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EC: Recommendation on subsea cable resilience

Despite ambitions to secure critical communications infrastructure, the EC is likely to come up short in delivering against its proposals

EC considers subsea cables in context of rising geopolitical tensions

On 21 February 2024, the EC released its Recommendation on Secure and Resilient Submarine Cable Infrastructures, detailing its approach to improving the resilience of strategic underwater infrastructure. Written in the context of suspected sabotage of cables in the Baltic Sea in 2023 and the heightened attention on security of the EU since the start of the war in Ukraine, the EC recommends up to “defence-level” standards of protection for the underwater lines that carry approximately 97% of data traffic globally. While state involvement in cable deployment and maintenance has ebbed and flowed historically, the EC’s call for EU Member States to become more active participants in the construction and security of the network would compete with the increasing proportion of cables completely or majority owned by big tech. The Recommendation also notes that the resilience of networks of smaller island Member States (including Ireland, which is a globally important technology hub) is dependent on the security of the subsea infrastructure connecting them to the European mainland. The EC plans to form an Expert Group to oversee activities set out in the recommendation, including to inform national and supranational mapping of existing cable infrastructure, and to identify “Cable Projects of European Interests” (CPEI).

Limited funding for state-backed cable projects

The EC suggests that additional public funding for CPEIs would be able to achieve some degree of improved resilience for the EU’s connectivity infrastructure as a whole. The combination of state aid with private investment in cable infrastructure would mirror the currently popular investor coalition model to finance new cable routes. Routes would qualify for CPEI status if they establish new or alternative secure routes – expanding a map that originated in colonial times – or if they can improve the capacity or resilience of existing cable infrastructure. Redundancy along strategic routes as well as increasing capacity along existing routes to accommodate exponential increases in data traffic have long been regular points of conversation among private investors of subsea infrastructure. However, the comparatively small amount of funding to be made available for CPEI routes is likely to have a limited impact in a market dominated by US and Chinese firms.

No funding or material support for recommendations on high-risk vendors

In both the mapping of the existing cable infrastructure and the identification of new CPEIs, Member States are also encouraged to assess the reliance projects and routes have on ‘high-risk suppliers’ through a Cable Security Toolbox. While some of the largest cable vendors include France’s Alcatel and the US’s SubCom, Huawei’s subsidiary HMN Tech continues to capture a growing share of the subsea hardware market. Not unlike vendor restrictions imposed on operators’ rollout of 5G networks, the EC has offered no central funding to mitigate the costs of restricting the use of HMN Tech equipment. Instead, Member States will largely be in control of implementing any future vendor restrictions. While the EC Recommendation marks a coherent approach to a uniquely unregulated portion of the global communications landscape, a lack of funding and a limited mandate in security matters  suggest that it will have a minimal impact without further progress towards a joint EU governance system.