MVNO Europe

MVNO Europe

Rue de la Loi, 38
1000 Brussels, Belgium
Phone: +32 2 789 66 23
Email: info@mvnoeurope.eu

Navigation Menu

MVNO Europe invites the European Commission to take utmost account of the ITRE Committee’s in-depth study on the impact of the Roaming-Like-At-Home regime

MVNO Europe invites the European Commission to take utmost account of the ITRE Committee’s in-depth study on the impact of the Roaming-Like-At-Home regime

Posted by on Nov 30, 2018 in Uncategorized |

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.

Read More

MVNO Europe encourages the German Telecoms Regulator to impose MVNO access to 5G networks to ensure a fair and non-discriminatory telecoms market in Germany

MVNO Europe encourages the German Telecoms Regulator to impose MVNO access to 5G networks to ensure a fair and non-discriminatory telecoms market in Germany

Posted by on Nov 23, 2018 in Uncategorized |

Brussels, 22 November 2018 – Following the publication of the draft ‘5G’ spectrum auction terms by the German Federal Network Agency (‘the BNetzA’), MVNO Europe calls on the German regulator to impose wholesale network access requirements on radio spectrum licensees. In addition, we ask the BNetzA to further detail the internal-external non-discrimination principle it puts forward, and to ensure that it unambiguously has full power to intervene, notably in cases of clear discrimination between mobile networks’ own businesses and other services providers.

While regretting the lacking provisions making third service providers’ – and more particularly Mobile Virtual Network Operators (hereafter ‘MVNOs’) – access to future 2 GHz and 3,6 GHz networks mandatory, MVNO Europe welcomes the progress made by the BNetzA on the obligations for Mobile Network Operators (hereafter ‘MNOs’) to cooperate in the development of a modern infrastructure. More specifically, MVNO Europe lauds the new negotiation requirements MNOs will have to comply with when it comes to service provider access, national roaming and infrastructure sharing. Similarly, MVNO Europe welcomes the BNetzA’s ability to arbitrate disputes and – where necessary – impose fines on operators infringing the non-discrimination principle.

The obligation for MNOs to cooperate in the expansion of 5G networks in Germany and BNetzA’s new capabilities can contribute to ensuring that German mobile operators do not obstruct competition and innovation. Obstruction to economic developments will be avoided only if the concept of internal-external non-discrimination is further clarified in the licence terms (e.g. by including the definition of the Advisory Council in Recital 499) and if BNetzA’s related fines and sanctions are readily applied. It is imperative that BNetzA unambiguously has full power to intervene on both technical and commercial aspects of wholesale network access.

Until now, the three incumbent German MNOs have made clear they have no intention of enabling non-discriminatory wholesale access to their networks, or to support industrial and Internet of Things (IoT) ecosystems. Many MVNOs, as well as industrial companies, willing to develop 5G networks and services, see their commercial and innovation potential curtailed, due to that fact that fit-for-purpose wholesale access to 4G is hampered by these MNOs. MVNO Europe believes that behaviour is detrimental not only to consumers’ interests but also to businesses of all sizes. Therefore, MVNO Europe hopes to mitigate the replication of such a situation with the development of 5G.

Jacques Bonifay, Chairman of MVNO Europe underlined that “fair and non-discriminatory access to 5G technologies for small operators and MVNOs is the only way to further advance German industrial and consumer interests. This is essential for boosting innovation and competition on both telecom consumer and business markets”.

Read More

German Telecoms Regulator should ensure MVNO access to 5G networks on its territory

German Telecoms Regulator should ensure MVNO access to 5G networks on its territory

Posted by on Aug 2, 2018 in Uncategorized |

industry-3087393_960_720

Brussels, 2 August 2018 – Following-up on the hearing of 13 July on the forthcoming auction for 2 GHz and 3,6 GHz radio spectrum held by the German Federal Network Agency (hereafter ‘the BNetzA’), MVNO Europe calls upon the German regulator to provide for mandatory wholesale network access requirements on radio spectrum licensees, or to structurally encourage participants in the German 5G spectrum assignment proceedings to formally commit to offering credible wholesale network access.

Until now, the three incumbent German Mobile Network Operators (hereafter MNOs) – namely Telekom Deutschland, Vodafone and Telefónica Deutschland – made clear they have no intention of enabling non-discriminatory wholesale access to their networks, or to support industrial and Internet of Things (IoT) ecosystems. Many Mobile Virtual Network Operators (hereafter MVNOs), as well as industrial companies willing to develop 5G networks and services, see their commercial and innovation potential curtailed, due to that fact that fit-for-purpose wholesale access to 4G is prevented by these MNOs. MVNO Europe believes that the behaviour of incumbent German operators runs counter to enabling competition and innovation. This is therefore detrimental to consumers’ interests as well as businesses of all sizes.

In this regard, MVNO Europe objects to the claims made by incumbent MNOs at the 13 July hearing, stating that there would be no basis in German or EU law to impose wholesale access obligations as part of radio spectrum licensing proceedings. In fact, in German law, § 60 and 61 of the Telekommunikationsgesetz enable both radio spectrum auctions and tender procedures to be accompanied by pre-conditions – such as the obligation for prospective licensees to commit to provide wholesale access to MVNOs, national, roaming, etc. At the European level, Article 5 of the EU Radio Spectrum Policy programme – which requires Member States to take competition issues into consideration and allows them to impose pro-competitive conditions when granting spectrum access rights – was formally approved by all EU governments in 2012 and is therefore binding. Moreover, similar possibilities and requirements are enshrined in the provisional final text of the European Electronic Communications Code, soon to be adopted.

