Internet Governance

Netnod replies to EC act on NIS2 Cybersecurity risk management
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 replies to EC white paper on digital infrastructure
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.
Netnod responds to the Swedish implementation of NIS2
At a high level Netnod has three main concerns with the NIS2 directive and its Swedish implementation in a cybersecurity context. 
Netnod response to foreign ownership of critical services
Netnod sees several problems with introducing yet another definition of critical and important services, this one in the context of foreign ownership.
Netnod comments on models for contingency supply and planning
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.
The future of the electronic communications sector and its infrastructure
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”.
Netnod and Internetstiftelsen responds to the EU Commission's proposed adoption of the Cyber Resilience Act
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
Public policies and statements
Netnod provides expert input in policy, regulatory and governance discussions that directly impact the context within which we operate.
Netnod responds to PTS proposals on the implementation of the European Code of Electronic Communications directive
Netnod responds to final report on secure and cost-efficient IT operations
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 responds to Ministry of Infrastructure proposal on broadband networks
Netnod does not recommend moving forward with the current proposal related to the localisation principle for municipal broadband expansion.
Netnod response to SOU 2021:63 Sveriges säkerhet - behov av starkare skydd för nätverks- och informationssystem
Netnod have responded to an open consultation on SOU 2021:63 “Sveriges säkerhet - behov av starkare skydd för nätverks- och informationssystem. This is in turn based on REGULATION (EU) 2019/881 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 17 April 2019 on ENISA (the European Union Agency for Cybersecurity) and on information and communications technology cybersecurity certification and repealing Regulation (EU) No 526/2013 (Cybersecurity Act).