COMMISSION STAFF WORKING DOCUMENT Accompanying the document Report from the Commission to the European Parliament and the Council on the review of the wholesale roaming market
Date: 2016-06-15
Institutions: Directorate-General for Communications Networks, Content and Technology, European Commission
Subjects: European Economic Area, consumer protection, mobile phone, price regulations, regulation of telecommunications, single market, telecommunications policy, telephone charges, transmission network, wholesale trade

EN 

   EN 

   EUROPEAN COMMISSION  Brussels, 15.6.2016  SWD(2016) 200 final   COMMISSION STAFF WORKING DOCUMENT Accompanying the document Report from the Commission to the European Parliament and the Council on the review of the wholesale roaming market {COM(2016) 398 final}  
 
 
COMMISSION STAFF WORKING DOCUMENT 
Accompanying the document 

Report from the Commission to the European Parliament and the Council 

on the review of the wholesale roaming market 

Table of Contents 

Table of Figures ...................................................................................................................................... 5 

Table of Tables ....................................................................................................................................... 7 

List of Acronyms .................................................................................................................................... 8 

1. 

INTRODUCTION .............................................................................................................................. 11 

2.  THE COMMISSION'S APPROACH TO THE REVIEW OF NATIONAL WHOLESALE MARKETS AND ITS 
LEGISLATIVE PROPOSAL ........................................................................................................................ 13 

2.1. 

Information and data gathering on wholesale and retail roaming markets ........................... 13 

2.2.  Analysis of the data ............................................................................................................... 14 

2.3. 

External study to estimate the costs of providing wholesale roaming services .................... 14 

2.4. 

Public consultation ................................................................................................................ 15 

2.5.  BEREC input ........................................................................................................................ 15 

2.6.  Commission's inter-service group ......................................................................................... 16 

2.7. 

The report on national wholesale roaming markets (this report) .......................................... 16 

2.8. 

Impact assessment for the Commission's legislative proposal .............................................. 16 

3.  OVERVIEW OF THE EU ROAMING REGULATIONS AND MARKET DEVELOPMENTS (2007-2015) ... 16 

3.1. 

Evolution of the EU Roaming Regulations (2007-2015) ...................................................... 16 

3.2. 

Evolution of wholesale and retail roaming prices (2007-2015) ............................................ 20 

3.2.1. 

Retail roaming prices .................................................................................................... 20 

3.2.2.  Wholesale roaming prices ............................................................................................. 22 

3.3. 

Evolution of roaming traffic in Europe ................................................................................. 24 

4.  COMPETITION DEVELOPMENTS IN RETAIL ROAMING MARKETS .................................................... 26 

4.1.  Description of the Commission's approach ........................................................................... 26 

4.1.1. 

Literature review ........................................................................................................... 26 

4.1.2. 

Questionnaires to operators and analysis of the data .................................................... 26 

4.2.  Market failures in retail roaming markets ............................................................................. 27 

4.2.1. 

Imperfect substitutes at the retail level .......................................................................... 27 

4.2.2. 

Lack of tariff transparency and bill shock ..................................................................... 29 

2 

 
 
 
4.2.3. 

Inelastic demand for roaming services for a significant proportion of the customer base
29 

4.3.  Domestic price level and consumption pattern ..................................................................... 31 

4.4.  A comparison of retail roaming and domestic traffic ........................................................... 31 

4.5.  Retail roaming offers ............................................................................................................ 35 

4.6.  Current technological developments as potential substitutes to roaming ............................. 36 

4.7.  Conclusion ............................................................................................................................ 39 

5.  ASSESSMENT OF THE COST OF PROVIDING WHOLESALE ROAMING SERVICES IN THE EEA ........... 40 

5.1. 

Introduction ........................................................................................................................... 40 

5.2.  Description of the Commission's approach ........................................................................... 40 

5.2.1. 

Questionnaires to NRAs and operators ......................................................................... 41 

5.2.2. 

External study to estimate wholesale roaming costs ..................................................... 41 

5.2.2.1.  The call for tenders ................................................................................................... 41 

5.2.2.2.  The objectives of the study ....................................................................................... 41 

5.2.2.3.  Consultation with NRAs and mobile operators ........................................................ 41 

5.3. 

Previous estimates of wholesale roaming costs .................................................................... 42 

5.4. 

The TERA Consultants cost model ....................................................................................... 42 

5.4.1. 

The approach followed by TERA Consultants ............................................................. 43 

5.4.2. 

High level assumptions in TERA's cost model ............................................................. 44 

5.4.2.1.  The choice of cost standard ....................................................................................... 44 

5.4.2.2.  The approach to cost modelling ................................................................................ 46 

5.4.2.3.  Estimation of network costs ...................................................................................... 47 

5.4.2.4.  Roaming-specific costs ............................................................................................. 54 

5.4.2.5.  Impact of seasonality ................................................................................................ 57 

5.4.2.6.  Total estimated wholesale roaming costs .................................................................. 59 

5.5. 

Termination rates .................................................................................................................. 60 

5.6. 

Transit costs .......................................................................................................................... 62 

5.7.  Comparison of the voice cost estimates derived from TERA's study against an alternative 
approach based on national mobile termination rates ....................................................................... 63 

5.8.  Cost estimates for SMS services ........................................................................................... 66 

5.9.  Conclusion on the costs of wholesale roaming services ....................................................... 67 

6.  DEGREE OF COMPETITION IN WHOLESALE ROAMING MARKETS ................................................... 68 

6.1.  Description of the Commission's approach ........................................................................... 69 

6.1.1. 

Literature review and previous studies ......................................................................... 69 

6.1.2. 

Questionnaire to operators and analysis of the data ...................................................... 69 

6.1.3. 

Public consultation ........................................................................................................ 70 

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6.2.  Market failures in wholesale roaming markets ..................................................................... 70 

6.2.1. 

Natural oligopoly structure, which fosters low intensity of competition ...................... 70 

6.2.2. 

Imperfect wholesale roaming substitutes ...................................................................... 71 

6.2.3. 

Double marginalisation and difficulties in coordination ............................................... 71 

6.2.4. 

Bilateral nature of wholesale roaming agreements ....................................................... 72 

6.2.5. 

Exclusion of MVNOs from wholesale roaming markets .............................................. 72 

6.3.  Overview of wholesale roaming agreements ........................................................................ 73 

6.3.1. 

Standard Roaming Agreements and roaming discount agreements .............................. 73 

6.3.2. 

Bilateral and unilateral roaming agreements ................................................................. 73 

6.3.3. 

Number of roaming agreements in each destination country ........................................ 74 

6.3.4. 

Pricing models .............................................................................................................. 74 

6.3.5. 

Permanent roaming ....................................................................................................... 75 

6.3.6.  Machine-to-Machine communications (M2M) ............................................................. 76 

6.4.  Description of the wholesale roaming market in the EU ...................................................... 77 

6.4.1.  Wholesale roaming traffic flows between Member States............................................ 77 

6.4.2.  Wholesale roaming traffic compared to retail domestic traffic ..................................... 79 

6.4.3.  Wholesale roaming payments and revenues balance .................................................... 82 

6.4.4.  Wholesale roaming prices  in the EU ............................................................................ 84 

6.5.  Degree of competition in national wholesale roaming markets ............................................ 87 

6.5.1. 

Operators' views of the functioning of the national wholesale roaming markets ......... 87 

6.5.2. 
roaming markets to enable RLAH in the EU ................................................................................ 90 

Operators' views about the ability of the current functioning of national wholesale 

6.5.3.  MVNOs' views of the functioning of the national wholesale roaming markets ........... 90 

6.5.4.  Wholesale roaming prices vs wholesale and retail domestic prices and underlying costs

91 

6.5.5. 

Presence of pan-European mobile operators ................................................................. 93 

6.5.6. 

Inside vs outside group roaming ................................................................................... 95 

6.5.6.1.  Steering roaming traffic inside the group.................................................................. 95 

6.5.6.2.  Inside vs outside group wholesale roaming prices .................................................... 96 

6.5.7. 

Competitive situation of operators with limited geographic scope ............................... 99 

6.6.  Conclusions ......................................................................................................................... 103 

7.  RLAH IN 2017 ............................................................................................................................. 104 

8.  CONCLUSIONS ............................................................................................................................. 105 

BIBLIOGRAPHY ............................................................................................................................... 108 

ANNEX 1: Existing 'Roam-Like-At-Home' (RLAH) offers .............................................................. 110 

ANNEX 2:  Wholesale roaming price paid and received ................................................................... 111 

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ANNEX 3:  Roaming traffic flows between countries ....................................................................... 112 

5 

 
 
 
 
 
Table of Figures 

Figure 1 - EEA average retail price per minute for intra-EEA roaming voice calls made ................... 20 
Figure 2 - EEA average retail price for intra-EEA outgoing SMS ....................................................... 21 
Figure 3 - EEA average retail price per MB ......................................................................................... 21 
Figure 4 - EEA average price per minute for wholesale non-group roaming voice calls ..................... 22 
Figure 5 - Average wholesale price per intra-EEA roaming SMS: charges to non-group companies .. 23 
Figure 6 - Average wholesale data price per MB (prepaid+postpaid), EEA average ........................... 23 
Figure 7 - Roaming traffic index: intra-EEA outgoing calls (Q3 2008=100) ....................................... 24 
Figure 8 - Retail SMS sent traffic index (Q3 2008=100)...................................................................... 25 
Figure 9 - Retail roaming data traffic index: (Q3 2008 = 100) ............................................................. 25 
Figure 10 - Intra-EEA retail roaming revenues as % of total retail revenues (x-axis) .......................... 32 
Figure 11 - Intra-EEA retail roaming traffic as % of total retail traffic (outgoing minutes) ................. 33 
Figure 12 - Intra-EEA retail roaming consumption as % of total retail consumption (outgoing SMS) 33 
Figure 13 - Intra-EEA retail roaming consumption as % of total retail consumption (data) ................ 34 
Figure 14 - Intra-EEA retail roaming revenues and volumes as % of total retail revenues and volumes 
(y-axis) by country, 2014 ...................................................................................................................... 35 
Figure 15. Steps in the estimation of costs in the TERA cost model .................................................... 47 
Figure 16: Re-allocation of costs not recovered through voice and SMS termination ......................... 48 
Figure 17: Example of re-balancing of costs with effective mobile termination rates ......................... 49 
Figure 18: TERA's cost estimates for voice origination after re-balancing for national MTRs under 
Scenario B (€c/min) .............................................................................................................................. 50 
Figure 19: TERA's cost estimates for data services (€c/MB) ............................................................... 50 
Figure 20: Comparison of TERA's voice origination costs against retail unit voice prices (€c/min) ... 53 
Figure 21: Comparison of TERA's data costs against retail unit data prices (€c/MB) ......................... 54 
Figure 22: Mark-ups on voice services for roaming-specific costs (€c/min) ........................................ 56 
Figure 23: Mark-ups on data services for roaming-specific costs (€c/MB) .......................................... 56 
Figure 24: Mark-ups on voice services for seasonality (€c/min) .......................................................... 59 
Figure 25: Total estimated wholesale roaming unit costs for voice origination (€c/min) .................... 60 
Figure 26: Total estimated wholesale roaming unit costs for data services (€c/MB) ........................... 60 
Figure 27: Fixed termination rates applicable in MS (S2 2015) – BU-LRIC rates in blue (€c/min) .... 61 
Figure 28: Mobile termination rates applicable in MS (S2 2015) – BU-LRIC rates in blue (€c/min) . 61 
Figure 29: Total estimated costs of wholesale roaming voice origination including the termination rate 
and transit costs (€c/min) ...................................................................................................................... 64 
Figure 30: Total estimated costs of wholesale roaming data services including transit costs (€c/MB) 64 
Figure 31: Comparison between the TERA-based estimated cost for wholesale roaming voice,an 
alternative approach to estimating costs for wholesale roaming voice, average wholesale roaming 
market price for unbalanced traffic (€c/min) ........................................................................................ 65 
Figure 32: Current wholesale roaming prices for SMS in MS (€c/SMS) ............................................. 67 
Figure 33 – Intra-EEA wholesale roaming (inbound) revenue as % of retail domestic revenue all 
services (x-axis) .................................................................................................................................... 79 
Figure 34 – Intra-EEA wholesale roaming (inbound) traffic as % of retail domestic traffic (x-axis) 
(outgoing voice) .................................................................................................................................... 80 
Figure 35 – Intra-EEA wholesale roaming (inbound) traffic as % of retail domestic traffic (outgoing 
SMS) ..................................................................................................................................................... 80 
Figure 36 – Intra-EEA wholesale roaming (inbound) traffic as % of retail domestic traffic (x-axis) 
(data) ..................................................................................................................................................... 81 

