Binding rules on spectrum fees, an EU authorisation regime for satellite services, a new EU access product and a “conciliation" process for IP interconnection disputes are among the main elements of the upcoming Digital Networks Act (DNA, Tracker).

The preliminary observations below are based on a leaked version of the draft DNA, still subject to change, seen by Cullen International. A more comprehensive analysis will follow once the European Commission has published the final version on 20 January 2026.

According to our analysis, these are the 11 key takeways:

1. A regulation after all
2. No extension of the framework to cloud
3. Undetermined spectrum licence duration and spectrum sharing
4. Harmonisation of spectrum fees and binding oversight
5. Market analysis: an EU-level access product as the remedy of choice
6. General authorisation: single passport procedure
7. From network contribution fees to a “facility for voluntary conciliation”
8. Copper decommissioning by 2035, subject to conditions
9. Single EU-level satellite framework to replace national athorisation
10. Net neutrality included in the DNA
11. Governance: renamed BEREC office, revamped RSPG

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