VAUNET position on the EU Commission’s White Paper on the future of electronic communications infrastructures

The White Paper is intended as a strategic document which, in addition to analysing the market situation, also contains scenarios and regulatory considerations for the future development of digital infrastructures. From the perspective of private media, the goal of promoting digital infrastructures is to be welcomed. At the same time, VAUNET points out that the special significance of private media for democracy, society and pluralism must always be taken into account in structural and regulatory considerations.

Therefore, VAUNET once again urges to reject any regulatory intervention in the telecommunications market that imposes direct or indirect payment obligations on audiovisual media, whether through a dispute resolution mechanism, mandated negotiations or other mechanisms that effectively amount to network charges for data-intensive services. Such network fees not only jeopardise the innovation and competitiveness of the media, but also pluralism. The White Paper correctly states that there is no situation in the interconnection market that requires regulation. However, individual passages in the White Paper suggest that the EU Commission has still not completely dismissed the idea of so-called „Network Fees„, which is not justified in light of its own statements.

With a view to a future Digital Networks Act, VAUNET also recalls the pivotal principle that any regulatory intervention should be based on a transparent and integrative process with a comprehensive analysis, at the end of which the evidence-based necessity for regulatory intervention must be proven. In accordance with the EU Commission’s „Better Regulation Principles“, any legislation should undergo a comprehensive public consultation of all stakeholders and, above all, a media compatibility test.