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Figure 37 – Intra-EEA wholesale roaming (inbound) revenues and traffic as % of retail domestic 
revenues and traffic (y-axis), 2014 ....................................................................................................... 82 
Figure 38 - Total intra-EEA wholesale roaming balance (revenues minus payments) as a % of total 
retail domestic revenues (x-axis), all services included ........................................................................ 83 
Figure 39 - Total intra-EEA wholesale roaming balance (revenues minus payments) as a % of total 
retail domestic revenues (y-axis), all services included, per country.................................................... 84 
Figure 40 - Average wholesale roaming prices for balanced and unbalanced traffic (inbound and 
outbound): voice services (2015) .......................................................................................................... 85 
Figure 41 - Average wholesale roaming prices for balanced and unbalanced traffic (inbound and 
outbound): SMS services (2015)........................................................................................................... 86 
Figure 42 - Average wholesale roaming prices for balanced and unbalanced traffic (inbound and 
outbound): data services (2015) ............................................................................................................ 86 
Figure 43 – Ratio inside group over outside group roaming volumes per operator and destination 
country (voice - outbound roaming traffic) ........................................................................................... 95 
Figure 44 - Ratio inside group over outside group roaming volumes per operator and destination 
country (SMS - outbound roaming traffic) ........................................................................................... 96 
Figure 45 - Ratio inside group over outside group roaming volumes per operator and destination 
country (data - outbound roaming traffic) ............................................................................................. 96 
Figure 46 – Ratio between inside group and outside group wholesale roaming unit prices per operator 
and destination country (voice - outbound roaming traffic) ................................................................. 97 
Figure 47 - Ratio between inside group and outside group wholesale roaming unit prices per operator 
and destination country (SMS - outbound roaming traffic) .................................................................. 98 
Figure 48 Ratio between inside group and outside group wholesale roaming unit prices per operator 
and destination country (data - outbound roaming traffic) ................................................................... 98 
Figure 49 – Average wholesale roaming price for unbalanced traffic vs operator size (voice - 
outbound traffic) ................................................................................................................................. 100 
Figure 50 – Average wholesale roaming price for unbalanced traffic vs operator size (SMS - outbound 
traffic) ................................................................................................................................................. 101 
Figure 51 – Average wholesale roaming price for unbalanced traffic vs operator size (data - outbound 
traffic) ................................................................................................................................................. 101 
Figure 52 - Difference between effective unit prices (payments/volumes) paid and received (data - 
outside group traffic) ........................................................................................................................... 102 
Figure 53 - Difference between effective unit prices paid and received (voice - outside group traffic)
 ............................................................................................................................................................ 111 
Figure 54 - Difference between effective unit prices paid and received (SMS - outside group traffic)
 ............................................................................................................................................................ 111 

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Table of Tables 

Table 1 - Regulatory measures introduced by the Roaming Regulations (2007-2016) ........................ 18 
Table 2: When travelling to another EU country, you generally... ....................................................... 28 
Table 3 - BEREC's estimations for upper bound, average and lower bound of wholesale costs for 
wholesale roaming services (2010) ....................................................................................................... 42 
Table 4 - BEREC's estimations wholesale costs for wholesale roaming services (2012) ..................... 42 
Table 5: Allowances included in the baskets of the study considered to estimate retail prices ............ 51 
Table 6: Country VAT rates used to derive domestic retail prices excluding VAT ............................. 51 
Table 7: Country retail prices using the relative prices of wholesale roaming prices........................... 52 
Table 8: Roaming-specific costs estimated by TERA .......................................................................... 55 
Table 9: Termination rate to be considered within the cost of originating a mobile roaming call 
(€c/min) ................................................................................................................................................. 62 
Table 10: Wholesale roaming services' cost estimates in each of the 29 countries considered in TERA 
Consultants' cost model......................................................................................................................... 68 
Table 11 - Inbound/Outbound ratio for roaming services: voice, data and SMS (in green values above 
150%, in blue values below 75%) ......................................................................................................... 78 
Table 12 - Presence of pan-European mobile operators ....................................................................... 94 
Table 13 - RLAH offers per country (add-ons are excluded), September 2015 ................................. 110 
Table 14 - Roaming voice traffic flow between countries in the second semester of 2014 ................ 112 

8 

 
 
 
 
List of Acronyms 

ARPM - Average Revenue Per Minute 

ARRPU - Average Retail Revenue Per User 

BEREC - Body of European Regulators in Electronic Communications 

DG CNECT - Directorate General for Communications Networks, Content & Technology 

EEA - European Economic Area 

EU - European Union 

EUR - Euro 

EUR/PPP - EUR/Purchasing Power Parity 

FUP - Fair Use Policy 

GB - Gigabyte 

GSM - Global System for Mobile communications 

GSMA - GSM Association 

HD - High Definition 

IA - Impact Assessment 

IMSI - International Mobile Subscriber Identity  

IOT - Internet of Things 

JRC - Joint Research Centre 

LBO - Local Break Out 

LTE - Long-Term Evolution 

MB - Megabyte 

MS - Member State 

MNO - Mobile Network Operator 

MTR - Mobile Termination Rate 

MVNO - Mobile Virtual Network Operator 

MWC - Mobile World Congress 

M2M - Machine to Machine 

NRA - National Regulatory Authority 

OECD - Organisation for Economic Co-operation and Development 

9 

 
 
OTT - Over-the-top 

VoIP - Voice over Internet Protocol 

Q1 - Quarter 1 

Q2 – Quarter 2 

Q3 - Quarter 3 

Q4 - Quarter 4 

RLAH - Roaming Like At Home 

SIM - Subscriber Identity Module 

SME - Small and medium-sized enterprises 

SMS - Short Message Service 

STIRA - Standard Terms for International Roaming Agreements 

US - United States 

VAT - Value-added tax 

VoIP - Voice over Internet Protocol 

VoLTE - Voice over Long-Term Evolution 

Wi-Fi - Wireless Fidelity 

3G - 3rd Generation 

4G - 4th Generation 

€c - euro cent  

Countries 

BE - Kingdom of Belgium 

BG - Republic of Bulgaria 

CY- Cyprus 

CZ - Czech Republic 

DK - Kingdom of Denmark 

DE - Federal Republic of Germany 

EE - Republic of Estonia 

IE - Ireland 

10 

 
 
 
EL - Hellenic Republic 

ES - Kingdom of Spain 

FR - French Republic 

HR - Republic of Croatia 

IS - Republic of Iceland 

IT - Italian Republic 

LI - Principality of Liechtenstein 

LV - Republic of Latvia 

LT - Republic of Lithuania 

LU - Grand Duchy of Luxembourg 

HU - Hungary 

MT - Republic of Malta 

NL - Kingdom of the Netherlands 

NO - Kingdom of Norway 

AT - Republic of Austria 

PL - Republic of Poland 

PT - Portuguese Republic 

RO - Romania 

SI - Republic of Slovenia 

SK - Slovak Republic 

FI - Republic of Finland 

SE - Kingdom of Sweden 

UK - United Kingdom of Great Britain and Northern Ireland 

11 

 
 
 
1.  INTRODUCTION 

In  October  2015  the  European  Parliament  and  the  Council  adopted  Regulation  2015/21201, 
which,  inter  alia,  amended  Regulation  531/20122  (hereinafter  Roaming  III  Regulation)  and 
entered  into  force  on  29  November  2015.  In  this  report,  the  Roaming  III  Regulation  as 
amended by Regulation 531/2012 is called the Roaming Regulation or simply the Regulation.  

The Regulation mandates the abolition of retail roaming surcharges in the EU from 15 June 
2017 (the Roam Like At Home – RLAH – regime), subject to fair usage of roaming services 
and  a  sustainability  clause.  With  the  establishment  of  the  obligation  to  charge  retail  roaming 
services  at  domestic  prices  (no  more  retail  roaming  surcharges)  subject  to  a  fair  use  of  these 
services, Regulation EU 2015/2120 has substantially defined a new retail regulatory regime for 
regulated roaming services: the roam-like-at-home (RLAH) regime.  

However,  while  retail  pricing  of  roaming  and  domestic  services  are  aligned  by  regulation,  the 
provision  of  retail  roaming  services  does  not  use  the  same  wholesale  inputs  as  retail  domestic 
services, in view of the fact that the provision of retail roaming service requires, by definition, the 
use of a different (visited) network.  

These wholesale roaming inputs are therefore to be bought in the market by the visiting operator. 
Wholesale  roaming  inputs  include  a  number  of  costs  specific  to  roaming  (i.e.  not  incurred  in 
providing  domestic  services),  such  as  roaming  operation  and  management  costs,  roaming 
financial and data clearing costs, roaming negotiation and contract management costs. In order to 
ensure  that the  retail  roaming  services  can be  provided  at  domestic  retail  prices, therefore,  it is 
necessary that wholesale roaming inputs are available at a price that makes generally possible for 
the visiting (home) operators the provision of RLAH, eventually subject to fair use and without 
prejudice  to  the  possibility  to  ask  for  a  sustainability  derogation  in  exceptional  circumstances, 
while at the same time ensuring that visited operators can recover the costs of provision of these 
services.  

The Regulation therefore mandates the Commission to review the wholesale roaming market 
by  15  June  2016,  with  a  view  to  assessing  measures  necessary  to  enable  abolition  of  retail 
roaming surcharges by 15 June 2017.  

