The “Roaming Coalition”, bringing together European competitive operators representing more than 70 million SIM cards, calls for sustainable conditions on the wholesale roaming market to enable fair competition as retail mobile roaming surcharges are scrapped.
The caps agreed today amongst Member States go against the underlying economics of operators at wholesale level, with a cap for data at 10€/GB on the wholesale market, while common existing retail offers have prices as low as 1€/GB.
A need for coherence between retail prices, wholesale caps and wholesale costs is supported by the Body of European Regulators in Electronic Communications (BEREC), in its recent opinion on the draft FUP act and sustainability of the abolition of retail roaming surcharges: “Retail price ≥ wholesale charge ≥ wholesale cost […] since Roam-like-at-Home (RLAH) necessitates that international roaming retail prices are set equal to domestic prices, entails that domestic retail prices in all EEA Member States should exceed wholesale roaming charges and at the same time the wholesale roaming caps should exceed the wholesale roaming costs”.
It can be seen from current retail offers on EU markets that the actual cost of supplying data at wholesale level is in fact much lower than claimed by the European Commission’s Impact Assessment, in particular for data. An International Telecommunications Union (ITU) report from 2015 shows that there are little justifiable additional costs, in practice, for the provision of international roaming compared to domestic roaming.
MVNO Europe has compiled figures comparing EU institutions wholesale caps proposals, the Commission’s impact assessment and retail domestic data pricing in 7 EU countries, namely Spain, Malta, Romania, Slovenia, Slovakia, Latvia and Bulgaria.
It is also essential to note that the shift to 4G-LTE means that the average price per GB will continue to decline sharply in the next years.
In this context, the Coalition welcomes and supports the draft report on the revision of the rules for wholesale roaming markets presented by the European Parliament Rapporteur MEP Miapetra Kumpula-Natri, as well as today’s agreement in Parliament on a glide path for data caps. The report proposes strong reductions of wholesale roaming caps, as well as a periodic review thereof, and contains an explanatory statement which correctly recognises the intrinsic connection between an extended retail Fair Use Policy and the level of wholesale roaming caps. In light of the Fair Use Policy proposals published on 26 September 2016, we consider that to ensure competition and end-user benefits, the wholesale roaming caps should be reduced to an even lower level.
Strongly reduced wholesale caps are essential to make it possible for European end-users to continue to use large data bundles, fully benefit from innovative services going forward, and take advantage of a European digital single market.
Please refer to the Roaming Coalition full position and MVNO Europe’s demonstration on retail data prices vs. proposals currently on the table.