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EUROPEAN COMMISSION

Brussels, 30.9.2026

COM(2026) 1010 final

2026/0301 (COD)

Proposal for a

REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL

establishing the European Union Critical Communication System (EUCCS)

{SEC(2026) 1010 final} - {SWD(2026) 1010 final} - {SWD(2026) 1011 final}

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CONTEXT OF THE PROPOSAL

• Reasons for and objectives of the proposal

In any emergency situation, from floods and earthquakes to terrorist attacks, fires and traffic

accidents, people rely on first responders and emergency services, such as law enforcement,

rescue and medical services, and firefighters, for help. To provide help effectively, these first

responders and emergency services need to be able to communicate and coordinate. Each

Member State therefore provides dedicated, non-public, and secure communications systems

for its emergency services (“critical communications systems”). These are mobile radio

communication systems used by emergency services1 that meet specific requirements in terms

of reliability, security and availability. These systems are built to withstand disruption and

continue to operate even when other communication channels fail. They are crucial for

coordinating the response to emergency and crises and thus ultimately help save lives.

However, these national systems reach their limits when first responders cross borders or

when they need to communicate with first responders from another Member State.

Emergencies, especially major emergencies, often affect several Member States or require

support from services from other Member State. An effective response to such emergencies,

as well as the daily protection of citizens across the Union and the Schengen area, require that

emergency services can cooperate with each other whenever and wherever they are, and can

communicate seamlessly across the EU. Yet today, there is no European system that allows

critical cross-border communication. This can complicate and delay the response in scenarios

like joint police patrols, hot pursuits across borders, as well as accidents or major disasters

such as fire or flood. In all these scenarios, most emergency services in Europe must rely on

ad-hoc arrangements, such as the physical exchange of radios, creating a patchwork of

different communication solutions or using commercial phones that are neither designed nor

equipped for public security and safety tasks. Efficient and seamless communication is

however not a matter of convenience: the ability to communicate defines the speed in which

emergency services can react. And that in turn defines how fast they can save lives.

The European Union Critical Communication System (EUCCS) aims to provide a European

solution, to equip those who protect us with the best communication means to fulfil their

mission. EUCCS will serve more than 5 million first responders in emergency services2

across Europe in their daily life-saving operations and during major emergencies. It will

significantly increase Europe’s response capability both in times of large-scale crises, but also

in daily emergencies, accidents, missing persons, crime and terrorism.

The 2015-16 wave of terrorist attacks, which brought to light the lack of communication

among emergency services in major crisis situations, showed the clear need for greater

1 ‘Emergency service’ means a service, recognised as such by the Member State, that provides immediate

and rapid assistance in situations where there is, in particular, a direct risk to life or limb, to individual

or public health or safety, to private or public property, or to the environment, in accordance with

national law. https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32018L1972. 2 The figure represents the number of expected users of EUCCS, as communicated by Member States.

this is not the number of interventions, but of personnel that uses critical communication means, and

thus will benefit directly from EUCCS. The number is based on a questionnaire to Member States’

competent authorities in which they were asked for report the expected number of users (such as police

officers, firefighters, medical services) to DG HOME.

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interconnectivity and interoperability of critical communications. This need led to the launch

of technical and operational coordination projects that prepared the EUCCS. The Covid-19

Pandemic, large-scale natural disasters such as wildfires, as well as the Russian war of

aggression against Ukraine further highlighted the importance of improved critical

communication capabilities, across different sectors. The initiative thus builds on, and is part

of, a long-term and strategic approach that is based on concrete operational needs.

EUCCS directly addresses the operational needs expressed by Member States and emergency

responders. Building on the results of EU-funded security research projects carried out in

2016-2023 - with involvement of first responders - the Commission is currently developing

with Member States the technical framework for EUCCS. In 2023, DG HOME established the

Mission Critical Communication Group (MCCG), comprising experts in the field of critical

communication from the EU Member States, the Schengen Associated countries, and EU

Agencies. This demonstrates the strong involvement of Member States, who had specifically

requested leadership by the Commission on EUCCS with the common understanding that

only EU-level action would be able to deliver such an ambitious system.

The legal framework presented in this Regulation is a light regulatory approach with a

minimum set of binding rules at EU level. This solution responds best to the complex

technological, operational, legal and political needs of the initiative. EUCCS creates a ‘system

of systems’ in which Member States remain in full control of their critical communication

systems, with mandatory inter-operability. At the EU-level, there would be no central data

management infrastructure. Rather, a technical interconnection infrastructure overseen by a

light governance component consisting of national Competent Authorities represented in a

European Union Critical Communication Group would provide the basis for interoperability,

as well as common support functions for Member States’ systems and operations. The system

is planned to be built in a gradual approach, taking into account the different stages of

transition to broadband communication of Member States’ national critical communication

systems. A first group of Member States should start operations in 2030, followed by the

other Member States in 2033 and 2036, the latter being the final deadline by which all

Member States must connect to the EUCCS. This flexibility allows Member States to adapt

their adherence to the EUCCS to the progress at national level, while already providing the

full benefits of the interoperability to those Member States that are ready earlier.

The system will cover the whole EU and – in view of the need and benefit of including the

full Schengen area – also the Schengen Associated Countries. For EUCCS to unfold its full

added value and to allow comprehensive communication and coordination in case of major

emergencies, it is essential that it covers all emergency services: law enforcement,

firefighters3, civil protection and medical emergency responders. This proposal is therefore

intrinsically linked with the proposal for a Regulation establishing the framework for the use

3 In line with the importance of tools in terms of connectivity, communication and coordination like the

European firefighting hub based in Cyprus announced by the President of the European Commission in

State of the Union Address 2025.

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of the European Union Critical Communication System by the Member States’ services and

other organisations in charge of civil protection.

• Consistency with existing provisions in the policy area

In the field of critical communication, an EU acquis does not yet exist. Member States’

critical communication systems are operating independently without legal harmonisation and

with limited interoperability.

• Consistency with other Union policies

The proposed Regulation establishes the legal basis for the EUCCS in line with the provisions

laid down in accordance with the existing and proposed legal acts in the area of civil

protection, space and defence, cybersecurity, digital innovation and infrastructure and

connectivity, including spectrum related aspects. Specifically, the Union Civil Protection

Mechanism4 establishes operational cooperation between Member States in emergency

response. The 112 and eCall provisions as part of the European Electronic Communications

Code5 and the Digital Networks Act6 regulate the electronic communications sector.

Regarding mobile satellite systems (MSS) management it takes into account the recently

proposed MSS Regulation7. For what concerns coverage and backup, the proposed EUCCS

regulation is in line with the Space Programme, in particular its secure connectivity

component. Finally, it is coherent with the Network and Information Security 2 (NIS2)8 and

Critical Entities Resilience (CER)9 Directives. The proposed Regulation complements the

regulatory landscape by determining resilience requirements for Member States’ critical

communication systems that are aligned with NIS-2 and CER, as well as the Cyber Resilience

Act to be fully applicable as of 11 December 2027.

The proposal is consistent with the Council Conclusions of 7 June 2021 on the protection of

public spaces10, which emphasised the importance of secure, interoperable mission-critical

communication. The EU Space Strategy for Security and Defence11 was the first European

Commission document to identify the creation of a European Union Critical Communication

System as a policy objective.12 In 2024, the political commitment was confirmed in the

4 Proposal for a Regulation of the European Parliament and of the Council on the Union Civil Protection

Mechanism and Union support for health emergency preparedness and response, and repealing Decision

No 1313/2013/EU (Union Civil Protection Mechanism) COM(2025) 548 final. 5 Directive (EU) 2018/1972 of the European Parliament and of the Council of 11 December 2018

establishing the European Electronic Communications Code. 6 Proposal for a Regulation of the European Parliament and of the Council on digital networks, amending

Regulation (EU) 2015/2120, Directive 2002/58/EC and Decision No 676/2002/EC and repealing

Regulation (EU) 2018/1971, Directive (EU) 2018/1972 and Decision No 243/2012/EU (Digital

Networks Act) COM(2026) 16 final. 7 Proposal for a Regulation of the European Parliament and of the Council on the procedure for

authorisation of systems providing mobile satellite services using the harmonised 2 GHz frequency

band and repealing Decision No 626/2008/EC. COM(2026) 0134 final. 8 https://eur-lex.europa.eu/eli/dir/2022/2555/oj/eng 9 https://eur-lex.europa.eu/eli/dir/2022/2557/oj/eng 10 Council Conclusions 9545/21 on the Protection of Public Spaces (2021); Council Recommendation (EU) 2022/915

on operational law enforcement cooperation (2022); 11 https://ec.europa.eu/transparency/documents-register/detail?ref=JOIN(2023)9&lang=en 12 https://defence-industry-space.ec.europa.eu/eu-space/eu-space-strategy-security-and-defence_en.

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Commission White Paper ‘How to master Europe’s digital infrastructure needs’, which

announced the establishment of EUCCS by 2030.13 Further momentum came with the 2024–

2029 Political Guidelines of Commission President von der Leyen, which stated that “our

united approach to security should be centred around a new European Critical

Communication System (…)”. The Niinistö Report14 also urged the EU to complete the

EUCCS as soon as possible and recommended to ensure its interoperability with systems used

by armed forces. This direction was reaffirmed in 2025 in ProtectEU – the European Internal

Security Strategy15 and the European Preparedness Union Strategy16, both announcing a

legislative initiative. The Preparedness Union Strategy specifically highlights the effects of

recent crises on multiple sectors and promotes a whole-of-government approach, bringing

together all relevant actors, across all levels of government, ensuring collaboration and

sharing of resources, to which the EUCCS would contribute.

1. LEGAL BASIS, SUBSIDIARITY AND PROPORTIONALITY

• Legal basis

The legal basis is Article 87(2)(a) of the Treaty of the Functioning of the European Union.

Article 87(1) of the Treaty of the European Union lays down the legal basis for the

establishment of police cooperation, including police, customs and other specialized law

enforcement services in relation to prevention, detection and investigation of criminal

offences. In this regard, Article 87(2)(a) of the Treaty of the Functioning of the European

Union provides for the possibility to establish measures concerning the collection, storage,

processing, analysis and exchange of relevant information. This includes the development of

necessary technical infrastructure.

Article 87(2)(a) of the Treaty of the Functioning of the European Union is the appropriate

legal basis for the establishment of the European Union Critical Communication System for

law enforcement authorities across borders among Member States and Schengen Associated

Countries. This regulation constitutes further development of the Schengen acquis, as it

further develops the Decision of the Executive Committee of 28 April 1999 on the Schengen

acquis relating to telecommunications.

• Subsidiarity

This proposal responds to calls from Member States and first responders for action at EU

level to facilitate and establish a legal framework for broader critical communication among

Member States as system of systems. The proposal aims to create a Union-wide interoperable

communication system for first responders by interconnecting the national systems, ensuring

seamless coordination during emergencies across Member States.

13 European Commission, White Paper: How to Master Europe’s Digital Infrastructure Needs (2024)

https://digital-strategy.ec.europa.eu/en/library/white-paper-how-master-europes-digital-infrastructure-

needs. 14 Niinistö, S. (2024), Safer Together – Strengthening Europe’s Civilian and Military Preparedness and

Readiness, p. 59 and p. 69.15 COM (2025)148final (2025) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex:52025DC0148. 16 European Commission (2025), European Preparedness Union Strategy, JOIN(2025) 130 final.

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Given the transnational nature of the European Union Critical Communication System,

including standardisation, interoperability and cross-border cooperation among first

responders, EU action is necessary.

National rules are insufficient to guarantee the required interoperability, responsibility, and

resilience of the communication system as they cannot create the necessary binding EU-wide

interoperability framework. The measures set out in this proposal must be adopted at Union

level to achieve the intended cross-border objective of establishing the European Union

Critical Communication System. Therefore, Union action is justified under the principle of

subsidiarity.

• Proportionality

The proposal lays down rules for Member States and providers of publicly available

interpersonal communications services for the establishment of an effective, secure and

interoperable critical communication system. The proposal defines clear rules for Member

States to develop the required architecture and infrastructure for the EUCCS, including

minimum resilience and security standards. These technical and operational demands are

strictly limited to what is essential to ensure that the EUCCS functions as a cohesive and

secure network system, capable of supporting cross-border communication among public

security authorities. The interconnectivity between current communication networks enhances

the systems’ efficiency and operational readiness, ensuring that first responders and

emergency services can rely on secure communication channels during critical operations.

The proposal takes into account that a system of systems solution imposes requirements on

Member States and service providers in order to establish a decentralised EU framework that

allows the national critical communication systems to be interconnected. It creates a

framework for Member States to designate competent national authorities that are obliged to

ensure the interconnectivity of Member States’ critical communication systems. The chosen

form of a decentralised EU framework - i.e. without a central EU competent authority -

balances the necessary requirements to establish a functioning EU and Schengen wide

interoperable communication system and the respect for national autonomy, without imposing

excessive requirements on the Member States. This architecture ensures that the EUCCS

functions as a unified framework to enhance overall effectiveness.

The proposal also requires Member States to impose rules on telecommunications service

providers to ensure the use of their networks for critical communication. These requirements

ensure that existing infrastructure can support the operational needs of the EUCCS, without

placing disproportionate technical or financial demands on service providers.

The measures taken are limited to responding to the essential needs for the creation of a

resilient and secure cross-border critical communication system between Member States and

security agencies.

• Choice of the instrument

Given the nature of emergency services, which bring together several different authorities and

services from Member States, the EUCCS consists of two proposals relying on two different

legal bases to ensure comprehensive interoperability across all relevant services. The first –

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present – proposal is based on Article 87 (2) (a) of the Treaty on the Functioning of the

European Union (TFEU), which gives the European Parliament and the Council, acting in

accordance with the ordinary legislative procedure, the possibility to establish directives and

regulations to facilitate police cooperation.

To include all relevant emergency services in the EUCCS, the scope of the framework is

extended to civil protection services and other organisations in charge of public safety by a

second regulation, Regulation EU (…/…) on establishing the framework for the inclusion of

the Member States’ civil protection services and other organisations in charge of public safety

into the European Union Critical Communication System, which is proposed in parallel and is

based on Article 196 TFEU.

Given the need to ensure a light central governance structure and one clear and unified

interoperability framework interconnecting the national systems, a regulation is the

appropriate legal instrument.

The proposal aims to establish a Union-wide critical communication system across Member

States and Schengen associated countries, ensuring secure and interoperable cross-border

communication for public authorities. A regulation is necessary to achieve direct application

across all Member States, thereby guaranteeing consistent implementation without the risk of

divergent national approaches that could compromise interoperability. This also ensures the

system can be operational without delay, addressing urgent security needs effectively. A

regulation is the only suitable legal instrument for establishing the binding technical

specifications, security standards, and governance structures required to support such a

system.

2. RESULTS OF EX-POST EVALUATIONS, STAKEHOLDER

CONSULTATIONS AND IMPACT ASSESSMENTS

• Ex-post evaluations/fitness checks of existing legislation

As the Regulation relates to a new area with no existing legislation at EU level, this point

does not apply.

• Stakeholder consultations

The Commission collected data through various sources and consultations methods.

The EUCCS system is built in close cooperation with the European industry, therefore

directly contributing to the overarching priorities of strategic autonomy and competitiveness.

In compliance with the Better Regulation guidelines, DG HOME published a Call for

Evidence in April 2025 and commissioned an external study to support the Impact

Assessment. The research for the initiative and this impact assessment started with targeted

surveys and interviews with EU Member States, which took place from July 2025 until June

2026 and mapped how Member States authorities are currently implementing their critical

communications system.

A Commission Open Public Consultation was conducted from 16 January until 10 April 2026.

Commission services also conducted targeted surveys and organised dedicated meetings with

representatives of industry, such as providers of critical communication infrastructure and

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services and mobile network operators, as well as NGOs and other relevant associations,

which took place from July 2025 until June 2026.

• Collection and use of expertise

As mentioned in the preceding section, the Commission has drawn on external expertise in the

context of consultations with, e.g. independent experts, expert networks and members of

academia, in developing the proposal at hand.

• Impact assessment

This proposal is supported by an impact assessment, which analysed a range of policy options

to address the identified problems related to limited operational mobility, limited functionality

of legacy systems and insufficient resilience.

The general objective of EUCCS is to enhance Europe’s capacity to react swiftly and

effectively to incidents and crises that require response across borders and by cooperation of

different types of emergency services.

Three specific objectives have been identified as:

– Specific Objective no. 1: Promote interoperable and secure cross-border and

cross-agency/operator critical communication and operational mobility among

emergency services

The objective is to provide emergency services with a resilient critical communication

infrastructure. The system should enable seamless operational mobility, meaning the ability of

emergency services to communicate seamlessly whenever, wherever and with whomever they

are tasked to cooperate. It shall furthermore promote interoperability and strengthen cross-

border and cross-agency operational mobility for an enhanced emergency response.

Specifically, all the critical communication systems of law enforcement, civil protection, and

other emergency response services across Member States need to be harmonised and

interconnected.

– Specific Objective no. 2: Support Member States in deploying broadband

critical communication systems

The ability to exchange data-rich information, such as images or video, across borders and in

real time is a key driver behind Member States’ decision to upgrade the current narrowband

systems used, notably TETRA17. It is important to underline that EUCCS does not ‘replace’

TETRA. Rather, it is the technological shift to broadband that will phase out narrowband

technologies, similar to what happened in commercial telecommunication.

The transition to broadband is necessary for the deployment of interoperable 5G mission-

critical capabilities. Broadband communications technology satisfies the current and evolving

needs for increasing data consumption, supporting advanced functionalities, such as real time

incident reporting and facilitating the integration of Artificial Intelligence. Furthermore,

technological harmonisation will contribute to making national investment in critical

17 TETRA, or Terrestrial Trunked Radio is a global standard for digital radio technology. In contrast,

Tetrapol is a 1988 proprietary technology even if its specification is publicly available.

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communications attractive and help build a more integrated and technologically advanced

European critical communications ecosystem.

– Specific Objective no. 3: Facilitate the achievement of a high and consistent

level of resilience of critical communications across Member States

Resilient infrastructure is essential to ensure connectivity and availability in all circumstances.

In this context, resilience refers to the capacity of critical communication infrastructures to

withstand, absorb, and rapidly recover from natural hazards, man-made disasters or security

incidents. Notably this can be achieved by ensuring advanced backup power, redundant

coverage, the separation of mission critical core network and radio access networks, as well as

strong protocol and cryptographic security. A broadband system would also contribute to a

higher level of security by authentication allowing for stronger protection against

cyberattacks. Furthermore, achieving this specific objective would contribute to future-

proofing critical communication systems and increasing Europe’s strategic autonomy against

potential geopolitical developments harming EU interests.

On the basis of these objectives, the impact assessment that supported the development of this

initiative explored different policy options. Besides the baseline situation, which would entail

no change over the current situation, these options included:

– Policy Option 1: voluntary pursuit of technical interconnectivity

This policy option is based on voluntary measures to promote interconnection of critical

communication systems between Member States. This would include the publication of non-

binding guidance by the Commission. Similarly to the baseline scenario, Member States

would continue to develop their national critical communication systems independently. They

would either maintain narrowband systems or transition to broadband solutions, in line with

national strategies, priorities, and available resources.

In theory, PO1 addresses all problems and their drivers, however it is very unlikely to solve

any of them in a satisfactory manner. Given the voluntary nature it is extremely unlikely that

all Member States and all emergency services would participate in a ‘voluntary EUCCS’. The

consultation with Member States concluded that only eleven Member States would be willing

to work on interoperability of broadband systems in the absence of a binding EU framework.

The BroadMap and BroadWay projects (2016 – 2022) were based on a voluntary approach

that should lead to a coordinated procurement of inter-operable solutions. Experience gained

from those projects largely led to the common understanding of Member States and the

Commission services that only an approach based on binding EU-level rules is likely to

successfully establish EUCCS.

In PO1, the Mission Critical Communication Group would recommend relevant international

standards (e.g. those developed by the European Telecommunications Standards Institute or

3GPP) and promote common operational procedures to support interconnection among

participating Member States. EU funding of projects could be leveraged aligning to existing

priorities.

– Policy Option 2: adoption of an EU legal act providing a legal basis for the

establishment of a decentralised EU framework

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This policy option would establish a ‘system of systems’ enabling the interconnection of

Member States national critical communication systems while preserving Member States’

sovereignty over their national critical communication systems.

The legal act would set out objectives, roles and responsibilities, minimum technical

requirements, and cross-border procedures. Implementation would take place gradually

following a convergence period with an initial system connecting around eight to ten Member

States by 2030, followed by a progressive expansion of services and participation in 2033 and

2036.

At the EU level, there would be no central data management infrastructure or central

operations capacity but a governance, as well as common support functions for Member

States’ systems. Interconnection of Member States’ systems will be facilitated, and a central

EU level monitoring capacity will be established. The combination of those elements is the

EU-level component of EUCCS. Two sub-options exist that differentiate from each other

according to the level of centralisation of this EU-level component:

• In sub-option 2.1 the EU-level component is light with a stronger role of the

Member States, for which the current EUCCS Preparation Project will be

reinforced to become the EUCCS Cooperation Project and only the necessary

elements for facilitating interconnectivity, monitoring and support tasks being

handled at EU-level.

• In sub-option 2.2 a central EU competent authority covers tasks related to

facilitation on technical interconnectivity, common EU services as well as

monitoring of the implementation of EUCCS across Member States.

Policy Option 2.1 and Policy Option 2.2 present very similar benefits and impacts.

Policy Option 2.1 ensures a higher degree of coherence with existing EU policies and respects

the principle of proportionality, as its measures are appropriately calibrated to the scale of the

challenges addressed. The creation of the governance measures and the light EU component

are relatively easy to achieve.

There is a variation of the cost, as Policy Option 2.2 requires slightly less human resources at

EU level due to the centralised governance structure. However, Policy Option 2.2 would have

required the creation of an EU Agency, or the significant modification of an existing Agency

mandate and resources, to act as competent authority. The Commission has thoroughly

reviewed existing Agencies and none of them would have the necessary legal mandate to

cover the different first responder groups, as well as the resources and capacity to handle the

EU component of EUCCS. Creating a new Agency on the other hand was determined to be

disproportionate.

Considering these facts, Policy Option 2.1 emerges as the preferred option. This Policy

Option provides the most effective response to the identified problem, offering a

comprehensive and reliable framework for achieving the policy objectives. While it may

entail higher costs compared to Policy Option 1, these are justified by the significantly greater

benefits and the more substantial impacts generated across economic, social, and

environmental dimensions. By contrast, Policy Option 1, although less burdensome, is not

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expected to deliver sufficient impact to address the identified problems, limiting its overall

suitability.

Different types of impacts have been identified and assessed in the Impact Assessment,

including but not limited to:

• Social impacts: Significant and structural benefits through binding

interoperability, harmonized procedures, and full operational mobility for an

estimated 3.7 million first responders across the Union. Enhanced safety and

security for citizens.

• Economic impacts: Substantial public investment (€3.571 billion) required for

an interoperable EU-wide system. Medium- to long-term benefits include

economies of scale, a more integrated market, and opportunities for European

industry, particularly Small and Medium Enterprises (SMEs), in critical

communication services, infrastructure, and equipment.

• Environmental impacts: More positive and structurally significant benefits

through strengthened cross-border response capacity, enabling faster and more

coordinated interventions to mitigate environmental risks.

EUCCS strengthens the capacity of emergency services and supports efficient coordination in

emergency and crisis situations, accelerates response to disasters and emergencies, and

enhances accountability and reliability. The general and specific objectives of the EUCCS

contribute to various United Nations Sustainable Development Goals18, notably: SDG 11,

SDG 13 and SDG 16.

The Impact Assessment was subject to scrutiny by the Regulatory Scrutiny Board, which

issued a positive opinion with reservations on 22 May 2026. The Board suggested to identify

better the collection of evidence presented; describe in more details the intervention logic and

problem drivers, specifically what concerns the interoperability between Member States;

elaborate in more detail the EU added value, preparedness of the Member States’

technological solutions and future-proofness of the chosen policy option; and better clarify,

assess and compare the costs and benefits of the options, including their distribution among

the various stakeholders.

All these elements have been addressed in the final version of the Impact Assessment.

Lastly, the impact assessment explains that EUCCS will have positive impacts on the

environment, notably as it enhances the capability to respond to disasters with environmental

impacts such as floods, fires and industrial accidents, as well as the fight against

environmental crime. Therefore, this legislative proposal is consistent with the climate-

neutrality objective set out in European Climate Law.

The summary sheet of the impact assessment is available at the following link: [LINK to be

inserted]

• Regulatory fitness and simplification

18 https://sdgs.un.org/goals

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This initiative is not a revision of existing legislation; therefore, a REFIT test has not been

performed.

• Fundamental rights

This proposal does not affect fundamental rights, but it supports Member States in the

exercise of their responsibility to ensure the safety and security of their citizens. Specifically,

the EUCCS enhances interoperability among emergency services across agencies and borders,

ensuring an effective and coordinated response to security threats, crises, and the protection of

citizens throughout the Member States. Member States’ responsibility to ensure the security

of every person is protected under Article 6 of the Charter of Fundamental Rights of the

European Union (Charter), and Article 5 of the European Convention on Human Rights

(ECHR). With respect to Article 2 ECHR and Articles 2(1) and 3(1) of the Charter, the

EUCCS could support the protection of life as well as the physical and mental integrity of

people by enabling rapid emergency response and coordination during crises such as terrorist

attacks or natural disasters. EUCCS does not equip law enforcement and emergency services

with any capabilities that may be used for direct exercise of force or infringements of other

rights.

– Compliance with Regulation 2016/679 (GDPR Regulation)

The EUCCS fully comply with the standards laid down in Regulation (EU) 2016/679 on the

protection of natural persons with regard to the processing of personal data and on the free

movement of such data (GDPR), in line with Article 8 ECHR (right to respect for private and

family life), Article 7 (respect for private and family life) and Article 8 of the Charter

(protection of personal data. The EUCCS facilitates the exchange of operational data

exclusively among emergency services and directly associated entities, e.g. emergency

medical services, hospitals. Such exchanges may include victim-related data, such as name,

age, sex, physical or psychological condition, but remain strictly limited to public security and

safety purposes. These advancements serve solely to improve emergency response, without

altering the existing legal framework for data protection. The EUCCS not enhance the

capabilities of law enforcement for activities with a potential fundamental rights impact, such

as surveillance of private communication.

The restrictions of data subject rights (e.g. access, erasure, or objection) in cross-border data

exchanges are in line with Article 23 GDPR, as the new dimension permits restrictions by

way of a legislative measure when necessary for public security, national defence, or law

enforcement, provided such limitations are proportionate. For critical communication,

processing of personal data would be based on the vital interest to protect life and to prevent

serious threats.

3. BUDGETARY IMPLICATIONS

The total costs have been established as part of the Impact Assessment in close cooperation

with Member States’ experts.

The total direct costs amount to €3,571 billion. Of those, for the EU component of the

EUCCS, which is to be provided by the European Commission, the impact assessment

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estimated the costs to amount to €1,156 billion, covering costs for the dedicated initial

network connection, standardisation and certification, satellite connectivity, testbeds, the

European Union Network Monitoring Centre, the European Union Security Monitoring

Centre, the European Critical Communications Group Committee, the System Accreditation

Board, the tasks of the EUCCS Cooperation mechanism, the elaboration of standard operating

procedures and guidelines additional human resources and for training of staff.

The costs that are directly related to the establishment of the System at the level of the

Member States and the interconnection of Member States’ systems to jointly form the EUCCS

amount to €2,415 billion, consisting of adjustment costs for network, infrastructure, user

equipment, applications and software licences for connecting to the EUCCS, as well as of

administrative costs, consisting of reporting tools for the national competent authority, human

resources needed for reporting and statistical work, training.

The costs that Member States would have to cover for transiting critical communication to

broadband over a period of 7 years are estimated at €12,667 billion, including the costs for

using existing public networks. Those costs are not induced by the EUCCS.

Without prejudice to the outcome of the negotiations on the next Multiannual Financial

Framework (MFF) the proposal, may be supported by Union programmes in accordance with

the objectives set out in the regulations establishing those programmes. The LFDS presents

estimated budgetary impact under Heading 4 including related human and administrative

resources.

4. OTHER ELEMENTS

• Implementation plans and monitoring, evaluation and reporting arrangements

Key Performance Indicators (KPIs) will be used to measure the success of EUCCS, aligned

with its specific objectives. These include: (i) the designation of National Competent

Authorities (NCAs) and EU competent bodies; (ii) the establishment of the European Union

Critical Communications Group (ECCG) and System Accreditation Board (SAB); (iii) the

number of Member States connected to EUCCS and number of first responders with

connectivity; (iv) the increased cross-border operational mobility (for instance, roaming

minutes); (v) the service quality metrics (for example, connection time, roaming service

quality, backup power capacity); (vi) compliance with security requirements (NIS2,

Cybersecurity Act), using European cybersecurity certification schemes where available; (vii)

the number of joint exercises and trained first responders; and (viii) progress in implementing

national strategies and adherence to Standard Operating Procedures (SOPs).

The Commission will evaluate the functioning and effectiveness of the Regulation in line with

standard evaluation requirements and report on its performance.

• Detailed explanation of the specific provisions of the proposal

EN 13 EN

The proposal is based on two Regulations as explained above. The main Regulation is based

on Art. 87 TFEU and is structured as follows:

Chapter I – General Provisions

This chapter describes the subject matter and the scope, namely enabling emergency services

and other public authorities in charge of security and public safety to seamlessly communicate

and exchange mission-critical information with each other, across borders, thereby enhancing

efficiency and effectiveness of response to emergencies and crisis situations. Furthermore, it

provides the key definitions and sets out the obligation for Member States to ensure the

interoperability of their national critical communication systems.

Chapter II – Member State Critical Communication Framework

This chapter describes the architecture of the Member States’ Critical Communication

Framework, which consists of the national critical communications system and the policies

governing its upgrade and use, supervised by a national Competent Authority. Specifically, it

describes the role of the Member State Competent Authority, the content of the national

mission critical-broadband communication strategy, the minimum components, spectrum

management and resilience requirements of the national critical communication system and

the obligations for providers of public electronic communications networks. These rules

ensure comparable frameworks and minimum harmonisation at Member State level, which is

a prerequisite for a coordinated transition into mission critical broadband and the basis for the

eventual interconnection of critical communication systems via the EUCCS. In line with the

objective of technological sovereignty and with the Commission’s Joint Communication on

Strengthening EU economic security19, to lower the risk of data leakage, espionage and of

physical and cyber-disruption, these rules exclude ownership, control or operation by high-

risk entities and avoids dependencies on single suppliers or high-risk suppliers, as well as

concealed vulnerabilities, backdoors or potential systemic ICT supply disruptions, by

excluding high-risk vendors from the core of the system and thus contributing to ensure the

supply chain security of the system.

Chapter III – European Union-level Governance

This chapter describes the governance at Union level. It sets out the European Union Critical

Communication Group, consisting of Member States’ delegates, that will steer policy

implementation, as well as the System Accreditation Board which will perform the technical

accreditation of Member States’ critical communication systems to ensure readiness to join

the EUCCS. A dedicated governance system ensures a strong role for Member States to

safeguard their control over national systems, while providing clear and coherent guidance for

the functioning of the EUCCS, as well as ensuring trust and verification of the accreditation,

to support the future development of the System.

Chapter IV – System Accreditation and Interconnection

The chapter describes the steps for Member State systems’ interconnection to form gradually

the European Union Critical Communication System. It includes an empowerment for the

19 JOIN/2025/977 finalof 3 December 2025.

EN 14 EN

Commission to adopt a delegated act to define the mandatory standards, explains the general

principles of accreditation and interconnection and how the Commission will facilitate the

interconnection via a dedicated infrastructure. Furthermore, it describes the principle of

gradual establishment and the assessment missions to be performed before an accreditation to

verify compliance with the legal obligations and technical standards. Due to the fact that

Member States have different starting points and the transition into mission critical broadband

will happen in different timelines and with different budgetary implications, agradual

approach is the only effective solution to ensure interconnection. The proposal sets 2036 as

the final date for transition and interconnection. The provisions of this Chapter are

supplemented by the Annex, which defines the Member States’ maturity levels.

Chapter V – European Union Components

This chapter describes the European dimension of the light technical components of the

System, namely the competences of the European Union Network monitoring centre and of

the European Union Security Monitoring Centre. The Network Monitoring Centre would host

the interconnection infrastructure and support the high-level monitoring of the functioning of

the interconnection and the interoperability. The Security Monitoring Centre would support

Member States’ Security Operation Centres by monitoring security threats to critical

communication systems. Both centres would be created as virtual service entities using

framework contract arrangements of the European Commission that are already today used

for similar tasks for the Commission and other EU bodies. Where relevant, both centres could

be supported with advice from ENISA.

Chapter VI – Union-level operational support

This chapter describes the different European level operational support measures, namely the

standard operating procedures and the use of EU Satellite Secure Connectivity services.

Standard operating procedures are a key element to ensure that apart from the technical

aspects, there is also operational harmonisation that is the basic for effective communication

in emergency situations. EU Satellite Assets will support the System by offering Member

States back-up and additional coverage where terrestrial systems are not available or

disrupted. Finally, the chapter describes the supporting role of the Commission for Member

States operations and system development, notably providing testbeds for the mission-critical

interconnection, developing best practices, guidance materials and methodologies, and cross-

border training activities and exercises to test critical communication systems for emergency

services.

Chapter VII – Evaluation

This chapter defines the measures for evaluation of the Regulation.

Chapter VIII – Delegated and Implementing Acts

This chapter confers the power on the Commission to adopt delegated acts and specifies the

committee procedure for the development of implementing acts.

Chapter IX – Final Provisions

EN 15 EN

This chapter lists the final provisions, notably that the Regulation would take immediate

effect in all Member States.

EN 16 EN

2026/0301 (COD)

Proposal for a

REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL

establishing the European Union Critical Communication System (EUCCS)

THE EUROPEAN PARLIAMENT AND THE COUNCIL OF THE EUROPEAN UNION,

Having regard to the Treaty on the Functioning of the European Union, and in particular

Article 87 (2), point (a) thereof,

Having regard to the proposal from the European Commission,

After transmission of the draft legislative act to the national parliaments,

Having regard to the opinion of the European Economic and Social Committee20,

Having regard to the opinion of the Committee of the Regions21,

Acting in accordance with the ordinary legislative procedure,

Whereas:

(1) People facing emergency situations in the Union depend on the fast, efficient, and

professional response, including by law enforcement authorities. From daily

operations, countering crime and terrorism, preserving the public order in case of

incidents or attacks, or providing security for mass events, these services need to

communicate seamlessly, exchange information in real time, and collaborate

effectively between each other and across borders.

(2) The effective functioning of the Schengen area and the prevention and response to

security threats or disasters depend on close cross-border law enforcement

cooperation, underpinned by continuous and reliable communication and information

exchange in cross-border operations, such as hot pursuits. Law enforcement

cooperation across borders within the area free of internal border controls on persons

relies on the ability of competent public authorities to maintain reliable and

interoperable communications when operating in a cross-border context, including in

situations requiring real-time coordination. Such cooperation significantly contributes

to ensuring the long-term security of the the Schengen area and of the Union citizens

and, as such, constitutes an important safeguard in an area without internal border

controls.

(3) It is essential that public authorities in charge of ensuring public order and security

have, within the framework of applicable Union and national law, the ability to

communicate effectively both within and across borders. In such an area, law

20 OJ C , , p. . 21 OJ C , , p. .

EN 17 EN

enforcement activities carried out by one Member State may have cross-border

implications for the security of others, and effective cooperation increasingly depends

on the capacity of authorities to coordinate actions and exchange information in a

mission critical and reliable manner. Secure, resilient and interoperable critical

communication systems therefore play a central role in ensuring continuity of law

enforcement operations and missions across borders and constitute an essential

component of the measures underpinning public security in an interdependent area

without internal border controls. Critical communication infrastructure should

guarantee the reliable, secure, and efficient transmission of vital information to

respond, coordinate and cooperate.

(4) At present, no system enables seamless cross-border cooperation between law

enforcement authorities in the Schengen area. Critical communication systems of the

Member States operate largely independently at national level and are based on

differing technical approaches, resulting in very limited interoperability and lack of

continuity of communications across internal borders. In an interdependent area

without internal border controls, such fragmentation undermines effective law

enforcement cooperation and the ability of authorities to respond jointly to security

threats. It is therefore necessary to establish clear, harmonised and effective

requirements at Union level, including common interoperability requirements and

standards, to support the modernisation and interconnection of Member States’ critical

communication systems.

(5) In order to address the need for operational mobility, strong resilience and strategic

autonomy of the Member States’ critical communication systems, the European Union

Critical Communication System (EUCCS) should be established as an overarching

framework that enables the relevant law enforcement authorities to communicate and

exchange data continuously and seamlessly with corresponding authorities in other

Member States for cross-border missions while operating within their familiar

operational environments, including the devices, applications, authentication

mechanisms and communication services they use in their routine activities.

(6) The European Union Critical Communication System constitutes a key action at

Union level in support of internal security objectives, as reflected in ProtectEU – the

European Internal Security Strategy22, which emphasises the importance of enhanced

cooperation, resilience and preparedness in addressing security threats to public order

and security. Moreover, as highlighted in the European Preparedness Union Strategy23,

the Union should strengthen its response capabilities and strategic preparedness,

including crisis-response tools, to address major emergencies, critical shortages and

hybrid attacks. The establishment of a European Union Critical Communication

System contributes to those objectives by providing a common framework enabling

competent authorities in charge of security and safety to communicate and exchange

data continuously and seamlessly.

22 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52025DC0148 23 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex:52025JC0130

EN 18 EN

(7) Whereas Member States may have different models for their national critical

communication systems, a set of key minimum requirements and the ability of

different types of law enforcement authorities to effectively communicate between

each other within a given Member State is a prerequisite for interconnecting to the

European Union Critical Communication System.

(8) The critical communication framework established by this Regulation should be

without prejudice to the organisation, command or conduct of law enforcement

activities, or to the ownership and operation of national critical communication

systems, which remain the responsibility of the Member States. The provisions laid

down in this Regulation do not interfere with the competence of Member States and

their authorities in terms of administrative autonomy. They do not affect their

responsibility for safeguarding national security and defence, their power to safeguard

other essential State functions, in particular concerning public security, territorial

integrity and the maintenance of law and order.

(9) In order for the European Union Critical Communication System to unfold its full

operational value, Member States should be encouraged to ensure its use also by their

services and other organisations in charge of civil protection, enabled by Regulation

(EU) 2021/836 of the European Parliament and of the Council 24. Cooperation

between different types of emergency services is the daily operational reality. Law

enforcement authorities depend on the seamless cooperation with firefighters, civil

protection and medical emergency responders to effectively conduct its mission,

thereby ensuring joint response of all relevant authorities in emergency situations.