On  the  one  hand,  with  regard  to  retail  roaming  regulation,  the  choice  to  establish  a  RLAH 
regime has been already taken by the co-legislators with Regulation 2120/2015; on the other 
hand the correct working of wholesale roaming market is a precondition for the achievement 
of the RLAH regime. Therefore the Commission has been entrusted with the specific task to 
review  the  wholesale  roaming  markets,  rather  than  the  evaluation  of  the  functioning  of  the 
entire Roaming III Regulation. The review of roaming wholesale market was carried out with 
a view to analyse the degree of competition in national roaming markets, any observable risk 
of  distortion  of  competition  and  investment  incentives  in  domestic  and  visited  markets  in 
order to assess the measures necessary to enable the achievement of the objective established 
by the co-legislators, i.e. the abolition of retail roaming surcharges by 15 June 2017. This was 
done  taking  into  account  the  need  to  ensure  that  the  visited  network  operators  are  able  to 
recover  all  costs  of  providing  regulated  wholesale  roaming  costs  and  the  need  to  prevent 
permanent  roaming  or  anomalous  or  abusive  use  of  wholesale  roaming  (Article  19  of  the 
Roaming Regulation).   

1 http://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=uriserv:OJ.L_.2015.310.01.0001.01.ENG&toc=OJ:L:2015:310:TOC  
2 http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32012R0531  

12 

 
 
                                                           
In line with this mandate, therefore, the aim of this report, together with its associated impact 
assessment, is not to review the entire functioning of the original Roaming III Regulation nor 
the RLAH obligation for which the wholesale review is actually a pre-condition, but is rather 
focused on the review of the wholesale roaming markets in the EU and to propose the most 
appropriate legislation at the wholesale level to ensure the success of the RLAH regime. In 
line with the mandate of the European Parliament and the Council set out in Article 19 of the 
Regulation, the focus of the Commission's assessment in this report is on: 

 
 
 

the developments in competition in the retail roaming markets (section 4); 
the costs of providing wholesale roaming services in the EU (section 5); and 
the degree of competition in national wholesale markets, including an assessment of 
the  wholesale  charges  applied,  the  competitive  situation  of  operators  with  limited 
geographic scope, the effects of commercial agreements on competition, as well as the 
ability of operators to take advantage of economies of scale (section 6). 

In addition, the Regulation mandates the Commission to have regard to specific criteria when 
assessing the most appropriate measures at the wholesale level to enable the abolition of retail 
roaming  surcharges.  The  Commission  has  carefully  considered  the  criteria  set  out  by  the 
European Parliament and Council in the Regulation in its impact assessment and legislative 
proposal accompanying this report, namely: 

 

 

 

the  risks  of  distortion  of  competition  and  investment  incentives  in  domestic  and 
visited markets of any measure proposed for wholesale roaming markets;  
the  need  to  ensure  that  visited  network  operators  are  able  to  recover  all  costs  of 
providing regulated wholesale roaming services,  including joint  and common costs; 
and, 
the  need  to  prevent  permanent  roaming  or  anomalous  or  abusive  use  of  wholesale 
roaming access for purposes other than the provision of regulated roaming services to 
roaming  providers'  customers  while  the  latter  are  periodically  travelling  within  the 
Union. 

The remainder of this report is structured as follows: 

  section  2  describes  the  overall  methodology  followed  by  the  Commission  in  the 

review of national wholesale roaming markets; 

  section  3  provides  an  overview  of  the  EU  Roaming  Regulations  to  date  and  their 

impact on market developments; 

  section 4 describes the competition developments in retail roaming markets across the 

EU to date3; 

  section  5  sets  out  the  Commission's  approach  to  assessing  the  costs  of  providing 
wholesale  roaming  services  and  a  summary  of  the  outcome  of  the  Commission's 
assessment  (more  detail  on  this  analysis  can  be  found  in  the  Final  report  of  the 
study4); 

  section 6 assesses the degree of competition in national wholesale roaming markets; 

3We first look at retail developments, then assesses wholesale markets, according to the practice in wholesale 
access regulation. Falch, M. and Tadayoni, R. (2014). Regulation of international roaming data services with the 
EU. In International Economics and Economic Policy. 
4 European Commission, Assessment of the cost of providing wholesale roaming services in the EEA, Final 
report, study conducted by TERA Consultants, to be published. 

13 

 
 
                                                           
  section  7  assesses  the  possible  impact  of  the  future  retail  RLAH  obligation  on 

competition on the wholesale roaming markets; 

  section 8  summarises the main conclusions of this report. 

2.  THE COMMISSION'S APPROACH TO THE REVIEW OF NATIONAL WHOLESALE MARKETS 

AND ITS LEGISLATIVE PROPOSAL 

In  this  section  the  Commission's  approach  in  reviewing  national  wholesale  markets  and  its 
legislative proposal is described, in particular, as regards: 

Information and data gathering on wholesale and retail roaming markets  

 
  Analysis of the data 
  The external study commissioned by the Commission to assess the costs of providing 

wholesale roaming services 

  Public consultation 
  Body of European Regulators in Electronic Communications (BEREC) input 
  Commission's inter-service group 
  Report on national wholesale roaming markets (this report) 
 
Impact assessment of the Commission's legislative proposal 

2.1. Information and data gathering on wholesale and retail roaming markets  

The  first  phase  of  the  review  process  consisted  in  gathering  quantitative  and  qualitative 
information about wholesale and retail markets in the EU. On 28 July 2015, the Commission 
sent  an  information  request  to  BEREC  specifying  the  data  and  information  necessary  to 
conduct the review of national wholesale roaming markets in accordance with the Regulation 
requirements5.   

Following  that  request,  BEREC,  in  collaboration  with  the  Commission,  sent  two 
questionnaires  to,  respectively,  mobile  (virtual)  network  operators  M(V)NOs  and  national 
regulatory  authorities  (NRAs)  on  11  September  2015.  These  questionnaires  aimed  at 
collecting  detailed  data,  facts  and  figures  about  the  degree  of  competition  in  national 
wholesale  markets,  the  level  of  wholesale  roaming  costs  incurred  by  a  visited  operator, 
including relevant joint and common costs, any observable risks of distortions of competition 
and investment incentives in home and visited market, and the competition developments in 
the retail roaming markets6. The questionnaire to NRAs also aimed at gathering information 
on the cost models and input data used by NRAs to estimate mobile network costs. Replies 
from operators and NRAs to these questionnaires were received in the course of September 
and  October  2015.  Some  operators  provided  updated  replies  in  November-December  2015 
and early January 2016.  

Through  this  information  gathering  exercise,  the  Commission  received  quantitative  and 
qualitative  information  from  135  operators  and  from  the  28  EU  NRAs  plus  the  Norwegian 
NRA. In the remainder of this report to the information gathered from operators and NRAs is 
referred as the 'autumn 2015 data collection'. 

5 The Commission's request for input to BEREC of 28 July 2015 also covered the inputs needed for the 
implementing acts mandated to the Commission by the Regulation on the weighted average of maximum MTRs 
across the EU, fair use policy, and sustainability mechanism. 
6 In addition, the questionnaire to operators included questions on fair use policies applied so far in unlimited 
domestic offers and roam-like-at-home-type of offers already marketed (usually for a fixed add-on price). 

14 

 
 
                                                           
In the course of December 2015 and January 2016, the Commission complemented this data 
collection exercise with additional requests on the characteristics and inputs of NRAs' mobile 
termination rates cost models, for the purpose of developing a cost model to assess the costs 
of  providing  wholesale  roaming  services  (a  more  detailed  description  of  the  external  study 
commissioned  by  the  Commission  to  TERA  Consultants  for  this  purpose  is  included  in 
section 5.4 below). 

In addition to these formal information requests, the Commission has held informal meetings 
with  NRAs  and  stakeholders  since  the  start  of  the  review  in  July  2015.  The  Commission's 
approach has been to consult openly with NRAs and BEREC on the analysis contained in this 
report  and  the  conclusions  of  its  legislative  proposal  (as  further  described  in  section  2.5 
below). 

2.2. Analysis of the data  

The analysis of the qualitative and quantitative data received on wholesale and retail roaming 
markets  in  the  autumn  2015  data  collection  was  conducted  by  DG  CNECT  and  the 
Competence  Centre  on  Microeconomic  Evaluation  (CC-ME)  of  the  Joint  Research  Centre 
(JRC)7  from  November  2015  to  February  2016.  DG  CNECT  has  also  relied  on  BEREC's 
analysis of this data carried out in parallel to the Commission's analysis (see section 2.5). 

2.3. External study to estimate the costs of providing wholesale roaming services 

The assessment of the level of costs incurred by visited network operators to offer wholesale 
roaming services provides, among other things, input for the analysis of the degree of market 
competition. To this end, the Commission ordered an external study to TERA Consultants8. 
The study was conducted between October 2015 and March 2016. Building upon cost models 
used by NRAs for mobile networks, the contractor has developed a cost model to estimate the 
costs  of  providing  wholesale  roaming  services  by  a  generic  European  mobile  network 
operator. The cost model was developed in close collaboration with the BEREC International 
Roaming Expert Working Group and NRAs. Anonymised data on wholesale roaming specific 
costs  collected  from  operators  in  the  autumn  2015  data  collection  described  in  section  2.1 
above  were  used  in  the  study  to  develop  the  cost  model.  In  addition,  BEREC  updated  its 
wholesale  roaming  costing  methodology  in  December  2015  and  the  Commission  used  this 
assessment  as  an  input  to  its  external  study  to  estimate  the  costs  of  providing  wholesale 
roaming services. 

In addition, the Commission invited NRAs, operators and trade associations, as well as other 
interested  stakeholders,  to  a  workshop  organised  together  with  TERA  Consultants  on  28 
January  2016  in  Brussels  to  present  the  interim  results  of  the  TERA  study  and  to  obtain 
feedback  on  the  study's  cost  model  for  wholesale  roaming  services.  The  feedback  from 
stakeholders has been incorporated into the cost model developed by TERA Consultants. 

Finally,  a  reality  check  exercise  was  conducted  in  March  2016.  During  two  weeks,  NRAs 
were invited to run and test the cost model on their input data. 20 NRAs provided comments 
and further information, in particular input data, where they deemed relevant to improve the 

7 The Joint Research Centre (JRC) is the European Commission's in-house science service employing scientists 
to carry out research in order to provide independent, evidence-based scientific advice and support to EU policy. 
For further information, please visit the JRC's website at: https://ec.europa.eu/jrc/.  
8 Study SMART 2015/006 "Assessment of the cost of providing wholesale roaming services in the EU", TERA 
Consultants. 

15 

 
 
                                                           
model. The model and the country input data used were then revised by TERA Consultants to 
take into account the feedback received from NRAs. 

The final version of the cost model developed by the contractor is described in more detail in 
Final report of the study9. 

2.4. Public consultation 

On  26  November  2015  the  Commission  launched  a  wide-ranging  12-week  public 
consultation to gather views on the functioning of, and level of competition on, the wholesale 
roaming  markets  in  the  EU,  on  the  need  to  regulate  them  in  view  of  the  abolition  of  retail 
roaming surcharges by 15 June 2017, on possible options for doing so, and on the possible 
risks  associated  with  permanent  roaming  and  the  ways  to  address  them10.  The  public 
consultation was closed on 18 February 2016. The Commission received 92 responses to the 
online  consultation  from  individual  consumers,  consumers'  associations,  mobile  network 
operators (MNOs), mobile virtual network operators (MVNOs), NRAs11 and governments, as 
well as a couple of responses from other businesses from all over the EU and Norway12.  

Among the 32 MNOs  that replied to  the public consultation,  the 9 group operators13 which 
operate  mobile  networks  in  at  least  three  Member  States  have  responded  to  the  public 
consultation at the group level (i.e. 1 reply per group)14. 

