If Greenland were digitally disconnected tomorrow, how much of its public sector could still operate?

If Greenland were digitally cut off tomorrow, how much of its public sector would still function? The uncomfortable answer: very little. The truth is that not only would the public sector break down, but society as a whole would likely also break down the longer a digital isolation would be in effect. This article outlines why it does not necessarily have to be this way and suggests that some remedies and actions can be taken to minimize the impact of an event where Greenland would be digitally isolated from the rest of the internet for an extended period (e.g., weeks to months).

We may like, or feel tempted, to think of digital infrastructure as neutral plumbing. But as I wrote earlier, “digital infrastructure is no longer just about connectivity, but about sovereignty and resilience.” Greenland today has neither.

A recent Sermitsiaq article on Greenland’s “Digital Afhængighed af Udlandet” by Poul Krarup, which describes research work done by the Tænketanken Digital Infrastruktur, laid it bare and crystal clear: the backbone of Greenland’s administration, email, payments, and even municipal services, runs on servers and platforms that are located mainly outside Greenland (and Denmark). Global giants in Europe and the US hold the keys. Greenland doesn’t. My own research reveals just how dramatic this dependency is. The numbers from my own study of 315 Greenlandic public-sector domains make it painfully clear: over 70% of web/IP hosting is concentrated among just three foreign providers, including Microsoft, Google, and Cloudflare. For email exchanges (MX), it’s even worse: the majority of MX records sit entirely outside Greenland’s control.

So imagine the cable is cut, the satellite links fail, or access to those platforms is revoked. Schools, hospitals, courts, and municipalities. How many could still function? How many could even switch on a computer?

This isn’t a thought experiment. It’s a wake-up call.

In my earlier work on Greenland’s critical communications infrastructure, “Greenland: Navigating Security and Critical Infrastructure in the Arctic – A Technology Introduction”, I have pointed out both the resilience and the fragility of what exists today. Tusass has built and maintained a transport network that keeps the country connected under some of the harshest Arctic conditions. That achievement is remarkable, but it is also costly and economically challenging without external subsidies and long-term public investment. With a population of just 57,000 people, Greenland faces challenges in sustaining this infrastructure on market terms alone.

DIGITAL SOVEREIGNTY.

What do we mean when we use phrases like “the digital sovereignty of Greenland is at stake”? Let’s break down the complex language (for techies like myself). Sovereignty in the classical sense is about control over land, people, and institutions. Digital sovereignty extends this to the virtual space. It is primarily about controlling data, infrastructure, and digital services. As societies digitalize, critical aspects of sovereignty move into the digital sphere, such as,

  • Infrastructure as territory: Submarine cables, satellites, data centers, and cloud platforms are the digital equivalents of ports, roads, and airports. If you don’t own or control them, you depend on others to move your “digital goods.”
  • Data as a resource: Just as natural resources are vital to economic sovereignty, data has become the strategic resource of the digital age. Those who store, process, and govern data hold significant power over decision-making and value creation.
  • Platforms as institutions: Social media, SaaS, and search engines act like global “public squares” and administrative tools. If controlled abroad, they may undermine local political, cultural, or economic authority.

The excellent book by Anu Bradford, “Digital Empires: The Global Battle to Regulate Technology,” describes how the digital world is no longer a neutral, borderless space but is increasingly shaped by the competing influence of three distinct “empires.” The American model is built around the dominance of private platforms, such as Google, Amazon, and Meta, where innovation and market power drive the agenda. The scale and ubiquity of Silicon Valley firms have enabled them to achieve a global reach. In contrast, the Chinese model fuses technological development with state control. Here, digital platforms are integrated into the political system, used not only for economic growth but also for surveillance, censorship, and the consolidation of authority. Between these two poles lies the European model, which has little homegrown platform power but exerts influence through regulation. By setting strict rules on privacy, competition, and online content, Europe has managed to project its legal standards globally, a phenomenon Bradford refers to as the “Brussels effect” (which is used here in a positive sense). Bradford’s analysis highlights the core dilemma for Greenland. Digital sovereignty cannot be achieved in isolation. Instead, it requires navigating between these global forces while ensuring that Greenland retains the capacity to keep its critical systems functioning, its data governed under its own laws, and its society connected even when global infrastructures falter. The question is not which empire to join, but how to engage with them in a way that strengthens Greenland’s ability to determine its own digital future.

In practice, this means that Greenland’s strategy cannot be about copying one of the three empires, but rather about carving out a space of resilience within their shadow. Building a national Internet Exchange Point ensures that local traffic continues to circulate on the island rather than being routed abroad, even when external links fail. Establishing a sovereign GovCloud provides government, healthcare, and emergency services with a secure foundation that is not dependent on distant data centers or foreign jurisdictions. Local caching of software updates, video libraries, and news platforms enables communities to operate in a “local mode” during disruptions, preserving continuity even when global connections are disrupted. These measures do not create independence from the digital empires. Still, they give Greenland the ability to negotiate with them from a position of greater strength, ensuring that participation in the global digital order does not come at the expense of local control or security.

FROM DAILY RESILIENCE TO STRATEGIC FRAGILITY.

I have argued that integrity, robustness, and availability must be the guiding principles for Greenland’s digital backbone, both now and in the future.

  • Integrity means protecting against foreign influence and cyber threats through stronger cybersecurity, AI support, and autonomous monitoring.
  • Robustness requires diversifying the backbone with new submarine cables, satellite systems, and dual-use assets that can serve both civil and defense needs.
  • Availability depends on automation and AI-driven monitoring, combined with autonomous platforms such as UAVs, UUVs, IoT sensors, and distributed acoustic sensing on submarine cables, to keep services running across vast and remote geographies with limited human resources.

The conclusion I drew in my previous work remains applicable today. Greenland must develop local expertise and autonomy so that critical communications are not left vulnerable to outside actors in times of crisis. Dual-use investments are not only about defense; they also bring better services, jobs, and innovation.

Source: Tusass Annual Report 2023 with some additions and minor edits.

The Figure above illustrates the infrastructure of the Greenlandic sole telecommunications provider, Tusass. Note that Tusass is the incumbent and only telecom provider in Greenland. Currently, five hydropower plants (shown above, location only indicative) provide more than 80% of Greenland’s electricity demand. Greenland is entering a period of significant infrastructure transformation, with several large projects already underway and others on the horizon. The most visible change is in aviation. Following the opening of the new international airport in Nuuk in 2024, with its 2,200-meter runway capable of receiving direct flights from Europe and North America, attention has turned to Ilulissat, on the Northwestern Coast of Greenland, and Qaqortoq. Ilulissat is being upgraded with its own 2,200-meter runway, a new terminal, and a control tower, while the old 845-meter strip is being converted into an access road. In southern Greenland, a new airport is being built in Qaqortoq, with a 1,500-meter runway scheduled to open around 2026. Once completed, these three airports, Nuuk, Ilulissat, and Qaqortoq, the largest town in South Greenland, will together handle roughly 80 percent of Greenland’s passenger traffic, reshaping both tourism and domestic connectivity. Smaller projects, such as the planned airport at Ittoqqortoormiit and changes to heliport infrastructure in East Greenland, are also part of this shift, although on a longer horizon.

Beyond air travel, the next decade is likely to bring new developments in maritime infrastructure. There is growing interest in constructing deep-water ports, both to support commercial shipping and to enable the export of minerals from Greenland’s interior. Denmark has already committed around DKK 1.6 billion (approximately USD 250 million) between 2026 and 2029 for a deep-sea port and related coastal infrastructure, with several proposals directly linked to mining ventures. In southern Greenland, for example, the Tanbreez multi-element rare earth project lies within reach of Qaqortoq, and the new airport’s specifications were chosen with freight requirements in mind. Other mineral prospects, ranging from rare earths to nickel and zinc, will require their own supporting infrastructure, roads, power, and port facilities, if the project transitions from exploration to production. The timelines for these mining and port projects are less certain than for the airports, since they depend on market conditions, environmental approvals, and financing. Yet it is clear that the 2025–2035 period will be decisive for Greenland’s economic and strategic trajectory. The combination of new airports, potential deep-water harbors, and the possible opening of significant mining operations would amount to the largest coordinated build-out of Greenlandic infrastructure in decades. Moreover, several submarine cable projects have been mentioned that would strengthen international connectivity to Greenland, as well as strengthen the redundancy and robustness of settlement connectivity, in addition to the existing long-haul microwave network connecting all settlements along the west coast from North to South.

And this is precisely why the question of a sudden digital cut-off matters so much. Without integrity, robustness, and availability built into the communications infrastructure, Greenland’s public sector and its critical infrastructure remain dangerously exposed. What looks resilient in daily operation could unravel overnight if the links to the outside world were severed or internal connectivity were compromised. In particular, the dependency on Nuuk is a critical risk.

GREENLAND’s DIGITAL INFRASTRUCTURE BY LAYER.

Let’s peel the digital onion layer by layer of Greenland’s digital infrastructure.

Is Greenland’s digital infrastructure broken down by the layers upon which society’s continuous functioning depends? This illustration shows how applications, transport, routing, and interconnect all depend on the external connectivity.

Greenland’s digital infrastructure can be understood as a stack of interdependent layers, each of which reveals a set of vulnerabilities. This is illustrated by the Figure above. At the top of the stack lie the applications and services that citizens, businesses, and government rely on every day. These include health IT systems, banking platforms, municipal services, and cloud-based applications. The critical issue is that most of these services are hosted abroad and have no local “island mode.” In practice, this means that if Greenland is digitally cut off, domestic apps and services will fail to function because there is no mechanism to run them independently within the country.

Beneath this sits the physical transport layer, which is the actual hardware that moves data. Greenland is connected internationally by just two subsea cables, routed via Iceland and Canada. A few settlements, such as Tasiilaq, remain entirely dependent on satellite links, while microwave radio chains connect long stretches of the west coast. At the local level, there is some fiber deployment, but it is limited to individual settlements rather than forming part of a national backbone. This creates a transport infrastructure that, while impressive given Greenland’s geography, is inherently fragile. Two cables and a scattering of satellites do not amount to genuine redundancy for a nation. The next layer is IP/TCP transport, where routing comes into play. Here, too, the system is basic. Greenland relies on a limited set of upstream providers with little true diversity or multi-homing. As a result, if one of the subsea cables is cut, large parts of the country’s connectivity collapse, because traffic cannot be seamlessly rerouted through alternative pathways. The resilience that is taken for granted in larger markets is largely absent here.

Finally, at the base of the stack, interconnect and routing expose the structural dependency most clearly. Greenland operates under a single Autonomous System Number (ASN). An ASN is a unique identifier assigned to a network operator (like Tusass) that controls its own routing on the Internet. It allows the network to exchange traffic and routing information with other networks using the Border Gateway Protocol (BGP). In Greenland, there is no domestic internet exchange point (IXP) or peering between local networks. All traffic must be routed abroad first, whether it is destined for Greenland or beyond. International transit flows through Iceland and Canada via the subsea cables, and via geostationary GreenSat satellite connectivity through Grand Canaria as a limited (in capacity) fallback that connected via the submarine network back to Greenland. There is no sovereign government cloud, almost no local caching for global platforms, and only a handful of small data centers (being generous with the definition here). The absence of scaled redundancy and local hosting means that virtually all of Greenland’s digital life depends on international connections.

GREENLAND’s DIGITAL LIFE ON A SINGLE THREAD.

Considering the many layers described above, a striking picture emerges: applications, transport, routing, and interconnect are all structured in ways that assume continuous external connectivity. What appears robust on a day-to-day basis can unravel quickly. A single cable cut, upstream outage, or local transmission fault in Greenland does not just slow down the internet. It can also disrupt it. It can paralyze everyday life across almost every sector, as much of the country’s digital backbone relies on external connectivity and fragile local transport. For the government, the reliance on cloud-hosted systems abroad means that email, document storage, case management, and health IT systems would go dark. Hospitals and clinics could lose access to patient records, lab results, and telemedicine services. Schools would be cut off from digital learning platforms and exam systems that are hosted internationally. Municipalities, which already lean on remote data centers for payroll, social services, and citizen portals, would struggle to process even routine administrative tasks. In finance, the impact would be immediate. Greenland’s card payment and clearing systems are routed abroad; without connectivity, credit and debit card transactions could no longer be authorized. ATMs would stop functioning. Shops, fuel stations, and essential suppliers would be forced into cash-only operations at best, and even that would depend on whether their local systems can operate in isolation. The private sector would be equally disrupted. Airlines, shipping companies, and logistics providers all rely on real-time reservation and cargo systems hosted outside Greenland. Tourism, one of the fastest-growing industries, is almost entirely dependent on digital bookings and payments. Mining operations under development would be unable to transmit critical data to foreign partners or markets. Even at the household level, the effects could be highly disruptive. Messaging apps, social media, and streaming platforms all require constant external connections; they would stop working instantly. Online banking and digital ID services would be unreachable, leaving people unable to pay bills, transfer money, or authenticate themselves for government services. As there are so few local caches or hosting facilities in Greenland, even “local” digital life evaporates once the cables are cut. So we will be back to reading books and paper magazines again.

This means that an outage can cascade well beyond the loss of entertainment or simple inconvenience. It undermines health care, government administration, financial stability, commerce, and basic communication. In practice, the disruption would touch every citizen and every institution almost immediately, with few alternatives in place to keep essential civil services running.

GREENLAND’s DIGITAL INFRASTRUCTURE EXPOSURE: ABOUT THE DATA.

In this inquiry, I have primarily analyzed two pillars of Greenland’s digital presence: web/IP hosting, as well as MX (mail exchange) hosting. These may sound technical, but they are fundamental to understanding. Web/IP hosting determines where Greenland’s websites and online services physically reside, whether inside Greenland’s own infrastructure or abroad in foreign data centers. MX hosting determines where email is routed and processed, and is crucial for the operation of government, business, and everyday communication. Together, these layers form the backbone of a country’s digital sovereignty.

What the data shows is sobering. For example, the Government’s own portal nanoq.gl is hosted locally by Tele Greenland (i.e., Tusass GL), but its email is routed through Amazon’s infrastructure abroad. The national airline, airgreenland.gl, also relies on Microsoft’s mail servers in the US and UK. These are not isolated cases. They illustrate the broader pattern of dependence. If hosting and mail flows are predominantly external, then Greenland’s resilience, control, and even lawful access are effectively in the hands of others.

The data from the Greenlandic .gl domain space paints a clear and rather bleak picture of dependency and reliance on the outside world. My inquiry covered 315 domains, resolving more than a thousand hosts and IPs and uncovering 548 mail exchangers, which together form a dependency network of 1,359 nodes and 2,237 edges. What emerges is not a story of local sovereignty but of heavy reliance on external, that is, outside Greenland, hosting.

