the author of this response paper, Tom Smyth has been working in the Information Technology field for 24 years and as an ISP Engineer for 18 years. This paper has been drafted on a voluntary basis and has been endorsed by a number SME ISPs in Ireland. 2.

The German Landkreistag (Deutsche Landkreistag, DLT) would like to thank you for the opportunity to provide guidance on the planned legal act on digital networks in the context of the call for evidence. Please find enclosed the Association’s comments.

Filed in German · English published by the European Commission

The Malta Business Bureau (MBB) strongly supports the vision behind the Digital Networks Act (DNA). However, the regulation must account for disparities in institutional capacity, enforcement capability, and market size across Member States.

AFNUM, Alliance Française des Industries du Numérique, represents the manufacturers of digital equipment and infrastructure, whose products (smartphone, server, 4G and 5G antennas, televisions, computers, etc.) form the basis on which the ‘high’ digital layers (software, applications, etc.) are based.

Filed in French · English published by the European Commission

ISPA, as an association of the Austrian internet economy, would like to thank you for the opportunity to provide feedback on a possible future Digital Networks Act as part of the European Commission’s Call for Evidence.

Filed in German · English published by the European Commission

Group III/A of the Austrian Federal Ministry of Labour, Social Affairs, Health, Care and Consumer Protection, responsible for consumer policy, would like to thank you for the opportunity to comment on the impact assessment of the Digital Networks Act (DNA) and would refer to the attached document.

Filed in German · English published by the European Commission

On the choice of legislative instrument: The provisions of any regulation should be fully harmonized and clear-cut, otherwise any ambiguities in the regulation would have to be adapted in national laws and may result in the same difficult regulatory patchwork as is the cited undesirable effect of a directive.

Nuuday Teglholmsgade 1 2450 Copenhagen SV Denmark Ref. Ares(2025)5711285 - 14/07/2025 nuuday.dk Dato: 10/07/2025 Nuuday response to the European Commission’s call for evidence on the Digital Networks Act Nuuday welcomes the opportunity to contribute to the European Commission’s Call for Evidence on the proposed Digital Networks Act (DNA).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Founded in 1958, Wray Castle is the first & leading provider of technical training to the telecommunications industry. Our customers include many of the worlds leading international telecommunications companies and organisations, such as Vodafone Group; we serve the transportation industry, where we power the International Union of Railways (UIC.org) telecoms academy; we serve the critical communications industry…

Overall, we reiterate that the EU connectivity market is working well for the benefit of all players, and we question the need for significant regulatory changes to incentivize investments on the supply side, whereas the main gap seems to be on the demand side.

On the open internet: Net neutrality must continue to be ensured and must not be jeopardised under the pretext of enabling and promoting innovative services, also because net neutrality does not preclude it in any way. Contrary to the Commission’s assertions in the call for evidence, the current net neutrality rules are sufficiently clear and do not need to be redesigned in favour of innovative services.

Filed in German · English published by the European Commission

Telenor's position on the Digital Networks Act emphasizes the importance of a secure, resilient, and sustainable European digital infrastructure to support competitiveness, security, and strategic autonomy. The company supports regulatory modernization to stimulate investment, innovation, and cross-border cooperation in telecom networks.

We acknowledge the call for evidence on the Digital Networks Act and appreciate the opportunity to contribute to this important debate. While we recognise the ambition to strengthen Europes position in the digital domain, we do not consider a complete overhaul of the current regulatory framework to be either necessary or a priority.

The future DNA (Digital Networks Act) is a major initiative by the European Commission aimed at modernising the current regulatory framework for electronic communications in the European Union, which dates back to 2018 and is no longer suited to the long-term challenges faced by operators.

ViaNova S.p.A. is an Italian telecommunications operator active in the B2B supply of fixed, mobile (full MVNO), Unified Communication, Cloud and Data Center services. ViaNova would like to bring a concrete and growing market need to the attention of the European Commission and the co-legislators: the possibility of using national geographical numbers also outside the national territory, but within the European…

Filed in Italian · English published by the European Commission

On behalf of the VAT Association of Alternative Telecom Network Operators in Austria, a unique alliance representing fixed and mobile network operators as well as infrastructure providers, we welcome and support the European Commissions initiative to develop the Digital Networks Act.

Eurofiber hopes that the Commission takes a balanced view when looking at all the evidence and input provided by all stakeholders, as so far it appears as if the Commission is taking a rather one-sided view as the texts published by the Commission so far seem largely unchanged from the ideas put forward in the initial White paper.

MASORANGE welcomes the commitment expressed by the European Commission to address the challenges facing the connectivity sector through the DNA, and appreciates the opportunity to contribute its perspective within the framework of this public consultation. The DNA represents a unique opportunity to correct long-standing inefficiencies in the sector.

A1 Group welcomes the Commissions initiative to prepare a Digital Networks Act (DNA) and shares the view that Europes connectivity framework requires a fundamental reset to foster innovation, investment, and competitiveness.

Cisco welcomes the European Commission's call for evidence looking at designing the future Digital Networks Act (DNA). Digital networks are not only the fundamental backbone for a thriving digital economy and society, but also for enabling Europes security and defense ambitions by ensuring secure communication channels and resilient infrastructure for military and intelligence operations.

