Internet Governance
Do not fix what is not broken. Netnod is against the suggestion that a metric should be developed based on which content providers should reimburse network operators.
Netnod welcomes the additional attention brought to the important topic of cybersecurity by the Cyber Resilience Act. However, Netnod believes that approach is fundamentally suboptimal and effort should instead be put towards accountability in the digital world. That is, instead of laying down ex-ante design requirements for digital products, the regulation should improve ex-post accountability processes in a digital environment.
Netnod sees some advantages to the proposed and slightly altered regulation with regards to electronic communications. However, Netnod believes that approach is fundamentally suboptimal and greater effort should have been put towards designing a legislative framework for the digital communications required for a digitised Sweden and Europe.
The report furthers a atrict environment for digitalisation rather than fundamentally questioning what the legislative environment for secure and cost-efficient IT operations should look like.
Netnod does not recommend moving forward with the current proposal related to the localisation principle for municipal broadband expansion.
Netnod believes that the creation of a specific sector for electronic communication and post is a good thing, and this does not have to overlap with the creation of a specific area for cybersecurity.
Netnod has submitted comments on the NIS-2 directive, a proposal from the European Commission (EC) on a directive with measures for a high common level of cybersecurity across the European Union.
Netnod’s view is that the risk assessment given in the proposal is too shallow and only focuses on one specific form of Denial of Service (DoS) attack
Netnod have sent comments to the Swedish Ministry of Infrastructure on the memorandum with ID I2019/02319/D The memorandum is a proposal regarding implementation of Directive (EU) 2018/1972 of the European Parliament and of the Council of 11 December 2018 establishing the European Electronic Communications Code.
Netnod has commented on the Ministry of Finance's release of SOU 2019:12, “New Powers in the Field of Consumer Protection”, a regulation that is proposed to come into force from 2020. The purpose of this new regulation is to streamline and strengthen cooperation between authorities in order to meet the challenges posed by digital development and strengthen cross-border e-commerce within the EU.
Netnod and the The Swedish Internet Foundation (IIS) have together with operators, technicians and other stakeholders finished the first phase of three in a project to define, the various elements that constitute internet access.