When broken down, it becomes clear how much of the Greenlandic namespace is not even in use. Of the 315 domains, only 190 could be resolved to a functioning web or IP host, leaving 125 domains, or about 40 percent, with no active service. For mail exchange, the numbers are even more striking: only 98 domains have MX records, while 217 domains, it would appear, cannot be used for email, representing nearly seventy percent of the total. In other words, the universe of domains we can actually analyze shrinks considerably once you separate the inactive or unused domains from those that carry real digital services.

It is within this smaller, active subset that the pattern of dependency becomes obvious. The majority of the web/IP hosting we can analyze is located outside Greenland, primarily on infrastructure controlled by American companies such as Cloudflare, Microsoft, Google, and Amazon, or through Danish and European resellers. For email, the reliance is even more complete: virtually all MX hosting that exists is foreign, with only two domains fully hosted in Greenland. This means that both Greenland’s web presence and its email flows are overwhelmingly dependent on servers and policies beyond its own borders. The geographic spread of dependencies is extensive, spanning the US, UK, Ireland, Denmark, and the Netherlands, with some entries extending as far afield as China and Panama. This breadth raises uncomfortable questions about oversight, control, and the exposure of critical services to foreign jurisdictions.

Security practices add another layer of concern. Many domains lack the most basic forms of email protection. The Sender Policy Framework (SPF), which instructs mail servers on which IP addresses are authorized to send on behalf of a domain, is inconsistently applied. DomainKeys Identified Mail (DKIM), which uses cryptographic signatures to verify that an email originates from the claimed sender, is also patchy. Most concerning is that Domain-based Message Authentication, Reporting, and Conformance (DMARC), a policy that allows a domain to instruct receiving mail servers on how to handle suspicious emails (for example, reject or quarantine them), is either missing or set to “none” for many critical domains. Without SPF, DKIM, and DMARC properly configured, Greenlandic organizations are wide open to spoofing and phishing, including within government and municipal domains.

Taken together, the picture is clear. Greenland’s digital backbone is not in Greenland. Its critical web and mail infrastructure lives elsewhere, often in the hands of hyperscalers far beyond Nuuk’s control. The question practically asks itself: if those external links were cut tomorrow, how much of Greenland’s public sector could still function?

GREENLAND’s DIGITAL INFRASTRUCTURE EXPOSURE: SOME KEY DATA OUT OF A VERY RICH DATASET.

The Figure shows the distribution of Greenlandic (.gl) web/IP domains hosted on a given country’s infrastructure. Note that domains are frequently hosted in multiple countries. However, very few (2!) have an overlap with Greenland.

The chart of Greenland (.gl) Web/IP Infrastructure Hosting by Supporting Country reveals the true geography of Greenland’s digital presence. The data covers 315 Greenlandic domains, of which 190 could be resolved to active web or IP hosts. From these, I built a dependency map showing where in the world these domains are actually served.

The headline finding is stark: 57% of Greenlandic domains depend on infrastructure in the United States. This reflects the dominance of American companies such as Cloudflare, Microsoft, Google, and Amazon, whose services sit in front of or fully host Greenlandic websites. In contrast, only 26% of domains are hosted on infrastructure inside Greenland itself (primarily through Tele Greenland/Tusass). Denmark (19%), the UK (14%), and Ireland (13%) appear as the next layers of dependency, reflecting the role of regional resellers, like One.com/Simply, as well as Microsoft and Google’s European data centers. Germany, France, Canada, and a long tail of other countries contribute smaller shares.

It is worth noting that the validity of this analysis hinges on how the data are treated. Each domain is counted once per country where it has active infrastructure. This means a domain like nanoq.gl (the Greenland Government portal) is counted for both Greenland and its foreign dependency through Amazon’s mail services. However, double-counting with Greenland is extremely rare. Out of the 190 resolvable domains, 73 (38%) are exclusively Greenlandic, 114 (60%) are solely foreign, and only 2 (~1%) domains are hybrids, split between Greenland and another country. Those two are Nanoq.gl and airgreenland.gl, both of which combine a Greenland presence with foreign infrastructure. This is why the Figure above shows percentages that add up to more than 100%. They represent the dependency footprint. The share of Greenlandic domains that touch each country. They do not represent a pie chart of mutually exclusive categories. What is most important to note, however, is that the overlap with Greenland is vanishingly small. In practice, Greenlandic domains are either entirely local or entirely foreign. Very few straddle the boundary.

The conclusion is sobering. Greenland’s web presence is deeply externalized. With only a quarter of domains hosted locally, and more than half relying on US-controlled infrastructure, the country’s digital backbone is anchored outside its borders. This is not simply a matter of physical location. It is about sovereignty, resilience, and control. The dominance of US, Danish, and UK providers means that Greenland’s citizens, municipalities, and even government services are reliant on infrastructure they do not own and cannot fully control.

Figure shows the distribution of Greenlandic (.gl) domains by the supporting country for the MX (mail exchange) infrastructure. It shows that nearly all email services are routed through foreign providers.

The Figure above of the MX (mail exchange) infrastructure by supporting country reveals an even more pronounced pattern of external reliance than in the case of web hosting. From the 315 Greenlandic domains examined, only 98 domains had active MX records. These are the domains that can be analyzed for mail routing and were used in the analysis below.

Among them, 19% of all Greenlandic domains send their mail through US-controlled infrastructure, primarily Microsoft’s Outlook/Exchange services and Google’s Gmail. The United Kingdom (12%), Ireland (9%), and Denmark (8%) follow, reflecting the presence of Microsoft and Google’s European data centers and Danish resellers. France and Australia appear with smaller shares at 2%, and beyond that, the contributions of other countries are negligible. Greenland itself barely registers. Only two domains, accounting for 1% of the total, utilize MX infrastructure hosted within Greenland. The rest rely on servers beyond its borders. This result is consistent with our sovereignty breakdown: almost all Greenlandic email is foreign-hosted, with just two domains entirely local and one hybrid combining Greenlandic and foreign providers.

Again, the validity of this analysis rests on the same method as the web/IP chart. Each domain is counted once per country where its MX servers are located. Percentages do not add up to 100% because domains may span multiple countries; however, crucially, as with web hosting, double-counting with Greenland is vanishingly rare. In fact, virtually no Greenlandic domains combine local and foreign MX; they are either foreign-only or, in just two cases, local-only.

The story is clear and compelling: Greenland’s email infrastructure is overwhelmingly externalized. Where web hosting still accounts for a quarter of domains within the country, email sovereignty is almost nonexistent. Nearly all communication flows through servers controlled by US, UK, Ireland, or Denmark. The implication is sobering. In the event of disruption, policy disputes, or surveillance demands, Greenland has little autonomous control over its most basic digital communications.

A sector-level view of how Greenland’s web/IP domains are hosted, local vs externally (outside Greenland).

This chart provides a sector-level view of how Greenlandic domains are hosted, distinguishing between those resolved locally in Greenland and those hosted outside of Greenland. It is based on the subset of 190 domains for which sufficient web/IP hosting information was available. Importantly, the categorization relies on individual domains, not on companies as entities. A single company or institution may own and operate multiple domains, which are counted separately for the purpose of this analysis. There is also some uncertainty in sector assignment, as many domains have ambiguous names and were categorized using best-fit rules.

The distribution highlights the uneven exercise of digital sovereignty across sectors. In education and finance, the dependency is absolute: 100 percent of domains are hosted externally, with no Greenland-based presence at all. It should not come as a big surprise that ninety percent of government domains are hosted in Greenland, while only 10 percent are hosted outside. From a Digital Government sovereignty perspective, this would obviously be what should be expected. Transportation shows a split, with about two-thirds of domains hosted locally and one-third abroad, reflecting a mix of Tele Greenland-hosted (Tusass GL) domains alongside foreign-hosted services, such as airgreenland.gl. According to the available data, Energy infrastructure is hosted entirely abroad, underscoring possibly one of the most critical vulnerabilities in the dataset. By contrast, telecom domains, unsurprisingly, given Tele Greenland’s role, are entirely local, making it the only sector with 100 percent internal hosting. Municipalities present a more positive picture, with three-quarters of domains hosted locally and one-quarter abroad, although this still represents a partial external dependency. Finally, the large and diverse “Other” category, which contains a mix of companies, organizations, and services, is skewed towards foreign hosting (67 percent external, 33 percent local).

Taken together, the results underscore three important points. First, sector-level sovereignty is highly uneven. While telecom, municipal, and Governmental web services retain more local control, most finance, education, and energy domains are overwhelmingly external. We should keep in mind that when a Greenlandic domain resolves to local infrastructure, it indicates that the frontend web hosting, the visible entry point that users connect to, is located within Greenland, typically through Tele Greenland (i.e., Tusass GL). However, this does not automatically mean that the entire service stack is local. Critical back-end components such as databases, authentication services, payment platforms, or integrated cloud applications may still reside abroad. In practice, a locally hosted domain therefore guarantees only that the web interface is served from Greenland, while deeper layers of the service may remain dependent on foreign infrastructure. This distinction is crucial when evaluating genuine digital sovereignty and resilience. However, the overall pattern is unmistakable. Greenland’s digital presence remains heavily reliant on foreign hosting, with only pockets of local sovereignty.

A sector-level view of the share of locally versus externally (i.e., outside Greenland) MX (mail exchange) hosted Greenlandic domains (.gl).

The Figure above provides a sector-level view of how Greenlandic domains handle their MX (mail exchange) infrastructure, distinguishing between those hosted locally and those that rely on foreign providers. The analysis is based on the subset of 94 domains (out of 315 total) where MX hosting could be clearly resolved. In other words, these are the domains for which sufficient DNS information was available to identify the location of their mail servers. As with the web/IP analysis, it is important to note two caveats: sector classification involves a degree of interpretation, and the results represent individual domains, not individual companies. A single organization may operate multiple domains, some of which are local and others external.

The results are striking. For most sectors, such as education, finance, transport, energy, telecom, and municipalities, the dependence on foreign MX hosting is total. 100 percent of identified domains rely on external providers for email infrastructure. Even critical sectors such as energy and telecom, where one might expect a more substantial local presence, are fully externalized. The government sector presents a mixed picture. Half of the government domains examined utilize local MX hosting, while the other half are tied to foreign providers. This partial local footprint is significant, as it shows that while some government email flows are retained within Greenland, an equally large share is routed through servers abroad. The “other” sector, which includes businesses, NGOs, and various organizations, shows a small local footprint of about 3 percent, with 97 percent hosted externally. Taken together, the Figure paints a more severe picture of dependency than the web/IP hosting analysis.

While web hosting still retained about a quarter of domains locally, in the case of email, nearly everything is external. Even in government, where one might expect strong sovereignty, half of the domains are dependent on foreign MX servers. This distinction is critical. Email is the backbone of communication for both public and private institutions, and the routing of Greenland’s email infrastructure almost entirely abroad highlights a deep vulnerability. Local MX records guarantee only that the entry point for mail handling is in Greenland. They do not necessarily mean that mail storage or filtering remains local, as many services rely on external processing even when the MX server is domestic.

The broader conclusion is clear. Greenland’s sovereignty in digital communications is weakest in email. Across nearly all sectors, external providers control the infrastructure through which communication must pass, leaving Greenland reliant on systems located far outside its borders. Irrespective of how the picture painted here may appear severe in terms of digital sovereignty, it is not altogether surprising. The almost complete externalization of Greenlandic email infrastructure is not surprising, given that most global email services are provided by U.S.-based hyperscalers such as Microsoft and Google. This reliance on Big Tech is the norm worldwide, but it carries particular implications for Greenland, where dependence on foreign-controlled communication channels further limits digital sovereignty and resilience.

The analysis of the 94 MX hosting entries shows a striking concentration of Greenlandic email infrastructure in the hands of a few large players. Microsoft dominates the picture with 38 entries, accounting for just over 40 percent of all records, while Amazon follows with 20 entries, or around 21 percent. Google, including both Gmail and Google Cloud Platform services, contributes an additional 8 entries, representing approximately 9% of the total. Together, these three U.S. hyperscalers control nearly 70 percent of all Greenlandic MX infrastructure. By contrast, Tele Greenland (Tusass GL) appears in only three cases, equivalent to just 3 percent of the total, highlighting the minimal local footprint. The remaining quarter of the dataset is distributed across a long tail of smaller European and global providers such as Team Blue in Denmark, Hetzner in Germany, OVH and O2Switch in France, Contabo, Telenor, and others. The distribution, however you want to cut it, underscores the near-total reliance on U.S. Big Tech for Greenland’s email services, with only a token share remaining under national control.

Out of 179 total country mentions across the dataset, the United States is by far the most dominant hosting location, appearing in 61 cases, or approximately 34 percent of all country references. The United Kingdom follows with 38 entries (21 percent), Ireland with 28 entries (16 percent), and Denmark with 25 entries (14 percent). France (4 percent) and Australia (3 percent) form a smaller second tier, while Greenland itself appears only three times (2 percent). Germany also accounts for three entries, and all other countries (Austria, Norway, Spain, Czech Republic, Slovakia, Poland, Canada, and Singapore) occur only once each, making them statistically marginal. Examining the structure of services across locations, approximately 30 percent of providers are tied to a single country, while 51 percent span two countries (for example, UK–US or DK–IE). A further 18 percent are spread across three countries, and a single case involved four countries simultaneously. This pattern reflects the use of distributed or redundant MX services across multiple geographies, a characteristic often found in large cloud providers like Microsoft and Amazon.

The key point is that, regardless of whether domains are linked to one, two, or three countries, the United States is present in the overwhelming majority of cases, either alone or in combination with other countries. This confirms that U.S.-based infrastructure underpins the backbone of Greenlandic email hosting, with European locations such as the UK, Ireland, and Denmark acting primarily as secondary anchors rather than true alternatives.

WHAT DOES IT ALL MEAN?

Greenland’s public digital life overwhelmingly runs on infrastructure it does not control. Of 315 .gl domains, only 190 even have active web/IP hosting, and just 98 have resolvable MX (email) records. Within that smaller, “real” subset, most web front-ends are hosted abroad and virtually all email rides on foreign platforms. The dependency is concentrated, with U.S. hyperscalers—Microsoft, Amazon, and Google—accounting for nearly 70% of MX services. The U.S. is also represented in more than a third of all MX hosting locations (often alongside the UK, Ireland, or Denmark). Local email hosting is almost non-existent (two entirely local domains; a few Tele Greenland/Tusass appearances), and even for websites, a Greenlandic front end does not guarantee local back-end data or apps.

That architecture has direct implications for sovereignty and security. If submarine cables, satellites, or upstream policies fail or are restricted, most government, municipal, health, financial, educational, and transportation services would degrade or cease, because their applications, identity systems, storage, payments, and mail are anchored off-island. Daily resilience can mask strategic fragility: the moment international connectivity is severely compromised, Greenland lacks the local “island mode” to sustain critical digital workflows.

This is not surprising. U.S. Big Tech dominates email and cloud apps worldwide. Still, it may pose a uniquely high risk for Greenland, given its small population, sparse infrastructure, and renewed U.S. strategic interest in the region. Dependence on platforms governed by foreign law and policy erodes national leverage in crisis, incident response, and lawful access. It exposes citizens to outages or unilateral changes that are far beyond Nuuk’s control.

