On 10 December, the European Emergency Number Association (EENA) has submitted its official response to the European Commission’s survey on the European Declaration on Digital Rights and Principles for the Digital Decade.
EENA welcomes the opportunity to respond to the European Commission’s survey on the European Declaration on Digital Rights and Principles for the Digital Decade. The rights enshrined in this declaration are vital for ensuring the safety of EU citizens online and offline by improving access to emergency services, and EENA’s response addresses the importance of these rights in relation to Articles 1 and 2.
Article 1: Putting people at the centre of the digital transformation
Article 1(b) of the Declaration emphasizes the need to place people at the centre of the digital transformation, including by taking all necessary measures to uphold individuals’ rights both online and offline.
In this regard, EENA notes that the right to contact emergency services at all times, codified in Article 109 of the European Electronic Communications Code (EECC), is crucial for public and individual safety. An example of a new requirement in the EECC made possible by advances in technology is advanced handset location through GNSS and Wi-Fi location, which can halve emergency response times. Article 110 EECC, which implements advancements in handset based public warning into Member States public warning systems, also ensures that people in the EU can receive public warnings on their mobile phones and take measures to protect themselves during natural and man-made disasters. Both of these new technologies are necessary for the protection of the right to life, codified in Article 2 of the Charter of Fundamental Rights, as well as the right to protection of property in Article 17 Charter.
Implementing technological advancements which improve public safety is therefore critical to ensuring that EU citizens and their rights are put at the centre of the digital transformation. However, despite these rights being codified in the EECC, the European Commission has not taken sufficient action to address the non-implementation of Article 109 EECC by several Member States. This lack of enforcement directly endangers the lives and property of EU citizens.
EENA therefore calls on the European Commission to strengthen enforcement mechanisms to ensure the full implementation of EU laws, guaranteeing that advancements in modern technology effectively benefit the rights of EU citizens.
Article 2: Solidarity and inclusion
Article 2(1)(b) of the Declaration, which focuses on solidarity and inclusion, calls on the European Commission and the European Parliament to ensure that new digital solutions foster inclusion and benefit all groups, including individuals with disabilities. In this regard, EENA welcomes the provisions of the EECC and the European Accessibility Act, which mandate the inclusion of native total conversation capabilities in handsets by 2026.
However, EENA is concerned about the insufficient attention this issue currently receives within EU policy discussions. This raises the risk that the 2026 deadline may not be met consistently across Member States, mirroring the challenges faced with the implementation of other emergency communications obligations under EU legislation. To address this, EENA urges the European Parliament and the European Commission to intensify efforts to ensure that Member States and handset providers fulfill these obligations by December 2026.