(10) There are other important users of critical communication systems. To cater for the

different situations in Member States and to allow for flexibility, Member States

should have at their discretion the to include other users into the System. This applies

notably to armed forces, national security authorities, public authorities responsible for

the protection of the environment and authorities or private entities responsible for the

delivery of essential services, notably as provided in Commission Delegated

Regulation (EU) 2023/245025 as well as for the operation of critical infrastructure as

defined in national law. Private security operators, in particular Monitoring and Alarm

Receiving Centres, play an essential role in the early detection and verification of

incidents, including coordinated first response with competent authorities, affecting

citizens, essential services, the resilience of critical entities, and public space security.

They should therefore be recognised as trusted contributors to emergency response

systems and consequently be included where appropriate in critical communication

networks in a complementary role to emergency services and other public authorities.

24 Regulation (EU) 2021/836 of the European Parliament and of the Council of 20 May 2021 amending

Decision No 1313/2013/EU on a Union Civil Protection Mechanism (OJ L 185, 26.5.2021, p. 1, ELI: http://data.europa.eu/eli/reg/2021/836/oj)

25 Commission Delegated Regulation (EU) 2023/2450 of 25 July 2023 supplementing Directive (EU)

2022/2557 of the European Parliament and of the Council by establishing a list of essential services (OJ

L, 2023/2450, 30.10.2023, ELI: http://data.europa.eu/eli/reg_del/2023/2450/oj).

EN 19 EN

(11) With a view to ensuring a comprehensive and harmonised approach to the transition

towards critical broadband and the interconnection of Member States’ systems into the

European Union Critical Communication System, each Member State should have in

place a strategy for critical communication. The strategy should set out objectives and

policy measures to be implemented. In the interests of coherence and efficiency, the

strategy should be designed to seamlessly integrate existing policies, building,

wherever possible, upon relevant existing national and sectoral strategies, plans or

similar documents.

(12) Critical communication is increasingly shifting towards broadband, using commercial

public electronic communications networks on a shared infrastructure basis. In this

context, the EUCCS should promote an ongoing transition from narrowband critical

communication systems to broadband, which is in line with the overall digital policy

of the Union. Coherence with the commercial public electronic communication

developments will allow critical communication to benefit also more quickly from the

market-driven technological advancement of the commercial sphere.

(13) Whereas Member States may have different models for their national critical

communication systems, a set of key minimum requirements and the ability of

different types of law enforcement authorities to effectively communicate between

each other within a given Member State is a prerequisite for interconnecting to the

European Union Critical Communication System.

(14) Until today, critical communication was delivered usually through dedicated, self-

contained networks designed to ensure availability, control, and resilience under

adverse conditions. This model provided law enforcement authorities with a high

degree of assurance over mission-critical communications.

(15) Modern critical communication is however dependent on commercial, publicly

available broadband networks, cloud-based services, and complex, software-defined

infrastructures, meaning they are embedded within a wider and highly interdependent

digital and electronic communications ecosystem. Critical communication can no

longer be considered in isolation but should be approached in coherence with the

security and resilience of the commercial public electronic communications networks.

(16) It is necessary to lay down a set of minimum requirements for the resilience and

security of Member States critical communication systems via this Regulation, without

prejudice to Member States full sovereignty over those systems.

(17) Critical communication systems may include or define as products with digital

elements. For products with digital elements placed on the internal market, including

both hardware and software, Regulation (EU) 2024/2847 of the European Parliament

and of the Council26 sets out cybersecurity requirements that require manufacturers to

26 Regulation (EU) 2024/2847 of the European Parliament and of the Council of 23 October 2024 on

horizontal cybersecurity requirements for products with digital elements and amending Regulations

(EU) No 168/2013 and (EU) 2019/1020 and Directive (EU) 2020/1828 (Cyber Resilience Act) (OJ L,

2024/2847, 20.11.2024, ELI: http://data.europa.eu/eli/reg/2024/2847/oj, ELI:

http://data.europa.eu/eli/reg/2024/2847/oj).

EN 20 EN

ensure a security by design approach and manage vulnerabilities during the lifecycle

of the product. To facilitate the implementation for manufacturers, the requirements of

the Cyber Resilience Act are being further specified by harmonised standards

requested by the European Commission to the European Standardisation Organisations

in line with Commission Implementing Decision C (2025)61827.

(18) The Union and its Member States should be able to operate the System without foreign

interference, ensuring the confidentiality, integrity and availability of the System and

of data transmitted via the System, including prohibiting the use of equipment from

high-risk suppliers, especially those subject to intrusive third-country laws regarding

national intelligence and data security. In this regard, the Union and its Member States

should also take into account the EU ICT Supply Chain Security Toolbox28 and make

use of the possibility to exclude an economic operator from participation in a

procurement procedure where the operator has been identified as a high-risk supplier

pursuant to Regulation (EU) XXXX/XXX [CSA2 proposal]29 in relation to the

provision of key components for the creation, functioning or operation of the EUCCS.

(19) Strengthening European control over key technologies required for the System is

essential for its security and resilience and is also one of the priorities of the Joint

Communication on strengthening Union economic security. The EUCCS should

leverage the required state-of-the-art technologies and innovative solutions, thereby

promoting strategic autonomy and competitiveness of the Union. The System should

therefore support the continuous innovation, testing, validation and integration of

emerging technologies, such as generative artificial intelligence, cloud computing,

post-quantum encryption and device-to-device communication, thus ensuring it

remains resilient in an evolving threat landscape.

(20) The EUCCS can rely on the use of dedicated spectrum to ensure interoperability and

continuous availability. Commission Implementing Decision (EU) 2016/68730 enables

Member States, subject to national decisions and choice, to designate and make

available up to 8 MHz of paired spectrum for critical communications within the 700

MHz frequency band. Member States should exchange experience and best practice

through the Radio Spectrum Policy Group to facilitate the coordinated designation and

27 Commission Implementing Decision C (2025)618 of 3 February 2025 on a standardisation request to

the European Committee for Standardisation (CEN), the European Committee for Electrotechnical

Standardisation (Cenelec) and the European Telecommunications Standards Institute (ETSI) as regards

products with digital elements in support of Regulation (EU) 2024/2847 of the European Parliament

and of the Council of 23 October 2024 on horizontal cybersecurity requirements for products, with

digital elements and amending Regulations (EU) No 168/2013 and (EU) 2019/1020 and Directive (EU)

2020/1828 (Cyber Resilience Act). 28 EU ICT Supply Chain Toolbox, NIS Cooperation Group, https://digital-skills-

jobs.europa.eu/sites/default/files/2026-

02/NISCG_2026_EU_ICT_Supply_Chain_Security_Toolbox_j7C7mjtm8bJ7UHDEItXtI2CDXS0_124

123.pdf 29 […] 30 Commission Implementing Decision (EU) 2016/687 of 28 April 2016 on the harmonisation of the 694-

790 MHz frequency band for terrestrial systems capable of providing wireless broadband electronic

communications services and for flexible national use in the Union (OJ L 118, 4.5.2016, p. 4, ELI:

http://data.europa.eu/eli/dec_impl/2016/687/oj).

EN 21 EN

availability of EU-harmonised spectrum for critical communications in accordance

with that Implementing Decision.

(21) Furthermore, Article 17 of Regulation […] of the European Parliament and of the

Council [on digital networks, amending Regulation (EU) 2015/2120, Directive

2002/58/EC and Decision No 676/2002/EC and repealing Regulation (EU) 2018/1971,

Directive (EU) 2018/1972 and Decision No 243/2012/EU (Digital Networks Act)]31

provides that the Union spectrum strategy shall identify radio spectrum needs and

ensure availability and, where relevant, protect radio spectrum necessary for fulfilling

objectives of different Union policy areas involving the use of radio spectrum,

including critical communications.

(22) Regulation (EU) XXXX/XXX [The Digital Networks Act] recognises the role of

critical communication, that enable emergency services and public authorities in

charge of security and safety to fulfil their mission and should therefore be fully

available on public communication networks. Consequently, providers of electronic

communications networks and services should adopt specific measures to ensure

uninterrupted electronic communications, including internet traffic, to the extent

necessary to effectively conduct emergency response.

(23) Critical communications may be supported by new technologies, like network slicing,

which should benefit from sufficient network capacity to ensure quality of service in

crisis situations. If necessary to ensure the quality of such services, the related traffic

should be prioritised and redundancy for continued availability of critical

communications should be ensured.

(24) Critical communication can be provided in the exercise of public powers32 for the

fulfilment of sovereign missions related to public security, safety and emergency

response, and therefore may fall outside the scope of internal market and competition

rules. Member States maintain competency to regulate the operational and financial

conditions of these services at the national level, in line with the applicable Union law.

Where the same communications infrastructure is used for the provision of both

commercial and critical communications services, appropriate safeguards may prevent

possible cross-subsidisation or overcompensation.

(25) In order to ensure the technical feasibility of seamless and continuous access to the

European Union Critical Communication System, it is necessary to establish common

technical and interoperability requirements enabling the mission critical

interconnection, interoperability and continuity of communications between Member

States’ critical communication systems. Standards are therefore required to ensure

operational mobility for law enforcement authorities across the Union and the

Schengen area, to guarantee interoperability between national mission-critical

communication systems. Compliance with such harmonised standards should provide

31 COM(2026) 16 final, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex:52026PC0016 32 Services of general interest - European Commission

EN 22 EN

one of the means to demonstrate conformity with the requirements laid down in this

Regulation.

(26) In order for the European Union Critical Communication System to function, it is

essential that Member States’ systems are compliant with a set of minimum

requirements, including readiness to interconnect with the systems of other Member

States. In order to accredit Member States’ systems readiness for inclusion into the

System in line with the security assurance levels laid out in the Regulation (EU)

XXXX/XXX of the European Parliament and the Council [on establishing a

framework of measures for strengthening Europe’s cloud and AI ecosystem]33, it is

necessary to establish a System Accreditation Board. Its activities should cover the

verification of Member States’ critical communication systems interconnection,

roaming readiness, rollout of baseline mission critical services and key enabling

capabilities, as well as alignment with the European Union Critical Communication

System security and resilience. The Board will ensure that Member States retain the

key role in accrediting critical communication systems, while at the same time

ensuring the necessary level of trust that is needed to perform their interconnection.

The assessment of the Board will be formalised by the Commission which adopts the

decision on the accreditation.

(27) Member States have different starting points and the transition into mission critical

broadband will happen in different timelines. Therefore, a gradual approach in which

Member States connect in three groups from 2030 onwards, with 2036 as the final date

for transition and interconnection.

(28) A European Union Network Monitoring Centre should be set up by the Commission

by outsourcing its cybersecurity and network management tasks. The centre should

operate as virtual entity to provide a specific service, thus removing the need to create

any official body. It should support the interconnection of Member States’ critical

communication systems and monitor the availability, performance, and continuity of

service. To facilitate the interconnection of Member States’ critical communication

systems, it is appropriate for the Union to provide a central mission critical

interconnection infrastructure. A central interconnection node should be established to

connect Member States’ systems, thus removing the need for a high number of

bilateral or regional interconnections.

(29) In order to ensure operational integrity, detect, assess and mitigate security threats to

the European Union Critical Communication System, it is necessary to establish a

European Union Security Monitoring Centre, using the same approach as for the

Network Monitoring Centre. It should cooperate closely with the Network Monitoring

Centre through continuous information exchange and coordinated incident-

management procedures. As per established practice in the telecommunication and

cyber security domain, the Security Monitoring Centre is separated from the Network

Monitoring Centre.

33 COM(2026) 502 final, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex:52026PC0502

EN 23 EN

(30) The Commission should facilitate cooperation among Member States and the

exchange of information, including best practices, on issues relating to this Regulation

with the support of a European Union Critical Communication Group, consisting of

experts from Member States.

(31) To ensure the resilience and continuity of critical communications for emergency

services, it is necessary to integrate non-terrestrial networks, including secure satellite

connectivity, as a backup and supplementary capability where terrestrial networks are

unavailable, degraded, overloaded, or compromised. The Union Secure Connectivity

Programme (IRIS²), established by Regulation (EU) 2023/588 of the European

Parliament and of the Council34, and the Governmental Satellite Communication

(GOVSATCOM) component, established by Regulation (EU) 2021/696 of the

European Parliament and of the Council35, provide the secure and scalable

infrastructure required to complement terrestrial networks in such scenarios. Access to

these systems remains subject to the decision-making authority of the GOVSATCOM

and IRIS² Competent Authorities and should respect the primary mission or

operational priorities of IRIS² or GOVSATCOM.

(32) Use of satellite connectivity within the EUCCS should be operationally driven, based

on authorisation by the competent authorities, technically feasible, and authorised,

with clearly defined service modes—including stationary backup, communication-on-

the-pause, communication-on-the-move, and direct-to-device connectivity to address

the diverse needs of law enforcement authorities. Such use should be granted only

where capacity and budgetary resources are available, and should be governed by

interoperability, security, and prioritisation rules to ensure alignment with Union law

and the operational requirements of Member States.

(33) When providing mobile satellite services (MSS) using the harmonised 2 GHz

frequency band, it is essential that sufficient MSS spectrum and capacity for

broadband and Direct-to-Device connectivity will be available for the EUCCS.

(34) The EUCCS is built on more than 10 years of Union funded research and deployment

projects. It is essential to continue to provide Member States, law enforcement

authorities and industry a framework for technical cooperation, innovation and testing,

building on the results of the projects Horizon 2020 Broadmap, Broadway and

EUCCS Preparation Project. Their results are fundamental for the development of

Member State pilot projects, for the organisation of large-scale exercises and trials of

the System and the Member States’ interconnections, to promote sharing of feedback

for evolving operational requirements and as a testbed for testing and validating

updated or new technological solutions before deployment.

34 Regulation (EU) 2023/588 of the European Parliament and of the Council of 15 March 2023

establishing the Union Secure Connectivity Programme for the period 2023-2027 (OJ L 79, 17.3.2023,

p. 1, ELI: http://data.europa.eu/eli/reg/2023/588/oj). 35 Regulation (EU) 2021/696 of the European Parliament and of the Council of 28 April 2021 establishing

the Union Space Programme and the European Union Agency for the Space Programme and repealing

Regulations (EU) No 912/2010, (EU) No 1285/2013 and (EU) No 377/2014 and Decision No

541/2014/EU (OJ L 170, 12.5.2021, p. 69, ELI: http://data.europa.eu/eli/reg/2021/696/oj).

EN 24 EN

(35) The System should furthermore provide the basis for the roll-out and use of

increasingly harmonised solutions for communication and situational awareness at a

Union level, including notably solutions piloted by Union funded initiatives. This is in

line with the EUCCS architecture, which follows a system of systems approach, in

which Member States’ critical communication systems interact and collaborate on the

basis of common standards and rules, resulting in enhanced functionalities and

performance beyond the capabilities of the individual systems.

(36) This Regulation respects fundamental rights and observes the principles recognised by

Articles 2 and 6 of the Treaty on European Union and reflected in the Charter of

Fundamental Rights of the European Union.

(37) Where, under this Regulation, personal data are processed, such processing should be

carried out in accordance with applicable Union and national law on the protection of

personal data. Given that critical communication systems are operated at national level

and remain under the responsibility of the Member States, the processing of personal

data carried out through such systems should continue to be subject to the applicable

data protection regime governing the respective national or Union actors involved.

Any processing of personal data under this Regulation is therefore subject, as

applicable, to Regulation (EU) 2016/679 of the European Parliament and of the

Council36, Directive (EU) 2016/680 of the European Parliament and of the Council37,

and Regulation (EU) 2018/1725 of the European Parliament and of the Council38.

(38) The EUCCS represents a trans-European digital public service within the meaning of

Regulation (EU) 2024/903 of the European Parliament and of the Council39. An

interoperability assessment has thus been carried out, and the resulting report will be

published on the Interoperable Europe Portal.

(39) In order to ensure the interconnection, at Union level, of the Member States critical

communication systems used by competent law enforcement authorities, the power to

adopt acts in accordance with Article 290 of the Treaty on the Functioning of the

European Union should be delegated to the Commission in respect of establishing the

36 Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the

protection of natural persons with regard to the processing of personal data and on the free movement of

such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (OJ L 119, 4.5.2016,

p. 1, ELI: http://data.europa.eu/eli/reg/2016/679/oj). 37 Directive (EU) 2016/680 of the European Parliament and of the Council of 27 April 2016 on the

protection of natural persons with regard to the processing of personal data by competent authorities for

the purposes of the prevention, investigation, detection or prosecution of criminal offences or the

execution of criminal penalties, and on the free movement of such data, and repealing Council

Framework Decision 2008/977/JHA (OJ L 119, 4.5.2016, p. 89, ELI:

http://data.europa.eu/eli/dir/2016/680/oj). 38 Regulation (EU) 2018/1725 of the European Parliament and of the Council of 23 October 2018 on the

protection of natural persons with regard to the processing of personal data by the Union institutions,

bodies, offices and agencies and on the free movement of such data, and repealing Regulation (EC) No

45/2001 and Decision No 1247/2002/EC (OJ L 295, 21.11.2018, p. 39, ELI:

http://data.europa.eu/eli/reg/2018/1725/oj). 39 Regulation (EU) 2024/903 of the European Parliament and of the Council of 13 March 2024 laying

down measures for a high level of public sector interoperability across the Union (Interoperable Europe

Act) (OJ L, 2024/903, 22.3.2024, ELI: http://data.europa.eu/eli/reg/2024/903/oj).

EN 25 EN

list of relevant standards related to critical communication. It is of particular

importance that the Commission carry out appropriate consultations during its

preparatory work, including at expert level, and that those consultations be conducted

in accordance with the principles laid down in the Interinstitutional Agreement of 13

April 2016 on Better Law-Making40. In particular, to ensure equal participation in the

preparation of delegated acts, the European Parliament and the Council receive all

documents at the same time as Member States' experts, and their experts

systematically have access to meetings of Commission expert groups dealing with the

preparation of delegated acts.

(40) In order to ensure uniform conditions for the implementation of this Regulation,

implementing powers should be conferred on the Commission on establishing

minimum requirements for the security and resilience of the Member States’ critical

communication systems, on laying down procedural arrangements necessary for the

functioning and decision-making of the System Accreditation Board, on the decision

on granting or refusing the accreditation to the Member States’ critical communication

system, on laying down standard operating procedures for the Member States’

competent law enforcement authorities for the use of the system for interagency and

cross-border critical communications, on required capacity, capabilities, technical

standards, governance, security, and accreditation for the use of satellite connectivity

within the system, on the prioritisation and service allocation procedures between

users at national level, ensuring uninterrupted access for law enforcement authorities.

(41) Those powers should be exercised in accordance with Regulation (EU) No 182/2011

of the European Parliament and of the Council41.

(42) The objectives of this Regulation of enhanced cooperation among law enforcement

authorities across borders cannot be sufficiently achieved by the Member States

individually but can rather by reason of enhanced cooperation among law enforcement

authorities across borders be better achieved at Union level. The Union may therefore

adopt measures, in accordance with the principle of subsidiarity as set out in Article 5

of the Treaty on European Union. In accordance with the principle of proportionality,

as set out in that Article, this Regulation does not go beyond what is necessary in order

to achieve those objectives.

(43) In accordance with Articles 1 and 2 of Protocol No 22 on the position of Denmark

annexed to the Treaty on European Union and to the Treaty on the Functioning of the

European Union, Denmark is not taking part in the adoption of this Regulation and is

not bound by it or subject to its application. Given that this Regulation builds on the

Schengen acquis, to the extent that it applies to cross-border cooperation between law

enforcement authorities, Denmark shall, in accordance with Article 4 of that Protocol,

40 OJ L 123, 12.5.2016, p. 1, ELI: http://data.europa.eu/eli/agree_interinstit/2016/512/oj. 41 Regulation (EU) No 182/2011 of the European Parliament and of the Council of 16 February 2011

laying down the rules and general principles concerning mechanisms for control by the Member States

of the Commission's exercise of implementing powers (OJ L 55, 28.2.2011, p. 13, ELI:

http://data.europa.eu/eli/reg/2011/182/oj).

EN 26 EN

decide within a period of six months after the Council has decided on this Regulation

whether it will implement it in its national law.

(44) As regards Ireland, this Regulation constitutes a development of the provisions of the

Schengen acquis in which Ireland takes part, in accordance with Council Decision

2002/192/EC of 28 February 2002 concerning Ireland’s request to take part in some of

the provisions of the Schengen acquis. Ireland is therefore bound by this Regulation

and subject to its application.

(45) As regards Iceland and Norway, this Regulation constitutes a development of the

provisions of the Schengen acquis within the meaning of the Agreement concluded by

the Council of the European Union and the Republic of Iceland and the Kingdom of

Norway concerning the latter’s’ association with the implementation, application and

development of the Schengen acquis42, which fall within the area referred to in Article

1, point G, of Council Decision 1999/437/EC.

(46) As regards Switzerland, this Regulation constitutes a development of the provisions of

the Schengen acquis within the meaning of the Agreement between the European

Union, the European Community and the Swiss Confederation on the Swiss

Confederation’s association with the implementation, application and development of

the Schengen acquis43, which fall within the area referred to in Article 1, point G, of

Decision 1999/437/EC, read in conjunction with Article 3 of Council Decision

2008/146/EC 44.

(47) As regards Liechtenstein, this Regulation constitutes a development of the provisions

of the Schengen acquis within the meaning of the Protocol between the European

Union, the European Community, the Swiss Confederation and the Principality of

Liechtenstein on the accession of the Principality of Liechtenstein to the Agreement

between the European Union, the European Community and the Swiss Confederation

on the Swiss Confederation’s association with the implementation, application and

development of the Schengen acquis45 which fall within the area referred to in Article

1, point G, of Decision 1999 /437/EC read in conjunction with Article 3 of Council

Decision 2011/350/EU46,

42 OJ L 176, 10.7.1999, p. 36, ELI: http://data.europa.eu/eli/agree_internation/1999/439(1)/oj. 43 OJ L 53, 27.2.2008, p. 52, ELI: http://data.europa.eu/eli/agree_internation/2008/178(1)/oj. 44 Council Decision 2008/146/EC of 28 January 2008 on the conclusion, on behalf of the European

Community, of the Agreement between the European Union, the European Community and the Swiss

Confederation on the Swiss Confederation's association with the implementation, application and

development of the Schengen acquis (OJ L 53, 27.2.2008, p. 1, ELI:

http://data.europa.eu/eli/dec/2008/146/oj). 45 OJ L 160, 18.6.2011, p. 21, ELI: http://data.europa.eu/eli/prot/2011/349/oj. 46 Council Decision 2011/350/EU of 7 March 2011 on the conclusion, on behalf of the European Union,

of the Protocol between the European Union, the European Community, the Swiss Confederation and

the Principality of Liechtenstein on the accession of the Principality of Liechtenstein to the Agreement

between the European Union, the European Community and the Swiss Confederation on the Swiss

Confederation's association with the implementation, application and development of the Schengen

acquis, relating to the abolition of checks at internal borders and movement of persons (OJ L 160,

18.6.2011, p. 19, ELI: http://data.europa.eu/eli/dec/2011/350/oj).

EN 27 EN

(48) The European Data Protection Supervisor was consulted in accordance with Article 42

of Regulation (EU) 2018/1725 of the European Parliament and of the Council and

delivered an opinion on [,,,].

HAVE ADOPTED THIS REGULATION:

EN 28 EN

CHAPTER I

GENERAL PROVISIONS

Article 1

Subject matter

This Regulation establishes the European Union Critical Communication System (EUCCS)

which interconnects, at Union level, the Member States’ critical communication

systems used by competent law enforcement authorities to ensure secure and reliable

connectivity for those systems.

Article 2

Responsibilities and duties of the Member States

1. Member States shall ensure that their national critical communication systems used

by competent law enforcement authorities are interoperable so that they can be

interconnected at Union level.

2. This Regulation shall apply to critical communication systems used by any authority

of the Member States competent under national law to exercise authority and to take

coercive measures for the purpose of preventing, detecting or investigating criminal

offences, including those carrying out the following functions:

(a) policing;

(b) border control as defined in Article 2, point 10 of Regulation (EU) 2016/399 of

the European Parliament and of the Council 47;

(c) coast guard functions;

(d) customs controls as defined in Article 5, point (27) of Regulation (EU)

2026/210848 .

3. Member States shall ensure that the European Union Agency for Law Enforcement

Cooperation (Europol) is granted access to use the EUCCS in line with its mandate.

4. Member States shall ensure that the European Border and Coast Guard Agency

(Frontex) is granted access to use the EUCCS, including the European Operational

Support in accordance with Chapter VI, for all operational activities in line with its

mandate.

47 Regulation (EU) 2016/399 of the European Parliament and of the Council of 9 March 2016 on a Union

Code on the rules governing the movement of persons across borders (Schengen Borders Code) (OJ L

77, 23.3.2016, p. 1, ELI: http://data.europa.eu/eli/reg/2016/399/oj). 48 Regulation (EU) 2026/2108 of the European Parliament and of the Council of 16 September 2026

establishing the Union Customs Code and the European Union Customs Authority, and repealing

Regulation (EU) No 952/2013 (OJ L, 2026/2108, 19.9.2026, ELI:

http://data.europa.eu/eli/reg/2026/2108/oj).

EN 29 EN

5. Member States shall ensure that the European Union Customs Authority is granted

access to use the EUCCS in line with its mandate.

Article 3

Definitions

1. For the purpose of this Regulation, the following definitions apply:

(1) ‘competent law enforcement authorities’ means any police, customs or other

authority of the Member States competent under national law to exercise

authority and to take coercive measures for the purpose of preventing,

detecting or investigating criminal offences including to maintain security and

public order;

(2) ‘critical communication’ means electronic communication that is not publicly

available, and which is essential for communication in emergencies and crisis

situations and for restoring or maintaining security and public safety;

(3) ‘users of critical communications’ means physical or legal persons that provide

public services of critical nature whose effective provision of which may

require situational awareness or confidential and uninterrupted communication

and that are recognised by Member States as such;

(4) ‘critical communication services’ means standardised electronic

communication services that provide enabling capabilities for competent law

enforcement authorities and other public authorities in charge of security and

safety;

(5) ‘non-terrestrial network’ means a network, or segments of a network, that use

an airborne or space-borne platform to host transmission equipment, which can

function as a relay node or a base station;

(6) ‘critical communication interconnection’ means the resilient technical and

operational linking of national critical communication systems via a network of

dedicated connectivity means, -such as fibre optics-, therefore enabling cross-

border critical communication;

(7) ‘public network’ means a public electronic communications network that is not

dedicated to governmental or mission-critical use;

(8) ‘radio access network’ means the part of a mobile network that connects user

devices to the mobile core network;

(9) ‘critical communication core’ means a mobile core network in accordance

with applicable European Telecommunications Standards- used for critical

communication that serves users separately from publicly available electronic

communication services and includes additional safeguards in terms of

resilience, and security to ensure guaranteed service and reliability providing

users with optimal quality of service, priority and pre-emption over

commercial users in emergency situations where Radio Access resources are

shared;

EN 30 EN

(10) ‘broadband critical communication’ means IP based packet switched critical

communication that enables Gigabit connectivity and real-time data, video,

text, voice and conferencing services;

(11) ‘narrowband critical communication’ means critical communication that is not

based on mission critical broadband, such as those defined under ETSI EN 300

392-1;

(12) ‘harmonised standard’ means a harmonised standard as defined in Article 2(1),

point (c), of Regulation (EU) No 1025/201249.

CHAPTER II

FRAMEWORK FOR CRITICAL COMMUNICATION IN THE MEMBER STATES

Article 4

Competent authorities

1. Each Member State shall designate a competent authority which shall have at least

the following tasks:

(a) prepare and implement the critical communication strategy as referred to in

Article 5;

(b) ensure the overall functioning, resilience and security of the critical

communication system in that Member State, including ensuring that it is used

in compliance with the interoperability, security, resilience and operational

requirements laid down by this Regulation;

(c) oversee the evolution of the critical communication system of that Member

State from narrowband towards broadband critical communication, as well as

any other technological development affecting critical communication;

(d) supervise personnel, networks and equipment necessary for the functioning of

the critical communication system of the Member State and take the measures

to allow for its interconnection with other Member States’ systems;

(e) ensure that providers of public electronic communications networks comply

with obligations in relation to Article 8 of this Regulation;

(f) act as single point of contact for the Commission and for the other competent

authorities for the purpose of the implementation of this Regulation;

49 Regulation (EU) No 1025/2012 of the European Parliament and of the Council of 25 October 2012 on

European standardisation, amending Council Directives 89/686/EEC and 93/15/EEC and Directives

94/9/EC, 94/25/EC, 95/16/EC, 97/23/EC, 98/34/EC, 2004/22/EC, 2007/23/EC, 2009/23/EC and

2009/105/EC of the European Parliament and of the Council and repealing Council Decision

87/95/EEC and Decision No 1673/2006/EC of the European Parliament and of the Council (OJ L 316,

14.11.2012, p. 12, ELI: http://data.europa.eu/eli/reg/2012/1025/oj).

EN 31 EN

(g) nominate a representative to the System Accreditation Board referred to in

Article 10;

(h) carry out pilot projects for the further development of the EUCCS, using

dedicated parts of the critical communication system of the Member State as

testbeds, validating and integrating state-of-the-art technologies and innovative

solutions before deployment of those deployments.

2. By 3 months after the entry into force of this Regulation at the latest each Member

State shall notify its competent authority to the Commission.

3. Each Member State shall ensure that its competent authority has the powers and the

adequate financial, human and technical resources to carry out, in an effective and

efficient manner, the tasks assigned to it.

4. Each Member State shall ensure that its competent authority, whenever appropriate,

and in accordance with Union and national law, consults and cooperates with other

relevant authorities, including the national competent authority established in

accordance with Article 68(4) of Regulation (EU) 2021/696 and Article 11(4) of

Regulation (EU) 2023/588.

Article 5

Critical Communication Strategy of the Member State

1. Member State shall adopt and transmit to the Commission a critical communication

strategy. That strategy shall set out the measures required for the transition from

existing narrowband to broadband and packet switched critical communication, as

well as for the interconnection of the critical communication system of the Member

State to the systems of other Member States.

2. The critical communication strategy shall include at least the following elements:

(a) defining the users of the Member State’s critical communication system;

(b) determining the framework for procurement for the purposes of the transition

to the broadband critical communication system and of the interconnection via

the critical communication interconnection infrastructure established on the

basis of commercial agreements with providers of publicly available electronic

communication networks;

(c) setting out the framework for the strategic collaboration with providers of

publicly available electronic communication networks and their role to ensure

the resilience of critical communication services;

(d) describing the deployment of the Member State’s critical communication

system in line with Article 6 and the measures to ensure its resilience in line

with Article 7;

(e) ensuring its coherence with national broadband plans;

(f) determining the transition period for narrowband critical communication

systems;

(g) outlining investment plans and envisaged funding;

EN 32 EN

(h) setting out the steps to be taken for interconnection with other Member States’

critical communication systems;

(i) setting out a framework and schedule for regular monitoring and, where

appropriate, adaptation of the national critical communication system to the

continuous innovation in critical communication and commercial electronic

communications, ensuring the future-proof evolution of its critical

communication system.

3. Member States shall regularly review and, where appropriate, update their critical

communication strategies and communicate any updates to the Commission upon

their adoption.

Article 6

Critical communication system of Member States

1. Critical communication system of a Member State shall consist as a minimum of the

following components:

(a) radio access network;

(b) critical communication core;

(c) critical communication services.

2. In accordance with the deadlines and requirements laid down in this Regulation and

the maturity levels set out in the Annex, each Member State shall establish its-critical

broadband communication system using existing network infrastructures offered by

providers of publicly available electronic communication networks to the extent

possible and appropriate on a shared basis using advanced traffic differentiation

techniques such as network slicing. Member States may use narrowband systems for

their critical communication systems as back-up and for providing additional

coverage.

3. Each Member State shall ensure that its critical communication system is able to

establish an interconnection with the critical communication systems of other

Member States by complying with the standards as defined under Article 11.

4. Member States shall exchange best practices on the use of EU-harmonised spectrum

suitable for critical communications in accordance with Implementing Decision (EU)

2016/687.

5. Member States shall ensure that services, systems and interconnection components

used for their critical communication system comply with standards as referred to in

Article 11 and are subject to conformity assessment, certification, interoperability

testing and field validation.

6. Member States may carry out pilot projects for the further development of the

System, including via the use of dedicated parts of the Member States’ critical

communication systems as for testing, validating and integrating state-of-the-art

technologies and innovative solutions before deployment.

EN 33 EN

Article 7

Resilience of Member States’ critical communication systems

1. Member States shall ensure a high level of resilience and security of their critical

communication systems. For that purpose, Member States shall:

(a) take appropriate and proportionate technical, operational and organisational

measures that reflect the principles of security by design and by default to

ensure the cybersecurity of the critical communication systems and its

components, including, where relevant, measures listed in Article 21(2) of

Directive (EU) 2022/2555 of the European Parliament and of the Council50;

(b) take appropriate and proportionate technical, security and organisational

measures to ensure the resilience of the critical communication systems and its

components, including, where relevant, measures listed in Article 13(1) of

Directive (EU) 2022/255751;

(c) meet pre-defined specific requirements to ensure the highest level of resilience

and appropriate separation end-to-end from any publicly available commercial

communications services. Such separation may be achieved through physical,

logical, technical, operational, organisational and/or contractual measures,

provided that those measures effectively guarantee the required level of

security, resilience, availability and control. Such separation shall not preclude

the deployment of critical communication services over public electronic

communications networks on a shared infrastructure basis;

(d) ensure the sovereignty, the exclusion of high-risk suppliers and overall supply

chain security related to the Critical Communication Core and any other key

ICT assets, in accordance with Regulation (EU) XXX/XXXX of the European

Parliament and the Council [on the European Union Agency for Cybersecurity

(ENISA), the European cybersecurity certification framework, and ICT supply

chain security and repealing Regulation (EU) 2019/881]52;

(e) ensure that critical communication data is not subject to third country

legislation requiring providers to grant, assist or support access to their

authorities or any other party.

2. Member States shall establish their critical communication security operations

centre. Those centres shall ensure the secure operation of the national critical

communications system and cooperation with the European Union Security

Monitoring Centre referred to in Article 15. Member States shall notify those centres

to the Commission upon establishment.

3. The Commission is empowered to adopt an implementing act establishing minimum

requirements for the security and resilience of the Member States’ critical

50 Directive (EU) 2022/2555 of the European Parliament and of the Council of 14 December 2022 on

measures for a high common level of cybersecurity across the Union, amending Regulation (EU) No

910/2014 and Directive (EU) 2018/1972, and repealing Directive (EU) 2016/1148 (NIS 2 Directive)

(OJ L 333, 27.12.2022, p. 80, ELI: http://data.europa.eu/eli/dir/2022/2555/oj) 51 Directive (EU) 2022/2557 of the European Parliament and of the Council of 14 December 2022 on the

resilience of critical entities and repealing Council Directive 2008/114/EC (OJ L 333, 27.12.2022, p.

164, ELI: http://data.europa.eu/eli/dir/2022/2557/oj) 52 [COM(2026) 11 final, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex:52026PC0011]

EN 34 EN

communication systems. Those implementing acts shall be adopted in accordance

with the examination procedure referred to in Article 22(2).

4. This Regulation shall not preclude Member States from adopting or maintaining

provisions of national law with a view to achieving a higher level of resilience of

critical communication systems, provided that such provisions do not interfere with

Member States’ obligations laid down in Union law.

Article 8

Use of public electronic communications networks for critical communication

1. Member States shall ensure the availability of public electronic communications

networks to convey critical communications with the level of quality required to

ensure its uninterrupted availability and effective functioning, including in

emergency and crisis situations subject to the relevant commercial agreements with

providers of such public electronic communication services. Such level of quality

shall take into account relevant technical parameters, including latency, jitter, packet

loss and throughput.

2. In situations of network congestion, or other duly justified cases, Member States

shall ensure that providers of public electronic communications networks implement

traffic management measures ensuring prioritisation and pre-emption of traffic

related to critical communication, in accordance with Article 3 of Regulation (EU)

2015/2120 of the European Parliament and of the Council53.

3. Remuneration for the conveyance of critical communications over public electronic

communications networks, including data, shall be subject to commercial agreements

between the relevant parties and shall be based on fair and reasonable terms and

conditions. Such remuneration shall not be excessive.

CHAPTER III

UNION-LEVEL GOVERNANCE

Article 9

European Union Critical Communication Group

1. The European Union Critical Communication Group (‘the Group’) is established.

2. The Group shall be composed of one representative for each of the Member States,

which are nominated by Competent Authorities and notified to the Commission, and

one representative of the Commission, nominated by the Director-General of the

53 Regulation (EU) 2015/2120 of the European Parliament and of the Council of 25 November 2015

laying down measures concerning open internet access and amending Directive 2002/22/EC on

universal service and users’ rights relating to electronic communications networks and services and

Regulation (EU) No 531/2012 on roaming on public mobile communications networks within the

Union (OJ L 310, 26.11.2015, p. 1, ELI: http://data.europa.eu/eli/reg/2015/2120/oj).

EN 35 EN

Directorate for Internal Affairs and Migration of the European Commission. The

Commission’s representative shall chair the Group. Where relevant for the

performance of its tasks, the Group may nominate permanent observers or invite

relevant stakeholders and other Commission services to participate in its work,

including the meetings of the Group. Where requested by the European Parliament,

the Chair may invite a representative from the European Parliament to attend one or

several meetings of the Group.

3. The Group’s tasks include:

(a) providing strategic guidance to Member States on the establishment and further

development of the System and the Member States’ components;

(b) collecting, exchanging and making available to relevant stakeholders best

practices on matters related to critical communication, such as resilience,

security, operational aspects, procurement or innovation;

(c) contributing to the preparation of implementing and delegated acts stemming

from this Regulation;

(d) reviewing and, where appropriate, providing input on the Mission Critical

Broadband Strategies as referred to in Article 5;

(e) providing guidance for Member States on compliance with Article 7(1), points

(c) and (d);

(f) cooperating with relevant Union institutions, bodies and agencies, third

countries or international organisations on matters related to this Regulation;

(g) monitor the progress of standardisation related to critical communication and

cooperate with relevant standardisation organisations;

(h) adopting non-binding guidance or recommendations on matters related to

critical communication;

(i) reviewing the outcome of assessment missions as referred to in Article 13 and,

where appropriate, making use of the results of such missions in the

identification of best practices according to point (b) of this paragraph and in

the provision of guidance and recommendations according to point (h) of this

paragraph;

(j) where relevant, assisting the Commission in the development of related

policies and documents, including on internal security, digital transition, space

connectivity or civil protection;

(k) exchanging on any topic relevant for critical communication.

Article 10

System Accreditation Board

1. A System Accreditation Board (‘the Board’) is established.

2. The Board shall be composed of a representative of each Member State, nominated

by the competent authority, and of a representative of the Commission.

Representatives of Member States shall be duly qualified in the field of critical

communication and accrediting communication systems, have an appropriate level of

security clearance, where necessary, and act objectively.

EN 36 EN

3. The Board shall assess Member States’ systems readiness for connection to the

EUCCS, on the basis of maturity levels set out in the Annex. The Board shall assess

the readiness of the Member State system, based on assessment missions in

accordance with Article 13 and on any other relevant information after notification

by the Member State of the readiness of the national system for accreditation.

