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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 |


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.

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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).
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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.

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Legislators should not lose sight of correcting discriminatory wholesale roaming charges despite progress on EECC

Legislators should not lose sight of correcting discriminatory wholesale roaming charges despite progress on EECC

Posted by on Feb 8, 2018 in Uncategorized |

Legislators make welcome progress on pro-competitive radio spectrum aspects of the draft European Electronic Communications Code, but high wholesale roaming charges are still hurting MVNOs and damaging competition for mobile services.

press release roaming photo

During the last trialogue meeting on the European Electronic Communications Code on 1 February 2018, the EU co-legislators made good progress by provisionally agreeing on a block of key provisions for radio spectrum and mobile telecommunications. MVNO Europe, the association of Mobile Virtual Network Operators, particularly welcomes the provisional agreement on Article 52, which confirms the promotion of competition as a guiding principle of radio spectrum assignment procedures.

However, European MVNOs and their ability to act as competitive challengers, are still very much hurt by extremely high wholesale roaming charges that have a strong discriminatory effect in the provision of roam-like-at-home (“RLAH”) services. For instance, a recent report by the French telecom regulator ARCEP[1] demonstrates that in France Mobile Network Operators where able to recover most of the losses incurred in implementing RLAH, because of the additional inbound roaming traffic that generated substantial extra revenues for them. MVNOs, by contrast, are not able to earn such revenues at all.

“When it comes to international roaming, MVNOs continue to be unjustifiably discriminated by EU Regulation on tariffs” said Innocenzo Genna, Vice-President of MVNO Europe. “MVNOs cannot offset any loss on outbound roaming traffic by relying on revenues from increased inbound roaming traffic, because of their virtual nature that impedes them to collect wholesale roaming revenues”. Thus: “MVNOs urge the European Commission to review as soon as possible the level of wholesale roaming charges contained in the EU regulation, and reduce them to put an end to this unfair discrimination, which harms competition and end-user interests, not only for consumers and business users of traditional mobile services, but also impedes the development of the Internet of Things” Genna continued.

MVNO Europe expects BEREC and National Regulatory Authorities to provide input to the European Commission during 2018, which should lead to a justifiably much lower level of wholesale roaming charges.

In addition, MVNO Europe expects EU Member States to duly implement the competition principle introduced in the upcoming European Electronic Communications Code by embedding an obligation to provide wholesale access to MVNOs in future spectrum licenses “Such an obligation would finally provide MVNOs with the necessary bargaining power when negotiating with network operators and, consequently, it would dramatically increase competitive conditions in mobile retail markets” said Federico Poggi from Fastweb and Vice-President of MVNO Europe.


[1] Les services de communications électroniques en France – 3ème trimestre 2017 – 11 January 2018

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MVNO Europe kicks off new year with election of experienced and revamped board

MVNO Europe kicks off new year with election of experienced and revamped board

Posted by on Feb 5, 2018 in Uncategorized |


Brussels – MVNO Europe looks forward to the new and old challenges the new year will bring to us. To meet those challenges, a revamped board has been (re-)elected that combines the best elements of both old and new.

Jacques Bonifay (Transatel) and Innocenzo Genna (CoopVoce) have been re-elected as President and Vice-President respectively to provide hard earned experience and ensure continuity within the association, allowing it to build on the work done in the previous years. Federico Poggi (Fastweb) and Lukas Jankauskas (Teledema) have been elected as new Vice-Presidents, inducing an exciting new vibe in the association and expanding its representativeness throughout Europe. “The association will seek to expand even further to strengthen its unique position as unified voice of all European MVNOs”, says Lukas Jankauskas.

The year 2018 will be of major importance for MVNOs. The EECC (European Electronic Communications Code) will be finalized and its provisions are crucial for guaranteeing fair market access conditions for MVNOs. “Fair access conditions to all EU markets is the only way to ensure a competitive balance between all operators throughout the European Union, for the benefit of innovation and consumer welfare”, says Innocenzo Genna. “Even more so, it would provide (new) European players with the opportunity to become genuine world leaders, extending their business even beyond EU borders”, says Jacques Bonifay, “especially since more and more MVNOs are developing in the IoT (Internet of Things) space, which creates new business perspectives”. Federico Poggi concludes that “2018 will also be the year in which the first 5G global standards emerge, the first step towards concrete 5G developments. MVNO Europe will continue to stress the vital role that MVNOs will have in future 5G markets”.

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End of roaming: unexpected side effects for consumers, business users and operators?

End of roaming: unexpected side effects for consumers, business users and operators?

Posted by on Jun 14, 2017 in Uncategorized |


Brussels, June 2017 –  As of June 15, mobile users in Europe will in principle be able to “roam-like-at-home”, under the EU new rules which abolish mobile roaming surcharges across the Union. MVNO Europe has always strongly supported the policy objective of “roam-like-at-home”, and its members are looking forward to offering roaming free offers to their customers. Yet, there might be unexpected side effects for consumers, business users and operators as wholesale regulated roaming caps still remain too high and could lead to competitive unbalances on the markets. Unfortunately, in this context we will not be surprised to see a number of operators applying and qualifying for derogations.

After years of intense negotiations, on the 15th of June, “roam-like-at-home” (RLAH) will come into force across the European Union. MVNO Europe has always strongly supported this policy objective of the European Commission and as MVNO Chair, Jacques Bonifay indicated “MVNOs have always played a crucial role in the past to reduce roaming costs for consumers and enterprises. The principle of offering RLAH is in MVNOs’ DNA.” Our members are ready to offer roaming to their customers at national prices, and many have already launched attractive RLAH offers in their respective markets.

However, we believe that in order to ensure fair market conditions for all players, the end of roaming needed to be accompanied by a strong decrease of wholesale roaming caps so as to better reflect the actual cost of international roaming. “Reducing wholesale caps is a simple measure that works to enable all operators to compete” said J. Bonifay. Today, RLAH is implemented with wholesale caps that are still too high compared to national wholesale pricing for most players in national markets and could cause significant problems for some operators. MVNO Europe has repeatedly flagged this risk to the European Institutions.

In this context, MVNO Europe will not be surprised to see in the future a number of operators applying, and qualifying for a derogation to the application of “roam-like-at-home”, the so-called “sustainability mechanism”, or even see national prices rise in some markets.

Our Vice-President Innocenzo Genna indicated “MVNOs are ready to punctually launch the RLAH regime. However, as we pointed out during the legislative process, the entire mechanism, in particular the wholesale caps, must be strongly revised to eliminate competitive unbalances that, at the end, would be detrimental for the consumer in terms of tariffs, variety of offers and innovation”.

As an association, we call for the European Commission to conduct an in-depth analysis of the impact of the end of roaming surcharges on all market segments, including Internet of Things (IoT), ahead of the launch of the review of the wholesale roaming caps planned for December 2019 and ensure that the regulated caps reflect actual costs.

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