14 Jun 19

Netnod comments on Ministry of Finance study on EU consumer protection regulation

Netnod has commented on the Ministry of Finance's release of SOU 2019:12, “New Powers in the Field of Consumer Protection”, a regulation that is proposed to come into force from 2020. The purpose of this new regulation is to streamline and strengthen cooperation between authorities in order to meet the challenges posed by digital development and strengthen cross-border e-commerce within the EU.

Netnod has commented that there needs to be more consideration on the part related to “a warning message” given to the use of digital signatures and encryption. These are increasingly used not only for the exchange of critical information but also for digital communication in general. This means, as the National Post and Telecom Agency (PTS) has also noted when the new gaming regulation was discussed, that intermediaries in transactions between traders and consumers (such as hosting providers and ISPs) cannot modify or identify communication when signing and encryption mechanisms prevent this.  

Netnod wishes to point out that these security mechanisms are extremely important for consumers to interact safely with traders and the public sector. Various government authorities have, for some years, been advocating the use of such mechanisms as TLS (security for among other things web based services), DNSSEC (security for the domain name system DNS), and RPKI (security for routing). Netnod suggests that the intermediary responsibility of the host service provider and the Internet service provider is limited to the services they provide and that measures remain that do not affect the established security features.

Netnod’s full response is available here

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