4. The Board shall send to the Commission the outcome of the assessment without

undue delay and where possible within three months of the notification.

5. The Commission may adopt implementing acts laying down procedural

arrangements necessary for the functioning and decision-making of the Board. Those

implementing acts shall be adopted in accordance with the examination procedure

referred to in Article 22(2).

CHAPTER IV

SYSTEM ACCREDITATION AND INTERCONNECTION

Article 11

Standards and general principles of accreditation and interconnection

1. Member States' critical communication systems shall, in order to be accredited,

comply with European and international standards and technical specifications

related to critical communication covering at least the following requirements:

(a) the proper functioning and interoperability of the components laid down in

Article 6(1);

(b) the use of broadband critical communication systems that use existing public

electronic communication network infrastructures laid down in Article 6(2);

(c) the ability of a Member States’ critical communication system to establish an

interconnection with the critical communication systems of other Member

States laid down in Article 6(3);

(d) technical, security and organisational measures to ensure the resilience and

cybersecurity of critical communication systems as laid down in Article 7(1);

2. The Commission shall adopt a delegated act to supplement the requirements for

critical communication systems of Member States referred to in paragraph 1 by

establishing the list of relevant standards.

3. Member States shall ensure compliance of their critical communication systems with

the standards referred to in this Article and shall pursue accreditation of those

systems by requesting the Board to accredit the national system and ensuring full

cooperation of all relevant entities during the accreditation process.

4. Taking into account the outcome of the assessment of the critical communication

system by the Board, referred to in Article 10(3), the Commission shall decide on

granting or refusing the accreditation, by means of an implementing act. Those

implementing acts shall be adopted in accordance with the examination procedure

referred to in Article 22(2).

EN 37 EN

5. When their critical communication system is accredited, Member States shall ensure

the interconnection of their national system via the critical communication

interconnection infrastructure referred to in Article 13 and in accordance with Article

14.

Article 12

Assessment missions

1. Upon receipt of a request for accreditation of a critical communication system of a

Member States, the Commission shall organise a mission to assess the compliance

with the requirements for accreditation set out in this Regulation and with the

standards referred to in Article 11.

2. In duly justified cases, the Board may also request the Commission to organise a

mission to a Member State whose critical communication system has already been

accredited to verify continuous compliance.

3. The Commission may request Member States to provide information before a

mission, notably on the functioning of the Member States’ critical communication

framework, national legal provisions affecting the components of the Member States’

critical communication system, standards adhered to, certifications obtained, as well

as system and interconnection technical performances, compliance with requirements

relating to the relevant the maturity levels of the EUCCS set out in the Annex.

4. The Commission shall, following a consultation with the Member State whose

critical communication system is assessed, select and appoint the members of each

mission. Each mission shall consist of experts from the Member State, experts from

any other Member States and Commission representatives. Additional experts,

including from Union Agencies or bodies, may be nominated as observers by the

Commission to join a mission.

5. Member States shall ensure that entities involved in their national critical

communication system provide missions with full and unhindered access to

information, systems and facilities, without prejudice to that Member State’s

responsibility for national security and the protection of its security interests.

6. The Commission, based on the findings of the mission, shall communicates its

opinion to the Board and the Member State whose critical communication system

was assessed.

7. The Member State that hosts the critical communication system shall ensure that its

competent authority and entities involved in the critical communication system

concerned take into account the findings and provide information to the Commission

and Board on the measures it has taken pursuant to the findings of the mission.

8. The Board shall consider the findings of the mission in its decision for accreditation

of a Member State’s system.

EN 38 EN

Article 13

Critical communication interconnection infrastructure

1. The Commission shall make available a critical communication interconnection

infrastructure that facilitates the interconnection of Member States’ systems. The

Critical Communication Interconnection infrastructure shall:

(a) provide connectivity dedicated to communications and information exchange

between Member States’ critical communication systems;

(b) ensure confidentiality, integrity and availability of communications and related

data;

(c) be designed to remain operational and performant, including during crises

affecting all electronic communication networks used for critical

communications.

2. The Critical Communication interconnection infrastructure shall use an existing

Union secure network for communications to connect Member States’ critical

communication systems.

3. The critical communication interconnection infrastructure shall be designed and

operated to minimise exposure to threats and reduce any attack surface.

4. The Commission and the Member States shall ensure continuity of service for the

interconnection by taking resilience measures thar are coherent with the measures

taken under Article 7.

Article 14

Gradual establishment

1. Interconnection of the accredited critical communication systems of the Member

States shall be implemented in three stages:

(a) the first stage shall start on 1 December 2030, as provided for in

paragraph 2;

(b) the second stage shall start on 1 December 2033, as provided in

paragraph 3;

(c) the third stage shall start on 1 December 2036, as provided in

paragraph 4.

2. Member States whose critical communication systems comply with the requirements

for the initial maturity level as set out in the Annex and have been accredited by the

Commission under the conditions set out in Article 11(4) by the dates referred to in

paragraph 1, point (a) shall interconnect their systems with other Member States’

accredited systems in the first stage.

3. Member States whose critical communication systems comply with the requirements

for the initial and advanced maturity levels as set out in the Annex and have been

accredited by the Commission under the conditions set out in Article 11(4) by the

date referred to in paragraph 1, point (b) shall interconnect their systems with other

EN 39 EN

Member States’ accredited systems in the second stage. The Member States referred

to in paragraph 2 shall comply with the requirements for the advanced maturity level

by the date referred to in paragraph 1, point (b).

4. All Member States shall ensure that their critical communication systems comply

with the requirements for the initial, advanced and optimal maturity levels as set out

in the Annex and that those systems have been accredited by the Commission

pursuant to Article 11(4) under the conditions set out in Article 10 by the date

referred to in paragraph 1, point (c).

5. The Commission shall make publicly available the list of Member States that are to

be included in the stages as defined in paragraph 1.

6. The EUCCS shall commence operations from the date referred to in paragraph 1,

point (a).

7. Member States may engage in bilateral or regional interconnection of their critical

communication systems prior to the dates referred to in paragraph 1, provided those

systems comply with the requirements set out in this Regulation.

8. Member States may engage with neighbouring third countries and territories that do

not contravene the interests of the Union, in view of establishing targeted

interconnection between respective critical communication systems, provided the

third country or territories’ critical communication system abides to the standards as

referred to in Article 11.

9. Before pursuing bilateral, or regional, interconnection as referred to in paragraphs 7

and 8, concerned Member States shall notify the Commission prior to the start of the

interconnection, and the Commission shall in turn inform the Board and the Group

without delay.

CHAPTER V

EUROPEAN UNION COMPONENTS

Article 15

European Union Critical Communication Network Monitoring Centre

1. The Commission shall establish a European Union Critical Communication Network

Monitoring Centre (‘Network Monitoring Centre’) for the System by 1 December

2029.

2. The European Union Critical Communication Network Monitoring Centre shall

perform, inter alia, the following tasks:

(a) host the Critical communication interconnection infrastructure;

(b) support the interconnection of Member States’ critical communication systems

as referred to in Article 14;

EN 40 EN

(c) monitor the availability, performance, and continuity of Union-level critical

communication roaming and interconnection;

(d) enable the roaming of users of critical communication systems across Member

States;

(e) monitor transmission for cross-border operational needs, including critical

communication roaming authentication and authorisation arrangements for

visiting users of the Member States’ critical communication systems;

(f) support cross-border testing of critical communications roaming functionality

and interoperability between Member States’ critical communication systems.

3. The Network Monitoring Centre shall cooperate closely with the European Security

Monitoring Centre and shall provide it, without undue delay, with network events,

performance information and other operational data necessary for cybersecurity

monitoring, incident detection and response.

4. The Network Monitoring Centre’s activities shall be without prejudice to the

provisions of Regulation (EU, Euratom) 2023/2841 of the European Parliament and

of the Council54.

Article 16

European Union Critical Communication Security Monitoring Centre

1. The Commission shall establish a European Security Monitoring Centre (‘Security

Monitoring Centre’) to collect and aggregate information on threats to the System by

1 December 2029.

2. To this end, the Member States’ Critical Communication Security Operations

Centres as referred to in Article 7 shall provide reports on a regular basis concerning

security incidents, vulnerabilities and risks affecting the System to the European

Security Monitoring Centre. A Critical Communication Security Operations Centre

shall notify any incident that interferes with or interrupts the functioning of the

national critical communications system or of its interconnection (‘critical incident’)

to the Security Monitoring Centre without delay and latest within [48 hours] of the

discovery of the incident.

3. The European Security Monitoring Centre shall monitor the System’s overall

security indicators, including authentication and authorisation events, trust

management, certificate status, access attempts, abnormal roaming patterns, misuse

of interconnection interfaces and threats affecting the communication infrastructure.

4. The Security Monitoring Centre and the Network Monitoring Centre shall provide

evidence to the System Accreditation Board for its decisions to accredit a Member

State system, or to verify its continuous compliance, by assessing the security,

cybersecurity and resilience requirements for the Member States’ critical

communication systems and their interconnections.

54 Regulation (EU, Euratom) 2023/2841 of the European Parliament and of the Council of 13 December

2023 laying down measures for a high common level of cybersecurity at the institutions, bodies, offices

and agencies of the Union (OJ L, 2023/2841, 18.12.2023, ELI:

http://data.europa.eu/eli/reg/2023/2841/oj).

EN 41 EN

5. The Security Monitoring Centre shall support testing of security controls for roaming

authentication and authorisation, trust management, interconnection interfaces and

mission-critical service interoperability.

6. The Security Monitoring Centre shall issue recommendations, propose mitigation

measures or suggest corrective actions concerning security incidents, vulnerabilities

and risks affecting Union-level critical communication roaming, communication

infrastructure, users’ authentication and mission-critical service interoperability. It

shall provide on a regular basis reports to the Commission, the European Union

Critical Communications Group, and the System Accreditation Board. In case of a

critical incident as referred to in paragraph 1, it shall provide a report without undue

delay. It shall cooperate with the Member States’ competent authorities and

cybersecurity authorities, CSIRTs Network members and relevant Union bodies and

agencies to manage incidents and to follow-up on recommendations and corrective

actions.

CHAPTER VI

OPERATIONAL SUPPORT

Article 17

Standard operating procedures

1. The Commission is empowered to adopt implementing acts to lay down standard

operating procedures for the Member States’ competent law enforcement authorities,

for the consistent, efficient and compliant use of the EUCCS for interagency and

cross-border critical communications. Those implementing acts shall be adopted in

accordance with the examination procedure referred to in Article 22(2).

2. The standard operating procedures shall lay down the roles, tasks, coordination

mechanisms and protocols needed for the operational use of the System with regards

to:

(a) the Member State competent authority referred to in Article 4;

(b) the cooperation of the Member State competent authority with the competent

authorities designed under Regulations (EU) 2021/696 and (EU) 2023/588;

(c) the cooperation of the Member State competent authority with the Union Civil

Protection Mechanism and Emergency Response Coordination Centre

(d) the operational cooperation between Member States’ competent law

enforcement authorities and other organisations using the EUCCS.

3. The standard operation procedures shall cover the following elements with regards to

cross-border critical communications:

(a) defining which service leads the communication arrangements based on the

incident type or location;

(b) establishing shared situational awareness and ensuring an efficient response;

(c) determining the responsibilities of the host and visiting countries’ authorities at

strategic, operational and tactical level;

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(d) establishing communication and interaction protocols, including for alerting,

group communication, fleet-mapping and dispatching, training and joint

learning.

Article 18

Use of Union Satellite Secure Connectivity services

1. Where authorised by a competent authority designed under the Regulations (EU)

2021/696 and (EU) 2023/588, the GOVSATCOM and IRIS² Competent Authorities,

users and devices of the System shall employ secure satellite connectivity services

provided under GOVSATCOM and IRIS² to extend, complement, or back up

terrestrial networks for emergency services in cases of unavailability, degradation,

overload, or compromise. The competent authorities designated under Regulations

(EU) 2021/696 and (EU) 2023/588, shall retain sole discretion over the approval of

such access and the allocation of resources between users. The allocation of

GOVSATCOM and IRIS2 capacities between users should be made in accordance

with the rules defined under Regulations (EU) 2021/696 and (EU) 2023/588.

2. For back-up and complementary coverage, as well as for direct-to-device

connectivity, users and devices of the EUCCS shall have access to secure

governmental communications services provided by the operator of the secure

MSS/hybrid system in accordance with Regulation (EU) XXX/XXXX of the

European Parliament and the Council [on the procedure for authorisation of systems

providing mobile satellite services using the harmonised 2 GHz frequency band and

repealing Decision No 626/2008/EC] 55.

3. When the services are accessed pursuant to paragraph 1 or paragraph 2, they shall be

used in the following four operational service modes:

(a) stationary mode in which fixed infrastructure providing backup

connectivity for critical communications during terrestrial network

outages;

(b) communication-on-the-pause in which rapidly deployable satellite

connectivity for emergency services in scenarios where fixed

infrastructure is temporarily unavailable or insufficient;

(c) communication-on-the-move in which continuous connectivity for

vehicles, vessels, aircraft, and aerial platforms, enabling real-time

command, control, and coordination during operations;

(d) direct-to-device in which satellite connectivity directly to handsets or

other user equipment used by competent authorities, in line with the MSS

Regulation or in the context of GOVSATCOM and IRIS2 , where such

services are available.

4. The Commission is empowered to adopt implementing acts to specify:

(a) the required capacity, capabilities, and technical standards for each

operational service mode referred to in paragraph 2;

55 [COM(2026) 311 final, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex:52026PC0311]

EN 43 EN

(b) the governance, security, and accreditation rules for the use of satellite

connectivity within the EUCCS, in accordance with the operational

requirements of critical communication;

(c) the prioritisation and service allocation procedures between the EUCCS

users at national level, ensuring uninterrupted access for law enforcement

authorities without exceeding the approved capacity and budgetary

limits.

5. In preparing the draft implementing acts, the Commission shall take into account the

operational requirements of EUCCS users. Those implementing acts shall not affect

the application of Regulations (EU) 2021/696, (EU) 2023/588 and Regulation (EU)

XXX/XXX[on the procedure for authorisation of systems providing mobile satellite

services using the harmonised 2 GHz frequency band and repealing Decision No

626/2008/EC].

6. The implementing acts referred to in paragraph 3 of this Article shall be adopted in

accordance with the examination procedure referred to in Article 22(2).,

7. Member State competent authorities designated under Article 4 of this Regulation

shall cooperate with competent authorities designated under Regulations (EU)

2021/696 and (EU) 2023/588s, as well as the Commission in the context of

Regulation (EU) XXX/XXX [on the procedure for authorisation of systems

providing mobile satellite services using the harmonised 2 GHz frequency band and

repealing Decision No 626/2008/EC] to ensure the availability, interoperability, and

effective use of secure satellite connectivity services within national critical

communication systems. Such cooperation shall include:

(a) the authorisation for the access to the services, at national level;

(b) the alignment of security and accreditation standards;

(c) the monitoring and reporting of service performance, incidents, and

compliance with Union rules, including capacity usage and budgetary

impacts.

8. For Member States participating in the EUCCS, but not participating in the relevant

Union space programmes, access to non-terrestrial or secure connectivity services

shall be subject to the applicable international agreements, association arrangements

or specific operational agreements governing such access concluded with the Union

or with participating Member States in accordance with Article 8(1) of Regulation

(EU) 696/2021 and Article 40 of Regulation (EU) 588/2023.

Article 19

Commission support to Member States

1. The Commission shall support the coordination of Member States’ technical and

operational cooperation on critical communication.

2. The support referred to in paragraph 1 may include:

EN 44 EN

(a) providing testbeds to prepare for the interconnection as referred to in Chapter

IV;

(b) funding of trials and exercises for emergency services to test the

interoperability of critical communication systems, operational procedures or

resilience of critical communication systems;

(c) supporting Member States in cooperating with industry and research to ensure

the continuous innovation of critical communication in the Union;

(d) supporting technical cooperation projects with third countries, in particular

candidate countries and potential candidates, with a view of achieving targeted

interoperability;

(e) the support referred to in paragraph 2 may be subject of Union funded projects.

CHAPTER VII

EVALUATION

Article 20

Evaluation

1. By [five years after the entry into force of this Regulation], and every five years

thereafter, the Commission shall submit a report to the European Parliament and to

the Council on the implementation of this Regulation, including detailed information

on how each Member State has implemented it, and shall, where appropriate,

propose amendments to this Regulation.

2. Member States shall, at the request of the Commission, provide it with the

information necessary for the preparation of the report referred to in paragraph 1, no

later than nine months before the expiry of the reporting deadline.

3. The reports referred to in paragraph 1 of this Article shall, where relevant, take into

account the results of evaluations carried out pursuant to Council Regulation (EU)

2022/92256, in particular as regards communication and the exchange of information.

CHAPTER VIII

DELEGATED AND IMPLEMENTING ACTS

56 Council Regulation (EU) 2022/922 of 9 June 2022 on the establishment and operation of an evaluation

and monitoring mechanism to verify the application of the Schengen acquis, and repealing Regulation

(EU) No 1053/2013 (OJ L 160, 15.6.2022, p. 1, ELI: http://data.europa.eu/eli/reg/2022/922/oj).

EN 45 EN

Article 21

Exercise of the delegation

1. The power to adopt delegated acts is conferred on the Commission subject to the

conditions laid down in this Article.

2. The power to adopt delegated acts referred to in Article 11 (2) shall be conferred on

the Commission for an indeterminate period from the entry into force of this

Regulation.

3. The delegation of power referred to in Article 11 (2) may be revoked at any time by

the European Parliament or by the Council. A decision to revoke shall put an end to

the delegation of the power specified in that decision. It shall take effect the day

following the publication of the decision in the Official Journal of the European

Union or at a later date specified therein. It shall not affect the validity of any

delegated acts already in force.

4. Before adopting a delegated act, the Commission shall consult experts designated by

each Member State in accordance with the principles laid down in the

Interinstitutional Agreement of 13 April 2016 on Better Law-Making.

5. As soon as it adopts a delegated act, the Commission shall notify it simultaneously to

the European Parliament and to the Council.

6. A delegated act adopted pursuant to Article 11 (2) shall enter into force only if no

objection has been expressed either by the European Parliament or by the Council

within a period of two months of notification of that act to the European Parliament

and the Council or if, before the expiry of that period, the European Parliament and

the Council have both informed the Commission that they will not object. That

period shall be extended by two months at the initiative of the European Parliament

or of the Council.

Article 22

Committee procedure

1. The Commission shall be assisted by a committee. That committee shall be a

committee within the meaning of Regulation (EU) No 182/2011.

2. Where reference is made to this paragraph, Article 5 of Regulation (EU) No

182/2011 shall apply.

EN 46 EN

CHAPTER IX

FINAL PROVISIONS

Article 23

Responsibilities for operation and maintenance

1. The costs incurred by the Member State for the operation, maintenance, development

and modernisation of their critical communication system shall be borne by each

Member State.

2. Each Member State shall set up and maintain at their expense the technical

infrastructure necessary to implement their obligations under this Regulation at

national level and shall be responsible for bearing the associated costs.

Article 24

Entry into force

This Regulation shall enter into force on the […] day following that of its publication in the

Official Journal of the European Union.

This Regulation shall be binding in its entirety and directly applicable in the Member States in

accordance with the Treaties.

Done at Brussels,

For the European Parliament For the Council

The President The President

EN 1 EN

LEGISLATIVE FINANCIAL AND DIGITAL STATEMENT

ANNEX 4

Contents

1. CONTEXT OF THE PROPOSAL ............................................................................... 1

2. LEGAL BASIS, SUBSIDIARITY AND PROPORTIONALITY ............................... 4

3. RESULTS OF EX-POST EVALUATIONS, STAKEHOLDER CONSULTATIONS

AND IMPACT ASSESSMENTS ................................................................................ 6

4. BUDGETARY IMPLICATIONS .............................................................................. 11

5. OTHER ELEMENTS ................................................................................................ 12

1. FRAMEWORK OF THE PROPOSAL/INITIATIVE ................................................. 3

1.1. Title of the proposal/initiative ...................................................................................... 3

1.2. Policy area(s) concerned .............................................................................................. 3

1.3. Objective(s) .................................................................................................................. 3

1.3.1. General objective(s) ..................................................................................................... 3

1.3.2. Specific objective(s) ..................................................................................................... 3

1.3.3. Expected result(s) and impact ...................................................................................... 5

1.3.4. Indicators of performance ............................................................................................ 5

1.4. The proposal/initiative relates to: ................................................................................. 6

1.5. Grounds for the proposal/initiative .............................................................................. 6

1.5.1. Requirement(s) to be met in the short or long term including a detailed timeline for

roll-out of the implementation of the initiative ............................................................ 6

1.5.2. Added value of EU involvement (it may result from different factors, e.g.

coordination gains, legal certainty, greater effectiveness or complementarities). For

the purposes of this section 'added value of EU involvement' is the value resulting

from EU action, that is additional to the value that would have been otherwise

created by Member States alone. ................................................................................. 7

1.5.3. Lessons learned from similar experiences in the past .................................................. 8

1.5.4. Compatibility with the multiannual financial framework and possible synergies with

other appropriate instruments ....................................................................................... 8

1.5.5. Assessment of the different available financing options, including scope for

redeployment ................................................................................................................ 9

1.6. Duration of the proposal/initiative and of its financial impact .................................. 10

1.7. Method(s) of budget implementation planned ........................................................... 10

2. MANAGEMENT MEASURES................................................................................. 12

2.1. Monitoring and reporting rules .................................................................................. 12

2.2. Management and control system(s) ........................................................................... 12

EN 2 EN

2.2.1. Justification of the budget implementation method(s), the funding implementation

mechanism(s), the payment modalities and the control strategy proposed ................ 12

2.2.2. Information concerning the risks identified and the internal control system(s) set up

to mitigate them.......................................................................................................... 13

2.2.3. Estimation and justification of the cost-effectiveness of the controls (ratio between

the control costs and the value of the related funds managed), and assessment of the

expected levels of risk of error (at payment & at closure) ......................................... 13

2.3. Measures to prevent fraud and irregularities .............................................................. 13

3. ESTIMATED FINANCIAL IMPACT OF THE PROPOSAL/INITIATIVE ............ 14

3.1. Heading(s) of the multiannual financial framework and expenditure budget line(s)

affected ....................................................................................................................... 14

3.2. Estimated financial impact of the proposal on appropriations ................................... 15

3.2.1. Summary of estimated impact on operational appropriations.................................... 15

3.2.1.1. Appropriations from voted budget ............................................................................. 15

3.2.3. Summary of estimated impact on administrative appropriations ................................. 1

3.2.3.1. Appropriations from voted budget ................................................................................ 1

3.2.4. Estimated requirements of human resources................................................................ 1

3.2.4.1. Financed from voted budget......................................................................................... 2

3.2.5. Overview of estimated impact on digital technology-related investments .................. 4

3.2.6. Compatibility with the current multiannual financial framework................................ 5

3.2.7. Third-party contributions ............................................................................................. 5

3.3. Estimated impact on revenue ....................................................................................... 6

4. Digital dimensions ................................................................................................................. 6

4.1. Requirements of digital relevance ....................................................................................... 6

EN 3 EN

1. FRAMEWORK OF THE PROPOSAL/INITIATIVE

1.1. Title of the proposal/initiative

Proposal for a Regulation of the European Parliament and Council on the European

Union Critical Communication System (EUCCS).

1.2. Policy area(s) concerned

Internal security, civil protection, digital and space.

1.3. Objective(s)

1.3.1. General objective(s)

The general objective is to enhance Europe’s capacity to react swiftly and effectively

to incidents and crises that require response across borders and by cooperation of

different types of emergency services.

1.3.2. Specific objective(s)

Specific objective No 1: Promote interoperable and secure cross-border and cross-

agency/operator critical communication and operational mobility among emergency

services.

The objective is to provide for emergency services a resilient critical communication

infrastructure that enables seamless operational mobility promote interoperability

and strengthen cross-border and cross-agency operational mobility for an enhanced

emergency response . Specifically, all the critical communication systems of law

enforcement, civil protection, and other emergency response services across Member

States need to be harmonised and interconnected.

Specific objective No 2: Support Member States to deploy broadband critical

communication systems.

The ability to exchange data-rich information, such as images or video, across

borders and in real time was highlighted as a central reason for the upgrade of the

current legacy systems used, notably TETRA. Most of the Member States report a

planned upgrade of their national legacy narrowband systems.

There is no contradiction between the upgrade of narrowband systems and the

transition to broadband. All critical communication systems in Member States will

run for a certain time in a hybrid setting, in which TETRA and mission-critical

broadband will run in parallel. This is called the ‘migration phase’ in which user

groups shift step by step from TETRA to broadband networks. Member States may

furthermore decide to run TETRA systems for longer periods to have a proven and

widely available back-up solution for voice communication, which remains the

single most important type of communication that must not fail during an emergency.

It is important to underline that it is not EUCCS that ‘replaces’ TETRA. It is the

EN 4 EN

technological shift to broadband, that is already taking place, that will phase out

narrowband technologies, like it has done already in commercial telecommunication.

EUCCS is established therefore precisely at this moment in time, to use the ongoing,

but still early transition towards mission-critical broadband to also introduce the

interoperability requirement. EUCCS itself is agnostic to the possibility of Member

States continue to run a narrowband system in parallel to their broadband system, on

the condition that their hybrid solution allows for the interconnection with other

Member States, covers the identified emergency services and offers the necessary

functionalities. That is also why a ‘cut-off’ clause for narrowband systems (like the

copper switch-off in the DNA) has not been considered.

Targeted interviews point to the need of transition to broadband to allow for the

deployment of interoperable 5G mission-critical capabilities. Broadband

communications technology satisfies the current and evolving needs for increasing

data consumption, supporting advanced functionalities, such as real time incident

reporting, high-resolution Geographic Information System (GIS), and high

bandwidth data exchange (i.e., live video, biometric data), and facilitating the

integration of Artificial Intelligence. In this regard, interviewees also underlined the

role of harmonisation at technological level in making national investment in critical

communications more attractive, while supporting the development of a more

integrated and technologically advanced European critical communications

ecosystem overall.

To conclude, a consensus is observed as to the necessity to transition to broadband as

this would ensure that critical communication systems remain technologically robust,

reliable, and future‑proof, able to adapt to new technologies and develop new

capabilities.

Specific objective No 3: Facilitate the achievement of a high and consistent level of

resilience of critical communications across Member States.

Resilient infrastructure is needed to ensure connectivity and availability in all

circumstances. In this context, resilience refers to the capacity of critical

communication infrastructures to withstand, absorb, and rapidly recover from natural

and man-made threats. Notably this can be achieved by ensuring advanced backup

power, redundant coverage, separation of mission critical core network and radio

access network as well as protocol and cryptographic security. In terms of security a

broadband system would improve encryption and authentication allowing for

stronger protection against cyberattacks. Resilient critical communication systems

can thus be achieved by progressively strengthening the robustness of national

critical communication systems through common resilience and security baselines

and the deployment of advanced protective measures at EU level. Survey findings

indicate that further action at the EU level would strengthen the overall resilience of

national critical communication systems . Furthermore, achieving this specific

objective would contribute to future-proofing critical communication systems,

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increasing Europe’s strategic autonomy in cases of geopolitical developments that

harm EU interests.

1.3.3. Expected result(s) and impact

Specify the effects which the proposal/initiative should have on the beneficiaries/groups targeted.

Expected results

ER1: Enhanced operational mobility across borders and agencies for public

authorities in charge of security and safety.

ER2: Increased resilience of Member States national critical communication system.

ER3: Increased operational efficiency Member States national critical

communication system.

ER4: Progressive development and deployment of new or upgraded critical

communication infrastructure, devices, applications and services, stimulating the

continuous evolution of critical communication system.

ER5: National critical communication system can respond to evolving user needs and

technological innovations.

Expected impacts:

EI1: Enhanced EU-wide preparedness and coordinated crisis response against natural

or man-made disasters, terrorist and cross-border crimes, and armed conflicts

through secure, reliable and interoperable critical communication systems that

support coordinated action by all relevant emergency services.

EI2: Positive social impacts, including greater citizen trust, safety, security and civil

protection across Member States enabled by faster, more coordinated and effective

emergency responses, ultimately resulting in saving lives.

EI3: Positive environmental impacts, including earlier detection with faster and

better coordinated cross-border responses to natural disasters, thereby reducing

environmental damage.

1.3.4. Indicators of performance

Specify the indicators for monitoring progress and achievements.

The successful implementation of SO1 will be measured by the number of Member

States that have interconnected critical communication systems, providing cross-

border and inter-agency critical communication. This will be assessed in three stages:

2030, 2033, and 2036.

The successful implementation of SO2 would be measured by the number of

Member States who deployed mission critical broadband systems as well as the total

number of emergency services’ personnel that are connected to those systems.

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The successful implementation of SO3 would be measured by the compliance of

Member States to the commonly agreed minimum resilience requirements.

To measure the success and effectiveness of the EUCCS, the below Key

Performance Indicators have been identified, based on the EUCCS Operational Plan

endorsed by the European Commission in May 2025. By monitoring these Key

Performance Indicators, the European Commission can ensure that EUCCS will

effectively meet its general objective: enhance Europe’s capacity to react effectively

and efficiently to cross-border and cross-agency incidents and crises, through a

secure and resilient critical communication infrastructure across the EU and

Schengen area.

1.4. The proposal/initiative relates to:

a new action

a new action following a pilot project / preparatory action57

the extension of an existing action

a merger or redirection of one or more actions towards another/a new action

1.5. Grounds for the proposal/initiative

1.5.1. Requirement(s) to be met in the short or long term including a detailed timeline for

roll-out of the implementation of the initiative

Following the principle of gradual establishment and by using leveraged maturity

models like the ENISA CSIRT Maturity Assessment model and the CISA Zero

Trust Maturity model, each Member State should gradually establish its mission-

critical communication system by progressing through the below maturity levels and

dimensions. Standardisation and certification, including on interoperability and

security, will also play an important role in the different dimensions.

Each level should be understood as a target for each Member State to reach .

Member States should establish their national mission-critical mobile broadband

services capability from today’s ‘traditional’ to ‘initial’ capability and evolve the

maturity of its secure communication system towards ‘optimal’, progressing through

all four maturity stages:

• Traditional – current

• Initial – to be achieved by 2030

• Advanced – to be achieved by 2033

• Optimal – to be achieved by 2036

The assessment of Member State’s maturity of their national mission-critical

communication system, regarding their maturity within the EUCCS, should be

carried out by peer review by all Member States (via MCCG). The MCCG shall

57 As referred to in Article 58(2), point (a) or (b) of the Financial Regulation.

EN 7 EN

follow jointly agreed criteria for the peer review. The concerned Member State

submits evidence which is reviewed by all the other Member States.

1.5.2. Added value of EU involvement (it may result from different factors, e.g.

coordination gains, legal certainty, greater effectiveness or complementarities). For

the purposes of this section 'added value of EU involvement' is the value resulting

from EU action, that is additional to the value that would have been otherwise

created by Member States alone.

Reasons for action at EU level (ex-ante)

Over the past few years, Member States have experienced increasingly frequent and

more severe natural and man-made disasters. Disasters such as the Covid-19

pandemic, catastrophic floods of July 2021 affecting Germany, Belgium and the

Netherlands, the Iberian Peninsula blackout in April 2025, or the forest wildfires that

took place throughout Europe in summer 2026. Crises affecting more than one

Member State and requiring joint response are the new normal. Member States

acknowledge thus the need for EU action: the Mission Critical Communication

Group endorsed in 2025 the EUCCS Operational Plan to facilitate the task of

coordinating the establishment of EUCCS. There are thus strong involvement and

constant consultation with Member States, which requested action by the

Commission on EUCCS, including by proposing a legal basis. Also in relevant

Council working parties, as well as at the level of the Council itself, Member States

had asked for the establishment of EUCCS for many years.

Furthermore, the study highlighted that one of the key challenges affecting the

current situation of critical communications across the EU is the existence of varying

levels of technological maturity of critical communication systems across the EU .

Given that these systems evolve from different baselines, shaped by different

budgetary capabilities, procurement cycles, and national risk appetite, the transition

toward advanced technologies is progressing at an uneven pace.

Given that EUCCS will cover the whole of the EU and the Schengen area and will

need to rely on a set of binding common rules, there is no realistic alternative to EU

action. In the absence of such action, Member States would need to engage in a very

large number of bilateral and multilateral agreements, operational procedures and

technical arrangements, assuming they would still pursue the goal of interconnecting

their next generation mission critical communication systems.

Expected generated EU added value (ex-post)

The Union’s action can be considered more effective than what Member States

acting alone can do, as it can establish a harmonised EU framework facilitating

cross-border and interagency critical communications. Completing EUCCS for the

whole of the EU and Schengen area by 2036 will directly benefit the operations of

around five million members of emergency services in Europe to save lives and

prevent harm to health and property, presenting one of the highest added values.

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EUCCS will streamline the costly deployment of mission-critical broadband and thus

create benefits for adequately planning of human and financial resources. Assuming

all Member States are completing the transition to broadband by 2036, Member

States remain responsible for covering the costs for their national systems. Several

Member States (e.g. France, Finland) are currently allocating national funding for

this purpose, using also EU funding such as the Recovery and Resilience Facility.

Other Member States indicated in the Mission Critical Communication Group that

they would seek EU financial support to transition to mission critical broadband.

Such funding could easier be part of the future EU funding programmes, if it

corresponded to a legal obligation.

When measuring the added value of EU action, it is important to consider that the

technical basis for EUCCS is the result of cooperation of the Commission, Member

States and European industry. The components of the system have been developed

and tested by Member States’ stakeholders, notably around 100 emergency services

to validate that the solution creates added value.

1.5.3. Lessons learned from similar experiences in the past

The EU-funded project Inter System Interoperability for TETRA-TetraPol Networks

(ISITEP), developed a cross-border communication infrastructure based on IP

integration. It was not further pursued for logistical, budgetary and operational

reasons. Furthermore, there have been previous attempts at connecting TETRA

systems, but only the Nordic countries - Norway, Sweden and Finland - succeeded in

integrating their networks in the Inter-System Interface (ISI)58. Attempts to replicate

the Nordic success at EU-level did not yield tangible results59.

The Regulation is based on more than 10 years of EU-funded research. BroadMap

and BroadWay projects (2016 – 2022) was based on a voluntary approach that

should lead to a coordinated procurement of inter-operable solutions. The project led

to the common understanding of Member States and the Commission services that

only an approach based on binding EU-level rules is likely to successfully establish

EUCCS.

1.5.4. Compatibility with the multiannual financial framework and possible synergies with

other appropriate instruments

Without prejudice to the outcome of the negotiations on the next Multiannual

financial framework (MFF) the proposal, may be supported by Union programmes in

accordance with the objectives set out in the regulations establishing those funds and

programmes. The LFDS presents estimated budgetary impact under Heading 4

including related human and administrative resources.

58 Norway and Sweden Interconnect Secure Radio Communication Networks - TCCA. 59 However, many of the key lessons have been translated into EUCCS via the EUCCS Preparation

Project, which included since its start experts from ISI. Notably the need to supplement technical

interoperability with Operational Procedures and to set up a governance for the system to function are

lessons-learnt from the Nordics. The same is true for the experience of international partners, notably

the U.S. FirstNet.

EN 9 EN

1.5.5. Assessment of the different available financing options, including scope for

redeployment

Without prejudice to the outcome of the negotiations on the next Multiannual

financial framework (MFF) the proposal, may be supported by Union programmes in

accordance with the objectives set out in the regulations establishing those funds and

programmes. The LFDS presents estimated budgetary impact under Heading 4

including related human and administrative resources.

EN 10 EN

1.6. Duration of the proposal/initiative and of its financial impact

limited duration

–  in effect from [DD/MM]YYYY to [DD/MM]YYYY

–  financial impact from YYYY to YYYY for commitment appropriations and

from YYYY to YYYY for payment appropriations.

unlimited duration

– Implementation with a start-up period from 2030,

– followed by full-scale operation.

1.7. Method(s) of budget implementation planned60

Direct management by the Commission

–  by its departments, including by its staff in the Union delegations;

–  by the executive agencies

Shared management with the Member States

Indirect management by entrusting budget implementation tasks to:

–  third countries or the bodies they have designated

–  international organisations and their agencies (to be specified)

–  the European Investment Bank and the European Investment Fund

–  bodies referred to in Articles 70 and 71 of the Financial Regulation

–  public law bodies

–  bodies governed by private law with a public service mission to the extent that

they are provided with adequate financial guarantees

–  bodies governed by the private law of a Member State that are entrusted with

the implementation of a public-private partnership and that are provided with

adequate financial guarantees

–  bodies or persons entrusted with the implementation of specific actions in the

common foreign and security policy pursuant to Title V of the Treaty on

European Union, and identified in the relevant basic act

–  bodies established in a Member State, governed by the private law of a

Member State or Union law and eligible to be entrusted, in accordance with

sector-specific rules, with the implementation of Union funds or budgetary

guarantees, to the extent that such bodies are controlled by public law bodies or

by bodies governed by private law with a public service mission, and are provided

with adequate financial guarantees in the form of joint and several liability by the

60 Details of budget implementation methods and references to the Financial Regulation may be found on

the BUDGpedia site: https://myintracomm.ec.europa.eu/corp/budget/financial-rules/budget-

implementation/Pages/implementation-methods.aspx.

EN 11 EN

controlling bodies or equivalent financial guarantees and which may be, for each

action, limited to the maximum amount of the Union support.

Comments

The funding indicated for the EUCCS European components and the Member States’

interconnection component will be directly mananged by the Commission.

The methods of budget implementation of the sources of financing and scope of Union

financial commitment in the post-2027 period remain subject to the outcome of

interinstitutional negotiations on the MFF 2028-2034

EN 12 EN

2. MANAGEMENT MEASURES

2.1. Monitoring and reporting rules

This Regulation will establish a System Accreditation Board comprising of delegates

from Member States to assess the progressive maturity of national critical

communication systems in line with the EUCCS, including notably if a Member

State is ready to join EUCCS. It would build on the EUCCS maturity approach

(Traditional → Initial 2030 → Advanced 2033 → Optimal 2036) . Its activities

would cover the verification of national critical communication systems

interconnection, roaming readiness, rollout of baseline mission critical services and

key enabling capabilities, as well as alignment with the EUCCS security and

resilience expectations, notably recognised cybersecurity management practices and

the progressive uptake of European Telecommunications Standards Institute/Global

Certification Forum standardisation and certification . Maturity assessment would be

conducted through a structured peer-review process using objective and

proportionate criteria and evidence, ensuring comparability. For legal reasons, the

function of the System Accreditation Board cannot be performed by the European

Union Critical Communication Group (or any other comitology committee).

A Member State critical communication system is accredited by the System

Accreditation Board. The Commission should organise a monitoring mission to

assess the compliance with the obligations set out in this Regulation. In duly justified

cases, the Board may also request the Commission to organise a monitoring mission

to one or several Member States whose critical communication system have been

already accredited to verify continuous compliance.

