The European Association of Full Mobile Virtual Network Operators (EAFM) welcomes the launch of the European Commission’s Digital Single Market Strategy. As innovative and cross-border mobile virtual operators, our members support this ambitious initiative aiming at making Europe a world leader in the digital economy. EAFM however strongly calls on the European Commission to ensure that the review of the regulatory framework for telecommunications ensures that all operators are able to compete, offering a wider range of diversified services for the full benefit of consumers and businesses.
The European Commission has stated on numerous occasions that telecommunications is the backbone of a genuine digital single market. We believe that allowing all market players to compete – including Mobile Network Operators (MNOs) but also smaller and more agile and cross-border Mobile Virtual Network Operators (MVNOs) – is crucial for the development of a healthy telecoms single market in the European Union.
MVNOs have positive effects for users and for investment where they are present. Full MVNOs in particular provide an important competitive stimulus, for the ultimate benefit of end-users. MVNOs buy airtime from host MNOs on the wholesale market, assuring the MNOs additional revenues which they can invest in radio access network infrastructure, without causing costly duplication of network assets.
We believe that the future telecoms framework must be in line with decisions taken in application of competition law. The European Commission enhanced Full MVNO access as a remedy in its recent decisions on 4 to 3 telecoms mergers in Austria, Ireland and Germany. Full MVNO access is considered a long-term solution (to monitored and reviewed) and is key to preserving competition, and needs to remain a focus in the regulatory framework for telecommunications.
Any undue focus on supporting large network operators, to the detriment of smaller and more agile operators, and/or continuing to permit high wholesale charges for international roaming, will seriously disadvantage MVNOs in their efforts to provide competitive international roaming. Fact is that EAFM members were the innovators, being the first providers of multi-country/multi number offers, and of inclusion of roaming destinations in the retail bundle. Any undue focus on supporting large network operators will also threaten MVNOs’ domestic market position as challengers of the telecoms incumbents, providing competitive prices and innovative services as first movers.
As the European Commission is launching its Digital Single Market Strategy, and its subsequent review of the telecoms framework, EAFM calls on the European Commission to create a more openly accessible market for all operators, in order to contribute to the growth of the fast-moving mobile communications sector, to ensure that consumers and business users have a wider range of diversified services to choose from and to develop competition on the retail mobile market to their benefit.
EAFM represents those companies that have negotiated Full-MVNO agreements with host MNOs. Our members in that sense have achieved commercial independence from their hosts, deploying their own network elements. EAFM was created in June 2012 and is currently composed of Liberty Global (incl. Virgin Media), EI Telecom (NRJ Mobile), Telenet, Transatel, Voiceworks and Cyta Hellas. Therefore, the activities of EAFM members span across more than 13 countries and serve millions of consumers who conscientiously choose more innovative services at attractive retail prices.