ETNO’s position on the draft delegated regulation on the obligation for certain companies to publish non-financial information

ETNO (European Telecommunications Network Operators' Association) represents Europe’s telecommunications network operators and is the principal policy group for European e-communications network operators. ETNO’s primary purpose is to promote a positive policy environment allowing the EU telecommunications sector to deliver best quality services to consumers and businesses.

ETNO (European Telecommunications Network Operators' Association) represents Europe’s telecommunications network operators and is the principal policy group for European e-communications network operators. ETNO’s primary purpose is to promote a positive policy environment allowing the EU telecommunications sector to deliver best quality services to consumers and businesses.

ETNO fully supports the EU taxonomy role as an essential facilitator of the EU Green Deal, with the purpose of channelling long-term, sustainable finance into sustainable activities.


Telecommunication companies have invested and continue to invest heavily in the build-out and upgrade of energy efficient and high-speed network infrastructure and data centres, as well as in the development and deployment of other ICT Services. In 2018, ETNO companies deployed 70.5% of the total network investment in Europe (€34.4bn, fixed and mobile)[1]. There is a common understanding among decision makers that climate targets will not be achieved without the crucial role of ICT as enablers, including the need for connectivity.

Transparent corporate disclosure with respect to the taxonomy’s criteria are crucial to foster sustainable investments. We welcome the intention to provide clarity on reporting scope, KPI definitions and timeline in the current draft regulation (2020/852).  However, many aspects of the suggested reporting obligations are unprecedented and inappropriate in various aspects, including scope, granularity, backwards orientation, confidentiality and competitive relevance.

Therefore, ETNO has decided to take this opportunity to provide feedback. In the following section we highlight our key considerations. Where possible, we includes our advice on possible improvement of the suggested transparency requirements.

 Read the full document at the link below

[1] See ETNO’s The State of Digital Communications 2020, available here https://etno.eu/library/reports/90-state-of-digi- 2020.html  

Read the position paper