Each monitoring mission shall consist of experts from the Member State in which the

critical communication system is located, experts from other Member States and

Commission representatives. Additional experts, including from EU Agencies or

bodies, may be nominated as observers to join a mission.

The Commission shall, following a consultation with the Member State that operates

the critical communication system, select and appoint the members of each

monitoring mission in accordance with their professional capacity.

The Commission should inform the European Union Critical Communication Group

of the organisation of a monitoring mission.

Furthermore, relevant Regulation(s) related to the MFF 2028-2034 will applied.

2.2. Management and control system(s)

2.2.1. Justification of the budget implementation method(s), the funding implementation

mechanism(s), the payment modalities and the control strategy proposed

By five years after the entry into force of this Regulation, and every five years

thereafter, the Commission should submit a report to the European Parliament and to

the Council on the implementation of this Regulation, including detailed information

EN 13 EN

on how each Member State has implemented it, and should, where appropriate,

propose amendments to this Regulation.

Similarly, the Member States should, at the request of the Commission, provide it

with the information necessary for the preparation of the report no later than nine

months before the expiry of the reporting deadline.

Concerning the management and control systems, relevant provisions related to the

MFF 2028-2034 will be applied.

2.2.2. Information concerning the risks identified and the internal control system(s) set up

to mitigate them

Concerning management and control systems, relevant provisions related to the MFF

2028-2034 will be applied.

2.2.3. Estimation and justification of the cost-effectiveness of the controls (ratio between

the control costs and the value of the related funds managed), and assessment of the

expected levels of risk of error (at payment & at closure)

Concerning management and control systems, relevant provisions related to the MFF

2028-2034 will be applied.

2.3. Measures to prevent fraud and irregularities

The existing fraud preventive measures applicable to the Commission will cover the

appropriations necessary for this Regulation. Concerning prevention of fraud and

irregularities, relevant provisions related to the MFF 2028-2034 will be applied.

EN 14 EN

3. ESTIMATED FINANCIAL IMPACT OF THE PROPOSAL/INITIATIVE

The estimated impact on expenditure and staffing for 2028 and beyond is added for

illustrative purposes only and does not pre-judge the next Multiannual Financial

Framework. The source of financing and scope of Union financial commitment in the

post-2027 period remain subject to the outcome of interinstitutional negotiations on

the MFF 2028-2034 and thereafter shall be determined through the annual budgetary

procedure. All appropriations and staffing allocations as of 2028 are indicative.

3.1. Heading(s) of the multiannual financial framework and expenditure budget

line(s) affected

• Existing budget lines

In order of multiannual financial framework headings and budget lines.

Heading of

multiannual

financial

framework

Budget line Type of

expenditure Contribution

Number

Diff./Non-

diff.61

from

EFTA

countries 62

from

candidate

countries

and

potential

candidates 63

From

other

third

countries

other assigned

revenue

Contribution

.

61 Diff. = Differentiated appropriations / Non-diff. = Non-differentiated appropriations. 62 EFTA: European Free Trade Association. 63 Candidate countries and, where applicable, potential candidates from the Western Balkans.

EN 15 EN

3.2. Estimated financial impact of the proposal on appropriations

3.2.1. Summary of estimated impact on operational appropriations

–  The proposal/initiative does not require the use of operational appropriations

–  The proposal/initiative requires the use of operational appropriations, as explained below

3.2.1.1. Appropriations from voted budget

EUR million (to three decimal places)

Heading of multiannual financial framework Number TBC

DG: HOME Year Year Year Year Year Year Year

TOTAL MFF 2028-2034 2028 2029 2030 2031 2032 2033 2034

Operational appropriations

Budget line Commitments (1a) p.m. p.m. p.m p.m p.m p.m p.m p.m

Payments (2a) p.m. p.m p.m p.m p.m p.m p.m p.m

Budget line Commitments (1b) 0

Payments (2b) 0

Appropriations of an administrative nature financed from the envelope of specific programmes64

Budget line (3) 0 0 0 0 0 0 0 0

TOTAL appropriations Commitments =1a+1b+3 p.mp.mp.mp.mp.mp.mp.mp.m

64 Technical and/or administrative assistance and expenditure in support of the implementation of EU programmes and/or actions (former ‘BA’ lines), indirect research, direct research.

EN 16 EN

for DG <HOME65>Payments =2a+2b+3 p.mp.mp.mp.mp.mp.m

p.m

(

65 In view of the uncertainty with regard to the final outcome of the negotiation on the next Multi Annual Financial Framework, the estimated total amount for establishing EUCCS has

been provisionally inserted for DG HOME as policy lead service. This is without prejudice to the final allocation of funding resources for EUCCS and their financial management,

which is likely to be co-delegated across different DGs

EN 17 EN

=1a+1b+3

=2a+2b+3

EN 18 EN

1

Heading of multiannual financial framework 4 ‘Administrative expenditure’66

DG: <HOME> Year Year Year Year Year Year Year TOTAL

MFF 2028-

2034 2028 2029 2030 2031 2032 2033 2034

Ÿ Human resources 1.202 1.202 1.202 1.202 1.202 1.202 1.202 8.414

Ÿ Other administrative expenditure 0.620 0.870 0.870 1.120 0.870 0.870 1.120 6.340

TOTAL DG

<HOME> 1.822 2.072 2.072 2.322 2.072 2.072 2.322 14.754

66 The necessary appropriations should be determined using the annual average cost figures available on the appropriate BUDGpedia webpage.

EN 19 EN

DG: <DIGIT> Year Year Year Year Year Year Year TOTAL

MFF 2028-

2034 2028 2029 2030 2031 2032 2033 2034

Ÿ Human resources 0.388 0.388 0.388 0.388 0.388 0.388 0.388 2.716

Ÿ Other administrative expenditure 0 0 0 0 0 0 0 0

TOTAL DG

<DIGIT>Appropriations

0.388 0.388 0.388 0.388 0.388 0.388 0.388

2.716

TOTAL appropriations under

HEADING 4 of the multiannual

financial framework

(Total

commitments

= Total

payments)

2.210 2.460 2.460 2.710 2.460 2.460 2.710 17.470

The estimated impact on expenditure and staffing for 2028 and beyond is added for illustrative purposes only and does not pre-judge the next

Multiannual Financial Framework. The source of financing and scope of Union financial commitment in the post-2027 period remain subject to

EN 20 EN

the outcome of interinstitutional negotiations on the MFF 2028-2034 and thereafter shall be determined through the annual budgetary procedure.

All appropriations and staffing allocations as of 2028 are indicative

t

EN 21 EN

-

- Output

- Output

EN 22 EN

EN 1 EN

3.2.3. Summary of estimated impact on administrative appropriations

–  The proposal/initiative does not require the use of appropriations of an administrative nature

–  The proposal/initiative requires the use of appropriations of an administrative nature, as explained below

3.2.3.1. Appropriations from voted budget

VOTED APPROPRIATIONS Year Year Year Year Year Year Year TOTAL 2028

- 2034 2028 2029 2030 2031 2032 2033 2034

HEADING 4

Human resources 1.590 1.590 1.590 1.590 1.5901.5901.590 11.130

Other administrative expenditure 0.620 0.870 0.870 1.120 0.870 0.870 1.120 6.34

TotalHEADING 4 2.210 2.460 2.460 2.710 2.460 2.460 2.710 17.470

Outside HEADING 4

The estimated impact on expenditure and staffing for 2028 and beyond is added for illustrative purposes only and does not pre-judge the next Multiannual

Financial Framework. The source of financing and scope of Union financial commitment in the post-2027 period remain subject to the outcome of

interinstitutional negotiations on the MFF 2028-2034 and thereafter shall be determined through the annual budgetary procedure. All appropriations and

staffing allocations as of 2028 are indicative.

3.2.4. Estimated requirements of human resources

–  The proposal/initiative does not require the use of human resources

–  The proposal/initiative requires the use of human resources, as explained below

EN 2 EN

3.2.4.1. Financed from voted budget

Estimate to be expressed in full-time equivalent units (FTEs)67

VOTED APPROPRIATIONS Year Year Year Year Year Year Year

2028 2029 2030 2031 2032 2033 2034

 Establishment plan posts (officials and temporary staff)

20 01 02 01 (Headquarters and Commission’s

Representation Offices) 6

6 6 6 6 6 6

20 01 02 03 (EU Delegations) 0 0 0 0 0 0 0

(Indirect research) 0 0 0 0 0 0 0

(Direct research) 0 0 0 0 0 0 0

Other budget lines (specify) 0 0 0 0 0 0 0

• External staff (inFTEs)

20 02 01 (AC, END from the ‘global envelope’) 4 4 4 4 4 4 4

20 02 03 (AC, AL, END and JPD in the EU

Delegations) 0 0 0 0 0 0 0

Admin. Support line • at Headquarters 0 0 0 0 0 0 0

[XX.01.YY.YY] • in EU Delegations 0 0 0 0 0 0 0

(AC, END - Indirect research) 0 0 0 0 0 0 0

(AC, END - Direct research) 0 0 0 0 0 0 0

Other budget lines (specify) - Heading 4 0 0 0 0 0 0 0

Other budget lines (specify) - Outside Heading 4 0 0 0 0 0 0 0

TOTAL 10 10 10 10 10 10 10

67 Please specify below the table how many FTEs within the number indicated are already assigned to the management of the action and/or can be redeployed

within your DG and what are your net needs.

EN 3 EN

The estimated impact on expenditure and staffing for 2028 and beyond is added for illustrative purposes only and does not pre-judge the next

Multiannual Financial Framework. The source of financing and scope of Union financial commitment in the post-2027 period remain subject

to the outcome of interinstitutional negotiations on the MFF 2028-2034 and thereafter shall be determined through the annual budgetary

procedure. All appropriations and staffing allocations as of 2028 are indicative.

The staff required to implement the proposal (in FTEs):

To be covered by

current staff

available in the

Commission

services

Exceptional additional staff*

To be financed

under Heading 4

or Research

To be financed

from BA line

To be financed from fees

Establishment

plan posts

6 (5 AD and 1 AST

posts)

N/A

External staff

(CA, SNEs, INT)

4 (2 CA and 2

END)

Description of tasks to be carried out by:

Officials and temporary staff DG HOME (3 AD and 1 AST posts): Overall implementation of the EUCCS at

national and EU level, including management of the European Union Critical

Communication Group and the System Accreditation Board. Preparation and adoption

of implementing and delegated acts.

DG DIGIT (2 AD): Support to the establishment of the mission-critical

interconnection infrastructure. Establishment and operation of the European Network

Monitoring Centre and of the European Security Monitoring Centre.

EN 4 EN

External staff DG HOME (2 CA and 2 END): Support to the overall implementation of the EUCCS

at national and EU level, including management of the European Union Critical

Communication Group and the System Accreditation Board. Preparation and adoption

of implementing and delegated acts.

The estimated impact on expenditure and staffing for 2028 and beyond is added for illustrative purposes only and does not pre-judge the next

Multiannual Financial Framework. The source of financing and scope of Union financial commitment in the post-2027 period remain subject

to the outcome of interinstitutional negotiations on the MFF 2028-2034 and thereafter shall be determined through the annual budgetary

procedure. All appropriations and staffing allocations as of 2028 are indicative.

3.2.5. Overview of estimated impact on digital technology-related investments

Compulsory: the best estimate of the digital technology-related investments entailed by the proposal/initiative should be included in

the table below.

Exceptionally, when required for the implementation of the proposal/initiative, the appropriations under Heading 4 should be

presented in the designated line.

The appropriations under Headings 1-3 should be reflected as “Policy IT expenditure on operational programmes”. This expenditure

refers to the operational budget to be used to re-use/ buy/ develop IT platforms/ tools directly linked to the implementation of the

initiative and their associated investments (e.g. licences, studies, data storage etc). The information provided in this table should be

consistent with details presented under Section 4 “Digital dimensions”.

TOTAL Digital and IT

appropriations

Year Year Year Year Year Year Year TOTAL MFF

2028 - 2034

2028 2029 2030 2031 2032 2033 2034

HEADING 4

EN 5 EN

IT expenditure (corporate) 0 0 0 0 0 0 0 0

Subtotal HEADING 4 0 0 0 0 0 0 0 0

3.2.6. Compatibility with the current multiannual financial framework

The proposal/initiative:

–  can be fully financed through redeployment within the relevant heading of the multiannual financial framework (MFF)

–  requires use of the unallocated margin under the relevant heading of the MFF and/or use of the special instruments as defined

in the MFF Regulation

– Without prejudice to the outcome of the negotiations on the next Multiannual Financial Framework (MFF) the proposal may be

supported by Union programmes in accordance with the objectives set out in the regulations establishing those funds and

programmes.  requires a revision of the MFF

3.2.7. Third-party contributions

The proposal/initiative:

–  does not provide for co-financing by third parties

–  provides for the co-financing by third parties estimated below:

Appropriations in EUR million (to three decimal places)

Year Year Year Year Year Year Year

Total 2028 2029 2030 2031 2032 2033 2034

Specify the co-financing

body

TOTAL appropriations

co-financed

EN 6 EN

3.3. Estimated impact on revenue

–  The proposal/initiative has no financial impact on revenue.

–  The proposal/initiative has the following financial impact:

–  on own resources

–  on other revenue

–  please indicate, if the revenue is assigned to expenditure lines

EUR million (to three decimal places)

Budget revenue line:

Appropriations

available for the current

financial year

Impact of the proposal/initiative68

Year 2028 Year 2029 Year 2030 Year 2031 Year 2032 Year 2033 Year 2034

Article ………….

For assigned revenue, specify the budget expenditure line(s) affected.

Other remarks (e.g. method/formula used for calculating the impact on revenue or any other information).

4. DIGITAL DIMENSIONS

4.1. Requirements of digital relevance

High-level description of the requirements of digital relevance and related categories (data, process digitalisation & automation, digital

solutions and/or digital public services)

68 In the case of traditional own resources (customs duties, sugar levies), the amounts indicated must be net amounts, i.e. gross amounts after deduction of 10 % for

collection costs, as proposed in COM(2025)574.

EN 7 EN

Reference to

the

requirement

Requirement description Actors affected or

concerned by the

requirement

High-level Processes Categories

Article 1 Establishes the EU Critical

Communication System

(EUCCS).

European Commission,

Member States

Digital solution

Digital public service

Article 2 Member States shall ensure that

their national critical

communication systems used by

competent law enforcement

authorities are interoperable so

that they can be interconnected at

Union level.

European Commission,

Member States

Digital solution

Digital public service

Article 4 Each Member State to designate a

competent authority; for

competent authorities to cooperate

where possible.

Member States Digital public service

Data

Article 5 Member State shall adopt and

transmit to the Commission a

critical communication strategy.

European Commission,

Member States

Data

Article 6 Minimum requirements for

components of a Member State’s

critical communication system

Member States Digital solution

Digital public service

Article 7 Member States shall take the

necessary measures to ensure the

resilience of all components of

critical communication systems.

The Commission is empowered to

European Commission,

Member States

Digital solution

EN 8 EN

adopt an implementing acts

establishing minimum

requirements for the security and

resilience of the Member States’

critical communication systems.

Article 8 Member States shall ensure the

availability of public electronic

communications networks to

convey critical communications

with the level of quality required

to ensure its uninterrupted

availability and effective

functioning, including in

emergency and crisis situations

subject to the relevant commercial

agreements with providers of such

public electronic communication

services.

Member States, providers

of public electronic

networks

Data

Article 9

Article 10

Establishment of a European

Union Critical Communication

Group and a System Accreditation

Board

European Commission,

Member States

Digital public service

Article 11 To be accredited, Member States’

systems must comply with

relevant European/International

standards and specifications. Must

ensure interoperability, security,

resilience, and the proper

functioning. The Commission

may adopt delegated acts to this

effect.

European Commission,

Member States,

standardisation bodies

Digital solution

Digital public service

EN 9 EN

Article 13 Detailing the interconnection of

Member States’ critical

communication systems. The

Commission shall make available

a Critical Communication

Interconnection infrastructure that

facilitates the interconnection of

Member States’ systems.

European Commission,

Member States

Digital solution

Digital public service

Article 14 Interconnection of Member

States’ systems to the System

shall be implemented in three

stages.

European Commission,

Member States

Digital public service

Article 15

Article 16

The Commission shall establish: a

European Union Network

Monitoring Centre; a European

Union Security Monitoring

Centre.

European Commission, Digital public service

Data

Article 17 The Commission shall adopt an

implementing act to lay down

standard operating procedures for

the Member States’ competent

authorities and emergency

services for the consistent,

efficient, and compliant use of the

System.

European Commission Digital public service

Article 18 Requirements as to the use of EU

Satellite Secure Connectivity

services

European Commission,

Member States

Digital public service

Digital solution

Article 19 The Commission shall support the European Commission, Digital public service

EN 10 EN

coordination of Member States’

technical and operational

cooperation on critical

communication.

Member States

Article 20 Evaluations European Commission Data

4.2. Data

High-level description of the data in scope

Type of data Reference to the requirement(s) Standard and/or specification (if applicable)

Designation of competent authorities Article 4 –

Mission-critical broadband communication strategy Article 5 –

Communications conveyed over public electronic

communication networks

Article 8 Of required quality, including with regard to

parameters such as latency, jitter, packet loss, and

throughput

Report from the European Union Network Monitoring

Centre

Article 15 –

Information collected and aggregated by the European

Union Security Monitoring Centre

Article 16

Reports by the European Union Security Monitoring

Centre (issue recommendations, propose mitigation

measures or suggest corrective actions)

Article 16

Reports from the European Union Security Monitoring

Centre concerning security incidents, vulnerabilities, and

risks

Article 16

EN 11 EN

Critical incident notifications Article 16

Security evidence to be used for system accreditation

purposes

Article 16

Reports by the European Union Security Monitoring

Centre following a critical incident

Article 16

Report on the implementation of this Regulation Article 20 –

Information provided for the purpose of preparing an

evaluation report

Article 20 –

Alignment with the European Data Strategy

The EUCCS aligns with the European Data Strategy, as it is developed designed to put people first, uphold European values, and make more

data available for protectiong our societies.

The EUCCS aligns with the General Data Protection Regulation (GDPR).

Alignment with the once-only principle

The EUCCS aligns with the once-only principle. The data remains with the Member States which will store, secure and reuse them following

the GDPR. Newly create data is accessible, interoperable and meets high-quality standards, facilitating the delivery of timely and efficient

crisis response across the European Union.

EN 12 EN

Data flows

High-level description of the data flows

Type of data Reference(s) to

the

requirement(s)

Actors who

provide the data

Actors who

receive the data

Trigger for the data

exchange

Frequency (if

applicable)

Designation of competent

authorities

Article 4 Member States European

Commission

Competent authority

designated (no later than

three months after the entry

into force of this Regulation)

//

Mission-critical broadband

communication strategy

Article 5 Member States European

Commission

Member State shall adopt and

transmit to the Commission a

critical communication

strategy. That strategy shall

set out the measures required

for the transition from

existing narrowband to

broadband and packet

switched critical

communication, as well as for

the interconnection of the

critical communication

system of the Member State

to the systems of other

Member States

Member States shall

regularly review and,

where appropriate,

update their critical

communication

strategies and

communicate any

updates to the

Commission upon

their adoption.

Communications conveyed

over public electronic

communication networks

Article 8 public electronic

networks

Member States Member States shall ensure

the availability of public

electronic communications

networks to convey critical

communications with the

level of quality required to

EN 13 EN

ensure its uninterrupted

availability and effective

functioning, including in

emergency and crisis

situations subject to the

relevant commercial

agreements with providers of

such public electronic

communication services.

Such level of quality shall

take into account relevant

technical parameters,

including latency, jitter,

packet loss and throughput.

Report from the European

Union Network Monitoring

Centre

Article 15 European Union

Network

Monitoring Centre

European

Commission

The European Network

Monitoring Centre shall

cooperate closely with the

European Security

Monitoring Centre and shall

provide it, without undue

delay, with network events,

performance information and

other operational data

necessary for cybersecurity

monitoring, incident

detection and response.

Information collected and

aggregated by the European

Union Security Monitoring

Centre

Article 16 Member States

Critical

Communication

Security

European Union

Security

Monitoring

Centre

The Member States’ Critical

Communication Security

Operations Centres as

referred to in Article 7 shall

provide reports on a regular

EN 14 EN

Operations Centres basis concerning security

incidents, vulnerabilities and

risks affecting the System to

the European Security

Monitoring Centre

Reports by the European

Security Monitoring Centre

(issue recommendations,

propose mitigation measures

or suggest corrective

actions)

Article 16 European Union

Security

Monitoring Centre

European

Commission

The European Security

Monitoring Centre shall issue

recommendations, propose

mitigation measures or

suggest corrective actions

concerning security incidents,

vulnerabilities and risks

affecting Union-level critical

communication roaming,

communication

infrastructure, users’

authentication and mission-

critical service

interoperability

Reports from the European

Security Monitoring Centre

concerning security

incidents, vulnerabilities,

and risks

Article 16 European Union

Security

Monitoring Centre

European

Commission

In case of a critical incident

as referred to in paragraph 1,

it shall provide a report

without undue delay. It shall

cooperate with the Member

States’ competent authorities

and cybersecurity authorities,

CSIRTs Network members

and relevant Union bodies

and agencies to manage

incidents and to follow-up on

recommendations and

corrective actions.

EN 15 EN

Critical incident

notifications

Article 16 European Union

Security

Monitoring Centre

European

Commission

In case of a critical incident

as referred to in paragraph 1,

it shall provide a report

without undue delay. It shall

cooperate with the Member

States’ competent authorities

and cybersecurity authorities,

CSIRTs Network members

and relevant Union bodies

and agencies to manage

incidents and to follow-up on

recommendations and

corrective actions.

Security evidence to be used

for system accreditation

purposes

Article 16 European Union

Security

Monitoring Centre

European

Commission

The European Security

Monitoring Centre shall

support testing of security

controls for roaming

authentication and

authorisation, trust

management, interconnection

interfaces and mission-critical

service interoperability

Reports by the European

Security Monitoring Centre

following a critical incident

Article 16 Member States

Critical

Communication

Security

Operations Centres

European Union

Security

Monitoring

Centre

A Critical Communication

Security Operations Centre

shall notify any incident that

interferes with or interrupts

the functioning of the

national critical

communications system or of

its interconnection (‘critical

incident’) to the European

Security Monitoring Centre

EN 16 EN

without delay and latest

within [48 hours] of the

discovery of the incident.

Report on the

implementation of this

Regulation

Article 20 European

Commission

European

Parliament and to

the Council

The Commission shall submit

a report to the European

Parliament and to the Council

on the implementation of this

Regulation, including detailed

information on how each

Member State has

implemented it, and shall,

where appropriate, propose

amendments to this

Regulation.

By five years after

the entry into force of

this Regulation, and

every five years

thereafter

Information provided for the

purpose of preparing an

evaluation report

Article 20 Member States European

Commission

Member States shall, at the

request of the Commission,

provide it with the

information necessary for the

preparation of the report

referred to in paragraph 1, no

later than nine months before

the expiry of the reporting

deadline.

4.3. Digital solutions

High-level description of digital solutions

EN 17 EN

Digital solution Reference(s)

to the

requirement(s)

Main mandated functionalities Responsible

body

How is

accessibility

catered for?

How is

reusability

considered?

Use of AI

technologies

(if

applicable)

EU Critical

Communications

System

(Interconnection via

the Mission Critical

Interconnection

infrastructure)

Article 1

Article 11

Article 13

Article 14

Article 19

The EU Critical Communications System

will interconnect the MS' critical

communication systems at the EU level

(connectivity for emergency services).

Secure, sovereign Mission Critical

Interconnection infrastructure that

facilitates the interconnection of Member

States’ systems. This shall:

• Provide connectivity dedicated to

communications and information

exchange between MSs' critical

communication systems

– Ensure confidentiality, integrity,

availability

– Be designed to remain operational

and performant, incl. during crises

affecting the public network.

Where authorised by the GOVSATCOM

and IRIS² Competent Authorities (CGA),

users and devices of the System shall have

access to secure satellite connectivity

services provided under: (a)

GOVSATCOM, as established by

Regulation (EU) 2021/696; and (b) IRIS²,

as established by Regulation (EU)

2023/588.

European

Commission

N/A

EN 18 EN

Member States’

critical

communication

systems

Article 6

Article 7

Article 11

Article 12

Shall comprise de minimis: Radio Access

Network; Critical Communication Core;

Mission Critical Services.

Must comply with relevant

European/International standards and

specifications. Ensure interoperability,

security, resilience, proper functioning.

Member

States

N/A

For each digital solution, explanation of how the digital solution complies with applicable digital policies and legislative enactments

EU Critical Communications System (Interconnection via the Mission Critical Interconnection infrastructure)

Digital and/or sectorial policy (when these are

applicable)

Explanation on how it aligns

AI Act Aspects to be further developed in implementing/delegated acts

EU Cybersecurity framework Limiting and prohibiting the use of equipment from high-risk suppliers, especially

those subject to intrusive third-country laws regarding national intelligence and data

security. Art. 7 - ensure the sovereignty, the exclusion of high-risk suppliers and

overall supply chain security related to at least the Critical Communication Core, in

alignment with the Cybersecurity Act 2 (CSA2)

eIDAS Aspects to be further developed in implementing/delegated acts

Single Digital Gateway and IMI Aspects to be further developed in implementing/delegated acts

Others

Member States’ critical communication systems

EN 19 EN

Digital and/or sectorial policy (when these are

applicable)

Explanation on how it aligns

AI Act Aspects to be further developed in implementing/delegated acts

EU Cybersecurity framework Article 7: reference made to Directive (EU) 2022/2557 (Critical Entities Resilience

Directive) and Directive (EU) 2022/2555 (NIS2). The Commission is empowered to

adopt an Implementing Act to further specify minimum requirements for the

security and resilience.

eIDAS Aspects to be further developed in implementing/delegated acts

Single Digital Gateway and IMI Aspects to be further developed in implementing/delegated acts

Others

4.4. Interoperability assessment

High-level description of the digital public service(s) affected by the requirements

Digital public service or

category of digital public

services

Description Reference(s) to the

requirement(s)

Interoperable

Europe Solution(s)

Other interoperability

solution(s)

Cross-border and cross-

agency critical

communication (EU

Critical Communications

System)

Interconnection of Member

States’ systems will be facilitated,

and a central EU level monitoring

capacity will be established. The

combination of those elements is

the EU-level component of the

EU Critical Communication

System (EUCCS). It will be

created an EU-level technical and

Article 1

Article 2

Article 4

Article 6

Article 11

Article 12

N/A N/A

EN 20 EN

component that provides the

initial interconnection

functionality for the Member

States’ systems and ensures high-

level monitoring of the Member

State networks.

EUCCS is expected to have a high

impact on digitalisation of Public

Administration and promote

broadband deployment. Critical

communication among emergency

services and other relevant forces

will contribute to digitalisation of

their operations. It will also

contribute to Digital Government

goals, including interoperability

of Public Services.

Article 14

Article 15

Article 16

Article 17

Article 18

Article 19

Impact of the requirement(s) as per digital public service on cross-border interoperability

Cross-border and cross-agency critical communication

Assessment Measure(s) Potential remaining

barriers (if applicable)

Alignment with existing digital and

sectorial policies

This Regulation is ensuring consistency with existing and forthcoming

EU initiatives (e.g., NIS2, the 5G Cybersecurity Toolbox, EU ICT

Supply Chain Security Toolbox).

–

Organisational measures for a smooth

cross-border digital public services

delivery

This Regulation will establish a governance architecture to ensure

coordinated implementation, consistent decision-making, and clear

accountability. More specifically:

EN 21 EN

Please list the governance

measures foreseen

– Each Member States would retain jurisdiction and operational

control over its infrastructure and servers. At the same time,

interconnection would be mandatory to guarantee operational

mobility and seamless cross-border communications. (Article 1;

Article 12)

– Member States must connect their national critical

communication systems within a defined transition period.

(Article 14)

• Designation of a National Competent Authority as the Member

States’ EUCCS single point of contact. The National Competent

Authority would oversee the development, implementation, and

operation of national mission critical broadband system and

services, ensure security and resilience, and enable

interoperability and cross-border cooperation, including EUCCS

testing, field exercises, and reporting processes. Each National

Competent Authority would need to appoint a Single Point of

Contact for coordination with other National Competent

Authorities. (Article 4)

• Member States must prepare a mission-critical broadband

communication strategy. This will set out measures to establish a

(national) critical communication system; to realise the transition

from existing narrowband/analogue communication systems to

mission-critical broadband; the interconnection into the System.

(Article 5)

• Establishment of a European Union Critical Communication

Group whose tasks include providing strategic guidance on the

establishment and further development of System and Member

States’ systems components. (Article 9)

• Framework for the accreditation of Member States’ systems. A

System Accreditation Board will be established to accredit the

readiness for inclusion of Member States’ systems into the

EN 22 EN

EUCCS based on the maturity levels detailed in the Annex to this

Regulation. Member States will be required to pursue

accreditation by making a request to the Board. (Article 10,

Article 12)

• A European Network Monitoring Centre will be established. This

will operate an IP interconnection exchange to facilitate

interconnection of critical communication systems and

monitoring of transmission capabilities. (Article 15)

• A European Security Monitoring Centre will be created to receive

and review reports and issue recommendations or corrective

actions on security incidents that affect Member States’ critical

communication systems. It does not handle security incidents

itself but acts as monitoring capacity. Following good practice

from the telecommunication sector and related policy domains,

the Network Monitoring Centre and Security Monitoring Centre

are going to be separate entities. They will be set up by the

European Commission, likely using framework contracts to

designate a specialised commercial service provider. (Article 16)

• The Commission shall adopt an implementing act to lay down

standard operating procedures for the Member States’ competent

authorities and emergency services for the consistent, efficient,

and compliant use of the System. The standard operating

procedures shall lay down the roles, tasks, coordination

mechanisms, and protocols needed for the operational use of the

System. They shall also cover elements with regard to cross-

border communication between different types of emergency

services. (Article 17)

• The Commission shall support the coordination of Member

States’ technical and operational cooperation on critical

communication. (Article 19)

Measures taken to ensure a shared //

EN 23 EN

understanding of the data

Use of commonly agreed open technical

specifications and standards

System Interconnections

– Member States shall ensure that Frontex and Europol and the

European Union Customs Authority is granted access to use the

EUCCS. (Article 2)

– Each Member State shall ensure that its mission-critical

broadband communication system is able to interconnect with the

systems of other Member States. (Article 6)

– Once the systems are accredited by the System Accreditation

Board, Member States shall ensure the interconnection of their

national systems with the EUCCS via the Mission Critical

Interconnection infrastructure (Article 11, 13 14).

–

Standards and Specifications

Interconnection would be based on common standards and agreed

technical profiles to ensure end-to-end interoperability verified prior to

connection to the EUCCS against conformance testbeds hosted by the

European Network Monitoring Centre. The testing would verify

technical, operational, and administrative conformance of the connected

national critical communication systems against the established

standards. The Commission may adopt delegated acts to establish a list or

relevant standards and technical specifications. (Article 11; Article 17)

Mission Critical Interconnection infrastructure (Article 13)

The Commission shall make available a secure, sovereign, Mission

Critical Interconnection infrastructure that facilitates the interconnection

of Member States’ systems. This will provide connectivity dedicated to

communications and information exchange between Member States’

EN 24 EN

critical communication systems.

Use of EU Satellite Secure Connectivity services (Article 18)

As concerning access to secure satellite connectivity services provided

under GOVSATCOM and IRIS², Member State competent authorities

shall ensure the availability, interoperability, and effective use of secure

satellite connectivity services within national critical communication

systems.

4.5. Measures to support digital implementation

High-level description of measures supporting digital implementation

Description of the measure Reference(s) to the

requirement(s)

Commission role

(if applicable)

Actors to be

involved

(if applicable)

Expected timeline

(if applicable)

Member States will adopt and maintain an

EUCCS strategy/roadmap aligned with the

EU legislative act and the EUCCS

Operational Plan.

Article 5 Member States

The Commission is empowered to adopt an

Implementing Act to further specify

minimum requirements for the security and

resilience of Member States’ critical

communication systems.

Article 7 Adopt an

Implementing Act

European

Commission

EN 25 EN

The Commission may adopt delegated acts

to establish a list of relevant standards and

technical specifications that Member States’

systems must comply with.

Article 11 Adopt Delegated

Act

Member States,

standardisation

bodies

The Commission shall adopt implementing

acts as relating to the use of EU Satellite

Secure Connectivity services

Article 18 Adopt an

Implementing Act

GOVSATCOM

and IRIS²

Competent

Authorities

EN 1 EN

EN EN

EUROPEAN COMMISSION

Brussels, 30.9.2026 COM(2026) 1010 final

ANNEX

ANNEX

to the

Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE

COUNCIL

establishing the European Union Critical Communication System (EUCCS)

{SEC(2026) 1010 final} - {SWD(2026) 1010 final} - {SWD(2026) 1011 final}

EN 1 EN

Annex

The following operational and technical requirements shall apply for initial, advanced and

optimal maturity levels:

Maturity

levels

Operational and technical requirements

Initial

maturity

level

1. Users: More than 50% of the total number of users of critical

communication defined by a Member State are connected to and using

the Member State critical communication broadband system.

2. User services: Use of mission-critical compliant applications, services

and devices, with focus on information exchange and shared situational

awareness.

3. Coverage: Mobile networks cover at least 70% of the Member State’s

land territory. Rapidly deployable communication tools and systems are

deployed within three days.

4. Operations: Information exchange and shared situational awareness for

operations.

5. Resilience: 8 hours backup power for the radio access network and

redundant backhaul.

6. Security: Standardised protocols and cryptographic security.

7. Spectrum: Shared spectrum with mission-critical users having priority.

8. Devices: Fit-for-purpose, including quality of service, priority and pre-

emption.

Advanced

maturity

level

1. Users: All users of critical communication defined by a Member States

use the Member State system.

2. User services: Use of mission-critical specific applications.

3. Coverage: Mobile networks cover at least 80% of the Member State’s

land territory.

(1) Rapidly deployable communication tools and systems are

deployed within two days.

(2) Satellite direct to device communication is integrated in the

Member State’s system.

4. Operations: Response enhanced by AI decision support and automatic

language translation tools.

5. Resilience: Advanced backup power.

6. Security: Advanced, including post-quantum cryptography.

7. Spectrum: Shared spectrum with mission-critical users having priority.

8. Devices with new functionalities, for example with augmented and

virtual reality.

EN 2 EN

9. Supply chain: Use of a trusted ICT supply chain.

Optimum

maturity

level

1. Users: All users of critical communication use the Member State

system.

2. User services: Use of evolved applications, using innovative devices

beyond smartphones.

3. Coverage: Mobile networks cover at least 90% of the Member State’s

land territory and 95% of the population. Rapidly deployable

communication tools and systems are deployed within one day.

4. Operations: Use of support tools for predictive and automated

response.

5. Resilience: Redundancy ensured by diversity of access.

6. Security: Post-quantum capable. Quantum key distribution.

7. Spectrum: Shared spectrum with mission-critical users having priority

and dedicated spectrum.

8. Devices: Terminals interoperable, supporting common services for

shared situational awareness and response.

9. Supply chain: Use of a trusted ICT supply chain.

EUROPEAN COMMISSION

22.05.2026

SEC(2026) 1010

REGULATORY SCRUTINY BOARD OPINION

{COM(2026) 1010}

{SWD(2026) 1010-1011}

Impact assessment / European critical communication system

________________________________

This opinion concerns a draft impact assessment which may differ from the final version.

Commission européenne/Europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGIË - Tel. +32 22991111

[email protected]

EUROPEAN COMMISSION REGULATORY SCRUTINY BOARD

Brussels, RSB

Opinion

Title: Impact assessment / European critical communication system

Overall opinion: POSITIVE WITH RESERVATIONS

(A) Policy context

First responders such as police officers, firefighters and emergency responders cannot

always easily use their radios and smartphones when working with their colleagues from

other Member States across borders.

The European Critical Communication System aims to link first responders’

communication systems in the EU and the Schengen area. This will facilitate their life-

saving operations and other work. It will also increase the EU’s resilience and strategic

autonomy.

(B) Key issues

The Board notes the additional information provided and commitments to make

changes to the report.

However, the report still contains significant shortcomings. The Board gives a

positive opinion with reservations because it expects the lead Service to rectify the

following aspects:

(1) The report does not sufficiently identify the problems, in particular in relation

to the interoperability cross-borders and within Member States, and what the

size of the interoperability problems are.

(2) The report does not sufficiently explore the preparedness of Member States and

does not assess potential technical uncertainties. It is not assessed if options are

future-proof.

(3) The analysis of impacts is not consistent. The impacts of the options, in particular

regarding the costs and benefits, are neither sufficiently assessed nor encompass

the effect that technical uncertainties could have. It does not sufficiently analyse

the distribution of costs/benefits among the various stakeholders.

2

(C) What to improve

(1) The report should better describe the dynamic baseline by analysing the current

situation of critical communication systems (CCS) in Member States, including

planning and the current/planned interoperability. It should indicate which systems

are currently in place e.g. narrowband, broadband, hybrid model in transition, and

what plans and investment cycles there are to develop and/or upgrade existing

systems in Member States. The report should provide more details regarding

technological trends (e.g. direct-to-device satellite communication, encryption, etc.),

the supply chain needs and related sovereignty aspects.

(2) The report should clarify the size of the problem in terms of the proportion of

communications that presently suffer from interoperability shortcomings, cross-

border and within Member States.

(3) The report should improve the description of options, including the baseline, building

on the Member States’ level of preparedness and related plans. The report should

better explain key requirements following from the intervention, including minimum

technical requirements. In addition, the report should provide more details on the

technical solutions and related uncertainties, trade-offs, key attributes of the new

system (security, resilience, functionalities); and how it will be ensured that the

requirements and technical solutions are future-proof, e.g. related to direct-to-device

satellite communication. The report should be clearer on the uncertainties related to

implementation and technical aspects.

(4) The report should better assess the impacts of the proposed measures as well as

potential unintended consequences. The report should enhance the assessment of

costs and benefits accruing to all stakeholders and clearly explain how the cost

estimates from several countries were extrapolated. The capital expenditures (CapEx)

and operational expenditures (OpEx) for Mobile Network Operators (MNOs) need to

be made clearer and quantified to the extent possible. The report should clarify

whether any resulting costs will be fully covered for MNOs, or not. The report should

assess to what extent other actors, e.g. commercial users, could be negatively

impacted, e.g. due to communication prioritisation on commercial networks.

(5) The sections analysing costs and benefits and comparing options should be clear and

consistent in the way that costs and benefits are presented. In particular, it should be

clarified whether benefits in terms of technological upgrades and facilitating data rich

transfer are to be attributed to the initiative, or to other investments and developments.

The costs and benefits should be analysed at the same level, i.e. if indirect benefits

are taken into account, also indirect costs should be included in the analysis.

(6) The report should, throughout the analysis, incorporate further observational data, and

consider how the evidence can be strengthened beyond the opinion data collected in

the public consultation.

Some more technical comments have been sent directly to the author Service.