The path forward is clear: treat digital sovereignty as critical infrastructure. Prioritize local capabilities where impact is highest (government/municipal core apps, identity, payments, health), build island-mode fallbacks for essential services, expand diversified transport (additional cables, resilient satellite), and mandate basic email security (SPF/DKIM/DMARC) alongside measurable locality targets for hosting and data. Only then can Greenland credibly assure that, even if cut off from the world, it can still serve its people.

CONNECTIVITY AND RESILIENCE: GREENLAND VERSUS OTHER SOVEREIGN ISLANDS.

Sources: Submarine cable counts from TeleGeography/SubmarineNetworks.com; IXPs and ASNs from Internet Society Pulse/Peering DB and RIR data; GDP and Population from IMF/Worldband (2023/2024); Internet penetration from ITU and National Statistics.

The comparative table shown above highlights Greenland’s position among other sovereign and autonomous islands in terms of digital infrastructure. With two international submarine cables, Greenland shares the same level of cable redundancy as the Faroe Islands, Malta, the Maldives, Seychelles, Cuba, and Fiji. This places it in the middle tier of island connectivity: above small states like Comoros, which rely on a single cable, but far behind island nations such as Cyprus, Ireland, or Singapore, which have built themselves into regional hubs with multiple independent international connections.

Where Greenland diverges is in the absence of an Internet Exchange Point (IXP) and its very limited number of Autonomous Systems (ASNs). Unlike Iceland, which couples four cables with three IXPs and over ninety ASNs, Greenland remains a network periphery. Even smaller states such as Malta, Seychelles, or Mauritius operate IXPs and host more ASNs, giving them greater routing autonomy and resilience.

In terms of internet penetration, Greenland fares relatively well, with a rate of over 90 percent, comparable to other advanced island economies. Yet the country’s GDP base is extremely limited, comparable to the Faroe Islands and Seychelles, which constrains its ability to finance major independent infrastructure projects. This means that resilience is not simply a matter of demand or penetration, but rather a question of policy choices, prioritization, and regional partnerships.

Seen from a helicopter’s perspective, Greenland is neither in the worst nor the best position. It has more resilience than single-cable states such as Comoros or small Pacific nations. Still, it lags far behind peer islands that have deliberately developed multi-cable redundancy, local IXPs, and digital sovereignty strategies. For policymakers, this raises a fundamental challenge: whether to continue relying on the relative stability of existing links, or to actively pursue diversification measures such as a national IXP, additional cable investments, or regional peering agreements. In short, Greenland’s digital sovereignty depends less on raw penetration figures and more on whether its infrastructure choices can elevate it from a peripheral to a more autonomous position in the global network.

HOW TO ELEVATE SOUTH GREENLAND TO A PREFERRED TO A PREFFERED DIGITAL HOST FOR THE WORLD … JUST SAYING, WHY NOT!

At first glance, South Greenland and Iceland share many of the same natural conditions that make Iceland an attractive hub for data centers. Both enjoy a cool North Atlantic climate that allows year-round free cooling, reducing the need for energy-intensive artificial systems. In terms of pure geography and temperature, towns such as Qaqortoq and Narsaq in South Greenland are not markedly different from Reykjavík or Akureyri. From a climatic standpoint, there is no inherent reason why Greenland should not also be a viable location for large-scale hosting facilities.

The divergence begins not with climate but with energy and connectivity. Iceland spent decades developing a robust mix of hydropower and geothermal plants, creating a surplus of cheap renewable electricity that could be marketed to international hyperscale operators. Greenland, while rich in hydropower potential, has only a handful of plants tied to local demand centers, with no national grid and limited surplus capacity. Without investment in larger-scale, interconnected generation, it cannot guarantee the continuous, high-volume power supply that international data centers demand. Connectivity is the other decisive factor. Iceland today is connected to four separate submarine cable systems, linking it to Europe and North America, which gives operators confidence in redundancy and low-latency routes across the Atlantic. South Greenland, by contrast, depends on two branches of the Greenland Connect system, which, while providing diversity to Iceland and Canada, does not offer the same level of route choice or resilience. The result is that Iceland functions as a transatlantic bridge, while Greenland remains an endpoint.

For South Greenland to move closer to Iceland’s position, several changes would be necessary. The most important would be a deliberate policy push to develop surplus renewable energy capacity and make it available for export into data center operations. Parallel to this, Greenland would need to pursue further international submarine cables to break its dependence on a single system and create genuine redundancy. Finally, it would need to build up the local digital ecosystem by fostering an Internet Exchange Point and encouraging more networks to establish Autonomous Systems on the island, ensuring that Greenland is not just a transit point but a place where traffic is exchanged and hosted, and, importantly, making money on its own Digital Infrastructure and Sovereignty. South Greenland already shares the climate advantage that underpins Iceland’s success, but climate alone is insufficient. Energy scale, cable diversity, and deliberate policy have been the ingredients that have allowed Iceland to transform itself into a digital hub. Without similar moves, Greenland risks remaining a peripheral node rather than evolving into a sovereign center of digital resilience.

A PRACTICAL BLUEPRINT FOR GREENLAND TOWARDS OWNING ITS DIGITAL SOVEREIGNTY.

No single measure eliminates Greenland’s dependency on external infrastructure, banking, global SaaS, and international transit, which are irreducible. But taken together, these steps described below maximize continuity of essential functions during cable cuts or satellite disruption, improve digital sovereignty, and strengthen bargaining power with global vendors. The trade-off is cost, complexity, and skill requirements, which means Greenland must prioritize where full sovereignty is truly mission-critical (health, emergency, governance) and accept graceful degradation elsewhere (social media, entertainment, SaaS ERP).

A. Keep local traffic local (routing & exchange).

Proposal: Create or strengthen a national IXP in Nuuk, with a secondary node (e.g., Sisimiut or Qaqortoq). Require ISPs, mobile operators, government, and major content/CDNs to peer locally. Add route-server policies with “island-mode” communities to ensure that intra-Greenland routes stay reachable even if upstream transit is lost. Deploy anycasted recursive DNS and host authoritative DNS for .gl domains on-island, with secondaries abroad.

Pros:

  • Dramatically reduces the latency, cost, and fragility of local traffic.
  • Ensures Greenland continues to “see itself” even if cut off internationally.
  • DNS split-horizon prevents sensitive internal queries from leaking off-island.

Cons:

  • Needs policy push. Voluntary peering is often insufficient in small markets.
  • Running redundant IXPs is a fixed cost for a small economy.
  • CDNs may resist deploying nodes without incentives (e.g., free rack and power).

A natural and technically well-founded reaction, especially given Greenland’s monopolistic structure under Tusass, is that an IXP or multiple ASNs might seem redundant. Both content and users reside on the same Tusass network, and intra-Greenland traffic already remains local at Layer 3. Adding an IXP would not change that in practice. Without underlying physical or organizational diversity, an exchange point cannot create redundancy on its own.

However, over the longer term, an IXP can still serve several strategic purposes. It provides a neutral routing and governance layer that enables future decentralization (e.g., government, education, or sectoral ASNs), strengthens “island-mode” resilience by isolating internal routes during disconnection from the global Internet, and supports more flexible traffic management and security policies. Notably, an IXP also offers a trust and independence layer that many third-party providers, such as hyperscalers, CDNs, and data-center networks, typically require before deploying local nodes. Few global operators are willing to peer inside the demarcation of a single national carrier’s network. A neutral IXP provides them with a technical and commercial interface independent of Tusass’s internal routing domain, thereby making on-island caching or edge deployments more feasible in the future. In that sense, this accurately reflects today’s technical reality. The IXP concept anticipates tomorrow’s structural and sovereignty needs, bridging the gap between a functioning monopoly network and a future, more open digital ecosystem.

In practice (and in my opinion), Tusass is the only entity in Greenland with the infrastructure, staff, and technical capacity to operate an IXP. While this challenges the ideal of neutrality, it need not invalidate the concept if the exchange is run on behalf of Naalakkersuisut (the Greenlandic self-governing body) or under a transparent, multi-stakeholder governance model. The key issue is not who operates the IXP, but how it is governed. Suppose Tusass provides the platform while access, routing, and peering policies are openly managed and non-discriminatory. In that case, the IXP can still deliver genuine benefits: local routing continuity, “island-mode” resilience, and a neutral interface that encourages future participation by hyperscalers, CDNs, and sectoral networks.

B. Host public-sector workloads on-island.

Proposal: Stand up a sovereign GovCloud GL in Nuuk (failover in another town, possible West-East redundancy), operated by a Greenlandic entity or tightly contracted partner. Prioritize email, collaboration, case handling, health IT, and emergency comms. Keep critical apps, archives, and MX/journaling on-island even if big SaaS (like M365) is still used abroad.

Pros:

  • Keeps essential government operations functional in an isolation event.
  • Reduces legal exposure to extraterritorial laws, such as the U.S. CLOUD Act.
  • Provides a training ground for local IT and cloud talent.

Cons:

  • High CapEx + ongoing OpEx; cloud isn’t a one-off investment.
  • Scarcity of local skills; risk of over-reliance on a few engineers.
  • Difficult to replicate the breadth of SaaS (ERP, HR, etc.) locally; selective hosting is realistic, full stack is not.

C. Make email & messaging “cable- and satellite-outage proof”.

Proposal: Host primary MX and mailboxes in GovCloud GL with local antispam, journaling, and security. Use off-island secondaries only for queuing. Deploy internal chat/voice/video systems (such as Matrix, XMPP, or local Teams/Zoom gateways) to ensure that intra-Greenland traffic never routes outside the country. Define an “emergency federation mode” to isolate traffic during outages.

Pros:

  • Ensures communication between government, hospitals, and municipalities continues during outages.
  • Local queues prevent message loss even if foreign relays are unreachable.
  • Pre-tested emergency federation builds institutional muscle memory.

Cons:

  • Operating robust mail and collaboration platforms locally is a resource-intensive endeavor.
  • Risk of user pushback if local platforms feel less polished than global SaaS.
  • The emergency “mode switch” adds operational complexity and must be tested regularly.

D. Put the content edge in Greenland.

Proposal: Require or incentivize CDN caches (Akamai, Cloudflare, Netflix, OS mirrors, software update repos, map tiles) to be hosted inside Greenland’s IXP(s).

Pros:

  • Improves day-to-day performance and cuts transit bills.
  • Reduces dependency on subsea cables for routine updates and content.
  • Keeps basic digital life (video, software, education platforms) usable in isolation.

Cons:

  • CDNs deploy based on scale; Greenland’s market may be marginal without a subsidy.
  • Hosting costs (power, cooling, rackspace) must be borne locally.
  • Only covers cached/static content; dynamic services (banking, SaaS) still break without external connectivity.

E. Implement into law & contracts.

Proposal: Mandate data residency for public-sector data; require “island-mode” design in procurement. Systems must demonstrate the ability to authenticate locally, operate offline, maintain usable data, and retain keys under Greenlandic custody. Impose peering obligations for ISPs and major SaaS/CDNs.

Pros:

  • Creates a predictable baseline for sovereignty across all agencies.
  • Prevents future procurement lock-in to non-resilient foreign SaaS.
  • Gives legal backing to technical requirements (IXP, residency, key custody).

Cons:

  • May raise the costs of IT projects (compliance overhead).
  • Without a strong enforcement, rules risk becoming “checkbox” exercises.
  • Possible trade friction if foreign vendors see it as protectionist.

F. Strengthen physical resilience

Proposal: Maintain and upgrade subsea cable capacity (Greenland Connect and Connect North), add diversity (spur/loop and new landings), and maintain long-haul microwave/satellite as a tertiary backup. Pre-engineer quality of service downgrades for graceful degradation.

Pros:

  • Adds true redundancy. Nothing replaces a working subsea cable.
  • Tertiary paths (satellite, microwave) keep critical services alive during failures.
  • Clear QoS downgrades make service loss more predictable and manageable.

Cons:

  • High (possibly very high) CapEx. New cable segments cost tens to hundreds of millions of euros.
  • Satellite/microwave backup cannot match the throughput of subsea cables.
  • International partners may be needed for funding and landing rights.

Security & trust

Proposal: Deploy local PKI and HSMs for the government. Enforce end-to-end encryption. Require local custody of cryptographic keys. Audit vendor remote access and include kill switches.

Pros:

  • Prevents data exposure via foreign subpoenas (without Greenland’s knowledge).
  • Local trust anchors give confidence in sovereignty claims.
  • Kill switches and audit trails enhance vendor accountability.

Cons:

  • PKI and HSM management requires very specialized skills.
  • Adds operational overhead (key lifecycle, audits, incident response).
  • Without strong governance, there is a risk of “security theatre” rather than absolute security.

On-island first as default. A key step for Greenland is to make on-island first the norm so that local-to-local traffic stays local even if Atlantic cables fail. Concretely, stand up a national IXP in Nuuk to keep domestic traffic on the island and anchor CDN caches; build a Greenlandic “GovCloud” to host government email, identity, records, and core apps; and require all public-sector systems to operate in “island mode” (continue basic services offline from the rest of the world). Pair this with local MX, authoritative DNS, secure chat/collaboration, and CDN caches, so essential content and services remain available during outages. Back it with clear procurement rules on data residency and key custody to reduce both outage risk and exposure to foreign laws (e.g., CLOUD Act), acknowledging today’s heavy—if unsurprising—reliance on U.S. hyperscalers (Microsoft, Amazon, Google).

What this changes, and what it doesn’t. These measures don’t aim to sever external ties. They should rebalance them. The goal is graceful degradation that keeps government services, domestic payments, email, DNS, and health communications running on-island, while accepting that global SaaS and card rails will go dark during isolation. Finally, it’s also worth remembering that local caching is only a bridge, not a substitute for global connectivity. In the first days of an outage, caches would keep websites, software updates, and even video libraries available, allowing local email and collaboration tools to continue running smoothly. But as the weeks pass, those caches would inevitably grow stale. News sites, app stores, and streaming platforms would stop refreshing, while critical security updates, certificates, and antivirus definitions would no longer be available, leaving systems exposed to risk. If isolation lasted for months, the impact would be much more profound. Banking and card clearing would be suspended, SaaS-driven ERP systems would break down, and Greenland would slide into a “local only” economy, relying on cash and manual processes. Over time, the social impact would also be felt, with the population cut off from global news, communication, and social platforms. Caching, therefore, buys time, but not independence. It can make an outage manageable in the short term, yet in the long run, Greenland’s economy, security, and society depend on reconnecting to the outside world.

The Bottom line. Full sovereignty is unrealistic for a sparse, widely distributed country, and I don’t think it makes sense to strive for that. It just appears impractical. In my opinion, partial sovereignty is both achievable and valuable. Make on-island first the default, keep essential public services and domestic comms running during cuts, and interoperate seamlessly when subsea links and satellites are up. This shifts Greenland from its current state of strategic fragility to one of managed resilience, without overlooking the rest of the internet.

