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

    ETNO-GSMA contribution to BEREC Report on Cloud and Edge Computing Services

    Cloud and edge services are at the core of the transformation that our sector is undergoing: telecoms operators are turning their networks into platforms for innovation by embracing disaggregated and cloud native architectures, high automation (e.g. based on AI/ML), programmability, and the development of new network as a service (NaaS) applications. As ETNO and the GSMA, we have outlined our vision for telecom transformation in our contribution to the European Commission’s consultation on the future of the electronic communications sector and its infrastructure, which is clearly reflected in the Commission’s White Paper “How to master Europe’s digital infrastructure needs?”1.

    23 May, 2024 Read more
  • Position papers

    ETNO Position Paper on 6G

    The European Union has set ambitious Digital Decade targets for 2030, among them the objective to cover all populated areas with wireless high-speed networks of at least 5G performance. Societies increasingly rely on high-speed mobile and broadband connections. We expect Europe’s mobile data consumption per user to continue growing in the coming years with an annual growth rate of 25% . Mobile connectivity has a key role to play in attaining digital inclusion for all European citizens and businesses and enabling the twin digital and green transition.

    29 April, 2024 Read more
  • Position papers

    ECTA, ETNO & GSMA Joint Statement on the European Parliament proposals to payment services regulation after the plenary vote

    Today, the European Parliament voted on a report proposing amendments to the European Commission’s proposal for a revised Payment Services Regulation. 

    The European telecommunications industry recognises the importance of revising payment service rules to improve consumer protection in electronic payments . We are keen to work closely with the banking sector to fight against impersonation fraud.

    Therefore, we call policymakers to find a proportionate and workable solution by deepening cooperation between the two sectors without changing the liability regime.

    To be effective in fighting impersonation fraud and safeguarding consumers the final text should strike the right balance and ensure that any additional obligations on telecommunications providers are aligned with what is legally and technically feasible.

    23 April, 2024 Read more
  • Position papers

    ETNO-GSMA position on impersonation fraud in Payment Services Regulation

    The GSMA and ETNO strongly encourage policymakers to reconsider their approach to increasing liability for electronic communications services (ECS) providers in cases of impersonation fraud.

    Imposing liability on ECS providers will move responsibility of repayment to the victims of fraud, rather than helping to combat fraud from happening. The financial services sector has the direct consumer contact, designs the financial products, and they should and can setup sufficient safeguards when they do so. Telecoms operators provide access to the free and open internet. Our products, including text messages and numbering are widely known and are not designed to cater to the need of the financial sector specifically. If the telecoms sector is to be made financially liable, then it will have to change the way internet access and communication services are provided and setup strict safeguards for the use of text messages to the severe detriment of both the consumers and the financial sector.

    Telecoms operators have seen the most effective solutions come from bilateral cooperation with the financial services sector and would encourage policymakers to combat fraud by working with industry to facilitate and encourage this cooperation. The Payment Services Regulation should focus on the cooperation as a solution to combat fraud.

    Telecoms operators value consumer trust and are invested in combatting ’spoofing’ fraud. Members of the GSMA and ETNO are already implementing anti-spoofing and wider anti-fraud solutions on a voluntary basis, which have already proven their effectiveness. However, there are obstructions, both technical and legal, to implementing EU-wide measures - obstructions which can vary in different member states where different legislation applies. These would prevent telecoms operators from complying with proposed measures in the Payment Services Regulation, so removing regulatory obstructions must be a first step in a challenging process.

    We elaborate on our reflections in the paper. 

    14 March, 2024 Read more
  • Position papers

    ETNO position paper on EU guidelines on exclusionary abuses by dominant undertakings

    With a view to the European Commission’s soon to be expected publication of the draft guidelines for the enforcement of Article 102 TFEU and the prohibition of exclusionary abuses by dominant undertakings, ETNO would like to provide some insights regarding its competitive experience on the telecoms market.
    20 February, 2024 Read more
  • Position papers

    ETNO reflection paper on submarine communication cables

    The European Union’s dependence on submarine communication cables has emerged as a significant concern for Europe’s security, resilience, and sovereignty, a vulnerability underscored by notable incidents involving the Nord Stream undersea gas pipeline in 2022 and undersea cables connecting Estonia and Finland in October 2023.

    As the European Commission prepares to release a connectivity package detailing a fresh strategy for its telecom sector and internet infrastructure, including a Recommendation to strengthen coordination among Member States in the deployment, security, and governance of crucial cable connections, ETNO aims to offer its perspective on augmenting the resilience and security of the Union’s submarine cable infrastructure.

    We elaborate on our reflections in the paper. For questions and clarifications regarding this position paper, please contact Paolo Grassia (grassia@etno.eu), Director of Public Policy at ETNO.



    1 February, 2024 Read more
  • Position papers

    ETNO comments to the European Commission’s Draft Implementing Regulation laying down templates concerning the transparency reporting obligations of providers of intermediary services and of providers of online platforms under Regulation (EU) 2022/206

    ETNO welcomes this opportunity to provide comments to the European Commission’s draft Implementing Regulation laying down templates concerning the transparency reporting obligations of providers of intermediary services and of providers of online platforms under the ‘Digital Services Act’ (DSA).

    In general, ETNO believes that the number of variables included in the annex I template should be strictly limited to the DSA obligations pursuant to articles 15(1), 24(1) and 42(2) in order to reduce to the administrative burden for providers. Obligations extend to ETNO members, who do not have neither ability nor the legal right to see the content of communications and therefore to moderate content for the vast majority of the services they provide. Many ETNO members also already publish transparency reports on relevant efforts (e.g. blocking of websites done on the basis of EU and national laws). Detailed regulation of how companies should report implies changes in systems and processes, without tangible benefits in terms of transparency.