Številka: 510-1/2025/3 Datum: 11.7.2025 AKOS Input to the European Commission’s Call for Evidence on the Digital Networks Act Contents 1. Introduction and views on the problems tackled by the initiative ................................................ 3 2. AKOS views on part B: objectives and policy options ................................................................ 3 2.1.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Call for Evidence on the Digital Networks Act 11 June 2025 Page | 1 The FTTH Council Europe welcomes the opportunity to contribute to the call for evidence on the Digital Networks Act (DNA). Simplification: There are a number of provision in the EECC which have not been used in its first five years in effect.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Alianza por una Internet Abierta para Latinoamérica y el Caribe (AIA-LAC) is a multi-stakeholder coalition that brings together diverse voices from the digital ecosystem. It promotes an open, secure, and inclusive internet, and contributes evidence-based input to digital policy and regulatory debates. We respectfully submit that regulatory changes to the EUs IP interconnection framework would not add value.

5 key messages 1. The only regulatory tool that boosts investment in connectivity is access regulation. 2. The only form of regulation that the DNA cannot remove is wholesale access to the civil infrastructure of the incumbent and, where applicable, physical network of the SMP. 3.

PSCE fully supports the initiative to develop the Digital Networks Act. We particularly welcome the consideration to include more than only the economic considerations which have been the focus of the innovation drive for mobile communication until recently.

The feedback highlights the EUs lagging performance in network rollout, next-generation technology adoption, and digital skills, as noted in the Digital Decade Report and DESI. While supporting the Commissions efforts to improve digital policy, the DNA is likely insufficient to address outdated telecom regulations.

Bandwidth is not advocating for a full deregulation or the rejection of the concept of Authorisations, as any such transition is highly unlikely to yield renewed end user trust in the communications eco-system that Europe needs.

The Coalition of Cloud and Fixed Wireless Access (CFWA, www.cfwa.it ) welcomes the opportunity to contribute to the consultation on the Digital Network Act, recognizing the importance of a modern and simplified legal framework for digital networks in Europe.

CRTV emphasizes the need to preserve the balance of the audiovisual ecosystem, particularly in countries like Italy where free-to-air TV ensures universal access to local and EU contents and supports cultural and social cohesion.

ccianet.eu • @CCIAeurope Ref. Ares(2025)5711158 - 14/07/2025 European Commission’s call for evidence on the Digital Networks Act CCIA Europe response July 2025 The Computer & Communications Industry Association (CCIA Europe) welcomes the opportunity to participate in the European Commission’s call for evidence on the Digital Networks Act (DNA).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Associazione Italiana Internet Provider (AIIP) is the first and historic Italian association representing more than 60 Internet operators, infrastructure and network providers, including FTTH, as well as providers of electronic communications services, data center and cloud services.

The Sports Rights Owners Coalition (SROC) is a forum of over 50 international and national sports bodies and competition organisers committed to protecting the vital contributions sports make to Europes society and economy (2% of GDP and 3% of total EU employment). SROC members are key providers of long-term jobs and generate vast tax revenues.

Microsoft welcomes the opportunity to provide feedback to the European Commissions call for evidence for an impact assessment of the Digital Networks Act (DNA). We appreciate the European Commission's efforts to address the fragmentation of the EUs connectivity sector and to review the regulatory framework as part of a broader effort to simplify the regulatory landscape and to advance a secure, competitive, and…

Contributo AGCOM alla Call for Evidence della Commissione europea sul Digital Networks Act L’Autorità per le garanzie nelle comunicazioni ringrazia la Commissione europea per l’opportunità fornita, tramite la Call for Evidence, di contribuire alla riflessione in merito alla prossima iniziativa legislativa “Digital Networks Act”.

Filed in Italian · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Abilian is a French and European software creator and vendor dedicated to building a sovereign, ethical, and sustainable digital future. Our mission is to provide strategic open-source alternatives to dominant proprietary solutions, empowering small and medium-sized enterprises (SMEs), public administrations, and research organizations to achieve digital autonomy.

ALLNET.ITALIA COMMENTS TO “CALL FOR EVIDENCE FOR AN IMPACT ASSESSMENT ON THE DIGITAL NETWORKS ACT” ARES (2025) 454553” Allnet Italia is a value-added distributor specialized in the IT and telecommunications sectors. Founded in Bologna in 2000, it is part of the Allnet Group, an international network with distribution operations across Germany, Austria, France, Spain, Greece, Malta, and the Nordics.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

ROCKET WAY COMMENTS TO “CALL FOR EVIDENCE FOR AN IMPACT ASSESSMENT ON THE DIGITAL NETWORKS ACT” ARES (2025) 454553” Rocket Way is an internet service provider operating in Liguria. It is a founding member of Ge-DIX.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Verizon is a global player. Outside of the U.S., Verizon provides a broad range of global communication products and enterprise solutions, predominantly to large business and government customers. We are established in most European Union (EU) Member States (MSs), and provide services in over 150 countries worldwide.

