Summary

  • COM(2026) 16 proposes one general-authorisation notification to a national regulator, followed by an EU-level information and confirmation process.
  • The text still preserves country-specific conditions, separate spectrum and numbering rights, national contact points and enforcement powers.

The word “passport” suggests that one permit should open every border. The European Commission’s proposed Digital Networks Act is narrower and more procedural. Under Articles 9–11, a provider intending to offer electronic communications networks or services in several Member States would notify the regulator of one country in which it intends to operate. That regulator would forward the filing to the proposed Office for Digital Networks (ODN), which would share it with the competent authorities in the other service countries. The first regulator would then confirm the general authorisation within a week.

That is a meaningful change from a system in which a provider might face a separate prior administrative act in each market. Article 10 says the provider would not need another decision or administrative act from a regulator of the Member State of notification before exercising rights derived from the general authorisation. Once confirmation arrives, the provider could begin activity, subject where necessary to separate rights of use.

But a single notification is not a single, all-purpose licence. Article 9 spells out what remains inside the operating perimeter, and Article 10 routes information to the countries where the service will actually be provided. The practical promise is fewer repeated entry steps. The institutional question is how a provider, regulator or customer can tell which authority owns each obligation when something goes wrong.

The proposal begins with a common general-authorisation regime. Its proposed conditions cover network resilience, emergency communications, referenced standards, cybersecurity and ICT supply-chain requirements, access for law-enforcement and judicial authorities, network integrity, interconnection and service interoperability. Some conditions draw directly on Union rules; others expressly refer to applicable national law in the Member States where service is provided. The proposal therefore makes national information part of the passport rather than pretending that every rule is identical.

Article 11 would require each Member State to designate a national single contact point. That office would keep current information about national legislation and procedures, including cybersecurity, access to data and data protection, and communicate it to the ODN. BEREC, working with the Commission and competent authorities, would issue guidelines on coherent, nondiscriminatory and proportionate application of the authorisation conditions. The proposed deadline is six months after the Regulation enters into force. It has not started: the file remains a proposal.

Other entry rights remain distinct. The text preserves additional conditions for using radio spectrum and numbering resources. A provider may receive general authorisation through the passport yet still need the relevant right of use under the DNA’s spectrum and numbering provisions. Nor does Article 10 remove administrative charges; Article 12 would constrain them to specified costs and require transparent, proportionate treatment and annual reporting.

The more difficult design choice appears after notification. The proposed national regulator of the notification country would normally have power to impose penalties for breaches of general-authorisation conditions. In a serious case, it could withdraw the right to operate across the countries covered by the passport, after consultation where necessary. At the same time, a regulator in a service country would retain power to penalise a breach with a serious negative impact there on national-security or public-interest grounds. Member States would also retain enforcement powers over applicable law in their own jurisdictions.

This is not simple centralisation. The notification regulator becomes a potential enforcement anchor; service-country authorities keep a narrower but consequential route; national contact points are expected to help coordinate facts and procedures. Whether those roles fit together will depend on the implementing details, including how authorities share evidence, avoid double penalties and identify the rule that was breached. The proposal says BEREC should help harmonise application, while leaving room for Commission implementing acts to specify notification, confirmation and mutual assistance.

The proposed public Union database adds another accountability layer. The ODN would maintain notifications and notified authorities would update entries at least every two months. A database can show that a filing was made and which countries were named. By itself it cannot prove that a service launched, that a spectrum right was granted, that local conditions were met or that customers received service. Those are separate facts and should not be collapsed into a passport record.

The transition is also conditional. Networks and services notified before a date set at six months after the Regulation enters into force would not need a new notification; providers could choose to seek a new general authorisation under the passport. New networks or services deployed after that transition point would enter the proposed process. Until lawmakers agree on the text and it enters into force, no calendar date or live application pathway can be inferred.

The legislative file is still moving. The European Parliament’s Legislative Observatory lists the ordinary procedure as awaiting a committee decision. In June, EU telecommunications ministers broadly supported the objectives but said the Single Passport required further work, alongside concerns about national circumstances, spectrum competence and security. Those records describe an open negotiation, not a settled institutional bargain.

For operators, the useful test is not whether the final act retains the name “passport.” It is whether one complete filing produces a timely confirmation, accurately communicates the conditions in every service country, and identifies who can respond to a breach. A provider expanding into another state will also need to separate general authorisation from spectrum, numbering, charges and any other rights of use. The form may become singular; the compliance map will not.

Heng Lu Note 64 informed the editorial lens on the boundary between a common initial interface and decisions left to local institutions. It is not evidence about EU law, and the proposed regulation is a binding legislative design rather than a voluntary coordination system.

Primary references: Commission proposal COM(2026) 16, Articles 9–12; European Parliament procedure 2026/0013(COD); Council telecommunications meeting, 9 June 2026; Commission overview of the Digital Networks Act; Heng Lu, Note 64.