Position Papers

Connect Europe's position papers represent the views of its member companies on a wide range of technical, regulatory, and trade issues. These papers are directed at European Union decision-makers, national governments, and the general public.

Position papers are developed either internally by our working groups or, occasionally, in cooperation with third parties such as other industry associations at the European and national levels. This section also includes materials from our previous association, ETNO.

14 Mar, 2024

ETNO-GSMA position on impersonation fraud in Payment Services Regulation

The GSMA and ETNO strongly encourage policymakers to reconsider their approach to increasing liability for electronic communications services (ECS) providers in cases of impersonation fraud.

20 Feb, 2024

ETNO position paper on EU guidelines on exclusionary abuses by dominant undertakings

With a view to the European Commission’s soon to be expected publication of the draft guidelines for the enforcement of Article 102 TFEU and the prohibition of exclusionary abuses by dominant undertakings, ETNO would like to provide some insights regarding its competitive experience on the telecoms market.

The following position is based on an internal legal assessment of the case law applied for the Guid

01 Feb, 2024

ETNO reflection paper on submarine communication cables

The European Union’s dependence on submarine communication cables has emerged as a significant concern for Europe’s security, resilience, and sovereignty, a vulnerability underscored by notable incidents involving the Nord Stream undersea gas pipeline in 2022 and undersea cables connecting Estonia and Finland in October 2023.

25 Jan, 2024

ETNO comments to the European Commission’s Draft Implementing Regulation laying down templates concerning the transparency reporting obligations of providers of intermediary services and of providers of online platforms under Regulation (EU) 2022/206

ETNO welcomes this opportunity to provide comments to the European Commission’s draft Implementing Regulation laying down templates concerning the transparency reporting obligations of providers of intermediary services and of providers of online platforms under the ‘Digital Services Act’ (DSA).

19 Jan, 2024

ETNO-GSMA comments on EDPB Guidelines 2/2023 on Technical Scope of Art. 5(3) of ePrivacy Directive

The protection of customer privacy and the confidentiality of their communications is at the core of the services offered by telecom operators. While these rules establish the foundation for delivering secure, trusted telecommunications services in Europe, they must also provide a degree of flexibility to enable European telcos to use data to improve customer experience, bring societal benefits, and, in general, keep pace with innovation and competition.

14 Dec, 2023

ETNO comments to the RSPG Draft Work Programme for 2024

The European Telecommunication Network Operators' Association (ETNO) welcomes the opportunity to provide feedback to the Radio Spectrum Policy Group (RSPG) Draft Work Programme 2024.

22 Nov, 2023

ETNO and GSMA response to the consultation on the Commission’s Delegated Regulation amending Regulation (EU) 2015/758 of the European Parliament and of the Council as regards the standards relating to eCall

ETNO and GSMA represent the telecoms sector in Europe and worldwide. Our members are the companies responsible for deploying next generation connectivity, with the aim of meeting the European Commission’s digital decade connectivity targets, and in parallel, making important progress on the twin green-digital transformation.

19 Oct, 2023

ETNO-GSMA response to the European Commission consultation on eCall: Delegated Act on PSAPs

Draft Delegated Regulation amending Delegated Regulation (EU) No 305/2013 supplementing Directive 2010/40/EU of the European Parliament and of the Council with regard to the harmonised provision for an interoperable EU-wide eCall.