Referentie: Call for Evidence - Digital Networks Act Datum: 10 July 2025 1. Current and Emerging Problems 1.1 Lack of Investments and Innovation NLdigital agrees with the Commission's assessment regarding investment and innovation gaps in the EU connectivity sector.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Orange response to the Commissions Call for Evidence on the Digital Networks Act. Orange calls for a bold review of the telecoms framework to ensure it is fit for purpose to deliver a digital continent while strengthening European competitiveness and fostering investment in digital infrastructure.

Europes competitiveness is under severe pressure. The EU has fallen behind the USA and China in terms of growth, productivity and innovative strength. Against this background, German industry has very much appreciated the attention to digital infrastructures attributed by the European Commission through the White Paper How to master Europes digital infrastructure needs, the Letta Report and the Draghi Report.

The African IXP Association (AFIX) urges the European Commission to refrain from introducing a mandatory dispute resolution mechanism in the IP interconnection market. The current voluntary, trust-based model functions efficiently, with minimal disputes and strong global scalability.

,,,,, Ref. Ares(2025)5711100 - 14/07/2025 1 GIGABIT-STRATEGIE I BERLIN I j euroAber Eurofiber Netz GmbH Hedwig-Dohm-Straße 2 Eurofiber Netz GmbH, Hedwig-Dohm-Straße 2, 10829 Berlin 10829 Berlin Geschäftsführer EU Commission Marco Siek, Christian Bakx Directorate General CNECT - Directorate B Rue de la Lai 51 B-1050 Brussels AG Berlin-Charlottenburg Sitz der Gesellschaft: Berlin HRB 202647 B Landesbank…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

We welcome the opportunity to provide input on the Digital Networks Act and value the chance to engage in this crucial discussion. While we understand the objective of enhancing Europes role in the digital arena, we believe that a full revision of the current regulatory framework is neither justified nor urgent.

Akamai’s response to the European Commission’s call for evidence on the Digital Networks Act 10 July, 2025 Introduction Akamai Technologies, Inc. (“Akamai” hereafter) welcomes the opportunity to provide input to the European Commission’s call for evidence on the Digital Networks Act (DNA).1 Akamai supports the European Union’s (EU) ambitious 2030 Digital Decade targets and is encouraged by reports that most EU…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Response to European Commission call for evidence on the Digital Networks Act July 2025 NON-CONFIDENTIAL Introduction Sky is one of Europe’s largest content creation and distribution businesses, serving over 23 million customers across six countries. We operate as both a major content provider (over satellite, fixed and mobile networks) and a leading communications provider in the fixed and mobile sectors.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

ecta, the european competitive telecommunications association, welcomes the opportunity to provide feedback on the European Commissions Call for Evidence on the Digital Networks Act. ecta places Europes global competitiveness at the forefront of its concerns.

Public service broadcasting plays a central role in democracy, diversity of opinion and social cohesion. Access to the content of public service broadcasting must therefore be ensured by all means of distribution, in particular by means of electronic communications networks and services. These have a useful function for the media and are not an end in themselves. This must be taken into account in the DNA.

Filed in German · English published by the European Commission

We acknowledge the call for evidence on the Digital Networks Act and appreciate the opportunity to contribute to this important debate. While we recognise the ambition to strengthen Europes position in the digital domain, we do not consider a complete overhaul of the current regulatory framework to be either necessary or a priority.

TNET Servizi is a local Internet Service Provider founded in 2005. Within a few years, it achieved 95% coverage of the Mantua province. Today, TNET Servizi operates over 2,500 km of infrastructure in the area, offering high-performance connectivity solutions such as FTTH (point-to-point), GPON (point-to-multipoint), and FTTC services.

Danish Entrepreneurs representing over 17,000 startups across Denmark strongly support the EUs ambition to modernize digital infrastructure through the Digital Networks Act (DNA). However, we caution that unless designed with innovation at its core, the DNA risks overregulation, reinforcing incumbents, and undermining Europes ability to lead in next-generation technologies such as AI, cloud, IoT, and quantum…

Mynet is a long-established telecommunications company based in Northern Italy, with a prominent role in the national SME telecom sector. Since 1995, we have emerged thanks to a distinctive approach that combines financial independence - direct and exclusive control by its owners-directors -, technological innovation and a deep commitment to the needs of local communities.

Investments, innovations, and consolidation in the European telecommunications market can only be realised effectively if the Digital Networks Act succeeds in maintaining and promoting competition. Implementing an access obligation through a regulation is the most effective and simplest means of directly maintaining and promoting competition.

Summary of Vantage Towers feedback on the Digital Networks Act (DNA) Vantage Towers welcomes the European Commissions call for evidence on the Digital Networks Act and urges policymakers to recognise that land and energy are as critical to Europes digital future as spectrum and regulatory reform.

The ORF is Austrias public service media broadcaster with a broad palette of services and channels in TV, Radio and Online, which have to be produced and distributed, in order to validate the mandatory household fee in Austria. Our content must be easy to find and prominently displayed on all relevant gateways giving access to media services.

Adigital, representing over 500 companies in Spains digital ecosystemincluding telecom operators, technology platforms, content providers, infrastructure firms, and digital service companieswelcomes the European Commissions efforts to open a debate on the Digital Networks Act.

