Position papers

ETNO's position papers present its member-companies' views on a wide range of technical, regulatory and trade issues to European Union decision-makers, national governments and the general public.

They are developed either internally by ETNO working groups or, occasionally, in co-operation with third parties such as other industry associations.

Click here for definitions of ETNO Position Papers and Expert Contributions.

  • Position papers

    170131 ETNO Data Portability Memo

    ETNO shared with the Article 29 Working Party the a legal memo noting that while the Guidelines provide many useful additions and clarifications, they also contain some suggestions that are particularly problematic for the industry, users and third parties.

    16 February, 2017 Read more
  • Position papers

    2nd Joint Declaration by Industry and RTOs: Boosting Europe’s Future Competitiveness as Key Priority for FP9

    We, the undersigned associations representing key European industrial research and innovation stakeholders, call on the European Commission, the European Parliament and the Council of the European Union to develop the next EU Research & Innovation Framework Programme (FP9) with an appropriate design and budget, at the level of the ambitions of the Renewed EU Industrial Policy Strategy.

    21 February, 2018 Read more
  • Position papers

    A Telecoms Industry View on the Digital Services Act: Joint Position Paper by ETNO and GSMA

    In this digital age, the future of our democracies, societies and economies depends on digital ecosystems that are open, fair, competitive, and respectful of the rule of law.

    The adoption of digital technology brings the promise of addressing some of the biggest challenges of our times: climate change, inclusion, socio-economic growth – just to name a few.
    However, progress will only happen if digital industries are able to advance a purpose that goes beyond just delivering for narrow categories such as “users” or “consumers”. Digital technology needs to serve citizens.

    7 September, 2020 Read more
  • Position papers

    Building a digitally-enabled recovery

    Executive Summary

    This paper offers unique insights on the impact of the coronavirus crisis on Europe’s top tech business: the telecom sector[1]. As we collectively work to re-design Europe’s vision and strategic plans for the coming years, ETNO puts forward facts, figures, analysis and ideas on how to reboot the EU socio-economic engine by leveraging telecom networks and digital services.

    1. The coronavirus crisis and the corresponding recession are testing not only Europe’s ambitions on digital networks and services, but also its policy and regulatory framework. A fresh look should be given on maintaining and boosting Europe’s investment capacity in new telecom networks and digital services.

    2. There is no recovery without ambitious plans for deep and widespread digitalization. Digitalization is the “missing” link that connects Europe’s recovery and growth plans with the EU Green Deal. We need concerted and bold effort to increase investment in 5G and fibre networks and ensure uptake of digital technologies by all industrial sectors, administrations and across all EU countries.

    3. The building site for Europe’s digital backbone is still open: the first step is to support and boost investment in 5G and fibre networks. We propose to develop a strategic focus on the following 4 key priorities:
      1. reduce the cost of roll-out (p.7)
      2. EU-wide good practices in spectrum allocation and use (p.8)
      3. align competition rules and digital aspirations (p.9)
      4. focus on inclusive connectivity (p.9)
    4. Fostering the European digital ecosystem, digital uptake and demand is as important as supporting supply. We propose to develop a strategic focus on the following 4 key areas:
      1. deeply digitalise Europe’s SMEs and public administration (p.10)
      2. involve consumers and promote adequate awareness and education on technology (p.11)
      3. pave the way for the creation of European digital leaders (p.12)
      4. unleash Europe’s potential in data-driven services (p.12)

    If you wish to stay tuned on ETNO’s updates on technology, telecoms and tech policy, you can subscribe to our #ETNODigital Newsletter. If you wish to discuss our ideas or get more information and insights, you can get in touch with our Team of policy and technology experts.

    [1] Forbes Digital 100 Index, 2019: of the 17 Europe-based brands, 11 are telecom operators and telecom equipment manufacturers.

    28 May, 2020 Read more
  • Position papers

    Civil enforcement of intellectual property rights: public consultation on the efficiency of proceedings and accessibility of measures - ETNO considerations

    ETNO is the European association representing approximately 40 member companies in the telecommunications market across 35 European countries. Besides being network and Internet access providers, many ETNO members also offer hosting services. In addition to this, many members are also content providers and are active in the promotion and provision of legal content services. As such, ETNO is very much interested in this debate.

    29 March, 2013 Read more
  • Position papers

    Comments on Draft ECC Recommendation 15(02): “Guidelines for Major Changes to National Numbering and Dialling Plans concerning E.164 Numbers”

    19 January, 2015 Read more
  • Position papers

    Communication on Engagement to the UN Global Compact and its ten Principles in the areas of Human Rights, Labour, Environment and Anti-Corruption

    27 January, 2016 Read more
  • Position papers

    Communication on Engagement to the UN Global Compact and its ten Principles in the areas of Human Rights, Labour, Environment and Anti-Corruption

    Find the full communciation here.

    The European Telecommunications Network Operators’ Association (hereinafter ETNO) with this document submits its second Communication on Engagement with the UN Global Compact.


    10 April, 2018 Read more
  • Position papers

    Consultation of e-Business Stakeholders for the WSIS+10 Review

    The C7 e-Business action line covers the following items:
    a) Governments, international organizations and the private sector, are encouraged to promote the benefits of international trade and the use of e-business, and promote the use of e-business models in developing countries and countries with economies in transition.
    b) Through the adoption of an enabling environment, and based on widely available Internet access, governments should seek to stimulate private sector investment, foster new applications, content development and public/private partnerships.
    c) Government policies should favour assistance to, and growth of SMMEs, in the ICT industry, as well as their entry into e-business, to stimulate economic growth and job creation as an element of a strategy for poverty reduction through wealth creation.

    15 February, 2013 Read more
  • Position papers

    CP073 - ETNO Common Position commenting on the Work Programme of the Radio Spectrum Policy Group (RSPG)

    ETNO considers the proposed 17-point RSPG Work Programme to be complete, requiring no additional points.

    9 January, 2004 Read more
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