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

    Telecommunications and Cable Industry Note on the Draft e-Privacy Regulation

    ETNO, the GSMA and Cable Europe, as the voice of Europe’s leading telecom and cable operators, have been heavily invested in the debate surrounding the draft e-Privacy Regulation, since its publication in January 2017.

    27 January, 2020 Read more
  • Position papers

    ETNO position on DNS over https (DoH)

    Executive summary

    The Domain Name System (DNS) is a critical element of the Internet infrastructure. DNS resolvers in particular play an essential role for operators and Internet Service Providers in providing access to the web for their customers. These resolvers are intermediaries that see the vast majority of DNS traffic sent today from and to their end-users to access the Internet, from web content to cloud infrastructures.

    A new protocol “DNS over HTTPS” (or DoH) was developed in order to enhance user privacy and security. This was itself followed by various announcements from browser makers on the deployment of the protocol. ETNO is of the opinion that, as a protocol, DoH may provide some improvement to currently deployed DNS technology. However, the foreseen deployment models raise a number of issues, not least related to policy, law enforcement, user privacy and governance.

    The deployment models of DoH will have a technical impact on operators, as well as a significant policy impact. Investigations and blocking against malicious content risk becoming more difficult, with operators no longer being able to comply with legal requests for blocking; and the impact of a failure will be multiplied on account of a single point of failure. Less accountability, less transparency, and reduced geographical diversity among public DNS resolvers may have broader impacts on existing EU policies which rely on a secure and transparent Internet ecosystem: ePrivacy, eEvidence, data and competition, and digital services.

    ETNO calls for a broader, international discussion – beyond the technical community – to consider the non-technical consequences related to data protection, regulation, competition and law enforcement. Policymakers should review DoH technology and its deployment models to consider its policy implications, while the technical community should work together to develop mechanisms to address the negative technical impacts.

    18 December, 2019 Read more
  • Position papers

    ETNO-GSMA Tax Policy Committee Position

    Implementation within Member States of provisions of Council Directive 2006/112/EC (“the EU VAT Directive”) concerning VAT adjustments on unpaid invoices, and specific impact on the telecommunications sector.

    5 December, 2019 Read more
  • Position papers

    GSMA ETNO Position paper on the proposal for a regulation on preventing the dissemination of terrorist content online

    Executive summary

    • We invite co-legislators to support the amended wording in the Parliament’s text on Article 2 and Recital 10, clarifying that hosting services which satisfy at least one of the following criteria should be outside of the scope of the regulation:

    9 July, 2019 Read more
  • Position papers

    ETNO Comments on EDPB draft Guidelines on Article 6(1)(b) GDPR


    On 9th April, the European Data Protection Board (EDPB) released its draft Guidelines on the processing of personal data under the contractual necessity legal basis (Article 6(1)(b) GDPR) in the context of the provision of online services to data subjects. EDPB has invited interested stakeholders to comment on the draft Guidelines until 24th May 2019. ETNO welcomes the opportunity to submit comments to the EDPB on this important topic, but regrets the static interpretation given by EDPB on the “contractual necessity” legal ground.

    31 May, 2019 Read more
  • Position papers

    Telecom operators’ priorities for Horizon Europe

    Last June, the European Parliament and the European Council endorsed a decision regarding the next Horizon Europe framework programme, which brings an overview of its structure. ETNO, which represents the key European telecom operators that heavily invest in research and innovation, would like to highlight a number of aspects that are vital for future research and development across all sectors, as they digitise and integrate advanced ICT technologies and services. 

    20 February, 2019 Read more
  • Position papers

    ETNO position paper on a revision of WTO rules in the field of telecommunications and other digital services / e-commerce

    The digital transformation is fundamentally changing societies and economies, including international trade. Digital trade creates tremendous opportunities for inclusive economic growth and societal advancement. At the same time, digitally enabled trade in goods and services has given rise to new regulatory challenges. Therefore, we are convinced that the digital economy should be an important element of bilateral and multilateral trade policy. Already in July 2016, ETNO called for an update of trade policy to reflect new realities of the digital economy.1

    18 February, 2019 Read more
  • Position papers

    ETNO Response to the Stakeholders' Consultation on Draft AI Ethics Guidelines

    ETNO responded today to the stakeholder consultation on the draft AI Ethics Guidelines for Trustworthy Artificial Intelligence, prepared by the European Commission’s AI High-Level Expert Group.

    1 February, 2019 Read more
  • Position papers

    ETNO response to the Public Consultations on BEREC Report on Access to physical infrastructure in the context of market analyses

    ETNO welcomes the opportunity offered to comment the draft BEREC report on Access to physical infrastructure in the context of market analysis. We welcome the comprehensive overview BEREC offers of the way various NRA’s treat physical infrastructure in the context of their respective national markets. However, we do have questions regarding the chapter reflecting on ways to deal with a hypothetical separate market for physical access. We elaborate on the reasons for that below.

    In order to access the full PDF document, you may click on the button below. 

    23 January, 2019 Read more
  • Position papers

    Joint ETNO / GSMA response to the BEREC public consultation on the Draft BEREC Report on Terminating Contracts and Switching Provider

    Do you have any comments or observations regarding the processes set out in Section 2 above, related to the switching of provider for different categories of ECS and the safeguards that are provided to consumers?

    • ETNO and GSMA find it surprising that BEREC has decided to look into contract termination and provider switching while the relevant regulation has been updated and significantly tightened – even including new far-reaching provisions on telecom bundles – in the new Directive (EU) 2018/1972 establishing a European Electronic Communications Code (EECC).
    23 January, 2019 Read more
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