Brussels, 14th of April 2025 – MVNO Europe welcomes BEREC’s Opinion on the EU Roaming Regulation Review, and urges the European Commission to adopt key proposals
MVNO Europe enthusiastically endorses BEREC Opinion dated 28 March 2025[1] on the forthcoming review of the EU Roaming Regulation[2], anticipated by 30 June 2025. BEREC’s Opinion represents a constructive step forward in addressing entrenched imbalances affecting MVNOs and fostering a more competitive, fair, and sustainable mobile market across the EU. BEREC’s recognition of the unique challenges faced by MVNOs – such as limited negotiating bargaining power, paying wholesale prices close to the regulated caps levels, and the absence of quality of service guarantees – validates the persistent concerns raised by MVNO Europe. Crucially, the BEREC Opinion highlights that while most MNOs secure wholesale roaming rates well below the caps, MVNOs often do not benefit from similar conditions, resulting in ongoing financial losses in the provision of “Roam Like At Home” (RLAH)
MVNO Europe is particularly encouraged by BEREC’s call for a significant reduction in wholesale roaming caps, aligning with the association’s long-standing advocacy. Current wholesale caps exceed the actual costs incurred by visited networks, and lowering them would restore competitive balance, mitigate systemic losses for MVNOs, and deliver more generous Fair Use Policy (FUP) allowances to end-users without compromising regulatory safeguards.
BEREC also underscores the pivotal role of MVNO Europe’s members’ in enabling seamless Machine-to-Machine (M2M) and Internet of Things (IoT) connectivity, including in-vehicle and cross-border use cases. However, MVNO Europe respectfully disagrees with BEREC’s conclusion that no further regulatory measures are currently needed in this area. MVNO Europe calls for a clear and harmonised regulatory framework for IoT, M2M, and connected cars services, including unequivocal wholesale access obligations for permanent roaming agreements. Such measures are essential to unlock the full potential of IoT-focused MVNOs, which are recognised by business partners like vehicle? car manufacturers, as European champions in delivering seamless, cross-border IoT connectivity.
In addition to recommending a redesign of the retail-level sustainability mechanism, BEREC’s opinion echoes MVNO Europe’s proposal for a pragmatic solution: introducing a wholesale-level sustainability mechanism, while lowering caps for the majority of the market to reflect actual cost levels.
As the European Commission prepares its review of the EU Roaming Regulation, MVNO Europe urges policymakers to seize this opportunity to deliver a more inclusive and sustainable internal market for mobile connectivity. MVNO Europe calls on the European Commission to include BEREC’s key proposals in its Review, and remains committed to collaborating with BEREC, the European Commission, and co-legislators to ensure the next phase of Roaming Regulation empowers competition and delivers tangible benefits to Europe’s consumers and ensure European businesses can thrive in a global Marketplace.
Quote from Alessandro Denaro, Policy Officer of MVNO Europe:
“We strongly support BEREC’s recognition that the current wholesale roaming framework does not fully serve competition or consumers. A substantial reduction in wholesale caps, the introduction of a wholesale-level sustainability mechanism, and the removal of unjustified restrictions on permanent roaming – for IoT, M2M and connected car services – would unlock innovation, strengthen Europe’s digital competitiveness, and enable MVNOs to continue delivering affordable, high-quality connectivity for consumers, businesses, and industry partners across the continent.”
________________________________________
[1] https://www.berec.europa.eu/en/all-documents/berec/opinions/berec-opinion-on-regulation-eu-2022612-on-roaming-on-public-mobile-communications-networks-within-the-union
[2] https://eur-lex.europa.eu/eli/reg/2022/612/oj