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

    Joint Telecom Industry Statement on the Gigabit Infrastructure Act

    Our Associations ECTA, ETNO, GIGAEurope and GSMA Europe represent the European telecommunications industry. Our industry plays a crucial part in connecting European citizens and businesses and facilitating the EU green and digital transition.

    27 September, 2023 Read more
  • Position papers

    ETNO comments to the RSPG Draft Opinion on the development of 6G and possible implications for spectrum needs and guidance on the roll-out of future wireless broadband networks

    The European Telecommunication Network Operators' Association (ETNO) welcomes the opportunity to provide feedback to the Draft RSPG Opinion on the development of 6G and possible implications for spectrum needs and guidance on the roll-out of future wireless broadband networks.

    25 August, 2023 Read more
  • Position papers

    ETNO comments to the RSPG Draft Opinion on Strategy on the future use of the frequency band 470-694 MHz beyond 2030 in the EU

    The European Telecommunication Network Operators' Association (ETNO) welcomes the opportunity to provide feedback to the Radio Spectrum Policy Group (RSPG) Draft Opinion on the “Strategy on the future use of the frequency band 470-694 MHz beyond 2030 in the EU”.

    24 August, 2023 Read more
  • Position papers

    ETNO position paper: Substantiating Green Claims and Right to Repair

    Telecom operators have taken decisive measures to increase sustainability of their operations and increase circularity in their business, bearing in mind the objective of increasing the useful life of devices.

    17 July, 2023 Read more
  • Position papers

    ETNO statement on International Data Transfers

    In the last years, new regulatory frameworks that guarantee user privacy in the digital environment have been adopted worldwide, from Africa, to South America and Asia.

    17 July, 2023 Read more
  • Position papers

    GIGAEurope, ETNO & GSMA seek greater clarity on the media concentration screening mechanism in the European Media Freedom Act

    Industry associations representing fixed and mobile connectivity providers in Europe, GIGAEurope, ETNO and GSMA, wholly support the objectives of the European Media Freedom Act (EMFA) to protect media independence and plurality, which are essential for functioning democracies and markets. As the legislative process advances, however, we would like to take this opportunity to recall the importance of ensuring that procedures for screening concentrations in Articles 21 and 22 provide the requisite legal certainty for companies with media-related services in their portfolios

    Drawing on related EU instruments,[1] GIGAEurope, ETNO and GSMA respectfully propose to reinforce Articles 21 and 22 of the EMFA proposal with the following technical details to ensure efficiency, predictability, and a clear division of responsibilities across the different regulatory bodies involved in this process.

    As investors and operators of Gigabit and 5G connectivity networks across Europe, our members play an important role in delivering audiovisual media services to EU citizens. The absence of the above procedural details on assessment timelines and safeguards for commercially sensitive information in the EMFA’s concentration screening mechanism could contribute to substantial delays and divergent procedures. This may lead ultimately to a more fragmented business landscape and unintentionally disincentivise valuable investment in the EU.


    For questions or clarifications on this joint statement, please contact:

    [1] See, for example, the EU Merger Regulation and the FDI Screening Regulation.

    17 July, 2023 Read more
  • 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.

    11 July, 2023 Read more
  • Position papers

    ETNO-GSMA position paper: European Spectrum Policy for the Digital Decade – options for the new Radio spectrum policy programme

    Global events over the last three years have reminded us that advanced telecom networks are essential if Europe is to be successful in its pursuit of global leadership in the digital economy, remaining secure and resilient in the face of unpredictable global threats, and able to achieve its migration towards net-zero.

    Digitalisation will revolutionise the global economy over the next 10 years, by transforming everything from transport, manufacturing, healthcare, education, energy management and public services. By 2030, digital technologies and connectivity will be the very fabric of our societies and economies. The ubiquitous availability of high speed, low latency 5G connectivity will drive this revolution - and it will be those regions of the world that deploy 5G first that will be positioned for global success in creating and controlling these new digital environments and economies. Europe is in a “lead or lose” situation. Our strategic interest is to lead the future of connectivity. As European telecom operators, we work to stay ahead of the curve in roll-out of 5G and FTTH, development of new network and cloud technologies, digital inclusion and the twin green-digital transition.

