Proposed Digital Network Act: Euralarm welcomes overall objective of facilitating technological evolution

Euralarm welcomes the overall objective of facilitating technological evolution while safeguarding continuity, legal certainty and the interests of end-users and critical services.

Euralarm has repeatedly raised concerns with the European Commission, including DG CONNECT, about the risks created by unplanned or short-notice timelines for network switch-off, particularly for fire safety, detection and alarm systems that depend on reliable communication networks. Against this background, the proposal’s approach to predictability and advance notice represents an important and constructive development.

In this context, particular attention should be paid to the provisions governing the switch-off of existing communication networks, notably Recital 36 and Article 5 of the proposal.

Background

The progressive switch-off of legacy communication networks is an inevitable part of technological development. However, such transitions must be carefully managed to avoid disruption, especially for users and services that rely on stable, always-available connectivity. Predictability, transparency and adequate preparation time are therefore essential elements of any switch-off process.

Recital 30 – Predictability and legal certainty

Recital 30 underlines the importance of orderly network transitions, stressing that stakeholders must be able to anticipate and prepare for network switch-off decisions. This recital reflects a key principle: network operators, service providers, public authorities and end-users all require sufficient visibility regarding when a network will be withdrawn and under what conditions.

From Euralarm’s perspective, this predictability is particularly critical for safety- and security-related systems, which often have long life cycles and are subject to regulatory, contractual and technical constraints. Abrupt or insufficiently announced switch-offs could create serious operational and safety risks.

Article 5 – Timing between announcement and switch-off

Article 5 further reinforces these principles by addressing the practical aspects of network switch-off, notably the relationship between the announcement of a switch-off and its effective implementation. The provision rightly recognises that a clear and sufficiently long period must elapse between the formal notification of a switch-off decision and the actual decommissioning of the network.

This time period is essential to allow:

• technical adaptation or migration to alternative networks;
• testing and certification of replacement solutions;
• contractual and operational adjustments by service providers and users; and
• coordinated planning for complex installations, including those linked to life-safety and security applications.

Euralarm considers it crucial that this interval be not only clearly defined, but also proportionate to the complexity and criticality of the services concerned, with flexibility where justified, therefore Euralarm would also support the definition of a interval longer than the 2 years include in the first proposal.

Call for support

Recital 30 and Article 5 together form a coherent framework that promotes an orderly, transparent and predictable approach to network switch-off. Their correct implementation will be key to ensuring that technological progress does not come at the expense of service continuity, safety or user confidence.

Euralarm therefore calls on stakeholders from the fire safety, detection and alarm industry to publicly support the proposed text as it stands, and to encourage policymakers to maintain these provisions unchanged throughout the legislative process. Preserving the current balance is essential to avoid uncertainty, ensure continuity of critical services, and provide industry and end-users with the stability required to plan and invest responsibly.