13 Aug 2026 Public Policy

Why Europe’s Digital Networks Act needs real simplification

6 minute read

Europe does not need a bigger telecoms rulebook. It needs a much clearer one.

That should be the key test for the Digital Networks Act – will it make network investment easier to commit, approve and deploy? Or will it simply remix existing complexity under a new legislative name?

The Commission is right to put simplification at the centre of Europe’s connectivity agenda. Europe has set ambitious goals for digital competitiveness, economic security, artificial intelligence, cloud, industrial automation and public-service modernisation.

These all depend on resilient, high-capacity networks. Those will only be built at the pace Europe needs if regulation supports delivery.

The risk is paper simplification. Fewer legal instruments will not help if the same duplicated duties, uncertainties and national divergence are still lurking underneath. Consolidating rules into one regulation will not help if the result preserves legacy obligations, duplicates horizontal law and pushes too many decisions into future guidance.

A proposal that removes a handful of obligations while adding new reporting, new process and new interpretative layers does not simplify the market. It just gives the problem a new name.

Europe’s digital ambitions now depend on sustained private investment. The EU’s annual digital investment gap is around €150bn.¹ Europe also needs around €475bn in mobile network investment over the next decade, while operators are forecast to invest around €270bn under current conditions, leaving a mobile investment gap of around €200–205bn.²

This complexity carries a tangible cost. Every additional review, notification, interpretative opinion or overlapping compliance duty absorbs time, legal resource and capital that could otherwise support fibre rollout, 5G standalone upgrades, network resilience or service innovation.

And if the DNA leaves companies waiting for years of guidance, Europe will have modernised the paperwork before it modernises the networks.

When rules delay investment, the cost goes beyond balance sheets. It is felt in slower fibre upgrades, weaker rural coverage, less resilient public services and fewer businesses able to use the digital tools Europe wants them to adopt.

Complexity raises the cost of delivery

Europe’s connectivity sector is being asked to do more with less certainty, and the economics of network investment are already under sustained pressure. Yet the regulatory framework around those networks has become too layered, fragmented and difficult to apply at scale.

Telecom operators face a complex mix of more than 28 European horizontal and sector-specific regulations, translating into 34 sets of obligations across the customer journey, from acquisition to service delivery and disconnection. Nearly half of them overlap.³

These overlapping rules change investment conditions. They raise the cost of doing business, slow decisions and increase the risk premium attached to European network investment.

The DNA takes useful steps by recognising that Europe’s telecoms framework needs modernising. But simplification will fail if existing sector-specific obligations are preserved, horizontal rules continue to apply in parallel, and new DNA provisions are added on top.

The problem is practical, not theoretical. A company planning a cross-border network service should not have to test the same activity against telecoms rules, cybersecurity duties, resilience obligations, consumer law, data rules and national guidance without a clear hierarchy between them.

A telecoms operator using traffic or location data to manage congestion, prevent fraud or protect network security can find itself navigating telecoms confidentiality rules, GDPR, ePrivacy and security obligations at the same time.

A serious network incident can trigger telecoms reporting, cybersecurity reporting, data-protection analysis and national resilience processes. Market access or spectrum rights could also become linked to Cybersecurity Act 2 compliance, creating parallel enforcement routes for the same underlying security objective.

These protections are necessary. But Europe should say which rule leads, rather than ask companies to prove the same thing several times, to different authorities and under different legal tests.

The outcome is regulatory congestion that bundles more regimes, more interpretation and more uncertainty under a single legislative banner.

Consumer groups and regulators are right to insist that simplification should not weaken protection, competition or independent oversight. The better answer is clearer responsibility, especially if the rules are coherent, targeted and understood by everyone expected to follow them.

There is also a Single Market issue. Coordination between national regulators is necessary, but it cannot be a substitution for clear primary legislation. Where the law is unclear, additional process gives businesses more years of interpretation rather than clearer rules from the outset.

Europe had 44 mobile network operator groups with more than 500,000 connections in the second quarter of 2025, compared with eight in the United States. Europe also had around 70–75 fibre network owner groups with more than 500,000 premises passed.⁴

A true Single Market cannot function with 27 routes to regulatory interpretation. Companies need to know which rules apply, who enforces them and whether compliance in one member state can scale across the Single Market.

The test for real simplification

As the DNA text is negotiated, each provision should face a practical test - does it remove duplication, reduce uncertainty and make responsibility clearer?

That requires three changes:

First, no duplicated duties. Where horizontal EU law already protects privacy, cybersecurity, consumers or resilience effectively, the DNA should not recreate the same obligation under a telecoms label.
Second, no automatic carry-over of legacy rules. Obligations designed for yesterday’s market should remain only where there is a clearly evidenced gap that horizontal law, competition, targeted funding or licence conditions cannot address.
Third, no certainty by instalment. The DNA should provide clarity at entry into force, not create a timetable for further interpretation.

These reforms would preserve Europe’s standards while making them easier to understand, enforce and comply with.

Simplification as a delivery tool

Europe’s digital future depends on networks that can absorb rising demand and support new services. Fixed internet traffic increased by around 11 per cent year-on-year in Europe in 2024, while mobile data traffic grew by 18.3 per cent. Data-centre interconnect traffic is expected to grow by up to 50 per cent per year between 2025 and 2030.⁵

The investment challenge is already visible. Europe is still forecast to have 41.8m people unserved by FTTH by 2030 and 27.7m people unserved by gigabit-capable networks.⁶ More than 50 per cent of SMEs are expected to need at least 1Gbps connectivity by 2035, while 80 per cent are expected to require network capabilities that would necessitate fibre.⁷

Those outcomes require a framework that lets capital flow quickly into networks. That framework must make responsibility clear across the digital value chain and reduce the cost of operating across the Single Market.

Europe has a clear digital ambition. The harder task is turning that ambition into deployable infrastructure. The rules need to be clear enough for companies to act, stable enough to support long-term investment and sufficiently coherent that regulators can enforce them.

If the DNA removes duplication, clarifies responsibility and gives investors certainty from day one, simplification can become a real competitiveness tool.

Then Europe’s digital reset will be judged by what gets built, not by the size of the rulebook itself.