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 and GSMA input for the Call for Evidence on virtual worlds (metaverses): a head start towards the next technological transition

ETNO and GSMA welcome the opportunity to provide input to the European Commission’s Call for Evidence on virtual worlds and the technologies driving the transformation towards the next technological transition.
24 May, 2023 Read more
Position papers
Joint Statement: Access to data by public bodies: a double-edge tool to use with caution and restraint

In times of crisis, companies stand ready to do their part and help public bodies by sharing data to tackle public emergencies, as evidenced during the Covid-19 pandemic. However, to function, mandatory data sharing between private companies and governments needs clear and transparent conditions for all parties involved.
22 May, 2023 Read more
Position papers
ETNO position paper on the European Commission’s proposal “Gigabit Infrastructure Act”

ETNO attaches great importance to the current proper implementation of the Broadband Cost Reduction Directive (BCRD) and its successor, the Gigabit Infrastructure Act regulation, in order to help accelerate the deployment time of 5G and Gigabit broadband, as well as to help reduce the overall cost of deploying these networks.
17 May, 2023 Read more
Position papers
EU Taxonomy and the European telecommunications sector

The European telecommunications sector is a major contributor to the fight against climate change. The sector is greening its own operations, and rolling out more energy-efficient, next generation networks, which play an important enabling role for smart solutions, thus reducing the environmental impact across other sectors of the economy and society.
11 April, 2023 Read more
Position papers
ETNO contribution to the consultation on the Global Digital Compact

ETNO and its members have long played a key role in global digital leadership, engaging with organizations such as the Internet Governance Forum (IGF), the International Telecommunication Union, the Council of Europe, and the institutions of the European Union.
5 April, 2023 Read more
Position papers
Joint GSMA – ETNO comments on the adoption of the European Parliament and Council of the EU mandate to negotiate on the Data Act

Thes comments have been released by ETNO and the GSMA

Brussels, 27 March 2023 - Europe’s telecommunication industry welcomes the Data Act and supports the objective of fostering data sharing and re-use across sectors and national borders in the single market.
27 March, 2023 Read more
Position papers
ETNO-GSMA position paper on the Cyber Resilience Act

The Cyber Resilience Act (CRA) proposal comes at a time when European society, its citizens and businesses have been dealing with a crisis period marked by the COVID-19 pandemic and the war in Ukraine. The telecommunications sector has been capable of responding to these challenges and of demonstrating its robustness, by providing secure and reliable infrastructures and services that are essential for the functioning of the EU’s Digital Internal Market. However, telecommunication network operators are still faced with security gaps in their digital value chains that need addressing.
20 March, 2023 Read more
Position papers
ETNO response on Key performance indicators for the Digital Decade policy programme 2030

ETNO welcomes the opportunity to provide its comments to the Draft European Commission Implementing Act on the Key performance indicators for the Digital Decade Policy Programme 2030 (DDPP). The telecom industry is engaged in fulfilling the 2025 Gigabit and 2030 Digital Compass objectives.
14 March, 2023 Read more
Position papers
Edge Cloud and Strategic Capacity Building in the EU Policy Context on Cloud

The pressures of the pandemic have shown the importance of a reliable and secure digital infrastructure and the need to avoid dependencies in strategic supply chains. Next to communication networks, cloud services form a critical part of the infrastructure that enables the proper functioning of our economies and societies in an increasingly digitized world. For the European Union, access to secure and state-of-the-art cloud infrastructure has therefore become a crucial policy objective to support the Union’s digital ambitions and to facilitate the data economy.

The increasing attention from policymakers has led to the emergence of what can be described as a first comprehensive set of regulations and initiatives aimed at the cloud market in Europe. Several initiatives with impact on cloud are either already adopted (DMA, NIS-Directive), currently being prepared (IPCEI CIS, EUCS, Data Act) or are yet to be proposed (Cloud Rulebook, Cloud Marketplace, Data Act sector-specific regulations). Amidst this rapidly evolving policy landscape, this paper aims to explain what edge cloud is, why it is relevant, and how it fits into the larger EU policy context. In addition, this paper elaborates on the unique role of European telecommunication providers in delivering an edge-cloud continuum.

For further questions, please contact Paolo Grassia, Public Policy Director at ETNO (grassia@etno.eu), Ross Creelman, Public Policy Manager at ETNO (creelman@etno.eu) and Xhoana Shehu, Policy Manager at ETNO (shehu@etno.eu).
10 January, 2023 Read more
Position papers
GSMA-ETNO input to BEREC’s opinion on the Commission Implementing Regulation on the Fair Use Policy and Sustainability of the Roaming Regulation

GSMA and ETNO welcome the opportunity to provide comments to BEREC’s opinion on the functioning of the Commission Implementing Regulation on the Fair Use Policy (FUP) and Sustainability of the Roaming Regulation.

The possibility to apply FUP is a fundamental feature of “roam-like-at-home” regime, which enables the operators to prevent losses caused by users using roaming services for purposes other than periodic travel.

This element of the roaming service conditions will become even more crucial in a M2M scenario, where FUP allows operators to prevent massive use of their M2M solution abroad, which would open up the doors for harmful arbitrage.

In the view of the GSMA and ETNO, the Fair use policy provisions not only need to be maintained but would benefit from improvements and simplification due to the current high complexity of the existing control mechanism.

In our view, the Regulation should be defined in a way where any controls are transparent and easy to understand for customers, easy to implement and track for network operators, and based on cost-efficient solutions. We therefore continue to believe that when reviewing the Implementing Regulation, the Fair use policy provisions should be changed concerning open data bundles, limits on voice/SMS, simplification of 4-month window rule, and proof of normal residence or stable links.

Fair use rules that foresee the (ex post) monitoring of roaming vs domestic presence and traffic are extremely costly and complex to implement. Therefore, in some cases, operators have decided not to use this tool at all.

The (ex-ante) setting of a fair use limit on open data bundles also present challenges e.g., it:, (i) does not protect operators from providing the service below cost, and (ii) will be watered down in the event of a further reduction of wholesale caps.

For further questions, please contact Maarit Palovirta, Senior Director Regulatory Affairs, ETNO (palovirta@etno.eu) or Xhoana Shehu, Policy Manager, ETNO (shehu@etno.eu) and Lotte Abildgaard (labildgaard@gsma.com), Director Public Policy, GSMA.
12 December, 2022 Read more
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