(D) Conclusion

The lead Service may proceed with the initiative.

The lead Service must revise the report and its executive summary in accordance

with the Board’s findings before launching the interservice consultation.

3

Full title Creation of a European critical communication system

Reference number PLAN/2024/2851

Submitted to RSB on 22 April 2026

Date of RSB meeting 20 May 2026

Electronically signed on 22/05/2026 11:16 (UTC+02) in accordance with Article 11 of Commission Decision (EU) 2021/2121

EN EN

EUROPEAN COMMISSION

Brussels, 30.9.2026 SWD(2026) 1010 final

COMMISSION STAFF WORKING DOCUMENT

IMPACT ASSESSMENT REPORT

Accompanying the documents

Proposal for a Regulation of the European Parliament and of the Council on

establishing the European Criitcal Communication System

Proposal for a Regulation of the European Parliament and of the Council establishing

the framework for the use of the European Critical Communication Sysrem by the

Member States' services and other organisations in charge of civil protection

{COM(2026) 1010 final} - {SEC(2026) 1010 final} - {SWD(2026) 1011 final}

1

Table of contents

GLOSSARY ................................................................................................................................................... 2

1. INTRODUCTION: POLITICAL, LEGAL AND TECHNOLOGICAL CONTEXT ........................... 3

2. PROBLEM DEFINITION .................................................................................................................... 6

3. WHY SHOULD THE EU ACT? .........................................................................................................16

4. OBJECTIVES: WHAT IS TO BE ACHIEVED? ................................................................................18

5. WHAT ARE THE AVAILABLE POLICY OPTIONS? .....................................................................21

6. WHAT ARE THE IMPACTS OF THE POLICY OPTIONS? ............................................................32

7. HOW DO THE OPTIONS COMPARE? .............................................................................................39

8. PREFERRED OPTION .......................................................................................................................45

9. HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED?...................................47

ANNEX 1: PROCEDURAL INFORMATION .............................................................................................48

1. LEAD DG, DECIDE PLANNING/CWP REFERENCES ...................................................................48

2. ORGANISATION AND TIMING.......................................................................................................48

3. CONSULTATION OF THE RSB ........................................................................................................49

4. EVIDENCE, SOURCES AND QUALITY..........................................................................................49

ANNEX 2: STAKEHOLDER CONSULTATION (SYNOPSIS REPORT) .................................................50

ANNEX 3: WHO IS AFFECTED AND HOW? ...........................................................................................55

1. PRACTICAL IMPLICATIONS OF THE INITIATIVE .....................................................................55

2. SUMMARY OF COSTS AND BENEFITS ........................................................................................55

3. RELEVANT SUSTAINABLE DEVELOPMENT GOALS ................................................................56

ANNEX 4: ANALYTICAL METHODS ......................................................................................................58

ANNEX 5: COMPETITIVENESS CHECK .................................................................................................63

ANNEX 6: SME CHECK .............................................................................................................................66

ANNEX 7: ADDITIONAL MATERIALS ....................................................................................................70

2

GLOSSARY

3GPP 3rd Generation Partnership Project. A global collaboration project that

develops and maintains standards for mobile telecommunications,

including 3G, 4G, 5G, and Internet of Things technologies.

Broadband The transmission of data over a wide range of frequencies, allowing for

high-speed and simultaneous transfer of multiple data streams. Used for

example for video and other large data.

LTE Long-Term Evolution is a wireless broadband communication standard

designed to provide high-speed mobile data and improved network

efficiency, forming the foundation of modern 4G networks.

MCX Mission-Critical Services is a standardized suite of communication

services designed to ensure reliable, secure, and low-latency

communications for public safety and other critical operations.

MNO Mobile Network Operator.

Narrowband A method of transmitting data over a small frequency range, optimized

for long-distance, low-data-rate, and energy-efficient communication.

Typically used for voice communication.

Quality, Priority and

Pre-emption (QPP)

A framework used in telecommunications to manage network resources

effectively. It enables networks to prioritize mission-critical services,

ensuring that essential applications get the necessary resources.

TETRA/ Tetrapol A digital professional mobile radio standard used for secure voice and

data communication, primarily by emergency services and military

organisations worldwide.

Testbeds A collection of technical equipment and software where different

configurations and operational situations are trialled.

3

1. INTRODUCTION: POLITICAL, LEGAL AND TECHNOLOGICAL CONTEXT

This Impact Assessment Report accompanies the legislative proposal to establish the European

Critical Communication System (EUCCS), interconnecting EU Member States and Schengen

Associated Countries’ (hereinafter referred to as “Member States”)next-generation mission-critical

communication systems.

EUCCS will serve more than 5 million first responders in emergency services1 across Europe

in their daily life-saving operations and during major emergencies. Emergency services typically

include law enforcement, rescue and health/medical services, and firefighters. They may, depending

on the situation, also include other public entities in charge of security and safety. Their effective

response requires that emergency services can communicate with each other, whenever and wherever

they are.

For this document, critical communication systems refer to mobile radio communication systems

and devices used by emergency services2 with specific requirements in terms of reliability, security

and availability. These systems are built to withstand disruption and continue to operate even when

other communication channels fail. They are crucial for coordinating the response to emergency and

crises and thus ultimately help saving lives. It is important to distinguish critical communication the

various ongoing initiatives to improve secure communications. While there are overlaps in terms of

technology and user groups, secure communication does not serve mission critical needs and is not

designed for emergency response.

Evidence basis for the Impact Assessment

This Impact Assessment Report is based on multiple sources, notably a study by an independent

consortium, targeted interviews with Member States, industry, and the contribution of the

Commission Expert Group with Member States on Mission Critical Communication (hereinafter

referred to as ‘mission-critical communication group’). HOME published also a Call for

Evidence and a Commission Open Public Consultation3. The Impact Assessment Report also builds

on the EUCCS Operational Plan, a roadmap for establishing the system of systems adopted by the

mission critical communication group in May 2025. Finally, it builds on the results stemming from

EU-funded security research activities, involving Member States and European industry, and

continuously validated in dedicated trials by more than 600 responders from emergency services from

1 That figure is based on the number of expected users of EUCCS, as communicated by Member States. this is not the

number of interventions, but of personnel that uses critical communication means, and thus will benefit directly from

EUCCS. The number is based on a questionnaire to Member States’ competent authorities in which they were asked for

report the expected number of users (such as police officers, firefighters, medical services) to DG HOME. 2 ‘Emergency service’ means a service, recognised as such by the Member State, that provides immediate and rapid

assistance in situations where there is, in particular, a direct risk to life or limb, to individual or public health or safety,

to private or public property, or to the environment, in accordance with national law. https://eur-lex.europa.eu/legal-

content/EN/TXT/HTML/?uri=CELEX:32018L1972. 3https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14532-European-Critical-Communication-

System/public-consultation_en.

4

20 Member States. The technological solutions were developed in almost 10 years of EU-funded

projects BroadMap4, BroadWay5, and EUCCS Preparation6.

Political context

EUCCS is based on a strong political mandate. Technical and operational coordination projects

leading later to EUCCS were enhanced as response to the 2015-2016 wave of terrorist attacks, which

highlighted the lack of communication among emergency services in major crisis situations. The

initiate thus follows long-term and strategic approach that is based on concrete operational needs. A

key milestone was the Council Conclusions of 7 June 2021 on the protection of public spaces, which

emphasised the importance of secure, interoperable mission-critical communication. The Covid-19

Pandemic as well as the Russian war of aggression against Ukraine further highlighted the importance

of improved critical communication capabilities, across different sectors. The EU Space Strategy for

Security and Defence mentioned for the first time the creation of a European Critical Communication

System as goal for the Commission.7 In 2023, the European Commission established thus the expert

group on mission-critical communication to support it in the establishment of EUCCS.

The political commitment was reiterated in 2024 in the Commission White Paper ‘How to master

Europe’s digital infrastructure needs’, which announced to establish EUCCS by 2030.8 Further

momentum came with the 2024–2029 Political Guidelines of Commission President von der Leyen,

which stated that “our united approach to security should be centred around a new European Critical

Communication System (…)”. Also, the Niinistö Report9 urged the EU to complete the EUCCS as

soon as possible and recommended to ensure its interoperability with systems used by armed forces.

This direction was reaffirmed in 2025 in ProtectEU – the European Internal Security Strategy10 and

the European Preparedness Union Strategy, both announcing a legislative initiative11 Consequently,

the legislative proposal establishing EUCCS has been included in the Commission’s Work

Programme for 2026.

Legal context

There are existing and proposed legal acts in the EU that cover areas that are relevant for critical

communication, notably acts establishing operational cooperation in civil protection including

emergency response, acts regulating the resilience of communication networks (such as the NIS-2

Directive), and acts that regulate the telecommunication sector, including rules for public safety (such

4 Horizon 2020 project (2016-2017). The primary goal was to collect and validate the operational requirements of

emergency services with the aim to establish a core set of specifications, and a roadmap for interoperable radio

communication solutions. https://cordis.europa.eu/project/id/700380. 5 Horizon 2020 project (2018-2023). Using pre-commercial procurement, emergency services from eleven Member States

and European companies developed and demonstrated in this project technological solutions for a pan-European

interoperable broadband mobile system. https://cordis.europa.eu/project/id/786912. 6 The on-going project funded from the Internal Security Fund started in 2022. https://euccs.eu/ The demand for building

EUCCS is most importantly formulated by the EUCCS Preparation Projects and its precursors. In this framework,

emergency service personnel themselves formulate and substantiate the need. This is furthermore substantiated by the

results of the Open Public Consultation. A summary of all consultation activities, that relied primarily on evidence from

Member States and their emergency services, can be found in Annex 4. 7 https://defence-industry-space.ec.europa.eu/eu-space/eu-space-strategy-security-and-defence_en. 8 European Commission, White Paper: How to Master Europe’s Digital Infrastructure Needs (2024) https://digital-

strategy.ec.europa.eu/en/library/white-paper-how-master-europes-digital-infrastructure-needs. 9 Niinistö, S. (2024), Safer Together – Strengthening Europe’s Civilian and Military Preparedness and Readiness, p. 59

and p. 69.10 COM (2025)148final (2025) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex:52025DC0148. 11 European Commission (2025), European Preparedness Union Strategy, JOIN(2025) 130 final.

5

as the ‘112’ and eCall provisions) as part of the Electronic Communications Code and the proposed

Digital Networks Act. Still, there is no existing legal framework on which EUCCS could be based.

In fact, the call for the Commission to put forward a proposal for legislation to establish EUCCS

came from Member States acknowledging that a system of such scope and size can only be realised

with an appropriate regulatory framework.

Armed forces in Europe are another major user group of critical communication. In some Member

States, they can share some of the critical communication networks used by civil emergency services,

while in other Member States there is a separation due to technical, operational or legal reasons. At

EU-level, there is only a legal basis to regulate critical communication for civil emergency responders

(see 3.1) therefore this initiative is addressing civil emergency services. There are however various

non-legislative activities taken by the Commission to respond the recommendation of the Niinistö

report and ensure interoperability of EUCCS with systems used by armed forces in Europe, which

will also ensure its contribution in countering hybrid threats.12

Technological context

The U.S. system ‘FirstNet’ is a key reference point and has been studied by DG HOME intensively,

including during site visits in the United States. While on the technological and end-user side (a

broadband system for all types of emergency services) there are important similarities, there exist

also key differences: FirstNet is provided by one single Mobile Network Operator (AT&T) across

the whole territory of the U.S. For that, dedicated spectrum is available that is allocated to emergency

services. Thus, the model cannot be replicated in the EU, given there are neither EU-wide Mobile

Network Operators, nor is it possible to simply harmonise or reserve spectrum via the EUCCS

Regulation. On international provisions that may affect digital sovereignty, it is important to

underline that the proposed EUCCS Regulation will only very partially be able to address those

matters. The question of digital sovereignty in relation to the U.S. is a much wider policy are and

concerns telecommunication and digital policy. However, EUCCS will spell out minimum resilience

requirements, which include Member States’ control over the critical parts of the network. This builds

on existing practices in Member States and is in line with the overall cybersecurity and 5G/6G policy

of the Union. EUCCS and Member States’ next generation critical communication systems will

adhere to the globally defined 3GPP (3rd Generation Partnership Project) standards, which have a

specific working group on mission critical communication. Since broadband communication of

emergency services will run over commercial networks, the alignment to the 3GPP mobile standards

is a must. To ensure additional resilience and security, an additional

Sustainable Development Goals (SDGs)

By enabling critical cross-border communication, EUCCS strengthens the capacity of emergency

services and supports efficient coordination in emergency and crisis situations, accelerates response

to disasters and emergencies, and enhances accountability and reliability. The general and specific

objectives of the EUCCS contribute to various UN SDGs13, notably: SDG no. 11 - Make cities and

human settlements inclusive, safe, resilient and sustainable; SDG no. 13 - Strengthen resilience and

adaptive capacity to climate-related hazards and natural disasters in all countries; and SDG no. 16 -

Promote peaceful and inclusive societies for sustainable development, provide access to justice for

all and build effective, accountable and inclusive institutions at all levels

12 The Mission Critical Communication Group has a working team on dual-use and regular work is being conducted with

European Defence Agency, the EU Military Staff and NATO. 13 https://sdgs.un.org/goals.

6

2. PROBLEM DEFINITION

Based on comprehensive stakeholder consultations, ten years of technical preparation projects, and

exchanges with Member States, emergency services and industry, three main problems have been

identified that the planned EU legislation needs to address. The problems, underlying problem drivers

and consequences are presented below.

Figure 1: Problem Tree

2.1.What are the problems (Ps)?

P1 - Existing critical communication systems enable only limited operational mobility of public

authorities responsible for security and safety across borders and limited communication

between emergency services.

Critical communication systems in the EU and Schengen area are operated in isolation, with very

limited interconnection across borders and between emergency services within Member States. In

Europe there are two main mission critical communication systems, namely TETRA and Tetrapol

whose initial development date back decades, when interoperability requirements and cross-border

7

cooperation were much less a priority14. Equipment from TETRA and Tetrapol can therefore neither

be operated in the other technology’s network, nor in networks from different vendors. That is caused

by the fact that different technical standards were used (TETRA and Tetrapol, see further below), as

well as the absence of a European framework to harmonise their deployment and evolution. This

means that to this day communication between different emergency services is complicated and

whenever responders cross a border, their communication equipment cannot be used. This leads to

significant problems in daily operations, as well when responding to major emergencies15. 13 out of

25 Member States still operate narrowband-only systems (TETRA/Tetrapol), while 12 Member

States report hybrid configurations combining narrowband with some form of broadband (trials).

Interviews with EU institutions and agencies, Member States’ authorities, and emergency services

confirmed that cross-border joint operations are hindered by the absence of interconnection between

critical communication systems. For all types of emergency services, evidence shows a however a

clear need for communication in cross-border or near-border incidents16, with an increase in cross-

border incidents over the past five years17. It is however not possible to give a definitive number on

all cross-border operations of all emergency services in Europe, as this number is neither collected

anywhere, nor would it be comparable.

The operational need is shown for example by the number of joint operations at the Schengen

borders18, as well as in context of the EU-funded project EU-Patrols19. Between 2022 and 2025,

nearly 1,000 joint patrol missions have been carried out to fight crime. Information comes from

questions asked to Member States’ emergency services on how much incidents have a cross-border

or near-border nature, in which 19 Member States (out of 25) estimated this number to reach 10%. A

significant number of Member States furthermore report an increase of such incidents. Additionally,

in the European Multidisciplinary Platform Against Criminal Threats (EMPACT) Framework20 over

300 operational actions take place annually. Finally, 50 joint centres currently exist across the

Schengen Area and 59 in Europe. These centres are set up between two or more Member States.

Another indicator is the number of prepositioned firefighters across Member States. This number is

expected to reach 770 this year.

Forest fires and any other deployments of the UCPM are a key use-case for EUCCS. EUCCS covers

all communication means of emergency services, be they ground-based, waterborne or aerial. A table

detailing the increase of EUCPM activations is included in Annex 721.

Figure 2: Map showing prepositioned Ground Forest Firefighting teams deployed through the UCPM in 2025

14 TETRA, or Terrestrial Trunked Radio is a global standard for digital radio technology. In contrast, Tetrapol is a 1988

proprietary technology even if its specification is publicly available. 15 Informal Commission Expert Group on Mission Critical Communication (MCCG), Opinion 1/2025: Plan for

Developing the European Critical Communications System (EUCCS), Version 1.0 (8 May 2025). 16 Based on answers to the survey question “In your experience, what percentage of public security and safety incidents

require cross-border communication?”: 19 out of 25 respondents estimated that up to 10% of incidents require cross-

border communication. 17 Based on the survey question “Have you observed an increase in the number of cross-border incidents over the past

five years?”: 11 out of 25 report a slight or significant increase. 18 In 2025 State of Schengen Report, it is highlighted that cross-border cooperation, particularly at the regional and border

areas, has improved significantly over the past year. 19 Protecting together: EU funded project EU-Patrols in action 20 EMPACT – fighting crime together 21 See Annex 7, figure 1.

8

Thus, the growing operational need for cross-border communication and communication between

emergency services is not reflected by existing systems: in the survey22, 19 out of 25 Member States

stated that the current critical communication systems do not sufficiently support interoperability

with other Member States. Furthermore, 16 out of 25 Member States reported that handover and

roaming is a problem in their cross-border critical communications23. There have been previous

attempts at connecting TETRA systems, but only the Nordic countries - Norway, Sweden and Finland

- succeeded in integrating their networks in the Inter-System Interface (ISI)24. Attempts to replicate

the Nordic success at EU-level did not yield tangible results25.

For instance, the EU-funded project Inter System Interoperability for TETRA-TetraPol Networks

(ISITEP), developed a cross-border communication infrastructure based on IP integration26. It was

not further pursued for logistical, budgetary and operational reasons (see chapter 2.1.2. Limited

functionality of legacy systems).

While the lack of inter-operability has always been a problem, the pressure to solve it is now much

higher than it was in the last decades as the operational and legal reality has evolved and cross-border

and EU-wide missions for all types of emergencies are much more frequent than they were. A detailed

22 Throughout the study, the term survey refers to the surveys conducted in the framework of the independent study. The

visualisation of their results is included in Annex 7. While the study (which was of high quality) is a key element of the

report, the Commission nevertheless conducted its own assessment thoroughly. Stemming from that, there is the

difference in the preferred option, where the study favoured PO 2.2 (system of systems with centralised governance),

while the Commission identifies PO 2.1 (system of systems decentralised governance). 23 See Annex 7, figures 1 and 2. 24 Norway and Sweden Interconnect Secure Radio Communication Networks - TCCA. 25 However, many of the key lessons have been translated into EUCCS via the EUCCS Preparation Project, which

included since its start experts from ISI. Notably the need to supplement technical interoperability with Operational

Procedures and to set up a governance for the system to function are lessons-learnt from the Nordics. The same is true

for the experience of international partners, notably the U.S. FirstNet. 26 Inter System Interoperability for Tetra-TetraPol Networks | FP7 | CORDIS | European Commission.

9

breakdown of the maturity level of national critical communication systems is available in Annex

727.

P2 – Narrowband critical communication systems do not support data-rich capabilities

available to civilians and required for increased efficiency of operational response.

Emergency response is increasingly dependent on the rapid exchange of digital information such as

incident imagery, video, live location and structured data. Like it is already common for commercial

telecommunication, emergency services need to shift coherently from the narrowband technologies

to broadband, which allows transmission of data over a wide range of frequencies, facilitating for

high-speed and simultaneous transfer of multiple data streams. Yet, emergency services in Member

States still depend on narrowband critical communication systems such as TETRA or Tetrapol, which

provide only limited data capacity as they were initially designed for voice and short messaging. This

creates efficiency losses, because information that is available early in an incident cannot be shared

securely and systematically over the mission-critical network, leading to delays and incomplete

situational awareness. Stakeholders describe this as a practical constraint that limits their efficiency.

They highlight the increasing need to transfer voice, pictures and video data for improved operational

coordination and situational awareness28.

P3 – Insufficient resilience of critical communication infrastructure across the EU and

Schengen area

Critical communication infrastructure is a prime target for malign actors, including both State and

non-State actors. Threats range from cyber-attacks, jamming, and electromagnetic interference to

physical sabotage. At the same time, critical communication systems can be disrupted by the impact

of natural disasters, such as floods and fires as well as by network problems, caused namely by

overload. According to Member States’ authorities, the threat landscape affecting critical

communication systems has evolved significantly over the past decade, with the frequency and

impact of incidents accelerating. Therefore, comprehensive resilience including back-up, re-routing

and redundancy is essential to ensure the functioning of critical communication systems.

There are several concrete examples of the failure of critical communication systems, including the

2016 Brussels terrorist attacks, in which also the commercial mobile networks failed due to overload;

the floods of summer 2022 affecting notably Germany and Belgium in which communication base

stations were destroyed; as well as the 2025 blackout in Spain and Portugal in which lack of power

led to disruption of networks. The examples confirm the collected data at European level via the

survey across Member States, which show that a number of Member States identified problems with

the resilience of critical communication systems29.

27 Annex 7, figures 2 and 3. 28 Feedback from the EUCCS Preparation trials carried out in Italy (November 2025) and Germany (March 2026). 29 See Annex 7, figure 5.Critical communication systems must have very high reliability, since their disruption has direct

impact on the ability to respond to emergencies. Thus, the fact that eight Member States out of 25 consider their current

system as not fully reliable or very reliable is evidence for the problem described. ‘Moderately reliable’ is not considered

sufficient. When national systems are being interconnected, there needs to be also minimum harmonisation of the

resilience and thus the reliability needs to be assessed as high in all Member States in the future.

10

Results of the Commission Open Public Consultation30 also point to a need to address existing gaps

in resilience31. Industry feedback supports the finding that resilience gaps translate into degraded

performance during crises32. Power outages are seen as an even stronger constraint33. On structural

resilience, industry respondents point to the effect of limited redundancy/backup, hindering

effectiveness34.

2.2. What are the problem drivers (PDs)?

PD1 – Limited interoperability between critical communication systems, caused by cost,

technological and operational complexity of interconnecting, and diverse technologies in use.

Interoperability constraints are rooted in a heterogeneous technology and uneven modernisation

across Member States. Both desk research and stakeholder consultations converge on the same

structural point: critical communications across Member States have evolved on different timelines

and with different technical choices, resulting in systems that do not interconnect consistently across

borders and between emergency services35.

Survey evidence illustrates the extent of this diversity of technologies in use. Most Member States

still operate only narrowband systems36 and the deployment of national critical communication

systems also varies widely from early deployments in the 1990s to systems introduced as recently as

2020–2024, reflecting different investment cycles and evolution pathways37. Targeted interviews

showed that reasons include the lack of a European broadband alternative and lengthy contracts for

narrowband technologies (going up to 20 years).

When asked specifically about 3GPP-standardised LTE/5G deployment for critical

communications38, only 9 out of 25 Member States report having already started deployment, while

a substantial number of Member States plans deployment only in later timeframes, including 5 out

of 25 Member States only targeting 203639. This is due to the lack of funding and a harmonised

European framework. The resulting heterogeneity and fragmentation results in practice in limited

30 The Commission Open Public consultation - although helpful to confirm certain assumptions - is in fact much less a

basis for the assessment than the elements mentioned above and must not be confused with the surveys conducted by the

independent study. 31 Feedback received from secunet Security Networks AG, Telefonica SA, Verisure Group, the Confederation of

European Security Services (CoESS), and the Firefighters of Madrid Municipality. 32 Based on the industry survey answers to the question “To what extent does the network congestion due to high traffic

hinder the effectiveness of cross-border critical communication systems during crisis situations?”. 33 Based on the industry survey answers to the question “To what extent do the power outages hinder the effectiveness of

cross-border critical communication systems during crisis situations?”. 34 Based on the industry survey answers to the question “To what extent do the absence of redundancy or backup systems

hinder the effectiveness of cross-border critical communication systems during crisis situations?”. 35 Informal Commission Expert Group on Mission Critical Communication (MCCG), Opinion 1/2025: Plan for

Developing the European Critical Communications System (EUCCS), Version 1.0 (8 May 2025). 36 Based on the survey question “What is the technological evolution or maturity level of your country’s current national

critical communication system?”: 13 out of 25 Member States still operate narrowband-only systems (TETRA/Tetrapol),

while the remainder report hybrid configurations combining narrowband with some form of broadband (trials). 37 Based on Member States answers to the survey question “Since when has/have your existing national critical

communication system(s) been in operation?”. 38 3GPP is the backbone of modern mobile communications, laying the foundation for seamless connectivity through its

rigorous standardization process. 39 Based on the Member States answers to the survey question “Has your country designed, implemented, or begun

deploying a broadband network based on 3GPP-standardised LTE and/or 5G technologies for critical communications?”.

11

interoperability. Even within Member States, interoperability between different types of emergency

services is not universal40. Cross-border interoperability is significantly less developed41.

Respondents also identified technical barriers, meaning the incompatibility of its equipment and

services, within TETRA and Tetrapol standards as obstacle to interconnection, followed by the

financial and operational burden of sustaining interconnection arrangements42. Interview outcomes

reinforce this finding. The consulted EU institutions and agencies, national authorities, end-user

organisations and industry actors consistently point to interoperability – both cross-border and cross-

agency - as one of the most critical shortcomings affecting cooperation and incident response.

Limited interoperability due to incompatible technologies and varying levels of system maturity

emerges as the most important problem driver in the Commission Open Public Consultation, pointed

out by 88% of respondents43.

PD1 has a causal link with P1, since the limited interoperability between Critical Communication

Systems leads, in practical terms, to limited cross-border operational mobility and communication

between emergency services.

PD2 - Insufficient network coverage in certain areas of Member States, specifically border

regions.

Coverage limitations are a structural constraint, particularly in border areas and sparsely populated

regions. Even where systems achieve high coverage, stakeholders note that operationally relevant

coverage is not evenly distributed: Rural and remote areas can face a weaker signal, limited capacity

and fewer resilience features, while coverage near borders may be intentionally reduced or

engineered conservatively to manage interference risks. This can create “dead zones” of degraded

service where cross-border deployments and mutual assistance are most likely to be needed.

Survey results indicate that most respondents consider overall coverage to be strong, but a non-

negligible minority still report gaps, suggesting that baseline coverage remains uneven across Europe,

as the Nordic countries reported for example in the Mission Critical Communication Group that they

face more pronounced coverage constraints44.

Stakeholders emphasise that coverage remains a key operational determinant. Where connectivity is

weak, responders must rely on workarounds and operate with reduced situational awareness,

therefore cross-border cooperation becomes more difficult. The practical complexities of ensuring

reliable coverage in border regions, where spectrum coordination and interference management can

constrain how networks are configured and where seamless handover cannot be assumed, have been

identified. In the Commission Open Public Consultation, a significant share of respondents points to

40 Member States‘ answers to the question “To what extent does/do the current national critical communication system(s)

support technical interoperability between public safety and emergency services within your country?”: 13 out of 25

Member States report “fully interoperable” and 5 out of 25 “mostly interoperable”, while 7 out of 25 report only moderate

to no cross-agency interoperability. 41 Based on the survey question “To what extent does/do the current national critical communication system(s) in your

country support technical interoperability with critical communication systems in other EU Member States?”: 11 out of

25 report cross-border interoperability is significantly less developed. 42 Based on the answers to the survey question “What are the main barriers to establishing such interconnections?”. 43 Member States report systems are “not interoperable at all” with neighbouring Member States, and only 2 out of 25

report full cross-border interoperability. 44 18 out of 25 Member States rate coverage as excellent (>90% geographic or >95% population coverage), and a further

3 out of 25 rate it as good. However, 4 out of 25 report only moderate coverage.

12

insufficient network coverage in certain areas (68%, 17 out of 25 respondents). Uptake of satellite-

based solutions to increase coverage remain limited.

PD2 also contributes to P1 because weak coverage means public authorities in charge of security and

safety cannot rely on seamless connectivity when operating in border, rural and remote regions,

which, in turn, limits operational mobility.

PD3 – Fragmentation of governance models, roles, responsibilities and operating procedures

during crises, as well as inconsistent legal frameworks across agencies and national systems.

Governance, operational, and legal fragmentation remain a constraint45. Desk research underlines

that operational mobility depends on more than technical connectivity: It requires alignment of legal,

organisational and semantic dimensions, yet EU and Schengen-wide standard operating procedures

are absent, and existing arrangements are often bilateral, or case-specific46.

Survey results indicate uneven preparedness to manage crises, specifically across borders. Only 8 out

of 25 Member States report having operational procedures in place to support cross-border missions

and collaboration, while the others do not have such procedures, have not confirmed them, or report

that they are not applicable in practice47. In the absence of a common operational framework, public

authorities in charge of security and safety continue to rely on ad-hoc arrangements and bilateral

agreements to communicate and cooperate, often leading to suboptimal operational outcomes in

cross-border emergencies. While governance of critical communication systems is reported as

centralised in most cases (20 out of 25 Member States), responsibility for managing critical

communications is typically spread across several bodies (ministries, agencies and, in some cases,

state-owned operators or contractors), and a minority of countries also involve regional and local

entities, creating coordination requirements during crises48.

Two-thirds of respondents to the industry survey identify fragmentation in the governance of critical

communication systems across Member States as a main current challenge. Moreover, a majority of

industry respondents (5 out of 9) assess that fragmented governance and coordination between

authorities hinder the effectiveness of cross-border critical communications, indicating that

governance gaps are not only a public-sector concern49. Fragmentation of governance frameworks,

45 Inter-operability is only partly a technical problem. It remains entirely true that TETRA and Tetrapol are technologies

that can only be integrated with significant effort. However, the main reason inter-operability was never systematically

pursued and thus not achieved across the EU is the lack of a governance that could manage the complexity of aligning

technical dimensions, operational procedures, harmonisation of minimum requirements and investment cycles. The three

Nordic countries succeeded also because cross-border cooperation in security and safety matters is based on a very

specific culture of trust and cooperation that cannot be replicated simply between all Member States. Only EU-level

action will be able to establish EUCCS. This is similar to other complex initiatives in the security and telecommunication

domains: the Schengen Information System, the Entry-Exit-System, the introduction of a common charger or the end of

roaming charges for commercial customers are examples where technically Member States, or the market, could have

tackled a specific problem, but only EU-level governance and regulatory powers made it possible in the end. 46 Informal Commission Expert Group on Mission Critical Communication (MCCG). Report from the Working Group

on “Standard Operating Procedures” (SOP), Version 1.0 (29 May 2024). 47 Based on the EU Member States survey answers to the question “Do you have operational procedures in place to

support cross-border missions and collaboration between authorities from different EU Member States?”. 48 Based on the EU Member States survey answers to the question “How is the governance of the national critical

communication system(s) organised in your country?”. 49 Based on the Industry survey answers to the questions “What are the main challenges your organisation faces in current

cross-border critical communication systems? Select all that apply.” and “To what extent do the fragmented governance

and coordination between authorities hinder the effectiveness of cross-border critical communication systems during

crisis situations?”.

13

roles and procedures across agencies and Member States is also identified as a key constraint in the

Commission Open Public Consultation (84% of respondents).

Problem Driver 3 feeds Problem 1 because fragmented governance, standard operating procedures

and legal frameworks prevent consistent authorisation and coordination across agencies and borders,

limiting operational mobility and inter-agency communication.

PD4 – The developments of cellular technology in commercial communications raise the

expectations about the functionalities that emergency services should have access to beyond

what legacy systems can deliver.

PD4 concerns a widening capability and expectation gap driven by rapid advances in commercial

cellular communications. Adaptation to new communication technologies is traditionally more

cautiously pursued by emergency services, because reliability and ensured functionality are the most

important requirement. Mass-market smartphones, fourth and fifth generation mobile networks

(4G/5G) and mainstream applications have normalised real-time, content-rich communications

(images, video, location and data), and this increasingly shapes what emergency services consider

necessary. However, many critical communication systems still rely primarily on narrowband, which

cannot provide routine, data-intensive use.

Stakeholder evidence consistently points to rising operational demand from emergency services for

richer functions such as sharing images and video, improving situational-awareness tools and

collaborating in real time50. Interviewees point out that the personnel of emergency services

sometimes compensate for the lack of these functionalities through parallel personal smartphones

and consumer applications, which creates security risks. Video and large data transfer are currently

missing. This translates into basic things like live video-feeds during operations, as well as the lack

of the ability to integrate data from sensors like those monitoring position and vital signs, or vehicles,

such as drones and CCTV systems.

Therefore, there is a growing demand to transition to 3GPP-based broadband systems, which would

enable mission-critical services beyond voice, including mission-critical data and video delivered

over 4G/5G networks.PD4 links directly to P2, as commercial cellular evolution is raising the

baseline of what “functional” critical communications look like, and legacy systems cannot meet

those expectations.

PD5 – Existing security standards, technologies and infrastructures are insufficiently adapted

to address evolving threats.

The threat environment for critical communications is evolving faster than national systems. Legacy

narrowband systems benefit from a non-IP-based architecture that provides intrinsic protection

against certain cyber threats, but these technologies are 25 years old. In 2023, the “TETRA:BURST”

report revealed a set of vulnerabilities in TETRA networks, including a weak cryptographic scheme

that enables attackers to de-anonymise and track users51.

Industry respondents report that cybersecurity vulnerabilities hinder cross-border critical

communications during crises at least “to a certain extent”52. This finding is supported also by

50 Feedback from operational trials of the EUCCS Preparation Project. 51 Midnight Blue, The TETRA:BURST Vulnerabilities (2023) https://www.midnightblue.nl/research/tetraburst. 52 Based on the Industry answers to the survey question “To what extent do the cybersecurity vulnerabilities hinder the

effectiveness of cross-border critical communication systems during crisis situations?”: 4 out of 9 at least “to a certain

extent” and 1 out of 9 report “to a great extent” or “always”.

14

feedback given by emergency services via the Commission Open Public Consultation53. Respondents

to the Commission Open Public Consultation highlight limitations in existing security standards and

infrastructures are a major challenge (76%, 19 out of 25 respondents).

Desk research points to a regulatory gap. There is currently no applicable EU legal act that addresses

comprehensively the resilience of systems used for mission-critical communications as a sector.

Horizontal instruments such as NIS2 Directive54 and CER Directive55 set obligations for the digital

infrastructure sector, but critical communication systems are excluded from their scope56. At the same

time, relevant EU cybersecurity initiatives, notably the 5G Cybersecurity Toolbox57, do not yet fully

translate into harmonised, mission-critical requirements and assurance practices across the diverse

national configurations used for public safety and security58. However, the recently proposed Digital

Networks Act59, provides for an obligation for providers of public electronic communication

networks, and publicly available electronic communication services to take all necessary measures

to ensure uninterrupted availability of critical communications60.

PD4 directly feeds P3, as evolving threats that outpace existing technologies and related security

standards and practices contribute to reducing the resilience of critical communication systems.

PD6 - Dependence on a single national mission-critical network with no assured alternate

network to use in case of disruption.

Member States’ narrowband networks have no assured alternate network to use in case of disruption.

Recent natural disasters show that critical communication systems can suffer cascading disruption

when power, backhaul and site autonomy are simultaneously stressed61.

Because there is generally no secondary mission-critical network, a national outage can rapidly

become a single point of failure for command-and-control and responder safety. In contrast, 3GPP

standards for mission critical services treat mission-critical communications as an application and

service layer that runs on dedicated servers and is accessed over a mobile network. This architecture

53 Feedback received from the German Police Trade Union, the Ministry of Justice and Digital Affairs of Estonia, the

Government of Canary Islands, and the Firefighters of Madrid Municipality. 54 Directive (EU) 2022/2555, https://eur-lex.europa.eu/eli/dir/2022/2555/2022-12-27/eng.The NIS2 Directive does not

apply to EUCCS and Member States’ critical communication systems, since it excludes as per Article 2 ‘public

administration entities that carry out their activities in the areas of national security, public security, defence or law

enforcement, including the prevention, investigation, detection and prosecution of criminal offences.’ On the other hand,

the minimum requirements for national critical communication systems under Policy Measure 2.6 will be coherent with

and inspired by NIS-2 and the CER-Directive.55 Directive (EU) 2022/2557, https://eur-lex.europa.eu/eli/dir/2022/2557/oj/eng. 56 Informal Commission Expert Group on Mission Critical Communication (MCCG), Workgroup on Security 57 European Commission, The EU toolbox for 5G security (29 January 2020) https://digital-

strategy.ec.europa.eu/en/library/eu-toolbox-5g-security. 58 Impact assessment study team. Co-creation Workshop #1 on the Intervention Logic. (02 October 2025). 59 Proposal for a Regulation on Digital Networks COM(2026) 16 final. 60 The proposal for a Digital Networks Act (DNA) includes provisions linking to the envisaged EUCCS Regulation. The

DNA was drafted in coherence with EUCCS and states ‘The Commission will adopt in 2026 a proposal to establish the

European Union Critical Communication System (EUCCS), to be operational by 2030, that will provide broadband

based secure communication services for public authorities across the EU and the Schengen area. The DNA proposal

complements those efforts by contributing to the EU’s overall capacity to respond to security threats and crises.’ Recitals

29, 38, as well as Articles 5 and 9 of the DNA proposal are designed to pave the way to Policy Measures described in

this draft impact assessment report, including PM 2.6 and 2.8. 61 For example, Ireland’s official post-incident review of Storm Éowyn reports that TETRA base station sites were

impacted by infrastructure damage or power loss, and that some services experienced significant disruption and loss of

voice capability in the worst-affected areas.

15

can guarantee higher resilience because the same mission critical service can, in principle, be reached

via more than one underlying mobile network operator network. This is in line with stakeholder

findings, as most respondents to the industry targeted survey report that the absence of redundancy

or backup systems hinders effectiveness to at least a certain extent62, and the interviews with the

Mission Critical Communication Group explicitly point to the need for multi-operator resilience.

PD6 directly contributes to P3, because reliance on a single mission-critical network with no assured

operational alternative translates into reduced resilience.

2.3.How likely is the problem to persist?

Problem 1. Limited operational mobility

All signs point toward this problem persisting and worsening. It is possible to make these assumptions

based on the overall fragmentation and uneven technological maturity observed across Member

States. Without EU action, the legal framework for mission critical communications would remain

fragmented, with significant disparities between Member States and disparities in investment cycles,

governance models and national priorities. Thus, operational mobility is not achieved, while the need

for it continues to rise.

Observing the rising trend of cross-border emergencies, as shown for example by the increasing

number of requests of cross border intervention by fire authorities63, it is likely that this trend will

continue. Consequently, emergency services would continue to lack effective means to communicate

in cross-border and inter-agency missions, negatively affecting their ability to effectively tackle

cross-border missions.

Problem 2. Limited functionality of legacy systems

All signs point toward this problem worsening. The telecommunication world is marked by rapid

technological change. In the commercial sphere, transfer of video and large data is a reality since a

long time, allowing also for a dynamic ecosystem for the development of applications and solutions.

The gap between what is available in the commercial and business world compared to what current

narrowband critical communication systems allow for is increasing with each new broadband-based

innovation. It is one of the reasons that emergency services are in many cases forced to switch to

commercial solutions that are neither designed, not equipped for critical communication purposes.