Therefore, MVNO Europe understands that the BNetzA is required to give reasoned consideration to potentially mandating wholesale network access as part of the 2 GHz and 3,6 GHz spectrum licensing proceedings.

Jacques Bonifay, Chairman of MVNO Europe expressed “concerns that cementing the current market structure would endanger German industrial interests as well as impede both innovation and competition on consumer and business markets.” He further added that “such a market evolution may prevent the emergence of pan-European and global 5G-based services delivered by European companies, given that it will be impossible to ‘scale-up’ in Europe if Germany cannot adequately be served”.

MVNO Europe members are prepared to pay a fair price for wholesale access, in a manner that will not only allow MNOs to make a fast and reasonable return on 5G investment, but also enable innovative developments fully capitalising on new network technologies.

Read More

MVNO Europe welcomes BEREC’s report on the effects of mobile mergers on retail market prices

MVNO Europe welcomes BEREC’s report on the effects of mobile mergers on retail market prices

Posted by on Jun 26, 2018 in Uncategorized |

SuperclusterBrussels – MVNO Europe welcomes BEREC’s study report on mobile post-merger prices and quality in Austria, Ireland and Germany and calls upon national authorities in charge of radio spectrum to further consider independent Mobile Virtual Network Operators (MVNOs) when granting radio spectrum licences and seeking credible remedies in telecom consolidation proceedings.

In light of the several mergers and acquisitions that took place in recent years on telecommunications markets and being aware that such economic developments can have a significant effect on market structures and competitive dynamics, the BEREC investigation found that, in all three cases, retail prices increased after the merger. In other words, the merger procedures negatively affected mobile end-users, made them pay more than they used to for their mobile subscriptions and created a need for counterbalancing measures.

Only focusing on behavioural remedies, the study concludes that granting access to MVNOs can be effective redress solutions to the 4-to-3 mobile mergers– like in the Austrian 2013 Hutchison/Orange merger. However, the BEREC underlines that it may take substantial time for such a remedy to produce results. This observation seems logical as, for two of the three cases analysed, data was available only for one and a half years after the merger.  Therefore, only short- to medium-run effects could be estimated.

As developing an MVNO business – like the development of any other business – requires a minimum of time, MVNO Europe invites the BEREC to perform additional ex-post analysis three to five years after merger operations. After such a period of time, the remedy effects of MVNOs on competition and market prices will become much more visible.

In light of the advent of 5G, it is indispensable that entry barriers to the market and access to new network technologies are facilitated for MVNOs – be they light or full MVNOs – so that they can truly provide end-user benefits through state-of-the-art innovation in areas such as the Internet of Things and high-speed Internet. More precisely, as far as MVNO Europe members are concerned, ideal remedies to ensure maximum MVNO countervailing effects on the market appear to be a combination of:

  1. Full MVNO access mandated on the Mobile Network Operator(s) concerned (e.g. as part of radio spectrum licensing or merger proceedings)
  2. Long-term, predictable and competitive wholesale access / traffic conditions and
  3. Structural commitments boosting the MVNOs’ customer base towards critical mass (e.g. by requiring merging MNOs to sell part of their customer base, and part of their sub-brands or shops, to a remedy taker MVNO).
Read More

MVNO Europe engages in constructive dialogue with Commissioner Gabriel on removing obstacles for MVNOs to compete

MVNO Europe engages in constructive dialogue with Commissioner Gabriel on removing obstacles for MVNOs to compete

Posted by on May 31, 2018 in Uncategorized |

Gabriel CommBrussels – On Tuesday 29th of June, MVNO Europe members had the pleasure to meet with the European Commissioner for the Digital Economy and Society, Mariya Gabriel. The association and the Commission had a constructive discussion on the future of the Digital Single Market and, more particularly, on how to overcome European barriers to the successful development of the Internet of Things (IoT), 5G and the wholesale roaming market.

Representatives from Cubic Telecom, Euro Information Telecom, Fastweb, Sky and Transatel attended the meeting to show the Commission the extent to which MVNOs are at the forefront of several market segments (i.e. IoT, 5G, mobile bundles and fixed, mobile, media, financial services integration) addressing consumers, businesses, and the public sector. European MVNOs represent +/- 10% of EU SIM cards, approach 25% of market shares in some EU Member States and have developed partnerships with major industrial players – including large car manufacturers.

However, available data shows that MVNOs still sometimes face access-to-the-network barriers, in particular in Germany, that fragilize their ability to innovate and create growth. As a result, the association called upon the Commission for EU policies allowing MVNOs to compete in all European telecom markets, and thereby enable consumers to obtain access to highly-developed technologies at fair prices. MVNO Europe believes that an appropriate legal, regulatory and political landscape is key to the full completion of the Digital Single Market.

More precisely, what MVNO Europe would like to see is a fair and balanced regulatory environment that ensures MVNOs are not withheld from 5G and IoT technological developments as well reduced wholesale roaming caps (set by EU Regulation 2017/920, which is subject to review in 2019) so that challenger operators can continue delivering competitive offers and high-quality services.

Jacques Bonifay, Chairman of MVNO Europe, expressed his “satisfaction to have the opportunity to discuss with Commissioner Gabriel about the successful developments of European IoT MVNOs worldwide as well as some of the concerning difficulties smaller players face in accessing certain European markets.

MVNO Europe thanks Commissioner Gabriel and her team for taking the time to consult with the representatives of MVNOs in Europe and remains available to provide the European Commission with expertise so as to make the European Union’s commitments in implementing a competitive and innovative digital single market a reality.

Read More