The  responses  to  the  public  consultation  are  summarised  in  the  relevant  sections  of  the 
present  report  on  wholesale  roaming  markets  (sections  5.4.1,  6.5.1,  6.5.2  and  7)  and  of  the 
Commission's  impact  assessment  (section  7.1)  accompanying  the  legislative  proposal.  The 
full analysis of the replies is available in Annex 2 of the Commission's impact assessment. 

2.5. BEREC input 

The  Commission  has  worked  closely  with  BEREC  in  its  review  of  the  wholesale  roaming 
market.  BEREC  provided  information  collected  in  autumn  2015  from  operators  and  NRAs 
(as  described  in  section  2.1  above)  and  contributed  to  the  Commission's  assessment  of  the 
costs of providing wholesale roaming services.  

9  European  Commission,  Assessment  of  the  cost  of  providing  wholesale  roaming  services  in  the  EEA,  Final 
report, study conducted by TERA Consultants, to be published. 
10  In  addition,  the  public  consultation  included  two  sets  of  questions  on  fair  use  policy  and  the  sustainability 
mechanism  foreseen  in  the  Regulation,  in  view  of  implementing  powers  conferred  to  the  Commission  by  the 
Regulation  on  these  two  topics.  A  short  summary  of  the  results  of  the  public  consultation  is  available  here: 
https://ec.europa.eu/digital-single-market/en/news/summary-report-public-consultation-review-national-
wholesale-roaming-markets-fair-use-policy 
11 Six NRAs replied on their own behalf. BEREC did not reply to the public consultation directly but provided 
on 29 February 2016 its Report on the wholesale roaming market BoR(16)33. 
12  In  addition  to  the  92  replies  to  the  online  questionnaire,  3  respondents  sent  their  replies  by  e-mail  and  2 
respondents sent separate position papers. . 
13Deutsche Telecom, Hutchinson Europe, Orange, Tele2, , Telefonica, Telekom Austria, Telenor, TeliaSonera, 
Vodafone 
14  Only  one  affiliate  of  one  of  these  nine  group  operators  provided  a  contribution  in  addition  to  the  group 
contribution.  Therefore,  22  independent  MNOs  (operating  in  one  or  two  Member  States)  have  replied  to  the 
public  consultation.  Since  the  9  group  operators  represent  in  total  64  operators  in  the  28  Member  States  plus 
Norway, the responses to the public consultation cover a total of 86 MNOs, plus 8 MVNOs, thus covering most 
of the telecom sector in the EU plus Norway (the total number of MNOs and MVNOs is on the order of 140; 
those having not responded are among the smaller operators). 

16 

 
 
                                                           
On 29 February 2016, BEREC published its report on the wholesale roaming market15 which 
analysed the data and information collected from operators in autumn 2015. The Commission 
has  relied  on  BEREC's  report  in  the  analysis  contained  in  the  present  report.  The  present 
report  also  draws  on  data  from  the  16th  International  Roaming  BEREC  Benchmark  Data 
Report published on 29 February 201616.  

2.6.  Commission's inter-service group 

In order to  support the preparation and drafting of this report and the impact  assessment,  a 
Commission  inter-service  group  was  established.  The  following  Commission  services  were 
invited  to  participate:  Secretariat  General,  Legal  Service,  Competition,  Internal  Market, 
Industry,  Entrepreneurship  and  SMEs,  Justice  and  Consumers.  The  group  met  on  a  regular 
basis throughout the wholesale roaming review process.  

2.7. The report on national wholesale roaming markets (this report) 

Based  on  the  inputs  received  via  the  questionnaires,  the  external  study  and  the  public 
consultation, this report analyses the functioning of the wholesale and retail roaming markets  
and assesses whether these markets are working well for consumers. To this aim, the report 
has  also  relied  on  previous  work  on  roaming  markets  done  by  the  Commission  and  more 
generally.  The overarching objective of this analysis is to determine whether it is necessary 
to further intervene in wholesale roaming markets in order to enable the provision of roaming 
services at domestic prices in the EU, within fair use limits, from 15 June 2017. 

2.8. Impact assessment for the Commission's legislative proposal 

Following  the  conclusion  in  this  report  that  further  regulatory  measures  are  needed  in 
wholesale  roaming  markets  to  enable  a  sustainable  provision  of  RLAH,  the  Commission's 
impact  assessment  accompanying  the  legislative  proposal  assesses  which  is  the  best 
regulatory option to intervene in wholesale roaming markets.  

3.  OVERVIEW OF THE EU ROAMING REGULATIONS AND MARKET DEVELOPMENTS (2007-

2015) 

In  this  section  the  evolution  of  the  EU  Roaming  Regulations  and  the  associated  market 
developments  at  the  wholesale  and  retail  level  over  the  period  2007-2015  are  briefly 
described.  

3.1. Evolution of the EU Roaming Regulations (2007-2015) 

Since  the  introduction  of  mobile  phone  services,  European  consumers  have  faced  high 
roaming charges (compared to the charges paid for equivalent domestic services) when using 
their  mobile  phones  while  travelling  abroad  in  other  EU  Member  States.  The  2003  EC 
Recommendation  on  relevant  markets  included  the  "wholesale  national  market  for 
international roaming  on public mobile networks" as  one of the markets to  be reviewed  by 
NRAs.  However,  competition  problems  in  international  roaming  markets  were  difficult  to 
address using the regulatory tools provided by the 2002 EU Regulatory Framework, and none 

15 BEREC Report on the wholesale roaming market, BoR(16)33, February 2016. 
16 BEREC, International Roaming BEREC Benchmark Data Report, BoR(16)28, February 2016. 

17 

 
 
                                                           
of  the  NRAs  found  any  individual  or  joint-dominance  justifying  the  regulation  of  this 
wholesale market.17 

Unable  to  tackle  the  problem  nationally,  national  telecoms  regulators  requested  the  EU  to 
intervene  to  address  the  problem  of  excessive  roaming  prices  within  the  EU18.  In  order  to 
tackle the problems in EU roaming markets, the Commission proposed three regulations that 
were adopted by the European Parliament and the Council in 2007, 2009 and 2012. The main 
regulatory measures introduced by the Commission's Roaming Regulations are summarised 
in Table 1 below. 

17  Infante,  J.  and  Vallejo,  I.  (2012),  Regulation  of  international  roaming  in  the  European  Union  –  Lessons 
learned, In Telecommunications Policy.  
18 European Regulators' Group (ERG) letter to the Directorate general of the Commission's DG information 
society, Fabio Colasanti, December 2005 

18 

 
 
 
 
                                                           
Table 1 - Regulatory measures introduced by the Roaming Regulations (2007-2016) 

Voice (outgoing calls)19 
Retail 

Wholesale 

Price cap 

Price cap 

SMS (outgoing SMS)20 
Retail 

Wholesale 
Not regulated 

Wholesale 
Not regulated  Not regulated  Not regulated 

Retail 

Data 

Other 

Roaming 
Regulation 
2007 

2009 

2012 

2016 

Period 
August  2007- 
June 2010 
July  2010  – 
June 2012 

July  2012  – 
April 2016 

Lower cap 

Lower cap 

Price cap 

Price cap 

Price cap 

Lower cap 

Lower cap 

Lower cap 

Lower cap 

Lower cap 

2016-

April 
June 2017 

Unchanged 

Domestic  price 
+  wholesale cap 
(RLAH+) 

Unchanged 

Unchanged 

Domestic 
price 
+ 
wholesale  cap 
(RLAH+) 

Free  of  charge  SMS  on  retail 
roaming prices 
Free  of  charge  SMS  on  retail 
roaming prices 

Structural measures to increase 
competition 
the  roaming 
in 
market 

Maximum  bill 
threshold 
(€50 
by default) 
Price cap 

Domestic  price 
+  wholesale  cap 
(RLAH+) 

19 Incoming calls have been subject to a decreasing price cap over time at retail level but have not been subject to any price cap at wholesale level. 
20 Incoming SMS are not charged while roaming. 

19 

 
 
 
  
                                                           
The  first  EU  Roaming  Regulation  was  introduced  in  2007,  it  included  the  following 
regulatory measures: 

  Voice services: wholesale and retail price caps; and 
  Transparency measures: SMS informing about retail roaming prices when entering a 

visited country free of charge. 

The retail cap forced operators to respect the price caps by default (the so-called Eurotariff), 
but allowed them to offer alternative retail tariffs for those customers that voluntarily opted 
out of the Eurotariff. The aim was to protect consumers from excessive retail charges while at 
the  same  time  allowing  competition  to  develop  in  the  form  of  alternative  tariffs.  This  first 
regulation also included transparency measures to alert consumers of retail roaming charges 
and avoid bill shock. 

The  first  EU  Roaming  Regulation  was  reviewed  in  2009.  The  second  EU  Roaming 
Regulation included the following regulatory measures: 

  Voice services: lower wholesale and retail price caps; 
  SMS services: wholesale and retail price caps introduced for the first time;   
  Data services: wholesale price cap and maximum bill threshold introduced for the first 

time; and 

  Continuation of transparency measures. 

The  second  EU  Roaming  Regulation  lowered  the  wholesale  and  retail  price  caps  on  voice 
services  to  account  for  the  reduction  in  the  underlying  costs  of  provision.  In  addition,  it 
introduced  for  the  first  time  wholesale  and  retail  price  caps  for  SMS  services.  Finally,  it 
imposed  a  "safeguard  cap"  on  data  services  at  the  wholesale  level  and  a  maximum  bill 
threshold for data services. The latter was designed to protect consumers from "bill shock" by 
setting a maximum bill of €50 by default (that could be adjusted by the consumer).21  

The third EU Roaming Regulation was adopted in June 2012, it included: 

  Voice services: lower wholesale and retail price caps; 
  SMS services: lower wholesale and retail price caps; 
  Data services: lower wholesale price cap and introduction of  retail price caps; 
  Continuation of transparency measures; 
  Extension of maximum bill threshold to extra-EEA roaming; and 
  Obligation  to  publish  a  wholesale  access  reference  offer  and  meet  all  reasonable 

requests for wholesale roaming access; 
Introduction of structural measures to foster competition in the roaming market. 

 

Lastly, the fourth Regulation of 25 November 2015 includes the following measures: 

  From 30 April 2016 to 14 June 2017: the surcharges on roaming services applicable in 
addition to domestic prices are capped by the last wholesale price caps set in the third 
Roaming  Regulation;  the  charge  on  incoming  calls  while  roaming  is  capped  at  the 
level of the weighted average of maximum MTRs across the EU; 

21 Consumers were informed that their consumption had reached 80% of the maximum threshold via an SMS. 
When consumption reached the maximum limit the data services were cut-off, unless customers gave explicit 
consent to exceed that limit. 

20 

 
 
 
 
 
 
                                                           
  From  15  June  2017:  RLAH,  i.e.  retail  roaming  services  to  be  provided  at  domestic 
prices, subject to fair use policy and to a sustainability clause, both to be detailed in an 
implementing act to be adopted by the Commission before 15 December 2016; 

  Adaptation of transparency measures to the RLAH regime; 
  Commission mandated to conduct a wholesale roaming review and make appropriate 

proposals by 15 June 2016 to enable a sustainable RLAH regime in the EU. 

