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Positions
DOT Europe Compilation paper on CSA
DOT Europe Compilation paper on CSA
This paper is a compilation of all 5 position papers on the Regulation laying down the rules to prevent and combat child sexual abuse
Press Releases
Industry signs Revised Code of Practice on Disinformation
Industry signs Revised Code of Practice on Disinformation
Joint Letter – Negotiations on the Revision of the Directive on Liability for Defective Products Cannot be Rushed
Joint Letter – Negotiations on the Revision of the Directive on Liability for Defective Products Cannot be Rushed
No further information available.
Positions
DOT Europe postion paper on the PLD
DOT Europe postion paper on the PLD
DOT Europe acknowledges the recent revision of the Product Liability Directive (PLD) by the European Commission and understands the motivation behind updating the text. To create the appropriate framework DOT Europe believes that the following key criteria need to be met.
Letters
Joint Industry Statement on the extension of the withdrawal button to all distance contracts
Joint Industry Statement on the extension of the withdrawal button to all distance contracts
DOT Europe, alongside 16 other trade associations, co-signed an industry letter to caution against extending the withdrawal button to all distance contracts. Rules for withdrawals should not be prescriptive but encourage a flexible and principles-based approach that creates the best experience for consumers.
Reports
Analysis of the FFT Sender Party Network Pays proposal
Analysis of the FFT Sender Party Network Pays proposal
The Fédération Française de Télécoms (FFT) released a note entitled “For a fair contribution of large bandwidth users to network financing”. Plum, commissioned by Google, has performed an analysis of the French note. The analysis was launched today. Plum Consulting investigates the FFT’s arguments, questions the debatable base of reasoning of the note and concludes “An SPNP model would lead to negative outcomes for both telecom industry and consumers. It adds it would be challenging to implement a SPNP model both on regulatory and legal grounds."
Positions
DOT Europe position paper on EMFA
DOT Europe position paper on EMFA
DOT Europe, the voice of leading Internet companies operating in Europe, and its members are committed to the principles of media plurality and welcome the underlying objectives set out in the European Media Freedom Act to protect media plurality and editorial independence.
Press Releases
DOT Europe publishes a position paper on the CSA Regulation
DOT Europe publishes a position paper on the CSA Regulation
No further information available.
Infographics
DOT Europe Key Asks – CSAM
DOT Europe Key Asks – CSAM
DOT Europe's Key Policy Asks - CSAM
Positions
DOT Europe Issue paper 5 – EU Centre
DOT Europe Issue paper 5 – EU Centre
DOT Europe position paper on the Regulation laying down rules to prevent and combat child sexual abuse - issue 5
Positions
DOT Europe Issue Paper 4 – Scope
DOT Europe Issue Paper 4 – Scope
DOT Europe position paper on the Regulation laying down rules to prevent and combat child sexual abuse - issue 4
Positions
DOT Europe Issue Paper 3 – Technologies
DOT Europe Issue Paper 3 – Technologies
DOT Europe position paper on the Regulation laying down rules to prevent and combat child sexual abuse - Issue 3
Positions
DOT Europe Issue Paper 2 – Detection Orders
DOT Europe Issue Paper 2 – Detection Orders
DOT Europe position paper on the Regulation laying down rules to prevent and combat child sexual abuse - Issue 2
Positions
DOT Europe Issue paper 1 – Risk assessment and mitigation
DOT Europe Issue paper 1 – Risk assessment and mitigation
DOT Europe position paper on the Regulation laying down rules to prevent and combat child sexual abuse - Issue 1
Press Releases
DOT Europe’s reaction to the publication of the liability proposals
DOT Europe’s reaction to the publication of the liability proposals
DOT Europe, the voice of digital, online and tech companies operating in Europe, acknowledges the publication of the European Commission’s proposals on AI and Product Liability.
Positions
DOT Europe draft questions document on the proposal for a Regulation laying down rules to prevent and combat child sexual abuse
DOT Europe draft questions document on the proposal for a Regulation laying down rules to prevent and combat child sexual abuse
No further information available.