ACKNOWLEDGEMENT.

I want to acknowledge my wife, Eva Varadi, for her unwavering support, patience, and understanding throughout the creative process of writing this article. I would also like to thank Dr. Signe Ravn-Højgaard, from “Tænketanken Digital Infrastruktur”, and the Sermitsiaq article “Digital afhængighed af udlandet” (“Digital dependency on foreign countries”) by Paul Krarup, for inspiring this work, which is also a continuation of my previous research and article titled “Greenland: Navigating Security and Critical Infrastructure in the Arctic – A Technology Introduction”. I would like to thank Lasse Jarlskov for his insightful comments and constructive feedback on this article. His observations regarding routing, OSI layering, and the practical realities of Greenland’s network architecture were both valid and valuable, helping refine several technical arguments and improve the overall clarity of the analysis.

CODE AND DATASETS.

The Python code and datasets used in the analysis are available on my public GitHub: https://github.com/drkklarsen/greenland_digital_infrastructure_mapping (the code is still work in progress, but it is functional and will generate similar data as analyzed in this article).

ABBREVIATION LIST.

ASN — Autonomous System Number: A unique identifier assigned to a network operator that controls its own routing on the Internet, enabling the exchange of traffic with other networks using the Border Gateway Protocol (BGP).

BGP — Border Gateway Protocol: The primary routing protocol of the Internet, used by Autonomous Systems to exchange information about which paths data should take across networks.

CDN — Content Delivery Network: A system of distributed servers that cache and deliver content (such as videos, software updates, or websites) closer to users, reducing latency and dependency on international links.

CLOUD Act — Clarifying Lawful Overseas Use of Data Act: A U.S. law that allows American authorities to demand access to data stored abroad by U.S.-based cloud providers, raising sovereignty and privacy concerns for other countries.

DMARC — Domain-based Message Authentication, Reporting and Conformance: An email security protocol that tells receiving servers how to handle messages that fail authentication checks, protecting against spoofing and phishing.

DKIM — DomainKeys Identified Mail: An email authentication method that uses cryptographic signatures to verify that a message has not been altered and truly comes from the claimed sender.

DNS — Domain Name System: The hierarchical system that translates human-readable domain names (like example.gl) into IP addresses that computers use to locate servers.

ERP — Enterprise Resource Planning A type of integrated software system that organizations use to manage business processes such as finance, supply chain, HR, and operations.

GL — Greenland (country code top-level domain, .gl) The internet country code for Greenland, used for local domain names such as nanoq.gl.

GovCloud — Government Cloud: A sovereign or dedicated cloud infrastructure designed for hosting public-sector applications and data within national jurisdiction.

HSM — Hardware Security Module: A secure physical device that manages cryptographic keys and operations, used to protect sensitive data and digital transactions.

IoT — Internet of Things: A network of physical devices (sensors, appliances, vehicles, etc.) connected to the internet, capable of collecting and exchanging data.

IP — Internet Protocol: The fundamental addressing system of the Internet, enabling data packets to be sent from one computer to another.

ISP — Internet Service Provider: A company or entity that provides customers with access to the internet and related services.

IXP — Internet Exchange Point: A physical infrastructure where networks interconnect directly to exchange internet traffic locally rather than through international transit links.

MX — Mail Exchange (Record): A type of DNS record that specifies the mail servers responsible for receiving email on behalf of a domain.

PKI — Public Key Infrastructure: A framework for managing encryption keys and digital certificates, ensuring secure electronic communications and authentication.

SaaS — Software as a Service: Cloud-based applications delivered over the internet, such as Microsoft 365 or Google Workspace, are usually hosted on servers outside the country.

SPF — Sender Policy Framework: An email authentication protocol that defines which mail servers are authorized to send email on behalf of a domain, reducing the risk of forgery.

Tusass is the national telecommunications provider of Greenland, formerly Tele Greenland, responsible for submarine cables, satellite links, and domestic connectivity.

UAV — Unmanned Aerial Vehicle: An aircraft without a human pilot on board, often used for surveillance, monitoring, or communications relay.

UUV — Unmanned Underwater Vehicle: A robotic submarine used for monitoring, surveying, or securing undersea infrastructure such as cables.

AI in RAN – Evolution, Opportunities, and Risks

INTRO.

On September 10, at the Berlin Open RAN Working Week (BOWW) (a public event arranged by Deutsche Telekom AG’s T-Labs), I will give a talk about AI in Open RAN and RAN in general. The focus of the talk will be on how AI in RAN can boost the spectral efficiency. I have about 20 minutes, which is way too short to convey what is happening in this field at the moment. Why not write a small piece on the field as I see it at the moment? So, enjoy and feel free to comment or contact me directly for one-on-one discussions. If you are at the event, feel free to connect there as well.

LOOKING BACK.

The earliest use of machine learning and artificial intelligence in the Radio Access Network did not arrive suddenly with the recent wave of AI-RAN initiatives. Long before the term “AI-native RAN” (and even the term AI) became fashionable, vendors were experimenting with data-driven methods to optimize radio performance, automate operations, and manage complexity that traditional engineering rules could no longer handle well or at all. One of the first widely recognized examples came from Ericsson, which worked with SoftBank in Japan on advanced coordination features that would later be branded as Elastic RAN. By dynamically orchestrating users and cell sites, these early deployments delivered substantial throughput gains in dense environments such as Tokyo Station (with more than half a million passengers daily). Although they were not presented as “AI solutions,” they relied on principles of adaptive optimization that anticipated later machine learning–based control loops.

Nokia, and previously Nokia-Siemens Networks, pursued a similar direction through Self-Organizing Networks. SON functions, such as neighbor list management, handover optimization, and load balancing, increasingly incorporate statistical learning and pattern recognition techniques. These capabilities were rolled out across 3G and 4G networks during the 2010s and can be seen as some of the earliest mainstream applications of machine learning inside the RAN. Samsung, Huawei, and ZTE also invested in intelligent automation at this stage, often describing their approaches in terms of network analytics and energy efficiency rather than artificial intelligence, but drawing on many of the same methods. Around the same time, startups began pushing the frontier further: Uhana, founded in 2016 (acquired by VMware in 2019), pioneered the use of deep learning for real-time network optimization and user-experience prediction, going beyond rule-based SON to deliver predictive, closed-loop control. Building on that trajectory, today’s Opanga represents a (much) more advanced, AI-native and vendor-agnostic RAN platform, addressing long-standing industry challenges such as congestion management, energy efficiency, and intelligent spectrum activation at scale. In my opinion, both Uhana and Opanga can be seen as early exemplars of the types of applications that later inspired the formalization of rApps and xApps in the O-RAN framework.

What began as incremental enhancements in SON and coordination functions gradually evolved into more explicit uses of AI. Ericsson extended its portfolio with machine-learning-based downlink link adaptation and parameter optimization; Nokia launched programs to embed AI into both planning and live operations; and other vendors followed suit. By the early 2020s, the industry had begun to coalesce around the idea of an AI-RAN, where RAN functions and AI workloads are tightly interwoven. This vision took concrete form in 2024 with the launch of the AI-RAN Alliance, led by NVIDIA and comprising Ericsson, Nokia, Samsung, SoftBank, T-Mobile, and other partners.

The trajectory from SON and early adaptive coordination toward today’s GPU-accelerated AI-RAN systems underscores that artificial intelligence in the RAN has been less a revolution than an evolution. The seeds were sown in the earliest machine-learning-driven automation of 3G and 4G networks, and they have grown into the integrated AI-native architectures now being tested for 5G Advanced and beyond.

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Figure: Evolution of Open RAN architectures — from early X-RAN disaggregation (2016–2018) to O-RAN standardization (2018–2020), and today’s dual paths of full disaggregated O-RAN and vRAN with O-RAN interfaces.

AI IN OPEN RAN – THE EARLIER DAYS.

Open RAN as a movement has its roots in the xRAN Forum (founded in 2016) and the O-RAN Alliance (created in early 2018 when xRAN merged with C-RAN Alliance). While the architectural thinking and evolution around what has today become the O-RAN Architecture (with its 2 major options) is interesting and very briefly summarized in the above figure. The late 2010s were a time when architectural choices were made in a climate of enormous enthusiasm for cloud-native design and edge cloud computing. At that time, “disaggregation for openness” was considered an essential condition for competition, innovation, and efficiency. I also believe that when xRAN was initiated around 2016, the leading academic and industrial players came predominantly from Germany, South Korea, and Japan. Each of these R&D cultures has a deep tradition of best-in-breed engineering, that is, the idea that the most specialized team or vendor should optimize every single subsystem, and that overall performance emerges from integrating these world-class components. Looking back today, with the benefit of hindsight, one can see how this cultural disposition amplified the push for the maximum disaggregation paradigm, even where integration and operational realities would later prove more challenging. It also explains why early O-RAN documents are so ambitious in scope, embedding intelligence into every layer and opening almost every possible interface imaginable. What appeared to be a purely technical roadmap was, in my opinion, also heavily shaped by the R&D traditions and innovation philosophies of the national groups leading the effort.

However, although this is a super interesting topic (i.e., how culture and background influence innovation, architectural ideas, and choices), it is not the focus of this paper. AI in RAN is the focus. From its very first architectural documents, O-RAN included the idea that AI and ML would be central to automating and optimizing the RAN.

The key moment was 2018, when the O-RAN Alliance released its initial O-RAN architecture white paper (“O-RAN: Towards an Open and Smart RAN”). That document explicitly introduced the concept of the Non-Real-Time (NRT) RIC (rApps) and the Real-Time (RT) RIC (xApps) as platforms designed to host AI/ML-based applications. The NRT RIC was envisioned to run in the operator’s cloud, providing policy guidance, training, and coordination of AI models at timescales well above a second. In contrast, the RT RIC (i.e., the official name is RT RIC, which is unfortunate for abbreviations among the two RICs) would host faster-acting control applications within the 10-ms to 1-s regime. These were framed not just as generic automation nodes but explicitly as AI/ML hosting environments. The idea of a dual RIC structure, breaking up the architecture in layers of relevant timescales, was not conceived in a vacuum. It is, in many ways, an explicit continuation of the ideas introduced in the 3GPP LTE Self-Organizing Network (SON) specifications, where optimization functions were divided between centralized, long-horizon processes running in the network management system and distributed, faster-acting functions embedded at the eNodeB. In the LTE context, the offline or centralized SON dealt with tasks such as PCI assignment, ANR management, and energy saving strategies at timescales of minutes to days. At the same time, the online or distributed SON reacted locally to interference, handover failures, or outages at timescales of hundreds of milliseconds to a few seconds. O-RAN borrowed this logic but codified it in a much more rigid fashion: the Non-RT RIC inherited the role of centralized SON, and the RT RIC inherited the role of distributed SON, with the addition of standardized interfaces and an explicit role as AI application platforms.

Figure: Comparison between the SON functions defined by 3GPP for LTE (right) and the O-RAN RIC architecture (left). The LTE model divides SON into centralized offline (C-SON, in OSS/NMS, working on minutes and beyond) and distributed online (D-SON, at the edge, operating at 100 ms to seconds) functions. In contrast, O-RAN formalized this split into the Non-RT RIC (≥1 s) and Near-RT RIC (10 ms–1 s), embedded within the SMO hierarchy. The figure highlights how O-RAN codified and extended SON’s functional separation into distinct AI/ML application platforms.

The choice to formalize this split also had political dimensions. Vendors were reluctant to expose their most latency-critical baseband algorithms to external control, and the introduction of an RT RIC created a sandbox where third-party innovation could be encouraged without undermining vendor control of the physical layer. At the same time, operators sought assurances that policy, assurance, and compliance would not be bypassed by low-latency applications; therefore, the Non-RT RIC was positioned as a control tower layer situated safely above the millisecond domain. In this sense, the breakup of the time domain was as much a governance and trust compromise as a purely technical necessity. By drawing a clear line between “safe and slow” and “fast but bounded,” O-RAN created a model that felt familiar to operators accustomed to OSS hierarchies, while signaling to regulators and ecosystem players that AI could be introduced in a controlled and explainable manner.

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Figure: Functional and temporal layering of the O-RAN architecture — showing the SMO with embedded NRT-RIC for long-horizon and slow control loops, the RT-RIC for fast loops, and the CU, DU, and RU for real-time through instant reflex actions, interconnected via standardized O-, A-, E-, F-, and eCPRI interfaces.

The figure above shows the O-RAN reference architecture with functional layers and interfaces. The Service Management and Orchestration (SMO) framework hosts the Non-Real-Time RIC (NRT-RIC), which operates on long-horizon loops (greater than 1 second) and is connected via the O1 interface to network elements and via O2 to cloud infrastructure (e.g., NFVI and MANO). Policies, enrichment information, and trained AI/ML models are delivered from the NRT-RIC to the Real-Time RIC (RT-RIC) over the A1 interface. The RT-RIC executes closed-loop control in the 10-ms to 1-s domain through xApps, interfacing with the CU/DU over E2. The 3GPP F1 split separates the CU and DU, while the DU connects to the RU through the open fronthaul (eCPRI/7-2x split). The RU drives active antenna systems (AAS) over largely proprietary interfaces (AISG for RET, vendor-specific for massive MIMO). The vertical time-scale axis highlights the progression from long-horizon orchestration at the SMO down to instant reflex functions in the RU/AAS domain. Both RU and DU operate on a transmission time interval (TTI) between 1 ms and 625 microseconds.

The O-RAN vision for AI and ML is built directly into its architecture from the very first white paper in 2018. The alliance described two guiding themes: openness and intelligence. Openness was about enabling multi-vendor, cloud-native deployments with open interfaces, which was supposed to provide for much more economical RAN solutions, while intelligence was about embedding machine learning and artificial intelligence into every layer of the RAN to deal with growing complexity (i.e., some of it self-inflicted by architecture and system design).