3.2. Evolution of wholesale and retail roaming prices (2007-2015) 

The  evidence  on  wholesale  and  retail  roaming  prices  presented  below  shows  that  since  the 
introduction  of  the  roaming  regulations  in  2007,  wholesale  and  retail  roaming  prices  have 
steadily  declined  in  line  with  the  price  caps  introduced  by  these  regulations.  Below  the 
impact  of  the  roaming  regulations  on  the  evolution  of  wholesale  and  retail  roaming  prices 
since 2007 is described. 

3.2.1.  Retail roaming prices  

In the third quarter of 2015, the EEA average retail prices for intra-EEA roaming voice, SMS 
and data services were 13.1 €c/min, 5.2 €c/SMS and 5.9 €c/MB respectively (VAT excluded) 
below the regulated caps of 19 €c/min, 6 €c/SMS and 20 €c/MB.22 

Figure 1 to Figure 3 show the evolution of EEA average retail prices for intra-EEA roaming 
voice, SMS and data services over the period 2007-2015. 

Figure 1 - EEA average retail price per minute for intra-EEA roaming voice calls made 

Source: International roaming BEREC Benchmark Data Report April – September 2015, BoR(16)28, February 
2016 

22 International roaming BEREC Benchmark Data Report April – September 2015, BoR(16)28, February 2016 

21 

 
 
 
 
 
 
 
 
 
                                                           
Figure 2 - EEA average retail price for intra-EEA outgoing SMS 

Source: International roaming BEREC Benchmark Data Report April – September 2015, BoR(16)28, February 
2016 

Figure 3 - EEA average retail price per MB 

Source: International roaming BEREC Benchmark Data Report April – September 2015, BoR(16)28, February 
2016 

The evidence presented above suggests that the evolution of retail prices for voice and SMS 
roaming services has been very closely aligned to the retail price caps set by the EU Roaming 
Regulations since 2007. In the case of data services, the difference between retail price caps 
and  effective  market  prices  has  been  significantly  larger  than  for  voice  and  SMS  services. 

22 

 
 
 
 
 
 
However,  the  evidence  presented  in  Figure  3  shows  that  the  three  successive  reductions 
observed in retail data roaming prices since 2007 were triggered by the introduction of retail 
wholesale data roaming caps in 2012 and its successive reductions in 2013 and 2014.  Section 
4  below  assesses  in  more  detail  the  reasons  why  effective  retail  roaming  prices  for  data 
services  are  lower  than  retail  caps  to  a  greater  extent  than  in  the  case  of  voice  and  SMS 
services.  

3.2.2.  Wholesale roaming prices 

In the third quarter of 2015, the EEA average wholesale prices for intra-EEA roaming voice, 
SMS  and  data  services  were  3.6  €c/min,  1.2  €c/SMS  and  1.7  €c/MB  respectively  (VAT 
excluded), below the regulated caps of 5 €c/min, 2 €c/SMS and 5 €c/MB.23 

Figure  4  to  Figure  6  show  the  evolution  of  EEA  average  wholesale  prices  for  intra-EEA 
roaming voice, SMS and data services over the period 2007-2015. 

Figure 4 - EEA average price per minute for wholesale non-group roaming voice calls 

Source: International roaming BEREC Benchmark Data Report April – September 2015, BoR(16)28, February 
2016 

23 International roaming BEREC Benchmark Data Report April – September 2015, BoR(16)28, February 2016 

23 

 
 
 
 
 
 
 
 
                                                           
Figure  5  -  Average  wholesale  price  per  intra-EEA  roaming  SMS:  charges  to  non-group 
companies 

Source: International roaming BEREC Benchmark Data Report April – September 2015, BoR(16)28, February 
2016 

Figure 6 - Average wholesale data price per MB (prepaid+postpaid), EEA average 

Source: International roaming BEREC Benchmark Data Report April  – September 2015, BoR(16)28, February 
2016 

24 

 
 
 
 
 
 
Similarly to the case of retail prices, the evidence presented above suggests that the evolution 
of wholesale prices for voice and SMS roaming services has been very closely aligned with 
the  wholesale  price  caps  set  by  the  EU  Roaming  Regulations  since  2007.  In  the  case  of 
wholesale  prices  for  data,  the  market  prices  have  been  significantly  lower  than  wholesale 
price  caps  over  the  period  2009-2014.  While  retail  prices  for  data  decreased  in 
correspondence  with  entry  into  force  of  the  reduction  of  caps,  the  decrease  in  wholesale 
prices for data also continued over each time period between two successive changes in cap 
level.  However,  the  gap  between  market  prices  and  wholesale  caps  has  substantially 
decreased over time as wholesale price caps have been reduced. 

3.3. Evolution of roaming traffic in Europe 

The  evidence  on  roaming  traffic  described  below  shows  that  the  decline  in  wholesale  and 
retail  roaming  prices  triggered  by  the  roaming  regulations  since  their  introduction  in  2007 
have  been  accompanied  by  a  steady  increase  in  roaming  traffic.  The  evolution  of  retail 
roaming traffic since 2008 is described below. 

Figure 7 to Figure 9 show the evolution of roaming traffic for voice, SMS and data since the 
first quarter of 2008. 

Figure 7 - Roaming traffic index: intra-EEA outgoing calls (Q3 2008=100) 

Source: International roaming BEREC Benchmark Data Report April – September 2015, BoR(16)28, February 
2016 

25 

 
 
 
 
 
Figure 8 - Retail SMS sent traffic index (Q3 2008=100) 

Source: International roaming BEREC Benchmark Data Report April – September 2015, BoR(16)28, February 
2016 

Figure 9 - Retail roaming data traffic index: (Q3 2008 = 100) 

Source: International roaming BEREC Benchmark Data Report April – September 2015, BoR(16)28, February 
2016 

There  has  been  a  significant  increase  in  voice  and  SMS  roaming  traffic  since  2008:  on 
average traffic in the EEA has increased by 51% in the case of voice and 56% in the case of 

26 

 
 
 
 
 
SMS sent between the third quarter of 2008 and the third quarter of 2015. This contrasts with 
the relatively lower growth observed in the EU for domestic traffic for these services.24 This 
shows  that  the  decrease  in  retail  roaming  prices  triggered  by  the  successive  roaming 
regulations has enabled an increase in consumers' use of roaming voice and SMS services in 
the EEA since 2008.   

The increase in roaming data traffic since 2008 has been even greater. Data roaming traffic in 
the EEA has  increased by  796% between the third quarter of 2008  and the third quarter of 
2015. While a significant share of this increase reflects the structural increase in mobile data 
usage  also  observed  in  domestic  markets25,  the  increase  in  roaming  data  traffic  has  been 
facilitated by the sharp reduction in  retail  roaming prices for data triggered by the roaming 
regulations over the last years.  

4.  COMPETITION DEVELOPMENTS IN RETAIL ROAMING MARKETS 

In this section the Commission reviews the developments in retail roaming markets observed 
in the last years. The remainder of the section is structured as follows: 

  First, the Commission's approach to analysing developments in retail roaming markets 

is provided; 

  Second, the market failures that have been traditionally associated with retail roaming 

markets are reviewed;  

  Third, a comparison of retail roaming and domestic markets is presented;  
  Fourth,  the  retail  roaming  offers  that  exist  in  EU  telecoms  markets,  with  a  special 

focus on RLAH-type of offers, are described;  

  Fifth,  the  technological  developments  and  potential  substitutes  to  roaming  that  have 

appeared in the last years are reported; 

  Finally, conclusions on the level of competition in retail roaming markets in the EU 

are drawn.  

4.1. Description of the Commission's approach 

4.1.1.  Literature review 

The Commission has extensively reviewed economic analyses on roaming markets to inform 
its  assessment  of  the  functioning  of  these  markets  in  the  EEA.  Where  relevant,  this  report 
reflects on these analyses and confronts them with the data and information provided by EEA 
mobile operators during the autumn 2015 data collection. 

4.1.2.  Questionnaires to operators and analysis of the data 

The Commission requested information on competition developments in roaming markets in 
the EU through a questionnaire sent in September 2015 by the Commission and BEREC to 
M(V)NOs in all Member States. 

24 For example, the average monthly outbound mobile voice minutes per person and the annual volumes of SMS 
messages in the UK increased by 10% and 5%, respectively, between 2008 and 2013 (see Statista here and here) 
and the number of outgoing call minutes on mobile networks and SMS sent in Germany increased by 29% and -
19%, respectively, between 2008 and 2014 (see Statista here and here). 
25 For example, average monthly data volume per mobile internet subscription in Germany increased by 970% 
between 2009 and 2014 (see Statista here) and total mobile data in the UK increased by 710% between March 
2011 and June 2015 (see Statista here). 

27 

 
 
  
                                                           
For  the  purpose  of  assessing  competition  developments  in  roaming  markets  in  the  EU, 
operators  were  requested  to  provide  information  on:  (i)  specific  retail  roaming  costs,  (ii) 
aggregated retail domestic and (intra-EU/extra-EU) roaming data consumption and revenues, 
(iii) RLAH-type of offers already marketed and their impact on demand for roaming services. 
The Commission's analysis relies on this information as well as BEREC's own assessment of 
competition developments in retail roaming markets based on this information. 

93  operators  provided  part  or  all  of  the  quantitative  data  requested  on  retail  domestic  and 
(intra-EU/extra-EU)  roaming  data  consumption  and  revenue.  The  CC-ME  of  the  JRC 
extracted the original data and organized them in a unified database. Several inconsistencies 
in  the  way  data  were  reported  were  corrected,  in  particular  as  regards  the  unit  of 
measurement. In section 4.4, the results of the analysis are shown by operator and by country. 
For  each  variable  of  interest  (e.g.  intra-EEA  retail  roaming  volume  as  %  of  total  retail 
consumption)  the  operators'  graph  represents  the  distribution  of  the  operators'  values  in  the 
sample  of  operators  providing  the  necessary  data  as  a  cumulative  fraction  of  the  sample 
(expressed as %). This means that for each value of the variable of interest on the x-axis, the 
graph shows what % of the operators' sample is below that value. Operators are looked at on 
a per-country basis, which means per subsidiary for the multi-country groups. The countries' 
graphs show the aggregated value of the variable of interest over all operators operating in a 
given country that have provided the necessary data. 

4.2. Market failures in retail roaming markets 

This  sub-section  provides  an  overview  of  the  market  failures  that  have  been  traditionally 
associated with retail roaming markets, in particular: 
Imperfect substitutes at retail level;  

 
  Lack of tariff transparency and bill shock; and 
 

Inelastic  demand  for  roaming  services  for  a  significant  proportion  of  the  customer 
base. 

4.2.1.  Imperfect substitutes at the retail level 

One of the main problems that has been typically associated with retail  roaming services is 
the lack of (or substantial imperfections in) substitutes, as customers have no effective means 
of substituting for the roaming service at retail level.26 In 2011 the Commission assessed the 
substitutability of retail roaming services with, among others: 

  Local SIM cards, which could be used in a dual-Sim handset as well) 
  VoIP, (directly linked to the availability of WiFi hotspots) 
  Global or regional SIM card (with multi-IMSI SIM cards or call back options). 

