DOT Europe recommendations ahead of ePrivacy trilogues
DOT Europe recommendations ahead of ePrivacy trilogues
In April 2021, DOT Europe shared its set of recommendations ahead of the upcoming trilogue meetings on ePrivacy.
DOT Europe Key Principles for Codes of Conduct under DSA
DOT Europe Key Principles for Codes of Conduct under DSA
Article 35 of the DSA proposal describes how more content- or service-specific Codes of Conduct for online platforms. As these Codes will form an important part of the co-regulatory architectue of the DSA, we believe it is important to keep some key principles in mind - based on learnings from existing codes of practice and conduct. In this paper DOT Europe proposes a collection of key principles for policy-makers' consideration.
DOT Europe’s position paper on NIS 2
DOT Europe’s position paper on NIS 2
In this position paper, DOT Europe welcomes the stated goal of the draft NIS 2, namely to harmonise and reduce the fragmentation of cybersecurity legislation across the EU. We put forward some recommendations regarding the scope, the security obligations, end-to-end encryption, reporting obligations, certification schemes, jurisdiction and enforcement. We would also like to draw attention to the necessity for the draft NIS 2 to take into account the existing and upcoming legislation in the field (EECC, draft DORA) to avoid creating confusion regarding definitions, obligations and supervision.
DOT Europe Summary of Recommendations on DSA
DOT Europe Summary of Recommendations on DSA
In this document, DOT Europe summarises the recommendations we have on Chapters I to III of the DSA proposal, building on the questions we raise in a complementary paper “DOT Europe Questions and Recommendations on the DSA”. With this feedback, we aim to contribute to the creation of an effective and proportionate framework which addresses stakeholders’ concerns, while supporting innovation in the EU Single Market.
DOT Europe Questions and Recommendations on DSA
DOT Europe Questions and Recommendations on DSA
DOT Europe's members have much to contribute to the discussion on the practicality and feasibility of the proposals in the DSA. In this paper, we put forward some initial questions, examples, and recommendations on Chapters I to III of the DSA. We believe these questions will need to be considered by policy-makers when reading the proposed text, in order to derive all the benefits of this new regulatory approach and deliver a balanced and proportionate framework that addresses stakeholders’ concerns, while supporting innovation in the EU Single Market.
DOT Europe’s response to the political advertising consultation
DOT Europe’s response to the political advertising consultation
On 2nd April 2021, DOT Europe submitted its response to the Commission's public consultation on political advertising.
DOT Europe’s response to the Commission’s discussion papers on the future of the Code of Practice on Disinformation
DOT Europe’s response to the Commission’s discussion papers on the future of the Code of Practice on Disinformation
In Q1 2021, the European Commission organised a series of workshops to consult stakeholders on the update of the Code of Practice on Disinformation. It also published a series of discussion papers in order to guide the discussion. This is our response to some elements included in the Commission's discussion papers.
DOT Europe preliminary remarks on the DSA
DOT Europe preliminary remarks on the DSA
February 2021: DOT Europe's preliminary remarks on the DSA proposal - highlighting that policy-makers need to keep in mind the focus, scope and coherence of the DSA in the upcoming legislative process.
Due Diligence Obligations in the DSA: DOT Europe Questions for Consideration
Due Diligence Obligations in the DSA: DOT Europe Questions for Consideration
December 2020: Many different stakeholders in the DSA debate have identified specific issues they wish to address in the online ecosystem, and have floated suggestions on how to do so - ranging from transparency reporting, to a “know your business customer” obligation, to notice and action rules. Collectively we have often seen these various measures referred to as “due diligence obligations”. For the DSA, DOT Europe wishes to offer some thoughts and questions regarding some of the due diligence obligations, which we believe will need to be considered to help deliver a balanced and proportionate framework.
DOT Europe Summary: Limited Liability and the Active-Passive Question
DOT Europe Summary: Limited Liability and the Active-Passive Question
December 2020: DOT Europe two-page summary of the limited laibility debate and the active-passive question, and how it realtes to the DSA.
DOT Europe Briefing: Limited Liabiltiy and the Active-Passive Question
DOT Europe Briefing: Limited Liabiltiy and the Active-Passive Question
December 2020: Dot Europe overview of the limited liabiltiy regime and the active-passive classification, and how it relates to the DSA.
DOT Europe Online Responsibility Framework Series: Introduction of a Governance Body
DOT Europe Online Responsibility Framework Series: Introduction of a Governance Body
This paper focuses on the potential need for an oversight structure to ensure the effectiveness of the Online Responsibility Framework for internet users. We believe that a robust governance system is required and that oversight is not just advisable, but is a necessary component of the DSA.
