Netnod responds to the national telecommunications cooperation group proposal

On 5 May 2023 Netnod was given the opportunity by the Ministry of Finance to comment on the suggestion of a telecoms collaboration group for peacetime crisis and high alert (Fi2023/01681 En telesamverkansgrupp för fredstida kriser och höjd beredskap).

Netnod has responded with the full response available here in Swedish.

In short, 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.

In addition, the suggested legislation does not take into account that there are private actors outside of the Swedish electronic communications sector which are of importance to electronic communications in Sweden.

As it currently stands, the suggested legislation improves clarity for government entities and agencies participating in the telecoms collaboration group, but risks causing private actors to participate as little as possible when they are forced to do so.