The architectural realization of this vision is the hierarchical RAN Intelligent Controller (RIC), which separates the control into different time domains and couples each to appropriate AI/ML functions:

  • Service Management and Orchestration (SMO, timescale > 1 second) – The Control Tower: The SMO provides the overarching management and orchestration framework for the RAN. Its functions extend beyond the Non-RT RIC, encompassing lifecycle management, configuration, assurance, and resource orchestration across both network functions and the underlying cloud infrastructure. Through the O1 interface (see above figure), the SMO collects performance data, alarms, and configuration information from the CU, DU, and RU, enabling comprehensive FCAPS (Fault, Configuration, Accounting, Performance, Security) management. Through the O2 interface (see above), it orchestrates cloud resources (compute, storage, accelerators) required to host virtualized RAN functions and AI/ML workloads. In addition, the SMO hosts the Non-RT RIC, meaning it not only provides operational oversight but also integrates AI/ML governance, ensuring that trained models and policy guidance align with operator intent and regulatory requirements.
  • Non-Real-Time RIC (NRT RIC, timescale > 1 second) – The Policy Brain: Directly beneath, embedded in the SMO, lies the NRT-RIC, described here as the “policy brain.” This is where policy management, analytics, and AI/ML model training take place. The non-RT RIC collects large volumes of data from the network (spatial-temporal traffic patterns, mobility traces, QoS (Quality of Service) statistics, massive MIMO settings, etc.) and uses them for offline training and long-term optimization. Trained models and optimization policies are then passed down to the RT RIC via the A1 interface (see above). A central functionality of the NRT-RIC is the hosting of rApps (e.g., Python or Java code), which implement policy-driven use cases such as energy savings, traffic steering, and mobility optimization. These applications leverage the broader analytic scope and longer timescales of the NRT-RIC to shape intent and guide the near-real-time actions of the RT-RIC. The NRT-RIC is traditionally viewed as an embedded entity within the SMO (although in theory, it could be a standalone entity)..
  • Real-Time RIC (RT RIC, 10 ms – 1 second timescale) – The Decision Engine: This is where AI-driven control is executed in closed loops. The real-time RT-RIC hosts xApps (e.g., Go or C++ code) that run inference on trained models and perform tasks such as load balancing, interference management, mobility prediction, QoS management, slicing, and per-user (UE) scheduling policies. It maintains a Radio Network Information Base (R-NIB) fed via the E2 interface (see above) from the DU/CU, and uses this data to make fast control decisions in near real-time.
  • Centralized Unit (CU): Below the RT-RIC sits the Centralized Unit, which takes on the role of the “shaper” in the O-RAN architecture. The CU is responsible for higher-layer protocol processing, including PDCP (Packet Data Convergence Protocol) and SDAP (Service Data Adaptation Protocol), and is therefore the natural point in the stack where packet shaping and QoS enforcement occur. At this level, AI-driven policies provided by the RT-RIC can directly influence how data streams are prioritized and treated, ensuring that application- or slice-specific requirements for latency, throughput, and reliability are respected. By interfacing with the RT-RIC over the E2 interface, the CU can dynamically adapt QoS profiles and flow control rules based on real-time network conditions, balancing efficiency with service differentiation. In this way, the CU acts as the bridge between AI-guided orchestration and the deterministic scheduling that occurs deeper in the DU/RU layers. The CU operates on a real-time but not ultra-tight timescale, typically in the range of tens of milliseconds up to around one second (similar to the RT-RIC), depending on the function.
  • DU/RU layer (sub-1 ms down to hundreds of microseconds) – The Executor & Muscles: The Distributed Unit (DU), located below the CU, is referred to as the “executor.” It handles scheduling and precoding at near-instant timescales, measured in sub-millisecond intervals. Here, AI functions take the form of compute agents that apply pre-trained or lightweight models to optimize resource block allocation and reduce latency. At the bottom, the Radio Unit (RU) represents the “muscles” of the system. Its reflex actions happen at the fastest time scales, down to hundreds of microseconds. While it executes deterministic signal processing, beamforming, and precoding, it also feeds measurements upward to fuel AI learning higher in the chain. Here reside the tightest loops, on a Transmission Time Interval (TTI) time scale (i.e., 1ms – 625 µs), such as baseband PHY processing, HARQ feedback, symbol scheduling, and beamforming weights. These functions require deterministic latencies and cannot rely on higher-layer AI/ML loops. Instead, the DU/RU executes control at the L1/L2 level, while still feeding measurement data upward for AI/ML training and adaptation.
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Figure: AI’s hierarchical chain of command in O-RAN — from the SMO as the control tower and NRT-RIC as the policy brain, through the RT-RIC as the decision engine and CU as shaper, down to DU as executor and RU as muscles. Each layer aligns with guiding timescales, agentic AI roles, and contributions to spectral efficiency, balancing perceived SE gains, overhead reductions, and SINR improvements.

The figure above portrays the Open RAN as a “chain of command” where intelligence flows across time scales, from long-horizon orchestration in the cloud down to sub-millisecond reflexes in the radio hardware. To make it more tangible, I have annotated the example of spectral efficiency optimization use case on the right side of the figure. The cascading structure, shown above, highlights how AI and ML roles evolve across the architecture. For instance, the SMO and NRT-RIC increase perceived spectral efficiency through strategic optimization, while the RT-RIC reduces inefficiencies by orchestrating fast loops. Additionally, the DU/RU contribute directly to signal quality improvements, such as SINR gains. The figure thus illustrates Open RAN not as a flat architecture, but as a hierarchy of brains, decisions, and muscles, each with its own guiding time scale and AI function. Taken together, the vision is that AI/ML operates across all time domains, with the non-RT RIC providing strategic intelligence and model training, the RT RIC performing agile, policy-driven adaptation, and the DU/RU executing deterministic microsecond-level tasks, while exposing data to feed higher-layer intelligence. With open interfaces (A1, E2, open fronthaul), this layered AI approach allows multi-vendor participation, third-party innovation, and closed-loop automation across the RAN.

From 2019 onward, O-RAN working groups such as WG2 (Non-RT RIC & A1 interface) and WG3 (RT RIC & E2 interface) began publishing technical specifications that defined how AI/ML models could be trained, distributed, and executed across the RIC layers. By 2020–2021, proof-of-concepts and plugfests showcased concrete AI/ML use cases, such as energy savings, traffic steering, and anomaly detection, running as xApps (residing in RT-RIC) and rApps (residing in NRT-RIC). Following the first O-RAN specifications and proof-of-concepts, it becomes helpful to visualize how the different architectural layers relate to AI and ML. You will find a lot of the standardization documents in the reference list at the end of the document.

rAPPS AND xAPPS – AN ILLUSTRATION.

In the Open RAN architecture, the system’s intelligence is derived from the applications that run on top of the RIC platforms. The rApps exist in the Non-Real-Time RIC and xApps in the Real-Time RIC. While the RICs provide the structural framework and interfaces, it is the apps that carry the logic, algorithms, and decision-making capacity that ultimately shape network behavior. rApps operate at longer timescales, often drawing on large datasets and statistical analysis to identify trends, learn patterns, and refine policies. They are well-suited to classical machine learning processes such as regression, clustering, and reinforcement learning, where training cycles and retraining benefit from aggregated telemetry and contextual information. In practice, rApps are commonly developed in high-level languages such as Python or Java, leveraging established AI/ML libraries and data processing pipelines. In contrast, xApps must execute decisions in near-real time, directly influencing scheduling, beamforming, interference management, and resource allocation. Here, the role of AI and ML is to translate abstract policy into fast, context-sensitive actions, with an increasing reliance on intelligent control strategies, adaptive optimization, and eventually even agent-like autonomy (more on that later in this article). To meet these latency and efficiency requirements, xApps are typically implemented in performance-oriented languages like C++ or Go. However, Python is often used in prototyping stages before critical components are optimized. Together, rApps and xApps represent the realization of intelligence in Open RAN. One set grounded in long-horizon learning and policy shaping (i.e., Non-RT RIC and rApps), the other in short-horizon execution and reflexive adaptation (RT-RIC and xApps). Their interplay is not only central to energy efficiency, interference management, and spectral optimization but also points toward a future where classical ML techniques merge with more advanced AI-driven orchestration to deliver networks that are both adaptive and self-optimizing. Let us have a quick look at examples that illustrate how these applications work in the overall O-RAN architectural stack.

Figure: Energy efficiency loop in Open RAN, showing how long-horizon rApps set policies in the NRT-RIC, xApps in the RT-RIC execute them, and DU/RU translate these into scheduler and hardware actions with continuous telemetry feedback.

One way to understand the rApp–xApp interaction is to follow a simple energy efficiency use case, shown in the figure below. At the top, an energy rApp in the Non-RT RIC learns long-term traffic cycles and defines policies such as ‘allow cell muting below 10% load.’ These policies are then passed to the RT-RIC, where an xApp monitors traffic every second and decides when to shut down carriers or reduce power. The DU translates these decisions into scheduling and resource allocations, while the RU executes the physical actions such as switching off RF chains, entering sleep modes, or muting antenna elements. The figure above illustrates how policy flows downward while telemetry and KPIs flow back up, forming a continuous energy optimization loop. Another similarly layered logic applies to interference coordination, as shown in the figure below. Here, an interference rApp in the Non-RT RIC analyzes long-term patterns of inter-cell interference and sets coordination policies — for example, defining thresholds for ICIC, CoMP, or power capping at the cell edge. The RT-RIC executes these policies through xApps that estimate SINR in real time, apply muting patterns, adjust transmit power, and coordinate beam directions across neighboring cells. The DU handles PRB scheduling and resource allocation, while the RU enacts physical layer actions, such as adjusting beam weights or muting carriers. This second loop shows how rApps and xApps complement each other when interference is the dominant concern.

Figure: Interference coordination loop in Open RAN, where rApps define long-term coordination policies and xApps execute real-time actions on PRBs, power, and beams through DU/RU with continuous telemetry feedback.

Yet these loops do not always reinforce each other. If left uncoordinated, they can collide. An energy rApp may push the system toward contraction, reducing Tx power, muting carriers, and blanking PRBs. In contrast, an interference xApp simultaneously pushes for expansion, raising Tx power, activating carriers, and dynamically allocating PRBs. Both act on the same levers inside the CU/DU/RU, but in opposite directions. The result can be oscillatory behaviour, with power and scheduling thrashing back and forth, degrading QoS, and wasting energy. The figure below illustrates this risk and underscores why conflict management and intent arbitration are critical for a stable Open RAN.

Figure: Example of conflict between an energy-saving rApp and an interference-mitigation xApp, where opposing control intents on the same CU/DU/RU parameters can cause oscillatory behaviour.

Beyond the foundational description of how rApps and xApps operate, it is equally important to address the conflicts and issues that can arise when multiple applications are deployed simultaneously in the Non-RT and RT-RICs. Because each app is designed with a specific optimization objective in mind, it is almost inevitable that two or more apps will occasionally attempt to act on the same parameters in contradictory ways. While the energy efficiency versus interference management example is already well understood, there are broader categories of conflict that extend across both timescales.

Conflicts between rApps occur when long-term policy objectives are not aligned. For instance, a spectral efficiency rApp may continuously push the network toward maximizing bits per Hertz by advocating for higher transmit power, more active carriers, or denser pilot signaling. At the same time, an energy-saving rApp may be trying to mute those very carriers, reduce pilot density, and cap transmit power to conserve energy. Both policies can be valid in isolation, but when issued without coordination, they create conflicting intents that leave the RT-RIC and lower layers struggling to reconcile them. Even worse, the oscillatory behavior that results can propagate into the DU and RU, creating instability at the level of scheduling and RF execution. The xApps, too, can easily find themselves in conflict when they react to short-term KPI fluctuations with divergent strategies. An interference management xApp might impose aggressive PRB blanking patterns or reduce power at the cell edge. At the same time, a mobility optimization xApp might simultaneously widen cell range expansion parameters to offload traffic. The first action is designed to protect edge users, while the second may flood them with more load, undoing the intended benefit. Similarly, an xApp pushing for higher spectral efficiency may keep activating carriers and pushing toward higher modulation and coding schemes, while another xApp dedicated to energy conservation is attempting to put those carriers to sleep. The result is rapid toggling of resource states, which wastes signaling overhead and disrupts user experience.

The O-RAN Alliance has recognized these risks and proposed mechanisms to address them. Architecturally, conflict management is designed to reside in the RT-RIC, where a Conflict Mitigation and Arbitration framework evaluates competing intents from different xApps before they reach the CU/DU. Policies from the Non-RT RIC can also be tagged with priorities or guardrails, which the RT-RIC uses to arbitrate real-time conflicts. In practice, this means that when two xApps attempt to control the same parameter, the RT-RIC applies priority rules, resolves contradictions, or, in some cases, rejects conflicting commands entirely. On the rApp side, conflict resolution is handled at a higher abstraction level by the Non-RT RIC, which can consolidate or harmonize policies before they are passed down through the A1 interface.

The layered conflict mitigation approach in O-RAN provides mechanisms to arbitrate competing intents between apps. It can reduce the risk of oscillatory behavior, but it cannot guarantee stability completely. Since rApps and xApps may originate from different sources and vary in design quality, careful testing, certification, and continuous monitoring will remain essential to ensure that application diversity does not undermine network coherence. Equally important are policies that impose guardbands, buffers, and safety margins in how parameters can be tuned, which serve as a hedge against instabilities when apps are misaligned, whether the conflict arises between rApps, between xApps, or across the rApp–xApp boundary. These guardbands provide the architectural equivalent of shock absorbers, limiting the amplitude of conflicting actions and ensuring that, even if multiple apps pull in different directions, the network avoids catastrophic oscillations.

Last but not least, the risks may increase as rApps and xApps evolve beyond narrowly scoped optimizers into more agentic forms. An agentic app does not merely execute a set of policies or inference models. It can plan, explore alternatives, and adapt its strategies with a degree of autonomy (and agency). While this is likely to unlock powerful new capabilities, it also expands the possibility of emergent and unforeseen interactions. Two agentic apps, even if aligned at deployment, may drift toward conflicting behaviors as they continuously learn and adapt in real time. Without strict guardrails and robust conflict resolution, such autonomy could magnify instabilities rather than contain them, leading to system behavior that is difficult to predict or control. In this sense, the transition from classical rApps and xApps to agentic forms is not only an opportunity but also a new frontier of risk that must be carefully managed within the O-RAN architecture.

IS AI IN RAN ALL ABOUT “ChatGPT”?

I want to emphasize that when I address AI in the RAN, I generally do not refer to generative language models, such as ChatGPT, or other large-scale conversational systems built upon a human language context. Those technologies are based on Large Language Models (LLMs), which belong to the family of deep learning architectures built on transformer networks. A transformer network is a type of neural network architecture built around the attention mechanism, which allows the model to weigh the importance of different parts of an input sequence simultaneously rather than processing it step by step. They are typically trained on enormous human-based text datasets, utilizing billions of parameters, which requires immense computational resources and lengthy training cycles. Their most visible purpose today is to generate and interpret human language, operating effectively at the scale of seconds or longer in user interactions. In the context of network operations, I suspect that GPT-like LLMS will have a mission in the frontend where humans will need to interact with the communications network using human language. That said, the notion of “generative AI” is not inherently limited to natural language. The same underlying transformer-based methods can be adapted to other modalities (information sources), including machine-oriented languages or even telemetry sequences. For example, a generative model trained on RAN logs, KPIs, and signaling traces could be used to create synthetic telemetry or predict unusual event patterns. In this sense, generative AI could provide value to the RAN domain by augmenting datasets, compressing semantic information, or even assisting in anomaly detection. The caveat, however, is that these benefits still rely on heavy models with large memory footprints and significant inference latency. While they may serve well in the Non-RT RIC or SMO domain, where time scales are relaxed and compute resources are more abundant, they are unlikely to be terribly practical for the RT RIC or the DU/RU, where deterministic deadlines in the millisecond or microsecond range must be met.

