Netnod's response to the proposal on the implementation of the Gigabit Infrastructure Act

Netnod has submitted its formal response to the report "Faster broadband throughout the country – measures for more efficient deployment of gigabit infrastructure" (SOU 2025:110). 

The response focuses on the implementation of the EU's Gigabit Infrastructure Act in Sweden. 

Key points from the response:

• Security risks with centralized data: Netnod warns against collecting detailed information about critical infrastructure in a single national database (SIP), as this creates a significant target for hostile actors.
• Decentralized information model: We support a model where the central point only contains metadata, while detailed technical information is shared directly between operators after security vetting.
• Precision in terminology: Netnod advocates for the "lasagna model" to distinguish between different technical layers (physical infrastructure, dark fiber, and internet access) instead of using the vague term "broadband".
• Focus on robustness over cost: We caution against an over-reliance on cost-cutting and rapid deployment, which may incentivize solutions with poor redundancy and physical protection.