Brussels, 24 March 2022 – MVNO Europe’s members are glad that the Roam-Like-at-Home regime, which has largely benefited European consumers and business users, is being prolonged until 2032. MVNO Europe nevertheless regrets that co-legislators did not show more ambition by further lowering wholesale roaming caps as well as embracing innovation and the Internet of Things. The association calls on European legislators to closely monitor these elements once the revised rules enter into application and review the Regulation accordingly so as to ensure that it does not become too detached from market realities.

The revised Roaming Regulation, voted today in the European Parliament, set somewhat lower wholesale roaming caps. MVNO Europe regrets that co-legislators were not more ambitious and sees these new caps as unfairly disconnected from the actual underlying costs and also from retail prices in domestic mobile communications markets. In fact, the wholesale roaming caps adopted are higher than retail prices enjoyed by consumers today in many EU Member States. As data usage keeps growing exponentially, these caps risk creating competitive disadvantages for MVNOs and smaller operators. As a result, MVNOs will have more difficulties playing their role trying to contribute to a more vibrant market by increasing the level of competition to the benefit of European consumers and businesses.

MVNO Europe calls on co-legislators to closely monitor the way the situation evolves and take into account market developments, including the latest network and technological developments (e.g. efficiencies from additional spectrum becoming available, 5G-related equipment efficiencies, active antenna systems, etc.) and their impact on relevant cost structures. Future reviews should also account for the fact that roaming volumes are expected to increase continually.

While MVNO Europe is glad to see that these future reviews will not be conducted by way of delegated act (as originally proposed by the European Commission), the association believes that the pace at which reviews take place should be set to every three years. This recurrence is highly needed as, for example, one simply cannot wait until 2027 to have a wholesale cap at 1€/GB while the data collected by the Body of European Regulators for Electronic Communications data shows that operators were widely exchanging data traffic below that rate back in 2018.

Finally, MVNO Europe regrets co-legislators’ lack of vision to deliver on the Commission’s initial ambition to contribute to the development of the Internet of Things. Today’s regulation makes no material progress in this regard. The adopted text amounts to continuing to tolerate, and in fact encourage, artificial restrictions in case roaming access is sought for the purpose of IoT. EU legislators should strive to ensure that roaming access is not artificially restricted to traditional Machine-to-Machine (M2M) communications involving no human interaction component. Definitional issues should be surmounted in a manner that does not restrict innovation. The future review of the EU Roaming Regulation should actively promote competition in the delivery of seamless Pan-EU IoT connectivity, ensuring that the IoT market is effectively part of the European Single Market.