Cullen Digital Networks Act (DNA) Hub

The EU Digital Networks Act (DNA) is a proposed legislative initiative aimed at addressing market fragmentation, investment conditions, and regulatory coordination in the electronic communications sector, with a focus on high-capacity and cross-border digital networks.

Cullen International provides targeted analytical coverage of the DNA, assessing its regulatory design, governance mechanisms, and potential market impacts. Further analysis is available upon request.

Request more information & access to the DNA report series

Digital Networks Act (DNA) proposal: great ambitions, moderate means

An EU-level authorisation regime for satellite services, a new EU access product, a voluntary “conciliation process” on IP interconnection disputes and a focus on network resilience are among the main innovations proposed under the Digital Networks Act.

11 key takeaways from the leaked draft

These preliminary observations are based on a leaked version of the draft DNA, still subject to change, seen by Cullen International before the European Commission published the final version on 20 January 2026.

Analysis of the proposed Digital Networks Act

Part 1: Spectrum

The proposed Digital Networks Act (DNA) regulation foresees an expanded role for the Commission and the upgraded Radio Spectrum Policy Body (RSPB, currently the Radio Spectrum Policy Group) to ensure a more harmonised approach to spectrum among EU member states. The main changes proposed include unlimited licence durations by default, spectrum sharing as the norm, new EU-level tools for spectrum management and added EU-level scrutiny for national spectrum assignments

Part 2: General authorisation

The draft Digital Networks Act (DNA) will facilitate cross-border provision of electronic communications networks and services through a single notification in just one member state, fully harmonised general authorisation conditions and streamlined reporting obligations. However, mandatory notification requirements will also imply new and extensive procedural rules, not least for member states that currently do not have any notification mechanisms in place.

Part 3: Satellite

The proposed Digital Networks Act (DNA) seeks to establish a centralised EU framework for satellite authorisations. It also sets out mechanisms for greater coordination between member states on satellite filings at international level. The proposed framework aims at strengthening the EU’s strategic autonomy and enhancing the single market and will involve the Commission in all stages, from allocation and licensing to enforcement.

Part 4: Net neutrality

The proposed Digital Networks Act (DNA) integrates the EU rules on net neutrality and opens a possibility for the European Commission to adopt binding implementing acts detailing the conditions to offer specialised services.

Part 5: SMP regulation

The Digital Networks Act (DNA) will largely preserve the existing approach to significant market power (SMP) access regulation. Under the Commission proposal, the DNA will maintain the core of the existing SMP access regime, including the three-criteria test as the trigger for ex ante regulation; recalibrate regulatory intervention by focusing more tightly on clearly identified market failures; prescribe an escalation from lighter to more intrusive remedies; and introduce an EU-harmonised wholesale access product as the new default access remedy.

Part 6: Copper decommissioning

The proposed Digital Networks Act (DNA) sets multiple deadlines for copper switch-off: in areas where certain conditions on fibre overage and availability of comparable services are met, member states must complete copper switch-off (CSO) by end 2033; and in the remaining areas, the copper switch-off must be completed by end 2039.

Part 7: Symmetric regulation

The Digital Networks Act (DNA) will provide more flexibility for national regulatory authorities (NRAs) while largely preserving the existing approach to symmetric access regulation.

Part 8: Consumer protection

The proposed Digital Networks Act (DNA) largely maintains the current set of end-user rights. In addition, the European Commission highlights the need for a coordinated approach to fight fraudulent activities that affect telecoms end users.

Part 9: Universal service

The proposed Digital Networks Act (DNA) will preserve the existing universal service objectives of availability, affordability, and social inclusion. It foresees the possibility of binding implementing acts by the European Commission on defining adequate internet access.

Part 10: Network contribution

The proposed DNA will extend the concept of interconnection to private networks such as content delivery networks, but without binding dispute resolution

Cullen International has updated its Legislation Navigator with the official text of the proposed Digital Networks Act (DNA), allowing you to easily browse through the 416 recitals, 210 articles, 50 definitions and 6 annexes proposed.

Request access to the Legislation Navigator

Request one of our DNA reports

To request one of our DNA reports and/or a demo of our Telecoms intelligence, please just complete the below form.

(Note: Our services are predominantly designed for the use of government entities, regulators, communications service providers or manufacturers. We reserve the right to offer access to our research only to selected organisations.

Feel free to contact us if you have any question regarding your eligibility for free extracts or a demo.)

Who?

Founded in Brussels in 1986, we’ve built our reputation on our expertise and neutrality, as well as the ability to convey complex information in a concise way. This has won us the trust of customers in over 90 countries.

Discover how we make regulation simple

Don't miss any regulatory news

Subscribe to our newsletter!

Contact Us

Cullen International Brussels office

Clos Lucien Outers 11-21/1

1160 Brussels

Belgium

Phone: +32 2 738 72 00

Email: discover@cullen-international.com

Privacy

Terms