The  Commission  concluded  that  none  of  the  assessed  possible  alternatives  was  a  perfect 
substitute for roaming based on their level of (i) mobility; (ii) availability; (iii) accessibility; 
(iv) affordability; and (v) ease of use.27 This lack of available substitutes at the retail level is 

26 Falch, M. and Tadayoni, R. (2014). Regulation of international roaming data services with the EU. In 
International Economics and Economic Policy. WIK-Consult (2010), Study on the Options for addressing 
Competition Problems in the EU Roaming Market, SMART 2010/018, December, p. 8 and BEREC (2010), 
International Mobile Roaming Regulation BEREC Report, December 2010. 
27 European Commission (2011), Commission Staff Working Paper – Impact Assessment of Policy Options in 
Relation to the Commission's Review of the Functioning of Regulation EC No 544/2009 of the European 

28 

 
 
 
                                                           
 
mainly due to  consumers' preference for using their mobile phone as they  do at  home over 
any available alternative.  

In relation to the Roaming III regulation, there are some changes to be considered, especially 
in  relation  to  OTTs.  According  to  a  study  by  Deloitte28,  OTT  VoIP  (Over-The-Top  Voice 
over  Internet  Protocol)  players  like  Skype,  Facetime  and  WhatsApp  have  been  used  for 
international  communications  for  years  now,  significantly  affecting  the  roaming  market.  
What  has  changed?  First  of  all,  smartphones  have  now  multiplied,  making  OTT  VoIP 
services much more available to the European consumer. Despite the lack of specific data, the 
introduction of voice service into the massively used WhatsApp in 2015 should be considered 
as an important development regarding the availability of OTT VoIPs as well.  Second, Wi-Fi 
hotspots, where the consumer can connect for free or for a fee, are more widespread now, a 
growing  trend  that  is  likely  to  extend  in  the  future29.  Third,  LTE  and  4G  speeds  are  better 
capable  of  providing  OTTs  good-quality  voice  calls  than  3G.  While  the  final  cost  of  this 
service  (some  estimates  talk  of  around  800Kb/Min)  is  variable  and  difficult  to  calculate,  it 
could nonetheless be competitive depending on the specific roaming tariffs.  

Yet, in spite of these trends, OTT VoIP services still present constrains in terms of mobility, 
availability,  accessibility  and  ease  of  use  that  should  not  be  underestimated.  Together  with 
local  SIM  cards,  or  global/regional  SIM  cards,  OTTs  are  only  imperfect  substitutes  for  the 
majority  of  consumers,  as  they  limit  mobility  and  do  not  allow  subscribers  to  receive 
incoming  calls  on  their  usual  numbers  (for  voice  and  SMS).  They  are  also  less  suited  to 
calling  businesses,  public  authorities  and  other  entities  outside  the  circle  of  friends  and 
family, particularly those OTT that do not terminate to the PTSN. OTT services may also be 
unable  to  access  premium  numbers,  interactive  automated  services,  micropayment  services 
and emergency services. 

In  addition,  alternatives  to  roaming  services  (e.g.  global  and  regional  MVNOs  and  SIM 
cards) lack sufficient uptake due to the lack of consumer awareness, complexity of usage for 
customers,  language  barriers,  and  low  brand  recognition  among  consumers  as  regards  the 
service providers. A general problem with any roaming substitute that has to be purchased in 
the visited country is that it imposes high search costs on the consumer, as s/he is obliged to 
become  knowledgeable  about  prices  and  services  in  each  visited  country.30  The  lack  of 
availability of substitutes for retail roaming services is reflected in consumers' patterns of use 
of mobile services when travelling to another EU country. Table 2 below shows the habits of 
EU mobile subscribers' when travelling abroad to another EU country.  

Table 2: When travelling to another EU country, you generally... 

Switch  off 
mobile 
phone 

Switch  off 
data 
capability 

Activate 
special  data 
roaming plan 

or 

Public 
private 
WiFi access 

Purchase 
local 
card 

SIM 

Other  Don't 
know 

Parliament and of the Council of 18 June 2009 on Roaming on Public Mobile Telephone Networks within the 
Community, 6 July 2011, SEC(2011) 871, pp.58-65. 
28 http://www2.deloitte.com/content/dam/Deloitte/de/Documents/technology-media-telecommunications/TMT-
Roaming_safe.pdf , p.10 
29 For a discussion on the possible impact of traffic off-load on roaming, see Marcus, J.S. et al. (2013) Structural 
solutions and the evolution of international mobile roaming (IMR) in Europe: Where are we headed?. WIK  
Available at SSRN: http://ssrn.com/abstract=2342637.   
30 WIK-Consult (2010), Study on the Options for addressing Competition Problems in the EU Roaming Market, 
SMART 2010/018, December, p. 15. 

29 

 
 
 
 
                                                                                                                                                                                     
EU 28 
Source:  Eurobarometer  (2014),  E-Communications  Household  Survey  and  Telecom  Single  Market  Survey  – 
Roaming Results, Special Eurobarometer no. 414, available here. 

16% 

10% 

25% 

28% 

18% 

6% 

9% 

According to the 2014 Eurobarometer on roaming, only 10% of mobile users use a local SIM 
card and 16% a public or private WiFi access when travelling abroad to another EU country. 
The majority of mobile users prefer instead to either switch off their mobile phone (28%) or 
switch off the data capability (25%).  

While  none  of  the  available  alternatives  appears  to  be  considered  a  good  substitute  for 
roaming  services,  a  series  of  technological  developments,  especially  eSims,    might  change 
this situation in the mid-term. These developments are briefly analysed in section 4.5 of this 
report.  

4.2.2.  Lack of tariff transparency and bill shock 

Mobile  users  typically  purchase  roaming  services  as  part  of  a  bundle  including  a  domestic 
subscription  allowing  access  to  domestic  mobile  services.  In  practice,  this  means  that 
roaming charges make up only a relatively small proportion of a user's total bill for its mobile 
services.31  Furthermore,  roaming  charges  tend  to  be  intermittent,  as  these  are  only  charged 
when  the  subscriber  uses  its  mobile  subscription  while  travelling  abroad  from  its  home 
country, which only happens occasionally for the majority of European mobile users.  

These features of roaming services have tended to result in a lack of tariff transparency for 
the majority of European mobile subscribers and have resulted in unexpected high roaming 
charges or "bill shock", which are also the product of certain smart phone features, such as 
hidden data consumption, which are difficult to control by the consumer. This lack of tariff 
transparency  and  bill  shock  may  have  been  mitigated  by  the  Commission's  Roaming 
Regulations, which have included measures to increase transparency and mitigate bill shock 
(as already described in section 3.1 above). However, for the reasons described above, lack of 
tariff  transparency  and  bill  shock  can  be  considered  an  intrinsic  characteristic  of  retail 
roaming services in the absence of adequate regulatory intervention. For example, in the 2006 
Eurobarometer  (prior  to  the  introduction  of  the  Roaming  Regulations  and  the  spreading  of 
smart phones), only 29% of respondents to the survey declared that they were familiar with 
international  roaming  charges.32  Even  currently,  in  spite  of  the  successive  regulations, 
roaming  within  the  EU  is  still  one  of  the  causes  for  unexpectedly  high  bills  amongst  users 
experiencing bill shock.33   

4.2.3.  Inelastic demand for roaming services for a significant proportion of 

the customer base 

31 WIK-Consult (2010), Study on the Options for addressing Competition Problems in the EU Roaming Market, 
SMART 2010/018, December, p. 8 
32  Eurobarometer  (2007),  Roaming  Summary,  Special  Eurobarometer  no.  269,  question  QB9.  42%  of 
respondents declared that they did not have a clear idea of the cost of communications when abroad, 14% stated 
they were not concerned with the question and 15% did not know.  
33  For  example,  Ofcom's  2014  report  on  unexpectedly  high  bills  cites  roaming  within  the  EU  as  one  of  the 
causes of unexpectedly high bills amongst those users experiencing bill shock. See Ofcom (2014), Incidence of 
unexpectedly high bills 2014 report, slide 14, available at here. 

30 

 
 
 
 
 
  
                                                           
There has not been much research into the price elasticity of demand of roaming services. As 
far as the Commission is aware, there have been the following empirical studies on the own 
price elasticity of demand of outgoing voice calls while roaming: 

  European  Commission  (2006):  three  different  scenarios  for  the  welfare  assessment 

have been used, namely, -0.55, -1.0 and -1.2;34 

  GSMA (2008): considered that the elasticity of demand should be -0.25;35 
  Europe Economics (2008): estimated that elasticity of demand should range between -

0.35 to -0.44;36 

  CMT (2009): estimated the elasticity of demand around -0.37.37 

In  the  Commission's  2011  Impact  Assessment  on  the  options  for  roaming  the  preparatory 
study for the IA had assumed relatively low elasticities of demand for voice and SMS (in the 
range of -0.2 to -0.3), albeit the elasticity for data was likely to be higher (it was difficult to 
assess the elasticity of demand for data, since usage was growing due to the increase in use of 
smartphones).38  Overall,  a  low  price  elasticity  of  demand  has  traditionally  been  associated 
with retail roaming services.39 

As  described  above,  the  low  price  elasticity  of  demand  is  likely  to  be  due  to  the  fact  that 
mobile  operators  typically  set  different  prices  for  roaming  services  and  bundle  these  with 
domestic offers. The resulting lack of transparency and high search costs for consumers (for a 
relatively small proportion of their total mobile bill) may drive the lack of responsiveness to 
prices  from  consumers  at  the  time  of  choosing  their  retail  tariff.40  In  addition,  roaming  bill 
shocks  are  also  likely  to  have  resulted  in  lower  price  responsiveness  from  end  users, 
especially  for  data.  Due  to  the  comparatively  high  roaming  prices,  which  are  still  mostly 
based on per-unit pricing rather than flat-rates41, and the lack of transparency and control in 

34 European Commission (2006), Impact Assessment of Policy Options in Relation to a Commission Proposal 
for a Regulation of the European Parliament and of the Council on Roaming on Public Mobile Networks Within 
the Community.  
35  GSMA  (2008),  GSMA  Briefing  Paper  On  the  Impact  Assessment  Accompanying  the  Proposal  for  a 
Regulation  of  the  European  Parliament  and  of  the  Council  Amending  Regulation  (EC)  No  717/2007  ON 
Roaming on Public Mobile Phone Networks Within the Community. 
36  Europe  Economics  (2008),  Review  of  the  Roaming  Regulation,  Study  for  the  European  Parliament's 
committee on Internal Market and Consumer Protection, IMCO, IP/A/IMCO/FWC/2006-186 C. 
37 CMT (2009), Report on the Analysis of the International Roaming Service in the Spanish Mobile Telephone 
Market. 
38 European Commission (2011), Commission Staff Working Paper – Impact Assessment of Policy Options in 
Relation to the Commission's Review of the Functioning of Regulation EC No 544/2009 of the European 
Parliament and of the Council of 18 June 2009 on Roaming on Public Mobile Telephone Networks within the 
Community, 6 July 2011, SEC(2011) 871, p.16. 
39  See,  for  example,  WIK  (2013),  International  Mobile  Roaming  Policy  and  Regulatory  Actions:  Theory  and 
Practice,  ITU  High-Level  Workshop  on  Regulatory  and  Economic  Aspects  of  Roaming,  slide  2;  Europe 
Economics (2008), Roaming Regulation, Brief for European Parliament, 9 December, slide 5, available here. 
40 European Commission (2011), Commission Staff Working Paper – Impact Assessment of Policy Options in 
Relation to the Commission's Review of the Functioning of Regulation EC No 544/2009 of the European 
Parliament and of the Council of 18 June 2009 on Roaming on Public Mobile Telephone Networks within the 
Community, 6 July 2011, SEC(2011) 871, p.16. 
41 See the latest BEREC Transparency and Comparability Report, Chapter 4. While the number of roaming 
bundles, limited add-ons and RLAH-type offers is clearly on the rise, per-unit pricing generally applies even in 
these tariffs, once the bundle restrictions are reached. For data roaming tariffs, for example, a significant number 
of operators have a 1 day restriction. 
http://berec.europa.eu/eng/document_register/subject_matter/berec/reports/5578-draft-report-on-transparency-
and-comparability-of-international-roaming-tariffs 

31 

 
 
 
  
                                                           
smart  phones'  data  consumption,  the  consumer  is  afraid  of  switching  on  the  overall  data 
capabilities of his device regardless of specific price differences. 

