As national regulatory authorities take on new statutory duties across a range of policy areas, their staffing and budgets have diverged. We compare the resourcing and funding of various European NRAs, and consider their capacity to meet their new duties.
Market convergence and technological development have brought NRAs new duties related to the digital economy, including online safety and AI. Added public policy objectives, such as promoting sustainability and economic growth, have also expanded the roles of regulators within communications markets.
Unlike its peers in the EU, Ofcom in the UK is preparing to implement online safety laws without the benefit of a centralised government agency supporting its enforcement activities. As such, the regulator has seen a rapid increase in its resourcing, including a 270% increase in funding related to online harms and the addition of over 400 new employees.
A number of NRAs in the EU have been designated as Digital Service Coordinators under the Digital Services Act. However, these new duties have come with limited additional resourcing, as in the case of Germany, Italy and Spain, where budgets have only increased between 4-8% in the past five years, despite considerable costs of tooling up.
In the absence of DSC responsibilities, European regulators have also seen their agendas expand in existing communications markets. ComReg in Ireland and Arcep in France represent similarly growing portfolios but vastly divergent outlooks for resourcing, perhaps in part due to the differences in how these regulators are funded.
For regulators funded centrally – processes, budgets and staffing levels do not appear to have significantly changed relative to the additional responsibilities. There has been limited funding growth over the past five years for regulators such as the CNMC (4%) and Arcep (1%). The capacity of NRAs to deliver on the implementation and enforcement of their new duties will be central to the success of wider public policy objectives.
Market convergence and technological developments are redefining the roles of sectoral regulators
As technological change continues to restructure telecoms markets and redefine how end users communicate, the work of national regulatory authorities (NRAs) has predictably changed too. Just as network operators are responding to the forces of market convergence, regulators have been increasingly assigned duties related to issues in emerging technology and the digital economy. With the implementation of new regulatory frameworks, such as the Online Safety Act in the UK and the Digital Markets Act (DMA) and Digital Services Act (DSA) in the EU, sectoral regulators have taken on the task of implementing and enforcing policies across a growing range of new technology markets. Similarly, regulators’ existing portfolios in communications markets have expanded to accommodate new public policy objectives, such as promoting sustainability and supporting economic growth.
While the landscape of responsibilities for sectoral regulators is not equal across Europe, regulators are taking on these duties with vastly different levels of additional support in terms of staffing and budgets. In the context of the new and varied roles adopted by NRAs, we compare trends in the funding and resourcing of regulators in recent years across six European countries (France, Germany, Ireland, Italy, Spain, UK).
In the UK, Ofcom has grown significantly in size to meet its new remit in online safety
There is perhaps no better example of the significant growth of NRAs in response to new regulatory duties than the recent changes experienced by Ofcom in the UK. Now 20 years into its tenure, the organisation has been tasked with the implementation and enforcement of the Online Safety Act, the UK’s flagship online safety law, which is often compared to the DSA in the EU. However, unlike its EU peers, Ofcom has no regulatory support from a central government agency, such as work the European Commission is undertaking in partnership with national regulators to enforce the DSA.
Figure 1
UK
Source: Assembly, Ofcom
Ofcom is funded through fees paid by stakeholders in the sectors it regulates. While those fees are not expected to be extended to stakeholders in the online safety portfolio until financial year 2026/2027, the regulator’s budget in preparation for the Online Safety Act has skyrocketed. Since Ofcom first budgeted for its online harms work in the 2021/2022 financial year, spending on that portion of its portfolio has grown over 270% from £19m to £71m for financial year 2024/2025. Over the same four-year period, the regulator added over 400 new employees, growing to a total headcount of nearly 1,400. Ofcom’s profile in communications and broadcasting has otherwise remained largely stable. Though some significant single-year shifts in revenue can be observed – such as a 28% increase in fees collected from the telecoms sector for the 2024/2025 financial year – longer term trends in funding reflect a much more level outlook.
Over the past five years, revenue related to telecoms, spectrum and broadcasting has not changed more than 10%, with the largest shift being an 8% reduction in fees collected from the telecoms sector. Given the rapid growth of Ofcom’s online safety resources as compared to those committed to its other duties, there have been questions about where the regulator’s traditional focus on communications and broadcasting markets now sits among its organisational priorities. In response, Ofcom has noted the importance of a unified regulator of networks and services and described its proactive work programme in telecoms in which stakeholders will see no reduction of effort.
Regulators in the EU with new online safety duties have also seen some growth in resourcing, though much less pronounced
In the EU, the DSA requires that Member States appoint a Digital Services Coordinator (DSC) to manage some of the implementation and enforcement work of the law. Of the competent authorities identified or appointed as DSCs to date, the vast majority (17 of 20) are telecoms NRAs. While many of these regulators had already begun work on topics related to the digital economy, such as net neutrality, their appointment as a DSC creates a range of new, labour-intensive duties, including creating administrative processes for certifying trusted flaggers of illegal content, accrediting researchers and responding to incoming constituent complaints and inquiries. Despite these new demands, some NRAs have seen limited increases in funding and staffing in recent years, both through revenue collected from regulated sectors and through centralised budget processes.
Figure 2
Spain
Source: Assembly, CNMC
As the DSC for Spain, the CNMC will add DSA-related duties to its existing portfolio work in competition policy, as well as in audiovisual and telecoms markets. Given its role as the national competition authority, the CNMC has also been an active participant in the rollout of the DMA, although its statutory duties under that law are comparatively limited. The CNMC’s budget has seen a small increase (4%) over the past five years, but given the breadth of the regulator’s remit in other network industries, including transportation and energy, the agency’s resourcing appears more limited compared to other NRAs with similar responsibilities.