1. Cloud services or cloud services should not be incorporated as an additional sector within the scope of DNA. 2. Taking into account the reality of market fragmentation at European level, even if the aim is to establish a common legal regime for the whole of the European Union by approximating and harmonising legislation, an objective which Spain is promoting, however, we believe that a model should be adopted…

Filed in Spanish · English published by the European Commission

ZPTCL response to the European Commission's Call for Evidence on the Digital Networks Act Introduction We appreciate the opportunity to respond to the European Commission's Call for Evidence on the Digital Networks Act (DNA). While we support efforts to strengthen Europe's digital infrastructure, we have significant concerns about several proposals that could fundamentally damage Europe's digital ecosystem.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Association of Municipal Enterprises (VKU) represents over 1590 municipal and municipal companies in the fields of energy, water/waste water, waste management and telecommunications. More and more member companies are engaged in broadband roll-out: Around 220 companies invest over EUR 912 million per year. We enclose our position paper on the European Commission’s call for evidence on the Digital Networks Act.

Filed in German · English published by the European Commission

Ladies and Gentlemen, please find enclosed the Austrian Federal Competition Authority’s comments on the European Commission’s ongoing consultation on the Call for Evidence – Digital Networks Act. Yours sincerely, for Director-General Mag. (FH) Mag. [name removed]

Filed in German · English published by the European Commission

Mr LAvicca thanked the Commission for consulting stakeholders again on the legislation on electronic communications networks as part of its draft amendments and simplification, some of which were planned at the time of the adoption of the European Code.

Filed in French · English published by the European Commission

I would like to thank the European Commission for the opportunity to express my views on the proposed Digital Networks Act (DNA). The submitted document does not provide a detailed analysis of the legislative or technical aspects of the proposal, but rather represents a general expression of support without an in-depth discussion of the potential implications of the proposed measures.

FiCom's comments are in the attached statement. However, here are FiCom's main messages: FiCom emphasizes the importance of simplifying, harmonizing, and ensuring fairness in regulation. The current regulatory framework is complex and does not adequately respond to market and technological changes. FiCom supports reducing reporting obligations and eliminating unnecessary administrative burdens.

The Unions policy objectives of consumer welfare, industrial competitiveness, security and resilience and environmental sustainability resonate strongly with the views of the 18 European or national organisations members of the Wider Spectrum Group (1).

Digital Networks Act - Call for evidence for an impact assessment Submission from Yahoo July 2025 1.​ 2.​ Introduction 1.1.​ Yahoo is pleased to provide these comments on this consultation. This submission sets out our initial observations. We may add to these comments later in the year after the Digital Networks Act package is expected to be published.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Digital Networks Act - Consultation The consulting engineering perspective on the upcoming Act 09 July 2025 The European Federation of Engineering Consultancy Associations (EFCA) has member associations in 27 countries, representing more than 10,000 companies from the European engineering consultancy industry and related fields.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

DOT Europe welcomes the European Commissions Call for Evidence on the DNA and supports efforts to modernise Europes connectivity framework to meet the goals of the Digital Decade. A regulatory environment that promotes investment and innovation is essential, and all future policy proposals should follow the principles of Better Regulation, ensuring intervention only where clear market failures are identified.

4iG’s Response to the Commission’s Call for Evidence on the Digital Networks Act 4iG Plc welcomes the publication and the opportunity to provide feedback on the European Commission’s Call for Evidence on the Digital Networks Act (DNA).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The European Utilities Telecom Council (EUTC) welcomes the European Commissions initiative to shape the forthcoming Digital Networks Act (DNA) and presents this contribution on behalf of utility operators managing mission-critical telecommunications infrastructure across Europe.

Through its European Public Policy Committee, IEEE welcomes the opportunity to respond to this Call for Evidence. In a recent technology policy whitepaper on communications networks in the EU (https://shorturl.at/NJROl), IEEE has focused on a number of issues that the DNA aims to tackle.

According to The Shift Project, the context of the Digital Networks Act as described in the call for contributions overlooks major issues that are just as important as the need to improve the performance of the European economy or the technological transformation of digital infrastructures.

While recognizing the importance of modernization, simplification and investments in electronic communications network, any regulation must not allow the concentration of the European telecommunications market into only a few hands.

Submission to the EC Call for Evidence by ASIC (France) SUBMISSION TO THE EC CALL FOR EVIDENCE ON THE DIGITAL NETWORKS ACT (DNA) WHO WE ARE The Association des services internet communautaires (ASIC), founded in 2007, is the first French organization to bring together players in the collaborative web and platforms.

Filed in French · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

EHINET SRL COMMENTS TO “CALL FOR EVIDENCE FOR AN IMPACT ASSESSMENT ON THE DIGITAL NETWORKS ACT” ARES (2025) 454553” Ehinet Srl is an Italian telecommunications company specializing in internet services, VoIP solutions, and hosting.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The App Association is a policy trade association for the small business technology developer community. Our members are entrepreneurs, innovators, and independent developers within the global app ecosystem that engage with verticals across every industry.

