Internet Governance
Netnod has answered that there are substantial challenges for connectivity in Sweden. Most importantly, the public needs to be able and willing to finance robust and resilient digital infrastructure.
Netnod notes the increased interest to ensure proper functioning of the Internet, although through vague terms such as “broadband” and “gigabit infrastructure” rather than specifying what the Internet or Internet Access is. Netnod is of the opinion that the legislator should take height for the global and distributed nature of the Internet and design policy thereafter.
Netnod has commented on several aspects of the consultation, but with emphasis on the issues of end-to-end-regulation in the space of vertically separated communications services. The consultation suggests that number independent interpersonal communications can be compared to telephony in terms of control over the message flow and contents. This is simply not true.
Do not fix what is not broken. Netnod is against the suggestion that a metric should be developed based on which content providers should reimburse network operators.
Netnod welcomes the additional attention brought to the important topic of cybersecurity by the Cyber Resilience Act. However, Netnod believes that approach is fundamentally suboptimal and effort should instead be put towards accountability in the digital world. That is, instead of laying down ex-ante design requirements for digital products, the regulation should improve ex-post accountability processes in a digital environment.
Netnod sees some advantages to the proposed and slightly altered regulation with regards to electronic communications. However, Netnod believes that approach is fundamentally suboptimal and greater effort should have been put towards designing a legislative framework for the digital communications required for a digitised Sweden and Europe.
The report furthers a atrict environment for digitalisation rather than fundamentally questioning what the legislative environment for secure and cost-efficient IT operations should look like.
Netnod does not recommend moving forward with the current proposal related to the localisation principle for municipal broadband expansion.
Netnod believes that the creation of a specific sector for electronic communication and post is a good thing, and this does not have to overlap with the creation of a specific area for cybersecurity.
Netnod has submitted comments on the NIS-2 directive, a proposal from the European Commission (EC) on a directive with measures for a high common level of cybersecurity across the European Union.
Netnod’s view is that the risk assessment given in the proposal is too shallow and only focuses on one specific form of Denial of Service (DoS) attack
