WHITE PAPER How to master Europe's digital infrastructure needs?
Date: 2024-02-21
Institutions: Directorate-General for Communications Networks, Content and Technology, European Commission
Subjects: 5G, Internet of Things, cloud computing, critical infrastructure security, digital single market, digital transformation, information security, information technology, innovation, transmission network

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 21.2.2024  COM(2024) 81 final  WHITE PAPER How to master Europe's digital infrastructure needs?  
 
 
- White paper – 

“How to master Europe’s digital infrastructure needs?” 

1. 

INTRODUCTION .................................................................................................................... 3 

2.  TRENDS AND CHALLENGES IN THE DIGITAL INFRASTRUCTURE SECTOR . 5 

2.1.  Europe’s connectivity infrastructure challenges ........................................................... 5 

2.2.  Technological challenges ................................................................................................. 7 

2.3.  Challenges of achieving scale in EU connectivity services ...................................... 10 

2.3.1. 

2.3.2. 

2.3.3. 

2.3.4. 

2.3.5. 

Investment needs ................................................................................................. 10 

Financial situation of the EU electronic communications sector ................. 11 

Lack of single market ......................................................................................... 13 

Convergence and level playing field ................................................................ 15 

Sustainability challenges .................................................................................... 16 

2.4.  Need for security in the supply and in the operation of networks ............................ 17 

2.4.1. 

2.4.2. 

2.4.3. 

Challenge of trusted suppliers ........................................................................... 17 

Security standards for end-to-end connectivity .............................................. 17 

Secure and resilient submarine cable infrastructures ..................................... 18 

3.  MASTERING THE TRANSITION TO THE DIGITAL NETWORKS OF THE 
FUTURE - POLICY ISSUES AND POSSIBLE SOLUTIONS .............................................. 20 

3.1.  Pillar I: Creating the “3C Network” - “Connected Collaborative Computing” ...... 20 

3.1.1. 

3.1.2. 

3.1.3. 

Capacity building through open innovation and technology capabilities ... 20 

Way forward ........................................................................................................ 22 

Summary of possible scenarios ......................................................................... 24 

3.2.  Pillar II: Completing the Digital Single Market ......................................................... 25 

3.2.1. 

3.2.2. 

3.2.3. 

3.2.4. 

3.2.5. 

3.2.6. 

3.2.7. 

3.2.8. 

3.2.9. 

Objectives ............................................................................................................ 25 

Scope of application ........................................................................................... 25 

Authorisation ....................................................................................................... 27 

Addressing barriers to core network centralisation ........................................ 27 

Radio spectrum .................................................................................................... 28 

Copper switch-off ............................................................................................... 31 

Access policy in a full fibre environment ........................................................ 32 

Universal service and affordability of digital infrastructure ......................... 35 

Sustainability ....................................................................................................... 35 

3.2.10. 

Summary of possible scenarios ......................................................................... 36 

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3.3.  Pillar III: Secure and resilient digital infrastructures for Europe ............................. 37 

3.3.1. 
Towards secure communication using quantum and post-quantum 
technologies ............................................................................................................................. 38 

3.3.2. 

3.3.3. 

Towards security and resilience of submarine cable infrastructures ........... 39 

Summary of possible scenarios  ........................................................................ 40 

4.  CONCLUSION ....................................................................................................................... 41 

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1.  INTRODUCTION 

A cutting-edge digital network infrastructure is the foundation for a flourishing digital economy 
and society. Secure and sustainable digital infrastructures are one of the four cardinal points of 
the  EU’s  Digital  Decade  Policy  Programme  2030,  one  of  the  main  priorities  of  the  current 
Commission.  It  is  also  at  the  heart  of  citizens’  interest,  who  made  several  digital-related 
proposals in the context of the Conference on the Future of Europe. Without advanced digital 
network  infrastructures,  applications  will  not  make  our  lives  easier,  and  consumers  will  be 
deprived of the benefits of advanced technologies. Only with the highest performance of such 
infrastructures, for example, will doctors be able to care for patients at a distance rapidly and 
safely, drones be able to improve harvests and reduce water and pesticide use, while connected 
temperature and humidity sensors enable real-time monitoring of the conditions in which fresh 
food is stored and transported to the consumer.  

There  are  also  many  examples  across  the  economy  of  how  enterprises  need  advanced 
connectivity and computing infrastructures for the processing of data closer to their operations 
and to their customers, to use or provide innovative applications and services. This is especially 
important  for  applications  that  require  real-time  data  processing,  such  as  Internet  of  Things 
(IoT)  devices,  autonomous  vehicles,  and  smart  grids,  as  well  as  to  reduce  latency  for 
applications related to predictive maintenance, real-time monitoring, and automation, leading 
to more efficient and cost-effective operations. Advanced digital network infrastructures and 
services will become a key enabler for transformative digital technologies and services such as 
Artificial  Intelligence  (AI),  Virtual  Worlds  and  the  Web  4.0,  and  for  addressing  societal 
challenges  such  as  those  in  the  fields  of  energy,  transport  or  healthcare  and  for  supporting 
innovation in creative industries.  

The  future  competitiveness  of  all  sectors  of  Europe’s  economy  depends  on  these  advanced 
digital  network  infrastructures  and  services,  as  they  form  the  basis  for  global  GDP  growth 
between EUR 1 and 2 trillion1 and the digital and green transition of our society and economy. 
There is, according to many sources, a strong link between the increased deployment of fixed 
and mobile broadband  and economic development2. Demand  for  connectivity is  essential to 
stimulate the economy. Higher speeds and new generations of mobile networks have a positive 
impact  on  GDP3.  Similarly,  studies  show  that  a  resilient  backbone  infrastructure  based  on 
secure  submarine  cables  can  boost  GDP4.  With  the  current  demographic  trends,  European 

1   Connected  World:  An  evolution  in  connectivity  beyond  the  5G  evolution,  McKinsey  2020  available  at 
https://www.mckinsey.com/industries/technology-media-and-telecommunications/our-insights/connected-
world-an-evolution-in-connectivity-beyond-the-5g-revolution 

2   Cf.“Analyzing  the  Economic  Impacts  of  Telecommunications”  Exploring  the  Relationship  Between 
Broadband  and  Economic  Growth”,  Background  Paper  prepared  for  the  World  Development  Report  2016: 
Digital Dividends, Michael Minges, 2015; “Europe’s internet ecosystem: socio-economic benefits of a fairer 
balance between tech giants and telecom operators”, Axon Partners Group, May 2022;  Kongaut,  Chatchai; 
Bohlin, Erik (2014): Impact of broadband speed on economic outputs: An empirical study of OECD countries, 
25th  European  Regional  Conference  of  the  International  Telecommunications  Society  (ITS):  "Disruptive 
Innovation in the ICT Industries: Challenges for European Policy and Business", Brussels, Belgium, 22nd-25th 
June, 2014, International Telecommunications Society (ITS), Calgary. 

3   Specifically, mobile’s baseline connectivity impact increases by about 15% when connections are upgraded to 
3G.  For  connections  upgrading  from  2G  to  4G,  the  impact  increases  by  approximately  25%,  according  to 
Mobile technology: two decades driving economic growth (gsmaintelligence.com) 

4   https://copenhageneconomics.com/publication/the-economic-impact-of-the-forthcoming-equiano-subsea-

cable-in-portugal/ 

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competitiveness needs to rely on productivity-boosting technologies, and digital infrastructure 
and services are key. 

In parallel, digital networks are undergoing a transformation where connectivity infrastructure 
is  converging  with  cloud  and  edge  computing  capabilities.  To  harness  the  benefits  of  this 
transformation,  the  electronic  communications  sector  needs  to  expand  from  the  traditional 
consumer  internet  market  towards  digital  services  in  key  economic  sectors,  such  as  the 
Industrial  Internet  of  Things  (IIoT).  Moreover,  the  equipment  sector  also  faces  major 
technological transformations linked to the trend towards software and cloud-based networks 
and  open  architectures.  Convergence  of  the  electronic  communications  and  IT  ecosystems 
brings opportunities for lower cost and innovative services, but also new risks of bottlenecks 
and  dependencies  in  the  field  of  cloud  infrastructure  and  services  as  well  as  leading  chip 
platforms5. To ensure economic security, it is therefore of utmost importance that innovation in 
this field continues to be driven in the Union and led by its industry. To achieve this, in the 
current  geopolitical  context,  the  Union  needs  to leverage  its  current  strength  in  the  network 
equipment supply market, with two of the three global suppliers being European. 

From a societal perspective, the availability of high-quality, reliable and secure connectivity for 
everybody and everywhere in the Union, including in rural and remote areas, is indispensable6. 
The necessary investments are massive7. A modern regulatory framework that incentivises the 
transition  from  legacy  copper networks to  fibre  networks, the development  of  5G and other 
wireless networks and cloud-based infrastructures as well as the scale up of operators within 
the  single  market,  and  which  takes  account  of  emerging  technologies  such  as  quantum 
communication, is key to ensuring that Europe has the advanced, secured communications and 
computing infrastructure it needs. Short of that, the EU risks missing its 2030 digital targets 
and falling behind other leading regions as regards competitiveness and economic growth and 
related user benefits.  

Finally, recent geopolitical developments highlighted the importance of security and resilience 
of infrastructures against both human-made and natural hazards, as well as the complementary 
role of terrestrial, satellite and submarine connectivity solutions, for uninterrupted availability 
of service under all circumstances. In a rapidly changing security landscape, a strategic Union-
wide approach to  security and resilience of  critical  digital infrastructures  is  essential for the 
EU’s economic security, building on the solid existing legislative framework, notably the NIS2 

5   Cybersecurity of Open Radio Access Networks, Report by NIS Cooperation Group, May 2022.  
6   This was also acknowledged in the Digital Decade Policy Programme 2030 (Decision (EU) 2022/2481 of the 
European  Parliament  and  of  the  Council  of  14  December  2022  establishing  the  Digital  Decade  Policy 
Programme 2030, OJ L 323, 19.12.2022, p. 4.). According to its Art. 4(2)(a), by 2030 all end users at a fixed 
location should be covered by a gigabit network up to the network termination point, and all populated areas 
should be covered by next-generation wireless high-speed networks with performance at least equivalent to 
that of 5G, in accordance with the principle of technological neutrality. 

7   https://digital-strategy.ec.europa.eu/en/library/investment-and-funding-needs-digital-decade-connectivity-

targets. 

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Directive8, the Directive on the resilience of critical entities9 and the Council Recommendation 
on a Union-wide coordinated approach to strengthen the resilience of critical infrastructure10 11. 

Against  this  background,  this  White  Paper  identifies  challenges  and  discusses  possible 
scenarios for public policy actions, such as a possible future Digital Networks Act, that aim to 
incentivise building the digital networks of the future, master the transition to new technologies 
and business models, meet future connectivity needs of all end-users, underpin competitiveness 
of  our  economy  and  ensure  secure  and  resilient  infrastructures  and  the  Union’s  economic 
security  as  reflected  by  the  common  commitments  of  the  EU  Member  States  in  the  Digital 
Decade Policy Programme12. 

2.  TRENDS AND CHALLENGES IN THE DIGITAL INFRASTRUCTURE SECTOR 

2.1. Europe’s connectivity infrastructure challenges 

The connectivity infrastructure of the Union is not yet ready to address the current and future 
challenges of the data-driven society and economy and the future needs of all end-users.  

On the supply side, the 2023 Report on the state of the Digital Decade13 underlines in particular 
limited fibre coverage (56% of all households, 41% of households in rural areas)14 and delays 
in  the  deployment  of  5G  standalone  networks  in  the  EU.  Current  trends  concerning  the 
trajectories for the digital infrastructure targets laid out in the Digital Decade Policy Programme 
203015 are a cause for concern. As regards fibre coverage, progress beyond 80% by 2028 does 
not seem likely, putting the achievement of the 2030 target of 100% in doubt. In comparison to 
the 56% fibre coverage in the EU in 2022, the US, which has traditionally relied on cable, had 
48.8%, while Japan and South Korea each reached 99.7%16, due to clear strategies in favour of 
fibre. 

As regards 5G roll-out, while basic 5G population coverage in the EU currently stands at 81% 
(with  only  51%  coverage  of  the  population  in  rural  areas),  this  metric  does  not  reflect  the 
delivery of actual advanced 5G performance. Most often, where 5G is deployed, it is not “stand-
alone”, i.e. with a core network separate from previous generations. Prospects for deployment 
of 5G stand-alone networks ensuring high reliability and low latency, which are key enablers 

8   Directive (EU) 2022/2555 of the European Parliament and of the Council of 14 December 2022 on measures 
for  a  high  common  level  of  cybersecurity  across  the  Union,  amending  Regulation  (EU)  No  910/2014  and 
Directive (EU) 2018/1972, and repealing Directive (EU) 2016/1148 (NIS 2 Directive), OJ L 333, 27.12.2022, 
p. 80–152.  

9   Directive  (EU)  2022/2557  of  the  European  Parliament  and  of  the  Council  of  14  December  2022  on  the 
resilience of critical entities and repealing Council Directive 2008/114/EC, OJ L 333, 27.12.2022, p. 164–198. 
10   Council  Recommendation  of  8  December  2022  on  a  Union-wide  coordinated  approach  to  strengthen  the 

resilience of critical infrastructure, 2023/C 20/01, OJ C 20, 20.1.2023, p. 1–11. 

11   This approach should also integrate challenges and opportunities for EU enlargement policies. 
12   Decision (EU) 2022/2481 of the European Parliament and of the Council of 14 December 2022 establishing 

the Digital Decade Policy Programme2030, OJ L 323, 19.12.2022, p.4. 

13   https://digital-strategy.ec.europa.eu/en/library/2023-report-state-digital-decade. 
14   https://digital-strategy.ec.europa.eu/en/library/broadband-coverage-europe-2022.  
15   The Digital Decade Policy Programme sets a series of objectives and targets to promote the development of 
resilient, secure, performant and sustainable digital infrastructures in the Union, including a digital target for 
the Commission and Member States to achieve gigabit connectivity for all by 2030. The Programme should 
enable connectivity across the Union and around the globe, for citizens and business, including, but not limited 
to, providing access to affordable high-speed broadband that can help remove communication dead zones and 
increase cohesion across the Union, including its outermost regions, rural, peripheral, remote and isolated areas 
and islands.  

16   See Global Fibre Development Index 2023, Omdia. 

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for industrial use cases, are not good. The deployment of such networks can be estimated at 
significantly less than 20% of populated areas in the EU. Although there is progress on early-
stage trials, operators have launched this architecture only in a small number of Member States 
and limited to some urban areas17. Such limited deployment could, among others, be related to 
the early stage of 3.6 GHz band deployment. Coverage by 5G in this mid-wave band, that is 
needed for higher speeds and capacity, currently stands at only 41% of the population. 5G will 
need, however, to extend its footprint beyond populated areas, to cater for advanced services, 
such  as  precision  farming.  Also,  while  basic  5G  coverage  in  the  largest  Member  States  is 
relatively similar to the US, other regions such as South Korea and China are better prepared 
for 5G stand-alone deployment. According to the 5G Observatory’s International Scoreboard, 
South Korea has deployed more than five times the number of 5G base stations per 100,000 
inhabitants than the EU, and China almost triple18.  

Finally, satellite broadband can bring broadband services with up to 100 Mbps download speeds 
to  very rural  and  remote areas, where no very high-capacity networks  are available, even if 
affordability remains crucial to facilitate take-up in these areas. They can also provide resilient 
emergency services in disaster or crisis situations. However, while satellite services can bridge 
the digital divide, they cannot currently replace the performance of ground-based networks. 

Overall, and without taking into account population density and quality of connectivity, the EU 
has similar fixed and mobile coverage than the US but lags significantly behind other parts of 
the world in particular on fibre coverage and 5G stand-alone. However, what counts more is 
what  remains  to  be  covered  and  more  importantly  whether  the  EU  is  in  a  good  position  to 
achieve its Digital Decade objectives for ubiquitous fibre and 5G coverage. In this respect, take-
up of high-speed services is of paramount importance, as it affects the capacity of the sector to 
invest.  On the demand side, the take-up of at least 1 Gbps broadband is very low (at 14% in 
2022 at EU level) and just above half of all EU households (55%) have adopted at least 100 
Mbps broadband. The take-up of high-speed fixed broadband subscriptions is lower in the EU 
than the US, South Korea or Japan19. Standard mobile broadband take-up is better and lies at 
87%, despite almost ubiquitous coverage with at least 4G networks. 