By contrast, the application of AI/ML in the RAN is fundamentally about real-time signal processing, optimization, and control. RAN intelligence focuses on tasks such as load balancing, interference mitigation, mobility prediction, traffic steering, energy optimization, and resource scheduling. These are not problems of natural human language understanding but of strict scheduling and radio optimization. The time scales at which these functions operate are orders of magnitude shorter than those typical of generative AI. From long-horizon analytics in the Non-RT RIC (greater than one second) to near-real-time inference in the RT-RIC (i.e., 10 ms–1 s), and finally to deterministic microsecond loops in the DU/RU. This stark difference in time scales and problem domains explains why it appears unlikely that the RAN can be controlled end-to-end by “ChatGPT-like” AI. LLMs, whether trained on human language or telemetry sequences, are (today at least) too computationally heavy, too slow in inference, and are optimized for open-ended reasoning rather than deterministic control. Instead, the RAN requires a mix of lightweight supervised and reinforcement learning models, online inference engines, and, in some cases, ultra-compact TinyML implementations that can run directly in hardware-constrained environments.

In general, AI in the RAN is about embedding intelligence into control loops at the right time scale and with the right efficiency. Generative AI may have a role in enriching data and informing higher-level orchestration. It is difficult to see how it can efficiently replace the tailored, lightweight models that drive the RAN’s real-time and near-real-time control.

As O-RAN (and RAN in general) evolves from a vision of open interfaces and modular disaggregation into a true intelligence-driven network, one of the clearest frontiers is the use of Large Language Models (LLMs) at the top of the stack (i.e., frontend/human-facing). The SMO, with its embedded Non-RT RIC, already serves as the strategic brain of the architecture, responsible for lifecycle management, long-horizon policy, and the training of AI/ML models. This is also the one domain where time scales are relaxed, measured in seconds or longer, and where sufficient compute resources exist to host heavier models. In this environment, LLMs can be utilized in two key ways. First, they can serve as intent interpreters for intent-driven network operations, bridging the gap between operator directives and machine-executable policies. Instead of crafting detailed rules or static configuration scripts, operators could express high-level goals, such as prioritizing emergency service traffic in a given region or minimizing energy consumption during off-peak hours. An LLM, tuned with telecom-specific knowledge, can translate those intents into precise policy actions distributed through the A1 interface to the RT RIC. Second, LLMs can act as semantic compressors, consuming the vast streams of logs, KPIs, and alarms that flow upward through O1, and distilling them into structured insights or natural language summaries that humans can easily grasp. This reduces cognitive load for operators while ensuring (at least we should hope so!) that the decision logic remains transparent, possibly explainable, and auditable. In both roles, LLMs do not replace the specialized ML models running lower in the architecture. Instead, they enhance the orchestration layer by embedding reasoning and language understanding where time and resources permit.

WHAT AI & ML ARE LIKELY TO WORK IN RAN?

This piece assumes a working familiarity with core machine-learning concepts, models, training and evaluation processes, and the main families you will encounter in practice. If you want a compact, authoritative refresher, most of what I reference is covered, clearly and rigorously, in Goodfellow, Bengio, and Courville’s Deep Learning (Adaptive Computation and Machine Learning series, MIT Press). For hands-on practice, many excellent Coursera courses walk through these ideas with code, labs, and real datasets. They are a fast way to build the intuition you will need for the examples discussed in this section. Feel free to browse through my certification list, which includes over 60 certifications, with the earliest ML and AI courses dating back to 2015 (should have been updated by now), and possibly find some inspiration.

Throughout the article, I use “AI” and “ML” interchangeably for readability, but formally, they should be regarded as distinct. Artificial Intelligence (AI) is the broader field concerned with building systems that perceive their environment, reason about it, and act to achieve goals, encompassing planning, search, knowledge representation, learning, and decision-making. Machine Learning (ML) is a subset of AI that focuses specifically on data-driven methods that learn patterns or policies from examples, improving performance on a task through experience rather than explicit, hand-crafted rules, which is where the most interesting aspects occur.

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Figure: Mapping of AI roles, data flows, and model families across the O-RAN stack — from SMO and NRT-RIC handling long-horizon policy, orchestration, and training, to RT-RIC managing fast-loop inference and optimization, down to CU and DU/RU executing near-real-time and hardware-domain actions with lightweight, embedded AI models.

Artificial intelligence in the O-RAN stack exhibits distinct characteristics depending on its deployment location. Still, it is helpful to see it as one continuous flow from intent at the very top to deterministic execution at the very bottom. So, let’s go with the flow.

At the level of the Service Management and Orchestration, AI acts as the control tower for the entire system. This is where business or human intent must be translated into structured goals, and where guardrails, audit mechanisms, and reversibility are established to ensure compliance with regulatory oversight. Statistical models and rules remain essential at this layer because they provide the necessary constraint checking and explainability for governance. Yet the role of large language models is increasing rapidly, as they provide a bridge from human language into structured policies, intent templates, and root-cause narratives. Generative approaches are also beginning to play a role by producing synthetic extreme events to stress-test policies before they are deployed. While synthetic data for rare events offers a powerful tool for training and stress-testing AI systems, it may carry significant statistical risks. Generative models can fail to represent the very distributions they aim to capture, bias inference, or even introduce entirely artificial patterns into the data. Their use therefore requires careful anchoring in extremes-aware statistical methods, rigorous validation against real-world holdout data, and safeguards against recursive contamination. When these conditions are met, synthetic data can meaningfully expand the space of scenarios available for training and testing. Without the appropriate control mechanisms, decisions or policies based on synthetic data risk becoming a source of misplaced confidence rather than resilience. With all that considered, the SMO should be the steward of safety and interpretability, ensuring that only validated and reversible actions flow down into the operational fabric. If agentic AI is introduced here, it could reshape how intent is operationalized. Instead of merely validating human inputs, agentic systems might proactively (autonomeously) propose actions, refine intents into strategies, or initiate self-healing workflows on their own. While this promises greater autonomy and resilience, it also raises new challenges for oversight, since the SMO would become not just a filter but a creative actor in its own right.

At the top level, rApps (which reside in the NRT-RIC) are indirectly shaped by SMO policies, as they inherit intent, guardrails, and reversibility constraints. For example, when the SMO utilizes LLMs to translate business goals into structured intents, it essentially sets the design space within which rApps can train or re-optimize their models. The SMO also provides observability hooks, allowing rApp outputs to be audited before being pushed downstream.

The Non-Real-Time RIC can be understood as the long-horizon brain of the RAN. Its function is to train, retrain, and refine models, conduct long-term analysis, and transform historical and simulated experience into reusable policies. Reinforcement learning in its many flavors is the cornerstone here, particularly offline or constrained forms that can safely explore large data archives or digital twin scenarios. Autoencoders, clustering, and other representation learning methods uncover hidden structures in traffic and mobility, while supervised deep networks and boosted trees provide accurate forecasting of demand and performance. Generative simulators extend the scope by fabricating rare but instructive scenarios, allowing policies to be trained for resilience against the unexpected. Increasingly, language-based systems are also being applied to policy generation, bridging between strategic descriptions and machine-enforceable templates. The NRT-RIC strengthens AI’s applicability by moving risk away from live networks, producing validated artifacts that can later be executed at speed. If an agentic paradigm is introduced here, it would mean that the NRT-RIC is not merely a training ground but an active planner, continuously setting objectives for the rest of the system and negotiating trade-offs between coverage, energy, and user experience. This shift would make the Non-RT RIC a more autonomous planning organ, but it would also demand stronger mechanisms for bounding and auditing its explorations.

Here, at the NTR-RIC, rApps that are native to this RIC level are the central vehicle for model training, policy generation, and scenario exploration. They consume SMO intent and turn it into reusable policies or models for the RT-RIC. For example, a mobility rApp could use clustering and reinforcement learning to generate policies for user handover optimization, which the RT-RIC then executes in near real time. Another rApp might simulate mMIMO pairing scenarios offline, distill them into simplified lookup tables or quantized policies, and hand these artifacts down for execution at the DU/RU. Thus, rApps act as the policy factories. Their outputs cascade into xApps, at the RT-RIC, CU parameter sets, and lightweight silicon-bound models deeper down.

The Real-Time RIC is where planning gives way to fast, local action. At timescales between ten milliseconds and one second, the RT-RIC is tasked with run-time inference, traffic steering, slicing enforcement, and short-term interference management. Because the latency budget is tight, the model families that thrive here are compact and efficient. Shallow neural networks, recurrent models, and temporal CNN-RNN hybrids are all appropriate for predicting near-future load and translating context into rapid actions. Decision trees and ensemble methods remain attractive because of their predictable execution and interpretability. Online reinforcement learning, in which an agent interacts with its environment in real-time and updates its policy based on rewards or penalties, together with contextual bandits, a simplified variant that optimizes single-step decisions from observed contexts, both enable adaptation in small, incremental steps while minimizing the risk of destabilization. In specific contexts, lightweight graph neural networks (GNNs), which are streamlined versions of GNNs designed to model relationships between entities while keeping computational costs low, can capture the topological relationships between neighboring cells. In the RT-RIC, models must balance accuracy with predictable execution under tight timescales. Shallow neural networks (simple feedforward models capturing non-linear patterns), recurrent models (RNNs that retain memory of past inputs), and hybrid convolutional neural network–recurrent neural network (CNN–RNN) models (combining spatial feature extraction with temporal sequencing) are well-suited for processing fast-evolving time series, such as traffic load or interference, delivering near-future predictions with low latency. Decision trees (rule-based classifiers that split data hierarchically) and ensemble methods (collections of weak learners, such as random forests or boosting) add value through their lightweight, deterministic behavior and interpretability, making them reliable for regulatory oversight and stable actuation. Online reinforcement learning (RL) and contextual bandits further allow the system to adapt incrementally to changing conditions without risking destabilization. In more complex contexts, lightweight GNNs capture the topological structure between neighboring cells, supporting coordination in handovers or interference management while remaining efficient enough for real-time use. The RT-RIC thus embodies the point where AI policies become immediate operational decisions, measurable in KPIs within seconds. When viewed through the lens of agency, this layer becomes even more dynamic. An agentic RT-RIC could weigh competing goals, prioritize among multiple applications, and negotiate real-time conflicts without waiting for external intervention. Such an agency might significantly improve efficiency and responsiveness but would also blur the boundary between optimization and autonomous control, requiring new arbitration frameworks and assurance layers.

At this level, xApps, native to the RT-RIC, execute policies derived from rApps and adapt them to live network telemetry. An xApp for traffic steering might combine a policy from the Non-RT RIC with local contextual bandits to adjust routing in the moment. Another xApp could, for example, use lightweight GNNs to coordinate interference management across adjacent cells, directly influencing DU scheduling and RU beamforming. This makes xApps the translators of long-term rApp insights into second-by-second action, bridging the predictive foresight of rApps with the deterministic constraints of the DU/RU.

The Centralized Unit occupies an intermediate position between near-real-time responsiveness and higher-layer mobility and bearer management. Here, the most useful models are those that can both predict and pre-position resources before bottlenecks occur. Long Short-Term Memory networks (LSTMs, recurrent models designed to capture long-range dependencies), Gated Recurrent Units (GRUs, simplified RNNs with fewer parameters), and temporal Convolutional Neural Networks (CNNs, convolution-based models adapted for sequential data) are natural fits for forecasting user trajectories, mobility patterns, and session demand, thereby enabling proactive preparation of handovers and early allocation of network slices. Constrained reinforcement learning (RL, trial-and-error learning optimized under explicit safety or policy limits) methods play an important role at the bearer level, where they must carefully balance Quality of Service (QoS) guarantees against overall resource utilization, ensuring efficiency without violating service-level requirements. At the same time, rule-based optimizers remain well-suited for more deterministic processes, such as configuring Packet Data Convergence Protocol (PDCP) and Radio Link Control (RLC) parameters, where fixed logic can deliver predictable and stable outcomes in real-time. The CU strengthens applicability by anticipating issues before they materialize and by converting intent into per-flow adjustments. If agency is introduced at this layer, it might manifest as CU-level agents negotiating mobility anchors or bearer priorities directly, without relying entirely on upstream instructions. This could increase resilience in scenarios where connectivity to higher layers is impaired. Still, it also adds complexity, as the CU would need a framework for coordinating its autonomous decisions with the broader policy environment.

Both xApps and rApps can influence CU functions as they relate to bearer management and PDCP/RLC configuration. For example, a QoS balancing rApp might propose long-term thresholds for bearer prioritization. At the same time, a short-horizon xApp enforces these by pre-positioning slice allocations or adjusting bearer anchors in anticipation of predicted mobility. The CU thus becomes a convergence point, where rApp strategies and xApp tactics jointly shape mobility management and session stability before decisions cascade into DU scheduling.

At the very bottom of the stack, the Distributed Unit and Radio Unit function under the most stringent timing constraints, often in the realm of microseconds. Their role is to execute deterministic PHY and MAC functions, including HARQ, link adaptation, beamforming, and channel state processing. Only models that can be compiled into silicon, quantized, or otherwise guaranteed to run within strict latency budgets are viable in this layer of the Radio Access Network. Tiny Machine Learning (TinyML), Quantized Neural Networks (QNN), and lookup-table distilled models enable inference speeds compatible with microsecond-level scheduling constraints. As RU and DU components typically operate under strict latency and computational constraints, TinyML and low-bit QNNs are ideal for deploying functions such as beam selection, RF monitoring, anomaly detection, or lightweight PHY inference tasks. Deep-unfolded networks and physics-informed neural models are particularly valuable because they can replace traditional iterative solvers in equalization and channel estimation, achieving high accuracy while ensuring fixed execution times. In advanced antenna systems, neural digital predistortion and amplifier linearization enhance power efficiency and spectral containment. At the same time, sequence-based predictors can cut down channel state information (CSI) overhead and help stabilize multi-user multiple-input multiple-output (MU-MIMO) pairing. At this level, the integration of agentic AI must, in my opinion, be approached with caution. The DU and RU domains are all about execution rather than deliberation. Introducing agency here could compromise determinism. However, carefully bounded micro-agents that autonomously tune beams or adjust precoders within strict envelopes might prove valuable. The broader challenge is to reconcile the demand for predictability with the appeal of adaptive intelligence baked into hardware.

At this layer, most intelligence is “baked in” and must respect microsecond determinism timescales. Yet, rApps and xApps may still indirectly shape the DU/RU environment. The DU/RU do not run complex agentic loops themselves, but they inherit distilled intelligence from the higher layers. Micro-agents, if used, must be tightly bound. For example, an RU micro-agent may autonomously choose among two or three safe precoding matrices supplied by an xApp, but never generate them on its own.

