Brussels, 21 January 2026 – MVNO Europe, the association representing Virtual Mobile Network Operators, responds to the European Commission’s legislative proposal for a Digital Networks Act (DNA), raising concerns that several provisions risk undermining wholesale access to mobile networks and reducing competition across European mobile markets.
As a long-standing advocate for competition and innovation in the European telecoms ecosystem, MVNO Europe welcomes the retention of some key regulatory safeguards in the Digital Networks Act. In particular, we support the preservation of Article 32 (ex Article 52 of the European Electronic Communications Code), which maintains national authorities’ ability to attach pro-competitive conditions, including wholesale access obligations, to radio spectrum licences. This remains essential for ensuring effective competition and supporting innovation in mobile communications markets, including Internet of Things, Machine-to-Machine and connectivity services for vehicles.
However, MVNO Europe warns that raising the threshold for imposing wholesale access to mobile networks (Article 32(3)), and a European Commission veto over the introduction of pro-competitive and wholesale access conditions (Article 31(3)(6)(7)) raises serious concerns about weakening wholesale access to mobile networks. MVNO Europe also stresses that any future BEREC guidelines to be adopted in application of Article 32(3) must fully reflect the central role of wholesale access in sustaining competition and must not unduly limit national authorities’ ability to include wholesale access provisions as part of spectrum-related measures, in order to preserve market contestability.
In addition, MVNO Europe has serious reservations about the approach set out in Article 24 on spectrum licence duration, which establishes spectrum usage rights of unlimited duration in principle, a minimum of 40 years where it concerns harmonised spectrum for wireless broadband services, and principles for renewal of spectrum licences. By significantly locking in spectrum holdings over time, this proposal will weaken competitive pressure in mobile markets and ultimately distort investment incentives and dampen innovation.
MVNO Europe therefore urges the co-legislators to revise the provisions of Articles 24, 31 and 32 in order to continue to enable competition to thrive as the genuine driver of innovation.
MVNO Europe also expresses concern that the proposed Digital Networks Act (DNA) does not sufficiently reflect the specific needs of the M2M, IoT and connected vehicles sectors. The current text lacks clear and consistent definitions for M2M, IoT, and Connected Vehicles, leaving important regulatory ambiguities unresolved. Furthermore, the DNA does not introduce an explicit obligation on mobile network operators to support permanent roaming to support the cross-border nature of these sectors. MVNO Europe believes this omission represents a missed opportunity to strengthen Europe’s digital sovereignty and competitiveness and calls on these issues to be addressed during the legislative process to ensure the development of a truly integrated Single Market for these sectors.
MVNO Europe stands ready to engage constructively with EU institutions to help shape a Digital Networks Act that actually serves European consumers and business, fosters innovation and long-term competitiveness across Europe’s telecommunications ecosystem, with competition at its core.