    The EU’s Digital Decade envisages full 5G or 5G equivalent coverage by 2030, which means ensuring digital equality and inclusion for all European citizens and businesses no matter where they are. Mobile broadband has been proven to be a catalyst for GDP growth[1],[2], as a basis for social inclusion and wellbeing and a powerful tool in the fight against climate change. [3] As Europe seeks to emerge from the uncertain environment of the pandemic and deliver the twin digital and green transition, mobile has an important role to play in connecting everyone and everything everywhere.

    The important question is how do we deliver on this vision? While most countries in Europe have deployed commercial 5G services, and nearly two-thirds of operators in the region have launched 5G networks, it is clear that there are large differences between Member States, between urban and rural areas and most worryingly between Europe and other leading regions.

    Data headset 2

    Moreover, ‘full’ standalone 5G — where 5G is also deployed in the core of the network — is needed to deliver the promise of the technology. We remain far from that point in the EU, and significantly behind the leading countries. Asia Pacific leads the way in terms of live standalone 5G deployments, while such services are only now starting to be deployed in a few EU Member States.


    In addition, 5G coverage is just one high-level indicator by which to measure the Union’s progress. It is also necessary to consider 5G adoption, capacity, quality of service (QoS) and investment levels especially in comparison with other regions. Furthermore, in those areas with larger rural or dispersed populations there is a danger that a lack of sufficient 5G services will compound inequalities in poverty, social exclusion and digital skills.

    Europe already has an investment gap in telecom networks and services (€174 billion as estimated by the EC[5]), in conjunction with overall declining or flat revenues in the sector, returns below the cost of capital, weak market valuations and high levels of debt. In our view, policy change can help shape a future in which Europe innovates, grows and stays in control of its connectivity. However, reversing the downward trend in mobile investment in Europe requires a set of remedies - including radical reform of spectrum policy - to recreate an environment that can recover investor appetite for the sector and rehabilitate a healthy investment capacity for the sector.

    At a time when telecom networks are widely acknowledged as critical network infrastructure (CNI) and enablers of the twin digital and green transition, the sector faces serious challenges that, if not addressed, will prevent Europe from establishing itself as a digital leader for the coming decades.

    Critically, this must include, from a spectrum policy perspective: prolonging existing licences to align with investor timeframes; preventing distortive or inefficient awards for new spectrum; minimising the cost burden of annual spectrum fees; and securing a pipeline of new harmonised mobile spectrum bands (such as 6 GHz) to accommodate future traffic demands in an energy and cost effective way – the RSPP therefore must take a more pro-investment approach and ensure the broad spectrum provisions already in the European Electronic Communications Code (EECC) are clarified further to achieve a more harmonised approach to licensing and more concrete and ambitious investment outcomes across the Union.

    Furthermore, with 5G networks having much greater minimum scale at local level[6], consolidation is essential. While consolidation falls under the competence of DG-COMP, it is imperative that also through the RSPP, the RSPG and DG-CNECT set out clearly why the scale which can be achieved through consolidation is necessary for 5G deployment as it will benefit consumers and speed up the achievement of the EU Digital Decade’s targets.

    We elaborate on our positions in the paper. For questions and clarifications regarding this position paper, please contact Xhoana Shehu (shehu@etno.eu), Policy Manager at ETNO, and Emma O’Toole (eotoole@gsma.com), Senior Manager, Spectrum at the GSMA Europe.


    [1] The Mobile Economy 2023, GSMA, March 2023

    [2] The Socio-Economic Benefits of Mid-Band 5G Services, GSMA, February 2022

    [3] Mobile Industry Impact Report: Sustainable Development Goals, GSMA, September 2022

    [4] Austria, Bulgaria, Finland, Germany, Italy and Spain, GSMA Intelligence

    [5] Exploratory consultation - The future of the electronic communications sector and its infrastructure, European Commission, February 2023

    [6] A large majority of investments are made in assets that need to be geographically close to end users

    3 July, 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
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