The reform of European telecommunications is entering the heart of the matter and, together with the political debate, the analyses on the effects that the future will have on the future are also intensifying. Digital Networks Act (DNA) could have an impact on the entire digital ecosystem. An independent study conducted by the telecommunications expert raises questions. Benoit Felten for CCIA Europe (Computer & Communications Industry Association), which analyzes the provisions of the legislative proposal dedicated to IP interconnection, identifying a series of potential critical issues that, according to the author, could alter the balance that has supported the development of the Internet in recent decades.
The report emphasizes that the opinions expressed are solely those of the author and do not necessarily represent the position of CCIA Europe. The aim of the analysis is to provide a technical contribution to the ongoing institutional debate between the European Parliament and the Council on the proposal presented by the European Commission on 21 January 2026.
An invisible infrastructure that supports the entire digital economy
The Internet is based on a system of technical and commercial agreements known as IP Interconnection, thanks to which thousands of networks belonging to different operators can seamlessly exchange data. Every streaming video, every digital payment, every cloud application, and every online service depends on this cooperation mechanism.
The study highlights how this model developed through voluntary agreements between operators, without the need for specific regulation. Internet traffic is mainly routed through three tools: transit, which guarantees connection to the entire global network; peering, that is, direct agreements between networks that choose to interconnect for mutual benefit; and the Content Delivery Network (CDN), distributed infrastructures that bring content closer to end users while reducing latency and network congestion. According to the analysis, this system has supported the growth of the digital economy by ensuring efficiency, resilience, and quality of services.
The report also recalls previous assessments of the BEREC and the European Parliamentary Research Service, according to which the IP interconnection market operates in a substantially competitive manner and does not present evidence of critical issues that would require structural regulatory intervention.
The two points of the Digital Networks Act under observation
The analysis focuses on two provisions of the proposed regulation. The first concerns: the article 9, which redefines the general authorization regime. According to Felten, the proposed wording significantly expands the range of entities potentially affected by the regulatory obligations, including not only telecommunications operators but also a wide range of digital economy players, such as content delivery networks, internet exchange points, cloud services, data center operators, digital platforms, private networks, and other information society service providers.
The second provision concerns the items 191-193, which introduce a new conciliation mechanism between electronic communications network operators and other economic entities. The European Commission's stated objective is to foster cooperation and resolve potential commercial disputes. The study notes, however, that the interconnection market has so far found its equilibrium through voluntary negotiations and cites BEREC's assessments, which do not identify any structural dysfunctions that would justify such regulatory intervention.
Fear of an expansion of regulatory obligations
According to the report, the extension of the authorization regime could lead to an increase in administrative procedures and compliance obligations for many digital operators, with the risk of overlaps with existing European regulations, such as the directive NIS2 or the regulation DORA.
The author also believes that the current wording could create interpretative uncertainty on the actual scope of the regulation, leaving national authorities considerable leeway in identifying the entities subject to the new rules. This situation, according to the analysis, could also result in fragmented regulatory implementation across Member States.
The potential economic implications for the entire digital ecosystem
A significant portion of the study focuses on the potential economic impacts of the new regulations. According to Felten, increased regulatory costs for entities such as CDNs, cloud providers, data center operators, and digital service providers could potentially ripple throughout the supply chain. Content Delivery Networks are now a fundamental infrastructure To efficiently distribute content and reduce network traffic. Any increase in their operating costs could impact the thousands of businesses that use these infrastructures and, indirectly, the prices paid by end users.
The study also recalls the The now central role of digital networks for cloud services, collaborative platforms, artificial intelligence, telemedicine, connected industrial systems and financial servicesAny change to the current interconnection balance, the author argues, could therefore impact the entire digital transformation process of European businesses.
From a technical point of view, the report notes that today the Interconnection agreements are defined on the basis of efficiency criteria, quality of service, and traffic optimization. Greater regulatory intervention could, however, influence these choices, potentially impacting latency, data routing flexibility, and, more generally, the ability of networks to rapidly adapt to growing connectivity demand.
Comparison with previous studies
To support your conclusions, The report also recalls two previous analyses carried out by Plum Consulting in 2024 and 2025, dedicated respectively to the extension of the European regulatory framework and to the effects of possible mandatory dispute resolution mechanisms in IP interconnection.
According to Felten, these researches converge in believing that the current interconnection model has favored innovation, competition and growth of the digital economy, while the introduction of new regulatory obligations could increase costs and uncertainty without any evidence of actual market failure. The study also notes that the documentation accompanying the European Commission's proposal provides no quantitative evidence demonstrating a systemic failure of the current interconnection model.
The proposals put forward by the report
In conclusions, The author suggests some specific changes to the text of the Digital Networks ActThese include a more precise definition of the entities subject to the general authorization regime, with the explicit exclusion of private networks and Content Delivery Networks, as well as assessing the feasibility of pursuing security and resilience objectives through existing regulatory instruments.
For the conciliation mechanism provided for in Articles 191-193, the study proposes its elimination or, alternatively, the suppression of the clause that could allow the current voluntary system to be transformed into a mandatory mechanism in the future.
According to Felten, the ongoing legislative debate represents the opportunity to explore the effects of the new provisions and find a balance between the objectives of competitiveness, security, and resilience pursued by the European Commission and the preservation of an interconnection model that, according to the analyses cited, has thus far supported the development of the European digital economy.
