15 December 2025 - 04 January 2026

Digital Economy

According to the Court of Justice of the EU (CJEU), the operator of an online marketplace will have a proactive duty to identify, verify and potentially refuse publication of an advertisement generated by a user of the platform which contains sensitive personal data. The advertisement should not be published if the sensitive data was unlawfully processed. The court also confirmed that the operator of the platform, as a data controller for personal data processed on its platform, may not absolve itself of its obligations under the GDPR by invoking the intermediary liability provisions set out in the e-Commerce Directive, now moved to the Digital Services Act.

     

Sustainability

EU legislators agreed on a binding intermediate target to reduce greenhouse gas emissions by 90% by 2040, compared with 1990 levels. The agreement included: "flexibility" for up to five percentage points of the target to be achieved from 2036 through international carbon credits; a review every two years of the progress made towards the climate targets; and the postponement of the application of the EU's emission trading system for buildings and road transport (ETS2) from 2027 to 2028.

     

Spectrum

The Panamanian regulator ASEP identified an additional 490 MHz for IMT use in the updated national frequency plan. ASEP also incorporated non-terrestrial networks into the IMT specification, enabling direct-to-device (D2D) communication as a service within the mobile concession contract.

     

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Media

Cullen International's special report explores how EU regulation and competition law affect different parts of the video gaming value chain. Alongside content-related issues, it looks at distribution via app stores, the role of cloud gaming and mobile networks, and environmental issues linked to gaming equipment.

Telecoms & Digital Economy

BEREC, the assembly of European national regulatory authorities, organised a public workshop following its report on submarine cable connectivity in Europe, while the European Commission confirmed the timeline for delivering the submarine cable security toolbox.

Watch the recording of our
recent webinar on the same topic!

     

Postal

BIPT is running a public consultation to determine whether regulatory action is needed to ensure efficient, fair and non-discriminatory access to the rapidly expanding parcel locker infrastructure in Belgium.

     

Postal

PostNL does not have to pay a €2m fine for failing to meet its quality requirements for the overnight delivery of domestic letters in 2019. The Dutch Trade and Industry Appeals Tribunal issued a definitive ruling on 16 December 2025, annulling the fine imposed by regulator ACM.

     

Antitrust & Mergers

The Norwegian competition authority launched an in-depth phase II merger control investigation into Telenor's proposed acquisition of the Norwegian consumer business of GlobalConnect. The investigation will focus on the retail fixed broadband market, where the parties compete.

     

Global Trends

2025 brought impressive developments in the digital world, with impacts on digital policies and regulations globally. Discover the topics that were most read by Cullen International Global Trends subscribers in 2025.

     

Global Trends

Nigeria is seeking to establish a comprehensive legal and regulatory framework for digital transformation in the country. The National Digital Economy and e-Governance Bill 2025, which is in its final steps before enactment, aims to consolidate multiple digital policy areas into a single law.

     

Telecoms

This note explains why the European Union has no homologation procedures for radio equipment and which form of market surveillance it uses instead.

   
     
     
     

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