Notes from the IAPP Europe: A focus on the Digital Networks Act

As we gradually move through the last quarter of 2025, the European Commission has only a couple more months left to honor its legislative and policy commitments for this year, as identified in the 2025 Commission Work Programme. 

In addition to the "hot item" of the year for digital governance professionals — the Digital Simplification Omnibus — which is expected to be unveiled on 19 November as part of the Digital Package, there are other initiatives remaining in the Commission’s digital policy to-do list.

One of them, the Digital Networks Act, is a legislative proposal that concerns the telecommunications sector and is anticipated to be published in December. The DNA was initiated during the previous Commission's mandate by the EU Commissioner for the Internal Market Thierry Breton. As described in the Commission's Communication on its 2025 work programme, it "will create opportunities for cross-border network operation and service provision, enhance industry competitiveness and improve spectrum coordination." The DNA is expected to reform the existing telecommunications framework laid out in the European Electronic Communications Code. According to some, it is "the EU’s most consequential telecoms reform in decades."

During a recent Euractiv event fully dedicated to discussing this legislative project, the telecoms community highlighted some of their concerns. During the discussion, they addressed the possibility of the DNA introducing network fees and how that may disturb net neutrality. It was also said that the DNA will create an oligopoly that will lead to price increases. 

There was a wide consensus among the panelists that the area needs regulatory tweaking, but the fear the DNA may aim to fix issues that do not exist was also voiced. Representatives of the French Telecoms Federation and Italian Internet Provider Association agreed there is no need to reopen the existing framework and change the rules. While certain issues, such as the 5G slicing discussion, need to be clarified, they can be addressed differently — for instance, through the Commission's guidelines. 

DG Connect representative Peter Stuckmann underlined that telcos are currently regulated on a national level, but there is a need to move to a single market where they operate more similarly. Stuckmann highlighted that the EU needs to focus on simplification, future proofness and resilience by design in order to be ready in the event of a disruption. 

While the DNA concerns the telecommunications sector, it is also relevant to the broader digital governance community. For instance, it will have a direct impact on AI and cloud development — as both need a robust system of connectivity. 

Additionally, a question remains whether the DNA may impact aspects of the broader rulebook currently applicable to telecoms on issues such as data retention, lawful interception and encryption.

Laura Pliauškaitė is European operations coordinator for the IAPP.