These delays represent a critical vulnerability for Europe’s economy as a whole, as the delivery 
of advanced data services and AI-based applications depends on them. The same applies to the 
deployment of edge computing infrastructure, another key enabler for time critical applications 
and computing capabilities in relation to real-time data-intensive use cases and IoT. There is a 
strong  correlation  between  the  deployment  of  capable  digital  networks  and  the  take-up  of 
modern technologies, which are currently not  developing at  large scale.  The Digital  Decade 
Policy Programme sets out a target of 10,000 climate-neutral highly secure edge nodes to be 
deployed by 2030 as well as targets for adoption of digital technologies, such as cloud, big data 
and AI, by European companies. The 2023 Report on the state of the Digital Decade underlined 
the risks for the achievement of these targets. Edge computing is still at its infancy in Europe20. 
The first data collected by the Edge Observatory21 show that Europe is on track in the initial 

17   5G  Observatory  Biannual  Report  October 

2023, 
content/uploads/2023/12/BR-19_October-2023_Final-clean.pdf 

page 

8, 

https://5gobservatory.eu/wp-

18   5G base stations per 100,000 inhabitants: 419 (South Korea), 206 (China), 77 (EU), 118 (Japan), 30 (US). 
19   Cf. International DESI (to be published on the basis of OECD data). 24.07 subscriptions per 100 inhabitants 
are higher than 100 Mbps in the EU, comparing to 29.60 in the US, 33,36 in Japan and 43,60 in South Korea. 

20   Report on the state of the Digital Decade 2023, SWD Digital Decade Cardinal Points, section 2.4. 
21   https://digital-strategy.ec.europa.eu/en/policies/edge-observatory. 

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phase  of  edge  nodes  deployment.  However,  under  current  trends,  and  without  further 
investment and incentives, the targets are unlikely to be met by 2030.  

Modern digital networks capable of expanding and maturing would stimulate the development 
of new use cases, creating business opportunities contributing to the digital transformation of 
Europe. The impact of missing the Digital Decade digital infrastructure targets would be far-
reaching, going beyond the scope of the digital sector, and would lead to missed opportunities 
in innovation areas such as automated driving, smart manufacturing, and personalised health 
care. 

2.2. Technological challenges 

New business models and entirely new markets are emerging from technological developments 
around the App Economy, IoT, Data Analytics, AI or new forms of content delivery such as 
high-quality video streaming. These applications require a continuous exponential increase in 
data processing, storage, and transmission. The ability to process and transport large amounts 
of data across the entire global Internet has led to the remote storage and processing of data in 
the cloud, between the cloud and the end-user through Content Delivery Networks (CDNs), and 
close  to  the  end-user  (edge  computing).  This  has  led  to  the  virtualisation  of  electronic 
communications networks functions in software and a shifting of these functions to the cloud 
or the edge22. 

This  new  model  of  network  and  service  provision  relies  not  only  on  traditional  electronic 
communications equipment, network and service providers but also on a complex ecosystem 
of  cloud,  edge,  content,  software  and  component  suppliers,  amongst  others.  The  traditional 
boundaries between these various actors are increasingly blurred as they form part of what can 
be  described  as  a  computing  continuum:  from  chips  and  other  components  for  high-speed 
processors embedded in devices, to edge computing working cohesively with centralised cloud 
services and AI-powered applications managing the network. This will allow computing to be 
integrated everywhere in the network.  

There  is  a  need  to  orchestrate  these  different  elements.  This  coordinated  management  of 
computing and network resources ensures that end-users have a seamless experience, no matter 
if they are on their mobile phone, at home, or in the car or train. This is because the orchestrator 
ensures that a broad range of computing environments interact in the background. 

One  example  is  the  connected  and  autonomous  vehicles,  which  will  increasingly  rely  on 
advanced  high-speed  and  low-latency  communication  and  computing  to  ensure  that  they 
communicate with network and road infrastructure in real time. This will allow these vehicles 
to contribute to optimising traffic flow and reducing congestion and accidents. 

22   This technological shift and new paradigm have been confirmed by the large majority of respondents to the 
Commission’s exploratory consultation launched last year to gather views and identify Europe’s needs in terms 
of connectivity infrastructure to lead the digital transformation. In particular, respondents identified network 
virtualisation, network slicing, and Network as a Service, as the technological breakthroughs that will have the 
largest impact in the coming years. These technologies are expected to drive the shift from traditional electronic 
communications networks to cloud-based, virtualised, software-defined networks, reducing costs, improving 
the  resilience  and  security  of  networks,  and  introducing  new,  innovative  services,  while  transforming 
ecosystem and business models. 
The results of the exploratory consultation were published in October 2023 and are available at https://digital-
strategy.ec.europa.eu/en/news/consultation-electronic-communications-highlights-need-reliable-and-
resilient-connectivity.  

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Another example is the use of secure high-speed connectivity in order to provide advanced e-
health services, including advanced e-health monitoring and e-health care in remote areas, using 
low-cost  devices.  For  this,  it  will  be  necessary  to  migrate  functionality  and  use  artificial 
intelligence  to  the  network,  which  should  be  located  as  close  to  the  user  as  possible.  Other 
technologies that could be part of the health care system of 2030 are sensor-based monitoring, 
extended reality (XR) and drones. 

This  technological  change  triggers  the  emergence  of  new  business  models  in  the  electronic 
communications services sector. The increasingly complex network operations push companies 
in  different  segments  of  the  value  chain  to  work  together  at  the  infrastructure  layer  while 
competition at the service layer becomes more complex. Main trends include network sharing, 
the separation of infrastructure and service layer and the creation of service platforms based on 
concepts  like  Network  as  a  Service  (NaaS)  and  IoT.  NaaS  creates  a  common  and  open 
framework between operators that makes it easier for developers to build apps and services in 
partnership with large cloud providers and content application providers (CAPs) that seamlessly 
communicate with each other and work for all devices and customers. At the same time, it also 
makes it possible for unconventional  players in  the network services  domain, such as cloud 
hyperscalers, to begin enterprise-grade services in that space23. 

These  changes  are  being  gradually  introduced  to  exploit  the  full  potential  of  5G  networks, 
especially  for  industrial  sectors,  the  so-called  ‘verticals’  such  as  manufacturing  or  mobility. 
With  its  successful  industry  and  public-private  partnerships,  the  EU  is  currently  leading 
(together with China) the development of these future industrial applications of 5G in vertical 
industry sectors. Examples include operational campus networks, e.g. in factories, ports and 
mines24 as well as the planned deployment of 5G corridors along EU transport networks25. Such 
changes will be key building blocks of the future 6G computing continuum, which is currently 
still  at  the  development  stage,  but  which  will  create  further  realignment  of  networks  and 
business cases, and further investment requirements for operators. 

Convergence of European electronic communications networks and cloud services to an EU 
“Telco  Edge  Cloud”,  as  envisaged  in  the  Industrial  Technology  Roadmap  of  the  European 
Alliance for Industrial Data, Edge and Cloud26 could become a major enabler for hosting and 
managing  network  virtualised  functions,  as  well  as  for  bringing  complementary  services 
addressing the rapidly growing markets for IoT-related products and services. This is expected 
to enable the transition to an industrial Internet enabling critical services in a broad range of 
sectors and activities of great benefit to citizens and industry alike. Concrete examples range 
from robot and drone services for industry, connected and autonomous vehicles interacting with 
edge networks deployed along the road for smart mobility and smart transportation systems, to 
use cases with stringent data privacy requirements such as remote patient healthcare. This calls 
for the broad availability of computing resources, fully integrated with network resources, to 
provide  the  data  transmission  and  data  processing  capacities  required  by  these  novel 

23   See 

for 

instance:  Integrated  Private  Wireless  on  AWS,  https://pages.awscloud.com/rs/112-TZM-
766/images/AWS%20Integrated%20Private%20Wireless%20eBook.pdf,  Announcing  private  network 
solutions on Google Distributed Cloud Edge, https://cloud.google.com/blog/products/networking/announcing-
private-network-solutions-on-google-distributed-cloud-edge. 

24   5G Observatory biannual report October 2023, Omdia’s Mobile Infrastructure Intelligence Service. 
25   https://digital-strategy.ec.europa.eu/en/policies/cross-border-corridors. 
26   European  industrial  technology  roadmap  for  the  next  generation  cloud-edge  offering,  May  2021 

https://ec.europa.eu/newsroom/repository/document/2021-
18/European_CloudEdge_Technology_Investment_Roadmap_for_publication_pMdz85DSw6nqPppq8hE9S9
RbB8_76223.pdf 

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applications. The Alliance is currently developing a further thematic roadmap on Telco Edge 
Cloud, which should be ready by mid-2024. 

Nowhere is that more obvious than in the city and large urban environments where these sectors 
and  activities  come  together.  The  data  that  they  generate  can  be  processed  and  combined 
locally, to reduce the use of network resources, orchestrate mobility and services in real-time, 
and optimise health and medical care for the citizen. If the different actors in this ecosystem 
work together, the Telco Cloud would potentially develop a new generation of compute and 
data orchestration systems capable of managing networked resources in environments such as 
smart cities, as well as providing interoperable services to develop and optimise the execution 
of data- and compute-intensive AI applications.  

However,  this  inevitable  opening  of  the  traditionally  “closed”  electronic  communications 
network in a NaaS approach exposes network capabilities to third parties and bears the possible 
risk of large non-EU providers becoming leading players in such ecosystems.  In the current 
geopolitical  context  and  from  an  economic  security  point  of  view,  this  would  constitute  a 
significant risk of additional dependence on non-EU players in the entire digital service sector. 
It is therefore key that European players develop the necessary capacities and scale27 to become 
service platform providers. 

This creates vast opportunities for the sector, in particular for equipment suppliers. The ability 
of European suppliers to seize them and become leading global providers of 6G equipment will 
largely  depend  on  how  they  navigate  the  broad  technological  changes  in  the  industry  and 
embrace the paradigm shift that comes with them (see section 2.4.1). The 2023 Beyond 5G/6G 
Roadmap of EU and US industries is a welcome development in this regard. 

In the next 5-10 years, both our infrastructure and encryption systems risk being compromised 
by ever more powerful computing brute force, and by the advent of quantum computing itself. 
These could render all existing key encryption systems at risk, leaving Europe’s communication 
networks  and  services  and  sensitive  data  (health,  financial,  security  or  defence-related  and 
more) extremely vulnerable. There is a clear and immediate need for the EU to start preparing 
its  digital  assets  to  face  this  risk.  A  number  of  recent  developments  based  on  quantum 
technologies, such as quantum key distribution, have significant potential to protect the EU’s 
sensitive data and digital infrastructure. 

For instance, the EU is working to deploy over the next ten years a fully certified end-to-end 
quantum  communication  infrastructure  (EuroQCI)  for  the  distribution  of  keys  used  in 
encryption technologies that will be gradually integrated in the EU Infrastructure for Resilience, 
Interconnectivity and Security by Satellite (IRIS2). Low Earth Orbit (LEO), and Medium Earth 
Orbit  (MEO)  satellite  constellations  and  other  non-terrestrial  connectivity  such  as  High-
Altitude Platforms (HAPs) further extend the boundaries of the technological changes to come.  

To conclude on technological challenges, the sectors of European electronic communications 
networks and services and network equipment stand currently at cross-roads; either they will 
embrace  and  endorse  technological  transformation,  or  they  will  leave  space  to  new  players, 
largely from outside the EU, with consequences in terms of EU economic security. 

27   The concept of scale may be very different in a NaaS environment in nature and magnitude compared to the 

economies of scale of typical current electronic communication networks. 

9 

 
 
 
 
 
2.3. Challenges of achieving scale in EU connectivity services 

2.3.1.  Investment needs 

According to a recent study conducted for the European Commission28, reaching current Digital 
Decade targets for Gigabit connectivity and 5G may require a total investment of up to EUR 
148  billion,  if  fixed  and  mobile  networks  are  deployed  independently,  and  stand-alone  5G- 
offering European citizens and businesses the full capabilities that can be offered by 5G mobile 
networks  is  deployed.  A  further  EUR  26-79  billion  of  investments  may  be  required  under 
different scenarios to ensure full coverage of transport corridors including roads, railways, and 
waterways, bringing the required total investment needs  for connectivity alone to over EUR 
200 billion. Despite the need to densify mobile networks to achieve higher performance, EU 
operators are focussing on reusing existing sites for low and mid-band deployments. However, 
for future upgrades, e.g. 6G or WiFi 6 the required network densification is likely to increase 
by a factor of 2-3 by the end of the decade at least in high-density demand areas.  

Beyond terrestrial connectivity, further investments are required for the integration of advanced 
satellite  services  providing  complementary  solutions  for  backhaul,  device  connectivity  in 
remote areas not covered by terrestrial technologies or to ensure service continuity in case of 
crisis or disaster relief.  

The  successful  completion  of  software  and  cloud-based  solutions  to  provide  NaaS  would 
require additional significant investment capacities. There is an estimated cloud investment gap 
in the EU of EUR 80 billion until 20272930. A slow transition of EU players towards cloud-
based  solutions  for  electronic  communications  services  and  beyond  would  present  risks  of 
further dependencies in the area of digital services.  

2.3.2.  Financial situation of the EU electronic communications sector 

The EU capacity to carry out the investments needed to successfully transform the connectivity 
sector to tackle technological challenges will depend on the financial situation of its electronic 
communications sector. 

In this context, the current financial situation of the EU electronic communications sector raises 
concerns for its capacity to find funding for the substantial investments that are needed to catch 
up with the technological shift. 

The average revenue per user  (ARPU) of  electronic communications  operators in  the EU is 
relatively low compared to other economies such as the US, Japan or South Korea31. This has 

28   https://digital-strategy.ec.europa.eu/en/library/investment-and-funding-needs-digital-decade-connectivity-

targets.  

29   European Alliance for Industrial Data, Edge and Cloud: “European industrial technology roadmap for the next-
generation  cloud-edge”,  extrapolating  until  2030  the  investment  gap  identified  in  the  Commission  Staff 
Working Document (27.5.2020):  Identifying Europe's recovery needs, SWD(2020) 98 final/2, Brussels, pp. 
17-18. 

30   Synergy Research Group, e.g. based on Q1/2023 data, Investments related  to general cloud capacities tailored 
to the business model of each cloud provider and not significantly overlapping with the general EU connectivity 
investment needs. 

31   In 2022, mobile ARPU was EUR15.0 in Europe, as opposed to EUR42.5 in the US, EUR26.5 in South Korea, 
and EUR25.9 in Japan. Fixed broadband ARPU was EUR22.8 in Europe versus EUR58.6 in the US, EUR24.4 
in Japan, and EUR13.1 in South Korea. ETNO, State of Digital Communications 2024, January 2024.  

10 

 
 
 
 
 
led to declining Return on Capital Employed (ROCE)32. The capital expenditure (Capex) per 
capita in the EU is also lower. In 2022, it stood at EUR 109.1 compared to EUR 270.8 in Japan, 
EUR  240.3  in  the  US  and  EUR  113.5  in  South  Korea33.  During  the  last  decade  stocks  of 
European electronic communications networks and services providers have underperformed in 
both  global  electronic  communications  indices  and  European  stock  markets34.  European 
providers  of  electronic  communications  networks  and  services  also  face  low  enterprise 
value/EBITDA multiples, suggesting lack of market confidence in the potential for sustainable 
long-term growth in revenues.  

Against  this  background,  the  proportion  of  at  least  some  of  the  electronic  communications 
operators’ net debt over their EBITDA has continued to grow. In addition, access to finance 
seems  to  have  degraded  as  interest  rates  jumped  from  historical  lows  and  widespread  risk 
aversion  linked  to  the  new  global  crises  result  in  macroeconomic  uncertainty.  As  other 
infrastructure  providers,  providers  of  electronic  communications  networks  will  also  need  to 
recover  investment  costs  over  several  decades,  and  even  a  slight  change  in  the  interest  rate 
impacts the financial viability of investment projects.  

In this context, perception of attractiveness of advanced digital networks by private investors is 
of  crucial  importance  for  the  future  of  connectivity.  Certain  investors  have  underlined  that 
mobilising  private  investments  requires  a  clear  business  case  for  profitability  and  higher 
margins. Profitability depends on the take-up of enhanced fixed and mobile networks, which is 
itself linked to the development and increased take-up of data intensive applications and use 
cases, e.g. based on edge computing, AI, and IoT. 

Also, in this context, some stakeholders underlined the importance of demand-side measures. 
In this regard, the Union supports the  adoption of digital technologies by SMEs through the 
objectives  and  targets  set  in  the  Digital  Decade  and  notably  through  the  European  Digital 
Innovation Hubs, the deployment of data spaces for stakeholders to share and reuse industrial 
data in a trustworthy environment and the access to future “AI factories”35. Increased use of 
advanced electronic communication services by businesses will reinforce the digitalisation of 
local ecosystems participating in EU wide supply chains and promote access to infrastructure-
intensive  applications  such  as  generative  AI,  edge  computing  and  supercomputing,  while 
avoiding possible undue competition distortion.  

