The EU Digital Networks Act should take into account the broader operating environment of digital infrastructure
The Digital Networks Act (DNA) represents an important step toward strengthening Europe’s digital infrastructure and supporting competitiveness, resilience and the functioning of the single market. At the same time, the proposal reflects an ongoing structural shift in the digital landscape. Connectivity is increasingly intertwined with cloud, data, AI, quantum and high-performance computing infrastructures.
While the DNA is primarily focused on strengthening Europe’s connectivity markets and incentivising investment by telecommunications and other connectivity providers, the broader digital infrastructure landscape is evolving rapidly. Initiatives such as EuroHPC and GÉANT are building a hyperconnected European infrastructure layer that will greatly enhance large-scale data exchange between EuroHPC supercomputers, national supercomputers, AI Factories, quantum facilities, research infrastructures and data centres across Europe. These developments demonstrate that connectivity increasingly extends beyond traditional telecommunications networks and forms part of a broader ecosystem of interconnected digital infrastructures.
CSC therefore encourages the Commission to ensure that the implementation of the DNA reflects these developments. In particular, the Union Preparedness Plan for Digital Infrastructures should adopt a sufficiently broad understanding of critical digital infrastructure, recognising the growing interdependencies between commercial connectivity networks and strategic public digital infrastructures, including research and education networks, HPC facilities, AI Factories, data infrastructures and other publicly governed digital capacities.
Resilience mapping, infrastructure monitoring, risk assessments and coordination mechanisms should take these interdependencies into account. A broader and more integrated approach would provide a more complete picture of systemic risks, improve preparedness for disruptions affecting multiple interconnected digital infrastructures.
Ensuring that connectivity policy reflects these developments will strengthen Europe’s ability to develop, operate and protect the infrastructures that underpin research, innovation, artificial intelligence and data-driven growth. It will also help ensure coherence between the Digital Networks Act and the broader EU technology sovereignty agenda.
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Irina Kupiainen
Irina Kupiainen is responsible for CSC’s public affairs.