Are the IXPs actually critical infrastructure?
Over the past year, the peering LAN of MIX-IT, the largest internet exchange point in Italy carrying 2.5-3 Tbps of traffic, has experienced multiple outages. The longest lasted 34 hours, which I understand has set a new world record.
These incidents should clearly demonstrate to regulators that IXPs do not generally meet the criteria for critical infrastructure / essential entities, and this is a major issue now that all European countries are starting to implement the NIS 2 directive. Despite such a long outage, the sky has not fallen and nobody has even noticed it outside the circle of network operators commenting from the sidelines.
Indeed, in most european countries the local internet exchanges have not been automatically declared as critical infrastructure.
I have been saying for a long time that IXPs should shut down their network once per year just to show that everything will still work without them… This may be perceived as a joke, but the point is that while internet exchanges as a category are important and help to improve the quality of connectivity for their members, no single IXP is indispensable in itself for the Internet to work. During an outage the traffic will just move to other IXPs or transits and it is the responsibility of individual networks to implement appropriate redundancy.
On a related note, Italian IXPs exhibit a notable distinction when compared to most of their European counterparts: here three of the five largest internet exchanges also operate their own data centers and passive interconnection infrastructures (commonly known as meet-me rooms). While the peering LANs themselves are not critical infrastructure, the big meet-me rooms (in Italy those operated by MIX, NAMEX and Retelit) should unequivocally be considered as such.