In this respect, it is highly possible that, especially regarding roaming data consumption, it is 
not so much the lack of a linear price elasticity that matters. What matters is the consumer's 
sense  of  control  over  such  consumption,  which  has  been  severely  damaged  by  both,  the 
structural  features  of  the  market,  and  the  opportunistic  strategies  of  its  agents,  especially 
facilitated  by  the  limits  of  steering  technologies42,  which  blurred  the  attribution  of  market 
responsibilities (see section 6.2).   

Indeed, the evidence presented above in section 4.2.1 shows that a significant proportion of 
end users (53%) opt for either switching off their mobile or data capabilities when travelling 
abroad.  This  is  most  likely  the  result  of  historical  high  per-unit  roaming  prices  and  the 
incidence of bill shock on EU mobile users when using their mobile abroad.  

The Commission therefore expects that the introduction of RLAH, which will eliminate the 
possibility  of  roaming  surcharges  (within  fair  use  limits),  will  give  consumers  a  renewed 
sense  of  security  when  using  roaming  services,  what  will  not  only  limit  the  scope  for  bill 
shocks  in  the  EU,  but  also  result  in  higher  demand  responsiveness  to  prices,  and  increase 
consumption up to optimal economic levels for both consumers and operators43.  

4.3. Domestic price level and consumption pattern 

BEREC analysis44 shows that the domestic annual retail revenue per user varies considerably 
between EEA countries from 3.70 € per month in Lithuania and Latvia to 43.80 € per month 
in  Liechtenstein45,  with  a  weighted  average  of  14.30  €.  There  are  also  large  differences  in 
domestic consumption patterns of mobile services (voice, SMS and data). These differences 
in consumption are particularly high for data services whose average use per user per month 
in 2014 varies from about 100 MB in Romania to almost 3000 MB in Finland. 

4.4. A comparison of retail roaming and domestic traffic 

Figure 10 to Figure 13 show, per operator, the share of intra-EEA retail roaming consumption 
in total retail (i.e. domestic plus roaming intra-EEA and extra-EEA) consumption, in terms of 
revenues and volumes for each service, based on operators' data from the autumn 2015 data 
collection. 

42 Dominguez Lacasa, Javier (2011). Competition for Partners: Strategic Games in Wholesale International 
Roaming. In 22nd European Regional Conference of the International Telecommunications Society.  
Ambjornsen, T., et al. (2011). Customer ignorance, price-cap regulation, and rent-seeking in mobile roaming. In 
Information Economics and Policy.  
43 Juniper Research estimates that, thanks to the RLAH policy, Europe  will experience the greatest decline on 
"silent  roamers"  in  the  world,  releasing  also  an  important  retail  revenue  opportunity  for  telecom  operators, 
especially  on  data.  In  Western  Europe,  Juniper  Research  estimates  that  the  lost  revenue  opportunity  for 
operators will decrease from 723.9 billion dollars in 2016 to 261.3 billion dollars in 2017, once RLAH has been 
implemented.    In  North  America,  for  example,  the  lost  revenue  opportunity  will  increase  from  909  billion 
dollars to 1.022 billion dollars in the same period.   

44 BEREC Report on the wholesale roaming market, BoR(16)33, February 2016, sections 2.1 and 2.2 
45 Highest value among EU Member States: 23.80 € in Ireland 

32 

 
 
 
 
 
 
 
 
 
                                                           
 
Figure 10 - Intra-EEA retail roaming revenues as % of total retail revenues (x-axis) 

Data: operators' replies to the autumn 2015 data collection 
JRC's calculations 

The share of direct intra-EEA retail roaming revenues, received by operators through current 
retail roaming surcharges, has been decreasing over the last years. This is result of decreasing 
retail roaming prices under decreased price caps in July 2013 and 2014. In the first semester 
2015, intra-EEA retail roaming revenues represented less than 5% of total retail revenues for 
almost 80% of the operators. This is an important observation in view of the sustainability of 
the abolition of retail roaming surcharges. 

33 

 
 
 
 
  
Figure 11 - Intra-EEA retail roaming traffic as % of total retail traffic (outgoing minutes) 

Data: operators' replies to the autumn 2015 data collection 
JRC's calculations 

Figure 12 - Intra-EEA retail roaming consumption as % of total retail consumption (outgoing 
SMS) 

Data: operators' replies to the autumn 2015 data collection 
JRC's calculations 

34 

 
 
 
 
Figure 13 - Intra-EEA retail roaming consumption as % of total retail consumption (data) 

Data: operators' replies to the autumn 2015 data collection 
JRC's calculations 

In  terms  of  volumes,  for  80%  of  the  operators,  intra-EEA  retail  roaming  consumption 
represents  less  than  3%  and  5%  of  total  retail  consumption  of  outgoing  minutes  and  SMS 
respectively.  For  data,  the  share  of  intra-EEA  retail  roaming  consumption  in  total  retail 
consumption is below 1.5% for 80 % of the operators.  

One can therefore make  the following observations. First  of all, the share of retail  roaming 
revenues  in  total  retail  revenues  (Figure  10)  is  higher  than  the  share  of  retail  roaming 
consumption in  total  retail consumption for voice and data (Figure 11 and  Figure 13). This 
reflects the higher prices paid by customers for retail roaming consumption than for domestic 
consumption. 

Second,  the  lower  share  of  roaming  consumption  in  total  consumption  for  data  services 
indicates  that  roaming  customers  seem  to  use,  proportionally  to  their  domestic  habits,  less 
data than voice and SMS while roaming in the EEA.  

Third, the share of roaming consumption in  total consumption for data has been increasing 
since 2013. This means that intra-EEA roaming data consumption has increased more rapidly 
than  domestic  data  consumption.  This  is  likely  to  be  a  direct  effect  of  the  two  successive 
retail  roaming  price  cap  regulations  in  July  2013  and  2014,  which  have  to  some  extent 
unleashed data usage in an intra-EEA roaming situation on top of the positive trend in data 
consumption observed domestically. RLAH is likely to potentiate even more this trend, in a 
general technological context where data consumption will be proportionally more and more 
important in all settings (domestic and whole travelling). 

35 

 
 
 
 
 
 
 
Figure  14  shows  per  country,  the  share  of  intra-EEA  retail  roaming  consumption  in  total 
retail (domestic plus roaming intra-EEA and extra-EEA) consumption, in terms of revenues 
and volumes for each service. 

Figure 14 - Intra-EEA retail roaming revenues and volumes as % of total retail revenues and 
volumes (y-axis) by country, 2014 

Data: operators' replies to the autumn 2015 data collection 
JRC's calculations 

In  2014,  the  share  of  intra-EEA  retail  roaming  revenues  in  total  retail  revenues  was  the 
highest  for  operators  in  Luxembourg  (~9%),  Slovakia  and  Slovenia  (~7%),  Norway  and 
Belgium  (~5%).  The  higher  share  observed  for  Luxembourg's  operators  is  linked  to  the 
longer time that residents of that country spend abroad in the EEA compared to residents of 
other EEA countries. For operators in all other countries than these five countries, the share 
of intra-EEA  retail  roaming revenues in  total  retail  revenues is  smaller than 5%. This  is  an 
important  observation  in  view  of  the  sustainability  of  the  abolition  of  retail  roaming 
surcharges. 

As noted at operator level in Figure 11 to Figure 13 above, for almost all countries, the share 
of retail roaming in total retail consumption is higher in terms of revenues than in terms of 
volumes.  This  is  due  to  the  higher  prices  paid  by  customers  for  roaming  services  than  for 
domestic  services.  For  almost  all  countries,  the  share  of  retail  roaming  in  total  retail 
consumption is smaller for data services than for voice and SMS services, a sign of the higher 
propensity  of  customers  to  limit  data  consumption  than  voice  or  SMS  consumption  while 
roaming. 

4.5. Retail roaming offers  

36 

 
 
 
 
 
This section is based on the information provided by EEA operators during the autumn 2015 
data  gathering  exercise  and  draws  on  the  analysis  made  by  BEREC  of  the  information 
received about existing RLAH offers46 .  

Recently an increasing number of operators have started to offer domestic tariff plans which 
include roaming services in the domestic bundle. This reflects new competition dynamics in 
the  retail  roaming  market,  the  roaming  part  of  a  domestic  tariff  plan  becoming  a  new 
commercial argument to attract customers and increase market shares. This is indicative that, 
in  the  RLAH  context,  "roaming  revenues"  will  be  in  part  transformed  and  included  in  the 
revenues derived from the domestic tariffs, with which operators compete for customers.47 

However,  most  of  these  tariff  plans  do  not  cover  all  EU  Member  States,  or  concern  only 
voice and SMS, or data only, and/or include roaming services in the domestic bundle as  an 
add-on package (i.e. for a fixed periodic - daily, weekly or monthly – charge which represents 
a fixed roaming surcharge over the domestic price),  In fact,  most of the available offers do 
not  fully  comply  with  the  RLAH  requirements  set  out  in  the  Regulation.  The  geographical 
scope  of  these  offers  usually  reflects  the  countries  where  the  operator  is  present,  and 
countries where good roaming deals were concluded. 

The  truly  RLAH  offers  (with  no  add-on)  which  exist  on  the  market  are  mostly  high-end 
domestic  tariff  plans  aimed  at  high-end  or  professional  users.    The  geographical  scope  of 
these RLAH offers varies. In some Member States however, such offers also exist for (non-
business) consumers while in other Member States, such offers do not exist at all (see Table 
13 in Annex 1).  

In  most  existing  RLAH  offers  (be  they  included  in  the  domestic  tariff  plan  for  an  add-on 
price  or  not)  the  amount  of  roaming  consumption  included  in  the  domestic  tariff  plan,  is 
subject to fair use clauses. These clauses may take very different forms across operators and 
tariff plans. Fair use limits usually depend on the price of the tariff plan and are more often 
expressed  as  a  volume  limitation  per  month.  This  volume  limit  may  be  on  the  amount  of 
domestic volume available while roaming or it may be on an extra specific roaming volume 
available on top of the domestic volume. In some cases, fair use limits are expressed in terms 
of days per year (e.g. from 10 to 60 days a year), often combined with an additional volume 
limit  per  month  on  data.  In  most  countries,  the  roaming  data  volumes  in  RLAH  offers  are 
rather low, usually below 500 MB per month. The roaming data allowance in RLAH offers is 
always capped, even if the offer includes unlimited voice and SMS units. 