Figure 3
Germany
Source: Assembly, BNetzA
Similar to the CNMC, BNetzA in Germany is responsible for the regulation of communications markets, as well as other network industries, including energy and transportation. In addition to its DSC designation, BNetzA has been active in other supranational legislative efforts in the digital space, including monitoring the progress of artificial intelligence (AI) regulation at the EU level. Though the regulator saw a one-year decline in its 2024 budget, like the CNMC, BNetzA has also benefited from a small increase (8%) in its budget over the past five years. As the largest European regulator we’ve considered, BNetzA’s approximately 3,000-person staff sets the agency apart from its international peers and suggests it may benefit from greater existing operational resources that could ease the strain of incorporating new responsibilities into its remit, especially in the context of administrative processes. However, it’s difficult to determine how many of these staff members are assigned to telecoms or digital services portfolios and therefore the extent to which BNetzA’s leading staff per capita ratio supports its work on communications markets.
Figure 4
Italy
Source: Assembly, AGCOM
Unlike the CNMC and BNetzA, Italy’s AGCOM is responsible solely for communications regulation and, like Ofcom, is funded by levies collected from stakeholders in regulated sectors, including telecoms. From the 2021/2022 financial year through the 2023/2024 financial year, AGCOM collected fees from online platforms to cover the administrative costs of its work programmes in the sector, including its work on copyright enforcement and the regulation of audiovisual services. From 2021/2022 to AGCOM’s most recent statements for the 2023/2024 financial year, the revenue collected from online platforms increased 125% to over €9m (£7.7m), charting a familiar ramping up in resourcing in advance of added online safety duties with its designation as a DSC. However, following a ruling issued by the European Court of Justice in January 2024, AGCOM has been barred from collecting these administrative fees from any platform services without a headquarters in Italy. As a result, AGCOM’s added resourcing is likely to disappear just as the full implementation of the DSA gets underway.
Despite gaining similar additional responsibilities, not all NRAs have seen increases in their funding
Among the NRAs which were not designated as DSCs, a range of new statutory duties have still broadened their responsibilities. In addition to coordinating the regulation of the digital economy with other regulators in their jurisdictions, European NRAs have led globally in advancing sustainability in communications markets both through regulatory action, as well as monitoring and reporting on markets. Two of the regulators who have seen such areas of growth in their existing communications portfolios, ComReg in Ireland and Arcep in France, represent distinctly different outlooks in resourcing.
Figure 5
Ireland
Source: Assembly, ComReg
In Ireland, ComReg works in tandem with the newly formed Coimisiún na Meán to regulate communications and media markets, respectively. Similar to Ofcom, ComReg is funded through levies paid by stakeholders in regulated industries, as well as via income related to spectrum licensing. These levies have been relatively stable over the past five years, with telecoms stakeholders seeing no change in the fees paid between the 2019/2020 financial year and the 2023/2024 financial year. During this period, however, the regulator utilised more of this income to support its regulatory activities, resulting in an overall budget increase. ComReg did still pay €12m (£10m) in surplus income to the Irish Government for the 2023/2024 financial year. Compared to the regulator’s 2018/2019 financial statements, this budget increase covered increased staff costs in telecoms and spectrum, which is reflected in a 22% increase in total employees across the same period.
Figure 6
France
Source: Assembly, Arcep
Both the revenue Arcep has collected on behalf of the French Government and the budget it has been allocated provide a stark contrast. Funded through a central appropriations process, Arcep’s budget is determined annually by the Government. Despite similarities with ComReg in its extended duties in sustainability and digital services, Arcep has seen only a 1% increase in its budget over the past five years, making it an outlier in budget per capita (£0.28) among its European peers we’ve considered (average budget per capita of £3.32). Like ComReg, Arcep also collects revenue on behalf of the French Government, including through the award of spectrum and enforcement activity. However, the regulator in France lacks control over its budgeting compared to say ComReg since its funding is determined entirely by the broader Government’s budget. Despite a significant increase in the revenue it has raised in the past five years, Arcep has not received additional funding to deliver on its new and expanding obligations.
Without adequate resourcing, regulators could be ill-equipped to deliver on wider public policy objectives
Given these variations in how European regulators are funded and the annual level of resourcing these agencies can expect, a number of questions can be raised about how prepared regulators are to take on new duties in both traditional telecoms portfolios and broader digital economy work. Especially among regulators which are funded through central budgeting processes, levels of funding and staffing do not appear to have been responsive to the growth in remits seen in recent years. Instead, regulators funded through centralised appropriations are more directly subject to the broader aims regarding government spending without consideration for sectoral specific trends. Especially in the context of new duties related to the digital economy, the capacity of regulators to implement and enforce new laws as well as act on new duties will serve as an important indicator of success for the wider policy making process.
As NRAs are increasingly responsible for implementing and enforcing laws related to the digital economy, such as online safety regulation, they will be working alongside the considerable financial resources of big tech, already well-known for their willingness to spend heavily in attempts to influence policymaking. Though a number of regulators have hired experts in a range of emerging technologies, NRAs are frequently cast as ill-equipped to engage with the technical elements of digital regulation. The addition of labour-intensive tasks, including collecting and managing sectoral sustainability data or vetting trusted flaggers of illegal online content, will further stretch staff capacity, which is already limited in some instances. Unlike the better established credibility these NRAs will carry into upcoming telecoms activities, including the UK’s Telecoms Access Review or the EU’s Digital Networks Act, the effective and timely implementation of ambitious of digital laws such as the DSA and Online Safety Act will be central to developing the credibility of these regulators in their new duties and ultimately achieving wider public policy objectives.
