The European Code of Electronic Communications: Remaining Challenges in IoT Deployment

The European Commission has set a broad and ambitious vision for the EU Digital Single Market and its electronic communications sector. The most significant development has been the Electronic Communications Code (Code). Despite some positive aspects, commentators have observed that the Code fails to confront long-term challenges for the European telecommunication sector and could hinder deployment of 5G networks in Europe, weakening the region’s competitiveness and harming European citizens. Such concerns are magnified with IoT, given the fact that IoT services have a strong pan-European dimension and cut across a variety of different industry sectors.

  • The different concepts in the Code create uncertainty for IoT providers in the EU, and ambiguity on who in the IoT supply chain is responsible for a number of obligations.
  • Such concepts will impact other regulations such as the future e-Privacy regulation and could create burdensome obligations for "non-traditional" electronic communication operators.
  • Regulation of IoT will remain fragmented because the level of service regulation varies considerably across member states, notably in terms of numbering resources.


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