Connected - February 2025

Written By

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Willy Mikalef

Partner
France

I am a tech-friendly lawyer based in Paris, specialising in data protection, communications and satellites, with a commitment to providing business-oriented, sustainable advice.

The February 2025 edition has been edited by Willy Mikalef with contributions from the Regulatory & Public Affairs team.

In this month’s edition, we delve into a broad array of pivotal topics shaping the tech regulatory landscape. We begin by outlining the key takeaways of the Paris AI Summit, and the latest GDPR enforcement measures taken in Italy against DeepSeek AI. Our focus then shifts to telecom regulatory updates in the UK, the Netherlands and Spain. 

We explore the implementation of NIS2 Directive in Spain, and ACM’s new responsibility as the supervisory body for the implementation of the DSA in the Netherlands. This newsletter also highlights the pre-release of the latest iteration of the UK digital identity and attributes trust framework.

Furthermore, we provide insights into a public consultation for telco providers in Spain regarding a revised framework for subscriber data, and another consultation in the UK on ransomware incident reporting. Finally, we cast our gaze towards the horizon with an analysis of the future of EU’s Digital Policy, and the key takeaways from the European Space Conference.

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Paris AI Summit: Policy and regulatory implications

The Paris AI Summit, held on 10-11 February 2025, marked a turning point in Europe's artificial intelligence (AI) strategy. Bringing together heads of state, business leaders, and AI experts, the event sought to position Europe as a major player in the global AI landscape.

READ THE FULL STORY

For more information, please contact Willy Mikalef and Pauline Pilain.


UK: Ofcom updates

We provide an update on three recent developments from Ofcom, the UK’s communications regulator, covering net neutrality, efforts to combat scam calls and proposals to set maximum rates for wholesale Application-to-Person SMS termination.

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For more information, please contact Anthony Rosen.


The Garante imposes a definitive limitation on the processing of Italian users’ personal data

On 30 January 2025, the Italian Data Protection Authority (Garante or Authority) imposed, as a matter of urgency and with immediate effect, a definitive limitation on the processing of Italian users’ personal data on Hangzhou DeepSeek Artificial Intelligence and Beijing DeepSeek Artificial Intelligence (the “Companies”), the Chinese companies providing the DeepSeek chatbot service (DeepSeek). DeepSeek is an open-source large language model (LLM) that has gained attention for its cost-efficient development process.

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For more information, please contact Adriano D'Ottavio.


Draft Law on Cybersecurity Coordination and Governance

On 14 January 2025, the Council of Ministers approved the Draft Law on Cybersecurity Coordination and Governance, which aims to transpose the NIS2 Directive, in effect since January 2023, into Spanish law.

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For more information, please contact Joaquin Muñoz and Marzena Ewa.


Netherlands: Latest telecom regulatory developments

We provide an update on three recent developments from the Dutch telecommunications industry. We cover the notification of a new decision on fixed and mobile call termination, a fine imposed on Vodafone for security lapses in interception systems, and the ACM's exploration of the 2G and 3G network phase-out.

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For more information, please contact Raoul Grifoni Waterman and Wilfred Steenbruggen.


CNMC consults on the draft circular on the provision of subscriber data

The Spanish National Commission for Markets and Competition (CNMC) has published a consultation seeking comments on the proposed updated circular on the provision of subscriber data for emergency services, telephone directories and enquiry services (draft Circular).

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For more information, please contact Alejandro Sola.


UK Government consults on ransomware incident reporting

As part of its focus on cybersecurity in 2025, the UK Government’s Home Office is consulting on new ransomware incident response rules aimed at reducing payments made by victims of ransomware incidents and increasing the government’s ability to respond to these attacks.

The Government’s proposals are part of wider plans to reform UK cybersecurity rules which were announced last year and are expected to take shape in 2025.

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For more information, please contact Rory Coutts and Matthew Buckwell.

OfDIA announces the Gamma Trust Framework

The Office for Digital Identities and Attributes (OfDIA) has published a pre-release of the latest iteration of the UK digital identity and attributes trust framework (Trust Framework) (gamma version). This is the fourth iteration of the Trust Framework, which was first published in 2021.

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For more information, please contact Elizabeth Dunn and Callum Granger.

To setting the national DSA scene: ACM designated with starring supervisory role

On 4 February 2025, the Dutch Authority for Consumers and Markets (ACM) was officially designated as the supervisory body for the enforcement of the Digital Services Act (DSA) in the Netherlands in the DSA Implementation Act. This development marks a significant step in the enforcement of the European digital regulatory framework on the Dutch market. The DSA aims to create a safer and more transparent digital environment by preventing illegal and harmful activities online and providing for enhanced user rights. The ACM is given a ‘starring role’ to act as the primary Dutch Digital Services Coordinator (i.e. national authority supervising the DSA) and is therefore now officially vested with powers to supervise and enforce the DSA nationally. The proactive attitude of the ACM since the entry into force of the DSA could lead to interesting developments in the Netherlands.

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For more information, please contact Pauline Kuipers, Roelien van Neck, Joost van Roosmalen, Quirijn Mohr and Frederik Westbroek.


Competitiveness Compass outlines vision for Europe’s digital future

An initiative aimed at reinforcing competitiveness as a fundamental principle for the European Union, the Competitiveness Compass, was launched by the European Commission on 29 January. The Competitiveness Compass presents a strategic vision for Europe's future, emphasising the importance of competitiveness in fostering innovation, advancing technology and driving economic growth. Influenced by the report on The Future of European Competitiveness by Mario Draghi, the former European Central Bank President, the Compass outlines three elements to boost competitiveness: bridging the innovation divide, creating a shared roadmap for decarbonisation and competitiveness, and reducing excessive dependencies whilst enhancing security.

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For more information, please contact Paula Alexe.


Paving the future of Europe’s space ambitions

The 17th European Space Conference, held on 28-29 January 2025, in Brussels, was a gathering of policymakers, industry leaders, and experts with the ambition to shape the trajectory of Europe’s space sector. The forum served as a platform for outlining Europe’s strategic direction in space technology, defense, and industrial policy. Whether in industrial competitiveness, strategic autonomy, or technological leadership, stakeholders emphasised the need for decisive policymaking and sustained investment.

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For more information, please contact Willy Mikalef and Elie Badawi.

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