Dr. Asma Chiha IDLab, Ghent University-imec Technologiepark-Zwijnaarde 126 9052 Ghent, Belgium [email removed] 10/07/2025 Directorate-General for Communications Networks, Content and Technology (DG CNECT) European Commission B-1049 Brussels Belgium Subject: Submission of Scientific Paper in Response to the European Commission Consultation on the Future of the Electronic Communications Sector Dear Sir or Madam, I am…

We believe that the future Digital Networks Act has the potential to significantly improve European digital infrastructure, but only if network neutrality rules are respected and consumer rights are strengthened. We warn against measures that would enable network discrimination, introduce network fees, or weaken ex-ante regulation of dominant operators.

It is high time that the EC remove the red tape which holds back European enterprise. Essentially this red tape amounts to regulation which hinders the conduct of trade and business. The European Union needs enterprise to grow its economy and support its quality of life. Consider the ECs folly with artificial intelligence (AI). In 2018, the EC said the European Union would now be a leader in AI.

Established in 1997, EuroISPA is the world's largest association of Internet Services Providers Associations, representing over 3,300 Internet Service Providers (ISPs) across the EU and EFTA countries. EuroISPA is recognised as the voice of the EU ISP industry, reflecting the views of ISPs of all sizes from across its member base. EuroISPA's feedback is attached below.

SIRO The [name removed], The Park, Carrickmines, Dublin 18 [email removed] www.SIRO.ie EU Commission 9th July 2025 BY PORTAL Response of SIRO DAC to the European Commission’s Call for Evidence on the Digital Networks Act (DNA) 1. Executive summary We welcome the Commission’s initiative to modernise the telecoms rulebook.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Cellnex would like to thank the European Commission for the opportunity to contribute its views on the upcoming Digital Networks Act (DNA). As Europe´s largest telecommunications towers and infrastructures operator, with a pan-European footprint spanning across 10 countries, Cellnex actively contributes to meeting Europe´s infrastructure needs.

We acknowledge the call for evidence on the Digital Networks Act and appreciate the opportunity to contribute to this important debate. While we recognise the ambition to strengthen Europes position in the digital domain, we do not consider a complete overhaul of the current regulatory framework to be either necessary or a priority.

We acknowledge the call for evidence on the Digital Networks Act and appreciate the opportunity to contribute to this important debate. While we recognise the ambition to strengthen Europes position in the digital domain, we do not consider a complete overhaul of the current regulatory framework to be either necessary or a priority.

Monopolkommission · Kurt-Schumacher Str. 8· 53113 Bonn European Commission Directorate-General for Communications Networks, Content and Technology 1049 Bruxelles/Brussels Belgium Chairman Prof. Dr. Tomaso Duso Tel +49 . 228 .

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

SIPORTAL SRL COMMENTS TO “CALL FOR EVIDENCE FOR AN IMPACT ASSESSMENT ON THE DIGITAL NETWORKS ACT” ARES (2025) 454553” Siportal Srl is a privately held Italian telecommunications company headquartered in Lentini, Sicily.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Europäische Kommission Generaldirektion Kommunikationsnetze, Inhalte und Technologien (Referat B1 – Politik der elektronischen Kommunikation, Umsetzung und Durchsetzung) Rue de la Loi / [address removed] Belgien Mass Response Service GmbH DC Tower 1, 45.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

No Network Fees Worum geht es? Telekommunikationsunternehmen fordern, dass sich Diensteanbieter, deren Angebote Datenverkehr in großem Umfang auslösen wie beispielsweise TV, VoD oder Streaming, Zahlungen an sie, die Betreiber der Telekommunikationsinfrastruktur, leisten. Sie plädieren daher auf europäischer Ebene für die Einführung des Prinzips, dass die „Sending Party“, d.h.

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Response to the Call for evidence on the future Digital Networks Act. Introduction: AOTEC is a Spanish business association that, since 2002, has been representing and defending the interests of more than 130 local and regional electronic communications and audiovisual operators in Spain. First: Competition and regulation versus mergers and deregulation. It is true that there is fragmentation in the European market.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Alegaciones y observaciones al proceso de consulta pública sobre el futuro Digital Networks Act (DNA) Ref. Ares(2025)5710625 - 14/07/2025 ALEGACIONES AL PROCESO DE CONSULTA PÚBLICA sobre la futura propuesta legislativa: DIGITAL NETWORKS ACT (DNA) Consulta abierta por la Comisión Europea - Ref.

Filed in Spanish · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Executive Summary Key Recommendations Use a directive, not a regulation To ensure flexibility and respect for well-functioning national systems. Promote competition through diversity of ownership Consolidation weakens resilience and drives up prices; diversity drives innovation. Reject the fair share model It undermines net neutrality and disadvantages local and municipal networks.

WT SRLS COMMENTS TO “CALL FOR EVIDENCE FOR AN IMPACT ASSESSMENT ON THE DIGITAL NETWORKS ACT” ARES (2025) 454553” WT SRLS is an internet service provider that operates in Italy providing internet service, cloud services, SaaS.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

We acknowledge the call for evidence on the Digital Networks Act and appreciate the opportunity to contribute to this important debate. While we recognise the ambition to strengthen Europes position in the digital domain, we do not consider a complete overhaul of the current regulatory framework to be either necessary or a priority.