Some investors pointed to the prudential rules for banks and insurance companies as inhibiting 
the deployment of capital and the stimulation of equity markets. They argue for reducing the 
levels of required capital set by the legislative framework on prudential regulation. For example, 
they claim that, in relation to insurance companies, the Solvency II directive36 would encourage 
insurance companies to reduce their exposure to equities for prudential reasons37 as equity prices 
are volatile. As a consequence, more equity investment would arguably lead to lower solvency 

32   As regards fixed markets, according to the 2023 State of the Digital Communications ETNO report, the ARPU 
of ETNO members was at EUR 21.8 compared to EUR 50.6 in the US and EUR 26.2 in Japan, and only ahead 
of South Korea (EUR 13) and China (EUR 4.9). 

33   Ibid. 
34   State of Digital Communications 2023, ETNO. 
35   Communication from the Commission to the European Parliament, the Council, the European Economic and 
Social  Committee  and  the  Committee  of  the  Regions  on  boosting  startups  and  innovation  in  trustworthy 
artificial intelligence, COM(2024)28 final. 

36   Directive 2009/138/EC of the European Parliament and of the Council of 25 November 2009 on the taking-up 
and pursuit of the business of Insurance and Reinsurance (Solvency II), OJ L 335, 17.12.2009, p. 1–155. 

37   Financer la quatrième révolution industrielle, Philippe Tibi, 2019. 

11 

 
 
 
 
 
ratios38. The recently agreed current review of the Solvency II framework has addressed these 
claims, and will result in substantial capital relief thanks to a reduction of the risk margin, to 
changes to the symmetric adjustment and the definition of clear criteria for long-term equity39. 
Investments, particularly those in infrastructure, would potentially be stimulated thanks to the 
increased insurance industry’s capacity to invest in EU businesses40. 

Nonetheless,  since  equity  invested  in  unlisted  stock  such  as  innovative  businesses  and  new 
electronic communications operators are still likely to be deemed riskier, public support is a 
necessary incentive. Investors also consider that public support, in particular from the Recovery 
and Resilience Facility and other EU funds (Next Generation EU, Structural Funds, Connecting 
Europe Facility (CEF), etc.) will help reach market failure areas, where demand is insufficient 
to  adequately  remunerate  private  deployment.  At  the  same  time,  in  investors’  view,  public-
private  partnerships,  where  the  public  capital  takes  the  form  of  guarantees  or  junior  co-
investment, could possibly be a good and efficient way to help the electronic communications 
sector fund its transformation.   

Investors finally explained that another element hindering the attractiveness of the European 
electronic communications market for large investors is its fragmentation and hence the lack of 
assets with sufficient scale. It is common that large investors have minimum thresholds for their 
investments because of their limited capacity to manage and/or monitor their portfolio. This 
means  there  are  fewer  financiers  competing  for  smaller  investments  than  for  larger  ones, 
resulting  in  less  favourable  conditions.  Further,  the  relative  cost  of  administering  large 
investments  is  lower  than  for  smaller  ones  thus  investors  can  offer  better  conditions.  The 
integration of national markets could be an opportunity to tap into a larger potential pool of 
investors  and  financing  conditions  for  electronic  communications  investments.  In  addition, 
increasing the size of projects can improve their cost efficiency and boost the projects financial 
viability. A better return profile will improve their attractiveness and eventually the financial 
conditions. 

2.3.3.  Lack of single market 

At present, the EU does not have a single market for electronic communications networks and 
services,  but  27  national  markets  with  different  supply  and  demand  conditions,  network 
architectures,  different  levels  of  coverage  of  very  high-capacity  networks,  different  national 
spectrum  authorisation  procedures,  conditions  and  timing,  as  well  as  different  (albeit  partly 
harmonised) regulatory approaches. The fragmentation does not only concern the supply side 
of the market. Also from the demand side, i.e. end-users, market  conditions differ from one 
Member State to another. This fragmentation was underlined by the majority of respondents to 
the  exploratory  consultation  on  the  future  of  the  electronic  communications  sector  and  its 
infrastructure41.  They  highlighted  that  the  removal  of  obstacles,  notably  burdensome  and/or 

38   Deloitte Belgium and CEPS for the European Commission, DG for Financial Stability, Financial Services and 
Capital Markets Union, Study on the drivers of investments in equity by insurers and pension funds, December 
2019. 

39   Confirmation of the final compromise text with a view to agreement, Proposal for a Directive of the European 

Parliament and of the Council amending Directive 2009/138/EC, 2021/0295 (COD). 

40   Communication from the Commission to the European Parliament and the Council on the review of the EU 
prudential  framework  for  insurers  and  reinsurers  in  the  context  of  the  EU’s  post  pandemic  recovery, 
COM(2021) 580, 2021.  

41   The results of the exploratory consultation were published in October 2023 and are available at: https://digital-

strategy.ec.europa.eu/en/news/consultation-electronic-communications-highlights-need-reliable-and-
resilient-connectivity. In this regard, the large majority of the respondents to this question (including telecom 

12 

 
 
 
 
 
 
fragmented  sectoral  regulation,  can  create  incentives  for  cross-border  consolidation  and 
emergence  of  a  fully  integrated  Digital  Single  Market.  Concerning  the  barriers  to  market 
integration,  the  majority  of  the  respondents  to  the  exploratory  consultation42  called,  in 
particular, for a more integrated spectrum market and a more harmonised approach to spectrum 
management across the EU. They suggested that it would be appropriate to align the approaches 
related  to,  for  example,  duration  of  licences,  reserve  prices,  annual  cost  of  spectrum,  or 
spectrum sharing practices.  

Radio spectrum policy is an area of shared competence between the EU and Member States. 
The  EU  adopts  rules,  in  particular  for  the  EU-wide  designation  of  frequency  bands  under 
harmonised  technical  conditions.  Member  States’  action  focuses  on  the  implementation  of 
spectrum authorisation, management and use. However, the way spectrum is managed and used 
in one Member State has an impact on the internal market as a whole, for example through 
disparate starting times in the development of new wireless technologies or new services or 
through  harmful  cross-border  interference,  with  further  possible  repercussions  for  EU 
competitiveness,  resilience  and  technological  leadership.  Therefore,  it  is  imperative  that 
spectrum  is  managed  in  a  more  coordinated  way  among  all  Member  States  to  maximise  its 
social and economic value and enhance terrestrial and satellite connectivity across the entire 
EU. 

The  past  attempts  for  more  EU  coordination,  convergence  and  certainty  in  spectrum 
management,  for  example,  in  the  context  of  the  proposal  for  a  Telecommunications  Single 
Market regulation43 and the European Electronic Communications Code (hereinafter referred 
to  as  the  “Code”)44,  were  not  successful  in  many  respects.  Ultimately,  this  had  detrimental 
consequences  for  the  EU  as  a  whole.  For  example,  the  authorisation  process  for  bands 
anticipated to enable future 5G deployment started in 2015 in the first Member States45 and is 
not yet fully completed now in 2024, despite the deadlines set at EU level. The authorisation 
process for the use of the 800 MHz and 2.6 GHz bands for 4G took 6 years for 26 Member 
States and even 10 years for 27, despite the absence of an exceptional pandemic event as for 
5G46. This has resulted in fragmented 4G and 5G roll-out landscapes across the EU, where some 
Member States were almost one wireless technology generation behind others. 

and satellite business associations, vendors, operators as well as NGOs) noted that the digital single market is 
hampered by the fragmentation of the sector into national markets. This is due both to cultural and diverging 
market  circumstances  and  the  lack  of  full  harmonisation  of  sector  rules  (e.g.  building  lawful  interception 
capabilities, data  retention, data  protection, reshoring requirements, cybersecurity and reporting obligations 
and network/service incident reporting requirements, spectrum auction conditions, etc.), which is also caused 
by  a  slow  and  piecemeal  implementation  of  EU  rules  at  national  level  and  fragmented  approaches  to 
enforcement. 

42   When replying to the consultation, the majority of the  respondents, mostly companies (ECN providers and 
digital platforms), business associations and consumer organizations, welcomed the idea of a more integrated 
spectrum market and a harmonised approach to spectrum management across the EU.  

43   COM(2013) 627 final.  
44   Directive (EU) 2018/1972 of the European Parliament and of the Council of 11 December 2018 establishing 

the European Electronic Communications Code, OJ L 321, 17.12.2018, p. 36. 

45   Commission  study  on  assessing  the  efficiency  of  radio  spectrum  award  processes  in  the  Member  States, 
including the effects of applying the European Electronic Communications Code, available at https://digital-
strategy.ec.europa.eu/en/library/study-assessing-efficiency-radio-spectrum-award-processes-member-states-
including-effects-applying. 
on 

European  Union, 

46  Commission 

assignment 

spectrum 

available 

study 

the 

in 

at 

https://op.europa.eu/en/publication-detail/-/publication/2388b227-a978-11e7-837e-01aa75ed71a1/language-
en. 

13 

 
 
 
 
 
Moreover,  in  certain  cases  where  spectrum  bidders  ended  up  paying  higher  prices  due  to 
artificial  scarcity  created  by  auction  design,  this  has  been  associated  with  a  reduction  in 
investment  capacities  and  delays  in  services  deployment  by  providers  of  electronic 
communications networks and services. Ultimately, it is the consumers and business users who 
have  paid  the  price  in  terms  of  suboptimal  quality  of  services,  which  ultimately  negatively 
impacts EU’s economic growth, competitiveness and cohesion. 

There  are  also  national  rules  beyond  sector  specific  electronic  communications  legislation 
imposing obligations, as regards, for instance, lawful interception, data retention or localisation 
of Security Operations Centres, that were also raised in the exploratory consultation as barriers 
to the full integration of the Single Market47. In these areas, lack of uniform legislation at EU 
level  contributed  to  significant  fragmentation  (e.g.  different  duration  of  data  retention 
obligations,  localisation  requirements  for  Security  Operations  Centres,  lack  of  mutual 
recognition for security vetting for relevant staff) preventing a provider operating a network in 
more than one Member State from exploiting economies of scale. 

Regulatory fragmentation is mirrored in the market structure. While there are around 50 mobile 
operators,  and  more  than  100  fixed  operators  in  the  EU,  only  few  European  operators  (e.g. 
Deutsche  Telekom,  Vodafone,  Orange,  Iliad  and  Telefonica)  are  present  in  several  national 
markets.  When  it  comes  to  mobile  markets,  at  service  level,  16  Member  States  have  three 
mobile network operators, nine Member States have four and two Member States have five. In 
certain  Member  States,  in  terms  of  distinct  mobile  electronic  communications  network 
infrastructures,  the  number  is  lower  than  the  number  of  service  providers  due  to  existing 
network sharing arrangements (e.g. in Denmark or Italy). Even the mobile operators that are 
part of corporate groups with a large footprint across the EU, operate within national markets 
and do not seem to harmonise their offerings and operational systems at EU level, due to the 
inherently different market and regulatory landscapes, beyond the need to ensure affordability 
in Member States with lower purchasing power.  

Against this backdrop of fragmentation in the EU (which is specific to the EU compared to 
other  regions  of  the  world)  and  low  profitability  levels,  the  question  arises  as  to  whether 
industrial  policy  measures  further  facilitating  the  cross-border  provision  of  electronic 
communications networks or different forms of cooperation upstream could allow operators to 
acquire sufficient scale, without compromising downstream competition. Some operators are 
of the view that there are no obstacles to cross-border provision of networks and services other 
than the net negative efficiencies and synergies (despite expected cost reductions which could 
be allowed by more centralised operations, especially in virtualised networks) that are due to 
fragmented regulatory conditions. Cross-border consolidation in itself has never been a problem 
from  a  competition  standpoint  because  of  the  national  dimension  of  the  EU  electronic 
communications markets. However, as long as the benefits of cross-border consolidation are 
limited by the persistence of national regulatory frameworks and the lack of a genuine single 
market, it cannot as such overcome the fallbacks mentioned earlier. 

47   The results of the exploratory consultation were published in October 2023 and are available at 

https://digital-strategy.ec.europa.eu/en/news/consultation-electronic-communications-highlights-need-
reliable-and-resilient-connectivity. For this point see page 12 under point ii. Obstacles to the Digital Single 
Market. 

14 

 
 
 
 
 
While prices and coverage differ considerably between Member States48 due to the inherently 
different market and regulatory landscapes, beyond the need to ensure affordability in Member 
States with lower purchasing power, mobile and fixed broadband prices are typically lower in 
the  EU  compared  to  the  US  for  the  vast  majority  of  tariffs,  bringing  significant  short-term 
consumer  benefits.  At  the  same  time,  coverage  for  fibre  is  higher  in  the  EU  and  basic  5G 
coverage  is  comparable  to  the  US  levels.  However,  while  the  single  market,  on  average, 
delivered on price, it did not deliver on the mass deployment of advanced infrastructures and 
services like 5G standalone or the proliferation of advanced industrial and IoT services49.  

Overall,  the  fragmentation  of  the  EU  market  for  electronic  communications  networks  and 
services  along  national  borders impacts the ability of operators to  reach the scale needed to 
invest in the networks of the future, in particular in view of cross-border services, important for 
an effective deployment of IoT, and a more centralized operation. 

2.3.4.  Convergence and level playing field 

The convergence of electronic communications networks and services and cloud infrastructures 
does not only concern the infrastructure layer, but also the service operations. As explained in 
section 2.2 above, connectivity markets are facing transformative technological developments 
the result of which will be both a converged supply (i.e. network and service provision) as well 
as a converged demand by end-users. Yesterday’s separation between “traditional” electronic 
communications networks/service providers and cloud or other digital service providers will 
tomorrow  be  superseded  by  a  complex  converged  ecosystem.  These  developments  raise  the 
question  whether  the  players  in  such  converged  ecosystem  should  not  fall  under  equivalent 
rules applicable to all and whether the demand side (i.e. end-users and in particular consumers) 
should not benefit from equivalent rights.  

Currently, the existing EU regulatory framework for electronic communications networks and 
services does not establish obligations related to the activities of cloud providers and does not 
regulate the relationship between the various players in the new complex digital infrastructure 
ecosystem.  More  specifically,  the  cloud  infrastructure  and  services  provision  are  not  in  the 
scope of the Code (contrary to the recent NIS2 Directive50 for instance). Even if cloud providers 
run  large  (backbone)  electronic  communications  networks,  these  networks  are  exempt  from 
parts  of  the  electronic  communications  regulatory  framework,  notably  in  the  area  of  access 
regulation and dispute resolution.  

More than 60%51 of the international traffic transits through submarine cables, which do not 
belong  to  “public  electronic  communication  network  operators”  within  the  meaning  of  the 
Code. Moreover, large cloud providers operate their own backbone networks and data centres 
and hand over the traffic deep into the networks of public electronic communication network 

48   Mobile and fixed broadband prices vary widely  across the EU not only in nominal terms but also at power 
purchasing parity. See European Commission, Directorate-General for Communications Networks, Content 
and Technology, Mobile and fixed broadband prices in Europe 2021  – Final report and executive summary, 
Publications Office of the European Union, 2022, available at https://data.europa.eu/doi/10.2759/762630. 

49   2023  Report 

on 

the 

state 

of 

the  Digital  Decade, 

available 

at 

https://digital-

strategy.ec.europa.eu/en/library/2023-report-state-digital-decade.  

50   Directive (EU) 2022/2555 of the European Parliament and of the Council of 14 December 2022 on measures 
for  a  high  common  level  of  cybersecurity  across  the  Union,  amending  Regulation  (EU)  No  910/2014  and 
Directive (EU) 2018/1972, and repealing Directive (EU) 2016/1148 (NIS 2 Directive), OJ L 333, 27.12.2022, 
p. 80. 

51   BoR  (23)  214,  Draft  BEREC  Report  on  the  general  authorization  and  related  frameworks  for  international 

submarine connectivity.  

15 

 
 
 
 
 
operators.  Consequently,  traffic  transits  mostly  on  private  networks,  which  are  largely 
unregulated, rather than on public ones.  

Another distinction made in the Code is between the kind of service provided; for example, 
most  obligations  apply  to  providers  of  internet  access  services  and  of  number-based 
interpersonal  communications  services  (NBICS)  while  providers  of  number-independent 
interpersonal  communications  service (NIICS) are  subject  to  only  a few  obligations and are 
exempt for instance from contribution to the funding of the Universal Service or the financing 
of sector regulation. Whilst both NIICS and cloud computing services are within the scope of 
the Digital Markets Act52, those rules only apply to gatekeepers designated for these specific 
core platform services. 

