Stellungnahme zu 4129/A (278337/SN)

Inhalt

Thank you for the opportunity to submit comments on the draft law that addresses Austria's transposition and implementation of the NIS-2 Directive.

Please find attached a paper that concerns Article 28 of the NIS-2 Directive and the domain name system. Rigorous implementation of Article 28 is essential to achieving the goal of increasing cybersecurity and fighting cybercrime in Austria and across the European Union.

The attached paper has the support and endorsement of the EU Cybercrime Task Force (EUCTF), composed of Heads of national cybercrime units from various Member States as well as representatives of Europol and the Commission. The paper also has the support of seventeen other organisations devoted to cybersecurity, child safety, patient and medicine safety, anti-counterfeiting and consumer protection, and IP rights protection, including Aktionskreis gegen Produkt--und Markenpiraterie (APM). Also included is the Cybersecurity Tech Accord (CTA). The CTA includes over 150 leading cybersecurity and technology companies as signatories (See: https://cybertechaccord.org/signatories/). The CTA recently published a blog post about these points and suggested legislative language for Member State implementation of Article 28 of the NIS-2 Directive, which may be found at this link: https://cybertechaccord.org/eus-network-and-information-system-directive-nis-2-can-restore-access-to-critical-whois-data/

Below is a complete list of the eighteen organisations that support and endorse the positions and suggested legislative language in the attached paper. Please note that the paper addresses national implementation of Article 28 and suggested legislative provisions in general for all Member States.

ABAC/BAAN Belgian Anticounterfeiting Association https://www.abac-baan.com/

AIM European Brands Association https://www.aim.be/

ANDEMA Spanish Anti-Counterfeiting Group https://www.andema.org/en/sobre-andema/sobre-nosotros

APM German Anticounterfeiting Association https://apm.net/

APWG Anti-Phishing Working Group https://apwg.org/

ASOP EU Alliance for Safe Online Pharmacy in the EU https://buysaferx.pharmacy/eu/

CHIS Children's Charities' Coalition on Internet Safety https://www.ecpat.org.uk/childrens-charities-coalition-on-internet-safety-digital-manifesto

COMITE COLBERT The Voice of French Luxury https://www.comitecolbert.com/

COA Coalition for Online Accountability http://www.onlineaccountability.net/

CTA Cybersecurity Tech Accord https://cybertechaccord.org/

ECPAT INTERNATIONAL Ending Sexual Exploitation of Children https://ecpat.org/

EUCTF European Union Cybercrime Task Force https://www.europol.europa.eu/about-europol/european-cybercrime-centre-ec3/euctf

REACT The Anticounterfeiting Network https://www.react.org/

RETTIGHEDS ALLIANCEN Danish Rights Alliance https://rettighedsalliancen.com/

RATTIGHETS ALLIANSEN Swedish Rights Alliance http://www.rattighetsalliansen.com/en/

SPAMHAUS The Spamhaus Project https://www.spamhaus.org/

TRACIT Transnational Alliance to Combat Illicit Trade https://www.tracit.org/

UNIFAB French Association to Promote and Protect Intellectual Property https://www.unifab.com/

Please accept my apologies for the fact that this submission and attached paper are in English.

Thank you for your consideration of the attached paper.

Sincerely,

Dean S. Marks
Emeritus Executive Director & Legal Counsel
Coalition for Online Accountability ("COA")
E-mail: ed4coa@gmail.com
Cell: +1-818-469-7185