Note de Réponse à l'appel à consultation sur le Digital Networks Act À l'attention de la Commission Européenne, En réponse à l’appel à consultation concernant la révision du Digital Networks Act, nous souhaitons exprimer nos préoccupations et proposer des pistes d’amélioration pour que la politique européenne en matière de réseaux numériques soit plus efficace et réponde mieux aux défis auxquels sont confrontés les…

Filed in French · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Nokia is a technology leader across mobile, fixed and cloud networks. Our solutions enable a more productive, sustainable and inclusive world. We are convinced the DNA should serve to: - Strengthen the investment capabilities of European telecom operators for timely deployments of very-high-capacity networks.

"We acknowledge the call for evidence on the Digital Networks Act and appreciate the opportunity to contribute to this important debate. While we recognise the ambition to strengthen Europes position in the digital domain, we do not consider a complete overhaul of the current regulatory framework to be either necessary or a priority.

Brussels, 9 July 2025 AIOTI Feedback on the upcoming Digital Networks Act Comments on Simplification objective: Investment needs: While we acknowledge the fragmentation of the European telecoms sector, it is our view that a consolidation of the European telecoms sector could stimulate massive investment in digital infrastructure across the European Union (EU) provided, however, that European consumers’ welfare is…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

CONFIDENTIAL ACT RESPONSE TO THE CFE ON THE DIGITAL NETWORKS ACT 9 JULY – FINAL Ref. Ares(2025)5540981 - 09/07/2025 PAGE | 1 ACT RESPONSE TO THE CALL FOR EVIDENCE ON THE DIGITAL NETWORKS ACT ACT members recognise the importance of strong and widely available telecoms infrastructure in Europe, which, among other benefits, enables European consumers to access high-quality TV and VoD services.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Ireland welcomes the opportunity to engage with the Commission through this call for evidence. The Digital Networks Act (DNA) will be an important piece of legislation that will shape the telecommunications market for years to come. However, it must not be the only tool that we use.

The Corporación Radio Televisión Española (RTVE) is a state-owned public company with special autonomy, entrusted with the mission of providing and ensuring the States public radio and television service in Spain.To do so, they rely on both broadcast and broadband infrastructures: terrestrial and satellite, fibre and 5G.

Euralarm takes the opportunity of the call for evidence issued by the European Commission on a Digital Networks Act to raise an issue faced by our members with the phasing out of mobile technologies. The attached Position Paper follows our briefing on risks and challenges of uncoordinated shutdown of 2G and 3G networks responding to the ECs White Paper "How to master Europe's digital infrastructure".

The Union of Entrepreneurs and Employers (ZPP) welcomes the European Commissions initiative to establish a Digital Networks Act (DNA) to modernize Europes digital infrastructure and ensure connectivity resilience.

We acknowledge the call for evidence on the Digital Networks Act and appreciate the opportunity to contribute to this important debate. While we recognise the ambition to strengthen Europes position in the digital domain, we do not consider a complete overhaul of the current regulatory framework to be either necessary or a priority.

Feedback to EC call for evidence on the Digital Networks Act Introduction to InterDigital InterDigital is a US corporation with headquarters in Wilmington Delaware and research centres in England, France, Canada and the US, which is engaged in the development of foundational wireless, video and AI technologies.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

"We acknowledge the call for evidence on the Digital Networks Act and appreciate the opportunity to contribute to this important debate. While we recognise the ambition to strengthen Europes position in the digital domain, we do not consider a complete overhaul of the current regulatory framework to be either necessary or a priority.

The Commission, availing itself in the preparatory phase of external consultants, on the (erroneous) assumptions of: (i) an alleged inferiority of the European Union compared to other more developed regions in the world, in digital communications networks and Services, full fiber and 5G deployment, (ii) an asserted superiority of foreign big champions in ICT which allegedly would maximize investments in the sector…

Réponse de Netalis SAS (FR) – LIR RIPE (AS-Netalis) – ARCEP : NTLS Ref. Ares(2025)5519498 - 08/07/2025 Réponse à l’appel à consultation de la Commission Européenne sur le Digital Networks Act (DNA) _ Answer to the European Commission’s Call for Evidence on the Digital Networks Act (DNA) 1 Réponse de Netalis SAS (FR) – LIR RIPE (AS-Netalis) – ARCEP : NTLS • Who we are Netalis (Registred as SIREN 812 132 512) is…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

We welcome the European Commission’s willingness to address the issue of managing digital infrastructure needs in Europe and in particular the elements geared towards revitalising investment in European networks.

Filed in French · English published by the European Commission

The Citizens’ Association Elektrosmog and Health welcomes the fact that the European Commission is working on the development of digital infrastructure. At the same time, we are concerned that the debate is largely technically-economic, without sufficient consideration of the impact on public health and the environment.

Filed in Slovak · English published by the European Commission

"We do not see the EU as lagging behind other developed regions in digital communications, nor do we believe that big champions are preferable to a strong network of competent SMEs across the EU. Therefore, we do not consider replacing the current regulatory framework a priority, as growth has already occurred within it. Our position is detailed in the attached document."

