Telekom Austria AG

Telekom Austria AG welcomes the European Commissions efforts to simplify and harmonize the EUs digital regulatory environment through the Digital Omnibus initiative. From our perspective, genuine simplification and harmonization require an ambitious, comprehensive approachnot just tweaking individual regulations, but ensuring that all digital legislation fits together consistently and efficiently.

A1 Telekom Austria Group Digital Networks Act (DNA) Position Paper 01 “Europe is not under-regulated. It is over-duplicated.” Executive Summary • • • Telecom regulation is still carried out separately in 27 Member States, creating duplication and fragmentation. National regulatory authorities cost ~€700–900 million annually – excluding significantly higher compliance costs.

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

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.

positive: * simplification of DMA * reduction of qualitative datapoints * clarification impacts/baseline etc. * better readability as well as integration of AR in the Standard to be improved: * information about thresholds for materiality to be amended * S1 metrics: some definitions still leave room for interpretation and are lacking practicability * E5: still only focused on producing companies, not meaningful and…

A1 Group appreciates the opportunity to provide input to the European Commission's consultation. We support the Commission's efforts and advocate for a swift, separate legislative proposal. This response encapsulates A1 Groups positions on key aspects of EU digital policy reform, underscoring our commitment to shaping a forward-looking regulatory framework that supports digital growth and innovation across Europe.