Taking all the above together, the O-RAN stack can be seen as a continuum of intelligence, moving from the policy-heavy, interpretative functions at the SMO to the deterministic, silicon-bound execution at the RU. Agentic AI has the potential to change this continuum by shifting layers from passive executors to active participants. An agentic SMO might not only validate intents but generate them. An agentic Non-RT RIC might become an autonomous planner. An agentic RT-RIC could arbitrate between conflicting goals independently. And even the CU or DU might gain micro-agents that adjust parameters locally without instruction. This greater autonomy promises efficiency and adaptability but raises profound questions about accountability, oversight, and control. If the agency is allowed to propagate too deeply into the stack, the risk is that millions of daily inferences are taken without transparent justification or the possibility of reversal. This situation is unlikely to be considered regulatory acceptable and would be in direct violation of the European Artificial Intelligence Act, violating core provisions of the EU AI Act. The main risks are a lack of adequate human oversight (Article 14), inadequate record-keeping and traceability (Article 12), failures of transparency (Article 13), and the inability to provide meaningful explanations to affected users (Article 86). Together, these gaps would undermine the broader lifecycle obligations on risk management and accountability set out in Articles 8–17. To mitigate that, openness becomes indispensable: open policies, open data schemas, model lineage, and transparent observability hooks allow agency to be exercised without undermining trust. In this way, the RAN of the future may become not only intelligent but agentic, provided that its newfound autonomy is balanced by openness, auditability, and human authority at the points that matter most. However, I suspect that reaching that point may be a much bigger challenge than developing the AI Agentic framework and autonomous processes.

While the promise of AI in O-RAN is compelling, it is equally important to recognize where existing functions already perform so effectively that AI has little to add. At higher layers, such as the SMO and the Non-RT RIC, the complexity of orchestration, policy translation, and long-horizon planning naturally creates a demand for AI. These are domains where deterministic rules quickly become brittle, and where the adaptive and generative capacities of modern models unlock new value. Similarly, the RT-RIC benefits from lightweight ML approaches because traffic dynamics and interference conditions shift on timescales that rule-based heuristics often struggle to capture. As one descends closer to execution, however, the incremental value of AI begins to diminish. In the CU domain, many bearer management and PDCP/RLC functions can be enhanced by predictive models. Still, much of the optimization is already well supported by deterministic algorithms that operate within known bounds. The same is even more pronounced at the DU and RU levels. Here, fundamental PHY and MAC procedures such as HARQ timing, CRC checks, coding and decoding, and link-layer retransmissions are highly optimized, deterministic, and hardware-accelerated. These functions have been refined over decades of wireless research, and their performance approaches the physical and information-theoretical limits. For example, beamforming and precoding illustrate this well. Linear algebraic methods such as zero-forcing and MMSE are deeply entrenched, efficient, and predictable. AI and ML can sometimes enhance them at the margins by improving CSI compression, reducing feedback overhead, or stabilizing non-stationary channels. Yet it is unlikely to displace the core mathematical solvers that already deliver excellent performance. Link adaptation is similar. While machine learning may offer marginal gains in dynamic or noisy conditions, conventional SINR-based thresholding remains highly effective and, crucially, deterministic. It is worth remembering that simply and arbitrarily applying AI or ML functionality to an architectural element does not necessarily mean it will make a difference or even turn out to be beneficial.

This distinction becomes especially relevant when considering the implications of agentic AI. In my opinion, agency is most useful at the top of the stack, where strategy, trade-offs, and ambiguity dominate. In the SMO or Non-RT RIC, agentic systems can propose strategies, negotiate policies, or adapt scenarios in ways that humans or static systems could never match. At the RT-RIC, a carefully bound agency may improve arbitration among competing applications. But deeper in the stack, particularly at the DU and RU, the agency adds little value and risks undermining determinism. At microsecond timescales, where physics rules and deadlines are absolute, autonomy may be less of an advantage and more of a liability. The most practical role of AI here is supplementary, enabling anomaly detection, parameter fine-tuning, or assisting advanced antenna systems in ways that respect strict timing constraints. This balance of promise and limitation underscores a central point. AI is not a panacea for O-RAN, nor should it be applied indiscriminately.

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Figure: Comparative view of how AI transforms RAN operations — contrasting classical vendor-proprietary SON approaches, Opanga’s vendor-agnostic RAIN platform, and O-RAN implementations using xApps and rApps for energy efficiency, spectral optimization, congestion control, anomaly detection, QoE, interference management, coverage, and security.

The Table above highlights how RAN intelligence has evolved from classical vendor-specific SON functions toward open O-RAN frameworks and Opanga’s RAIN platform. While Classical RAN relied heavily on embedded algorithms and static rules, O-RAN introduces rApps and xApps to distribute intelligence across near-real-time and non-real-time control loops. Opanga’s RAIN, however, stands out as a truly AI-native and vendor-agnostic platform that is already commercially deployed at scale today. By tackling congestion, energy reduction, and intelligent spectrum on/off management without reliance on DPI (which is, anyway, a losing strategy as QUIC becomes increasingly used) or proprietary stacks, RAIN directly addresses some of the most pressing efficiency and sustainability challenges in today’s networks. It also appears straightforward for Opanga to adapt its AI engines into rApps or xApps should the Open RAN market scale substantially in the future, reinforcing its potential as one of the strongest and most practical AI platforms in the RAN domain today.

A NATIVE-AI RAN TEASER.

Native-AI in the RAN context means that artificial intelligence is not just an add-on to existing processes, but is embedded directly into the system’s architecture, protocols, and control loops. Instead of having xApps and rApps bolted on top of traditional deterministic scheduling and optimization functions, a native-AI design treats learning, inference, and adaptation as first-class primitives in the way the RAN is built and operated. This is fundamentally different from today’s RAN system designs, where AI is mostly externalized, invoked at slower timescales, and constrained by legacy interfaces. In a native-AI architecture, intent, prediction, and actuation are tightly coupled at millisecond or even microsecond resolution, creating new possibilities for spectral efficiency, user experience optimization, and autonomous orchestration. A native-AI RAN would likely require heavier hardware at the edge of the network than today’s Open (or “classical”) RAN deployments. In the current architecture, the DU and RU rely on highly optimized deterministic hardware such as FPGAs, SmartNICs, and custom ASICs to execute PHY/MAC functions at predictable latencies and with tight power budgets. AI workloads are typically concentrated higher up in the stack, in the NRT-RIC or RT-RIC, where they can run on centralized GPU or CPU clusters without overwhelming the radio units. However, by contrast, a native-AI design pushes inference directly into the DU and even the RU, where microsecond-scale decisions on beamforming, HARQ, and link adaptation must be made. This implies the integration of embedded accelerators, such as AI-optimized ASICs, NPUs, or small-form-factor GPUs, into radio hardware, along with larger memory footprints for real-time model execution and storage. The resulting compute demand and cooling requirements could increase power consumption substantially beyond today’s SmartNIC-based O-RAN nodes. An effect that would be multiplied by millions of cell sites worldwide should such a design be chosen. This may (should!) raise concerns regarding both CapEx and OpEx due to higher costs for silicon and more demanding site engineering for power and heat management.

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Figure: A comparison of the possible differences between today’s Open RAN and the AI-Native RAN Architecture. I should point out that the AI-Native RAN architecture is my own depiction and may not be how it may eventually look.

A native-AI RAN promises several advantages over existing architectures. By embedding intelligence directly into the control loops, the system can achieve higher spectral efficiency through ultra-fast adaptation of beamforming, interference management, and resource allocation, going beyond the limits of deterministic algorithms. It also allows for far more fine-grained optimization of the user experience, with decisions made per device, per flow, and in real-time, enabling predictive buffering and even semantic compression without noticeable delay. Operations themselves become more autonomous, with the RAN continuously tuning and healing itself in ways that reduce the need for manual intervention. Importantly, intent expressed at the management layer can be mapped directly into execution at the radio layer, creating continuity from policy to action that is missing in today’s O-RAN framework. Native-AI designs are also better able to anticipate and respond to extreme conditions, making the system more resilient under stress. Finally, they open the door to 6G concepts such as cell-less architectures, distributed massive MIMO, and AI-native PHY functions that cannot be realized under today’s layered, deterministic designs.

At the same time, the drawbacks of the Native-AI RAN approach may also be quite substantial. Embedding AI at microsecond control loops makes it almost impossible to trace reasoning steps or provide post-hoc explainability, creating tension with regulatory requirements such as the EU AI Act and NIS2. Because AI becomes the core operating fabric, mistakes, adversarial inputs, or misaligned objectives can cascade across the system much faster than in current architectures, amplifying the scale of failures. Continuous inference close to the radio layer also risks driving up compute demand and energy consumption far beyond what today’s SmartNIC- or FPGA-based solutions can handle. There is a danger of re-introducing vendor lock-in, as AI-native stacks may not interoperate cleanly with legacy xApps and rApps, undermining the very rationale of open interfaces. Training and refining these models requires sensitive operational and user data, raising privacy and data sovereignty concerns. Finally, the speed at which native-AI RANs operate makes meaningful human oversight nearly impossible, challenging the principle of human-in-the-loop control that regulators increasingly require for critical infrastructure operation.

Perhaps not too surprising, NVIDIA, a founding member of the AI-RAN Alliance, is a leading advocate for AI-native RAN, with strong leadership across infrastructure innovation, collaborative development, tooling, standard-setting, and future network frameworks. Their AI-Aerial platform and broad ecosystem partnerships illustrate their pivotal role in transitioning network architectures toward deeply integrated intelligence, especially in the 6G era. The AI-Native RAN concept and the gap it opens compared to existing O-RAN and classical RAN approaches will be the subject of a follow-up article I am preparing based on my current research into this field.

WHY REGULATORY AGENCIES MAY END THE AI PARTY (BEFORE IT REALLY STARTS).

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Figure: Regulatory challenges for applying AI in critical telecom infrastructure, highlighting transparency, explainability, and auditability as key oversight requirements under European Commission mandates, posing constraints on AI-driven RAN systems.

We are about to “let loose” advanced AI/ML applications and processes across all aspects of our telecommunication networks. From the core all the way through to access and out to consumers and businesses making use of what is today regarded as highly critical infrastructure. This reduces cognitive load for operators while aiming to keep decision logic transparent, explainable, and auditable. In both roles, LLMs do not replace the specialized ML models running lower in the architecture. Instead, they enhance the orchestration layer by embedding reasoning and language understanding where time and resources permit. Yet it is here that one of the sharpest challenges emerges. The regulatory and policy scrutiny that inevitably follows when AI is introduced into critical infrastructure.

In the EU, the legal baseline now treats many network-embedded AI systems as high-risk by default whenever they are used as safety or operational components in the management and operation of critical digital infrastructure. This category encompasses modern telecom networks squarely. Under the EU AI Act, such systems must satisfy stringent requirements for risk management, technical documentation, transparency, logging, human oversight, robustness, and cybersecurity, and they must be prepared for conformity assessment and market surveillance. If the AI used in RAN control or orchestration cannot meet these duties, deployment can be curtailed or prohibited until compliance is demonstrated. The same regulation now also imposes obligations on general-purpose AI (foundation/LLM) providers, including additional duties when models are deemed to pose systemic risk, to enhance transparency and safety across the supply chain that may support telecom use cases. This AI-specific layer builds upon the EU’s broader critical infrastructure and cybersecurity regime. The NIS2 Directive strengthens security and incident-reporting obligations for essential entities, explicitly including digital and communications infrastructure, while promoting supply-chain due diligence. This means that operators must demonstrate how they assess and manage risks from AI components and vendors embedded in their networks. The EU’s 5G Cybersecurity Toolbox adds a risk-based, vendor-agnostic lens to supplier decisions (applied to “high-risk” vendors). Still, the logic is general: provenance alone, whether from China, the US, Israel, or any “friendly” jurisdiction, does not exempt AI/ML components from rigorous technical and governance assurances. The Cyber Resilience Act extends horizontal cybersecurity duties to “products with digital elements,” which can capture network software and AI-enabled components, linking market access to secure-by-design engineering, vulnerability handling, and update practices.

Data-protection law also bites. GDPR Article 22 places boundaries on decisions based solely on automated processing that produce legal or similarly significant effects on individuals, a genuine concern as networks increasingly mediate critical services and safety-of-life communications. Recent case law from the Court of Justice of the EU underscores a right of access to meaningful information about automated decision-making “procedures and principles,” raising the bar for explainability and auditability in any network AI that profiles or affects individuals. In short, operators must be able to show their work, not just that an AI policy improved a KPI, but how it made the call. These European guardrails are mirrored (though not identically) elsewhere. The UK Telecoms Security Act and its Code of Practice impose enforceable security measures on providers. In the US, the voluntary NIST AI Risk Management Framework has become the de facto blueprint for AI governance, emphasizing transparency, accountability, and human oversight, principles that regulators can (and do) import into sectoral supervision. None of these frameworks cares only about “who made it”. They also care about how it performs, how it fails, how it is governed, and how it can be inspected.

The AI Act’s human-oversight requirement (i.e., Article 14 in the EU Artificial Intelligence Act) exists precisely to bound such risks, ensuring operators can intervene, override, or disable when behavior diverges from safety or fundamental rights expectations. Its technical documentation and transparency obligations require traceable design choices and lifecycle records. Where these assurances cannot be demonstrated, regulators may limit or ban such deployments in critical infrastructure.

Against this backdrop, proposals to deploy autonomous AI agents deeply embedded in the RAN stack face a (very) higher bar. Autonomy risks eroding the very properties that European law demands.

  • TransparencyReasoning steps are difficult to reconstruct: Traditional RAN algorithms are rule-based and auditable, making their logic transparent and reproducible. By contrast, modern AI models, especially deep learning and generative approaches, embed decision logic in complex weight matrices, where the precise reasoning steps cannot be reconstructed. Post-hoc explainability methods provide only approximations, not complete causal transparency. This creates tension with regulatory frameworks such as the EU AI Act, which requires technical documentation, traceability, and user-understandable logic for high-risk AI in critical infrastructure. The NIS2 Directive and GDPR Article 22 add further obligations for traceability and meaningful explanation of automated decisions. If operators cannot show why an AI system in the RAN made a given decision, compliance risks arise. The challenge is amplified with autonomous agents (i.e., Agentic AI), where decisions emerge from adaptive policies and interactions that are inherently non-deterministic. For critical infrastructure, such as telecom networks, transparency is therefore not optional but a regulatory necessity. Opaque models may face restrictions or outright bans.
  • Explainability – Decisions must be understandable: Explainability means that operators and regulators can not only observe what a model decided, but also understand why. In RAN AI, this is challenging because deep models may optimize across multiple features simultaneously, making their outputs hard to interpret. The EU AI Act requires high-risk systems to provide explanations that are “appropriate to the intended audience,” meaning engineers must be able to trace technical logic. In contrast, regulators and end-users require more accessible reasoning. Without explainability, trust in AI-driven traffic steering, slicing, or energy optimization cannot be established. A lack of clarity risks regulatory rejection and reduces operator confidence in deploying advanced AI at scale.
  • Auditability – Decisions must be verifiable: Auditability ensures that every AI-driven decision in the RAN can be logged, traced, and checked after the fact. Traditional rule-based schedulers are inherently auditable, but ML models, especially adaptive ones, require extensive logging frameworks to capture states, inputs, and outputs. The NIS2 Directive and the Cyber Resilience Act require such traceability for digital infrastructure, while the AI Act imposes additional obligations for record-keeping and post-market monitoring. Without audit trails, it becomes impossible to verify compliance or to investigate failures, outages, or discriminatory behaviors. In critical infrastructure, a lack of auditability is not just a technical gap but a regulatory showstopper, potentially leading to deployment bans.
  • Human Oversight – The challenge of real-time intervention: Both the EU AI Act and the NIS2 Directive require that high-risk AI systems remain under meaningful human oversight, with the possibility to override or disable AI-initiated actions. In the context of O-RAN, this creates a unique tension. Many RIC-driven optimizations and DU/RU control loops operate at millisecond or even microsecond timescales, where thousands or millions of inferences occur daily. Expecting a human operator to monitor, let alone intervene in real time, is technically infeasible. Instead, oversight must be implemented through policy guardrails, monitoring dashboards, fallback modes, and automated escalation procedures. The challenge is to satisfy the regulatory demand for human control without undermining the efficiency gains that AI brings. If this balance cannot be struck, regulators may judge certain autonomous functions non-compliant, slowing or blocking their deployment in critical telecom infrastructure.

