Brussels, 2 August 2019 – MVNO Europe welcomes the ČTÚ’s draft of 5G spectrum auction terms through which it is seeking to bolster competition in the Czech Republic by enabling a fourth mobile network operator and imposing (MVNO) wholesale access obligations in the 700 MHz licenses.
MVNO Europe urges the ČTÚ to maintain and extend wholesale access (MVNO) obligations in the spectrum licenses in the final text of the tender, as this will enable competition on a market where shares secured by independent MVNOs (i.e. MVNOs whose shareholding is not (in full or in part) controlled by the three main Mobile Network Operators) remain limited. More particularly, MVNO Europe welcomes Annexes 2A and 2B of the draft as these address elements such as equivalent network quality, scope and coverage for MVNOs and the recognition of the concepts of Full-MVNO and MVNE (Enabler) – which (among others) are crucial for effective wholesale (MVNO) access.
Room for improvement
While it generally applauds the draft terms circulated by the ČTÚ, MVNO Europe has identified several elements that raise concerns and that would necessitate some improvements in the final version of the tender document. Three of them are listed below:
- Rather than being framed in terms of enabling the provision of ‘high-speed Internet access’, the wholesale access obligation should be more generic (or at least refer to ‘mobile data’) in order to enable MVNO/MVNEs to use the wholesale access for other purposes (e.g. Internet of Things (IoT) and specialised services for industries (e.g. factories, connected vehicles), devices (laptops, tablets, AR glasses), education (e.g. campuses), and the public sector (e-health) .
- The requirement to publish a reference offer for Full MVNO/MVNE access is welcome, but its provisions, and contract negotiation provisions, seem to allow in practice a time lag (possibly of many months) between the spectrum holder launching its own services, and enabling an MVNO to effectively launch its own retail or wholesale services. Time lag/technology lag has been a factor holding back MVNOs in the Czech Republic and elsewhere in the past and has seriously damaged competition (and thereby end-users’ interests). The ČTÚ should make sure that time lags are avoided by enabling simultaneous launch of services by the Host network operator and MVNOs/MVNEs.
- The ČTÚ should extend wholesale access obligations to 3400-3600 MHz spectrum or at least include an opportunity for bidders to make a voluntary commitment to renew and extend wholesale access across all their spectrum holdings. A reward (e.g. in terms of lower spectrum fees) could be given to operators making such commitments.
Relationship with three-criteria test and Significant Market Power regulation
In parallel with the Czech spectrum tender terms, MVNO Europe encourages the ČTÚ to continue its efforts to ensure (by means of regulatory intervention where justified) a competitive Czech electronic communications market that serves end-users (both Business-to-Consumer and Business-to-Business – including public sector) interests. MVNO Europe generally agrees with the ČTÚ’s findings on the three-criteria test for the wholesale mobile access market, and agrees with the ČTÚ that the European Commission’s assessment of the ČTÚ’s findings is unsound. In particular, there is a need to recognise the objective reality, which is that alternative brands in the Czech Republic are mostly controlled by the Mobile Network Operators (in particular by O2) and that truly independent MVNOs have only achieved a very small market share to-date. Therefore, further regulatory intervention is needed to make the market genuinely competitive. If the ČTÚ is to ameliorate the current condition of the Czech electronic communications market (which is characterised by among the highest prices and the lowest mobile data allowances in the EU), it should consider efficient measures which – among other things – will enable Full MVNOs/MVNEs to become genuine competitors.
Brussels, 2 April 2019 – MVNO Europe welcomes the addition of Welcome Italia. Active on both the fixed and mobile markets, Welcome Italia positions itself as one of the best Italian telecommunications service providers for business customers.
MVNO Europe is delighted to expand its membership with the addition of Welcome Italia – an operator focused on providing best-in-class services to business customers. Operating on the fixed market since 1999, Welcome Italia launched its mobile services in April 2018 under the name Vianova Mobile. With this move, Welcome Italia aims to integrate and maximize the potential of fixed-line and mobile networks, Wi-Fi, Private Branch Exchange and smartphones. As with many other MVNOs, Welcome Italia is designed to quickly and smoothly adapt to its clients’ ever-changing needs.
MVNO Europe looks forward to helping Welcome Italia further develop its MVNO activities. Together MVNO Europe and Welcome Italia will seek to progress towards fair and non-discriminatory network access conditions for MVNOs – regardless of the technology – in Italy and other EU countries. In parallel, with Welcome Italia among its members, MVNO Europe will keep fighting for the reduction of regulated wholesale roaming charges in the EU in order to enable MVNOs to increase competition on European markets and thereby benefit end-users.
Jacques Bonifay, chairman of MVNO Europe, warmly welcomed the new member “who will help the association to achieve a vibrantly competitive market, which remains the best tool to promote innovation, cross-border solutions and take-up of services by users.”.
Brussels, 15 January 2019 – MVNO Europe keeps growing with the addition of sipgate Wireless. Together with its affiliate sipgate GmbH, sipgate Wireless offers integrated mobile and fixed solutions to businesses and consumers.