2.3.5.  Sustainability challenges  

The ICT sector accounts for between 7 and 9% of global electricity consumption (forecast to 
rise  to  13%  by  2030)53,  around  3%  of  global  greenhouse  gas  emissions54,  and  increasing 
amounts of e-waste. Yet, if properly used and governed, digital technology can help cut global 
emissions  by  15%55,  outweighing  the  emissions  caused  by  the  sector.  For  instance,  smart 
building design has the potential to generate energy savings of up to 27%56 and smart mobility 
applications  have  been  shown  to  be  able  to  reduce  transport  emissions  by  up  to  37%57. 
Connected and Automated Mobility is expected to be one of the main drivers to decarbonise 
the transport sector and 5G is expected to be one of its main enablers.  However, significant 
further efforts are needed to apply digital technology systematically and make sure it powers 
solutions carefully designed according to circular, regenerative principles.  

The “softwarisation” and “cloudification” of the next generations of electronic communications 
networks hold the promise of efficiency gains for all sectors, but also present new challenges 
in  terms  of  energy  consumption  (e.g.  Open  Radio  Access  Network  -  RAN  -  in  cellular 
networks). Increased energy consumption due to step changes in traffic load has a cost in itself 
that has significantly increased in recent years with rising energy prices. At the same time, high 
energy costs could incentivise investments into more energy-efficient and low-carbon network 
operations and technologies with less e-waste.  

Modern  digital  networks  can  contribute  significantly  to  sustainability.  Concrete  examples 
include the deployment and adoption of new and more efficient technologies such as fibre, 5G 
and 6G, and the phasing out of legacy fixed and mobile networks. Also, the use of more efficient 
codecs (coders-decoders)58 for data transmission is essential. Newer generation video codecs 
are inherently more sustainable by minimising outgoing energy and power at the same video 
quality. At the same time, proper attention and investments, including sustainable financing, 
need to be ensured so that connectivity can accelerate and deliver on the digital enablement to 
green other sectors, through smart digital solutions that reduce the climate and environmental 

52   Regulation  (EU)  2022/1925  of  the  European  Parliament  and  of  the  Council  of  14  September  2022  on 
contestable and fair markets in the digital sector and amending Directives (EU) 2019/1937 and (EU) 2020/1828 
(Digital Markets Act), OJ L 265, 12.10.2022, p. 1. 

53   Strategic Foresight Report 2022; EU Action Plan on Digitalising the Energy System.  
54   The Shift Project, “Déployer la sobriété numérique”, October 2020, p. 16; World Bank 2022.  
55   World Economic Forum 2019.  
56   https://www.buildup.eu/en/news/overview-smart-hvac-systems-buildings-and-energy-savings-0.  
57   TransformingTransport.eu, EU-funded Horizon 2020 Big Data Value Lighthouse project.  
58   A codec is a process that compresses large amounts of data  – most commonly a video stream - before their 

transmission and decompresses them after the reception. 

16 

 
 
 
 
 
footprint across industrial processes, energy systems, buildings, mobility, and agriculture and 
support the efforts towards climate neutral and smart cities. 

2.4. Need for security in the supply and in the operation of networks 

2.4.1.  Challenge of trusted suppliers 

In  a  geopolitical  environment  increasingly  marked  by  tension  and  conflict,  the  growing 
requirement  for  security  and  resilience  of  key  enabling  communications  technologies  and 
critical infrastructure highlights the need to rely on diversified and trusted suppliers, to prevent 
vulnerabilities  and  dependencies,  with  potential  knock-on  effects  on  the  entire  industrial 
ecosystem. The EU 5G Cybersecurity Toolbox59 for example put forward a set of recommended 
measures to  mitigate the risks to  5G networks, notably  the assessment of the risk profile of 
suppliers  and  the  application  of  restrictions  for  suppliers  considered  as  high  risk,  including 
necessary exclusions from key assets. In this respect, in its Communication of 15 June 2023 on 
the  “Implementation  of  the  5G  Cybersecurity  Toolbox”60  the  Commission  considered  that 
Huawei and ZTE present in fact materially higher risks than other 5G suppliers and confirmed 
that decisions adopted by Member States to restrict those suppliers are justified and compliant 
with the 5G Toolbox.  

Gaps  left  by  these  high-risk  vendors  in  the  supply  chain  require  the  development  of  new 
capacities provided by existing or new actors. In this context, Research & Innovation (R&I) 
efforts in key technologies relevant for secure communications networks will have to be stepped 
up  to  ensure  that  a  sufficient  level  of  intellectual  property  and  production  capacity  remains 
available across the entire EU supply chain, at all times. The objective is not only to ensure that 
the  EU  remains  among  the  global  leaders  in  communications  systems,  but  also  to  achieve 
leadership in  the development of  new capabilities in  related areas such as edge cloud,  radio 
frequency 
resilient 
cryptography, non-terrestrial connectivity, and submarine cable infrastructures.  

technology,  quantum  communications,  quantum 

identity  chips 

2.4.2.  Security standards for end-to-end connectivity  

To  achieve  the  highest  security  and  resilience,  the  EU  should  also  lead  the  development  of 
security standards covering the entire value stack, from end-to-end and from the hardware layer 
up to the service layer (e.g. secure messaging and videoconferencing standards). The challenge 
for the EU is to ensure that such developments result in common and interoperable security 
standards  for  all  key  infrastructural  elements  underpinning  sensitive  communications 
infrastructures. The Commission is working with Member States to establish the EU Critical 
Communication  System  (EUCCS)  to  connect  communication  networks  of  all  public  law-
enforcement, civil protection and safety responders in Europe by 2030 to allow for seamless 
critical communication and operational mobility across the Schengen area61. The related setting 
of mission critical standards will enhance strategic autonomy in a particularly sensitive segment 
of the communication sector. 

59   https://digital-strategy.ec.europa.eu/en/news/connectivity-toolbox-member-states-agree-best-practices-boost-

timely-deployment-5g-and-fibre. 

60   C(2023) 4049. 
61   EUCCS is based on projects funded by the EU security research programme and the Internal  Security Fund. 
The current rollout of testbeds in Member States will also establish the link to EU connectivity assets in Space, 
in line with the EU Space Strategy for Security and Defence.  

17 

 
 
 
 
 
The  new  digital  era  will  be  based,  among  others,  on  quantum  technologies  for  secure 
connectivity and quantum computing. Communication networks and the way data are protected 
will experience a paradigm shift as a direct consequence of advances in quantum computing. 
As  safeguarding  our  data  and  securing  communication  are  vital  for  our  society,  economy, 
infrastructure, services, and prosperity, as well as our political stability, we need to anticipate 
threats coming from potential malicious use of future quantum computers, which could put our 
traditional methods of encryption at risk.  

The Cyber Resilience Act (CRA), which is set to enter into force later this year, will contribute 
significantly to securing EU’s digital infrastructure. It places security-by-design obligations on 
the  manufacturers  of  hardware  and  software  products,  covering  the  entire  life  cycle  of  such 
products from their design and development to their maintenance. The CRA not only covers 
many of the products deployed in digital infrastructures, such as routers, switches or network 
management  systems,  but  also  requires  the  manufacturers  of  connectable  hardware  and 
software products at large to protect the confidentiality and integrity of data by state-of-the-art 
means.  This  could  entail,  where  appropriate,  the  use  of  quantum-resistant  cryptography.  To 
support manufacturers in their implementation, the Commission will request the development 
of European standards by the European Standardisation Organisations. In addition, the recently 
adopted  European  Cybersecurity  Scheme  on  Common  Criteria  (EUCC)  will  allow 
manufacturers of technological components, such as chips, to provide security assurance in a 
harmonised manner under the EU’s Cybersecurity Act. 

2.4.3.  Secure and resilient submarine cable infrastructures 

A precondition for secure communications is a higher level of resilience and integration of all 
communication channels: terrestrial, non-terrestrial and, importantly, submarine. In the current 
context of increased cybersecurity and sabotage threats, governments in all regions are paying 
particular  attention  to  their  reliance  on  critical  submarine  cables.  Indeed,  over  99%  of 
intercontinental data traffic is carried through submarine cables, and three insular EU Member 
States, Cyprus, Ireland and Malta, as well as a number of islands in other Member States and 
outermost regions are highly dependent on them.  

In  particular,  Russia’s  war  of  aggression  against  Ukraine  has  had  a  significant  impact  on 
awareness about the security of communications networks, including submarine cables, given 
its potential capability to disrupt cables and suspicious monitoring activities of Russian vessels. 

Europe has global leaders in fibre production. However, since 2012, large non-EU providers 
have been increasingly investing in own infrastructures, which is already leading to strategic 
dependencies, which may be further exacerbated going forward.  

In the EU, there have been repeated calls to strengthen the security and resilience of submarine 
cable  infrastructures,  including  increasing  public  funding  to  support  private  investment  in  a 
challenging environment. For instance, the Nevers Call of March 202262 recognised the utmost 
importance of critical infrastructure, such as electronic communications networks and digital 
services,  to  many  critical  functions,  and  the  fact  that  the  latter  are  a  prime  target  for 
cyberattacks. The Council, in its Conclusions on the EU’s Cyber Posture of 23 May 2022 and 
on the EU Policy on Cyber Defence of 22 May 2023, requested risk evaluations and scenarios 
to be undertaken. In its  Critical Infrastructure Resilience Recommendation  on a Union-wide 

62   https://presse.economie.gouv.fr/08-03-2022-declaration-conjointe-des-ministres-de-lunion-europeenne-

charges-du-numerique-et-des-communications-electroniques-adressee-au-secteur-numerique/. 

18 

 
 
 
 
 
coordinated approach to strengthen the resilience of critical infrastructure of 8 December 2022, 
the Council set out targeted actions at EU and Member States’ level for enhanced preparedness, 
enhanced response and international cooperation. These actions focus on critical infrastructure, 
including those with significant cross-border relevance and in the identified key sectors energy, 
transport, space, and digital infrastructure.  

In the State of the Digital Decade report 2023, the Commission underlined the importance of 
making progress towards more resilient and more sovereign networks and in particular to limit 
the vulnerability of the EU’s key infrastructure, including submarine networks. It also issued a 
clear recommendation to Member States to boost the investments necessary for the security and 
resilience  of  such  infrastructures.  Member  States  have  also  committed  to  reinforce  Internet 
connectivity between Europe and its partners, in the Ministerial Declaration on “European Data 
Gateways as a key element of the EU’s Digital Decade”.  

Moreover,  the  EU-NATO  Task  Force  on  the  resilience  of  critical  infrastructure  discussed 
submarine  infrastructure  on  several  occasions.  Its  Final  Assessment  Report  includes  a 
recommendation for EU and NATO staffs to “[e]xplore possibilities for exchanges on how to 
improve  the  monitoring  and  protection  of  critical  infrastructure  in  the  maritime  domain  by 
relevant  authorities  and  discuss  ways  to  enhance  maritime  situational  awareness”.  Staff 
exchange have intensified in the context of the Structured Dialogue on Resilience, including in 
light of the establishment of the NATO Critical Undersea Infrastructure Coordination Cell to 
address the security of inter alia submarine cables. 

Incidents such as in the Baltic Sea63, following which Finland activated the EU Hybrid Toolbox 
mechanism64,  have  however  demonstrated  that  elements  of  submarine  cable  infrastructure 
remain  vulnerable,  even  if  the  system  itself  is  resilient  due  to  multiple  redundancies.  This 
underlines  the  need  to  further  advance  and  coordinate  work  at  EU  level  to  foster  cable 
infrastructure security and resilience. Consequently, the European Council on 27 October 2023 
consequently stressed “the need for effective measures to strengthen the resilience and ensure 
the security of critical infrastructure”, while underlining “the importance of a comprehensive 
and coordinated approach.” 

As mandated by the 2022 Council Recommendation as regards submarine cable infrastructures, 
the  Commission  carried  out  studies  and  consulted  relevant  stakeholders  and  experts  on 
appropriate  measures  in  relation  to  possible  significant  incidents  regarding  submarine 
infrastructure. The results of the study will be shared with Member States at the appropriate 
confidentiality level.  

A key conclusion is that the current framework in the EU cannot fully address the challenges 
identified. Concrete elements currently lacking include an accurate mapping of existing cable 
infrastructures  informing  a  consolidated  EU-wide  assessment  of  risks,  vulnerabilities  and 
dependencies, a common governance of cable technologies and cable-laying services, ensuring 
rapid and secure repair and maintenance of cables, as well as the identification and funding of 
critical intra-EU and global cable projects. 

63   A submarine gas pipeline (between Finland and Estonia) and electronic communications cables (between FI 

and EE, and between SE and EE) were damaged. 

64   Council conclusions of 21 June 2022 on a Framework for a coordinated EU response to hybrid campaigns.  

19 

 
 
 
 
 
3.  MASTERING  THE  TRANSITION  TO  THE  DIGITAL  NETWORKS  OF  THE 

FUTURE - POLICY ISSUES AND POSSIBLE SOLUTIONS 

3.1. Pillar I: Creating the “3C Network” - “Connected Collaborative Computing” 

As described in earlier sections, people and devices communicating with each other, doctors 
caring for their patients at a distance, buildings becoming intelligent through sensors, and other 
future  applications  facilitating  business  and  improving  the  lives  of  citizens  depend  on  the 
availability of high-performing digital infrastructures.  

The  advancement  of  on-device  edge  technology  is  expected  to  facilitate  the  presence  of 
significant  computational  capacity,  especially  those  equipped  with  AI  processors,  in  a  wide 
range of devices, including robots, drones, medical devices, wearables and self-driving cars. 
Computation is no longer bound to dedicated computing environments such as data centres. 
Instead,  it  has  become  embedded  and  ubiquitous  in  almost  everything.  This  will  allow  to 
combine  on-device  edge  with  the  rest  of  the  broad  range  of  edge  computing  categories  and 
different  types  of  cloud  services  in  collaborative  computing  environments65.  However,  the 
integration of these different computing resources with various network capacities will require 
intelligent  orchestration,  that  also  allows  optimisation  for  security  and  sustainability 
considerations. 

As section 2.2 describes, just as connectivity and computing are converging, the companies in 
these  different  segments  of  the  value  chain  also  need  to  work  together,  including  chips 
manufacturers,  electronic  communications  network  equipment  providers,  edge  and  cloud 
service providers. But the different sectors are fragmented and, as well as lacking scale, they 
do  not  have  a  common  approach  to  the  innovation  necessary  to  deliver  next  generation 
connectivity and computing. Thus, as well as orchestration in the technical sense, these sectors 
require close collaboration in order to succeed. 

We  need  to  ensure  that  these  innovations  are  implemented  in  the  EU  and  safeguard  our 
economic security and prosperity. In particular, it is of key importance that EU industry has 
sufficient  technology  capacity  in  key  parts  of  the  digital  supply  chain  and  is  able  to  reap 
economic benefits in the most attractive parts of the digital value chain. The goal is to foster a 
vibrant community of European innovators, creating the “Connected Collaborative Computing” 
Network (“3C Network”), an ecosystem that spans semiconductors, computational capacity in 
all kinds of edge and cloud environments,  radio technologies,  to  connectivity  infrastructure, 
data management, and applications.  

3.1.1.  Capacity building through open innovation and technology capabilities 

As  hybrid  networks,  edge  computing,  and  full  cloud  migration  change  the  architecture  of 
connectivity  infrastructure,  the  historical  strength  of  Europe  in  the  network  equipment  and 
service  industry  is  at  risk.  It  is  therefore  important  to  safeguard  EU  global  leadership  in 
electronic communications network equipment and facilitate the build-up of further industrial 
capacities in this transition towards interoperable cloud-based networks and the integration of 
telco-edge infrastructures and services. Next to industrial capacity, it is equally important for 
the  EU  to  strengthen  its  technological  innovation  capabilities  as  well  as  developing  the 
necessary knowledge and skills.  

65   Collaborative computing environments have also been referred to in literature as Swarm computing, Ambient 

Computing, and Tactile internet, among other additional terms. 

20 

 
 
 
 
 
EU  businesses  increasingly  partner  with  non-EU  players,  both  within  the  electronic 
communications services ecosystem but also in the supply industry. While such partnerships 
with  actors  from  like-minded  countries  can  generate  synergies  and  benefits,  a  potential 
dependency  on  a  small  number  of  suppliers  of  critical  infrastructures  and  services,  such  as 
cloud, edge or AI tools, or submarine cable infrastructures, bears the risk of new bottlenecks or 
lock-ins66.  The  goal  must  be  to  create  an  equally  strong  dynamic  for  partnership  between 
businesses within Europe. 

