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’s position on the draft delegated regulation on the obligation for certain companies to publish non-financial information

    ETNO (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.

    ETNO fully supports the EU taxonomy role as an essential facilitator of the EU Green Deal, with the purpose of channelling long-term, sustainable finance into sustainable activities.

    4 June, 2021 Read more
  • Position papers

    ETNO policy position on Data Governance Act

    With the ever-growing number of data generated today, the EU needs the right governance model to unleash the potential of the data economy that could benefit to the society, citizens and companies. A key pillar of the EU Data Strategy (February 2020) welcomed by ETNO, the proposed Data Governance Act aims at boosting data sharing across sectors and member states while increasing citizens’ and companies’ trust and control over their data.

    As the telecom industry can provide data market places and data broker services [1], ETNO welcomes the opportunity to provide feedback to the DGA and share its views to achieve a successful, competitive, and innovative single data market.

    10 May, 2021 Read more
  • Position papers


    ETNO and GSMA welcome the Commission’s initiative to create a harmonised ex-ante instrument targeted at the providers of core platforms services designated as gatekeepers via the Digital Markets Act (DMA). Current legislative instruments are not sufficient to ensure contestable and fair markets in the digital economy. This would also support the DMA’s objective to strengthen the internal market by setting out harmonised rules across the EU.

    6 May, 2021 Read more
  • Position papers

    ETNO POSITION PAPER on the EC proposal on the review of roaming regulation

    The main objective pursued by the EC when reviewing current Roaming regulation is to assess whether the retail roaming market within the EU (RLAH) is working properly and whether since 2014 the market has experienced any material changes that are not properly reflected or tackled through current framework and accordingly the need for an update of such framework.

    According to diverse reports from the EC and BEREC, it seems that the RLAH regulation in force is working well. The EC proposal  is based on a cost modelling not taking into account the ongoing 5G transformation, the traffic patterns and investment needs. Moreover, the  ‘quality of service (QoS)’ obligations beyond existing transparency rules are not fit for purpose. In addition, the impact of the COVID crisis is not adequately considered across a number of dimensions, such as the impact on supply chains or deployment planning, volumes, …

    Read the full document at the link below.

    5 May, 2021 Read more
  • Position papers

    Digital Services Act Joint Position by the GSMA and ETNO

    Since the adoption of the eCommerce Directive (eCD) in 2000, the use of digital services has increased considerably. Last year, almost 85 percent of all individuals in the EU-28, aged between 16 and 74 years, were using the internet regularly1. At the same time, the variety of online services has also grown exponentially, and new business and value creation models have emerged. In particular, the importance of online platforms that allow the wide dissemination of user-uploaded content to society has drastically increased.

    27 April, 2021 Read more
  • Position papers

    ETNO – GSMA joint response to the European Commission’s Digital Levy public consultation

    ETNO and the GSMA welcome the possibility to provide their comments below in response to the European Commission’s (‘EC’) Digital Levy public consultation.

    14 April, 2021 Read more
  • Position papers

    ETNO responses to RSPG Consultations on draft opinions on RSPP, Spectrum sharing, and Additional spectrum needs

    As ETNO appreciates the opportunity to provide comments to the consultations on the RSPG draft opinions on RSPP, Spectrum sharing, and Additional spectrum needs and guidance on the fast rollout of future wireless broadband networks.

    30 March, 2021 Read more
  • Position papers

    ETNO position paper on the Revised Directive on Security of Network and Information Systems (NIS2)


    ETNO welcomes the Cybersecurity Package proposed by the European Commission on 16th December 2020, which is an important part of the EU's digital transformation and recovery efforts. The package consists of the EU Cybersecurity Strategy for the Digital Decade (Cybersecurity Strategy), a proposal for a Directive on the Resilience of Critical Entities, repealing the Critical Infrastructure Directive (EC) 2008/114, and notably, a proposal for a Directive on measures for a high common level of cybersecurity across the Union (‘NIS 2'), repealing Directive (EU) 2016/1148 (NIS).

    30 March, 2021 Read more
  • Position papers

    Public Consultation on the Evaluation and Review of the Broadband Cost Reduction Directive


    The Broadband Cost Reduction Directive (2014/61/EU) aims to facilitate and incentivise the roll-out of high-speed electronic communications networks by lowering the costs of deployment with a set of harmonised measures. The measures focus on access to existing physical infrastructure, coordination of civil works, simplification of administrative procedures and requirements for in- building physical infrastructure for new buildings and major renovations. It also includes provisions to ensure transparency of relevant information through Single Information Points and dispute resolution mechanisms. 

    3 March, 2021 Read more
  • Position papers

    Joint Statement on Strengthening sectoral social dialogue in the services industry: The all-important role of social partners in building a resilient Europe

    The origin of European social dialogue lies in the EU’s decision to address social and economic issues arising from the creation of an EU single market through discussions between representatives of employers and workers (Art. 154f). Social dialogue has been the cornerstone of the social dimension of the single market.

    28 January, 2021 Read more
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