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17 December 2025

Horizon Scanner: Energy, Planning, Infrastructure And Construction December 2025 - Digital Infrastructure

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Two proposals to simplify existing digital legislation and stimulate growth make up the European Commission's Digital Package on Simplification, published on 19 November 2025.
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DIGITAL SIMPLIFICATION AND CONSOLDATION

Two proposals to simplify existing digital legislation and stimulate growth make up the European Commission's Digital Package on Simplification, published on 19 November 2025.

The first proposal focuses primarily on: (a) consolidating the EU's data legislation; and (b) making targeted amendments to the GDPR. The second proposal focuses on targeted simplification measures for the Artificial Intelligence Act.

The proposals will undergo inter-institutional negotiations before they can be adopted. Further information on the package, including proposed amendments to the data rules, the GDPR and cookie rules, is available here: Simpler EU digital rules and new digital wallets to save billions for businesses and boost innovation.

NOTICE OF SUSPECTED NON-COMPLIANCE

ComReg issued a notice of suspected non-compliance to Eircom Limited pursuant to section 63 of the Communications Regulation and Digital Development Hub Agency (Amendment) Act 2023. It relates to Eircom's dealing with a request for access by NBI Infrastructure DAC to Eircom's duct network in accordance with Eircom's obligations under ComReg Decision D10/18. ComReg suspects that Eircom did not comply with its obligations to meet reasonable requests for access to its Civil Engineering Infrastructure. Eircom has until 16 January 2026 to make written submissions.

EUROPEAN DIGITAL SOVEREIGNTY

The Minister of State for Trade Promotion, AI and Digital Transformation signed the Declaration for European Digital Sovereignty on behalf of Ireland. The Declaration reaffirms Ireland's commitment to building a digitally sovereign Europe and establishes a common framework for enhancing Europe's digital capabilities, while preserving access to open markets, interoperability and international collaboration.

DISTRICT COURT PROSECUTION

ComReg reported on a hearing in the District Court in Macroom concerning a criminal prosecution against VOIP and Internet Services Limited, trading as Tipp Broadband and Rural Broadband. The case involved four counts of non-compliance with obligations under the Communications Regulation Act 2002 and the Communications Regulation and Digital Hub Development Agency (Amendment) Act 2023. VOIP and Internet Services Limited has since lodged an appeal against the penalty.

CONSUMER CARE STATISTICS REPORT Q3 2025

ComReg published its Consumer Care Statistics Report for Q3 2025 (1 July to 30 September). During that period, ComReg recorded 4,200 issues, compared to 3,300 issues in Q2. 91% of all issues recorded were queries and 8% were complaints. There was a 28% increase in the number of issues recorded compared to the same period in 2024.

DPROGRAMME OF MEASUREMENT OF NON-IONISING RADIATION

As the body responsible for the management of Ireland's radio frequency spectrum, ComReg publishes interim reports summarising the results of Non-Ionising Radiation surveys conducted in proximity to a sample of licensed transmitter sites. It has published its second interim report of 2025, summarising the results of surveys carried out in September 2025 by Compliance Engineering Ireland Ltd.

SATELLITE EARTH STATION LICENCES

Earlier this year, ComReg consulted on applications from Starlink Internet Services Limited and Amazon Kuiper Services Europe SARL for satellite earth stations ("SES") licences. At that stage, ComReg published Information Notices setting out its preliminary views that the proposed SES would not cause harmful interference to other SES and fixed radio links already operating in the relevant frequency band and proposed to grant licences for the proposed SES. Following the consultation, ComReg has published a summary of submissions received to its Information Notices, concluding that it will grant the licences.

BROADCASTING TRANSMISSION SEVICES

ComReg published a draft decision following its review of the Broadcasting Transmission Services ("BTS") markets in Ireland. The decision presents ComReg's analysis of the wholesale BTS market by examining the Relevant Retail TV Broadcast Market and the Relevant Radio Broadcast Market to determine whether any service provider has significant market power and, if so, to impose any appropriate remedies. A non-confidential version of the submissions to the consultation is available here: Broadcasting-Transmission-Services-Draft-Decision.

ADMINISTRATIVE SANCTION GUIDELINES

ComReg consulted on its Proposed Administrative Sanction Guidelines, which are intended to provide guidance in respect of the calculation of administrative financial sanctions, the award of compensation, the award of refunds, and the suspension or withdrawal of authorisation or rights of use for radio spectrum or numbering resources.

UNIVERSAL SERVICE FUNDING

As the designated universal service provider until 30 June 2023, eir submitted a request for compensation in relation to the net cost of providing universal service obligation ("USO") services for the years 2010-2011, 2012-2013, 2013-2014, 2014-2015 and 2015-2016. ComReg determined that, in the financial years for which eir requested compensation, the net cost of the provision of the USO did not represent an unfair burden on eir. ComReg considers that the matter of USO funding relating to periods prior to June 2023 is now finalised.

CALL HANDLING FEE REVIEW FOR 2026-2027

ComReg has published its review of the Emergency Call Answering Service maximum permitted call handling fee for the period 12 February 2026 to 11 February 2027, with the underlying report for assessing the fee. ComReg considers factors including the expected rate of call volumes, depreciation and any changes to operating costs, and proposes a maximum call handling fee for 2026 of €3.96.

This article contains a general summary of developments and is not a complete or definitive statement of the law. Specific legal advice should be obtained where appropriate.

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