Today, we submitted our response to the European Commission’s exploratory consultation on network fees.
We support the Commission’s goal of “ensuring access to excellent connectivity for everyone” and, in our submission, explain how we have been active partners in delivering that goal. However, proposals by a handful of telecom operators to be cross-subsidised by content application providers (CAPS) are fundamentally flawed. They misrepresent the digital ecosystem, including the symbiotic relationship between telcos and CAPs. We urge the Commission to recognise the value that CAPs provide to the digital ecosystem, in addition to the multi-billion euro investments that Meta has made – and continues to make – into Europe’s digital infrastructure.
We encourage the Commission to deeply examine the negative impacts of the telco-led proposals. We explain why the creation of what is effectively a required private sector handout for selected telecom operators would lead to bad outcomes for European businesses and consumers, disincentivize innovation and investment, and distort competition.
Allowing selected telecom operators to charge twice for the same infrastructure – already charging consumers for internet access while also mandating discriminatory network fees from CAPs – will harm net neutrality, the structure of the open internet, as well as consumers without any guarantee of more investment in networks.
Meanwhile, we continue to be concerned by statements that the development of the metaverse justifies a network fee, which as we have explained are just not true. We were also disappointed that the starting premise of the exploratory consultation was to assume market failure, despite significant evidence to the contrary.
The tide is turning against imposing network fees. From policymakers and regulatory experts to consumer groups and civil society organisations, a range of institutions united by the desire to preserve the basic principles of the internet and a competitive digital market economy have criticised the proposals. Of course, we will engage with any additional consultations and look forward to evaluating a full impact assessment. But we urge the Commission to consider the evidence, listen to the range of organisations who have voiced concerns, and abandon these misguided proposals as quickly as possible.