The reliance on narrowband creates a gap between law enforcement and malign actors, given the

latter ones can easily adopt the latest commercial solutions, or even tailor-made communication

solutions for criminal purposes. Developments related to Artificial Intelligence, Internet of Things,

satellite connectivity and quantum will only widen the gap of what current narrowband can offer,

compared to what is needed and expected by emergency services to effectively conduct their

missions.

62 Based on the industry answers to the survey question “To what extent do the absence of redundancy or backup systems

hinder the effectiveness of cross-border critical communication systems during crisis situations?”: 5 out of 9 Member

States report that the absence of redundancy or backup systems hinders effectiveness to at least a certain extent. 63 For instance, in 2025 there were 29 wildfires in Portugal in which Spanish firefighting resources were deployed, and

14 wildfires in Spain in which Portuguese resources were deployed. Data is available at

https://www.proteccioncivil.es/documents/20121/0/Informe%20anual%20de%20incendios%20forestales%202025/e21

875ac-6eec-9ef0-3bc8-06227b443bcb.

16

Problem 3. Insufficient resilience

All signs point toward this problem persisting, moreover it is likely to worsen. The strategic

framework of the EU rests on the assumption that challenges both in terms of man-made hazards,

including ones stemming from geopolitical confrontation, as well as the impact and frequency of

natural hazards are likely to increase64.

As described above, communication infrastructure has specific requirements for ensuring its

resilience. Without action being taken that would also accelerate the transition of critical

communication systems towards broadband, those systems would not benefit from the concrete

advantages in terms of resilience that broadband offers (redundancy, dynamic environment for threat

detection and mitigation, continuous innovation in the commercial sphere, back-up solutions via non-

terrestrial assets etc.). Furthermore, the communication world is moving towards broadband fast and

narrowband technologies will not enjoy the same level of innovation and maintenance. In case

narrowband would be maintained, the problems with its resilience would worsen over time, given

that there are less providers of security solutions, encryption and less experts for maintenance.

3. WHY SHOULD THE EU ACT?

3.1.Legal basis

The initiative shall enable emergency services to carry out their operations across the EU and

Schengen area. This can only happen based on common requirements, rules and procedures which

are legally binding and directly applicable in all Member States.

The legal bases of the legislative proposal are Articles 87 and 196 of the Treaty on the Functioning

of the European Union (TFEU). Article 87(2) TFEU provides a legal basis for the establishment of

EUCCS for public security authorities, notably law enforcement, border guards, customs. The

legislative proposal should be intended as a further development of the Schengen acquis. Article 196

TFEU provides a legal basis for public safety authorities, notably firefighters, civil protection and

rescue services. For legal reasons, two separate legal instruments would be required to cover all

emergency services. Other users, notably armed forces, other public authorities or operators of critical

infrastructure can be included by national decision. However, there is no obligation stemming from

the EU legal act.

3.2.Subsidiarity: Necessity of EU action

The principle of subsidiarity is described in Article 5(3) TEU.

Over the past few years, Member States have experienced increasingly frequent and more severe

natural and man-made disasters. Disasters such as the Covid-19 pandemic, catastrophic floods of July

2021 affecting Germany, Belgium and the Netherlands, or the Iberian Peninsula blackout in April

2025. Crises affecting more than one Member State and requiring joint response are the new normal.

Member States acknowledge thus the need for EU action: the Mission Critical Communication Group

endorsed in 2025 the EUCCS Operational Plan tofacilitate the task of coordinating the

establishment of EUCCS. There are thus strong involvement and constant consultation with Member

States, which requested action by the Commission on EUCCS, including by proposing a legal basis.

64 See ProtectEU: a European Internal Security Strategy COM(2025) 148 final (Brussels, 2025) https://eur-

lex.europa.eu/legal-content/EN/TXT/?uri=celex:52025DC0148 and European Preparedness Union Strategy,

JOIN(2025) 130 final.

17

Also in relevant Council working parties, as well as at the level of the Council itself, Member States

had asked for the establishment of EUCCS for many years 65.

Furthermore, the study highlighted that one of the key challenges affecting the current situation of

critical communications across the EU is the existence of varying levels of technological maturity of

critical communication systems across the EU66. Given that these systems evolve from different

baselines, shaped by different budgetary capabilities, procurement cycles, and national risk

appetite67, the transition toward advanced technologies is progressing at an uneven pace.

Given that EUCCS will cover the whole of the EU and the Schengen area and will need to rely on a

set of binding common rules, there is no realistic alternative to EU action. In the absence of such

action, Member States would need to engage in a very large number of bilateral and multilateral

agreements, operational procedures and technical arrangements, assuming they would still pursue the

goal of interconnecting their next generation mission critical communication systems.

3.3.Subsidiarity: Added value of EU action

Subsidiarity (For non-exclusive competence)

The Union’s action can be considered more effective than what Member States acting alone can do,

as it can establish a harmonised EU framework facilitating cross-border and interagency critical

communications. Completing EUCCS for the whole of the EU and Schengen area by 2036 will

directly benefit the operations of around five million members of emergency services in Europe to

save lives and prevent harm to health and property, presenting one of the highest added values.

EUCCS will streamline the costly deployment of mission-critical broadband and thus create benefits

for adequately planning of human and financial resources. Assuming all Member States are

completing the transition to broadband by 2036, Member States remain responsible for covering the

costs for their national systems. Several Member States (e.g. France, Finland) are currently allocating

national funding for this purpose, using also EU funding such as the Recovery and Resilience Facility.

Other Member States indicated in the Mission Critical Communication Group that they would seek

EU financial support to transition to mission critical broadband. Such funding could easier be part of

the future EU funding programmes, if it corresponded to a legal obligation.

When measuring the added value of EU action, it is important to consider that the technical basis for

EUCCS is the result of cooperation of the Commission, Member States and European industry. The

components of the system have been developed and tested by Member States’ stakeholders, notably

around 100 emergency services to validate that the solution creates added value. The surveys

conducted clearly show that Member States expect that the creation of EUCCS will address current

challenges in cross-border critical communication:

Figure 3: Reported level of expectation for the EUCCS to address current challenges in cross-border critical communications68

65 Council Conclusions 9545/21 on the Protection of Public Spaces (2021); Council Recommendation (EU) 2022/915 on

operational law enforcement cooperation (2022);. 66 Targeted interview with MCCG Working Group for Action 5: Alignment of National Components (11 December

2025).

68 Based on the survey answer to the question “To what extent would the EUCCS address these challenges and improve

future responses?”.

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4. OBJECTIVES: WHAT IS TO BE ACHIEVED?

4.1.General objective

The general objective is to enhance Europe’s capacity to react swiftly and effectively to incidents and

crises that require response across borders and by cooperation of different types of emergency

services.

Figure 4. Objective tree

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4.2.Specific objectives

The specific objectives have been identified as in line with other EU policies:

4.2.1 SO1: Promote interoperable and secure cross-border and cross-agency/operator critical

communication and operational mobility among emergency services.

The objective is to provide for emergency services a resilient critical communication infrastructure

that enables seamless operational mobility promote interoperability and strengthen cross-border and

cross-agency operational mobility for an enhanced emergency response69. Specifically, all the critical

communication systems of law enforcement, civil protection, and other emergency response services

across Member States need to be harmonised and interconnected.

Successful implementation of SO1 will be measured by the number of Member States that have

interconnected critical communication systems, providing cross-border and inter-agency critical

communication. This will be assessed in three stages: 2030, 2033, and2036.

4.2.2 SO2: Support Member States to deploy broadband critical communication systems

The ability to exchange data-rich information, such as images or video, across borders and in real

time was highlighted as a central reason for the upgrade of the current legacy systems used, notably

TETRA. Most of the Member States (17 out of 25) report a planned upgrade of their national legacy

69 White Paper: How to Master Europe’s Digital Infrastructure Needs? (2024)

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narrowband systems70. There is no contradiction between the upgrade of narrowband systems and

the transition to broadband. All critical communication systems in Member States will run for a

certain time in a hybrid setting, in which TETRA and mission-critical broadband will run in parallel.

This is called the ‘migration phase’ in which user groups shift step by step from TETRA to broadband

networks. It is important to underline that it is not EUCCS that ‘replaces’ TETRA. It is the

technological shift to broadband that will phase out narrowband technologies, like it has done already

in commercial telecommunication.

Targeted interviews point to the need of transition to broadband to allow for the deployment of

interoperable 5G mission-critical capabilities. Broadband communications technology satisfies the

current and evolving needs for increasing data consumption, supporting advanced functionalities,

such as real time incident reporting, high-resolution Geographic Information System (GIS), and high

bandwidth data exchange (i.e., live video, biometric data), and facilitating the integration of Artificial

Intelligence. In this regard, interviewees also underlined the role of harmonisation at technological

level in making national investment in critical communications more attractive, while supporting the

development of a more integrated and technologically advanced European critical communications

ecosystem overall.

To conclude, a consensus is observed as to the necessity to transition to broadband as this would

ensure that critical communication systems remain technologically robust, reliable, and future‑proof,

able to adapt to new technologies and develop new capabilities.

Successful implementation of SO2 would be measured by the number of Member States who

deployed mission critical broadband systems as well as the total number of emergency services’

personnel that are connected to those systems.

4.2.3 SO3: Facilitate the achievement of a high and consistent level of resilience of critical

communications across Member States

Resilient infrastructure is needed to ensure connectivity and availability in all circumstances. In this

context, resilience refers to the capacity of critical communication infrastructures to withstand,

absorb, and rapidly recover from natural and man-made threats. Notably this can be achieved by

ensuring advanced backup power, redundant coverage, separation of mission critical core network

and radio access network as well as protocol and cryptographic security. In terms of security a

broadband system would improve encryption and authentication allowing for stronger protection

against cyberattacks. Resilient critical communication systems can thus be achieved by progressively

strengthening the robustness of national critical communication systems through common resilience

and security baselines and the deployment of advanced protective measures at EU level. Survey

findings indicate that further action at the EU level would strengthen the overall resilience of national

critical communication systems71. Furthermore, achieving this specific objective would contribute to

future-proofing critical communication systems, increasing Europe’s strategic autonomy in cases of

geopolitical developments that harm EU interests. Successful implementation of SO3 would be

70 Member States may furthermore decide to run TETRA systems for longer periods to have a proven and widely available

back-up solution for voice communication, which remains the single most important type of communication that must

not fail during an emergency. 71 Based on the industry survey answers to the question “To what extent would the EUCCS provide greater resilience of

critical communication?”, with 3 out of 9 industry respondents considering that it would do so “to a certain extent” and

another 3 out of 9 “to a great extent”.

21

measured by the compliance of Member States to the commonly agreed minimum resilience

requirements72.

5. WHAT ARE THE AVAILABLE POLICY OPTIONS?

5.1.What is the baseline from which options are assessed?

The baseline scenario is that there have been very few successful implementations of interconnecting

emergency services’ networks across borders, as well as limitations to critical communication

between different types of emergency services.

The legal framework for mission critical communications is fragmented as no harmonisation takes

place. On the technical side and despite project-level achievements, significant disparities between

Member States exist that continue to depend on narrowband systems as their primary national critical

communication systems, and those Member States who introduced complementary broadband

services. 13 out of 25 Member States still operate narrowband-only systems (TETRA/Tetrapol),

while 12 Member States report hybrid configurations combining narrowband with some form of

broadband (trials). Technological dependence on third countries in critical communication is today

low. Not a single Member State is dependent on a third-country provider for their core network.

While there are important suppliers of non-EU origin, there is no systemic dependency problem,

given that alternatives in Europe are available. The aim is at least indirectly to maintain such level of

autonomy, while having to consider the realities in the global digital communication market. There

are limits on what an initiative establishing EUCCS can do to address systemic dependencies in the

commercial digital infrastructure and telecommunication sector.

Consequently, emergency services that rely on an outdated technical solution frequently revert to

unsatisfactory ad hoc arrangements, or commercial solutions unfit for critical operations to

communicate. Effective operational cooperation between services and across borders is significantly

limited by that.

5.2.Description of the policy options

Starting from this baseline, three possible policy options have been considered. The table below

presents the intervention logic by showing what problem each policy option is addressing and what

it is expected to achieve.

Figure 5: Intervention logic

72 As defined in the EUCCS Operational Plan and later to be adopted by an Implementing Act (see policy measures).

22

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5.2.1. Policy option 0: no further EU intervention

PO0 assumes the case of no EU intervention, meaning that the scenario described in the

baseline would persist. While market-driven or voluntary initiatives could promote cooperation

between Member States’ critical communication systems, such developments have not

materialised in the last decades and would remain unlikely in the absence of a coordinated

European approach. Furthermore, the costs for the necessary upgrades to modernise national

critical communication systems to broadband would continue to be borne entirely by Member

States individually, without any coordinated investment and financial support at EU level.

Under PO0, fragmentation between Member States’ critical communication systems is

projected to increase, given the uneven technological maturity across Member States.

5.2.2. Policy option 1: voluntary pursuit of technical interconnectivity

PO1 is based on voluntary measures to promote interconnection of critical communication

systems between Member States. This would include the publication of non-binding guidance

by the Commission. Similarly to PO0, Member States would continue to develop their national

critical communication systems independently. They would either maintain narrowband

systems or transition to broadband solutions, in line with national strategies, priorities, and

available resources.

PO1 is addressing in principle all problems and their drivers. However, given the voluntary

nature it is extremely unlikely that all Member States and all emergency services would

participate in a ‘voluntary EUCCS’. The survey launched with Member States concludes that

only eleven Member States would be willing to work on interoperability of broadband systems

in the absence of a binding EU framework. Thus, while PO1 in theory aims at all problems and

their drivers, it is very unlikely to solve any of them in a satisfactory manner. The assumption

is further substantiated by the fact that the initial approach in the BroadMap and BroadWay

projects (2016 – 2022) was based on a voluntary approach that should lead to a coordinated

procurement of inter-operable solutions. It is to a significant extent the experience from that

project which led to the common understanding of Member States and the Commission services

that only an approach based on binding EU-level rules is likely to successfully establish

EUCCS.

In PO1, the Mission Critical Communication Group would recommend relevant international

standards (e.g. those developed by the European Telecommunications Standards Institute or

3GPP) and promote common operational procedures to support interconnection among

participating Member States. EU funding of projects could be leveraged aligning to existing

priorities. PO1 would include those measures, which may be taken entirely or selectively:

PM1.1 - Continuation of the mandate of the Mission Critical Communication Group as an

informal expert group

The Commission would renew the Mission Critical Communication Group mandate,

maintaining it as expert group with an advisory role to support its work on interconnectivity,

standards, the modernisation and innovation of national critical communication systems, and

on voluntary interconnection between Member States. It would also contribute to the

development of non-binding working documents, including guidance on standards for critical

24

communication systems interconnection and security as well as the EUCCS Standard

Operating Procedures Handbook.

PM1.2 - Promotion and guidance on standards for interconnectivity and security

This PM promotes the consistent adoption and implementation of standards, notably those

developed by the European Telecommunications Standards Institute and 3GPP, to enable

technical interconnectivity among Member States. The Commission, supported by the Mission

Critical Communication Group, would ensure awareness, encourage adoption of relevant

standards.

PM1.3 – Exchange of best practices on critical communication systems modernisation and

innovation

This PM facilitates the exchange of best practices between Member States in transitioning from

narrowband systems to broadband-based solutions that meet evolving operational and security

needs of critical communications. Through the Mission Critical Communication Group,

Member States would share and consolidate technology-neutral approaches on phased-in

migration strategies, the adoption of broadband technologies for critical communications, and

the incorporation of innovative features such as secure data exchange and need resilience

mechanisms.

PM1.4 – Development of an EUCCS Standard Operating Procedures Handbook

This PM develops a voluntary EUCCS Standard Operating Procedures Handbook to support

Member States in harmonising operational procedures under the EUCCS framework.

Coordinated by the Mission Critical Communication Group, the Standard Operating

Procedures Handbook would define common operational procedures – including a common

taxonomy for Member States and guidance on governance, roles and responsibilities, and crisis

workflows, and it would serve as reference for aligning national Standard Operating Procedures

with best practices in critical communications at EU-level.

PM1.5 – Recommendations on resilience of critical communication systems infrastructure

This PM foresees non-binding recommendations to Member States, issued by an EU body in

collaboration with the Mission Critical Communication Group, notably relating to

cybersecurity and hybrid threats to strengthen the resilience of national critical communication

systems infrastructure. These recommendations would provide a common ground of guidance

and examples of technical and functional improvements, gathered through peer exchange, to

enhance preparedness against cyberattacks and hybrid threats, this way reducing major

disruptions, and improving the overall resilience and security of critical communication

systems across Member States.

5.2.3. Policy option 2: legislative proposal establishing a system of systems

PO2 includes the adoption of an EU legal act providing a legal basis for the establishment of a

decentralised EU framework (i.e., a ‘system of systems’) enabling the interconnection of

Member States national critical communication systems while preserving Member States’

sovereignty over their national critical communication systems.

25

The legal act would set out objectives, roles and responsibilities, minimum technical

requirements, and cross-border procedures. Implementation would take place gradually

following a convergence period with an initial system connecting around eight to ten Member

States by 2030, followed by a progressive expansion of services and participation in 2033 and

2036.

At the EU-level, there would be no central data management infrastructure or central operations

capacity but a governance, as well as common support functions for Member States’ systems.

Interconnection of Member States’ systems will be facilitated, and a central EU level

monitoring capacity will be established. The combination of those elements is the EU-level

component of EUCCS.Two sub-options exist that differentiate from each other according to

the level of centralisation of this EU-level component:

o In sub-option 2.1 the EU-level component is light with a stronger role of the Member

States, for which the current EUCCS Preparation Project will be reinforced to become

the EUCCS Cooperation Project and only the necessary elements for facilitating

interconnectivity, monitoring and support tasks being handled at EU-level.

o In sub-option 2.2 there is a central EU competent authority that covers tasks related

to facilitation on technical interconnectivity, common EU services as well as

monitoring of the implementation of EUCCS across Member States.

The EUCCS framework would be in principle the same under both sub-options, thus also the

Policy Measures to be taken under the sub-options are identical:

I. Governance and strategy

PM2.1 – Establishment of governance structures at the Member State and EU levels, as well

as of an European Critical Communications Group Committee

This PM establishes a governance architecture through the EU legislative act to ensure

coordinated implementation, consistent decision-making, and clear accountability. More

specifically:

• Designation of a National Competent Authority73 as the Member States’ EUCCS single

point of contact. The National Competent Authority would oversee the development,

implementation, and operation of national mission critical broadband system and services,

ensure security and resilience, and enable interoperability and cross-border cooperation,

including EUCCS testing, field exercises and reporting processes. Each National

Competent Authority would need to appoint a Single Point of Contact for coordination with

other National Competent Authorities;

• Establishment of the European Critical Communication Group as formal expert group to

advise the Commission (replacing the existing informal Mission Critical Communication

Group). The European Critical Communication Group would be tasked to ensure EU- and

Schengen-wide coordination and provide structured input through comitology to steer

implementation priorities and support the EU in adopting implementing and delegated acts.

73 Informal Commission Expert Group on Mission Critical Communication (MCCG) Working Group on Action

5. National Competent Authority Tasks for EUCCS Services. Working document,Version 009 (4 December 2025).

26

Its delegates come from the National Competent Authorities of Member States74. The

governance is the same as other formal Commission expert groups. Furthermore, several

other policy measures are going to be guided and adopted by the group.

PM2.2 – EU-level monitoring of compliance and maturity assessment via a System

Accreditation Board

This PM establishes a System Accreditation Board comprising of delegates from Member

States to assess the progressive maturity of national critical communication systems in line

with the EUCCS, including notably if a Member State is ready to join EUCCS. It would build

on the EUCCS maturity approach (Traditional → Initial 2030 → Advanced 2033 → Optimal

2036)75. Its activities would cover the verification of national critical communication systems

interconnection, roaming readiness, rollout of baseline mission critical services and key

enabling capabilities, as well as alignment with the EUCCS security and resilience

expectations, notably recognised cybersecurity management practices and the progressive

uptake of European Telecommunications Standards Institute/Global Certification Forum

standardisation and certification76. Maturity assessment would be conducted through a

structured peer-review process using objective and proportionate criteria and evidence,

ensuring comparability. For legal reasons, the function of the System Accreditation Board

cannot be performed by the European Critical Communication Group (or any other comitology

committee).

PM2.3 - Member States’ strategies on critical communications

This PM obliges Member States to adopt and maintain an EUCCS strategy/roadmap aligned

with the EU legislative act and the EUCCS Operational Plan. This would mirror the approach

taken in frameworks such as NIS2 and ensure political ownership, planning certainty, and

accountability. The strategy/action plan should set out: (i) national governance (including

designation of the National Competent Authority and national points of contact for cross-

border cooperation and interoperability testing), (ii) implementation timelines and milestones

for procurement, rollout and migration to mission critical broadband and mission critical

services, (iii) investment priorities and financing, (iv) an approach for the transition from

legacy narrowband systems (including their role and interoperability during migration, if it’s

the case), and (v) national risks with mitigation measures (security, resilience, continuity, and

preparedness). Member States would be responsible for keeping the strategy updated over time.

74 This concerns notably: PM 2.3 (Member States’ strategies) where the group will be the key forum to discuss

those strategies; PM 2.6 (Minimum requirements for national critical communication systems), for which the

group will support the Commission in the drafting of an Implementing Act (see also further below); PM 2.7

(Reporting obligations for Member States), where the group will be the key forum to discuss reports received by

the Commission; PM 2.9 (Adherence to risk-based guidance concerning autonomy and sovereignty) to serve as

forum for exchanges of best-practices and exchanges with relevant other stakeholders, including industry; as well

as PM 2.11 (Standard Operating Procedures) to be adopted by the group. 75See EUCCS Operational Plan p. 20-21. The governance and operations of PO 2.1 are based on findings of the

EUCCS Operational Plan and the results of the EUCCS Preparation Project in which Member States, emergency

services and industry partners work since many years on the technical and organisational backbone of EUCCS,

including the maturity model. 76 Mission Critical Communication (MCCG) Working Group on Action 5. EUCCS System Initial Maturity Level

2030 Definitions. Working document,Version 005 (21 January 2026).

27

II. EU-level components and system support function

PM2.4 - Creation of the European Network Monitoring Centre and European Security

Monitoring Centre

This PM mandates the creation of an EU-level technical and component that provides the initial

interconnection functionality for the Member States’ systems and ensures high-level

monitoring of the Member State networks. An IP interconnection exchange to facilitate

interconnection of critical communication systems and monitoring of transmission capabilities

shall be operated by a European Network Monitoring Centre. It does not, however, include

operation or central data management; thus development, maintenance and operations of

critical communication remain under full Member State control.

A European Security Monitoring Centre will be created to receive and review reports and

issue recommendations or corrective actions on security incidents that affect Member States’

critical communication systems. It does not handle security incidents itself but acts as

monitoring capacity.

Following good practice from the telecommunication sector and related policy domains, the

Network Monitoring Centre and Security Monitoring Centre are going to be separate entities.

They will be set up by the European Commission, likely using framework contracts to

designate a specialised commercial service provider.

PM2.5 – Establishment of the interconnection of EU and national components of EUCCS

This PM establishes that Member States must connect their national critical communication

systems within a defined transition period. Interconnection would be based on common

standards and agreed technical profiles to ensure end-to-end interoperability verified prior to

connection to the EUCCS against conformance testbeds hosted by the European Network

Monitoring Centre. The testing would verify technical, operational, and administrative

conformance of the connected national critical communication systems against the established

standards. Each Member States would retain jurisdiction and operational control over its

infrastructure and servers. At the same time, interconnection would be mandatory to guarantee

operational mobility and seamless cross-border communications.

PM2.6 – Minimum requirements for national critical communication systems

This PM sets minimum technical and operational requirements for national critical

communication systems to ensure interoperable critical communication systems both within

and across Member States. That will be achieved via testbeds: Member States would need to

ensure that their national systems meet the requirements for connecting to EUCCS against

those testbeds.

Detailed technical parameters would be specified and updated through implementing/delegated

acts and through the EU standardisation and certification process (European

Telecommunications Standards Institute/European Committee for Standardisation/European

Committee for Electrotechnical Standardization) that would translate the EUCCS Operational

Plan into common specifications and testable profiles. EUCCS and the Member States’

systems are based on the mission-critical standards developed in 3GPP, with a supplementary

EUCCS-centred standard being developed in Europe by ETSI.

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The minimum requirements to be adopted via and Implementing Act concern also the resilience

and security of the Member States’ systems77. Detailed parameters that are likely to inspire the

drafting of that Implementing Act are included in the EUCCS Operational Plan78. Other

technical parameters necessary to successfully interconnect Member States’ systems and

ensure the compatibility of different devices and services are to be achieved via the adherence

to standards (3GPP and ETSI).

III. Requirements of critical communication systems

PM2.7 – Reporting obligations for Member States

This PM sets obligations for Member States and operators of critical communication systems

to periodically report to the EU to support EU level oversight and the EUCCS maturity

assessment. Reporting would cover the progress in meeting the minimum requirements set by

the EU legislative act, the implementation of national strategies/action plans, operational

performance and reliability metrics, compliance with security and resilience requirements,

including significant incidents/vulnerabilities and mitigation measures and adherence to the

EUCCS Standard Operating Procedures Handbook. Reporting will be done only every two

years, and the Commission will provide a common format (template or electronic platform).

PM2.8 – Obligations for Mobile Network Operators to support critical communication

This PM introduces a requirement for Mobile Network Operators in the EU legislative act to

guarantee access and service to critical communication users on national networks, coherent

with the obligation already proposed in the Digital Networks Act. These obligations would

ensure that critical communications receive priority over commercial traffic in duly justified

cases, especially during crises. As critical communication is delivered via Mobile Network

Operators or other commercial networks; these obligations should cascade to the contractual

and regulatory arrangements between Member States and the Mobile Network Operators.

PM2.9 – Adherence to risk-based guidance concerning autonomy and sovereignty

This PM embeds autonomy and sovereignty as guiding principles of the EUCCS framework.

It does not set rigid obligations; instead, it establishes common expectations for governance

and operation of national critical communication systems, reflected primarily in the recitals of

the EU legislative act. It promotes maintaining Member States jurisdictional control over core

network functions and sensitive operational data by limiting external dependencies through

risk-based vendor and supply-chain choices for critical components, with mitigation where

sovereignty or security risks arise. It is ensuring consistency with existing and forthcoming EU

initiatives (e.g., NIS2, Cloud & AI Development Act, the 5G Cybersecurity Toolbox).

PM2.10 – Establishment of the EU support functions of the EUCCS

77 Besides the resilience requirements to be specified in an implementing act, the envisaged legal act under PO

2.1 will also include an article on resilience of Member States’ systems under which they will need to ensure

resilience and protection measures for their critical communication systems. 78 A summary of chapter 7.2.2 of the EUCCS Operational Plan is provided in Annex 7.

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At EU-level, there will be further support to Member States’ critical communication systems.

To address PD2 - Insufficient network coverage and ‘PD6 - Dependence on a single national

mission-critical network with no assured alternate network to use in case of disruption‘the EU

satellite constellations, such as IRIS², will be leveraged to support EUCCS. While EUCCS (and

critical communication is general) relies primarily on terrestrial networks, satellites have a

crucial role for back-up and additional coverage. The planned use of IRIS² for EUCCS was

announced 2023 in the EU Space Strategy for Security and Defence and has been detailed out

in a dedicated working team of the Mission Critical Communication Group. Satellite

connectivity is a key component and indeed EUCCS is the main driver within IRIS² for the

development of direct-to-device functionalities. There is full complementarity with the EU

satellite programme and the future use of direct-to-device communication in included into

EUCCS, since critical communication on broadband will be a mix of land-based and space-

based connectivity. Technical preparation talks have been conducted, and a concept of

operations will be proposed. A future trial of EUCCS in 2027 would test the use of EU satellite

connectivity to provide additional back-up (if land-based communication systems are

disrupted) and coverage (in areas where there is no mobile network). In the future, Member

States connected to EUCCS will thus have the possibility to use tokens for their critical

communication purposes and deploy satellite support.

IV. Support measures for operations

PM2.11 – Standard Operating Procedures Handbook

This PM mandates the European Critical Communications Group to develop binding EUCCS

Standard Operating Procedures. The procedures would ensure predictable cross-border

cooperation by harmonising how authorities request and aid, coordinate command and control,

and mobilise and use EUCCS services in routine and crisis scenarios. The core elements would

cover the minimum operational baseline needed for operational mobility, including a common

taxonomy, common addressing, cross-border contact and escalation procedures,

dispatch/control-room cooperation and information sharing, and common principles for

different types of missions. The European Critical Communications Group would maintain the

Handbook over time, updating the binding elements where and expanding the best practices

based on joint exercises, lessons learned, and operational experience.

PM2.12 – Training, education and exercise programmes

This PM establishes Member States coordinated training, education programmes, and regular

exercises79. The goals are to ensure emergency services can effectively operate EUCCS

services and applications, improve trust, familiarity, and uptake, support the integration of new

technologies, and strengthen cross-border coordinated operations. In parallel, funding has been

reserved under Horizon Europe for the further technical development of EUCCS. For the

EUCCS to be future proof, a continuous innovation cycle shall be run in parallel via the future

EU framework for research and via the EUCCS Cooperation Project included in the preferred

PO 2.1.

79 The training is to be offered by the EUCCS Cooperation Project and addresses all emergency services personnel,

as in principle all of them could be deployed in cross-border settings.

30

Differences between Policy Option 2.1 and 2.2

As described above, the measures taken under both sub-options are identical, given they are

both based on a system of systems approach. The key difference between the sub-options lays

in the handling of certain tasks and monitoring. Under the sub-option 2.1 the central monitoring

and facilitation of interconnection (PM 2.4, 2.5) will be set up by the Commission and

outsourced under existing framework contracts to specialised providers experienced in

providing such services to public authorities. The EUCCS Cooperation Project would be

increased financially to provide services to Member States to support PM 2.2, 2.11 and to

implement PM 2.12.

Sub-option 2.2 would foresee an EU Agency handling tasks related to central monitoring and

interconnection, as well as providing common services and applications, training and further

technical development. Concretely, the Agency would have performed largely PM 2.4, 2.5 and

2.12. Furthermore, it would advise on PM 2.2, 2.9 and 2.11. A graph detailing the functioning

of Policy Option 2.1 is attached in Annex 780.

5.3.Options discarded at an early stage

Policy Option 3 would have foreseen a centrally managed EU critical communication system

providing critical communication across the EU and the Schengen area, including central data

management infrastructure. This centralised system would have dedicated infrastructure or

establish an EU level mission critical core within the network infrastructure of commercial

mobile network operators of all Member States. It would be developed and maintained by an

EU institution or agency responsible for the operation, maintenance, and security of the

centralised network and its shared services, including a central talk group patching capability.

Given the lack of the existence of an EU body that would have the legal and operational

mandate for such task, it would have required the creation of a new, dedicated EU body or

agency.

It is likely that this option would have addressed P1, P2 and P3. This option was however

discarded as being disproportionate, too costly and operationally unrealistic. This solution does

not correspond to the operational and technical reality of critical communication which runs

over mobile communication networks in a highly decentralised structure. From a system

architecture perspective, centralising the connections of millions of emergency services and

hundreds of thousands of base stations across 31 participating Member States is not realistic,

as confirmed early on by the Mission Critical Communication Group and the EUCCS

Preparation Project. A central system would as well as present a very strong interference in

Member States’s sovereignty. Under this option, the total costs would amount to € 13, 897

billion to be covered by EU budget, as the Union would have to cover both the EU component

and Member States’ costs for setting up their national broadband critical communication

system (see further below costs for other PO).

Policy Option 4 would have introduced a legislative proposal to create a system of systems of

the existing narrowband (TETRA and Tetrapol) systems. Such option would not have required

Member States to transition into mission critical broadband, thus presenting a more harmonised

starting point, given narrowband systems exist in all Member States today. In principle,

80 See Annex 7, figure 16.

31

interconnection of those systems would increase operational mobility for voice

communication, thus serve partly P1. However, the option was discarded for two main reasons:

a) it would not have addressed the problems of limited functionalities (P2) and insufficient

resilience (P3), given the limitations of the current technology that were described in this

impact assessment; and b) the complexity of achieving interoperability ex-ante is too high

compared to paving the way for interoperability of mission critical broadband systems. As

described above, existing systems cannot simply be interconnected. Investing in 2026 in

interconnection of narrowband systems81 would furthermore not be aligned with the overall

Commission ambition to promote broadband across the telecommunication sector.

81 The cost estimates for setting up (CapEx) such a single interconnection amounts to € 1,2 million. The operational

costs for the ISI network between Finland, Norway and Finland amounts to € 20 million per year. In several

Member States, the TETRA and Tetrapol networks are coming to their end-of-life and need either to be upgraded

or replaced.

32

6. WHAT ARE THE IMPACTS OF THE POLICY OPTIONS?

6.1.Social Impacts

The main social impact is enhancing emergency services’ ability to save lives and to protect

people’s health, safety as well as preventing damage to private or public property. This is

enabled by their increased ability to communicate seamlessly, therefore enhancing their

cooperation and coordination.

PO1 generates limited social impact, as its policy measures remain confined to participating

Member States. Therefore, achieving interoperable critical communication at Member State

and European level would at least take very long. That means that significantly less people

would benefit from faster and more efficient response by emergency services.

Social impacts of PO2.1 and PO2.2 are expected to be much higher. Both sub-options are

expected to contribute significantly to the social impacts described, as the consistent

deployment of interoperable critical communication will allow all people in all Member States

to benefit from the fast and efficient response of emergency services.

Findings from the surveys support this assumption, with most industry respondents considering

that the EUCCS would enable more efficient operations82. 12 out of 14 respondents in targeted

interviews emphasised the added value of the EUCCS would lie in enabling seamless cross-

border and cross-agency communication, improving coordination of operational responses, and

ensuring timelier detection and management of crises. Responses to the Commission Open

Public Consultation also confirm a clear preference for a system of systems as here foreseen in

sub-options 2.1 and 2.2.

6.2.Economic Impact

Complete and fully comparable country-specific cost data are not available for all Member

States. National critical communication systems differ in terms of technological maturity,

governance structures and implementation pathways, which affects the comparability of some

cost assumptions. While consultation and expert evidence made it possible to identify several

expected benefits, not all of these could be quantified within the scope of the impact

assessment83. The methodology applied for the cost estimates is the same used for the study

provided by the external contractor84.

82 Based on the industry survey answer to the question “To what extent would the EUCCS provide more efficient

operations to respond to cross-border natural or man-made disasters and security incidents?”. 83 These limitations were addressed through triangulation across evidence sources, the use of proxy values where

justified, and the application of ranges or sensitivity-oriented assumptions where precise estimates could not be

established. The use of a shortlisted country sample, cluster-based extrapolation, and validated interview follow-

up was intended to improve the robustness of the cost model while remaining proportionate to the evidence

available. 84 The cost assessment measured incremental costs against the baseline scenario, that is, the additional costs arising

under each policy option relative to continuation of the status quo. The analysis distinguished between adjustment

costs and administrative costs, with costs separated into one-off (CapEx) and recurrent components (OpEx). A 7-

year time horizon was chosen to mirror the phased roll-out of the EUCCS delineated in the Operational Plan,

which foresees implementation milestones in 2030, 2033 and 2036. Recurrent costs were then expressed in

33

For all policy options, it is important to differentiate between a) the modernisation of Member

States’ critical communication systems; and b) the costs related to establishing EUCCS. The

costs for the transition of Member States’ systems to broadband is not stemming from the

EUCCS initiative itself or the proposed legislation. Member States have in most cases already

started this process to close the technological gap that are presented by narrowband systems ,

and leverage innovation in telecommunications sector which are already widely available for

commercial users. The transition to broadband is happening in all spheres of

telecommunication at different pace to accommodate for the need of large data transfers. .

Without EUCCS, this transition to broadband would only take longer, without following

common timelines and standards. Furthermore, Member States deciding to maintain their

narrowband communication systems would face high maintenance costs85. Further details on

the cost data collection and estimation approach are provided in Annex 7 on the “Methodology

for the cost assessment, and a detailed breakdown of costs per policy option can be found in

Annexes 7.2 to 7.5.

The cost estimates have been established through extensive consultations with Member States

and targeted questionnaires with European industry. A detailed breakdown of costs can be

found in Annexes 7.2 to 7.5.

6.2.1. Policy option 0: no EU-level intervention

Under this option, Member States independently transition from narrowband to broadband

solutions, following divergent strategies, priorities, and available resources. Thirteen86

Member States, which are currently preparing for developing and setting up their broadband

communication systems, provided detailed cost estimate. The costs of the status quo (PO0)

comprise only the Member States’ public authorities' related costs, given that under this policy

option, there is no EU-level intervention.

On this basis, cost estimates for the other Member States were calculated, by dividing them

into three groups of large, medium-sized and small Member States:

1) Cluster 1 consists of eight large Member States: France, Romania, Spain, Sweden,

Germany, Italy, Norway and Poland.

2) Cluster 2 consists of fourteen medium-sized Member States: Belgium, Czech

Republic, Denmark, Finland, the Netherlands, Austria, Bulgaria, Greece, Hungary,

present-value terms using a 3% social discount factor in real terms. Nothing indicates that the initiative would

increase the costs of the Member States in terms of the Cost data for EU-level public authorities were estimated

based on working meetings conducted with the European Commission and technical experts. The absence of

incremental costs for businesses and other economic operators has been confirmed through targeted interviews as

well as working meetings with the European Commission and relevant business associations and industry

representatives. 85

Finland signed a 10-year contract for € 48 million with its primary mobile network operator in 2020. 2028-2030

is the deadline for migration to broadband, with TETRA phasing out in 2032. The annual costs for TETRA till

2032 amounts to € 25,8 million. For keeping TETRA beyond 2032, investments of up to € 50 million per year

would be needed. 86 Belgium, Czech Republic, Denmark, Estonia, Finland, France, Latvia, Luxembourg, the Netherlands, Romania,

Slovenia, Spain, and Sweden.

34

Ireland, Lithuania, Portugal, Slovak Republic, Switzerland (including Liechtenstein,

which will share one system with Switzerland).

3) Cluster 3 consists of eight smaller Member States: Estonia, Latvia, Luxembourg,

Slovenia, Croatia, Cyprus, Iceland and Malta.

Member States marked in bold provided detailed cost estimates for PO0 as well as for sub-

options PO2.1 and PO2.2 which were the basis for the calculations presented in Annexes 7.2,

7.4 and 7.5.

The estimated costs for establishing the national broadband critical communication systems

(capital expenditure/CapEx) range from € 70 million for Estonia and € 231, 9 million for

Belgium to € 410 million for France. The estimated operational expenditure/OpEx costs per

year is € 14 million for Estonia, € 75,3 million for Belgium and € 101 million for France.

