Since 2007, the ESYS Foundation has engaged in reflection on security issues and has contributed to legislative processes, seeking to provide expertise and know-how in the field. In this spirit, we hereby submit the following remarks in the context of this call for evidence process focused on these issues necessary to reduce administrative burden, inefficiencies and increase European competitiveness: 1.
EF
ESYS Foundation
NGO · Spain
not in the EU Transparency RegisterThis organization files on consultations without a register number, so its record here is built from its filings alone. Register facts (staff, costs, accreditations) are not available for it.
4
positions filed
in the 665 files tracked
3
legislative files
of 665 tracked
3
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 665 consultation files tracked so far (57,774 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
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Their record over time
ESYS Foundation filed 4 positions between 11 Jul 2025 and 13 Apr 2026, across 3 of the 665 legislative files tracked here, attaching a full position paper 3 times.
2025 · 2 filed2026 · 2 filed
What they argued
ESYS Foundation welcomes the opportunity to contribute to the Call for Evidence on the forthcoming Digital Networks Act (DNA) ESYS wishes to emphasize, as clearly stated in the Commissions document, that The availability of high-quality, reliable and secure connectivity for end-users as well as for key economic sectors is a must.
Although ESYS fully supports both the substance and the ambition of Regulation (EU) 2024/2847, the current timeline reveals structural implementation gaps liable to compromise the effectiveness and coherence of the Regulation.
Article 100 should be amended so that it is not the Commission but the European Council that shall verify the risk posed by that country and that adopts the measures provided for in Articles 101 and 102 of the proposal.
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Turns up on the same files
Organizations that also filed on at least two of the same consultations. A shared interest in the same dossiers, not evidence of coordination, and we do not suggest any.
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