Article 110, European Electronic Communications Code

Maximising functionality and operational benefits


What the legislation requires to implement Reverse 112

Article 110, European Electronic Communications Code

110(1)  "By 42 months after entry into force (June 2022), Member States shall ensure that, when public warning systems regarding imminent or developing major emergencies and disasters are in place, public warnings are transmitted by providers of mobile number-based interpersonal communication services to the end-users concerned."


110(2)  "Notwithstanding paragraph 1, Member States may determine that public warnings be transmitted through publicly available electronic communications services other than those referred to in paragraph 1, and other than broadcasting services, or through a mobile application relying on an internet access service, provided that the effectiveness of the public warning system is equivalent in terms of coverage and capacity to reach end-users including those only temporarily present in the area concerned, taking utmost account of BEREC guidelines.  Public warnings shall be receivable by end-users in an easy manner."

BEREC (Body of European Regulators of Electronic Communications) will publish its guidelines, within 18 months (by June 2020) on how to assess that the effectiveness of public warning systems under paragraph 2 is equivalent to those under paragraph 1.

Recital 260aa  "End-users concerned should be deemed to be those end-users who are located in the geographic areas potentially being affected by imminent or developing major emergencies and disasters during the warning period, as determined by the competent authorities." 

Recital 293 makes a critical point that affects national requirements.  This is that public warnings should be transmitted to "all end-users concerned".  That should be interpreted to mean everyone with a mobile phone within coverage of the warning area regardless of his/her choice of device and network service provider. That could exclude any PWS technology platform that is not compatible with every mobile phone available worldwide today.

Recital 293. "Diverging national law has developed in relation to the transmission by electronic communications services of public warnings regarding imminent or developing major emergencies and disasters. In order to approximate law in that area, this Directive should therefore provide that, when public warning systems are in place, public warnings should be transmitted by providers of mobile number-based interpersonal communication services to all end-users concerned. The end-users concerned should be considered to be those who are located in the geographic areas potentially being affected by imminent or developing major emergencies and disasters during the warning period, as determined by the competent authorities."

Key points

Paragraphs 1 and 2:

(i)   Mandatory implementation of a public warning system by June 2022, which

(ii)  Shall alert all citizens and visitors alike, regardless of whether he/she is a resident or only temporarily within the area affected.

Paragraph 1 only:

(i)  Transmission of the alerts shall be done via the public telephone networks, and  

(ii)  Received on the mobile telephone of choice carried by each citizen and visitor.

Paragraph 2 only:

(i)   The alternative technology shall be as effective as that used in 1 in terms of coverage, capacity, public access and reach to every citizen and visitor alike, and

(ii)  utilise a publicly available electronic communications technology, which does not include TV and radio broadcasts or a smartphone application. 

Technologies available today

Paragraph 1

(i)  Location-based SMS (fully compliant with Article 110(1) today), and/or

(ii) Cell Broadcast (not yet fully compliant today, due to some handset and network limitations that can reduce public access and reach to less than 40% of mobile phones manufactured worldwide).

Paragraph 2

A viable alternative to (i) and (ii) above that is accessible to and reaches everyone within the area affected.  

What we do best - simplifying complexity

Zefonar adds unrivalled value to your project, from design to deployment, through our subject matter expertise in:

  • Scoping: to maximise functionality and operational benefits 

  • Delivery: the most effective all hazards, all agencies capability

  • Risk reduction: avoiding problems and pitfalls that result in sub-optimal systems

  • Future-proofing: sustainability and matching increasing public expectations and demands 

  • Reducing costs: collaboration to accelerate design through to delivery

  • Frameworks: enabling policy and legislation

  • Market engagement: negotiations between government and suppliers

  • Technology selection: evaluation and system assurance

  • Project implementation: working alongside the technology supplier

  • Operational readiness: operating procedures, manuals, training and exercising

  • Community education: media, marketing and communication, and 

  • Post-implementation evaluation: review and continuous improvement. 

We apply the design principles of sequencing projects to follow:

  1. "People" -  determining the community safety outcomes and operational/functional requirements to achieve them; 
  2. "Process" - transforming the user organisations' operational processes and procedures to optimise when and how to use the system, and 
  3. "Technology" - matching the best available, future-proofed technology that delivers the maximum against the operational and statutory requirements that can be delivered ahead of the June 2022 deadline.

We will also coordinate post-implementation user and community reviews to identify lessons for continuous improvement and the trajectory for technical evolution.  We will help you ensure the system is sustainable to meet both the enduring and emerging needs for public safety and future telecommunications capabilities.

Unrivalled Global Experience & Trusted Independent Advice

Government Strategy

We'll help you apply a global, lessons learned approach to optimise national capacity and capability to accelerate design through to implementation at reduced cost:

  • Rigorous project governance
  • Setting national strategy and the enabling, policy, procedural and legislative frameworks
  • Public-private funding options
  • Developing the Business Case
  • Hands-on project management, guidance and support   
  • National Risk and Threat Mapping
  • Stakeholder management - Emergency Services and Responder Agencies, Government and Communities
  • Inter-agency collaboration and coordination

Operational Readiness

We bring experienced leadership in the field of all hazards, all agencies operations:

  • Facilitating multi-agency workshops to capture operational requirements and use cases
  • Determining the overarching System Design Principles
  • Mapping the business transformation and process change 
  • Creating the authorisation and GDPR compliance controls to access, store and retrieve personal data 
  • Interfacing Wireless Emergency Alerting with other public warning systems 
  • Developing all-agency Standard Operating Procedures 
  • Integration with Control and Incident Room procedures 
  • Operational readiness and training 
  • Community education

Technical Fit

We'll help you decide which technology best serves your national requirements using evidence-based analysis that's independent from ICT suppliers:

  • Reviewing technology options and evaluating against operational requirements and community safety expectations
  • Avoiding risks and limitations
  • Whether to access personal data: benefits vs disbenefits
  • Ensuring inclusive public access and reach
  • Advising on supplier and government contract negotiations
  • Contract management and administration
  • Higher returns on investment through a single architecture delivering multiple capabilities 
  • Community-based trials and pre-launch user testing 
  • Systems administration and 24/7 assurance monitoring 
  • Post-implementation evaluation and continuous improvement

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