The Confederation of European Security Services (CoESS) welcomes the European Commission’s proposal for a Digital Networks Act as an important step towards more resilient and transparent digital infrastructure in Europe. The proposal reflects key concerns raised by the private security sector, particularly the need for better coordination and transparency in the transition from legacy 2G/3G networks to newer technologies. Provisions requiring network operators to plan and communicate migration roadmaps are essential to ensure business continuity for critical services such as alarm monitoring and response.

These improvements are particularly important given the continued reliance of Monitoring and Alarm Receiving Centres (MARCs) on legacy networks across Europe. Reliable connectivity is crucial for detecting incidents and ensuring timely intervention, especially in the protection of critical infrastructure and public safety. The proposed obligations on operators to guarantee uninterrupted availability of emergency communications therefore represent a positive and necessary step forward.

However, CoESS highlights that the proposed minimum two-year notification period for network migrations does not reflect the operational realities of the sector. Alarm systems and communication technologies often have long lifecycles, and upgrading large installed bases across Europe is complex, time-consuming and costly. Based on industry experience, such transitions typically require five to seven years to be completed safely and efficiently.

For this reason, CoESS calls on EU co-legislators to extend the minimum transition period to at least five years. A longer timeframe would ensure a smooth migration, avoid unnecessary costs, and most importantly guarantee uninterrupted protection for citizens, businesses and critical infrastructure.

The full position paper can be found here.