Cybersecurity

The Internet is a global matter that requires multistakeholder management and must not be governed by national or EU legislation. It is crucial to differentiate between the Internet itself and the services that rely on it.

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

Netnod argues for keeping content and distribution separate, ensuring that any content can be delivered across any platform. Netnod also stresses the need for robust and available services, especially in times of crisis.

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

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

On 2 September 2023, Netnod was given the opportunity by Sweden’s Ministry of Defence to comment on an inquiry into models for contingency supply and planning (SOU 2023:50). Netnod is critical that the investigation did not thoroughly investigate the issue of long term infrastructure investments and costs.

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