    We elaborate on our comments in the document For questions and clarifications regarding this feedback, please contact Xhoana SHEHU, Policy Manager at ETNO (shehu@etno.eu).

    25 January, 2024 Read more
  • Position papers

    ETNO-GSMA comments on EDPB Guidelines 2/2023 on Technical Scope of Art. 5(3) of ePrivacy Directive

    The protection of customer privacy and the confidentiality of their communications is at the core of the services offered by telecom operators. While these rules establish the foundation for delivering secure, trusted telecommunications services in Europe, they must also provide a degree of flexibility to enable European telcos to use data to improve customer experience, bring societal benefits, and, in general, keep pace with innovation and competition.

    Now that the General Data Protection Regulation (GDPR) has been in force for over seven years, a significant body of experience and jurisprudence has developed regarding its application. It is crucial that the e-Privacy rules align with the GDPR, enabling the European industry to remain competitive in the growing field of data analytics and take a leadership role in responsible artificial intelligence.

    ETNO and the GSMA regret that the old e-Privacy Directive (ePD) has become untenable in light of and legal and technological developments that have occurred over the past decade. A series of EU regulations governing the use of personal and non-personal data, such as the Data Act, Data Governance Act, Digital Markets Act, and the soon-to-come Artificial Intelligence Act, have been added to the GDPR. Together, they form a richer framework that combines data privacy with the promotion of competitiveness and innovation. The ePD no longer fits this evolving regulatory landscape.

    We elaborate on our recommendations in the paper. For questions and clarifications regarding this feedback, please contact Paolo Grassia (grassia@etno.eu), Director of Public Policy at ETNO

    19 January, 2024 Read more
  • Position papers

    ETNO comments to the RSPG Draft Work Programme for 2024

    The European Telecommunication Network Operators' Association (ETNO) welcomes the opportunity to provide feedback to the Radio Spectrum Policy Group (RSPG) Draft Work Programme 2024.

    14 December, 2023 Read more
  • Position papers

    ETNO and GSMA response to the consultation on the Commission’s Delegated Regulation amending Regulation (EU) 2015/758 of the European Parliament and of the Council as regards the standards relating to eCall

    ETNO and GSMA represent the telecoms sector in Europe and worldwide. Our members are the companies responsible for deploying next generation connectivity, with the aim of meeting the European Commission’s digital decade connectivity targets, and in parallel, making important progress on the twin green-digital transformation.

    As operators of mobile networks, which carry eCall communications, we have long engaged with the European Commission, national governments, and regulators to discuss the future of eCall, knowing that the phasing-out of 2G/3G networks is already done in many parts of the world and well underway in Europe. We therefore welcome the Commission’s consultation on the draft Delegated Regulation. We would like to emphasize that the subsequent early adoption and entry into force of the Delegated Acts impacting both car manufacturers and PSAPs is of great importance for many reasons, resource efficiency, innovation transformation and in relation to spectrum. Indeed, spectrum currently used in legacy networks is refarmed for 4G/5G mobile networks, meeting increasing demand for high-speed connectivity and IoT solutions.

    Draft Delegated Regulation amending Regulation (EU) 2015/758

    We support the proposed approach where new vehicles, placed on the market after 1st January 2027 will be considered in conformity with the regulation where they comply with the technical specifications for packet-switched eCall.

    In this regard, we also express our strong support for the voluntary option for early adopters to be considered in compliance with the regulation should they decide to place new vehicles on the market supporting eCall in packet-switched networks after 1st January 2025.

    Immediate use of new standards

    The utmost priority of the forthcoming Delegated Act is for the standards and technical specifications cited therein to be made applicable as soon as possible. This is a key objective of the act and should therefore not be delayed by the additional requirement for standards to be transposed into national legislation before being able to be applied. We are therefore highly concerned about the proposal to defer the date of application of such standards in recital 7.

    Rather, we encourage the Commission and the Council to enable the immediate application of the cited standards and technical specifications upon entry into force of the Delegated Act, in the understanding that these standards have already been developed, approved and published for use in the EU internal market.

    This is also critical for the voluntary adoption from certain manufactures as well (as mentioned in our point above) which demand such predictability and assurance at the earliest possible.

    Long-term solution to eCall

    ETNO and GSMA have engaged in thorough discussions with relevant stakeholders, including the European Commission, since several years now to raise our concerns on the current eCall solution. The priority for all the participants in the ecosystem is on ensuring that new vehicles will be supporting packet-switched eCall in 4G/5G networks as soon as possible. With the current proposals for Delegated Acts well underway, we anticipate this to be solved urgently.

    Following, the conclusion of this urgent task, which benefits everyone involved and the European citizens, a long-term solution for eCall should be anticipated and planned for in the Commission’s future mandate from October 2024.



    ETNO, the European Telecommunications Network Operators' Association, represents Europe’s telecommunications network operators and is the principal policy group for European e- communications network operators. ETNO’s primary purpose is to promote a positive policy environment allowing the EU telecommunications sector to deliver best quality services to consumers and businesses.

    The GSMA is a global organisation unifying the mobile ecosystem to discover, develop and deliver innovation foundational to positive business environments and societal change. Our vision is to unlock the full power of connectivity so that people, industry, and society thrive. Representing mobile operators and organisations across the mobile ecosystem and adjacent industries, the GSMA delivers for its members across three broad pillars: Connectivity for Good, Industry Services and Solutions, and Outreach.

    22 November, 2023 Read more
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