April 23, 2026 – VAUNET – the Association of Private Media – has issued a position paper on the Digital Networks Act (DNA). The DNA is intended to overhaul future telecommunications, network, and platform regulation, and will also serve as the successor to the Directive on the European Electronic Communications Code (EECC).
Digital Networks Act: VAUNET Position Paper Calls for Consideration of the Impact on the Media
With its proposal for the European Digital Networks Act (DNA), the EU aims to modernize the rules governing digital networks. VAUNET – the Association of Private Media – generally welcomes the goal of creating high-performance and secure digital infrastructures. These infrastructures are the foundation for delivering professional media content to users via various transmission channels. At the same time, the association sees a significant need for improvement in several key areas. This is because the DNA not only addresses telecommunications issues; it must also take into account and safeguard the foundations of media freedom, cultural diversity, and democratic opinion-forming.
1. No network fees through the back door
VAUNET views the “voluntary” arbitration between network operators and other market players in the “ecosystem” as provided for in the DNA with particular concern. According to the recitals, this refers to content providers. In practice, this procedure threatens to indirectly introduce network fees—at the expense of media companies as well—or to pave the way for such fees. Given the market power of large telecommunications providers, fair outcomes would be virtually impossible to guarantee. Rising distribution costs would further increase the already high economic pressure on private media, thereby jeopardizing journalistic quality, diversity, and investment. VAUNET therefore demands: No network fees and no arbitration mechanisms that create pressure for such payments.
2. Ensuring Radio in Cars – Now and in the Future
Radio is indispensable for information, entertainment, and, in particular, crisis communication. While the DNA generally recognizes the importance of radio in cars, the proposed regulation is no longer sufficient. More and more vehicles are coming onto the market without built-in radios. VAUNET therefore calls for the mandatory installation of radio receivers to be required. Furthermore, the approach should be future-proof and technology-neutral: what matters is not the method of reception, but reliable access to radio content—including, but not limited to, terrestrial broadcasting.
3. Managing the copper network phase-out without disrupting access to information
The gradual transition from copper to fiber-optic networks is both necessary and sensible. Nevertheless, VAUNET warns against regulations that could lead to gaps in service coverage – for example, if copper networks are shut down even though fiber-optic connections are not yet actually available. In cities in particular, this can disrupt access to information—with social and age-related consequences. The criterion for a shutdown must therefore be the actual availability of fiber-optic connections (FTTH). Member states should retain sufficient flexibility in this regard.
4. Spectrum policy is also cultural policy
Radio frequencies are essential for broadcasting and media diversity. VAUNET sees a risk that the DNA is overly centralized in this area and overlooks national particularities. Cultural and media issues require subsidiarity-based solutions tailored to national contexts, particularly in the broadcasting sector. Furthermore, the association criticizes shortcomings in the democratic legitimacy of certain procedures.
5. Clear Separation Between Networks and Content
Finally, VAUNET warns against regulating content delivery networks (CDNs) in the same way as traditional telecommunications services. Media companies actively relieve the burden on networks by efficiently delivering their content. New licensing and reporting requirements would place a disproportionate burden on precisely these players. The DNA must therefore make it clear: content providers are not telecommunications companies.
Conclusion: Without modern and reliable infrastructure, media outlets cannot reach people with their content. Therefore, policymakers must carefully consider the impact of the Digital Networks Act on the media sector and address it appropriately.