In the area of semiconductors, the EU has reacted to reverse this trend: with the Chips Act67, 
the EU has put forward an ambitious programme which has already mobilised more than EUR 
100 billion of public and private investments. But when it comes to connectivity infrastructures, 
an industrial policy of similar magnitude to incentivise investments by EU players and catalyse 
the 3C Network to enable future applications is currently missing. 

Nevertheless, in the equipment sector, the EU has a solid base that it can build upon. Today, it 
is the home of two of the three largest suppliers of digital network equipment, both as regards 
global sales market share and share of standard essential patents. Following decades of success 
in shaping mobile communication standards and driving innovation in the EU and globally, the 
challenge is to build on this leading position and leverage it to the broader supply and value 
chain, such as in the area of edge and cloud computing but also chips, where Europe starts from 
a weaker position. This extends to complementary infrastructures, such as submarine cables or 
even non-terrestrial connectivity.  

As for production, deployment, and operational capacities, Europe can also build on its strength 
when it comes to R&I in the upstream part of the digital value chain. The EU already hosts a 
solid R&I base for networks, with globally renowned scientific excellence on which future R&I 
ecosystems  can  build.  The  geopolitical  context  and  the  trend  towards  ever  more  critical 
applications, such as blockchain in finance, connected trucks in logistics, or telemedicine, call 
for infrastructure security and resilience by design. These design criteria therefore need to be 
placed at the forefront of our R&I efforts.  

However, the transformation of the EU’s connectivity industry requires significant investment 
capacities,  in  particular  when  compared  to  the  massive  investments  made  by  large  cloud 
providers into cloud, edge, and AI capacities. There are a number of EU funding instruments 
and  programmes  that  already  support  private  investments  in  R&I  in  relation  to  the 
communications  sector.  These  include  the  Smart  Networks  and  Services  Joint  Undertaking 
(SNS JU) under Horizon Europe, but also InvestEU, the Digital Europe Programme (DEP), and 
the Connecting Europe Facility (CEF) Digital.  

The SNS JU is the current EU platform for R&I funding towards 6G systems in cooperation 
between industry and public actors. One of its main objectives is to leverage the EU’s strength 
in  network  supply  towards  the  broader  value  chain  including  cloud  and  software  as  well  as 
devices  and  components.  The  SNS  JU  already  addresses  several  industry-led  R&I  needs 
(mostly in anticipation of 6G): research on concepts, architectures and core components of 6G 
systems, large-scale trials and pilots, standardisation, virtualisation of networks, cloud software, 
as  well  as  AI-enabled  radio  access  networks.  This  current  scope  is,  however,  too  narrow  to 

66   Commission  study  on  5G  Supply  Market  Trends,  August  2021,  available  at  https://digital-

strategy.ec.europa.eu/en/library/commission-publishes-study-future-5g-supply-ecosystem-europe. 

67   Regulation (EU) 2023/1781 of the European Parliament and of the Council of 13 September 2023 establishing 
a framework of measures for strengthening Europe’s semiconductor ecosystem and amending Regulation (EU) 
2021/694 (Chips Act) (Text with EEA relevance), OJ L 229, 18.9.2023, p. 1–53.  

21 

 
 
 
 
 
address the challenges identified. Moreover, the existing budget of EUR 900 million for 2021-
2027  is  focused  on  R&I  activities.  This  represents  a  small  amount  in  the  face  of  those 
challenges, compared to what would be required to catalyse the next generation connectivity 
ecosystem covering the entire computing continuum. 

In  December  2023,  the  Commission  approved  up  to  EUR  1.2  billion  of  State  aid  by  seven 
Member  States  for  an  Important  Project  of  Common  European  Interest  (IPCEI)  in  Next 
Generation  Cloud  Infrastructure  and  Services  (IPCEI  CIS),  which  is  expected  to  unlock 
additional  EUR  1.4  billion  in  private  investments68.  Already  in  June  2023,  the  Commission 
approved another IPCEI to support research, innovation and the first industrial deployment of 
microelectronics  and  communication  technologies  across  the  value  chain  (IPCEI  ME/CT), 
involving 14 Member States, counting with EUR 8.1 billion in public funding, unlocking EUR 
13.7  billion  in  private  investments.  Leading  chip  suppliers  and  network  equipment  vendors 
participate, to develop advanced chips for electronic communications networks.  

3.1.2.  Way forward  

To ensure a more efficient use of resources, the EU needs to establish a coordinated approach 
to the development of integrated connectivity and computing infrastructures, making sure that 
today’s connectivity providers become tomorrow’s providers of collaborative connectivity and 
computing,  capable  of  orchestrating  the  different  computing  elements  that  this  ecosystem 
requires. To do so it is not only necessary to develop a synergetic ecosystem between actors in 
the  different  sectors,  but  also  to  rethink  the  interplay  and  synergies  that  can  be  established 
between existing EU funding programmes. This is necessary in order to maximise the impact 
of  R&I  in  communications  and  computing  networks,  but  also  capacity  building  and  pre-
deployment,  especially  given  the  convergence  of  technologies  and  services  (cloud-edge 
continuum, AI, connectivity). These programmes could be built around the overall objectives 
of improving the EU’s industrial capacities, of contributing to a secure and resilient connectivity 
and  computing  infrastructure,  and  of  bolstering  Europe’s  competitiveness.  Ultimately,  this 
could provide the environment for future networks and applications being developed, tested, 
deployed, and integrated in the EU. 

A  key  step  towards  the  3C  Network  could  be  taken  by  proposing  for  consideration  in 
forthcoming work programmes a number of large-scale pilots that set up end-to-end integrated 
infrastructures  and  platforms  and  bring  together  players  from  different  segments  of  the 
connectivity value chain and beyond. These could be considered for funding under the Horizon 
Europe programme or its successors. 

If  pursued,  these  pilot  infrastructures  would  be  used  to  test  innovative  technologies  and 
applications (including demos, proof of concepts and early deployment of technologies). They 
could  be  attached,  where  appropriate,  to  the  European  network  of  competence  centres  in 
semiconductors, which are maximising synergies with the European Digital Innovation Hubs. 
Initial pilots could focus on 5G corridors, e-health and smart communities. These initial, up to 
three large-scale pilots would not only promote exchanges between players from the traditional 
electronic communications value chain and players along the broader computing continuum, 
but also with non-digital sectors, ensuring emphasis on concrete applications. The integrated 
infrastructures and platforms would bring together not just the key technologies from startups 
to large businesses but also researchers and attract talent to develop knowledge and skills.  

68   https://ec.europa.eu/commission/presscorner/detail/en/ip_23_6246. 

22 

 
 
 
 
 
Europe  can  build  again  on  existing  initiatives  to  scale  up  innovative  technologies  and 
applications. One example is the development of 5G corridors, funded under the CEF Digital 
programme,  where  the  corridors  can  be  used  for  testing  and  piloting  new  technologies  and 
applications, in particular connected and autonomous driving but also advanced logistics and 
IoT applications. Another example is the smart communities, where pilot architectures could 
be used to  trial  AI systems  and applications funded under the EU’s AI flagship, in  order to 
maximise synergies and ensure that computing at the edge serves as a fuelling station for AI-
powered algorithms. As well as urban agglomerations, a smart communities pilot could account 
for specific challenges of rural surroundings, so that any solutions are ‘rural ready’. 

To  succeed,  Europe  must  mobilise  all  the  relevant  actors  into  a  collaborative  computing 
ecosystem. As well as the 6G Industry Association, the key private sector partners in the SNS 
JU,  the  European  Alliance  for  Industrial  Data,  Edge  and  Cloud  (the  Cloud  Alliance)  brings 
together actors in the cloud and edge environment. Concretely in the next few years, the SNS 
JU could coordinate the creation of immediate synergies with relevant programmes and IPCEIs. 
Following the publication of this White Paper, the Commission will shortly start developing 
with stakeholders the specifications of this task, building notably on the ongoing work to further 
develop  and  deploy  European  Telco  Edge  Cloud  capacities,  as  envisaged  by  the  Industrial 
Technology Roadmap developed by the Cloud Alliance.  

The existing IPCEIs, in particular in the area of microelectronics and connectivity as well as 
next  generation  cloud  infrastructure  and  services,  could  be  used  to  structure  innovation  and 
accelerate market take-up. In October 2023, the Commission launched a Joint European Forum 
for Important Projects of Common European Interest (JEF-IPCEI) to focus on identifying and 
prioritising strategic technologies for the EU economy  that could  be  relevant  candidates for 
future  IPCEIs.  As part of the JEF-IPCEI, and drawing  from  the experience under the Chips 
Joint  Undertaking  (Chips  JU),  CEF2,  DEP,  and  relevant  national  and  regional  funds,  the 
possibility of supplementing these measures with a new IPCEI to tackle the need for large scale 
infrastructure deployment together with the exploration of integration of additional target areas 
along the computing continuum such as chips in order to respond adequately to the massive 
future compute demands of artificial intelligence could be discussed. 

In addition, the Strategic Technologies for Europe Platform (STEP) will boost investments in 
critical technologies in Europe including deep and digital technologies. STEP also introduces 
the Sovereignty seal – the EU quality label for sovereignty projects. 

In the longer term, to further leverage EU technology capacities, it would need to be determined 
whether and how related areas that are crucial for future networks  could be brought under a 
single cooperative governance. The appropriate mix of budget sources at Union, national and 
industry levels would also need to be determined, including the role of different possible EU 
programmes.  Inspiration  could  be  taken  from  the  examples  of  the  recent  AI  innovation 
package69  and  the  Chips  Act,  which  extended  the  mandates  of  respective  current  Joint 
Undertakings on European High Performance Computing and Chips (EuroHPC JU and Chips 
JU). Future research priorities could include security solutions in critical hardware and software 
modules, interoperability and federation between edge and cloud infrastructures supported by 
open-source activities, diversified supply chains for products, components, and materials, while 
strengthening know-how in the EU, and sustainability solutions covering various aspects of the 

69 COM/2024/28 final. 

23 

 
 
 
 
 
networking  domain  (“Sustainable  6G”)  and  a  variety  of  the  vertical  industries,  such  as 
manufacturing, transport, energy, and agriculture (i.e. “6G for sustainability”). 

Increased and better aligned R&I activities that are embedded into an industrial strategy could 
strengthen Europe’s technology capacity, create synergies, ensure coherence, and leverage the 
multiplier  effect  of  EU  actions  for  private  investments.  It  could  also  provide  the  means  of 
ensuring the EU’s security and resilience in this domain as well as improve cooperation among 
European players in an ecosystem that spans the whole computing continuum, supporting them 
to  compete  on  an  equal  footing  with  global  competitors.  The  goal  would  be  to  ensure  the 
availability of European solutions able to establish a single entry point for EU funding across 
the whole continuum from radio frequency to chips to software to algorithms to edge and cloud 
compute capacity, so that Networks-as-a-Service are not an end in themselves but an enabler 
of orchestration, fuelling actual services and applications ‘made in Europe’. 

3.1.3.  Summary of possible scenarios 

•  Scenario 1: The Commission may consider proposing large-scale pilots that set up end-
to-end integrated infrastructures and platforms for telco cloud and edge. In a second 
step  these  pilot  infrastructures  would  be  used  to  orchestrate  the  development  of 
innovative technologies and AI applications for various use cases. 

•  Scenario 2: The possibility of following-up the accomplishments of IPCEI CIS by a new 
infrastructure-focussed IPCEI could be discussed by the Commission’s Joint European 
Forum  for  Important  Projects  of  Common  European  Interest  (JEF-IPCEI),  which  is 
tasked with identifying and prioritising strategic technologies for the EU economy that 
could be relevant candidates for future IPCEIs. 

•  Scenario 3: Massive investments in connectivity capacity are required to support the 
creation of a collaborative connectivity and computing ecosystem. The Commission may 
consider  different  options  in  order  to  frame  these  investments  into  a  simplified  and 
coordinated support framework for a truly digital single market drawing on European 
and national, public and private investments.  

o  This  should  streamline  procedures  and  improve  synergies  between  existing 
instruments and programmes (including based on the experience with the Chips 
Joint  Undertaking,  Important  Projects  of  Common  European  Interest,  the 
Connecting  Europe  Facility  and  the  Digital  Europe  Programme),  possibly 
tasking as a pilot under the current Multiannual Financial Framework the Smart 
Networks  and  Services  Joint  Undertaking  (SNS  JU)  to  adopt  a  more 
coordinating  role,  and  by  liaising  with  stakeholders  such  as  the  European 
Alliance for Industrial Data, Edge and Cloud as appropriate). 

o  This  should  explore  means  to  ensure  strengthening  coherence,  simplification 
and  clarity  of  future  support  action,  without  prejudice  to  institutional 
programme  design  and  budget  allocation  prerogatives  under  the  next 
Multiannual Financial Framework. 

24 

 
 
 
 
3.2. Pillar II: Completing the Digital Single Market 

3.2.1.  Objectives  

One  of  the  main  objectives  of  the  Code  is  to  promote  connectivity  by  putting  in  place  a 
regulatory framework conducive to more investment in very high-capacity networks. With this 
objective in mind, a number of legal provisions in the area of access regulation and spectrum 
management were designed to facilitate investment, and to  cut red tape.  However, despite a 
number of new provisions introduced in the Code, the results have not been satisfactory (e.g. 
joint authorisation process to grant individual rights of use for radio spectrum, co-investment 
and wholesale only provisions had not been much used in practice). This is due not only to the 
delayed  transposition  by  several  Member  States,  but  also  because  of  the  complexity  of  the 
framework and its procedures.  

While reinforcing investment objectives, the Code also aims at promoting competition (both at 
infrastructure  as  well  as  at  services  level),  contributing  to  the  development  of  the  internal 
market and promoting end-user benefits. The assumption is that competition drives investment 
based on market demand and is beneficial to consumers and businesses. All these principles 
remain  valid  but  in  addition  due  to  recent  technological  developments  and  new  global 
challenges,  it  should  be  considered  whether  incorporating  wider  dimensions  such  as 
sustainability,  industrial  competitiveness,  and  economic  security  into  the  policy  framework, 
would be appropriate.  

Whatever  measures  might  be  taken  in  the  future  to  address  said  new  challenges,  end-users’ 
protection, including consumers, will continue to carry important weight among the objectives. 
Ultimately, the stable bedrock of any future regulation should be the “European Declaration on 
Digital Rights and Principles for the Digital Decade” of 15 December 2022, according to which 
people are at the centre of the digital transformation in the European Union and all businesses, 
including SMEs, should benefit from it.  

3.2.2.  Scope of application 

In light of the developments described above (see section 2.3.4), and in  particular the quick 
progressing  of  convergence  between  electronic  communications  networks  and  cloud,  a 
rethinking of the scope of application of the electronic communications regulatory framework 
could be considered. Currently, an end-user sends or receives data that “travel” via different 
networks or network segments (ranging e.g. from submarine cables to local access networks) 
and that are subject to different applicable rules. It is difficult to justify the rationale for such 
difference in the applicable rules (for instance, as regards lawful interception). 

At the same time, the recent technological changes create an opportunity for alignment of the 
operations  of  electronic  communications  and  cloud  services  with  the  development  of  pan-
European core network operators. For example, the cloudification of 5G networks can provide 
significant  benefits  to  the  electronic  communications  network  providers  and  allow  them  to 
leverage  the  same  economies  of  scale  of  cloud  providers  by,  inter  alia,  unifying  the  core 
network  functionality  of  several  national  electronic  communications  networks  in  the  cloud. 
However,  when  it  comes  to  electronic  communications  networks,  this  integration  of 
functionalities  in  centralised  cloud  data  centres  that  provide  cross-border  core  network 
functionalities currently faces several legal barriers due to non-harmonised legal frameworks 
in the Member States, inter alia, in the area of authorisation.  

25 

 
 
 
 
On the service side, a consistent provision of NaaS-based applications relying on standalone 
5G  core  networks,  network  slicing,  and  spectrum  resources  available  across  Member  States 
could provide a new business case for cross-border operations. 

