Moderating Content Can’t Be a Blunt Instrument

^{Region: Europe
Threat type: Regulation of DNS Infrastructure
Last updated: 1 December 2023}

A new EU-based DNS resolver could become a content moderation tool, if it’s made mandatory.

DNS4EU is a proposed EU-funded project that seeks to increase protections against cybersecurity threats and increase Internet reliability for users. There isn’t any new regulation, but instead the EU has pledged funds for the creation of new Internet infrastructure.

A DNS resolver converts domain names into IP addresses. It works like a digital phone operator for the Internet that looks up IP addresses in the DNS, so that you can efficiently access the websites and content you are looking for. If there is an outage or attack, the traffic can be rerouted, making the system resilient.

The EU hopes that the creation of this new resolver will ensure that DNS resolution data and related meta-data is processed within the EU, better safeguarding data and privacy for EU Internet users. The creation of the new resolver also seeks to provide a more resilient, secure, and diversified DNS resolution offering by creating redundancies with the existing global system.

Policymakers have emphasized the voluntary nature of DNS4EU and that there will be no requirement for Europeans to use it. However, if the use of the resolver were to be made mandatory this would present a significant threat of fragmentation. European Internet users would risk facing a filtered version of the DNS, and the Internet-according-to-DNS4EU.

A single common global identifier is a key feature of an unfragmented network. If users are restricted to only being allowed to use DNS4EU there is a risk that such a resolver would become a point of control, determining what parts of the Internet are accessible for European users. It also risks becoming a single point of failure if alternatives are not allowed. There is also a concern that EU member states and other actors could abuse DNS4EU to monitor the behavior of Internet users or filter content violating fundamental rights.

As long as DNS4EU is deployed on a voluntary basis, many of these concerns can easily be avoided.

Status

A consortium of 9 members and 4 associated partners has been formed with the goal of organizing a stakeholder group of industry, technical, and policy experts to contribute to the development of DNS4EU by working with European and national authorities, such as telecom regulatory authorities. A Czech company called Whalebone.io is currently building the DNS4EU resolver. Full deployment is scheduled for 2025.

Our Position

As long as the use of DNS4EU remains voluntary, this does not pose a great risk of fragmentation. The creation of redundancies in the DNS infrastructure is not a negative development.

However, content filtering is concerning and safeguards should be developed to prevent abuse. Content moderation should be conducted at the platform level, not at the infrastructure level.

In either case, the trend of applying geographic borders to global infrastructure is concerning as this normalizes the approach and could inspire other actors around the world to introduce their own DNS resolvers, which may be mandatory to use. Other countries including Mauritius and Kazakhstan have previously attempted to impose the mandatory use of national DNS resolvers, with the capability of indiscriminate filtering. Efforts such as these would fragment the DNS system, creating barriers to interconnectivity for Internet users around the world.

Talking Points

It is important that the use of DNS4EU is voluntary. If so it can help improve a more resilient and diverse ecosystem, but if mandatory it creates risks of Internet fragmentation.
There is a risk of EU member states using DNS4EU to filter content and do it at the infrastructure level. It is important that DNS4EU include safeguards to prevent this. Content moderation, if indispensable, should happen at the platform level.
The concept of a regional DNS resolver is dangerous. Europe’s approach may inspire other actors around the world to create their own national or regional resolvers, the use of which may be mandatory. This would fragment the Internet and create barriers to interconnection.

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