Positions
DOT Europe Q&A paper on AI
DOT Europe Q&A paper on AI
In this paper DOT Europe addresses some recurring concerns regarding AI technology and the scope of the AI Act.
Letters
Joint industry statement on the DSA stay-down provisions
Joint industry statement on the DSA stay-down provisions
On 24 May 2022, DOT Europe, together with six other organisations, shared its concerns on the newly introduced stay-down provision in the Digital Services Act. The statement was sent to Mr Bruno Le Maire for the Council Presidency, Ms Executive Vice-President Vestager and Mr Commissioner Thierry Breton for the European Commission, and to MEP Schaldemose and IMCO Shadows as well as to Rapporteurs of opinion-giving committees for the European Parliament.
Positions
DOT Europe position paper on the Regulation on the Transparency and Targeting of Political Advertising
DOT Europe position paper on the Regulation on the Transparency and Targeting of Political Advertising
In May 2022, DOT Europe published its position paper on the Regulation on the Transparency and Targeting of Political Advertising (TTPA).
Press Releases
DOT Europe’s reaction to the publication of the CSAM Regulation and BIK Strategy
DOT Europe’s reaction to the publication of the CSAM Regulation and BIK Strategy
DOT Europe, the voice of digital, online and tech companies operating in Europe, supports the Commission’s objective to set-up a coherent and updated regulatory framework around child safety online.
Positions
DOT Europe publishes position paper on Data Act
DOT Europe publishes position paper on Data Act
DOT Europe position paper assesses Data Act against its objectives of increasing data-sharing in the EU.
DOT Europe’s reaction to the interinstitutional agreement on the DSA
DOT Europe’s reaction to the interinstitutional agreement on the DSA
DOT Europe congratulates the European Commission, Council and the European Parliament on the agreement reached today on the Digital Services Act (DSA).
DOT Europe reacts to draft Data Act
DOT Europe reacts to draft Data Act
DOT Europe reacts to draft Data Act, questioning provisions on cloud and data contracts.
Positions
Algorithmic decision-making: transparency as explainability
Algorithmic decision-making: transparency as explainability
In this position paper, DOT Europe seeks to provide clarity on the workings of algorithms and propose a set of criteria for transparency in algorithms that is meaningful to citizens and public authorities alike.
DOT Europe welcomes progress on Digital Services Act
DOT Europe welcomes progress on Digital Services Act
DOT Europe, the voice of leading internet companies in Europe, welcomes the progress made in the European Parliament on the Digital Services Act allowing for trilogues to commence.
Press Releases
DOT Europe cautiously optimistic ahead of IMCO vote on DSA
DOT Europe cautiously optimistic ahead of IMCO vote on DSA
Today, DOT Europe shared its cautious optimism ahead of the IMCO vote on the DSA.
DOT Europe’s paper on the One-stop-shop
DOT Europe’s paper on the One-stop-shop
In this short paper, DOT Europe looks at the role of the one-stop-shop in EU legislation and addresses some of the criticisms to present a balanced view of OSS mechanisms and their uses.
Positions
End-to-end encryption: between privacy enhancement and law enforcement
End-to-end encryption: between privacy enhancement and law enforcement
In this short paper, DOT Europe presents its considerations on the tension between privacy enhancement and access to data by law enforcement authorities to better inform the current debate on this topic.
Positions
Encryption and end-to-end encryption: a primer
Encryption and end-to-end encryption: a primer
In this paper, DOT Europe provides an overview of encryption practices, their differences and common areas of application in order to better inform legislative initiatives in this area.
Press release – DOT Europe reaction to ITRE and JURI votes
Press release – DOT Europe reaction to ITRE and JURI votes
DOT Europe today expressed deep concern on the direction the Digital Services Act (DSA) is taking following votes in the Industry (ITRE) and Legal Affairs (JURI) committees last week.