On  the  network  side,  it  is  to  be  recalled  that  -  in  contrast  to  voice  traffic  (which  is  billed 
according to the "calling party's network pays" principle) - IP interconnection currently appears 
to rely on transit and peering agreements usually based on a “bill-and-keep” approach where 
the  Internet  Service  Provider  (ISP)  does  not  receive  payments  at  the  wholesale  level  for 
terminating  traffic.  According  to  the  model  generally  attributed  to  the  IP  interconnection 
market, the ISP normally recovers its costs at the retail level by selling internet connectivity to 
its end-users, who generate internet traffic when retrieving data/content offered by CAPs. For 
supplementary  paid  peering  and  for  transit,  typically  payment  is  made  on  the  basis  of  the 
capacity provided at the point of interconnection. The main recent changes in the overall global 
architecture of the internet and of interconnection are caused and driven by the expansion of 
own  backbone  and  delivery  infrastructures  by  the  CAPs.  This  has  shifted  the  relation  of 
interconnection  in  the  form  of  transit  and  peering70,  with  “on-net”  exchange  now 
predominating71,  with  the  CDNs'  dedicated  local  storage  servers  (cache  servers)  collocated 
directly in the ISPs' networks. This leads to a very direct and cooperative interaction between 
CAPs and ISPs as they have to agree on technical and commercial conditions for transit and 
peering bilaterally (e.g. on the locations of traffic handover, the level of transit prices, on the 
question of settlement-free or paid peering or on quality and efficiency aspects).  

There are very few known cases of intervention (by a regulatory authority or by a court) into 
the contractual relationships between market actors72, that generally functions well and so do 
the markets for transit and peering. There has been nonetheless a vivid debate on this topic73. 
Moreover, it cannot be excluded that the number of cases in the future will increase. Should 
this be the case, subject to careful assessment, policy measures could be envisaged to ensure 
swift resolution of disputes. For example, the commercial negotiations and agreements could 
possibly  be  further  facilitated  by  providing  for  a  specific  timeline  and  by  considering  the 
possibility  for  requests  for  dispute  resolution  mechanisms,  in  case  commercial  agreements 
could not be found within a reasonable period of time. In such case, NRAs or (in cases with a 
cross-border  dimension)  BEREC  could  be  solicited,  as  they  have  the  necessary  technical 
knowledge, and important experience in dispute resolution and in assessing market functioning. 

3.2.3.  Authorisation 

The general authorisation regime established in 2002 and maintained in the Code replaced the 
previous regime of individual licenses/authorisations, by pre-establishing generally applicable 
conditions for the provision of electronic communication networks and services (ECNS). Yet, 
given the local character of the physical networks, and the fact that spectrum is deemed to be a 

70   See e.g. WIK-consult: Final study report “Competitive conditions on transit and peering markets”, Bad Honnef, 

28.02.2022. 

71   Only a  few  ISPs do not allow on-net data  exchange, continuing instead to exchange  traffic across network 

boundaries and point of interconnection. 

72   For an overview of known cases see WIK-consult: Final study report “Competitive conditions on transit and 

peering markets”, Bad Honnef, 28.02.2022. 

73   For an overview of the various arguments raised in this debate, see e.g. also the responses to the relevant section 
the  exploratory  consultation  available  at  https://digital-strategy.ec.europa.eu/en/news/consultation-

of 
electronic-communications-highlights-need-reliable-and-resilient-connectivity. 

26 

 
 
 
 
 
national resource (see section 3.2.5), authorisations are subject to conditions established by the 
Member States’ competent authorities and granted and implemented at national level.  

Nonetheless, due to cloudification and softwarisation, network provision is less and less linked 
to location. Furthermore, coverage of wireless networks, such as satellite networks, can extend 
beyond national – and even EU – borders. While there are still clear benefits in keeping the 
implementation  of  authorisation  regimes  at  national  level,  in  particular  for  local  access  and 
retail services, assigning radio spectrum under conditions which differ between Member States 
may not always be the most efficient approach, in particular for satellite communications. There 
could therefore be an economic and technical justification for a more European approach.  

One of the elements explaining the fast development of information society services has been 
the fact that they could be provided to the entire EU simply by complying with the legislation 
of the Member State of establishment (‘so called ‘country of origin’ principle), without the need 
to  comply with  the legislation  of each Member  State in  which services  are provided. While 
network virtualisation may technically allow the provision of cross-border core networks and 
create  a  market  for  core  network  services,  the  business  case  cannot  develop  if  there  is 
insufficient scale, or if different regulatory regimes hinder such business case. To develop the 
business case, setting out a single set of rules by enabling authorisation based on the ‘country 
of origin’ principle for providers of core networks and core network services could balance the 
approach to all types of providers of digital networks and services, putting them on a more equal 
level. In the converging ecosystem, where a boundary between the “traditional” providers of 
digital networks and services on the one hand and the providers of e.g. cloud services on the 
other hand becomes increasingly blurred, the regulatory treatment of those services should be 
more  holistic.  It  could  also  lessen  the  administrative  burden  by  bringing  in  potential 
rationalisation of reporting obligations of different actors. 

The application of a single set of rules based for instance on a ‘country of origin’ principle for 
core networks and core network services would enable EU core network operators to leverage 
the full potential of the internal market to reach critical size, take advantage of scale economies, 
and  reduce  capital  expenditure  and  operating  costs,  thus  solidifying  their  financial  position, 
attracting more private investments and ultimately contributing to EU competitiveness. In this 
scenario, the applicable legislation and the competent authority to regulate access to networks 
and retail services provided to end-users would remain the same and the one closest to the end-
users, i.e. those of the Member State of the provision of the access network and of the retail 
service. This would also ensure that the specificities of local markets are adequately taken into 
account when defining appropriate access remedies and when guaranteeing the highest level of 
protection of end-users.  

3.2.4.  Addressing barriers to core network centralisation  

In  addition  to  the  sector-specific  regulatory  barriers  mentioned  above,  contributors  to  the 
exploratory consultation listed other regulatory barriers to the establishment of a true Digital 
Single  Market  such  as  different  obligations  across  the  EU  with  regard  to  network/service 
incident  reporting  or  security  vetting  requirements,  building  lawful  interception  capabilities, 
data  retention  regimes,  privacy  and  reshoring  requirements  or  cybersecurity  and  reporting 
obligations74.  

74   The results of the exploratory consultation were published in October 2023 and are available at https://digital-

strategy.ec.europa.eu/en/news/consultation-electronic-communications-highlights-need-reliable-and-
resilient-connectivity. For this specific point see page 12 under point ii. Obstacles to the Digital Single Market. 

27 

 
 
 
 
 
Having  due  regard  to  Member  States’  sovereignty  as  well  as  their  competence  on  security 
issues, it  is  worth  reflecting  on  whether and how those other barriers  could  be  addressed  to 
allow achieving scale and enhance innovation. For example, in relation to security incidents or 
security  vetting  to  further  improve  harmonisation  and  a  high  level  of  security,  different 
measures  could be envisaged, such as introducing  close cooperation between those Member 
States where a core network spans, guaranteeing core network operators the right to request all 
competent authorities of the Member States in which they provide networks to agree on a set 
of  conditions  and  requirements  to  be  consistently  applied  throughout  the  network  and  be 
verified at a one stop shop; defining security requirements for core network operators through 
EU level guidance etc. As regards law enforcement obligations such as lawful interception, one 
option could be that core network operators identify in each Member State where they operate 
a point of contact for competent national law enforcement authorities. Soft law measures, such 
as  an  EU  recommendation  or  guidelines,  could  help  identify  and  specify  such  solutions  on 
security and law enforcement.  

3.2.5.  Radio spectrum 

Spectrum  plays  a  pivotal  role  in  wireless  connectivity  and  should  be  managed  in  the  best 
coordinated way possible among all Member States to fulfil the Union objectives of sustainable 
development,  balanced  economic  growth,  economic,  social  and  territorial  cohesion,  and 
solidarity  among  Member  States.  Earlier  attempts  to  establish  greater  EU  coordination  in 
spectrum management were not fully successful, and, in parallel, discrepancies and delays have 
been  observed  in  authorising  spectrum  for  5G  deployment  across  the  Member  States.  As  a 
consequence, today Europe is lagging behind its international competitors on the uptake of 5G. 
The observations in Section 2 indicate that there is scope to further improve spectrum policy 
across the EU and make spectrum management fit for the Digital Decade needs and targets.  

3.2.5.1. Adapting  spectrum  management  to  Digital  Decade  needs:  lessons 

learned from earlier legislative efforts 

A  number  of  proposals  by  the  European  Commission  to  better  harmonise  the  release  and 
licensing of radio spectrum for mobile services have faced considerable resistance in the past 
10 years. In view of the delays, fragmentation and in certain instances artificial scarcity that led 
to  very  high  prices  paid  for  spectrum,  it  is  worth  considering  whether  solutions  that  were 
proposed in earlier legislative efforts, but eventually not retained by the co-legislators, could 
have  avoided  some  of  the  negative  effects  that  are  now  evident  given  the  delayed  5G 
deployment. Considering the necessity to complete 5G roll-out and timely 6G deployment, a 
more cooperative approach between the national and European level is of vital importance for 
EU competitiveness. In this context, areas that deserve to be considered and possibly lead to 
relevant actions include: (i) EU level planning of sufficient spectrum for future use cases, (ii) 
strengthening  EU  level  coordination  of  auction  timing,  and  (iii)  considering  more  uniform 
spectrum authorisation landscape.  

No wireless service can be deployed without the availability of sufficient spectrum resources. 
This would include evolving and new areas such as vertical use cases, 6G, IoT applications, 
WiFi,  local  spectrum  use.  Also,  this  includes  rapidly  developing  satellite  communications, 
ensuring secure government and commercial applications, including direct-to-device satellite 
connectivity,  using  spectrum  allocated  for  mobile  satellite  and,  if  appropriate,  terrestrial 
services.  In  this  context  it  should  be  considered  whether,  to  ensure  that  new  technology 
advancements are rolled out across the EU at the same time, an EU spectrum roadmap towards 
6G should be enshrined in the law and enforced in a coordinated way by all Member States. 

28 

 
 
 
 
Coordinated  release  and  refarming  would  be  crucial  in  this  context.  Key  example  is  the 
coordinated switch-off of 2G and 3G networks (with release of the relevant spectrum for other 
uses)  while,  in  parallel,  implementing  solutions  for  continuous  support  of  important  legacy 
services such as emergency and critical communications (e.g. eCall75).  

At  the  same  time,  efficiency  in  spectrum  use  should  be  further  enhanced  to  meet  the  fast 
growing  needs  of  existing  and  future  wireless  applications.  For  example,  stricter  conditions 
attached  to  spectrum  usage  rights  could  be  considered,  where  appropriate,  including  the 
principle of ‘use it or lose it’ so as to avoid the creation of barriers to market entry and inefficient 
allocation of scarce resources. Efficiency could also be achieved whenever possible through 
shared and flexible use of spectrum with innovative and dynamic solutions or new forms of 
licensing and methods using, for example, databases and licensed-shared access, geolocation 
and  artificial  intelligence.  Parallel  to  enabling  new  services,  spectrum  efficiency  can 
significantly  enhance  consumer  experience,  quality  of  service,  competitiveness,  and 
environmental sustainability. At the same time the needs of end-users, such as persons with 
disabilities  who  rely  on  assistive  technologies  that  require  adequate  and  stable  spectrum 
availability, should be taken into account. 

Moreover,  looking  at  the  deployment  of  the  next  wireless  communications  technologies  or 
renewal of existing licenses for broadband wireless communications, Europe cannot afford yet 
another spectrum authorisation process  for the next  generation mobile technology spreading 
over almost a decade, with huge disparities in timelines of auctions and network infrastructure 
deployment between Member States. To avoid that the same problems appear in the future, it 
should be considered how to better coordinate timing of auctions and ensure it is tighter across 
the whole EU.  

The  single  market  could  benefit  from  better  coordinated  spectrum  authorisation  and  usage 
conditions and rights including their appropriate duration to promote efficient investment across 
the  whole  EU.  In  this  context,  to  date,  the  voluntary  spectrum  authorisation  peer  review 
mechanism that was adopted under the Code has not proven to be effective. Therefore, as an 
alternative, a notification mechanism similar to that used for market analysis as implemented 
under Article 32 of the Code could be considered to reinforce the coordination of authorisation 
procedures and conditions regarding the use of spectrum in the internal market. 

3.2.5.2. New challenges in spectrum management 

In the context of the reflection on core networks (discussed in 3.2.4), it is worth exploring the 
possibility, on the spectrum management side, for operators of EU core networks and pluri-
national operators to request competent authorities to seek better aligned national authorisation 
processes  and  conditions  so  as  to  increase  their  communications  capacities.  This  could 
primarily  apply  with  regard  to  the  existing  spectrum  usage  rights  or  general  authorisations, 
notably with regard, in particular, to the duration of licenses, spectrum usage conditions, such 
as quality of service objectives/obligations in the context of the 2030 connectivity targets, as 
well as the possibility to integrate satellite and terrestrial networks into new hybrid networks. 
These  could  be  aligned  to  allow  pan-EU  or  plurinational  operators  to  operate  in  a  more 
harmonised environment across borders. Such alignment could increase efficiency and ensure 

75   Regulation (EU) 2015/758 of the European Parliament and of the Council of 29 April 2015 concerning type-
approval  requirements  for  the  deployment  of  the  eCall  in-vehicle  system  based  on  the  112  service  and 
amending Directive 2007/46/EC, OJ L 123, 19.5.2015, p. 77–89. 

29 

 
 
 
 
 
legal certainty for operators of EU core networks and pluri-national operators, while respecting 
the rights already granted.  

In addition, in particular the fast development of the satellite sector and its cross-border nature 
invite  new  reflections  regarding  enhanced  or  common  licensing  regimes  (even  EU-level 
selection  and  authorisation,  if  appropriate),  to  promote  the  emergence  of  cross-border  or 
genuine  pan-EU  operators,  while  leaving  spectrum  revenues  to  the  Member  States.  Such 
approach  would  complement  the  upcoming  proposal  for  a  Union  legislative  act  for  safe, 
resilient  and  sustainable  space  activities  in  the  Union  (EU  Space  Law)  laying  down  the 
foundation  for  safe,  resilient  and  sustainable  space  activities,  and  aiming  at  achieving 
consistency for all operators of space infrastructure.  

Spectrum  efficiency  and  investment  incentives  should  be  considered  a  priority,  subject  to 
competition considerations, in market shaping measures for example as regards reservation for 
new entrants or spectrum caps and overall design of auction processes. In this respect, it should 
be noted that, while auction prices for 3G and 4G were even higher, 5G auctions implemented 
in  Europe  between  2015  and  2023  still  raised  around  EUR  26  billion76,  not  to  mention  the 
administrative charges due to national authorities for spectrum management. This amount was 
paid by operators, in addition to the investments necessary for the deployment of the network 
infrastructure.  The  consequence  thereof  (particularly  in  cases  of  artificial  increase  of  the 
spectrum price without adequate market justification) has been roll-out delays and suboptimal 
network quality and performance to the detriment of consumers and businesses. To help bridge 
the significant investment gap in the deployment of advanced communications networks, the 
financial  burden  could  be  alleviated  by  adopting  bidding  processes  geared  towards 
infrastructure investments. 

Considering the potentially enlarged scope of the tasks that will need to be developed at EU 
level regarding radio spectrum, in particular with regard to coordinated, harmonised or common 
selections or authorisations,  a more integrated spectrum governance mechanism at  EU level 
should be considered. 

From an international perspective, a more coherent spectrum management approach should be 
developed to ensure the EU’s digital sovereignty and to defend EU interests externally. In this 
regard, the EU should retain full control over EU spectrum usage decisions especially when 
confronted  with  geopolitical  and  security  challenges  to  guarantee  the  cybersecurity, 
independence and integrity of EU communications networks. This includes, in particular, the 
preparation of technical harmonisation measures for the use of spectrum in the Union77 and of 
international negotiations such as World Radiocommunication Conferences. Member States, if 
appropriate at Council level, should be able to take positions regarding spectrum management 
in full independence from non-EU actors. This means reconsidering the role of the European 
Conference  of  Postal  and  Telecommunications  Administrations  (CEPT)  in  EU  decision 
making, given the representation of non-EU Member States in this international body. Going 
forward, while continuing to rely on the technical expertise of CEPT, the Commission could be 

76   More  than  EUR  109  bn  for  3G  and  more  than  EUR  40bn  for  4G.  ETNO,  2024  State  of  the  Digital 

Communication Report. 

77   Under  the  676/2002/EC  Radio  Spectrum  Decision,  with  a view  to  the  adoption  of  technical  harmonisation 
measures to ensure the availability and efficient use of radio spectrum, the Commission is cooperating with the 
CEPT  gathering  experts  from  national  authorities  responsible  for  radio  spectrum  management  from  46 
European countries, including the 27 EU Member States.  

