Internet Governance
Netnod believes that the act named Cybersecurity risk management & reporting obligations for digital infrastructure, providers and ICT service managers will not lead to the intended effect.
Netnod believes that the white paper does not take into account the design and architecture of the Internet and does not recognise the importance of the Internet for society.
At a high level Netnod has three main concerns with the NIS2 directive and its Swedish implementation in a cybersecurity context.
Netnod sees several problems with introducing yet another definition of critical and important services, this one in the context of foreign ownership.
Netnod has commented on several aspects of the consultation, but with emphasis on the issues of end-to-end-regulation in the space of vertically separated communications services. The consultation suggests that number independent interpersonal communications can be compared to telephony in terms of control over the message flow and contents. This is simply not true.
On 2 September 2023, Netnod was given the opportunity by Sweden’s Ministry of Defence to comment on an inquiry into models for contingency supply and planning (SOU 2023:50). Netnod is critical that the investigation did not thoroughly investigate the issue of long term infrastructure investments and costs.
On the 23th of February 2023 the European Commission invited actors to comment on the exploratory consultation of “The future of the electronic communications sector and its infrastructure”.
On 19 September 2022, Netnod was given the opportunity by the EU to comment on the EU Commission’s adoption of the Cyber Resilience Act at the EU-level.
Netnod provides expert input in policy, regulatory and governance discussions that directly impact the context within which we operate.
Netnod has responded to the final report of the investigation on secure and cost-efficient IT operations (SOU 2021:97) and sees two issues: the report considers existing legislation as a strict environment; and it does not cover the current needs of the public sector.
Netnod does not recommend moving forward with the current proposal related to the localisation principle for municipal broadband expansion.