Netnod policy statements

Netnod provides expert input in policy, regulatory and governance discussions that directly impact the context within which we operate.

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 has provided feedback on the draft legislation for critical services resilience, emphasizing concerns about the interplay between laws, the effectiveness of the all-risk approach, lack of clarity on the law's impact, and the need for positive incentives for cybersecurity.

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.

At a high level Netnod has three main concerns with the request for comments regarding a national cybersecurity center (NCSC) - part 2.

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. 

At a high level Netnod has three main concerns with the request for comments regarding a national cybersecurity center (NCSC).

Netnod sees several problems with introducing yet another definition of critical and important services, this one in the context of foreign ownership.

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.