30 

 
 
 
 
 
assisted by an ad hoc group composed solely of the Member States’ representatives whenever 
issues linked to EU sovereignty might be at stake.  

EU  and  Member  States’  interests  should  also  be  defended  at  the  EU  external  borders  and 
globally through common actions adopted by all Member States and the EU in full spirit of 
solidarity. Harmful radio interference affecting Member States and originating in third countries 
should therefore be addressed through strong and efficient action not only by the Commission 
but  also,  by  all  Member  States  acting  jointly  in  support  of  bilateral  negotiations  and  in 
multilateral  negotiations  with  third  countries  including  in  international  fora  such  as  the 
International Telecommunication Union.  

Better alignment of existing and future spectrum usage rights, clarity in the policy orientations 
for the coming decade and more certainty in spectrum management throughout the Union could 
promote  investments  and  boost  EU  competitiveness  and  scale,  eliminate  remaining  barriers 
caused  by  the  fragmentation  induced  by  national  practices.  In  turn,  this  would  promote  the 
internal  market  of  converging  high-speed  wireless  broadband 
development  of 
communications and enable planning and provision of integrated multi-territorial networks and 
services and economies of scale, thereby fostering innovation, economic growth and the long-
term benefit of end users. 

the 

3.2.6.  Copper switch-off  

The migration from legacy copper to newly deployed fibre networks is a key process to facilitate 
the  transition  towards  the  new  connectivity  ecosystem  and  contributes  to  the  EU’s  green 
objectives78.  At  the  same  time,  it  will  promote  the  take-up  of  the  new  services  and  thus 
contribute  to  increasing  the  return  on  fibre  investment  and  support  the  achievement  of  the 
Digital Decade target whereby, by 2030, all end users at a fixed location should be covered by 
a gigabit network up to the network termination point79.  

While the decommissioning of copper networks has the potential to decrease the OPEX costs 
for operators providing at the same time a more sustainable infrastructure due to lower energy 
consumption, the process requires coordination of all stakeholders.  Predictable and balanced 
measures  are  necessary  to  avoid  the  migration  reversing  competitive  gains,  including 
competitive infrastructure roll-out, under the current regulatory regime. The needs of end-users, 
in  particular  vulnerable  groups  and  end-users  with  disabilities,  should  also  be  carefully 
addressed.  While  the  Code  already  contains  provisions  on  migration  processes  and  the  new 
Gigabit  Recommendation80  aims  at  providing  updated  guidance  to  regulators,  a  clear  path 
towards migration would send a strong signal to the sector further incentivizing investment.  

The copper switch-off process requires close monitoring. NRAs should ensure that the design 
of the switch-off process by the operator with significant market power (SMP), in particular as 

78   Currently,  the  process  of  copper  switch-off  varies  considerably  in  the  EU.  By  2023  the  leading  fixed  line 
operators had announced plans for switching off their copper network in 16 Member States (BE, EE, EL, ES, 
FI, FR, HU, IE, IT, LU, MT, PL, PT, SE, SI, SK), while actual decommissioning has already commenced in 
10 Member States (BE, EE, ES, FI, LU, MT, PL, PT, SE, SI). However, the progress within these Member 
States varies significantly. See also BEREC summary report on the outcomes of the internal workshop on the 
migration from legacy infrastructures to fibre-based networks, 5 Dec. 2019, BoR (19) 23.  

79   Another possible scenario is that copper networks would be at least partially replaced by fixed wireless access 
products  (based  on  5G).  Moreover,  significant  differences  in  fibre  deployment  pace  may  lead  to  smaller, 
localized markets, not allowing a truly single market to emerge. 

80   Commission Recommendation of 6.2.2024 on the regulatory promotion of gigabit connectivity, C(2024) 523 

final. 

31 

 
 
 
 
 
regards its timing and agenda, does not allow strategic behaviour that would risk weakening 
competition at wholesale or retail level. Some operators, at least initially, would not switch off 
copper  (in  particular,  if  it  is  supplemented  by  vectoring,  which  enables  higher  quality  of 
broadband  services  –  though  falling  significantly  below  VHCN  performance).  It  cannot  be 
excluded  that  some  operators  try  to  switch  over  customers  from  copper  to  fibre  via  lock-in 
strategies  that  would  undermine  the  business  case  of  FTTH  alternative  operators.  Operators 
would  lower  FTTH  wholesale  prices  in  view  of  competing  FTTH  entry  in  order  to  keep 
wholesale customers. Therefore, the regulatory incentives for the switch-off, in particular on 
temporary  copper  price  increase  during  the  switch-off  phase  as  proposed  in  the  Gigabit 
Recommendation,  should  be  accompanied  by  sufficient  safeguards  to  preserve  competition 
(similar  to  those  provisionally  agreed  under  the  Gigabit  Infrastructure  Act81  (GIA)  and 
described  in  next  section).  Furthermore,  lighter  access  regulation  on  very  high-capacity 
networks could be imposed by applying pricing flexibility, subject to safeguard mechanisms as 
provided in the new Gigabit Recommendation.  

In light of the above, setting a recommended date for achieving the copper switch-off would 
provide for planning certainty throughout the Union and would offer end-users opportunities of 
fibre  connections  under  similar  timeframes.  Considering  the  national  circumstances  and  the 
connectivity  targets  set  in  the  Digital  Decade,  achieving  a  copper  switch-off  for  80% 
subscribers in the EU by 2028 and the remaining 20% by 2030 seems appropriate. Such a clear 
roadmap for copper switch-off would support the 2030 connectivity targets and send a strong 
signal for investors that there is a clear path towards a return on investment in fibre networks.  

3.2.7.  Access policy in a full fibre environment 

The objective of liberalisation of the EU electronic communications sector was, following the 
global trends, to bring competition into a sector characterised by legal/statutory monopoly and 
to combat historical negative consequences of such monopoly (e.g. resulting inefficiency, lack 
of innovation, low quality, monopoly rents) etc. However, from its very inception, the ultimate 
goal was to limit sector specific regulation over time and - after a transition period and subject 
to competition developments - to migrate in the sector to a market-based environment subject 
only to competition rules.  

Ex-ante regulatory intervention has been broadly successful in lifting barriers to competition in 
the national market for fixed legacy networks. The emergence of competition after regulatory 
intervention made it possible to reduce the number of markets that national regulators need to 
assess  ex-ante  from  18  to  2  between  2003  and  202082.  As  the  markets  subject  to  ex-ante 
regulation and the number of operators designated as having SMP have diminished83 in view 
of the progressing deployment of competing network infrastructures, it is right time to explore 
the possibility of not  recommending  at  the EU level  any market  for ex-ante regulation.  The 
possibility of leaving electronic communications networks to ex-post control alone could have 
merit in certain circumstances, as we observe infrastructure competition developing notably in 
many  densely  populated  areas  where  end  customers  benefit  from  a  variety  of  competing 

81   https://ec.europa.eu/commission/presscorner/detail/en/ip_24_669. 
82   Commission Recommendation (EU) 2020/2245 of 18 December 2020 on relevant product and service markets 
within the electronic communications sector susceptible to ex ante regulation in accordance with the Code (the 
2020 Recommendation on Relevant Markets, OJ L 439, 29.12.2020, p. 23-31. 

83   In the key “bottleneck” market for wholesale local access, in Bulgaria, Romania, the Netherlands the regulation 
was phased out due to the existing competition. In Czechia, Denmark,  Hungary and Poland the markets are 
partly deregulated. In Austria, no operator is designated as having SMP  and wholesale access products are 
provided based on commercial terms.  

32 

 
 
 
 
 
services based on at least two independent fixed broadband networks (e.g. coaxial cable and 
fibre). 

Despite this progress, some barriers still persist (and may continue to persist in the near future) 
in some geographical areas (in particular rural/remote), and the need for ex ante intervention in 
such  cases  remains.  However,  with  the  objective  to  foster  the  progressive  deployment  of 
alternative  fibre  networks  and  with  legacy  networks  of  former  incumbents  to  be  ultimately 
replaced by Gigabit networks, the Commission and the NRAs will need to further adjust their 
intervention to keep pace with the market evolution and ensure investment incentives which are 
currently reduced by the perspective of overbuilding. In particular, NRAs should monitor the 
degree  of  infrastructure  competition,  potentially  defining  separate  geographic  markets  and 
limiting  ex  ante  regulation  to  the  areas  where  it  is  still  needed  or  applying  differentiated 
remedies, ensuring their appropriateness and proportionality84. 

To foster pan-European network roll out, the development of a more EU-level access regulation 
toolkit  could  be  envisaged  to  complement  or  replace,  when  necessary,  the  national/local 
approach. Indeed, in a full-fibre environment, access products can be provided more centrally 
and at the higher network level without altering the capacity of access seekers to compete in 
terms of the services and quality as offered to the end-users. Such EU-wide remedies already 
exist in the current framework and they have been very successful in tackling common issues 
across the EU (e.g. introduction of single Union-wide mobile termination rates or roaming). 
They led to less burdensome albeit effective regulation reducing fragmentation. A decade later 
after the first Commission proposal of harmonised access remedies85, the lack of cross-border 
provision of electronic communications products and services persists. Therefore, time appears 
ripe for considering the introduction some EU-wide access remedies. While broadband access 
networks will remain predominantly of local character (due to demand and supply patterns), 
such unified and standardised access product could in turn facilitate the further integration of 
the  single  market.  This  tool  should  support  the  emergence  of  pan-European  operators.  For 
example, the provisional agreement on the GIA introduces symmetric regulation for access to 
civil engineering assets, including specific provisions aimed at protecting the business case of 
FTTH operators (although in some cases optional for Member States to implement). Operators 
investing in new fibre networks will be able to refuse access to their (newly deployed) physical 
infrastructure  if  they  provide  wholesale  access,  such  as  dark  fibre,    fibre  unbundling,  or 
bitstream under certain conditions, suitable for the provision of very high capacity networks 
under fair and reasonable terms and conditions86. At the same time, while phasing out ex ante 
regulation to foster investment incentives for the deployment of physical fibre networks across 

84   See recital 172 of the Code. 
85   Proposal for a Regulation of the European Parliament and of the Council laying down measures concerning 
the  European  single  market  for  electronic  communications  and  to  achieve  a  Connected  Continent,  and 
amending Directives 2002/20/EC, 2002/21/EC and 2002/22/EC and Regulations (EC) No 1211/2009 and (EU) 
No 531/2012, Brussels, 11.9.2013, COM(2013) 627 final. 

86   Member  States  could  allow  network  operators  and  public  sector  bodies  to  refuse  access  to  physical 
infrastructure by offering active access, such as bitstream  as an alternative to physical access, under conditions, 
i.e. the deployment project of the requesting operator addresses the same coverage area, there is no other fibre 
network  connecting  end-user  premises  (FTTP  )  serving  this  coverage  area,  and  the  same  or  an  equivalent 
refusal  possibility  is  applied  at  the  date  of  the  entry  into  force  of  the  regulation,  in  the  Member  State  in 
accordance with national law complying with Union law. Also, networks deployed by undertakings owned or 
controlled by public sector bodies in rural or remote areas and operated on a wholesale only basis could receive 
an  extra  protection  from  competition  if  a  Member  State  allows  them  to  refuse  requests  to  coordinate  civil 
works. 

33 

 
 
 
 
 
the whole of the EU, competition can be still preserved by providing for virtual access to lower 
the barriers for  rolling out pan-European networks on a virtual basis.  

In particular, where symmetric and harmonized regulation offered by standard remedies would 
not be sufficient and market failures would still persist, a safety net allowing continued ex-ante 
local  regulation  could  be  maintained.  For  this  purpose,  the  “3  Criteria  Test”87  should  allow 
NRAs to determine (sub-national) markets where ex ante regulation is still necessary to address 
persistent market failures. In such (limited) geographic areas the SMP regulation could ensure 
that local access seekers remain in the market and prevent re-monopolisation of less densely 
populated areas or more generally in absence of competitive pressures. The limited SMP-based 
regulation  could  be  ancillary  or  replaced  to  more  general,  harmonised  symmetric  rules 
addressing  access  to  civil  engineering  infrastructure  with  safeguards  providing  investment 
certainty, e.g. in view of risk of unreasonable overbuild. 

3.2.8.  Universal service and affordability of digital infrastructure 

The availability of adequate broadband internet services, of the quality that is needed to perform 
basic tasks on-line, such as eGovernment services, social media, browsing or performing video 
calls, is ubiquitous throughout the EU. Hence, in most of the Member States, Universal Service 
obligations are focused on consumers with low income or special needs.  

However, in the future, a different kind of social exclusion may emerge, that of weaker end-
users not being able to benefit from the best available networks due to their localisation (for 
example rural/remote areas) or due to the price of services. It is important to ensure that this 
does not lead to a social digital divide, and that all end-users may reap the benefits of very-high 
speed connectivity. It is hence important to ensure that Member States take measures to support 
such end-users and ensure appropriate geographical coverage.  

The importance of ensuring Universal Service in the future has also been acknowledged by the 
European Parliament, the Council and the European Commission in the “European Declaration 
on Digital Rights and Principles for the Digital Decade”. According to its principle 3 “Everyone, 
everywhere in the EU, should have access to affordable and high-speed digital connectivity” 
and they commit to “(…) ensuring access to high-quality connectivity, with available Internet 
access, for everyone wherever in the EU, including for those with low income”.  

Sector-specific  universal  service  obligations  have  relied  on  two  modes  of  financing:  state 
financing and sector financing, the latter being the predominant form. Sector financing has so 
far been limited to electronic communications providers, while providers of NIICS have been 
excluded.   

In  addition  to  the  Universal  Service,  a  number  of  Member  States  have  tried  to  ensure  the 
affordability of networks through state financing in the form of connectivity vouchers with the 
view to boosting the take-up of high-speed offers. The latest Broadband State Aid Guidelines 
have  clarified the  conditions  under  which such  connectivity vouchers  may comply with  EU 

87   In accordance with Article 67(1) of the Code and Recital 22 of the 2020 Recommendation on Relevant Markets, 
the national regulatory authorities can also define other relevant product and service markets, not recommended 
for ex-ante regulation, if they can prove that in their national context, the markets meet the “three criteria test”. 
A market may be considered to justify the imposition of regulatory obligations if all of the following criteria 
are met: (a) high and non-transitory structural, legal or regulatory barriers to entry are present; (b)  there is a 
market structure which does not tend towards effective competition within the relevant time horizon, having 
regard to the state of infrastructure-based competition and other sources of competition behind the barriers to 
entry; (c) competition law alone is insufficient to adequately address the identified market failure(s). 

34 

 
 
 
 
 
State aid rules and the General Block Exemption Regulation now exempts from notification 
certain types. Vouchers, financed by the Member States, may be used to prevent or remedy any 
divide in access to very high -capacity networks.  

3.2.9.  Sustainability  

A focus on environmental sustainability aspects of the digital transformation of the economy 
and society is a key requirement of the Digital Decade Policy Programme. The recent COP28 
drew on EU proposals and actions in the field and launched a Green Digital Action in an effort 
to reinforce the role of digital in reaching international goals on climate change (such as on 
global  warming,  e-waste,  fossil  fuels)  with  a  key  involvement  of  the  mobile  electronic 
communications  and  satellite  industry  sectors.  These  developments  reinforce  and  give  an 
international dimension to European efforts in integrating sustainability in digital standards by 
design.  

Another important aspect is to create more awareness on the issue of sustainability in digital 
networks.  In  this  respect,  in  its  Communication  “Shaping  Europe’s  digital  future”88  the 
Commission  raised  the  possibility  of  introducing  ‘transparency  measures  for  electronic 
communications operators on their environmental footprint’ at EU level. In the EU Action Plan 
for  Digitalising  the  Energy  System89,  the  Commission  announced  that  it  will  work,  in 
consultation  with  the  scientific  community  and  stakeholders,  towards  defining  common  EU 
indicators for measuring the environmental  footprint of electronic  communications services. 
Furthermore, the Action Plan foresees the development, by 2025, of an EU Code of Conduct 
for  the  sustainability  of  electronic  communications  networks  to  help  steering  investments 
towards  sustainable  infrastructures.  Following  this  announcement,  the  Commission  in  2023 
launched a survey to collect input on sustainability indicators from stakeholders involved in the 
design,  development,  deployment  and  operation  of  telecommunications  networks  providing 
communications  services to  both  commercial  and residential  customers90. The results of the 
work on the sustainability indicators will be published in the coming weeks. 