As we do not consider the EU inferior to other developed regions in the world in digital communication networks and services, neither we consider that "big champions" are better than a substrate of competent SMEs distributed on the EU territory, we do consider the replacement of the current regulatory environment neither a priority nor something needed in giving strength for growth to something that has already…

NET GLOBAL SRL COMMENTS TO “CALL FOR EVIDENCE FOR AN IMPACT ASSESSMENT ON THE DIGITAL NETWORKS ACT” ARES (2025) 454553” NET GLOBAL SRL is an Italian company based in the province of Padua, we are an Internet Service Provider and we deal, through the 4ALL brand, with providing internet connectivity services to small and medium-sized businesses, companies, public administrations and private consumers through our 100%…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Thank you for the opportunity to comment on the draft Digital Networks Act. We would like to draw your attention to the following aspect when finalising the Act. We consider that the DNA must reflect the value media brings to society, safeguarding citizens ability to access media services. The DNA and further regulations should promote both broadcast and broadband distribution equally.

8 July 2025 Input regarding future EU regulation in the telecommunications sector Call for evidence: Digital Networks Act Delivered by Teleindustrien (Telecom Industry Association Denmark) Europe is facing a serious situation with an increased threat level, which means it is necessary across all areas of society to prioritize investments in security and resilience. The telecom sector is no exception.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

CONNESI S.P.A. COMMENTS TO “CALL FOR EVIDENCE FOR AN IMPACT ASSESSMENT ON THE DIGITAL NETWORKS ACT” ARES (2025) 454553” Located in central Italy, Connesi is a one-stop provider for all connectivity, ICT and telephony services, and we cater to all those professionals who need high reliability solutions.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

New Digital Networks Act should include provisions according to which the largest telecom operators were obliged to lease their networks (fiber) to the smaller telecom companies which need the network when they further sell their internet services and products to their customers.

Wi-Fi Alliance welcomes the Commissions efforts to address fragmentation and investment gaps in the EUs digital infrastructure. The Digital Networks Act (DNA) is a vital opportunity to promote a more inclusive, harmonized framework that fully reflects the importance of license-exempt wireless networks in achieving the Unions connectivity targets. 1.

Dear Members of the Commission, I am pleased to submit my recent research paper, entitled Optimal financial contributions for infrastructure development: A cooperative game-theoretic approach, as part of the European Commissions Call for Evidence for the forthcoming Digital Networks Act (DNA).

Warsaw, 7th July, 2025 Mr Peter Stuckmann Head of Unit Electronic Communications Policy, Implementation and Enforcement (CNECT.B.1) Directorate-General for Communications Networks, Content and Technology European Commission Dear Mr Stuckmann, On behalf of Digital Poland Association, an organisation bringing together the digital and advanced technologies industry of Poland, I wish to express appreciation for the…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Electronic Communications Committee (ECC) of the European Conference of Postal and Telecommunications Administrations (CEPT) welcomes the opportunity to share its perspective on the Digital Networks Act (DNA) initiative. This is provided in the attachment.

TDC NET appreciates the opportunity to contribute to the Commissions work on the Digital Networks Act (DNA). We highly appreciate the DNA proposal to build upon the Commissions White Paper on EU connectivity, the Letta report on the EU single market, and the Draghi report on the competitiveness of the EU economy.

Call for Evidence: Digital Networks Act The European VOD Coalition (the “Coalition”) welcomes the opportunity to provide feedback on the European Commission's "Call for Evidence" for the proposed Digital Networks Act (DNA).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Thank you for your feedback on the upcoming Digital Networks Act. As a non-profit organisation working on consumer protection, we want to respond to some of the European Commission’s concerns in this area and help ensure that the resulting regulation does not lead to unjustified price increases or problems in access to individual services for consumers.

Filed in Czech · English published by the European Commission

Ladies and Gentlemen, we welcome in principle the European Commission’s initiative to modernise Europe’s digital infrastructure and speed up the roll-out of the Digital Networks Act (DNA). Nevertheless, in the current draft, we see important shortcomings that need to be addressed urgently in order to shape DNA in a holistic, sustainable and human-friendly approach. 1.

Filed in German · English published by the European Commission

Representing a managed infrastructure provider in the B2B telecom sector, I strongly oppose the proposed Digital Networks Act (DNA). While the desire to make Europes connectivity stronger is understandable, the design risks creating a profound market imbalance that disproportionately harms small and medium-sized enterprises (SMEs), which form the backbone of our digital economy. Here are my findings: 1.

We welcome the European Commissions attention to connectivity, as a key supporting infrastructure for digital transformation, itself the key to spurring long term growth and prosperity in Europe. The considerations in the Call for Evidence raise a number of questions and challenges, notably about the process, the quality of impact assessment and of the solutions envisaged.

We welcome the efforts to simplify telecoms rules, but such consolidation should be strictly based on facts and technology neutrality, in line with the principle of proportionality in national regulation. Furthermore, we believe that the Commission’s interest in extending the scope and objectives of the current legal framework needs to be carefully balanced against gold-plating.