DOT Europe Online Responsibility Framework Series: Introduction of Necessary Safeguards
DOT Europe Online Responsibility Framework Series: Introduction of Necessary Safeguards
In this paper, part of the landmark series on the Online Responsibility Framework, DOT Europe is calling for the introduction of a legal safeguard which would allow companies to take proactive actions to remove illegal content and activity from their services, without the risk of additional liability for those attempts to tackle illegal content.
DOT Europe Online Responsibility Framework Series: A Legal Basis to Act
DOT Europe Online Responsibility Framework Series: A Legal Basis to Act
In this paper, part of the landmark series on the Online Responsibility Framework, DOT Europe recommends focusing on illegal content in the Digital Services Act and highlights the risks of attempting to tackle harmful-but-lawful content through the same legal instrument.
EDiMA response to the NIS consultation
EDiMA response to the NIS consultation
On 2nd October 2020, EDiMA submitted its response to the Commission's consultation on the review of the Directive on security of networks and information systems (NIS Directive)
EDiMA response to the NIS Consultation
EDiMA response to the NIS Consultation
On 2nd October 2020, EDiMA sent its response to the Commission's public consultation on the Directive on security of network and Information Systems (NIS Directive).
EDiMA’s Position Paper on Artificial Intelligence (AI)
EDiMA’s Position Paper on Artificial Intelligence (AI)
In September 2020, EDiMA published its position paper on artificial intelligence based on the European Commission's White Paper released earlier.
EDiMA response to the European Democracy Action Plan Consultation
EDiMA response to the European Democracy Action Plan Consultation
EDiMA's response to the European Commission's consultation on Protecting European democracy from interference and manipulation – European Democracy Action Plan
DOT Europe on the fundamental principles of the e-Commerce Directive
DOT Europe on the fundamental principles of the e-Commerce Directive
DOT Europe's overview of the fundamental principles of the e-Commerce Directive, and why they should be maintained and clarified in upcoming DSA discussions.
EDiMA response to targeted consultation on Article 17 of the Copyright Directive (2020)
EDiMA response to targeted consultation on Article 17 of the Copyright Directive (2020)
In autumn 2019 the European Commission began a series of stakeholder dialogues for the development of a guidance on Article 17 of the Copyright Direcrive for Member State implementation, in particular regarding the cooperation between online content-sharing service providers and rightholders under the new rules. To conclude this process the Commission then launched a targeted consultaiton on Article 17 of the Directive, and invited stakeholders to submit responses. EDiMA was an active participant during the stakeholder dialogue meetings, and responds here to the Commission's targeted consultation on Article 17 of the Directive.
EDiMA response to public consultation on the Digital Services Act
EDiMA response to public consultation on the Digital Services Act
EDiMA's response to the European Commission's public consultation on the Digital Services Act package.
EDiMA feedback on the German Presidency ePrivacy questionnaire
EDiMA feedback on the German Presidency ePrivacy questionnaire
In this document, EDiMA provides its feedback on the German Presidency's ePrivacy questionnaire, published in July 2020.
EDiMA feedback on DSA Inception Impact Assessment and Roadmap
EDiMA feedback on DSA Inception Impact Assessment and Roadmap
EDiMA's submission to the Commission's request for feedback on the IIA/Roadmap on the Digital Services Act: Deepening the Internal Market and clarifying responsibilities for digital services.
Annex to the EDiMA response on the Data Strategy Consultation
Annex to the EDiMA response on the Data Strategy Consultation
Together with its response to the AI data strategy questionnaire, EDiMA submitted this annex. It provides for a more detailed overview of the association's position and clarifies some specific points.
EDiMA response to the European Strategy for Data Consultation
EDiMA response to the European Strategy for Data Consultation
This document is the copy of EDiMA's response to the Commission's consultation on its Data Strategy. It was submitted on 30 May 2020.
Annex to EDiMA’s response to the Consultation on the AI White Paper
Annex to EDiMA’s response to the Consultation on the AI White Paper
Together with its response to the AI consultation's questionnaire, EDiMA submitted this annex. It provides for a more detailed overview of the association's position and clarifies some specific points.
EDiMA response to the AI White Paper Consultation
EDiMA response to the AI White Paper Consultation
This document is the copy of EDiMA's response to the Commission's consultation on its White Paper on Artificial Intelligence. It was submitted on 10 June 2020.
EDiMA response to the Commission’s AI roadmap
EDiMA response to the Commission’s AI roadmap
EDiMA response to the Commission’s AI roadmap. EDiMA and its members can offer insight into the interplay between the technical aspects of AI and its broader impact on the economy and society, and are committed to maximising the benefits of AI for Europe.
