Dutch internet providers now have ACM guidance on websites linked to EU-sanctioned Russian media. ACM has also published a practical list. Providers still decide whether and how to restrict access.
Why this matters
For a listed website, ACM says it will not enforce against a provider for a net-neutrality breach caused by blocking it. The list is not a blocking order or a complete sanctions database. New domains and mirror sites still need assessment. Someone must log updates, approve action, answer customers and retain the decision record. The guidance covers internet access providers. Hosting firms, cloud suppliers and platforms must check their role and contracts.
Example
A regional provider receives a report about a possible mirror site. Its domain resembles one on ACM’s list, but the site contains other material. The legal and network owners check the domain, legal ground and scope before restricting access. They record the approval and technical change. Customer support receives an approved explanation, and the file gets a review date. That record supports a response to a complaint or later correction.
XTROVERSO tips
- Name one owner. Give one person authority over intake, assessment and escalation. A shared mailbox or supplier feed is not enough.
- Map the decision route. Write down how a report moves from legal review to approval, implementation, testing and review.
- Separate three types of report. Distinguish a listed website, a possible mirror site and an unverified complaint. Do not process them as identical cases.
- Keep a short decision file. Record the source, legal ground, decision-maker, scope, implementation date and next review date.
- Prepare customer support. Give staff an approved explanation and a clear escalation contact. Support teams should not improvise legal answers.
- Budget for the full control. Include monitoring, legal review, engineering time, testing and dispute handling in normal network costs.
Need help setting up the owner, decision file and review route for your digital service?
The data, sourcing, and analysis behind this article were conducted by Paolo Maria Pavan. AI was not used to identify sources, build the factual basis, or produce the analytical judgment contained here. AI was used only as a drafting aid. The final English text was personally reviewed, edited, and approved by Paolo Maria Pavan before publication.
References
- ACM publiceert leidraad gesanctioneerde websites | ACM
- ACM — Leidraad praktische lijst met websites van gesanctioneerde media-entiteiten
- ACM — Jaarverslag netneutraliteit 2026
- Rijksoverheid — EU neemt 21ste sanctiepakket aan tegen Rusland
- Rijksoverheid — Contact met telecomsector over sancties tegen Rusland
- ACM — Leidraad praktische lijst, PDF
