Delivering EU scale in connectivity: an assessment of the Digital Networks Act

The proposed Digital Networks Act (DNA) is Europe’s latest attempt to deliver a more harmonised and investment-friendly connectivity framework. It moves from a Directive to a Regulation and introduces new Union-level mechanisms. This shift is necessary but not sufficient: EU-level centralisation will only deliver results if it produces genuine simplification, legal certainty and faster decision-making.

Previous telecoms reforms, including the European Electronic Communications Code (EECC), already sought to reduce fragmentation. However, many coordination tools remained non-binding and reliant on
voluntary alignment between Member States, particularly regarding conditions, timing and procedures. The DNA proposal goes in the right direction in several key areas: the introduction of a single passport for service provision, a Union-level satellite authorisation regime and a more investment-oriented spectrum framework all have the potential to remove structural barriers and improve predictability for operators.
To deliver, this shift must avoid a set of foreseeable risks, and result in genuine simplification rather than a relocation of complexity to the EU level. In several areas, new procedures, coordination layers and implementing measures could recreate fragmentation or delay decision-making in a different form:

• The single passport must operate as a truly self-contained system. Host Member States must not recreate parallel notification/registration requirements in substance, and enforcement must avoid duplicative proceedings or ‘double jeopardy’ for the same breach.
• The investment-oriented spectrum approach should be preserved and reinforced, ensuring that any grounds for modification or non-renewal are narrowly defined and applied predictably, whilst EU-level coordination reduces fragmentation without delaying assignments.
• The Union satellite authorisation framework should remain aligned with existing international and European coordination mechanisms, notably ITU obligations and established CEPT-based harmonisation approaches, and must not introduce new barriers to terminal
  deployment across Europe.
• Copper-to-fibre transition should be accelerated through incentives and readiness-based flexibility, not fixed EU timelines. Switch-off should occur when measurable readiness conditions are met, guaranteeing end-users equivalent or improved services.
• Specialised services need legal certainty in the primary text, rather than leaving key elements to future implementing acts that would prolong uncertainty.
• Resilience and security provisions must avoid duplication, in particular with NIS2. New data collection requirements should be limited to identified gaps.
• The end-user rights and universal service framework largely preserves the EECC toolbox. The DNA should focus on reducing gold plating and fragmentation in practice, and on keeping universal service strictly limited to affordable basic broadband and addressing remaining gaps through targeted, technology-neutral public funding and demand-side measures like vouchers.
• Governance and secondary legislation must be proportionate: essential elements should be defined in the Regulation itself, with implementing/delegated acts limited to technical and operational detail, prioritised and adopted within clear timelines.

Overall, the DNA can deliver more integrated and investment-friendly connectivity across Europe. This will depend on ensuring that centralisation leads to simplification, legal certainty and faster decision-making, rather than additional bureaucracy.