Internet Governance
Netnod has submitted its views on the government inquiry Samlade förmågor för ökad cybersäkerhet SOU 2025:79 (Combined Capabilities for Increased Cybersecurity).
Netnod provides expert input in policy, regulatory and governance discussions that directly impact the context within which we operate.
Netnod emphasises the need for accountability and transparency in the DNS root server system's governance to ensure its continued global acceptance and preserve a multi-stakeholder model against increasing demands from nation-states and corporations.
Netnod agrees with the report's assessment that there is no need to amend the regulations concerning storage and adaptation obligations in the Electronic Communications Act, but has two main concerns with the proposed changes.
The updated proposal continues to include the same issues as highlighted by Netnod in the prior consultation: never promote backdoors, do not forbid end-to-end-encryption and do not harmonise the legal frameworks for number dependent and number independent services.
The Internet is a global matter that requires multistakeholder management and must not be governed by national or EU legislation. It is crucial to differentiate between the Internet itself and the services that rely on it.
Netnod argues for keeping content and distribution separate, ensuring that any content can be delivered across any platform. Netnod also stresses the need for robust and available services, especially in times of crisis.
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 is of the opinion that PTS suggests a geographical and product market definition which implies that electronic communications services are vertically integrated services, rather than services produced through the coordination of many actors, many of which are network operators.
Netnod is critical of the suggestion to force private actors to participate in such a group, and instead Netnod suggests that participation should be based on market logic. That is, the public should use market instruments rather than legal impositions to ensure fruitful participation.
