Concerns have been raised that the European Union's Digital Networks Act (DNA) under way could make things more complex rather than simplifying regulation. Still, analysts noted it is significant as a strategic attempt to redefine networks as a core supply chain in the age of artificial intelligence (AI).
Cho Dae-geun, an adjunct professor at Sogang University's Graduate School of Public Policy, stated accordingly at the "8th Telecom Industry Insight Seminar" held on the 15th at the Korea Telecommunications Operators Association (KTOA) building in Seocho-gu, Seoul, while presenting on "Key policies and implications of the EU DNA."
Professor Cho defined the DNA as the EU's plan to overhaul the next-generation communications and connectivity regulatory framework. He said, "The EU DNA aims to tweak network rules across Europe to strengthen the internal market and improve investment conditions, while enhancing the autonomy and resilience of the connectivity infrastructure needed in the AI era," adding, "It is an attempt to redesign, in broad strokes, everything from existing telecom regulation simplification to spectrum, licensing, and next-generation network elements."
However, Professor Cho assessed that the bill has faced considerable pushback even before getting fully on track. The European Commission (EC) is touting the DNA as strengthening the internal market, simplifying regulation, and securing sustainable connectivity, but the actual institutional design may differ from expectations.
In particular, Professor Cho said the criticism from the Body of European Regulators for Electronic Communications (BEREC) warrants attention. According to Cho, BEREC sees the DNA as adding an unnecessary regulatory layer without clear added value, and believes lower-level rules spanning multiple areas could undermine future regulatory predictability.
He also raised the allocation of authority as a key issue. Professor Cho said, "The DNA reads as aiming to reduce the powers and discretion of national regulatory authorities (NRAs) and concentrate them at the EU level," adding, "BEREC's concern is that for a successful single market, the unique authority of national regulators—namely subsidiarity that enables immediate responses to each member state's circumstances—must be maintained."
Professor Cho also said the effectiveness of the DNA remains uncertain. The bill is likely to be revised multiple times over the next one to two years as it proceeds through the European Parliament and the Council of the European Union, and its initial policy direction could change significantly as stakeholder demands are reflected. He also pointed out that leaving sensitive issues, such as open-internet regulation and cooperation in the digital ecosystem, to BEREC guidelines instead of placing them directly in the text could create confusion. Cho explained that this structure could increase uncertainty for both market participants and end users. He added that political burdens the European Commission must resolve are not small, given pushback from some member states and pressure from trade talks with the United States.
Even so, Professor Cho assessed that the DNA's strategic value itself is not small. Above all, he emphasized the significance of the bill codifying networks not as mere infrastructure but as a core supply chain in the AI era. He said it represents a shift in thinking to place connectivity, autonomy, and resilience at the center of telecom policy.
He also pointed to investment incentives. Professor Cho explained, "The DNA is underpinned by approaches to reduce burdens on market participants, such as extending spectrum license terms, streamlining administrative procedures, and reviewing exclusions from traditional universal service obligations." He added, "There also appears to be an intention to centrally manage next-generation network elements such as low Earth orbit satellites, submarine cables, and AI-RAN at the national level."
Professor Cho also analyzed that the DNA goes beyond a simple telecom bill and takes on the character of an "ecosystem policy" that addresses a wide range of stakeholders surrounding networks. He said it is considering cooperation and dispute-resolution mechanisms that encompass not only telecom operators but also platforms, equipment, services, and users.
Professor Cho said the DNA's success or failure hinges on balancing deregulation and predictability. He said, "If the system is not designed transparently, Europe's digital ambitions could sink into a swamp of complex regulation," and suggested, "Korea should also look to these global regulatory trends and consider clear and transparent institutional support measures to spur network investment."