Digital Networks Act consultation

Dear everyone,

We are working on our feedback submission to the adopted Digital Networks Act proposal, COM(2026). As the text has now been formally adopted, this is not a call for evidence but our task is to comment on the text’s provisions with precision, and argue for changes in the legislative process.

Our response will be anchored in the following principles:
 Net neutrality is non-negotiable: traffic management must be technically necessary and proportionate, never commercially motivated.
 Security and resilience must not become cover for expanded surveillance or law enforcement access without judicial oversight.
 Digital inclusion requires active protection, not just formal availability: copper switch-off must not leave vulnerable users behind.
 Open spectrum and anti-incumbency: spectrum governance must not entrench dominant operators at the expense of smaller actors and new entrants.
 Democratic accountability of BEREC: enhanced EU-level governance requires commensurate transparency and civil society participation.
 The DNA must not shift costs from operators to citizens or create new barriers to accessing the internet.
 We support investment in high-quality connectivity infrastructure. Our critique is about governance, rights, and access, not whether the DNA should exist.

We would welcome any suggestions on specific provisions of the text that relate to these principles.

Deadline for inputs: 8 June 2026

For further information, please refer to the Commission’s adoption page (midway down the page):

https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14709-Digital-Networks-Act_en