MVNO Europe is pleased to further expand by welcoming sipgate Wireless among its members. Based in Düsseldorf and active in Germany for more than nine years, sipgate Wireless operates as a full MVNO. Its very high-quality mobile solutions are marketed by its affiliate Sipgate GmbH to serve both businesses and consumers using the brands “sipgate team” and “simquadrat”. With better telephony as declared goal, sipgate Wireless distinguishes itself by offering transparent and personalized services to its customers.
With sipgate Wireless among its members, MVNO Europe will keep fighting to eliminate all the existing barriers that prevent MVNOs from competing and innovating on European markets. Above all, and especially in light of the emergence of 5G technologies, this implies securing fair and non-discriminatory network access conditions for MVNOs in all European countries. In parallel, in order to fulfil the needs of telecommunications customers, MVNO Europe and sipgate Wireless will work together on reducing EU wholesale roaming caps as well as on finding common grounds with some handset manufacturers on technical issues.
Jacques Bonifay, chairman of MVNO Europe, said that “with 5G auction procedures approaching in several European countries, if we are to secure a regulatory landscape allowing for competition, innovation and benefiting all end-users, it is of utmost importance to guarantee that MVNOs have fair network access”.
Brussels, 07 January – MVNO Europe starts the new year with the addition of freenet Group. As the mother company of three MVNOs in Germany – namely mobilcom-debitel, callmobile and klarmobil – representing 12 million subscribers, the freenet Group offers a wide array of services on mobile and TV markets.
MVNO Europe is delighted to welcome its first German member. The freenet Group, operating online, via 570 own shops and several thousand distribution outlets throughout Germany, offers high-quality post-paid contracts and pre-paid offers for mobile communications. The freenet Group also provides state-of-the-art digital IPTV entertainment and terrestrial TV services. In parallel, the freenet Group develops innovative digital applications that relate to home automation and security, energy, data security, and infotainment.
In view of the wholesale agreements the freenet Group has with the three German MNOs, its well-established presence on the German market (i.e. around 12 million mobile subscribers) as well as the regular exchanges it has with the authorities like Bundesnetzagentur and Bundeskartellamt, MVNO Europe believes that the new member will help the association make progress towards fair and non-discriminatory network access conditions – regardless the technology – in Germany. The new member will also bolster MVNO Europe’s efforts to make wholesale roaming prices reduced in a way that truly benefits consumers and businesses within the EU.
Jacques Bonifay, chairman of MVNO Europe, expressed his satisfaction “to have a member with prominent presence in the biggest European country and that will allow MVNO Europe to make its voice heard more legitimately on crucial innovation and competition issues”.
Brussels, November 2018 – MVNO EUROPE welcomes the European Parliament‘s assessment work on the impact of Roaming-Like-At-Home (RLAH) and calls on the European Commission to carefully examine the ITRE Committee in-depth study to swiftly reduce wholesale roaming regulated tariffs.
Last week, at the hearing organized by the European Parliament’s Industry Committee (ITRE), Michael Krammer, CEO of Ventocom (member of MVNO Europe), explained to Members of the European Parliament (MEPs) and to the European Commission to what extent Mobile Virtual Network Operators’ business has been affected by the special wholesale regime accompanying the end of retail roaming surcharges within the EU/EEA. While praising the advantages gained by consumers, Michael Krammer underlined the huge cost incurred by MVNOs as a result of the explosion of roaming traffic (+100%), in particular data usage. Given that MVNOs do not own their own network, as opposed to MNOs, MVNOs cannot offset those costs by trading wholesale roaming to other operators (while MNOs are able to do it). In parallel, MVNOs do not have the same ability to negotiate competitive wholesale prices as MNOs do. This problem is worsened by the fact that regulated wholesale caps remain substantially above retail prices. As a result, in Austria, but also in many other European countries, MVNOs are forced to sell roaming to their customers at a loss and to pay wholesale roaming prices that are 50% higher than those MNOs pay to each other. The resulting effect is that MVNOs are at a disadvantage, which undermines their ability to fully play their role in boosting competition on telecom markets as they always did.
MVNO Europe is glad to observe that the Body of European Regulators for Electronic Communications (BEREC), the European Consumer Organisation (BEUC), and several MEPs are aware and recognize the need for the European institutions to deal with this abnormal situation on wholesale markets in order to make the Roaming-Like-At-Home regime a success in the long term for both operators and end-users (consumers and business users). The Chair of the hearing, MEP Paul Rübig (EPP, Austria) even declared that “the next European Digital Commissioner will have to demonstrate that roaming matters will remain central during his/her term”.
Both the positive and side effects produced by one year of implementation of the RLAH regime have been further assessed by the European Parliament Research Services (EPRS) in the recently in-depth study titled “Roaming: One Year After Implementation”. The study finds that wholesale roaming caps are at least 10x higher than the real cost of providing wholesale roaming services. In order to “fix” wholesale markets’ roaming problems, the report recommends “lowering of the wholesale cap for international mobile”, “enabling permanent roaming at a wholesale level for IoT application providers” and “sharing future 5G networks with open access to all service providers including MVNOs”. MVNO Europe believes that, if it is to achieve a European Digital Single Market, the European Commission has to seriously take into account these conclusions when it will conduct a review of the wholesale roaming market in 2019.