Press Releases
Press release – DOT Europe publishes position paper on the Artificial Intelligence Act
Press release – DOT Europe publishes position paper on the Artificial Intelligence Act
No further information available.
Positions
DOT Europe position paper on the Artificial Intelligence Act
DOT Europe position paper on the Artificial Intelligence Act
In this position paper DOT Europe states its support for the AI Act’s objectives, namely to create a harmonised framework for AI at the European level that protects consumers and fundamental rights while creating conditions for investment and innovation in the AI sector. We also put forward some suggestions on how the co-legislators can improve the text, for example providing clearer and more focused definitions, avoiding impractical provisions on training datasets and establishing modalities for amending the definition of high-risk AI.
DOT Europe’s response to the Digital Principles consultation
DOT Europe’s response to the Digital Principles consultation
On 1st September 2021, DOT Europe submitted its response to the Commission's public consultation on the Declaration of Digital Principles – the ‘European way’ for the digital society.
Press release – Launching of a joint call for interest to take part in the work on the Code of Practice on Disinformation
Press release – Launching of a joint call for interest to take part in the work on the Code of Practice on Disinformation
Brussels, July 9th 2021 – DOT Europe, the current signatories of the Code of Practice on Disinformation and the European Commission launched a Joint Call for interest to parties to express their interest in taking part in the process of developing the strengthened Code and becoming signatories thereto.
Joint industry letter calling for preserving the E-Commerce Directive key principles in the DSA
Joint industry letter calling for preserving the E-Commerce Directive key principles in the DSA
No further information available.
Positions
DOT Europe’s position paper on the Data Governance Act
DOT Europe’s position paper on the Data Governance Act
In June 2021, DOT Europe released its position paper on the Data Governance Act (DGA).
Press release – DOT Europe reaction to the European Commission guidance on the implementation of ART. 17 of the Directive on Copyright in the Digital Single Market (Directive 2019/790/EC)
Press release – DOT Europe reaction to the European Commission guidance on the implementation of ART. 17 of the Directive on Copyright in the Digital Single Market (Directive 2019/790/EC)
DOT Europe, the voice of digital, online and tech companies in the EU acknowledges the European Commission’s publication of the long-awaited guidance on the implementation of ART. 17 of the Directive on Copyright in the Digital Single Market (Directive 2019/790/EC) – just before the implementation deadline of the Directive.
Press release – DOT Europe disappointed by IMCO draft report on the DSA
Press release – DOT Europe disappointed by IMCO draft report on the DSA
Brussels, 2nd June 2021 – DOT Europe, the voice of digital, online and tech companies in the EU, is disappointed by the European Parliament Committee on the Internal Market and Consumer Protection (IMCO) draft report on the Digital Services Act (DSA), published this week.
Letters
Joint statement on the DSA – 27 May 2021
Joint statement on the DSA – 27 May 2021
On 27 May 2021 DOT Europe co-signed, together with 5 other organisations, a joint statement on the Digital Services Act ahead of the 27 May Competitiveness Council.
Positions
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.
Positions
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.
Positions
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.
Positions
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 liability debate and the active-passive question, and how it relates to the DSA.
DOT Europe Briefing: Limited Liability and the Active-Passive Question
DOT Europe Briefing: Limited Liability and the Active-Passive Question
December 2020: DOT Europe overview of the limited liability 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.
Positions
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)
Positions
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).
Positions
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.
Positions
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.
Positions
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.
Positions
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.
Positions
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.
Positions
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.
Positions
EDiMA Cadre Responsabilité
EDiMA Cadre Responsabilité
EDiMA Responsibilité en ligne - Online Responsibility Framework
Positions
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 Releases
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.
Positions
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.
Positions
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.
Positions
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.
Positions
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.
EDiMA reaction to the inception impact assessment on tackling illegal content online
EDiMA reaction to the inception impact assessment on tackling illegal 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.
Positions
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.
Positions
EDiMA feedback on the proposal for amending AVMS Directive (2016)