Beyond pursuing sustainability public policy objectives, such transparency efforts could be the 
basis to create incentives to attract investments in the electronic communications sector to make 
ICT greener (‘green ICT’) and have it enable the greening of other sectors (‘ICT for green’), 
particularly where investment funds are increasingly directing capital to green and sustainable 
infrastructures. The Commission will engage with the industry to further improve the usability 
and potential scope of the EU Taxonomy for green investment in electronic communications 
networks ensuring it is based on robust and credible science-based metrics. In this regard, the 
Commission could also assess the metrics to estimate the net carbon impact of digital solutions 
in climate critical sectors such as energy, transport, construction, agriculture, smart cities and 
manufacturing, as developed by the European Green Digital Coalition91. The aim should be that 
these metrics can be used by industrial actors, procurers and financial entities to measure the 
net  gains  in  emission  reduction,  enabling  sustainable  finance  to  deploy  and  scale  digital 
solutions including the necessary digital infrastructures. 

Nonetheless,  to  ensure  success  in  achieving  sustainability  objectives,  it  is  essential  that  all 
players of the digital network ecosystem, including CAPs, cooperate towards an efficient use 

88   COM(2020) 67 final.  
89   COM(2022) 552 final. 
90   https://joint-research-centre.ec.europa.eu/scientific-activities-z/green-and-sustainable-telecom-

networks/sustainability-indicators-telecom-networks_en. 

91   See, greendigitalcoalition.eu.  

35 

 
 
 
 
 
of resources while meeting energy needs. Beyond concrete actions to reduce carbon footprint, 
these players could also contribute to increasing transparency on the emissions related to the 
usage of their services, such as codecs’ performance labels . 

3.2.10. 

Summary of possible scenarios 

•  Scenario 4: In order to address the converged electronic communications connectivity 
and services sector and to ensure that its benefits reach all end-users everywhere, the 
Commission  may  consider  broadening  the  scope  and  objectives  of  the  current 
regulatory framework to ensure a regulatory level playing field and equivalent rights 
and obligations for all actors and end-users of digital networks where appropriate to 
meet  the corresponding  regulatory objectives; given  the  likely  global  magnitude and 
impact  of  the  technological  developments  and  of  any  possible  regulatory  changes,  a 
reform of the current framework needs to be properly assessed in terms of the economic 
impact on all actors as well as debated broadly with all stakeholders;  

•  Scenario  5:  In  order  to  address  technological  and  market  developments  and  the 
resulting need to change the regulatory paradigm and ensure less burden for companies 
and more  efficient  service delivery, while continuing  to  protect  vulnerable end-users 
and promote territorial coverage, the Commission may consider: 

o  measures to accelerate copper switch-off (such as a target in 2030, aligned to 
the Digital Decade target for Gigabit connectivity, and support for copper-fibre 
switch-over from 2028); 

o  a  change  to  access  policy  in  view  of  full  fibre  environment,  by  proposing  a 
European  wholesale  access  product  and  recommending  no  markets  for 
presumptive ex ante regulation while maintaining a safety net for NRAs to keep 
regulation  if  the  “3  Criteria  Test”  is  met  (reverse  burden  of  proof).  In  the 
alternative,  only  markets  for  civil  infrastructure  might  be  considered  for 
regulation  ex  ante  (as  the  most  persistent  bottleneck),  combined  with  the 
implementation  of  lighter  access  regulation  (no  price  regulation  or  pricing 
flexibility) along the lines of the recently adopted Gigabit Recommendation.   

•  Scenario 6: In order to facilitate the single market and building scale for activities of 

all players, the Commission may consider: 

o  a  more  integrated  governance  at  Union  level  for  spectrum  that  would  allow, 
where  necessary,  for  greater  harmonisation  of  spectrum  authorisation 
processes and thereby create the conditions for market scale necessary for pan-
EU operators  to  attain larger  investment  capacity;  the Commission  may also 
consider solutions for more aligned authorisation and selection conditions, or 
even  single  selection  or  authorisation  processes,  for  terrestrial  and  satellite 
communications  and  other  innovative  applications  that  make  clear  cases  for 
fostering the development of the single market; 

o  a  more  harmonized  approach 

the  possible 
establishment  of  “country  of  origin”  principle  for  certain  activities  less 
connected to consumer retail markets and local access networks). 

to  authorisation  (through 

36 

 
 
 
 
•  Scenario  7:  The  Commission  may  consider  facilitating  greening  of  digital  networks 
through promoting the timely switch-off of copper networks and the move to a full fibre 
environment  and  a  more  efficient  use  of  networks  (codecs)  throughout  the  Union 
territory. 

3.3. Pillar III: Secure and resilient digital infrastructures for Europe 

To protect the value of the massive investments that Europe is to undertake to build the cutting-
edge infrastructure that it needs to deliver economic growth and societal benefits, it is important 
to  ensure  that  such  infrastructure  is  secure.  Given  the  threats  outlined  in  Section  2  above, 
adequate  attention  should  be  given  to  physical  security,  notably  in  relation  to  the  backbone 
infrastructure, as well as to the transmission of data from end to end of the network. 

3.3.1.  Towards  secure  communication  using  quantum  and  post-quantum 

technologies 

Advances  in  quantum  computing  come  with  implications  for  existing  encryption  methods, 
which  play  a  crucial  role  in  ensuring  end-to-end  security  in  digital  networks,  including 
electronic  communication  networks  and  the  critical  infrastructures  they  are  underpinning. 
Although quantum computers capable of breaking current encryption algorithms are not yet a 
reality, the first operational quantum computers are being deployed world-wide. Therefore, the 
EU  needs  to  anticipate  the  maturing  of  quantum  computers  and  start  developing  transition 
strategies towards a quantum-safe digital infrastructure now, i.e. secure against attacks from 
quantum  computers.  Short  of  this,  the  effort  and  investment  in  cutting-edge  digital 
infrastructure  to  deliver  applications  of  critical  societal  relevance,  such  as  in  the  field  of 
mobility or healthcare, could be compromised. 

Post-Quantum Cryptography (PQC) is a promising approach to make our communications and 
data resistant to quantum attacks, as it is based on mathematical problems hard to solve even 
by quantum computers. As a software-based solution, for which new dedicated hardware is not 
necessary, PQC allows for a swift transition to higher protection levels.  

PQC  is  already  high  on  the  agenda  of  many  countries.  National  authorities,  as  well  as  the 
European Union Agency for Cybersecurity (ENISA) have published reports on preparing for 
the  implementation  and  deployment  of  PQC92.  The  US  Cybersecurity  and  Infrastructure 
Security  Agency  (CISA)  established  a  PQC  Initiative  to  unify  and  drive  agency  efforts  to 
address threats posed by quantum computing93. 

However, the current framework in the Union cannot fully address the challenges posed by the 
migration  to  a  quantum-safe  digital  infrastructure.  Addressing  these  challenges  requires  a 
coordinated  effort  at  EU  level,  involving  mainly  government  agencies.  For  an  effective 
transition towards PQC, efforts should be synchronized ensuring the roadmaps are aligned at 
Union  level,  with  concrete  timelines  for  every  transition  step.  Assessment  of  the 
implementation  of  the  transition  plans  will  be  beneficial  not  only  to  gather  information  on 

at 

92   See, ANSSI Avis scientifique et technique de l’ANSSI sur la migration vers la cryptographie post-quantique, 
available 
anssi-avis-migration-vers-la-cryptographie-post-quantique.pdfanssi-avis-migration-vers-la-
cryptographie-post-quantique.pdf; BSI. Migration zu Post-Quanten-Kryptografie. Migration zu Post-Quanten-
Kryptografie  -  Handlungsempfehlungen  des  BSI  (bund.de)Migration  zu  Post-Quanten-Kryptografie  - 
Handlungsempfehlungen  des  BSI  (bund.de) ;  Post-Quantum  Cryptography:  Current  state  and  quantum 
mitigation — ENISA (europa.eu); Post-Quantum Cryptography - Integration study — ENISA (europa.eu).  

93   https://www.cisa.gov/news-events/news/cisa-announces-post-quantum-cryptography-initiative.  

37 

 
 
 
 
 
practical  challenges  and  gaps,  but  also  to  anticipate  needs  for  future  EU  regulatory 
requirements.  

It is therefore important to encourage Member States to develop a coordinated and harmonized 
approach, ensuring consistency in the development and adoption of EU PQC standards across 
Member  States.  This  consistency  would  promote  interoperability,  allowing  systems  and 
services  to  function  seamlessly  across  borders,  preventing  fragmentation,  different  levels  of 
efficiencies in the transition, and ensure a European approach to PQC. Measurable effects of 
the  transition  are  expected  to  appear  around  2030.  This  step  appears  to  be  compelling  and 
needed to preserve future policy options in an evolving technology landscape. That is why the 
Commission will set out recommendations to this effect in due course. 

In  the  long-term,  Quantum  Key  Distribution94  (QKD)  will  offer  additional  security  to  our 
communications, at the physical network layer. Hybrid implementation schemes PQC/QKD are 
part of guidelines issued by different National Security Agencies and enter discussions about 
the design of coordinated actions at EU level. The combination of QKD and PQC will allow 
for full end-to-end security in our digital communications. QKD represents a hardware-based 
solution  which  is  based  on  the  unique  properties  of  quantum  physics,  rather  than  on 
mathematical functions, and it is in principle inherently robust against brute-force attacks, as 
well  as  against  new  mathematical  discoveries  that  are  the  underlying  weakness  of  classical 
cryptography. Intense research is ongoing on different fronts to overcome the current practical 
challenges  of  this  technology,  and  first  deployment  test-beds  are  at  present  being  delivered 
under the EuroQCI initiative95  funded by  the DEP and SAGA96. EuroQCI will be gradually 
integrated under IRIS2. In principle, QKD will represent a full paradigmatic shift of the digital 
infrastructure ecosystem, and constitutes already now a forward-looking, highly competitive 
technology of high interest also for future applications such as the Quantum Internet. 

3.3.2.  Towards security and resilience of submarine cable infrastructures 

As  described  in  Section  2.4  above,  the  security  and  resilience  of  the  EU’s  network  and 
computing infrastructure is an essential element of our digital autonomy. In particular, it is clear 
that  the  security  of  submarine  cable  infrastructures  is  a  particularly  pressing  issue  of  EU 
sovereignty and poses a challenge to EU resilience. 

To overcome the identified challenges and protect the European interests, structural measures 
need to be considered. While the exact scope of these measures would need to be defined, a 
focus area should be the reinforcement of advanced R&I activities to strengthen the economic 
security of the EU, particularly in support of new fibre and cable technologies as part of the 
strengthening of the EU’s technical capacity as laid out in Section 3.1 above. 

Another  key  area  to  be  addressed  in  the  long  term  concerns  the  financing  of  new  strategic 
submarine cable infrastructures and the increase of security and resilience of existing ones. In 
this respect, an amendment by Delegated Act of the Annex Part V of the CEF Regulation could 

94   The Commission is working with all 27 EU Member States, and the European Space Agency (ESA), to design, 
develop and deploy the European Quantum Communication Infrastructure (EuroQCI). It will be an integral 
part of IRIS², the new EU space-based secure communication system. 

95   The European Quantum Communication Infrastructure (EuroQCI) Initiative | Shaping Europe’s digital future 

(europa.eu)  

96  The  space-based  component  for  EuroQCI,  known  as  SAGA  (Security  And  cryptoGrAphic  mission),  is 
developed  under  ESA’s  responsibility  and  consists  of  satellite  quantum  communication  systems  with  pan-
European reach. 

38 

 
 
 
 
 
be considered in order to establish a CPEI list and related labelling system of strategic Cable 
Projects of European Interest (CPEIs) that would address identified risks, vulnerabilities and 
dependencies.  CPEIs  could  be  conceived  to  comply  with  the  most  advanced  technological 
standards, such as sensor capabilities for their own monitoring and to support EU policies in 
the field of security, sustainability, or civil protection.  

More generally, it will be important to ensure appropriate funding of CPEIs and pool together 
EU and national funding instruments, and explore the feasibility and potential leverage effect 
of  financial  instruments  as  possible  implementing  modes  to  ensure  synergies  and  sufficient 
financing of CPEIs. Where appropriate, the Member States may decide also to design Cable 
IPCEI(s) in compliance with the criteria set in the IPCEI Communication97. Member States may 
also explore if the deployment and operation of certain CPEIs require further public support in 
line with State aid rules, or if it can be supported through the purchase of capacity for public 
use. 

As  a  result,  a  joint  EU  governance  system  on  submarine  cable  infrastructures  could  be 
envisaged, including: (i) additional elements to consider for mitigating and addressing  risks, 
vulnerabilities and dependencies under a consolidated EU-wide assessment, and priorities for 
increasing  resilience;  (ii)  revised  criteria  to  upgrade  existing  or  to  fund  new  cables;  (iii)  an 
update of the co-created priority list of CPEI, both intra-EU and international, based on strategic 
importance and respect for the above criteria; (iv) pooled funding from various sources for such 
projects, including potentially through equity funds in which the Union could participate with 
Member States to de-risk private investment and (v) further actions to secure supply chains and 
avoid dependency on high-risk third-country suppliers.  

Point (iv) could include specific action regarding the reinforcement of maintenance and repair 
capacity at EU level, which would mitigate the impact of any attempts to sabotage submarine 
cable infrastructure. This work stream could learn from the experience gained under the Union 
Civil  Protection Mechanism and RescEU, particularly  regarding firefighting, with  a view to 
building up an EU-funded fleet of maintenance and repair vessels. 

Finally, the need to work towards harmonised security requirements should also be addressed 
and  promoted  in  international  fora,  including  through  the  identification  of  best-in-class 
standards  that  harness  the  latest  developments  in  security  and  self-monitoring  capacities  for 
cables  and  associated  routing  and  relay  equipment,  which  could  be  recognised  through  a 
dedicated EU certification scheme.  

While  safeguarding  the  space  for  future  policy  options,  in  the  current  geopolitical  context 
described above and responding to the Council Recommendation as regards submarine cable 
infrastructures, it is necessary to take action to ensure the basis for a coordinated EU response. 
Therefore, alongside this White Paper, the Commission recommends to Member States certain 
immediate  actions  to  prepare  measures  in  the  longer  term.  These  possible  actions  are 
specifically  related  to  submarine  cable  infrastructure  that  Member  States  can  adopt  in  the 
implementation  of  the  Council  Recommendation  on  resilience  of  critical  infrastructure 
concerning submarine cable infrastructure. The Commission Recommendation will ensure that 
Member  States  and  the  Commission  work  together  to  implement  a  coordinated  and  robust 
approach as a precursor to the identification of the appropriate level of EU funding of relevant 

97   Communication on the criteria for the analysis of the compatibility with the internal market of State aid to 

promote the execution of IPCEIs, OJ C 528, 30.12.2021, p. 10–18. 

39 

 
 
 
 
 
R&I  activities,  in  light  of  the  scale  of  the  challenge,  and  eventually  a  more  centralised 
governance framework in the longer term. 

3.3.3.  Summary of possible scenarios  

•  Scenario 8: The Commission will promote the reinforcement of advanced R&I activities 

across the EU in support of new fibre and cable technologies. 

•  Scenario  9:  The  Commission  may  consider  establishing  a  CPEI  list  and  related 

labelling system by a Delegated Act under the Connecting Europe Facility. 

•  Scenario  10:  The  Commission  may  conduct  a  review  of  available  instruments,  in 
particular  grants,  procurement,  blending  operations  under  InvestEU  and  grant 
blending facilities, with a particular focus on leveraging private investment to support 
CPEIs, including the possibility of an equity fund. 

•  Scenario 11: The Commission may consider proposing a joint EU governance system 

on submarine cable infrastructures.  

•  Scenario  12:  The  Commission  may  consider  harmonising  security  requirements  in 
international  fora,  which  may  be  recognised  through  a  dedicated  EU  certification 
scheme. 

4.  CONCLUSION 

As  we  are  at  the  crossroads  of  major  technological  and  regulatory  developments,  it  is  of 
tantamount importance to debate these developments broadly with all stakeholders and like-
minded partners. Hence, with this White Paper the Commission launches a broad consultation 
of Member States, civil society, industry, and academics, to collect their views on the scenarios 
outlined  in  this  White  Paper  and  provide  them  with  an  opportunity  to  contribute  to  the 
Commission’s future proposals in this domain.  

These  ideas  put  forward  include  both  policy  means  to  ensure  secure  and  resilient  digital 
infrastructures and possible scenarios for key elements of a future regulatory framework. This 
consultation will allow a comprehensive dialogue with all concerned parties that will inform 
the next steps of the Commission.  

The Commission invites comments on the proposals set out in the White Paper through a public 
consultation available at https://ec.europa.eu/info/law/better-regulation/have-your-say_en. The 
consultation is open for comments until 30.06.2024.  

40