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

Download our full analysis for details:

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And find out more on our DNA coverage in the Cullen Digital Networks Act (DNA) Hub.

Clients of our European Telecoms service, can access the analysis directly on our client portal via the following link: