From Draghi to DNA: The Alignment Scorecard

Overview

The publication of the European Commission’s proposed Digital Networks Act (DNA) marks the first comprehensive legislative response to Mario Draghi’s diagnosis of Europe’s competitiveness challenges in the telecom and connectivity sector.

This report provides a strict legal-text alignment assessment of the DNA against the 20 telecom-related recommendations identified in Draghi’s report on European competitiveness.

Rather than offering political commentary or economic forecasting, the scorecard asks a precise and verifiable question:

To what extent does the operative legal text of the DNA align with the substance of Draghi’s telecom agenda?

The assessment is based exclusively on binding articles, annexes, and procedures in the Commission proposal. Recitals are used only for interpretative support. No weighting or policy impact judgement is applied.

Headline Results

Out of the 20 Draghi telecom recommendations:

• 🟢 9 are aligned with binding provisions in the DNA

• 🟠 7 are partially aligned, reflected in law but through procedurally limited, voluntary, or incomplete mechanisms

• 🔴 4 are not aligned, with no meaningful binding provision in the proposal

The findings reveal a selective pattern of delivery.

The DNA internalises key elements of Draghi’s agenda in areas where EU-level competence is already well established — notably spectrum governance, network deployment, cybersecurity coordination, consumer protection, and single market enforcement.

However, structural reforms relating to merger control, regulatory philosophy, and EU-level investment instruments remain outside the scope of the proposal.

What This Scorecard Enables

This Alignment Scorecard establishes a clear legal baseline at the moment of Commission proposal.

It enables:

• A stable reference point for parliamentary amendments and Council negotiations

• A structured way to distinguish between drafting gaps and structural political limits

• A foundation for monitoring how alignment evolves during co-decision and implementation

Importantly, the scorecard does not assume that alignment with Draghi is either necessary or sufficient for effective policy. Its value lies in clarifying where strategic intent has been operationalised in binding law — and where it has not.

About the Draghi Observatory & Implementation Index

This publication forms part of EPIC’s Draghi Observatory & Implementation Index, launched in September 2025.

The Observatory tracks the operationalisation of the Report on the Future of European Competitiveness, mapping reforms, legislative proposals, and implementation gaps across sectors. It has rapidly become a reference framework for evaluating the EU’s competitiveness agenda.