Preliminary assessment of the fourth payment request of Romania

and the Special Telecommunication Services (STS) with the conclusions of the verification team for investment 14 of Digital component.

3. Analysis:

The justification and substantiating evidence provided by the Romanian authorities cover all constitutive elements of the target.

Hubs that shall allow access to Internet Service Provider (ISP) services for public interest institutions and entities.

Article 1 of the Financing Contract No. 760002 of 19 October 2022) for increasing the resilience and cybersecurity of the ISP infrastructure provided for the Romanian public authorities signed with Special Telecommunication Service (STS) (hereinafter referred to as “the Financing Contract”) (Evidence No. 4) stipulates that the contractor will ensure that hubs provide access to ISP services for public interest institutions and entities at central and local level. Furthermore, Report No. 1 of 6 December 2025 on the entry into operation (Evidence No. 3) of hardware and software procured under the Investment 14 (hereinafter referred to as “Report No. 1 on the entry into operation”) details the hardware and software equipment provided for each hub. On-site Inspection Report No. 183613 of 8 December 2025 (Evidence No. 5) (hereinafter referred to as “On-site Inspection Report”) confirms that the verification team from the Ministry of Economy, Digitalisation, Entrepreneurship and Tourism (MEDAT) had performed on-site checks certifying that all hardware and software were functioning and the project was completed by 28 December 2024 as per the Financing Contract

(Evidence No. 4), including that hubs have access to ISP services for public interest institutions and entities.

Every county in Romania shall have a hub.

According to Law No. 290 of 29 November 2018, published in the Official Journal No. 1052 of 12 December 2018, Romania is administratively organized at county level, comprising 41 counties and the Municipality of Bucharest. Article 1 of the Financing Contract (Evidence No. 4) sets the target of 41 hubs to be delivered by the contractor. Report No. 1 of 6 December 2025 on the entry into operation (Evidence No. 3) confirms that equipment and technologies for the respective hubs are located in multiple locations within the 40 counties of Romania and several locations in Bucharest. According to Annex of Law No. 290 of 29 November 2018, published in the Official Journal No. 1052 of 12 December 2018, the headquarters of the Ilfov County are in the Municipality of Bucharest. Therefore, the Special Telecommunication Services (STS) locations serving the Ilfov county are located in the Municipality of Bucharest. This arrangement does not alter the scope, functionality, or coverage of the investment, nor does it reduce accessibility or capacity as every county in Romania is covered by a hub.

Each of these hubs shall be connected to a national Internet distribution network, with multiple Tier I suppliers and associated Security mechanisms. Security services which shall be provided:

• - Anti-dos (denial-of-service) protection at multiples of 10Gbps
• - Associated Computer Emergency Response Team (CERT) services (security audiences, monitoring

of security events throughout the network, response to security incidents)

• - Associated Security Operations Centres services (notification and escalation mechanisms for

beneficiaries)

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