Brussels, 16 January 2022 – MVNO Europe welcomes 2023 with a set of priorities leading its work programme for the new year. The fair share debate, emergency communications, Roaming and BEREC work are on our agenda with the overall goal to promote innovation and fair competition in the telecom market, as well as to make sure that there is equivalent network access for MVNOs across all Europe.

Network investment contributions: In 2022, MVNO Europe published its position paper on the topic where we highlight the risks of a European Commission initiative potentially requiring payments from internet ecosystem participants for network investment. In 2023, we keep on actively following the debate, with the goal of making sure that MVNOs, which already contribute to network investments by purchasing wholesale services from MNOs, are not left apart from the discussions with the risk of incurring in higher costs that will benefit MNOs and distort competition vis-à-vis MVNOs.

Availability of emergency communications and network and handset compatibility with VoLTE: With the sunset of 2G and 3G networks, some handsets are not able to access emergency communications unless they are compatible with VoLTE, and some cars’ eCall systems may cease functioning properly. The issues, already largely problematic in the USA, where 2G and 3G sunset is more advanced, are being actively discussed (e.g. in the Radio Spectrum Policy Group). As MVNOs, we advocate for handset manufacturers and MNOs to remove any obstacle for end-users of MVNOs to have access to emergency calls.

Fair competition among MVNOs and MNOs in the retail market: In 2022, MVNO Europe welcomed the entry into force of the Digital Markets Act (DMA), especially its article 6.6 which requires gatekeepers to remove technical and other obstacles to the user’s freedom to switch and subscribe to different network providers.

With an effective implementation of the DMA, handset manufacturers such as Apple and other Vendors, would finally be forced to stop discriminating MVNOs and small operators which are not able to sign the carrier partner agreement with Apple and other Vendors because it includes unsustainable commercial obligations. In 2023, MVNO Europe will monitor the implementation of the DMA and keep on advocating for a fairer competition before the European Commission, BEREC and NRAs.

We are also looking forward to the review of the Radio Spectrum Policy Programme expected in 2023, with the goal to advocate for the importance to keep the pro-competitive provisions intact.

Roaming: In 2022, we welcomed the entry into force of the reviewed Roaming Regulation. However, we believe that the current wholesale roaming caps are too high and disconnected from market realities. We are looking forward to the revision of the Regulation in order to advocate for lower wholesale caps that would better guarantee a fairer competition in the market. MVNO Europe is also monitoring the potential expansion of the free roaming area to Ukraine and the Western Balkans.

BEREC: Finally we keep on actively following the work of the Body of European Regulators for Electronic Communications (BEREC). MVNO Europe regularly contributes to BEREC public consultations that are relevant to us, such as the ongoing consultation on the Draft BEREC Report on regulatory treatment of business services and the expected call for input on the Work Programme 2024. We are also looking forward to the expected publication of BEREC study on wholesale mobile access, to which some of our members contributed.

With this exciting agenda striving for innovation and fairer competition in the European telecom and IoT markets, we wish you all a good beginning of the year !