As shown in Annex 7.2, the average capital expenditure costs per year amount to € 292 million

for a large, € 122 million for a medium-sized and € 55, 9 million for a large Member State. The

average OpEx costs per year amount to € 67, 4 million for a large, € 48, 1 million for a medium-

sized and € 12, 16 million for a small Member State. Calculated over a seven-years period, the

total investment for setting up all the Member States’ broadband critical communication

systems amounts to € 12, 667 billion87.

6.2.2. Policy option 1: Voluntary pursuit of technical interconnectivity

Eleven Member States (Austria, Sweden, France, Finland, Germany, France, Finland,

Germany, Poland, Italy, Ireland, Norway, Iceland, Lithuania) replied that they have (as it is

already the case for Finland, Sweden and Norway participating in the FINOSE-ISI cooperation)

respectively are planning or willing to create interconnections with two or more neighbouring

countries. Six Member States gave a negative reply and eight replied that they do not know.

Only those eleven Member States that expressed an interest to establish bilateral connections

were considered for estimating the costs for PO1.

Annex 7.3 gives an overview of the estimated costs for PO1: For Member States, the average

costs for setting up one bilateral connection (CapEx) are estimated to amount to € 1, 4 million.

The estimated costs for maintaining this connected over 7 years amount to € 1, 18 million. At

EU level, the cost estimates for the continuation of the mandate and management of the

Commission expert group on mission critical communication over seven years and for the

elaboration of guidelines amount to € 3, 38 million.

The total estimated costs for PO1 amounts to € 162, 44 million, consisting of the costs for

voluntary interconnectivity of the above mentioned eleven Member States, considering the

number of interconnections they envisage (ranging from one to eight), and of EU costs.

6.2.3. Policy option 2: legislative proposal establishing a system of systems

PO2 foresees a ‘system of systems’ enabling the interconnection of Member States national

critical communication systems, with sub-option 2.1 foreseeing a lighter EU-level component

87 This considers that Liechtenstein will be part of the Swiss national system.

35

and sub-option 2.2 envisaging a central EU competent authority facilitating this

interconnection.

The cost estimates for PO2.1, consisting of costs for Member States and costs for the EU, are

presented in Annex 7.4: The Member States’ costs amount to € 2, 415 billion, consisting of

adjustment costs for network, infrastructure, user equipment, applications and software

licences for connecting to the EUCCS ecosystem, as well as of administrative costs,

consisting of reporting tools for the national competent authority, human resources needed for

reporting and statistical work, training, etc. The detailed cost estimates provided by the thirteen

Member States listed above provided the basis for calculating the costs for all Member States,

following the cluster-approach.

The EU costs amount to € 1, 156 billion, covering costs for the dedicated Internetwork Packet

Exchange (IPX) network, standardisation and certification, satellite connectivity, testbeds, the

European Network Monitoring Centre, the European Security Monitoring Centre, the European

Critical Communications Group Committee, the System Accreditation Board, the tasks of the

EUCCS Cooperation mechanism, the elaboration of standard operating procedures and

guidelines, additional human resources and for training of staff. The total costs for sub-option

2.1 are estimated to amount to € 3, 571 billion.

The cost estimates for PO2.2 can be found in Annex 7.5:Covering the same cost items, the

Member States’ costs for PO2.2 are the same for PO2.1, amounting to € 2, 415 billion. The

EU cost estimates for PO2.2 are slightly lower than for PO2.1, amounting to € 1, 153 billion.

This is due to a higher degree of centralisation, with the EU competent authority taking over

the tasks of the European Security Monitoring Centre, the European Network Monitoring

Centre, the System Accreditation Board and EUCCS Cooperation foreseen in PO2.1. The total

estimated costs for PO2.2 to amount to € 3, 568 billion.

PO2 generates significant economic impacts, requiring substantial public investment to

establish an interoperable EU and Schengen-wide system of systems. The legally binding

framework enables medium- to long-term benefits, including opportunities for economies of

scale through standardisation and joint procurement, and a more integrated and predictable

market environment.

6.2.4. Obligations and compensation for mobile network operators

In EUCCS, mobile network operators should treat separately the critical communication traffic

and users from commercial network services, ensuring quality of service, including priority

mechanisms, and seamless roaming (with voice, video and data) across different mobile

networks. In practice, this requires neither additional network capacity nor new functionalities,

as they are already included as a basic feature in the mobile network operators’ radio access

networks. To meet 3GPP requirements for mission-critical services, each mobile network

operator needs to configure and enable these capabilities.

Furthermore, it is worth noting that priority mechanisms that priority mechanisms do not have

significant impact for commercial users under normal network conditions, as the impact is

limited only to the situation when the network is overloaded. This situation only occurs seldom,

36

leading to a temporary and usually short reduction in quality of service88. Operators already

manage similar prioritisation for 112 calls as a standard procedure. In the Commission Open

Public Consultation, one European mobile network operator which already provides mission-

critical communication services via a dedicated core network pointed out that traffic

prioritisation should be carefully measured and controlled to minimise impact on commercial

users.

Mobile network operators may need to prioritise emergency services network traffic. This

already happens today and is included into the price offer to emergency services. While the

percentage of emergency services to the total number of mobile network users is less than 1%,

they represent a large single customer. In a competitive market environment, they can secure a

price very close to the avoidable cost level plus a reasonable margin.

This approach is illustrated by two Member State examples: a Member State established a

commercial framework with two mobile network operators providing quality of service,

priority and pre-emption capabilities, while national roaming agreements are in place with two

additional operators, offering extended coverage. The costs related to mobile network operators

are covered in the contracts and amount to € 150 million over a four-year period. Traffic

prioritisation is not identified as a cost driver, but part of the service package. A second Member

State signed a similar 10-year contract for € 48 million with its primary mobile network

operator in May 202089.

Therefore, there is no need for additional network capacity and the relevant capabilities already

exist in commercial networks and only need to be activated, configured or contractually

framed. However, actual costs may vary depending on the national implementation model and

the service, resilience, security and interoperability requirements imposed. The synthesis of the

information collected indicates that EUCCS is not expected to new infrastructure costs for

mobile network operators, as the required functionalities are, in most cases, already embedded

in commercial 4G/5G standards and infrastructures. The main economic impact relates instead

to contractual service levels, resilience requirements, operational integration, and governance

arrangements defined at national level.The EUCCS does not add costs for MNOs in terms of

traffic because emergency services users typically represent less than 1% of total subscribers;

prioritisation mechanisms are activated dynamically only during congestion situations;these

situations remain infrequent and temporary;and operators already manage comparable priority

mechanisms today, including emergency call handling and network management policies.

Further details are provided in Annex 7.8.

In case Member States consider negotiating compensation with mobile network operators, the

compensation model should be based on avoidable costs plus a reasonable margin. This

approach would support economic efficiency and ensure market neutrality by preventing

88 Based on targeted interviews with Member States in the MCCG that have already such arrangements with

mobile network operators, as well as feedback from the EUCCS Preparation Project 89 Information provided in the draft impact assessment on the obligations for MNOs is provided via dedicated

interviews with technical experts from four Member States. Those Member States have contractual arrangements

with Mobile Network Operators to facilitate mission-critical communication.

37

overcompensation of a single mobile network operator. It would also avoid emergency services

from being pushed to cheaper, less resilient commercial offers90.

For Mobile Network Operators, the large-scale shift of critical communication to commercial

networks offers new business opportunities. The need to grant certain priorities is well

understood in the sector and consequently was not fundamentally objected in targeted

consultations91 and the open public consultation.

6.2.5. European industry

EUCCS depends on supply chains for network infrastructure, devices, applications and

services. In this security relevant area, the EU and Member States should safeguard their

strategic autonomy. European companies have played a key role in developing technological

solutions for EUCCS in the pre-commercial procurement project BroadWay and continue this

important role in the EUCCS Preparation Project. There are positive economic impacts

expected for European providers of critical communication infrastructure and services due to

the accelerated transition of Member States to broadband systems and reliable timelines till

203692.

6.2.6. Impact on SMEs and competitiveness

For the industry overall, there are positive impacts expected for providers of critical

communication infrastructure and services due to the accelerated transition of Member States

to broadband systems and reliable timelines till 2036. We estimate 9,000 SMEs are offered

new market opportunities. Those providing existing Applications will be encouraged to

become compatible with EUCCS, which is not considered to be a complex process. A dedicated

SME test has been performed in Annex 6.

6.3.Impact on fundamental rights

All options would comply fully with fundamental rights considerations.

EUCCS aligns with human rights and fundamental freedoms, adhering to the principles and

rights enshrined in the Charter of Fundamental Rights of the European Union (The Charter),

the European Convention on Human Rights (ECHR). Specifically, the EUCCS enhances

interoperability among emergency services across agencies and borders, ensuring an effective

and coordinated response to security threats, crises, and the protection of citizens throughout

90 Furthermore, this approach ensures strict compliance with the CJEU Altmark ruling (Case C-280/00), which

dictates that compensation must not exceed what is necessary to cover costs incurred in discharging public service

obligations. It also prevents wide pricing disparities across the Union, where local market conditions might

otherwise distort the cost of essential safety services. 91 The information provided in this draft impact assessment on the obligations for Mobile Network Operatorsis

provided via dedicated interviews with technical experts from Finland, Belgium, Norway and France. Those

Member States have contractual arrangements with Mobile Network Operators to facilitate mission-critical

communication. A dedicated consultation was furthermore organised for Mobile Network Operators in March

2026 in DG HOME, attended the GSM Association (GSMA). Neither in reaction to this consultation, nor as part

of the open public consultation have MNOs raised significant concerns related to possible obligations to facilitate

critical communication. 92 See Annex 5 and 6, based on input from the associations representing the critical communication industry (The

Critical Communication Association- TCCA and Public Safety Communication Europe-PSCE, as well as the

market study “SNS Telecom Public Safety Market report 2026”.

38

the Member States. The security of every person is protected under Article 6 of the Charter and

Article 5 ECHR. Under Article 2 ECHR, Article 2(1) and Article 3(1) the Charter, the EUCCS

could support the protection of life as well as the physical and mental integrity of people by

enabling rapid emergency response and coordination during crises such as terrorist attacks or

natural disasters. EUCCS does not equip law enforcement and emergency services with any

capabilities that may be used for direct exercise of force or infringements of other rights.

6.3.1 Compliance with Regulation 2016/679 (GDPR Regulation)

Under Article 8 ECHR (right to respect for private and family life), Article 7 (respect for private

and family life) and Article 8 the Charter (protection of personal data), the EUCCS fully

comply with the standards laid down in Regulation (EU) 2016/679 on the protection of natural

persons with regard to the processing of personal data and on the free movement of such data

(GDPR). The EUCCS facilitates the exchange of operational data exclusively among

emergency services and directly associated entities, e.g. emergency medical services, hospitals.

Such exchanges may include victim-related data, such as name, age, sex, physical or

psychological condition, but remain strictly limited to public security and safety purposes.

These advancements serve solely to improve emergency response, without altering the existing

legal framework for data protection. EUCCS on the other hand does not enhance the

capabilities of law enforcement for activities with a potential fundamental rights impact, such

as surveillance of private communication.

The restrictions of data subject rights (e.g. access, erasure, or objection) in cross-border data

exchanges are in line with Article 23 GDPR, as the new dimension permits restrictions by way

of a legislative measure when necessary for public security, national defence, or law

enforcement, provided such limitations are proportionate. For critical communication,

processing of personal data would be based on the vital interest to protect life and to prevent

serious threats.

6.4. Impact on the environment

EUCCS will have positive impacts on the environment, notably as it enhances the capability to

respond to disasters with environmental impacts such as floods, fires and industrial accidents,

as well as the fight against environmental crime. PO1 generates limited environmental benefits,

as it relies on voluntary uptake. However, it would still provide benefits against environmental

challenges such as climate change, chemical hazards, and ecosystem degradation. While

improved coordination and response in crisis situations may support the mitigation of

environmental risks, impacts remain limited in scope and uneven. PO2.1 and 2.2 both generate

more positive and structurally significant environmental benefits through strengthened cross-

border response capacity and interoperability across Member States.

6.5. Impact on digitalisation

PO2 is expected to have a high impact on digitalisation of Public Administration and promote

broadband deployment. Critical communication among emergency services and other relevant

forces will contribute to digitalisation of their operations. It will also contribute to Digital

Government goals, including interoperability of Public Services. For PO1 that impact would

be more limited, as the roll-out of broadband for critical communication would be at least

slower.

39

6.6. Impact on vulnerable people/gender considerations

PO2 is expected to have a positive impact on vulnerable people. The possibility to exchange

real-time video feeds, richer situational awareness tooling and collaborative field applications

could better support emergency services in communicating with vulnerable people in distress,

e.g. the possibility to exchange in real-time videos communication to support American Sign

Language communication with people with hearing disabilities or allowing emergency services

to live-streaming a situation of distress for elderly, child or person with disability to ensure the

intervention of specialists.

7. HOW DO THE OPTIONS COMPARE?

The objective of this comparison is to determine which option performs best against a

consistent set of evaluation criteria. The comparison focuses on PO1 and PO2 and their sub-

options. Each policy option was evaluated against the following criteria:

• Effectiveness, i.e. the extent to which the option achieves the specific and general

policy objectives of the intervention;

• Efficiency, i.e. the relationship between the resources used (costs) and the results

achieved (benefits);

• Coherence, i.e. the extent to which the option is consistent with other relevant Union

policies and legal frameworks;

• Subsidiarity and proportionality, i.e. whether the policy option is appropriate and does

not go beyond what is necessary to achieve the policy objectives.

In addition, the analysis considers the economic, social, and environmental impacts. Policy

options that outperformed others were assigned a relative “+” or “++”. Those that

underperformed were assigned a relative “-“ or “--", and those that were average, were assigned

a relative “0”.

7.1 Effectiveness

The table below summarises the expected effectiveness of the proposed policy options vis-à-

vis the specific objectives of the intervention, namely:

• Specific Objective 1: promote interoperable and secure cross-border and cross-agency

critical communications for public authorities responsible for security and safety,

allowing authorised emergency services to communicate and operate seamlessly across

all EU Member States, and across competent authorities.

• Specific Objective 2: enable EU Member States to deploy broadband critical

communication systems with the necessary mission critical services and supporting

enablers to provide authorised emergency services with data-rich and real-time

capabilities.

• Specific Objective 3: Facilitate the achievement of a high and consistent level of

resilience of critical communications across the EU Member States, by implementing

common security requirements and resilience measures that safeguard the

confidentiality, integrity, and availability of critical communications by 2036.

40

7.2 Efficiency

Efficiency assesses the extent to which the objectives can be achieved at the lowest possible

cost, considering both direct and indirect impacts on stakeholders.

PO 1 - Voluntary pursuit of

technical interconnectivityPO 2.1 - system of systems (lighter

EU-level component)

PO 2.2 - system of systems

(central EU competent

authority)

SO #1 PO 1 delivers limited improvements

in interoperable and secure cross-

border and cross-agency critical

communications, as it relies on

voluntary interconnectivity and non-

binding coordination. Impacts

remain uneven across Member

States, with limited uptake reducing

its effectiveness in ensuring

seamless communication. (+)

PO 2.1 delivers significant

improvements in interoperable and

secure cross-border and cross-agency

critical communications through

binding interoperability requirements

and mandatory connectivity. That

binding element ensures that all

Member States participate and thus

more emergency services benefit from

EUCCS. However, coordination

across multiple governance bodies

may affect the uniformity and

timeliness of implementation. (++)

PO 2.2 reveal to be similar to 2.1

exception made for clearer

accountability, more streamlined

decision-making, and more

consistent oversight. Given the

centralisation of such task in an

EU competent authority. (++)

SO #2 PO 1 is only marginally effective in

enabling the deployment of

broadband critical communication

systems. The absence of binding

requirements constrains progress,

resulting in fragmented

development and limited

advancement across Member States.

That would include very likely that

some emergency services are not

receiving broadband functionalities,

or much later than others do. (+)

PO 2.1 is highly effective in enabling

the deployment of broadband critical

communication systems, including

mission-critical services and data-rich

functionalities. They will become

available to almost 5 million

responders in emergency services in

foreseeable timelines. While the

binding framework supports large-

scale deployment, coordination

complexity may lead to some

implementation variability across

Member States. (++)

Identical to PO 2.1.

SO #3 PO 1 provides limited

improvements in achieving a high

and consistent level of resilience of

critical communications, as

voluntary measures do not ensure

the uniform implementation of

security and resilience practices.

This leads to uneven levels of

resilience across Member States,

given that different resilience

measures are been taken and less

priority may be assigned to them. (+)

PO 2.1 delivers strong improvements

in achieving a high and consistent

level of resilience of critical

communications through common

standards and mandatory

requirements. This would ensure the

resilience measures are comparable in

the Member States and that their

implementation is obligatory.

However, fragmented governance may

affect consistency in oversight and

implementation. (++)

PO 2.2 reveal to be equal to 2.1,

exception made for clearer

accountability mechanisms due

to the more centralised

governance. Given the

centralisation of such task in a

EU competent authority. (++)

41

PO 1 - Voluntary pursuit of

technical interconnectivity

PO 2.1 - system of systems (lighter

EU-level component)

PO 2.2 - system of systems (central

EU competent authority)

Costs PO 1 is primarily driven by the

additional costs for Member

States, to the extent national public

authorities decide to establish

voluntary bilateral

interconnections and would

remain comparatively limited at

the EU level.

EUR 162.4 million would be

necessary to create

interconnections between Member

States, on a voluntary basis. (-)

The costs of PO 2.1 are higher than

option 1, mainly driven by the

necessary implementation of an EU

layer of the EUCCS, and the creation

of one connection per Member State

to it.

The overall cost of PO2.1

(decentralised governance) is

estimated at EUR 3.571 billion,

comprising EUR 2.415 billion for EU

Member States and EUR 1.156 billion

at EU level. (--)

The costs of PO 2.2 remain in the

same order of magnitude as the costs

of option 2.1. The only difference

being efficiency gains on human

resources at EU level due to the

centralised governance in a single

agency.

The overall cost of PO2.2

(centralised governance) is instead

estimated at EUR 3.568 billion,

comprising the same EUR 2.415

billion for EU Member States and

EUR 1.153 billion at the EU level. (-

-)

This PO introduces a high liability

cost for the EU competent, who will

be liable in the case the systems does

not work properly in an emergency.

Benefits Up to 3 million -responders and

would have partial operational

mobility, limited to the Member

States with which their country has

a voluntary bilateral connection.

(+)

Costs savings opportunities will

remain low. (0)

An estimated number of 11

countries could create between 2

and 3 bilateral connections. (+)

PO 1 will slightly improve the

resilience of critical

communication systems, which

will remain driven by Member

States with voluntary guidance

from the EU. (0)

PO 1 would enable only a limited

degree of seamless roaming. In

addition, only a limited number of

Member States are expected to

transition to broadband in the

temporal scope by 2036. (+)

5 million responders in emergency

services would have full operational

mobility across the Member States.

(++)

Costs savings opportunities such as

joint procurement could be leveraged

by Member States. (+)

All Member States would be

interconnected with each other. (++)

PO 2.1 will improve the resilience of

critical communication systems to

some extent, with mandatory guidance

from the EU. (+)

PO 2.1 would enable only a high

degree of seamless roaming. In

addition, all Member States are

expected to transition to broadband

by2036, thus providing data-rich

functionalities to emergency services.

(++)

Identical to option 2.1.

7.3 Coherence

42

Coherence examines the extent to which each policy option aligns with existing EU policies,

legislation, and broader strategic objectives. The policies and strategies that appear relevant for

a ‘coherence’ evaluation are essentially three:

• EU internal security policy, reflected in the ProtectEU strategy, the European Internal

Security Strategy, which highlighted the need for more effective tools for law

enforcement, including EUCCS enabling cross border communication between

different authorities.

• EU telecommunication policy, and in particular the Digital Networks Act which aims

to modernise, simplify and harmonise the EU framework for connectivity networks and

contains provisions on the availability of mission critical communications.

• EU cybersecurity policy, especially the NIS2 Directive which establishes general

reporting obligations for operators of essential services and digital services providers.

cybersecurity risk-management and incident-reporting obligations.

PO 1 - Voluntary pursuit of

technical interconnectivity

PO 2.1 - system of systems

(lighter EU-level component)

PO 2.2 - system of systems

(EU competent authority)

ProtectEU strategy Low level of interconnection of

Member States due to the

voluntary nature of the

obligations. (+)

Strong level of interconnection of

Member States with the

implementation of an EU-layer.

(++)

Identical to PO 2.1.

EU telecommunication

policy

PO 1, through its voluntary

guidance and the work of the

Mission Critical Communication

Group is not likely to interfere

with the provisions of the Digital

Networks Act. (0)

The Digital Networks Act

proposes to introduce obligations

for providers of public electronic

communications networks to

ensure the continuity and

uninterrupted availability of

mission critical communications.

Coherent with the Digital

Networks Act, Policy Option 2.1

would enable data roaming to

facilitate cross-border operations.

(+)

Identical to PO 2.1.

EU cybersecurity

strategy

Under PO 1, Member States will

have the possibility to follow

voluntary guidance from the

Mission Critical Communication

Group on the resilience of

national critical communication

systems, including on

cybersecurity. (+)

Under PO 2.1, mandatory

guidance will be provided by the

Mission Critical Communication

Group on the resilience of

national critical communication

systems, including on

cybersecurity aspects. (++)

Identical to PO 2.1.

7.4 Subsidiarity and proportionality

Regarding subsidiarity, all three aspects laid down in article 5(3) of the TUE have been taken

into consideration: (i) whether the initiative falls under an exclusive competence of the Union,

(ii) whether the objectives of an action cannot be sufficiently achieved by the Member States,

but (iii) can be better achieved at Union level, by reason of the scale and effects of the proposed

action.

43

Regarding proportionality, two main aspects have been considered: (i) whether the proposed

options are proportionate to the objectives, i.e. they do not go beyond / fall short of what is

necessary to satisfactorily address the problem / achieve the objectives; and (ii) whether the

costs implied are proportionate to the expected outcome.

PO 1 - Voluntary pursuit of

technical interconnectivity

PO 2.1 - system of systems (lighter

EU-level component)

PO 2.2 - system of systems

(EU competent authority)

Subsidiarity

The cooperation among emergency

services is not an exclusive

competence of the Union.

PO 1 partially responds to the

fragmentation of national critical

communication systems which limit

operational mobility. This issue is

not resolved by Member States.

Only a very limited number of

Member States have ongoing

interoperability initiatives or are

planning to interconnect with one or

two neighbour Member States.

PO 1 would partially achieve the

first objective of the EUCCS it

would coordinate the voluntary

development of national critical

communication systems in an

interoperable manner. (+)

Cooperation among emergency

services is not an exclusive

competence of the Union.

PO 2.1 responds more effectively to

the fragmentation of national critical

communication systems, thus fostering

to a greater extent the operational

mobility of emergency services. This

issue and the insufficient

functionalities and resilience of MCX

services are not resolved by Member

States.

PO 2.1 would better achieve the

objectives as it would mandate the

development of national critical

communication systems in an

interoperable manner. (++)

Similar to Policy Option

2.1. However, the fact that

significant tasks related to

critical communication

would be handled by an EU

agency would slightly

reduce Member States

sovereignty in a domain

related to national security

and law enforcement.

Proportionality PO 1 remains proportionate by

allowing Member States to retain

full ownership of their critical

communication systems.

When looking at the proportionality

of costs compared to the

achievement of the objectives, we

note that PO1 has moderate costs.

However, it only partially responds

to the SO 1 and 3 of the EUCCS,

almost not at all to SO 2. (0)

Under PO 2.1, the ‘system of systems’

enables Member States to interconnect

while keeping their national critical

communication systems.

Costs and burden on Member States is

higher. However, it remains

proportionate, as binding requirements

are justified by the scale of problems

addressed, while measures are targeted

and limited to what is y for

interoperability and a consistent level

of resilience and security. (++)

Cost and burden are similar

to PO 2.1 and proportionate.

However, the adaptation of

an existing EU agency’s

mandate or the creation of a

new one would be a

significant effort. (+)

7.5 Social, environmental and economic impact

PO 1 - Voluntary pursuit of

technical interconnectivity

PO 2.1 - system of systems (lighter

EU-level component)

PO 2.2 - system of systems

(EU competent authority)

Social Impact PO 1 generates limited social

benefits, namely on public health

and public safety through better

coordination and response times

PO 2.1 generates significant and

structural social benefits through

binding interoperability requirements,

and harmonised procedures.

Identical to PO 2.1.

44

PO 1 - Voluntary pursuit of

technical interconnectivity

PO 2.1 - system of systems (lighter

EU-level component)

PO 2.2 - system of systems

(EU competent authority)

during cross-border incidents.

However, impacts remain

restricted to participating Member

States, resulting in uneven and

limited effects across Member

States. Up to 3 million personnel

emergency services would have

very partial operational mobility (+)

Mandatory interconnection improves

the scale, reliability, and consistency

of cooperation, enhancing real-time

coordination, situational awareness,

and joint operations across Member

States for 5 million personnel in

emergency services. (++)

Environmental

impacts

PO 1 generates limited

environmental benefits, as it relies

on voluntary uptake. While

improved coordination and

response in crisis situations may

support the mitigation of

environmental risks, impacts

remain limited in scope and uneven

across Member States due to

reliance on bilateral arrangements.

(+)

PO 2.1 generates more positive and

structurally significant

environmental benefits through

strengthened cross-border response

capacity and consistent

interoperability across Member States.

The binding and harmonised

framework enables faster and more

coordinated interventions, supporting

more effective mitigation of

environmental risks and limiting their

escalation. (++)

Identical to PO 2.1.

Economic

Impact

PO 1 generates limited to moderate

economic impacts, primarily

affecting public authorities through

adjustment and administrative costs

linked to interconnections. Costs

remain relatively contained with

EUR 162 million. Nevertheless, the

non-binding nature of the

intervention limits broader effects,

preventing the emergence of

significant market improvements or

economies of scale. (-)

PO 2.1 generates significant

economic impacts, requiring

substantial public investment to

establish an interoperable EU and

Schengen-wide system of systems,

with costs estimated at EUR 3.571

billion. However, the binding

framework enables medium- to long-

term benefits, including opportunities

for economies of scale through

standardisation and joint procurement,

and a more integrated and predictable

market environment. (--)

Similar to PO 2.1.

PO 2.2 is slightly less costly

than option 2.1 with EUR

3.568 billion of investment,

as the centralisation of the

EU governance framework

allows for greater staff

allocation efficiencies. (--)

The table below summarises the comparative performance of the policy options across the

main evaluation criteria.

Policy Option 1 Policy Option 2.1 Policy Option 2.2

Effectiveness + ++ ++

Efficiency ++ + +

Coherence + ++ ++

45

Subsidiarity + ++ +

Proportionality 0 ++ +

Social Impact + ++ ++

Environmental impacts + ++ ++

Economic Impact - -- --

Overall, the comparison indicates that Policy Option 2.1 and 2.2 perform more favourably

across most criteria, particularly effectiveness and coherence. Whereas policy option 2.1

performs even stronger on subsidiarity and proportionality. Policy Option 1 on the other hand

demonstrates relative advantages only on efficiency, due its low cost.

8. PREFERRED OPTION

8.1.Policy option 2.1

Based on the comparative analysis presented above, Policy Option 2.1 emerges as the preferred

option.

This Policy Option provides the most effective response to the identified problem, offering a

comprehensive and reliable framework for achieving the policy objectives. While it may entail

higher costs compared to Policy Option 1, these are justified by the significantly greater

benefits and the more substantial impacts generated across economic, social, and

environmental dimensions. By contrast, Policy Option 1, although less burdensome, is not

expected to deliver sufficient impact to address the identified problems, limiting its overall

suitability. The U.S. system FirstNet93 for example serves emergency services across the

United States. However, all emergency services join FirstNet voluntarily at their own initiative.

They are also not automatically able to communicate with each other across agencies and State

borders. While FirstNet is a success what concerns its relatively early roll-out and geographic

coverage, the US example confirms that obligatory rules are more likely to achieve the

objectives described in this impact assessment.

Policy Option 2.1 and Policy Option 2.2 on the other hand present very similar benefits and

impacts.

Policy Option 2.1 ensures a higher degree of coherence with existing EU policies and respects

the principle of proportionality, as its measures are appropriately calibrated to the scale of the

challenges addressed. The creation of the governance measures and the light EU component

are relatively easy to achieve.

There is a variation of the cost, as Policy Option 2.2 requires slightly less human resources at

EU level due to the centralised governance structure. However, Policy Option 2.2 would have

required the creation of an EU Agency, or the significant modification of an existing Agency

mandate and resources, to act as competent authority. The Commission has thoroughly

reviewed existing Agencies and none of them would have the necessary legal mandate to cover

93 https://www.firstnet.com/

46

the different first responder groups, as well as the resources and capacity to handle the EU

component of EUCCS. Creation of a new Agency on the other hand would be disproportionate.

Considering these facts, 2.1 is therefore retained as the preferred Policy Option.

8.2.REFIT (simplification and improved efficiency)

This initiative is not a revision of existing legislation; therefore, a REFIT test has not been

performed.

8.3.Application of the ‘one in, one out’ approach

This initiative is not a revision of existing legislation; therefore, the ‘one in, one out’ approach

does not apply.

9. HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED?

In line with the Better Regulation Tool #43 on the Monitoring arrangements and indicators94,

this chapter identifies core indicators to measure the success of the EUCCS initiative. This way

94 European Commission, Better Regulation Toolbox 2023: Chapter 5 – Monitoring the application of

interventions (2023) Tool #43 ‘Monitoring the application of interventions’

https://commission.europa.eu/document/download/fe5655c0-d3d5-4f18-87c0-

ecdce5bdf1be_en?filename=BR%20Toolbox%20-%20Dec%202025%20-%20Chapter%205.pdf.

47

it sets a framework for the monitoring and the data collection throughout the lifecycle of the

initiative to oversee its progress, ensure the availability of data, and allow for the evaluation of

its results hereafter.

This exercise considers contextual considerations (i.e., technological developments,

geopolitical landscape, telecommunications market changes), as they can influence the

EUCCS’ implementation, and leverages existent data sources, including those used in the other

chapters of the report. A Table95 was created to summarise and map the proposed indicators

against the specific objectives, the policy measures, sources, the possible collection methods,

the responsible entity, and the suggested frequency of collection. A prioritisation is also

included reflecting the following logic:

• High priority: mandatory requirement

• Medium priority: non mandatory but highly recommended

• Low priority: non mandatory requirement

The indicators serve as a basis for a final elaboration and selection from the European

Commission, for use in future exercises of data collection, for example in the context of an

evaluation or revision of the legal act, or in a support/thematic study.

Based on Tool #43, the indicators also meet the Relevant, Accepted, Credible, Easy, and

Robust (RACER) criteria. They are Relevant as they align directly with the specific objectives

of the EUCCS initiative and its overarching goal. They will be Accepted following consultation

with relevant EU bodies and Member States competent authorities. They are Credible as they

are formulated in a clear and unambiguous way. They are Easy to monitor as they rely on

information that can be sourced through reporting from the EU Member States National

Competent Authorities and relevant EU bodies (e.g. eu-LISA, ENISA), and finally, they are

Robust, as they require statistics on operational data that are machine-generated, meaning less

prone to error.

To measure the success and effectiveness of the EUCCS, the Key Performance Indicators in

Annex 7.9 have been identified, based on the EUCCS Operational Plan endorsed by the

European Commission in May 2025. By monitoring these Key Performance Indicators, the

European Commission can ensure that EUCCS will effectively meet its general objective:

enhance Europe’s capacity to react effectively and efficiently to cross-border and cross-agency

incidents and crises, through a secure and resilient critical communication infrastructure across

the EU and Schengen area.

95 See Annex 7.8.

48

ANNEX 1: PROCEDURAL INFORMATION

1. LEAD DG, DECIDE PLANNING/CWP REFERENCES

The lead DG is the Directorate-General for Migration and Home Affairs (DG HOME) for the

preparation of this initiative and the work on the impact assessment. No other DGs were associated

to the initiative. The initiative is listed in the Commission Work Programme 2026.

2. ORGANISATION AND TIMING

The inter-service steering group for the impact assessment was set up on 3 December 2024 with

participation of the following Directorates-General: Secretariat-General (SG), Service Juridique (SJ),

Directorate-General for Budget (BUDG), Directorate-General for Communications Networks,

Content and Technology (CNECT), Directorate-General for Defence Industry and Space (DEFIS),

Directorate-General for Digital Services (DIGIT), Directorate-General for European Civil Protection

and Humanitarian Aid Operations (ECHO), Directorate-General for Directorate-General for Internal

Market, Industry, Entrepreneurship and SMEs (GROW), Directorate-General for Justice and

Consumers (JUST), Directorate-General for Health and Food Safety (SANTE), Directorate-General

for Research and Innovation (RTD), Directorate-General for Taxation and Customs Union

(TAXUD), the European Commission's Health Emergency Preparedness and Response Authority

(HERA), and the European Commission Joint Research Centre (JRC).

The call for evidence was launched on 30 April 2025 and concluded on 28 May 2025.

The public consultation was launched on 16 January 2026 and concluded on 10 April 2026.

Targeted stakeholder consultations were conducted from 25 July 2025 to 1 June 2026.

ISG meetings:

Four ISG meetings and two written consultations were organised:

- ISG meeting on 3 December 2024 focused on the political context of the initiative, the call for

evidence and the terms of reference for the impact assessment study. Written consultation was

conducted from 3 December 2024 to 12 December 2024 on call for evidence and terms of reference

for the impact assessment study.

- ISG meeting on 1 July 2025 focused on the first results of the call for evidence, and a first

assessment of the policy options.

- ISG meeting on 3 December 2025 focused on updates regarding the legal base, the targeted

consultation activities and the public consultation.

- ISG meeting on 15 April 2026 focused on a discussion of the Impact Assessment draft text. Written

consultation was initiated on 13 April 2026 on the final draft of the impact assessment. Written

feedback on the draft impact assessment was received by 17 April 2026.

49

3. CONSULTATION OF THE RSB

An Upstream Meeting with the RSB has been held on 13 February 2026 and led to further refinement

of the problem definition, notably by narrowing the scope and simplifying. The first version of the

draft Impact Assessment report was submitted to the Regulatory Scrutiny Board (RSB) on 22 April

2026.

The RSB issued a positive opinion with comments, which were all implanted and had focussed on

the following elements:

The IA report outlined the dynamic baseline by analysing the current situation of critical

communication systems (CCS) in Member States, including planning and the current/planned

interoperability. It specified which systems are currently in place e.g. narrowband, broadband, hybrid

model in transition, and what plans and investment cycles there are to develop and/or upgrade

existing systems in Member States.

The IA report was enriched with details regarding technological trends (e.g. direct-to-device satellite

communication, encryption, etc.), the supply chain needs and related sovereignty aspects. The

problem definition was enhanced in terms of the proportion of communications that presently suffer

from interoperability shortcomings, cross border and within Member States.

The description of options, including the baseline, building on the Member States’ level of

preparedness and related plans was further explained. Key requirements following from the

intervention, including minimum technical requirements were added and the report provides more

details on the technical solutions and related uncertainties, trade-offs, key attributes of the new system

(security, resilience, functionalities); and how it will be ensured that the requirements and technical

solutions are future-proof, e.g. related to direct-to-device satellite communication.

The analysis was further detailed on the impacts of the proposed measures as well as potential

unintended consequences. That concerned notably the assessment of costs and benefits accruing to

all stakeholders and a clear overview on how the cost estimates from several Member States were

extrapolated. The capital expenditures (CapEx) and operational expenditures (OpEx) for Mobile

Network Operators (MNOs) were made clearer and quantified to the extent possible and it ws

clarified that those costs are subject to renumeration and commercial agreements.

The sections analysing costs and benefits were further refined to outline benefits in terms of

technological upgrades and facilitating data rich transfer are to be attributed to the EUCCS, or to

other investments and developments. The costs and benefits were detailed, i.e. if indirect benefits to

be taken into account and indirect costs to be factored in.

The report clarified further the very broad evidence basis on which EUCCS is founded, notably the

underlying research projects, consultation with Member States, industry and other key stakeholders.

4. EVIDENCE, SOURCES AND QUALITY

For this impact assessment, the Commission collected data through various sources and consultations

methods.

EUCCS is built in close cooperation with European industry, therefore directly contributing to

the overarching priorities of strategic autonomy and competitiveness. European industry is

partner in EUCCS Preparation and its precursor projects, with Airbus, Leonardo, Frequentis and

Teltronic demonstrating the technical feasibility for EUCCS in ongoing trials with Member States.

50

EUCCS has been presented at the most relevant international events relevant for critical

communication in 2024 and 2025, including Critical Communication World (Dubai, Brussels), the

Global Public Safety Operator Conference (Washington, Sydney) and the European Police Congress

(Berlin). In compliance with the Better Regulation guidelines, DG HOME published the Call for

Evidence in April 2025, and, in July 2025, contracted a nine-month-study to support the Impact

Assessment. A CommissionOpen Public Consultation was conducted from 16 January until 10 April

2026 and targeted surveys as well as dedicated meetings have taken place with representatives of

industry, such as providers of critical communication infrastructure and services and mobile network

operators.

The research for the initiative and this impact assessment started with targeted surveys and interviews

with EU Member States, which took place from July 2025 until June 2026 and mapped how Member

States authorities are currently implementing their critical communications system.

The Commission conducted targeted surveys and interviews with critical communications industry

representatives, as well as NGOs and other relevant associations, which took place from July 2025

until June 2026.

51

ANNEX 2: STAKEHOLDER CONSULTATION (SYNOPSIS REPORT)

The Public Consultation was conducted between 16 January and 10 April 2026. The consultation

aimed to gather evidence from a broad range of stakeholders on the key challenges, needs and

expectations related to the functioning of critical communication systems across EU Member States,

with particular attention to cross-border and inter-agency operational contexts.

In particular, the consultation sought to assess the extent to which existing systems enable effective

cross-border and inter-agency communication, identify key operational, technical and governance-

related challenges, and gather stakeholder feedback on possible policy approaches to enhance

interoperability, resilience, security and coordination at EU level.

In total, 25 contributions were received, reflecting a broad range of perspectives across stakeholder

groups and geographical contexts. Responses were collected through an online questionnaire (EU

Survey) and included both closed questions, enabling quantitative analysis, and open-ended

questions, providing qualitative insights. A more detailed breakdown indicates that public authorities

constitute the largest group of respondents (52%, 13 out of 25), followed by EU citizens (20%, 5 out

of 25) and companies (16%, 4 out of 25), with limited representation from business associations and

trade unions.

From a geographical perspective, responses are concentrated in 5 Member States, with Germany

accounting for the largest share (48%, 12 out of 25), followed by Spain (20%, 5 out of 25), Belgium

(8%, 2 out of 25) and France (8%, 2 out of 25), and a limited number of contributions from the

Netherlands.

All contributions were systematically reviewed and, where relevant analysed by stakeholder category

and country of origin to identify recurring views, areas of convergence, and points of divergence.