The upshot for telecom is clear. Even as generative and agentic AI move into SMO/Non-RT orchestration for intent translation or semantic compression, the time-scale fundamentals do not change. RT and sub-ms loops must remain deterministic, inspectable, and controllable, with human-governed, well-documented interfaces mediating any AI influence. The regulatory risk is therefore not hypothetical. It is structural. As generative AI and LLMs move closer to the orchestration and policy layers of O-RAN, their opacity and non-deterministic reasoning raise questions about compliance. While such models may provide valuable tools for intent interpretation or telemetry summarization, their integration into live networks will only be viable if accompanied by robust frameworks for explainability, monitoring, and assurance. This places a dual burden on operators and vendors: to innovate in AI-driven automation, but also to invest in governance structures that can withstand regulatory scrutiny.

In a European context, no AI model will likely be permitted in the RAN unless it can pass the tests of explainability, auditability, and human oversight that regulators will and also should demand of functionality residing in critical infrastructures.

WRAPPING UP.

The article charts an evolution from SON-era automation to today’s AI-RAN vision, showing how O-RAN institutionalized “openness + intelligence” through a layered control stack, SMO/NRT-RIC for policy and learning, RT-RIC for fast decisions, and CU/DU/RU for deterministic execution at millisecond to microsecond timescales. It argues that LLMs belong at the top (SMO/NRT-RIC) for intent translation and semantic compression, while lightweight supervised/RL/TinyML models run the real-time loops below. “ChatGPT-like” systems (i.e., founded on human-generated context) are ill-suited to near-RT and sub-ms control. Synthetic data can stress-test rare events, but it demands statistics that are aware of extremes and validation against real holdouts to avoid misleading inference. Many low-level PHY/MAC primitives (HARQ, coding/decoding, CRC, MMSE precoding, and SINR-based link adaptation) are generally close to optimal, so AI/ML’s gains in these areas may be marginal and, at least initially, not the place to focus on.

Most importantly, pushing agentic autonomy too deep into the stack is likely to collide with both physics and law. Without reversibility, logging, and explainability, deployments risk breaching the EU AI Act’s requirements for human oversight, transparency, and lifecycle accountability. The practical stance is clear. Keep RT-RIC and DU/RU loops deterministic and inspectable, confine agency to SMO/NRT-RIC under strong policy guardrails and observability, and pair innovation with governance that can withstand regulatory scrutiny.

  • AI in RAN is evolutionary, not revolutionary, from SON and Elastic RAN-style coordination to GPU-accelerated AI-RAN and the 2024 AI-RAN Alliance.
  • O-RAN’s design incorporates AI via a hierarchical approach: SMO (governance/intent), NRT-RIC (training/policy), RT-RIC (near-real-time decisions), CU (shaping/QoS/UX, etc.), and DU/RU (deterministic PHY/MAC).
  • LLMs are well-suited for SMO/NRT-RIC for intent translation and semantic compression; however, they are ill-suited for RT-RIC or DU/RU, where millisecond–to–microsecond determinism is mandatory.
  • Lightweight supervised/RL/TinyML models, not “ChatGPT-like” systems, are the practical engines for near-real-time and real-time control loops.
  • Synthetic data for rare events, generated in the NRT-RIC and SMO, is valid but carries some risk. Approaches must be validated against real holdouts and statistics that account for extremes to avoid misleading inference.
  • Many low-level PHY/MAC primitives (HARQ, coding/decoding, CRC, classical precoding/MMSE, SINR-based link adaptation) are already near-optimal. AI may only add marginal gains at the edge.
  • Regulatory risk: Deep agentic autonomy without reversibility threatens EU AI Act Article 14 (human oversight). Operators must be able to intervene/override, which, to an extent, may defeat the more aggressive pursuits of autonomous network operations.
  • Regulatory risk: Opaque/unanalyzable models undermine transparency and record-keeping duties (Articles 12–13), especially if millions of inferences lack traceable logs and rationale.
  • Regulatory risk: For systems affecting individuals or critical services, explainability obligations (including GDPR Article 22 context) and AI Act lifecycle controls (Articles 8–17) require audit trails, documentation, and post-market monitoring, as well as curtailment of non-compliant agentic behavior risks.
  • Practical compliance stance: It may make sense to keep RT-RIC and DU/RU loops deterministic and inspectable, and constrain agency to SMO/NRT-RIC with strong policy guardrails, observability, and fallback modes.

ABBREVIATION LIST.

  • 3GPP – 3rd Generation Partnership Project.
  • A1 – O-RAN Interface between Non-RT RIC and RT-RIC.
  • AAS – Active Antenna Systems.
  • AISG – Antenna Interface Standards Group.
  • AI – Artificial Intelligence.
  • AI-RAN – Artificial Intelligence for Radio Access Networks.
  • AI-Native RAN – Radio Access Network with AI embedded into architecture, protocols, and control loops.
  • ASIC – Application-Specific Integrated Circuit.
  • CapEx – Capital Expenditure.
  • CPU – Central Processing Unit.
  • C-RAN – Cloud Radio Access Network.
  • CRC – Cyclic Redundancy Check.
  • CU – Centralized Unit.
  • DU – Distributed Unit.
  • E2 – O-RAN Interface between RT-RIC and CU/DU.
  • eCPRI – Enhanced Common Public Radio Interface.
  • EU – European Union.
  • FCAPS – Fault, Configuration, Accounting, Performance, Security.
  • FPGA – Field-Programmable Gate Array.
  • F1 – 3GPP-defined interface split between CU and DU.
  • GDPR – General Data Protection Regulation.
  • GPU – Graphics Processing Unit.
  • GRU – Gated Recurrent Unit.
  • HARQ – Hybrid Automatic Repeat Request.
  • KPI – Key Performance Indicator.
  • L1/L2 – Layer 1 / Layer 2 (in the OSI stack, PHY and MAC).
  • LLM – Large Language Model.
  • LSTM – Long Short-Term Memory.
  • MAC – Medium Access Control.
  • MANO – Management and Orchestration.
  • MIMO – Multiple Input, Multiple Output.
  • ML – Machine Learning.
  • MMSE – Minimum Mean Square Error.
  • NFVI – Network Functions Virtualization Infrastructure.
  • NIS2 – EU Directive on measures for a high standard level of cybersecurity across the Union.
  • NPU – Neural Processing Unit.
  • NRT-RIC – Non-Real-Time RAN Intelligent Controller.
  • O1 – O-RAN Operations and Management Interface to network elements.
  • O2 – O-RAN Interface to cloud infrastructure (NFVI and MANO).
  • O-RAN – Open Radio Access Network.
  • OpEx – Operating Expenditure.
  • PDCP – Packet Data Convergence Protocol.
  • PHY – Physical Layer.
  • QoS – Quality of Service.
  • RAN – Radio Access Network.
  • rApp – Non-Real-Time RIC Application.
  • RET – Remote Electrical Tilt.
  • RIC – RAN Intelligent Controller.
  • RLC – Radio Link Control.
  • R-NIB – Radio Network Information Base.
  • RT-RIC – Real-Time RAN Intelligent Controller.
  • RU – Radio Unit.
  • SDAP – Service Data Adaptation Protocol.
  • SINR – Signal-to-Interference-plus-Noise Ratio.
  • SmartNIC – Smart Network Interface Card.
  • SMO – Service Management and Orchestration.
  • SON – Self-Organizing Network.
  • T-Labs – Deutsche Telekom Laboratories.
  • TTI – Transmission Time Interval.
  • UE – User Equipment.
  • US – United States.
  • WG2 – O-RAN Working Group 2 (Non-RT RIC & A1 interface).
  • WG3 – O-RAN Working Group 3 (RT-RIC & E2 Interface).
  • xApp – Real-Time RIC Application.

ACKNOWLEDGEMENT.

I want to acknowledge my wife, Eva Varadi, for her unwavering support, patience, and understanding throughout the creative process of writing this article.

FOLLOW-UP READING.

  1. Kim Kyllesbech Larsen (May 2023), “Conversing with the Future: An interview with an AI … Thoughts on our reliance on and trust in generative AI.” An introduction to generative models and large language models.
  2. Goodfellow, I., Bengio, Y., Courville, A. (2016), Deep Learning (Adaptive Computation and Machine Learning series). The MIT Press. Kindle Edition.
  3. Collins, S. T., & Callahan, C. W. (2009). Cultural differences in systems engineering: What they are, what they aren’t, and how to measure them. 19th Annual International Symposium of the International Council on Systems Engineering, INCOSE 2009, 2.
  4. Herzog, J. (2015). Software Architecture in Practice, Third Edition, Written by Len Bass, Paul Clements, and Rick Kazman. ACM SIGSOFT Software Engineering Notes, 40(1).
  5. O-RAN Alliance (October 2018). “O-RAN: Towards an Open and Smart RAN“.
  6. TS 103 982 – V8.0.0. (2024) – Publicly Available Specification (PAS); O-RAN Architecture Description (O-RAN.WG1.OAD-R003-v08.00).
  7. Lee, H., Cha, J., Kwon, D., Jeong, M., & Park, I. (2020, December 1). “Hosting AI/ML Workflows on O-RAN RIC Platform”. 2020 IEEE Globecom Workshops, GC Wkshps 2020 – Proceedings.
  8. TS 103 983 – V3.1.0. (2024)- Publicly Available Specification (PAS); A1 interface: General Aspects and Principles (O-RAN.WG2.A1GAP-R003-v03.01).
  9. TS 104 038 – V4.1.0. (2024) – Publicly Available Specification (PAS); E2 interface: General Aspects and Principles (O-RAN.WG3.E2GAP-R003-v04.01).
  10. TS 104 039 – V4.0.0. (2024) – Publicly Available Specification (PAS); E2 interface: Application Protocol (O-RAN.WG3.E2AP-R003-v04.00).
  11. TS 104 040 – V4.0.0. (2024) – Publicly Available Specification (PAS); E2 interface: Service Model (O-RAN.WG3.E2SM-R003-v04.00).
  12. O-RAN Work Group 3. (2025). Near-Real-time RAN Intelligent Controller E2 Service Model (E2SM) KPM Technical Specification.
  13. Bao, L., Yun, S., Lee, J., & Quek, T. Q. S. (2025). LLM-hRIC: LLM-empowered Hierarchical RAN Intelligent Control for O-RAN.
  14. Tang, Y., Srinivasan, U. C., Scott, B. J., Umealor, O., Kevogo, D., & Guo, W. (2025). End-to-End Edge AI Service Provisioning Framework in 6G ORAN.
  15. Gajjar, P., & Shah, V. K. (n.d.). ORANSight-2.0: Foundational LLMs for O-RAN.
  16. Elkael, M., D’Oro, S., Bonati, L., Polese, M., Lee, Y., Furueda, K., & Melodia, T. (2025). AgentRAN: An Agentic AI Architecture for Autonomous Control of Open 6G Networks.
  17. Gu, J., Zhang, X., & Wang, G. (2025). Beyond the Norm: A Survey of Synthetic Data Generation for Rare Events.
  18. Michael Peel (July 2024), The problem of ‘model collapse’: how a lack of human data limits AI progress, Financial Times.
  19. Decruyenaere, A., Dehaene, H., Rabaey, P., Polet, C., Decruyenaere, J., Demeester, T., & Vansteelandt, S. (2025). Debiasing Synthetic Data Generated by Deep Generative Models.
  20. Decruyenaere, A., Dehaene, H., Rabaey, P., Polet, C., Decruyenaere, J., Vansteelandt, S., & Demeester, T. (2024). The Real Deal Behind the Artificial Appeal: Inferential Utility of Tabular Synthetic Data.
  21. Vishwakarma, R., Modi, S. D., & Seshagiri, V. (2025). Statistical Guarantees in Synthetic Data through Conformal Adversarial Generation.
  22. Banbury, C. R., Reddi, V. J., Lam, M., Fu, W., Fazel, A., Holleman, J., Huang, X., Hurtado, R., Kanter, D., Lokhmotov, A., Patterson, D., Pau, D., Seo, J., Sieracki, J., Thakker, U., Verhelst, M., & Yadav, P. (2021). Benchmarking TinyML Systems: Challenges and Direction.
  23. Capogrosso, L., Cunico, F., Cheng, D. S., Fummi, F., & Cristani, M. (2023). A Machine Learning-oriented Survey on Tiny Machine Learning.
  24. Hubara, I., Courbariaux, M., Soudry, D., El-Yaniv, R., & Bengio, Y. (2016). Quantized Neural Networks: Training Neural Networks with Low Precision Weights and Activations.
  25. AI Act. The AI Act is the first-ever comprehensive legal framework on AI, addressing the risks associated with AI, and is alleged to position Europe to play a leading role globally (as claimed by the European Commission).
  26. The EU Artificial Intelligence Act. For matters related explicitly to Critical Infrastructure, see in particular Annex III: High-Risk AI Systems Referred to in Article 6(2), Recital 55 and Article 6: Classification Rules for High-Risk AI Systems. I also recommend taking a look at “Article 14: Human Oversight”.
  27. European Commission (January 2020), “Cybersecurity of 5G networks – EU Toolbox of risk mitigating measures”.
  28. European Commission (June 2023), “Commission announces next steps on cybersecurity of 5G networks in complement to latest progress report by Member States”.
  29. European Commission, “NIS2 Directive: securing network and information systems”.
  30. Council of Europe (October 2024), “Cyber resilience act: Council adopts new law on security requirements for digital products.”.
  31. GDPR Article 22, “Automated individual decision-making, including profiling”. See also the following article from Crowell & Moring LLP: “Europe’s Highest Court Compels Disclosure of Automated Decision-Making “Procedures and Principles” In Data Access Request Case”.