Filed in German · English published by the European Commission

CISPE’s Recommendations for the Digital Networks Act July 2025 About CISPE CISPE is an association of more than 35 cloud infrastructure service providers, the vast majority of which are European SMEs. Our members deliver essential cloud services across the EU, support millions of users, and invest heavily in European infrastructure.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Digital Network Act (DNA) Unleashing the full potential of European Digital Networks A holistic vision Sovereignty and industrial competitiveness are overarching EU policy imperatives in telecoms. These objectives can only be met with a true single market for digital connectivity, overcoming national borders, providing a strategic space for EU industrial actors initiatives in all sectors to invest and innovate…

1-7-2025 Danish Industry - DI Digital Transparency Register No: 749958415-41 Contribution from the Confederation of Danish Industry (DI) on Digital Networks Act - call for evidence The Confederation of Danish Industry (DI) welcomes the opportunity to contribute to the European Commission’s forthcoming proposal for a “Digital Networks Act” (DNA).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

At CEDEC, we represent the interests of 2000 local and regional energy and broadband companies across Europe, close to citizens and businesses, serving 100 million electricity, gas and district heating customers and broadband connections.

TYP Vårt dnr: Xx 2025-07-01 Emma Ström Sveriges kommuner och regioners synpunkter på Digital Networks Act Sveriges Kommuner och Regioner (SKR) välkomnar möjligheten att lämna synpunkter på EU-kommissionens arbete med Digital Networks Act (DNA).

Filed in Swedish · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The comments by EMMA-ENPA focus on the DNA objective referred in the present Call of incentivising all market players to invest in advanced connectivity. Fully in keeping with its previous feedback, EMMA-ENPA would oppose the potential imposition under the DNA, directly or indirectly and under any form, of a fair contribution by all digital players an option advanced in the 2023 exploratory public consultation.

This submission from the Coalition for Creativity (C4C) addresses two proposals under the "Level Playing Field" heading of the Digital Networks Act (DNA) Call for Evidence, namely the proposals to empower regulators to "facilitate cooperation" and to "clarify" Open Internet rules. Our core concern is that these proposals risk introducing mandatory network usage fees and eroding net neutrality through the back door.

With 90% of homes passed and a 73% take-up rate by the end of 2024, the FttH rollout in France stands as a remarkable success story. 1/ Keys of the FttH roll-out Frances FttH success story is underpinned by three foundational pillars: Strong Government Leadership Initiated in 2013, the Plan France Très Haut Débit established clear national objectives and mobilized 13 billion in public investment to accelerate fiber…

It is important for Europe to coordinate to improve digital relations and ensure fast and reliable connectivity for all. At the same time, I would like to draw attention to the health risks of the proliferation of radio frequencies on both humid and flora. 5G is not yet deployed but 6G is already emerging, even though more and more people are being made intolerant to waves.

Filed in French · English published by the European Commission

The European Commission's "Forging Europe's Digital Future" initiative appropriately prioritizes modernizing and harmonizing our digital infrastructure. While this work is absolutely essential, we believe the initiative can achieve even greater impact and resilience by explicitly embracing the principles of a human-centric data economy.

Feedback on the DNA Pr. Giovanna De Minico, Dr. Maria Francesca De Tullio SUMMARY VERSION SEE ATTACHMENT FOR THE FULL VERSION Introduction The Digital Networks Act (DNA) aims to strengthen the EUs fundamental objectivesindustrial competitiveness, sustainability, security, and consumer welfare. The present asymmetric rules are designed to foster competition and innovation.

The European Union of the Deaf (EUD), representing 31 members, the National Associations of the Deaf (NAD) across the EU, the EEA, as well as Switzerland and the United Kingdom, wishes to highlight critical issues impacting more than 1 million deaf sign language users under the current European electronic communications framework. 1.

Digital Networks Act aims to help boost secure high-speed broadband, both fixed and wireless. We "Europeans for Safe Connections" we welcome the emphasis on fixed broadband infrastructure. However, we feel compelled to provide constructive feedback on the health implications of wireless connectivity. Suggestion no. 1: Prioritize cabled connections. Suggestion no.

The Input to Digital Network Acts 2025 presents the consolidated feedback of the DigitalTrade4.EU consortium in response to the European Commissions strategic initiatives on the Digital Networks Act and the European Data Union. Our consortium outlines a unified vision for a secure, interoperable, and dual-use digital infrastructure that supports both economic competitiveness and defence readiness.

Digital Networks Act aims to help boost secure high-speed broadband, both fixed and wireless. We "Europeans for Safe Connections" we welcome the emphasis on fixed broadband infrastructure. However, we feel compelled to provide constructive feedback on the health implications of wireless connectivity. Suggestion no. 1: Prioritize cabled connections. Suggestion no.

Europe needs a fairer regulatory framework for all players in the sector to strengthen domestic digital infrastructure and services providers in a global competition and to grow employment opportunities. Truly sustainable competition for all industry players should not be solely based on prices, as this impacts on employment in the sector.

All swedish municipalities who created injustice by zero collaborations with individuals ans diarienumbers involved in Human Rights and the Right to Health as a project supporting HealthCare Analyse via www.vardanaly.se became a responsibility to report for my study circle Sustainable Open Studio from 2012-2025.

Innovation via films and contributions should be included via UHR as educational support to freelance study circle leader: Sustainable Open Studio via EU and 49 organisationan via 49 platformsshared with WIPO Global Award 2024-2025 with no support from Sweden yet as project to help FitForFutureGenerations.