Netnod policy statements
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.
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.
In general Netnod believes the trust in certification is too high
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 sees some issues with the interim report in the public investigation into secure and cost-effective IT operations.
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
