On 21 January 2026, the European Commission (“Commission”) unveiled its landmark proposal for the Digital Networks Act (“DNA Proposal”), an ambitious attempt to overhaul the framework for the regulation and development of electronic communications networks and services across the EU. The Commission’s stated aim with the DNA Proposal is to establish a “modern and simplified legal framework that incentivises the transition from legacy networks to fibre, high quality 5G and 6G networks, and cloud-based infrastructures, as well as increased scale through service provision and cross-border operation.” To do this, the DNA Proposal would replace and consolidate several existing EU laws, including the European Electronic Communications Code (“EECC”), the BEREC Regulation, and parts of the Open Internet Regulation and e-Privacy Directive.

A key theme of the proposal is harmonization of rules—arising first and foremost from the fact that this is a directly-applicable Regulation rather than a Directive like the current European Electronic Communications Code. Several of the substantive provisions in the DNA Proposal may take a significant amount of influence over the communications networks and services away from Member State governments and up to EU level. In turn, the Commission clearly hopes to promote larger-scale communications network and service providers that can operate across the EU, and that have the funds to invest in modern communications infrastructure. The DNA Proposal could, therefore, have a substantial and long-lasting impact on the connectivity and communications markets in the EU, although we anticipate significant debate about many of the provisions of the DNA Proposal throughout the legislative process.

Below, we summarize seven of the most eye-catching changes to the regulatory framework for communications providers in the DNA Proposal.