Our formal response to the European Commissions Digital Networks Act (DNA) posits that the proposal suffers from a fundamental conceptual error by characterizing the Internet as a vertically integrated system rather than a layered, distributed 'network of networks'.
NET
Netnod
Company · Sweden · EU Transparency Register 132766341878-97
5
positions filed
in the 665 files tracked
5
legislative files
of 665 tracked
5
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.
Who they are
Among the 1210 companies & groups on this site, they rank #337 by legislative files engaged, a count of participation, not a measure of influence.
0.2
declared lobbying FTE
self-declared
< €10K
declared costs / yr (floor)
0
EP accreditations
as declared to the register
2021
in the register since
Declares membership of
- Euro-IX
- Svenska Operatörers Forum
- Internet Society →
- Internet Cooperation for Assigned Names and Numbers
- Swedish Networks Users Society
- ICC Sweden
- GAIA-X
- Réseaux IP Européens
- Internet Engineering Task Force
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026).
- Register category
- Companies & groups
- Registered as
- Netnod AB (Netnod)
- Head office
- Solna, Sweden
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026); cost bands are floors, not audited totals. Reused under Commission Decision 2011/833/EU.
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Their record over time
Netnod filed 5 positions between 18 Mar 2021 and 15 Jun 2026, across 5 of the 665 legislative files tracked here, attaching a full position paper 5 times.
2021 · 1 filed2023 · 1 filed2024 · 1 filed2026 · 2 filed
What they argued
Netnod sees three primary concerns. First, Netnod opposes the mandatory collection of entity IP ranges (Article 3(4)), suggesting ENISA retrieve this data directly from RIR systems (WHOIS/RDAP) to avoid duplicative, error-prone reporting. Second, we stress the need to reinforce the established global, multistakeholder model for Internet standards and limit new ENISA powers to policy, not operational protocols.
Netnod welcomes the opportunity to provide feedback on the consultation launched on 24 February 2024 on the European Commissions White Paper How to Master Europes Digital Infrastructure Needs? (hereinafter WP). Netnod has the following comments: - The leitmotif of the WP concerns further convergence and vertical integration of networks in the EU; This is contrary to the Internet model and contrary to the findings of…
A summary of Netnod comments on the content of the suggested regulation can be found below. For the full response, see attached document. 1. There is no recognition that a product can consist of many components.
Netnod have in the attached PDF comments on the proposed directive. A summary: Regarding CSIRTs Netnod believe it is not only the reporting to a CSIRT that is important, but also what a CSIRT produces with the help of that information. The directive because of this should include requirements for CSIRTs to produce good reports. Regarding the domain name system (DNS) the definitions must be much more clear.
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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.
Showing 5 of 206.
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Everything on this page comes from Netnod’s own submissions to the European Commission. We have added nothing and interpreted nothing. If something is wrong or out of date, email info@policyspeak.com and we will correct it. If you are an individual named in a record, our privacy policy sets out your rights to correction, objection and removal.
Quotes are verbatim from submissions published by the European Commission, trimmed to their opening passage and never summarized by a model. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.