This approach allows for a nuanced understanding of stakeholder positions, including potential

differences across institutional profiles and national contexts. While the consultation achieved broad

outreach, the distribution of responses across stakeholder groups should be taken into account when

interpreting the results, as certain categories, particularly public authorities, are more strongly

represented.

Key findings

State of play

Stakeholder responses indicate a very strong consensus on the critical importance of reliable and

secure cross-border and inter-agency communication for public authorities responsible for security

and safety. A large majority of respondents consider such capabilities to be very important (88%, 22

out of 25), with only a marginal share indicating lower levels of importance. This highlights a near-

unanimous recognition of the operational relevance of effective communication systems in an

increasingly interconnected risk environment. At the same time, respondents consistently point to

significant limitations in the current functioning of critical communication systems across Europe. A

large majority consider that existing systems are not sufficient to support effective cross-border and

inter-agency operations (76%, 19 out of 25). This suggests a clear gap between operational needs and

current system performance, particularly in cross-border contexts.

This assessment is further corroborated by stakeholder views on the relevance of key problem drivers.

Limited operational mobility and interoperability across borders and between agencies is identified

as a major issue, with the vast majority of respondents considering it relevant or very relevant (84%,

21 out of 25). Similarly, limited resilience of critical communication infrastructure in the face of

52

evolving threats is widely perceived as a significant problem (84%, 21 out of 25). Concerns related

to limited autonomy and sovereignty of communication systems are also prominent, with 76% of

respondents (19 out of 25) considering this issue relevant or very relevant.

The consultation also highlights a set of underlying structural factors contributing to these challenges.

Limited interoperability due to heterogeneous technologies and varying levels of system maturity

emerges as the most critical driver, as pointed out by 88% of respondents (22 out of 25). Similarly,

fragmentation of governance frameworks, roles and procedures across agencies and MS is also

identified as a key constraint (84%, 21 out of 25), alongside limitations in existing security standards

and infrastructures (76%, 19 out of 25). In addition, a significant share of respondents points to

dependencies on non-EU suppliers (68%, 17 out of 25), insufficient network coverage in certain areas

(68%, 17 out of 25), and a fragmented EU market limiting innovation and standardisation (76%, 19

out of 25).

Corroborating quantitative data, qualitative feedback point to persistent technical and operational

barriers, including the lack of cross-border compatibility of existing systems, the continued reliance

on legacy narrowband technologies, and the complexity of replacing entrenched infrastructures.

Respondents also highlight emerging risks related to cybersecurity vulnerabilities, dependence on

third-country technologies, and insufficient spectrum availability. More broadly, stakeholders

underline that fragmented and heterogeneous systems, combined with complex governance and

regulatory environments, continue to hinder effective coordination and rapid response in cross-border

emergency situations.

Overall, the consultation reveals a strong and consistent perception that, while the importance of

mission-critical communications is widely acknowledged, current systems remain fragmented,

insufficiently interoperable, and not fully adapted to evolving operational and security requirements.

Necessity and added value on EU intervention

Stakeholder responses indicate a strong perception that the identified challenges cannot be

sufficiently addressed by Member States alone, and that EU-level intervention would be necessary

to effectively tackle them. A very large majority of respondents consider EU action to needed (88%,

22 out of 25). Only a limited share expresses lower levels of necessity (12%, 3 out of 25), this suggests

a broad recognition of the cross-border nature of the identified problems and the limitations of purely

national approaches. While this overall assessment is widely shared, stakeholder differences emerge

more clearly when considering market and regulatory aspects, with industry respondents expressing

neutral views regarding the implications of EU intervention in terms of regulatory burden and

flexibility, while public authorities and EU citizens more consistently emphasise the need for

coordinated action to address cross-border operational challenges.

These findings are further reinforced by stakeholder views on the added value of EU action; indeed,

respondents consistently attribute high significance to EU-level intervention across all assessed

dimensions. Ensuring interoperability and operational mobility of public authorities across borders

emerges as the area with the strongest perceived added value, with 96% of respondents (24 out of

25) considering it significant or very significant. Similarly, increasing the resilience and security of

critical communication infrastructure is seen as highly dependent on EU action (88%, 22 out of 25).

Strong interest is also attributed to strengthening EU technological sovereignty and reducing

dependencies on non-EU suppliers (80%, 20 out of 25 significant or very significant), as well as

promoting technological innovation and competitiveness in the EU critical communication sector

(88%, 22 out of 25). In this context, stakeholder views diverge more visibly on market implications,

with industry respondents placing greater emphasis on potential impacts on investment conditions

53

and flexibility, while EU citizens highlight opportunities for market integration, economies of scale

and enhanced competitiveness.

Overall, these findings point to a strong convergence of views among stakeholders that EU-level

action would provide substantial added value across multiple dimensions, particularly in addressing

interoperability challenges, strengthening resilience and security, and supporting a more coordinated

and integrated approach to critical communications across Europe.

Policy Options

Stakeholder responses reveal a differentiated perception of the suitability of the policy options, with

clear patterns of convergence and some areas of more mixed views. The status quo option is widely

perceived as inadequate, with a very large majority of respondents expressing disagreement (80%,

20 out of 25). The voluntary approach based on technical interconnectivity receives more mixed

assessments. While a majority of respondents express disagreement (52%, 13 out of 25), a non-

negligible share indicates support (20%, 5 out of 25), and a significant proportion remains neutral

(24%, 6 out of 25).

By contrast, the option establishing a system of systems based on an EU legal framework is associated

with a strong level of stakeholder support. A large majority of respondents express agreement (84%,

21 out of 25), including 44% (11 out of 25) who strongly agree, while only a limited share expresses

disagreement (12%, 3 out of 25).

The option involving a fully centralised EU system receives comparatively more balanced

assessments. While a majority of respondents express agreement (88%, 22 out of 25), a notable share

expresses disagreement (28%, 7 out of 25).

Beyond the assessment of options, stakeholders emphasise a number of key considerations for the

design of any potential EU intervention. In particular, a very large majority highlight the importance

of ensuring clear roles and responsibilities across EU and national levels (92%, 23 out of 25),

flexibility to adapt to technological change (92%, 23 out of 25), and proportionality and respect for

Member State sovereignty (84%, 21 out of 25). Strong emphasis is also placed on ensuring coherence

with existing EU legislation (88%, 22 out of 25), minimising administrative burden (76%, 19 out of

25), and carefully considering obligations for mobile network operators (68%, 17 out of 25).

Qualitative feedback further underlines the importance of addressing operational, legal and technical

constraints, including the need for secure interoperability with legacy systems, alignment with EU

security classification frameworks, standardisation of procedures, and access to funding for

infrastructure deployment. Stakeholders also highlight concerns related to data protection,

operational usability, and the need to balance EU-level coordination with national specificities and

competencies.

Assessment of the impacts

These patterns are broadly reflected in the assessment of expected impacts. The status quo option is

predominantly associated with negative impacts across economic, social and environmental

dimensions, with negative or very negative ratings ranging from 60% (15 out of 25) for economic

impacts to 64% (16 out of 25) for social impacts and 64% (16 out of 25) for environmental impacts.

While this option is associated with relatively low or moderate adjustment and administrative costs

(24%, 6 out of 25 indicating very low costs and 16%, 4 out of 25 neutral), respondents point to higher

enforcement and opportunity costs, reflecting inefficiencies linked to the persistence of fragmented

systems, which contributes to its overall negative impact profile.

54

The voluntary interconnection option presents mixed opinions, with responses distributed across

negative (40%, 10 out of 25) and positive (32%, 8 out of 25) economic impacts, and similar patterns

across social and environmental dimensions, reflecting uncertainty regarding its overall

effectiveness. This is mirrored in the cost assessment, where respondents identify moderate to high

costs, particularly in terms of enforcement (32%, 8 out of 25 indicating high costs), suggesting that

the coordination of voluntary arrangements may generate additional complexity without fully

delivering the expected benefits. In this regard, stakeholder responses indicate that industry actors

are more likely to perceive higher enforcement and opportunity costs linked to coordination burdens

and the absence of harmonised frameworks, while public authorities tend to associate costs with

inefficiencies arising from continued fragmentation rather than direct financial investment.

In contrast, the system of systems option is consistently associated with positive impacts, with 80%

of respondents (20 out of 25) indicating positive or very positive economic impacts, 92% (23 out of

25) for social impacts, and 44% (11 out of 25) for environmental impacts, although the latter shows

a more moderate distribution. These benefits are, however, associated with higher upfront costs, with

a majority of respondents identifying high adjustment and compliance costs (48%, 12 out of 25), as

well as high administrative (44%, 11 out of 25) and enforcement costs (40%, 10 out of 25).

Differences across stakeholder groups are particularly visible in the perception of these costs, with

industry respondents more frequently indicating high adjustment and enforcement costs due to direct

exposure to implementation and infrastructure requirements, while public authorities tend to adopt a

more balanced view, recognising both the scale of initial investments and the expected efficiency

gains from reduced fragmentation. This suggests that, while the option entails significant initial

investments, it is perceived as delivering more substantial and consistent benefits over time.

Finally, the centralised EU system option is generally associated with positive impacts, with 48% of

respondents (12 out of 25) indicating positive or very positive economic impacts and 64% (16 out of

25) for both social and environmental impacts, although these are accompanied by a higher share of

negative assessments compared to the system of systems. This more mixed perception is closely

linked to the significantly higher cost expectations associated with this option, particularly in terms

of very high adjustment and administrative costs (32%, 8 out of 25 and 36%, 9 out of 25 respectively),

reflecting the scale and complexity of establishing a centralised infrastructure. Stakeholder responses

indicate that industry actors are more likely to report very high adjustment and administrative costs,

reflecting direct exposure to infrastructure deployment and compliance requirements, while public

authorities also report high administrative costs linked to organisational restructuring and governance

adaptation. EU citizens, although recognising the scale of upfront investments, more frequently

emphasise the potential for long-term efficiency gains and reduced duplication across Member States.

Overall, the consultation reveals a clear preference for more coordinated approaches compared to the

baseline and voluntary scenarios, while also highlighting important trade-offs in terms of costs,

feasibility and governance that need to be considered in the design of EU-level intervention.

Conclusion

The analysis of the Public Consultation highlights a consistent recognition among stakeholders of the

growing importance of critical communication systems in ensuring effective public safety, security

and crisis response across Europe. At the same time, the findings point to persistent limitations in the

current functioning of these systems, especially when approaching cross-border and inter-agency

contexts. Fragmentation of technologies, governance frameworks and operational procedures

continue to constrain interoperability, limit operational mobility and reduce the overall effectiveness

of coordinated responses to emergencies and security incidents.

55

These challenges are perceived as structural in nature and closely linked to the evolving operational

and threat environment. In this context, the current landscape is not considered fully adequate to

support the needs of public authorities responsible for security and safety.

The consultation confirms the overall perception that these issues cannot be effectively addressed

through isolated national actions. The cross-border dimension of critical communications, combined

with the need for common standards, shared procedures and enhanced resilience, points to the need

for more coordinated approaches at EU level. The role of EU intervention in enabling

interoperability, strengthening security and resilience, supporting technological innovation, and

fostering a more integrated and predictable framework is widely expected among the various

stakeholders.

At the same time, the assessment of policy options highlights the relevance of balancing the benefits

of increased coordination with considerations related to feasibility, costs and governance. Structured

and coordinated approaches are generally seen as better suited to addressing the identified challenges,

however, stakeholders emphasise the need to preserve flexibility, respect Member State

competencies, and ensure that any future framework remains adaptable to national specificities and

operational realities.

Overall, the consultation results point to a clear need to address existing gaps in interoperability,

resilience and coordination, while highlighting the importance of designing solutions that are both

effective at EU level and workable in practice. This requires a calibrated approach that combines

common principles and standards with sufficient flexibility to accommodate the diversity of systems

and operational contexts across Europe.

56

ANNEX 3: WHO IS AFFECTED AND HOW?

1. PRACTICAL IMPLICATIONS OF THE INITIATIVE

5 million emergency services across Europe will benefit from inter-agency and cross-border critical

communications enabling faster and more efficient response to incidents and major crises. Citizens

across Europe will benefit from reduced response time of emergency services in case of accidents,

security incidents, and natural disasters. There will be positive impacts for providers of critical

infrastructure services and solutions. Mobile network operators will have to make arrangements to

facilitate critical communications on commercial networks.

2. SUMMARY OF COSTS AND BENEFITS

I. Overview of Benefits (total for all provisions) – Preferred Option

Description Amount Comments

Direct benefits

Enhanced cooperation and

information exchange for

emergency services

5 million users in 31 Member States

interconnected via EUCCS

Faster and more efficient response to in case

of accidents, security incidents, and natural

disasters

Strengthening of EU

security industry to provide

state of the art critical

communications technology

Close to 14 billion EUR investments to be made

at the EU and Member States level combined, to

be carried out in harmonised timelines by 2030,

2033 and 2036

Providers of critical communications

infrastructure, solutions and services will

directly benefit from streamlined

investments from the EU and Member States

in mission critical broadband, creating

business opportunities and enhancing

European competitiveness at the

international level

Indirect benefits

Strengthening of EU

strategic autonomy in the

critical communications

sector

Up to 9000 European companies could benefit

from a dynamic investment ecosystem created

under EUCCS

EUCCS will enhance strategic autonomy

and give them a competitive advantage to

the European industry also beyond Europe

(1) Estimates are gross values relative to the baseline for the preferred option as a whole (i.e. the impact of individual

actions/obligations of the preferred option are aggregated together); (2) Please indicate in the comments column which

stakeholder group is the main recipient of the benefit;(3) For reductions in regulatory costs, please describe in the

comments column the details as to how the saving arises (e.g. reductions in adjustment costs, administrative costs,

regulatory charges, enforcement costs, etc.;);.

II. Overview of costs – Preferred option

Citizens/Consumers Businesses Administrations

One-off Recurrent One-off Recurrent One-off Recurrent

Policy

Option 2.1

Direct adjustment

costs N/A N/A N/A N/A € 794,919,480.98 € 2,478,045,299.38

Direct

administrative

costs

N/A N/A N/A N/A € 189,624,205.24 €

108,808,668.70

Direct regulatory

fees and charges N/A N/A N/A N/A N/A N/A

Direct

enforcement costs N/A N/A N/A N/A N/A N/A

57

Indirect costs N/A N/A N/A N/A

(1) Estimates (gross values) to be provided with respect to the baseline; (2) costs are provided for each identifiable

action/obligation of the preferred option otherwise for all retained options when no preferred option is specified;

(3) If relevant and available, please present information on costs according to the standard typology of costs

(adjustment costs, administrative costs, regulatory charges, enforcement costs, indirect costs;).

III. Application of the ‘one in, one out’ approach – Preferred option(s)

[M€]

One-off

(annualised total net present

value over the relevant period)

Recurrent

(nominal values per year)

Total

Businesses

New administrative

burdens (INs)

N/A N/A N/A

Removed administrative

burdens (OUTs)

N/A N/A N/A

Net administrative

burdens*

N/A N/A N/A

Adjustment costs**NA N/A

Citizens

New administrative

burdens (INs)

N/A N/A N/A

Removed administrative

burdens (OUTs)

N/A N/A N/A

Net administrative

burdens*

N/A N/A N/A

Adjustment costs**N/A N/A

Total administrative

burdens*** N/A N/A N/A

(*) Net administrative burdens = INs – OUTs;

(**) Adjustment costs falling under the scope of the OIOO approach are the same as reported in Table 2 above. Non-annualised

values;

(***) Total administrative burdens = Net administrative burdens for businesses + net administrative burdens for citizens.

3. RELEVANT SUSTAINABLE DEVELOPMENT GOALS

IV. Overview of relevant Sustainable Development Goals – Preferred Option(s)

Relevant SDG Expected progress towards the Goal Comments

SDG no. 16 – Promote peaceful and inclusive

societies for sustainable development,

provide access to justice for all, and build

effective, accountable, and inclusive

institutions at all levels

By enabling interoperable, secure, and resilient cross-

border communication among public authorities

responsible for security and safety, the EUCCS

strengthens the operational capacity of these

institutions, supports efficient coordination in crisis

situations, and enhances the accountability and

reliability of public security and safety services.

58

SDG no. 11 - Make cities and human

settlements inclusive, safe, resilient and

sustainable

By 2030, significantly reduce the number of deaths and

the number of people affected and substantially

decrease the direct economic losses relative to global

gross domestic product caused by disasters, including

water-related disasters, with a focus on protecting the

poor and people in vulnerable situations.

SDG no. 13 - Strengthen resilience and

adaptive capacity to climate-related hazards

and natural disasters in all countries

The EUCCS will strengthen resilience and adaptive

capacity to climate-related hazards and natural disasters

in all countries.

SDG no. 16 - Promote peaceful and inclusive

societies for sustainable development,

provide access to justice for all and build

effective, accountable and inclusive

institutions at all levels

The EUCCS will Strengthen relevant national

institutions, including through international

cooperation, for building capacity at all levels to

prevent violence and combat terrorism and crime.

59

ANNEX 4: ANALYTICAL METHODS

The stakeholder consultation activities carried out under this Study aimed to support the impact

assessment on the EUCCS initiative by collecting evidence on the current state of critical

communication systems across Europe, the main challenges affecting cross-border mission-critical

communications, stakeholders’ views on the policy options under consideration for the establishment

of the EUCCS, and their economic, social, environmental, and technical impacts.

In line with the Better Regulation Guidelines, the consultations were designed to ensure that the

impact assessment is grounded in evidence from the stakeholders most directly concerned by the

initiative.

The Call for Evidence feedback was qualitatively analysed by recognising stakeholder positions,

recurring issues in cross-border critical communications, as well as preferences regarding the policy

options identified for the establishment of the EUCCS.

The Public Consultation was designed to engage a broad spectrum of public and private stakeholders

and collect both quantitative and qualitative evidence on the needs, challenges and expectations

related to cross-border mission-critical communication in Europe. Contributions received through

the questionnaire were reviewed and analysed as a whole and, where relevant, by stakeholder

category in order to identify recurring views, areas of convergence and points of divergence.

The targeted survey for EU Member States public authorities collected both quantitative and

qualitative information on the governance of critical communications, existing and planned technical

capabilities in the EU Member States, interoperability, resilience, cross-border use cases, perceived

challenges and the expected impacts of the policy options for the establishment of the EUCCS. 27

replies were received in total, corresponding to 25 countries. For analytical purposes, duplicate

responses from France and Sweden were consolidated to a unique country-based response.

The targeted survey for industry representatives collected mainly qualitative information on the

current state of the market, technical and operational challenges, and views on the policy options and

their impacts. The survey covered organisations identifying as 3GPP/mission critical technology

providers, TETRA technology providers, critical communications device providers, and Mobile

Network Operators.

The exploratory and targeted interviews were semi-structured and organised around tailored

interview guides depending on the stakeholder group. Interview minutes were shared with the

interviewees for review and validation. Inputs from EU institutions and agencies, international

organisations, end-users, industry representatives, and Mission Critical Communication Group

working group leaders were analysed qualitatively to identify recurring themes, converging views

and points of divergence across stakeholder groups. Conversely, interviews targeting European

authorities collected quantitative data on the costs of the policy options for the establishment of the

EUCCS and were therefore analysed using quantitative methods.

The co-creation workshops were organised to support the development and validation of the

intervention logic and policy measures for the establishment of the EUCCS. Bringing together

representatives from EU institutions and agencies, European public authorities, and end-user

organisations, these workshops applied design thinking principles to test preliminary hypotheses and

foster a shared understanding of the problems, problem drivers, external factors, general and specific

objectives, policy options, and expected impacts. The discussions and outputs from these workshops

60

were reviewed qualitatively and used to refine the analytical framework and inform the subsequent

steps of the Study.

Finally, the Mission Critical Communication Group meetings were used as an additional consultation

channel to collect expert input from European public authorities, as well as EU bodies and agencies.

Inputs gathered through these meetings were used to complement and contextualise the evidence

collected through the other consultation activities.

For all consultation activities, the data were cleaned and analysed using both descriptive and

qualitative methods. Quantitative findings were aggregated in tables and charts using spreadsheets,

while open-text responses and interview minutes were reviewed to identify common themes,

explanatory factors and illustrative stakeholder positions. The results from the different consultation

channels were compared to identify points of convergence and divergence.

The primary evidence stems extensive consultation of Member States and their emergency services.

That was achieved via a series of surveys and targeted interview conducted by the contractor team

that delivered the supporting study, as well as direct outreach and additional questionnaires of DG

HOME to the Mission Critical Communication Group, which comprises almost all competent

authorities of Member States. More specifically:

• Call for Evidence (April 2025 - May 2025), with 24 responses from EU citizens - companies

- public authorities - public agencies - industry and interest associations - NGOs, to obtain

feedback on the Commission's understanding of the problem and possible solutions and give

us any relevant information that they may have, including on possible impacts of the different

options.

• Public Consultation (January 2026 – April 2026), with 25 responses from EU citizens –

business associations - public authorities – companies – trade unions – NGOs, to engage a

broad spectrum of public and private stakeholders to gather relevant information on the needs,

challenges, and expectations related to cross-border mission-critical communication.

• Targeted survey for EU Member States public authorities (November 2025 – January 2026),

with 25 responses, to identify the state-of-play of critical communication systems at the

national level, gather information on the needs for EU intervention and cross-border

communications, and collect views on the policy options for the EUCCS, as well as their

impacts and cost estimates.

• Targeted survey for industry representatives (November 2025 – December 2025), with 9

responses, to identify the current state of critical communications systems from the industry

perspective, gather information on the needs for EU intervention and cross-border

communication, and collect views on the policy options for the EUCCS, including their

impacts and cost estimates.

• 14 exploratory interviews (September 2025) with EU institutions and agencies - EU MS

public authorities - industry representatives - end-users - international organisations, to gain

a deeper understanding of the political context, identify potential challenges and limitations,

draw lessons from related EU-funded projects, and gather preliminary feedback on the current

issues, the rationale for the EUCCS, and its objectives and drivers.

• 21 targeted interviews (January 2026 – March 2026) with EU MS public authorities - industry

representatives - end-users of critical communication systems – leaders of the Mission Critical

61

Communication Group (MCCG) working groups, to collect views from underrepresented

stakeholder groups, clarify any gaps or uncertainties from the surveys and gather quantitative

data for the impact assessment.

• 3 co-creation workshops (2 October 2025, 24 October 2025 and 19 November 2025) with EU

institutions and agencies - EU MS public authorities - end-user organisation, to reach a

common agreement and alignment among all participants on the intervention logic (problems,

problem drivers, external factors, general and specific objectives, policy options and expected

impacts) and the policy measures for the EUCCS.

• Consultations of the MCCG during 3 meetings (22-23 October 2025, 11 December 2025 and

26 February 2026), to collect the expert group’s opinions and ask targeted questions to gather

quantitative and qualitative data.

Consultation session (10 March 2026) with Mobile Network Operators (MNOs) representative

organisations (Global System for Mobile Communications Association (GSMA), The Critical

Communications Association (TCCA) and Public Safety Communication Europe (PSCE Europe)),

to gather information on the needs for EU intervention and cross-border communication, and collect

views on the policy options for the EUCCS, including their impacts and cost estimates, with a

particular focus on MNOs.The table below summarises the consultation activities carried out,

indicating for each consultation type its period, number of consultations, objectives, stakeholder

groups covered, and number of respondents.

62

Consultation

activity Period

Number of

consultations Objectives Stakeholder groups covered

Number of

respondents

Call for

Evidence

analysis

Sept-

Oct

2025

1 Analyse the feedback received on the Call for evidence published

on the ‘Have Your Say’ web portal. • EU citizens (6)

• Companies (5)

• Public authorities (4)

• Public agencies (3)

• Industry and interest associations (3)

• Non-governmental organisations (NGOs) (3)

24

Public

Consultation

Jan-

Apr

2026

1 Engage a broad spectrum of public and private stakeholders to

gather relevant information on the needs, challenges, and

expectations related to cross-border mission-critical

communication in EU MS and SAC.

• EU citizens (5)

• EU MS and SAC public authorities (13)

• Business associations (1)

• Companies (4)

• Trade Unions (1)

• NGOs (1)

25

Targeted

survey for

EU MS and

SAC

Nov

2025-

Jan

2026

1 Identify the state-of-play of critical communication systems at the

national level, gather information on the needs for EU intervention

and cross-border communications, and collect views on the policy

options for the EUCCS, as well as their impacts and cost estimates.

• EU MS and SAC public authorities

25

Targeted

survey for

industry

representativ

es

Nov-

Dec

2025

1 Identify the current state of critical communications systems from

the industry perspective, gather information on the needs for EU

intervention and cross-border communication, and collect views

on the policy options for the EUCCS, including their impacts and

cost estimates.

• Industry representatives (critical communication

system providers, MNOs)

9

63

Consultation

activity Period

Number of

consultations Objectives Stakeholder groups covered

Number of

respondents

Exploratory

interviews

Sept

2025

14 Gain a deeper understanding of the political context, identify

potential challenges and limitations, draw lessons from related EU-

funded projects, and gather preliminary feedback on the current

issues, the rationale for the EUCCS, and its objectives and drivers.

• EU institutions and agencies (6)

• EU MS and SAC public authorities (3)

• Industry representatives (3)

• End-users (1)

• International organisations (1)

14

Targeted

interviews

Jan-

Mar

2026

21 Collect views from underrepresented stakeholder groups, clarify

any gaps or uncertainties from the surveys and gather quantitative

data for the impact assessment.

• EU MS and SAC public authorities (9)

• Industry representatives (3)

• End-users of critical communication systems (2)

• MCCG working group leaders (7)

21

Co-creation

workshops

02 Oct

2025

24 Oct

2025

19 Nov

2025

3 Reach a common agreement and alignment among all participants

on the intervention logic (problems, problem drivers, external

factors, general and specific objectives, policy options and

expected impacts) and the policy measures for the EUCCS.

• EU institutions and agencies

• EU MS and SAC public authorities

• End-user organisations

/

MCCG

meetings

22-23

Oct

2025

11 Dec

2025

26 Feb

2026

3 Collect the expert group’s opinions and ask targeted questions to

gather quantitative and qualitative data. • EU MS and SAC public authorities

• EU institutions and agencies

/

ANNEX 5: COMPETITIVENESS CHECK

1. Overview of impacts on competitiveness

Dimensions of

Competitiveness

Impact of the

initiative (++ / + / 0 / -

/ -- / n.a.)

References to sub-sections of

the main report or annexes

Cost and price

competitiveness ++ Technical impact analysis

International

competitiveness ++ Technical impact analysis

Capacity to innovate ++ Technical impact analysis

SME competitiveness ++ Annex 6

2. Synthetic assessment

EUCCS is expected to have a positive impact on European competitiveness in the critical

communication domain. Critical communication is a small but very specialised segment of the

overall telecommunication sector and European companies are currently among the leading

providers and exporters of services, specifically in the narrowband technologies. The

establishment of EUCCS will support the business opportunities by providing harmonised and

predictable timeline for the deployment of mission critical broadband in Member States.

Specialised industry can thus adapt and offer tailored services and solutions, benefiting from

procurement launched by Member States and increased demand for new devices, services and

solutions that facilitate broadband-based functionalities for emergency services.

The move to a 3GPP based EUCCS with the de-coupling of the three key elements (below) of the

CCS supplier offerings will result in increased competitiveness in each domain.

i. user equipment (UE)

ii. radio-access and transport network

iii. the central mission critical servers

Specifically, the migration to ubiquitous mobile phone networks will result in opening to

competition of the EU market. Basing EU on mobile phone technologies will create a much larger

potential supplier base, moving the supply chain to outside of the niche market occupied by the

TETRA and TETRAPOL suppliers.

Similarly, the mission critical market will be de-coupled from the radio-access networks and will

connect to the UE in the same fashion as mobile phone apps do with mobile services. This opens

the ecosystem to value-add services that can be offered over the CCS network by new entrants

with much lower barriers to entry, creating a more competitive ecosystem and driving prices lower

as a result. Given the number of National Authorities and range of nations that would be covered

by the EUCCS, this would create a very unique market that could support a multitude of offerings

from smaller companies.

65

Competition for the mobile phone contracts to support the Public Protection and Disaster Relief

users, while only small in numbers in absolute terms, constitute a very large single contract for

mobile phone companies. This should create price and functionality competition amongst mobile

service providers.

Formation of EUCCS will drive the evolution of critical communication broadband market

worldwide. Europe is readily leading in multi-agency communication via national shared public

safety narrowband networks. European based TETRA and Digital Mobile Radio (DMR)

technologies are globally dominant in the digital narrowband sector outside North America. With

3GPP based Broadband transition fundamentally 5G based solutions will be deployed throughout

the world. To function properly EUCCS must address many challenges other nations will be facing

as their broadband transition commences. By addressing the challenges like broadband

interoperability best practises and standards are set others will de facto follow giving an edge to

EUCCS suppliers.

3. Competitive position of the most affected sectors

General market including consumers

3GPP UE sector: this is not a sector where the EU has any meaningful presence.

3GPP mobile networks: the EU has a large presence here, but it is unlikely to be affected one

way or another by the EUCCS.

3GPP mission critical services: this is a sector where the EU has an important presence which

would benefit from the increased innovation and competition of a 3GPP EUCCS. Conversely,

Remaining on TETRA and TETRAPOL based systems would dilute commercial incentives for

the existing suppliers to invest in 3GPP based solutions that would be marketable globally.

Critical Communications market sectors

Devices

- Chipset: dependency on Qualcomm and Mediatek

- Operating system: currently dependency on Android and iOS, opportunity to build

independent OS ecosystem

- Design: several sector specific leading companies

- Assembly: full competence – competitive if supply chain security is an important factor

Networks

- Core and RAN: Europe is leading 3GPP based defence development that has significant

synergies with critical communication sector.

- EUCCS via the national Public Protection and Disaster Relief BB networks drives

availability, resiliency, reliability and security demand in general in mobile networks. This

has already generated many new business opportunities in network design, management,

monitoring, automation. These innovations will be required not only for Public Protection

and Disaster Relief Broadband services, but also for consumer and enterprise services as

recognition of society mobile communication dependency increases.

66

Applications

- European challenge is very fragmented market requiring plenty of localisation among

others due to different languages leading many times to project instead of product type

implementations. EUCCS opportunity is to foster more common baseline requirements

leading to greater market, yet localised products that can be adjusted to target markets

outside Europe.

- European benefit is very advanced multi-agency and partly multi-national co-operation that

has driven efficient operational models and products supporting them. These field

operational models can be exported to other nations with the product and services support.

EUCCS will drive this development cross national borders

Society perspective

- Societies are deeply dependent on always functioning mobile communication. EUCCS

increases the general European service availability to all citizens and enterprises as EUCCS

related investments in hardening, power resilience etc. largely impacts commercial

networks.

67

ANNEX 6: SME CHECK

OVERVIEW OF IMPACTS ON SMES

Relevance for SMEs

Based on SME filter and the ISG discussion, this initiative is relevant for SMEs96.

(1) IDENTIFICATION OF AFFECTED BUSINESSES AND ASSESSMENT OF RELEVANCE

Are SMEs directly affected? In which sectors?

Yes. Providers of:

- critical communication services, infrastructure and equipment.

- mobile and control room and testing applications.

- integrators of multi-sensor systems for situational awareness

- providers of integrated deployable communication systems

- threat intelligence and vulnerability assessment security services

Estimated number of directly affected SMEs

We estimate 9,000 SMEs are offered new market opportunities. For example:

15% 1.350 Critical communication services, infrastructure and equipment.

35% 3.150 Mobile and control room and testing applications.

14% 1.260 Integrators of multi-sensor systems for situational awareness

15% 1.350 Providers of integrated deployable communication systems

10% 900 Threat intelligence and vulnerability assessment security services

1% 50 Training Services

10% 900 Specific consulting, for example where national competent

authorities

100% 9.000

Those providing existing Applications will be encouraged to become compatible with EUCCS,

which is not considered to be a complex process.

Estimated number of employees in directly affected SMEs

Over 450 000

Are SMEs indirectly affected? (No) In which sectors? What is the estimated number of

indirectly affected SMEs and employees?

96 https://ec.europa.eu/docsroom/documents/63274

68

Yes. Most society sectors will benefit from higher availability, resilience, improved mobile network

coverage - especially in rural areas. Better reliable communication improves rural areas companies

– typically SMEs – competitivity as they can better offer their services utilising digitalised channels.

(2) CONSULTATION OF SME STAKEHOLDERS

How has the input from the SME community been taken into consideration?

Yes, SMEs participated in the Call for Evidence, the Commission Open Public Consultation and

the targeted stakeholders' consolations. Furthermore, SME are part of the consortia that developed

the technical basis for EUCCS, including the current ISF-funded EUCCS Preparation Project. In

BroadWay and EUCCS Preparation, ~10 SMEs were directly involved in the process, and ~50

involved in outside engagements.

Are SMEs’ views different from those of large businesses?

The Call for Evidence, the Commission Open Public Consultation, the active integration in the

EUCCS Preparation Project as well as the targeted stakeholder consultations have not shown any

difference between the position of SME and bigger players in the market.

The large businesses contracted for the technical work under the EU-funded EUCCS Preparation

project have all engaged with SME’s who have developed the core functionality of Mission Critical

Services.

(3) ASSESSMENT OF IMPACTS ON SMES97

What are the estimated direct costs for SMEs of the preferred policy option?

There are no costs for SME related to the preferred policy option.

Qualitative assessment

N/A

Quantitative assessment

N/A

What are the estimated direct benefits/cost savings for SMEs of the preferred policy option98?

Qualitative assessment

Providers of critical communication services, infrastructure and equipment, integrated systems and

applications are in many cases SME. They will benefit from the establishment of EUCCS, given it

provides clear timelines and incentives for the modernisation of critical communication systems in

Member States. That creates in turn business opportunities as new services and devices will be

required by emergency services. Especially for services, devices and applications there is big

97 The costs and benefits data in this annex are consistent with the data in annex 3. The preferred option

includes the mitigating measures listed in section 4. 98 The direct benefits for SMEs can also be cost savings.

69

potential for smaller industry players and start-ups, while on the infrastructure side traditionally

bigger enterprises define the market. This is already seen through EUCCS Preparation, as explained

above.

Quantitative assessment

The global market for Applications (see point 1) alone, is $11.2 billion by 2030 (quoted in the SNS

Telecom Public Safety Market report 202699). Scaled to Europe (15%) is ~€1.65 billion. This covers

the following which are mostly provided by SMEs, or large industry working with SMEs:

• Mission-Critical Voice & Group Communications

• Real-Time Video Transmission

• Messaging, File Transfer & Presence Services

• Mobile Office & Field Applications

• Location Services & Mapping

• Situational Awareness

• Command & Control

• AR/VR/MR (Augmented, Virtual & Mixed Reality)

Integration of systems (2 bullets in point 1) has a global market of $5.2 billion with a scaled estimate

for Europe of €0.8 billion.

A market opportunity for SMEs of ~€2.45 billion. Considering 9000 SMEs, there would be ~€27M

opportunity each.

What are the indirect impacts of this initiative on SMEs?

N/A

(4) MINIMISING NEGATIVE IMPACTS ON SMES

Are SMEs disproportionately affected compared to large companies?

No.

If yes, are there any specific subgroups of SMEs more exposed than others?

N/A

Have mitigating measures been included in the preferred option/proposal?

No

CONTRIBUTION TO THE 35% BURDEN REDUCTION TARGET FOR SMES

99 Public Safety LTE & 5G Market: 2025-2030: Opportunties, Challenges, Strategies and Forecasts

https://www.snstelecom.com/public-safety-lte

70

Are there any administrative cost savings relevant for the 35% burden reduction target for

SMEs?

No.

71

ANNEX 7: ADDITIONAL MATERIALS

7.1 Graphs supporting this Impact Assessment

Below are graphs and visualizations that help better substantiate the claims made

throughout the report and offer evidence. All figures are referenced to in footnotes

throughout the text for ease of consultation.

Figure 1. Rise in the number of activations of the UCPM mechanism

Figure 2. Maturity level of national critical communication systems in Member States

Narrowband system

(MS)

Narrowband system

(SAC)

Hybrid

configurations

(MS)

Hybrid

configurations

(SAC)

12 NO 11 1

Figure 3. Expected entry into EUCCS (data collected during the 12th MCCG Meeting, 22-23 April 2026)

2030 2033 2036

11 4 15

72

Figure 4. Reported level of interoperability with CCS in other MS and SAC

Figure 5. Reported level of handover/roaming being an issue in cross-border critical communications

73

Figure 6. Reported resilience of national critical communication systems in the EU Member States100

Figure 7. Reported period since national critical communications systems became operational in the MS

100 The categories of reliability and resilience in the targeted survey are defined as follows:

1 - Very unreliable and not resilient (commercial best-effort service only; very limited backup power (<2h)

and little or no redundancy of sites, backhaul, or core);

2 - Unreliable and poorly resilient (some backup power (about 2–6h at key sites) or limited redundancy, but

many critical sites or links remain single points of failure; no systematic QPP);

3 - Moderately reliable and somewhat resilient (backup power of about 6–12h at many key sites; partial

redundancy of sites/backhaul or core; some QPP for critical users; vulnerabilities remain in major or

prolonged incidents);

4 - Reliable and resilient (backup power of about 12–24h at most key sites; redundant RAN/backhaul and a

redundant core network for critical services; QPP widely implemented);

5 - Very reliable and highly resilient (backup power >24h at critical sites; strong redundancy across RAN,

backhaul and core; consistent QPP; effective fallback options (e.g. D2D or satellite) available for extreme or

long-lasting incidents).

74

Figure 8. Reported period since national critical communications systems became operational in the MS

75

Figure 9. Reported coverage of national critical communication systems in EU Member States

Figure 10. Reported impact of cybersecurity vulnerabilities on the effectiveness of cross-border operations

across MS

76

Figure 11. Reported impact of the absence of backup systems on the effectiveness of cross-border

operations across EU MS and SAC

Figure 12. Reported cybersecurity evolution of critical communication systems in the next 5-10 years in

the scenario of no EU action

77

Figure 13. Reported level of seamless Public Protection and Disaster Relief roaming across borders in MS

Figure 14. Reported plans or projects to update or upgrade national legacy narrowband systems

78

Figure 15. Reported priorities or needs for improving current national CCS over the next 5 years

79

Figure 16. Visualisation of operations of preferred policy option 2.1

Detailed overview of costs for Policy Options

7.2. POLICY OPTION 0 = Status quo

Cluster Average one-off cost

(CapEx)

Average annual recurrent

cost (OpEx)

Average discounted OpEx over

7 years at 3% discount factor

Total average cost [1] = average

CapEx + average discounted

Opex

Cluster 1 – large countries

(8: FR, RO, ES, SE, DE, IT, NO,

PL)

€ 292,905,000.00 € 67,481,250.00 € 420,427,281.67 € 713,332,281.67

Cluster 2 – medium countries

(14: BE, CZ, DK, FI, NL, AT, BG,

GR, HU, IE, LT, PT, SK, CH + LI)

€ 122,024,499,89

€ 48,127,168.22

€ 299,845,875.26

€ 421,870,375.70

Cluster 3 – small countries

(8: EE, LV, LU, SI, HR, CY, IS,

MT)