The Digital Networks Act (DNA): Europe’s Explosive Connectivity Reform

Why the DNA Redefines Europe’s Digital Foundation

With the Digital Networks Act (DNA), the EU is preparing one of the most profound reforms of its telecommunications sector. The aim is to overcome regulatory fragmentation, accelerate investments in future-proof network infrastructures, and strengthen Europe’s digital competitiveness on a global scale.

However, the DNA is more than a technocratic piece of legislation: it represents a paradigm shift towards a unified, resilient, and sovereign digital infrastructure—while also being at the heart of a highly emotional controversy over the introduction of a so-called Fair-Share Model. This model aims to obligate large content providers to co-finance the networks, with potential implications for net neutrality and the openness of the internet.

The Pressure for Reform: Why the EECC Is No Longer Sufficient

The current legal framework—the European Electronic Communications Code (EECC)—is considered outdated. It is based on a directive implemented individually by each member state, resulting in inconsistent outcomes.

The Key Deficiencies:

• 27 national markets with different rules
• No EU-wide economies of scale for network operators
• Regulatory gap in cloud and platform services

With the DNA, the EU is shifting to a regulation as a legal form—meaning uniform, directly applicable, and binding. This aims to create a true European connectivity single market.

The Strategic Goals of the DNA

1. Standardization and Harmonization

The DNA replaces the patchwork of national regulations with a consistent framework. The vision: less bureaucracy, more economies of scale, greater investment security.

2. Accelerated Network Expansion

Technological priorities:

• Complete fiber migration
• Completion of the 5G rollout, preparation for 6G
• EU-wide spectrum management instead of national solo efforts

3. Resilience and Security

The focus is on protecting critical infrastructures such as undersea cables or 5G components. The Commission is considering a joint EU governance model for particularly sensitive network elements.

Overview: The Strategic DNA Goals at a Glance

The Controversial Fair Share: Who Should Pay for the Networks?

The Telcos’ Perspective

Telecommunications providers demand that Large Traffic Generators (LTGs)—such as Netflix, Google, Meta—contribute to network costs. Their arguments:

• 95% of data traffic comes from a few platforms
• Telcos finance the infrastructure—LTGs monetize it
• A fair contribution should close the €174 billion investment gap

A proposed mechanism would require LTGs to negotiate once they exceed a threshold (e.g., 5% of national data traffic)—with binding dispute resolution by authorities.

The Opposition: Net Neutrality and Open Internet at Risk

Critics—including NGOs, platform operators, and consumer associations—fear:

• Violation of net neutrality
• Restriction of the open internet
• Increased costs for end users
• Regulatory complexity and market distortion

In particular, the principle of Settlement-Free Peering (SFP)—the free exchange of data between networks—is threatened by the DNA. It is the backbone of an open, dynamic internet.

Comparison of Positions on the Fair-Share Model

The Geopolitical Component: Infrastructure as a Security Issue

In addition to economic and technological goals, the DNA also pursues a clear security policy agenda:

• Protection against foreign access to critical network infrastructure
• Building strategic autonomy in connectivity resources
• Preparation for hybrid threat scenarios and sabotage acts

The planned joint management of the undersea cable infrastructure is an expression of this security policy reorientation.

Recommendations for Action: Digitization Without Collateral Damage

To make the DNA a success, the EU must safeguard both infrastructural investment security and digital freedom rights. Three suggestions:

1. Transparency Instead of Compulsion

Instead of fixed fees, usage costs and profits should be disclosed to enable fair negotiations based on data.

2. Investment Models with Incentive Components

The EU should develop performance-based financing instruments—similar to pay-per-milestone models in the construction industry.

3. Earmarking of Revenues

Any fees should be used exclusively for national network expansion—no cross-financing of corporate interests.

Conclusion: The DNA as a Test Case for Europe’s Digital Leadership Ambitions

The Digital Networks Act is more than a telecommunications law. It is Europe’s attempt to write the rules for the digital decade itself—sovereign, innovation-friendly, and in technological leadership.

However, the DNA will be measured by whether it can resolve the tension between infrastructure promotion and digital freedom. If this balancing act fails, either investment stagnation or the erosion of the open internet threatens.

The DNA is thus a litmus test for Europe’s ability to unite regulatory vision with technological reality.