Netnod policy statements
Netnod provides expert input in policy, regulatory and governance discussions that directly impact the context within which we operate.
Netnod's response emphasises that: there is no reason to harmonise the requirements for number independent communication services with those for number dependent communication services; and that, from a security perspective, clear text adaptability requirements cannot be part of the suggested solution.
Netnod's response to the AI Commission's roadmap emphasizes that public administration should adapt to facilitate effective digitalization and that expert authorities, rather than political bodies, should be empowered to promote digitalization and AI usage.
Netnod agrees with the report's assessment that there is no need to amend the regulations concerning storage and adaptation obligations in the Electronic Communications Act, but has two main concerns with the proposed changes.
During the spring of 2025 the Swedish government released the national strategy on cybersecurity. While the strategy itself is clear and detailed, it does not directly address the long-term consequences of short-term priorities, nor does it explore how to align the long-term incentives of for-profit actors to Sweden’s national security interests.
The updated proposal continues to include the same issues as highlighted by Netnod in the prior consultation: never promote backdoors, do not forbid end-to-end-encryption and do not harmonise the legal frameworks for number dependent and number independent services.
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 believes that the act named Cybersecurity risk management & reporting obligations for digital infrastructure, providers and ICT service managers will not lead to the intended effect.
Netnod believes that the white paper does not take into account the design and architecture of the Internet and does not recognise the importance of the Internet for society.