EDiMA Cadre Responsabilité
EDiMA Cadre Responsabilité
EDiMA Responsibilité en ligne - Online Responsibility Framework
Press Release: Spotify joins EDiMA
Press Release: Spotify joins EDiMA
14 January 2020 - Spotify joins leading digital trade association: EDiMA
New Online Responsibility Framework
New Online Responsibility Framework
In this paper, DOT Europe outlines a vision for a new Online Responsibility Framework, in which we set out how internet companies and other stakeholders can tackle illegal content and address concerns in the online ecosystem.
Press Release: EDiMA calls for a new Online Responsibility Framework
Press Release: EDiMA calls for a new Online Responsibility Framework
EDiMA Press Release 07 January 2020 - EDiMA calls for a new Online Responsibility Framework.
EDiMA briefing on CJEU ruling Eva Glawischnig-Piesczek v Facebook Ireland (2019)
EDiMA briefing on CJEU ruling Eva Glawischnig-Piesczek v Facebook Ireland (2019)
EDiMA briefing on CJEU ruling on Eva Glawischnig-Piesczek v Facebook Ireland Case C-18/18, and on how it ties into ongoing discussions on the DSA.
EDiMA response to UK Online Harms White Paper
EDiMA response to UK Online Harms White Paper
EDiMA response to UK Online Harms White Paper Consultation, published in 2019.
EDiMA unresolved issues on ePrivacy
EDiMA unresolved issues on ePrivacy
This paper aims to detail the different issues that still need to be addressed during Council negotiations in the draft ePrivacy Regulation.
EDiMA position paper on the draft Terrorist Content Regulation (TERREG)
EDiMA position paper on the draft Terrorist Content Regulation (TERREG)
This document is EDiMA's position paper on the draft Regulation to prevent the dissemination of terrorist content online, published in December 2018.
EDiMA Position Paper on P2B relations (Platform-to-business)
EDiMA Position Paper on P2B relations (Platform-to-business)
This is the EDiMA position paper on the Platform-to-business (P2B) Regulation, issued in 2018.
EDiMA’s examples document on the TERREG
EDiMA’s examples document on the TERREG
This document compiles concrete examples of issues posed by the draft Regulation in the fight against terrorist content online.
This document features EDiMA's detailed reaction to the Inception Impact Assessment on tackling illegal content online (2018).
EDiMA Infographic on Potential Services in Scope of Article 13 (2018)
EDiMA Infographic on Potential Services in Scope of Article 13 (2018)
EDiMA infographic detailing the different vairety of online service providers potentially captured in scope of Article 13 of the copyright Directive, originally published in 2018.
EDiMA’s reaction to the Notice and Action (N&A) Communication
EDiMA’s reaction to the Notice and Action (N&A) Communication
In this document, EDiMA reacts in details to the Commission's Communication on tackling illegal content online.
EDiMA Briefing on Article 13 in Four Steps (2017)
EDiMA Briefing on Article 13 in Four Steps (2017)
EDiMA overview of four main concerns with Article 13 of the proposed copyright Directive, originally publsihed in 2017.
EDiMA briefing on the Pirate Bay CJEU ruling
EDiMA briefing on the Pirate Bay CJEU ruling
EDiMA briefing on the CJEU ruling on Case C-610/15 on the Pirate Bay, and its links to discussion on draft copyright Directive, published in 2017.
EDiMA’s DSM mid-term review
EDiMA’s DSM mid-term review
In June 2017, EDiMA published its own Digital Single Market (DSM) mid-term review document, highlighting the progress made since 2015 and where the Commission should step-up its efforts for the next two and a half years.
EDiMA briefing on Article 13 of draft Copyright Directive (2017)
EDiMA briefing on Article 13 of draft Copyright Directive (2017)
EDiMA's briefing on the concerns with the propoal for Article 13 of the draft copyright Directive, document published in 2017.
EDiMA Copyright Position Paper (2017)
EDiMA Copyright Position Paper (2017)
EDiMA position paper on the proposed Directive on copyright in the Digital Single Market, originally published in 2017.
EDiMA – DIGITALEUROPE Policy Brief on the Impact of Article 11 on Publishers’ Rights (2017)
EDiMA – DIGITALEUROPE Policy Brief on the Impact of Article 11 on Publishers’ Rights (2017)
Originally published in 2017 during the debate on Article 11 of the draft copyright Directive, detailing our concerns on that proposal.
EDiMA feedback on the proposal for amending AVMS Directive (2016)