GSMA response to the Call for Evidence for the Report on the review of the Digital Decade Policy Programme - GSMA Europe
Friday December 19, 2025

GSMA response to the Call for Evidence for the Report on the review of the Digital Decade Policy Programme

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The GSMA welcomes the opportunity to submit feedback to the European Commission’s call for evidence for the Report on the review of the Digital Decade Policy Programme (DDPP).

European telecoms are the backbone of Europe’s digital competitiveness. Widespread availability of state-of-the-art, secure and resilient connectivity infrastructure is equally crucial for the EU’s overall competitiveness vis-à-vis other world regions and the fundamental ambition of the Digital Decade 2030 to “[promote] a human-centred, fundamental-rights-based, inclusive, transparent and open digital environment”. Competitiveness should be at the core of EU’s strategic thinking, and can only be achieved with a strengthened and financially sustainable EU telecommunications sector, that and enables the necessary investments into connectivity infrastructure, cybersecurity, and advanced digital services for the overall benefit of European citizens, industry, and the public sector. Financially healthy telecom operators will enable European companies to compete globally. A financially strong telecommunications sector capable of undertaking the required investments should be added to the Digital Decade 2030 general objectives in Article 3, which already contains a reference to a ‘competitive data cloud infrastructure’ (article 3, paragraph 1(e)).

Given the long timelines of major digital investments, particularly large-scale, capital-intensive digital infrastructure, a more long-term and predictable policy framework, could greatly enhance planning certainty.

Today, all together, building full gigabit coverage for Europe is estimated to require significant investment. The GSMAi 5G index shows Europe lagging, on average, significantly behind other regions on 5G coverage and speeds[1][2], While public funding can be useful, it is unlikely to bridge that gap on its own. It is also important to ensure that it does not crowd out private investments and that it is used only in cases of market failure.

Yet another challenge of EU digital infrastructure markets is its fragmentation compared to other regions of the world. This prevents reaching the necessary economies of scale, which in turn limit our possibilities to invest in more resilient networks and innovative services for our customers, end-users and industries alike. Fragmentation of policies has also taken a toll on our industry’s global competitiveness, via numerous national divergences and gold-plating in areas where EU harmonisation makes perfect sense, such as pro-investment spectrum licencing and usage rules.

Efforts to address this fragmentation should focus on harmonization and enabling scale, while ensuring that any measures taken are risk-based, proportionate, and do not unnecessarily restrict access to innovative, best-in-class global technologies. The objective is to strengthen Europe’s competitiveness and resilience through open, fair, and non-discriminatory policies.

For the DDPP, the priority at this stage is not to define new targets or KPIs. Instead, what is needed is, first, a genuinely ambitious reform of the telecom regulatory framework with the DNA — one that enables the EU to meet the targets already in place. Second, we urge a reform of EU competition policy to foster investment and enable scale. Finally, stakeholders’ involvement in the DDPP process could be further enhanced.

In our response, we highlight some key areas to improve telecom operators’ investment capacity in best-in-class connectivity networks and services.


[1] Spectrum Pricing and Renewals in Europe

[2] Mobile Connectivity Index

For more information, please contact:

pfako@gsma.com