Once  fair  use  limits  are  reached,  users  can  usually  continue  using  roaming  services  at 
regulated prices. Data is often simply throttled beyond fair use. 

4.6. Current technological developments as potential substitutes to roaming 

In the questionnaire circulated by BEREC in mid-September 2015, many operators stated that 
incipient technological developments such as eSIM or VoLTE among others will impact the 
functioning  of  the  roaming  market.  While  these  technological  developments  still  are  at  an 

46 BEREC Report on the wholesale roaming market, BoR(16)33, February 2016, section 2.3. 
47 According to Juniper Research's estimates, Western Europe will continue to be, despite the immediate effects 
on revenue of the RLAH regulation, the largest roaming market in the world, accounting for 14.011 billion 
dollars in 2020. 

37 

 
 
 
 
 
 
 
                                                           
early phase of implementation in the market, this section reviews their potential effect in the 
roaming context, with a special focus on eSims.  

  What are eSims? 

Electronic  Sim  cards  (also  known  as  virtual  Sims)  are  here  understood  as  a  new  type  of 
technologies that allow consumers to switch and combine mobile operators without having to 
introduce a physical Sim card in their mobile devices.48   

  What are eSims theoretical market impact? 

eSim  cards  can  basically  reduce  consumer's  transaction  costs  when  switching/combining 
operators.  In theory, this opens up the possibility of greater choice and competition at both, 
domestic and EU level.  eSims can be a significant substitute for roaming (see below).  

  What is their current diffusion/situation? 

While in the machine-to-machine context, eSIMs cards have been used for several years, its 
introduction in consumer devices is only now taking-off.  At the 2015 and 2016 editions of 
Mobile World Congress in Barcelona, the GSMA staged its intention to align all ecosystem 
participants on standardized reference architecture in order to introduce eSIMs.  In the 2015 
edition of the MWC, Simless, Inc., a US-based startup, unveiled the world's first GSM phone 
without  a  SIM  card  slot.  "Apple  SIM",  which  works  in  several  iPad  models  and  in  limited 
countries,  is  a  form  of  eSim  that  gives  users  the  option  to  select  from  a  number  of  carrier 
partners. These include GigSky, a pay-as-you-go data provider that offers cellular data plans 
in more than 90 countries.49  On July 16, 2015 The Financial Times reported that Apple and 
Samsung were in talks with a significant amount of telecom groups to launch a standardized 
eSim card50.  

eSims  were  cited  as  the  second  technology  to  have  the  greatest  future  impact  on  the 
telecommunications  market  (below  cognitive  technology)51  in  a    survey  conducted  by  IBM 
(and  presented  in  IDATE's  Digiworld  Summit).    A  recent  report  by  McKinsey52states  that 
"the  ability  to  change  providers  easily  means  that  eSim  customers  don’t  have  to  carry 
multiple  Sims,  have  full  tariff  transparency,  and  can  more  easily  avoid  roaming  charges". 
eSims diffusion seems strongly aligned with the diffusion of "wearables", connected cars and 
global roaming devices and containers53, what has a strong international component. This is 
confirmed by the results of the Public Consultation that the Commission undertook in 2015 in 
view  of  the  revision  of  the  overall  EU  Telecommunications  Framework,  where  a  specific 
question on eSims was asked to stakeholders.  

48 In terms of their potential openness, eSims are related to the so called "network-agnostic Sim cards", first 
regulated in the Netherlands in 2014.  Companies (not costumers) are free to issue their own Sims, and then buy 
minutes, SMS and data in bulk from operators, what could have an impact on roaming as well. See: 
https://gigaom.com/2014/03/14/holland-says-yes-to-the-network-agnostic-sim-card/ 
49 Juniper Research (December 2015). Mobile Roaming. Market Trends & Competitive Landscape. p 12. 
50 http://www.ft.com/intl/cms/s/0/fc78a3ea-294b-11e5-acfb-cbd2e1c81cca.html#axzz3yv6cE3pN 
51 http://www.digiworldsummit.com/wp-content/uploads/2015/07/DWS15_Rob_van_den_Dam_1.pdf 
52 http://www.mckinsey.com/industries/telecommunications/our-insights/e-sim-for-consumers-a-game-changer-
in-mobile-telecommunications 
53 http://rethink-wireless.com/2016/02/22/esim-extends-its-reach-to-wearables-cars-and-global-
roaming/?utm_source=Rethink+Wireless+List&utm_campaign=f06999aa53-
Rethink_Wireless_Monday_22_02&utm_medium=email&utm_term=0_80b97e02cb-f06999aa53-164266989 

38 

 
 
                                                           
  What is/can be their impact on roaming? 

eSims are a technical development that constitutes a possible substitute to roaming, providing 
a potentially less expensive solution for consumers, and thus introducing competition forces 
at  both  retail  and  wholesale  level.  This  entails  not  only  a  technical,  but  a  subjective 
perception: consumers must see eSims as a satisfactory solution to their international needs. 
Following the RIII impact assessment report (Annex I)54, 5 criteria to evaluate the potential 
of eSims as substitutes for roaming were considered. 

1. Mobility. Refers to the possibility of being able to move while using voice, SMS or 
data service. eSims offer high mobility - the consumer can use a local plan throughout 
the territory covered by the local chosen provider's network.  

2.  Availability.  Refers  to  the  availability  of  the  alternative  itself  as  well  as  of  the 
technical  coverage.  eSims  themselves  have  currently  a  very  limited  availability,  but 
given the situation explained above, they might become a standard in the near future. 
There will be a period of co-existence between Sim and eSim.  In terms  of the local 
operators  available  to  the  consumer,  eSims  make  it  potentially  very  easy  for  the 
consumer to choose between offered plans, as there is no need to switch the Sim card, 
nor go to a foreign retail store to buy a local Sim. On the other hand, the availability 
of  operators  will  depend  on  potential  blockages,  especially  likely  to  take  place  in 
subsidized handsets. 

3.  Accessibility.  Relates  to  the  possibility  of  being  reached  at  any  time  and  at  any 
location on the same phone number. eSims offer high accessibility, as domestic home 
numbers can potentially  be combined with  foreign  numbers using the same headset. 
The  trend  towards  data  and  VoLTE  is  also  a  significant  positive  factor  towards 
accessibility. 

4.  Affordability.  Concerns  the  investment  (one-off  cost)  and  the  cost  of  using 
(recurring  cost  depending  on  the  volume  of  services)  for  using  alternative  services. 
With  eSims,  the  consumer  can  easily  benefit  from  local  tariffs  (for  example,  easily 
buying X GB of data), which can be potentially better than RLAH tariffs or RLAH + 
sustainability  tariffs.  This  introduces  market  pressure  to  RLAH-type  of  offers  that 
include more generous FUP (to avoid "educating" consumers on switching operators 
once FUPs limits are surpassed).  

 5. Ease of use. Refers to the steps required / possible difficulties before being able to 
use the service, as well as the ease of the actual use of the alternative service. eSims 
have  the  potential  to  dramatically  reduce  the  transaction  costs  related  to  the 
consumer's research efforts to find and compare service providers in the area. There 
might be, however, learning costs for users regarding different local tariffs.   

In sum, the current availability of eSims, and of operators that are given access to the eSim 
"market",  is  the  main  factor  limiting  eSIMs  being  a  viable  substitute  for  roaming.  There  is 
still  high  uncertainty  regarding  the  specific  strategies  that  operators  are  going  to  follow  in 
relation  to  this  new  technological  development.  For  example,  if  Local  Break-Out  (LBO) 
technologies  (see  section  5.6)  diffuse  in  parallel  to  eSims,  visited  operators  may  decide  to 

54 Other technologies considered have been: Local SIM cards, Over Wi-Fi, Over WiMax, Multi-IMSI, Call 
back.  

39 

 
 
                                                           
restrict eSims packages in order to avoid cannibalization. Nonetheless, eSims show indeed a 
clear potential to introduce competitive pressure in the international roaming market, but this 
will be contingent on the different strategies that will finally shape the technology. 

Other  technological  developments  related  to  roaming  are  VoLTE  and  Fi.  VoLTE  promises 
HD voice over packet-switched technology to the consumer that has a supporting device. It is 
associated to an infrastructural change towards all-data, so it can have a substitution effect in 
relation  to  current  voice  and  SMS  roaming  services,  creating  a  new  dynamic  at  both 
wholesale and retail level. It terms of roaming, however, VoLTE use will still be dependent 
on  the  data  provisions  of  visited  networks.  While  VoLTE,  due  to  its  better  traffic 
management,  is  widely  seen  by  operators  as  a  way  of  competing  with  OTTs  (also  in  the 
roaming  context)55,  it  is  only  now  that  plans  around  its  deployment  are  being  released  in 
Europe56.  It  is  indeed  still  soon  to  venture  into  the  actual  specific  effects  that  this 
technological development might have on international roaming markets57. 

Google  has  also  developed  a  technology  and  an  associated  business  model  with  a  potential 
high  impact  on  international  roaming.  Google  Fi  lets  users  connect  to  the  best  available 
network in each situation. The signal, which can come from different operators in one single 
session, is in principle never dropped58: The user automatically switches to Wi-Fi, 3G/4G, or 
other different networks without noticing. Fi is currently available in certain Nexus models in 
the  US,  where  Google  has  become  a  de  facto  MVNO.  Through  its  deals  with  mobile 
operators, Google has secured competitive internationals roaming rates: Google Fi costumers 
surf at the same rate (10$ per 1GB) than in the US in more than 120 countries, but at reduced 
3G speeds. Google Fi-type of models/technologies, if coming to the European market, could 
bring competitive pressure to RLAH offers.    

4.7. Conclusion 

There have been some important developments on the retail roaming markets recently, with 
domestic  offers  proposing  more  and  more  affordable  roaming  prices  to  the  customers. 
However,  most  of  the  new,  RLAH-like,  retail  roaming  offers  are  not  RLAH  offers  in  the 
sense of the Roaming Regulation, i.e. covering the full of the EU for no additional surcharge 
at all (no add-on) within fair-use limits.  In addition, these developments  are unequal  across 
Member  States  .  With  the  current  levels  of  competition  in  wholesale  roaming  markets, 
therefore, the retail markets have not been capable of delivering full EU-wide RLAH. 

Regarding technological developments concerning roaming, there have also been significant 
changes in some Member States, especially the diffusion of smartphones, OTT services and 
the  proliferation  of  Wi-Fi  hotspots.  Among  the  new  emerging  technologies,  eSims  might 
have  a  significant  impact  in  the  mid-term,  even  though  this  is  highly  contingent  to  the 
different strategies that will be play-out around them. Overall, however, none of the observed 
technologies constitutes a perfect substitute for roaming services. Thus, their current market 
pressure remains limited.   

55 http://www.businesswire.com/news/home/20150224006896/en/81-Operators-VoLTE-Key-Competing-OTTs-
Expect 
56 Orange announced in the MWC16 its plans to offer VoLTE and Wi-Fi calling services in Europe. 
57 Juniper Research predicts a 783% growth on VoLTE connections until 2018. The same organization also 
estimates that data will take an increasing proportion of the global roaming revenues at least until 2020.  
58 Juniper Research (December 2015). Mobile Roaming. Market Trends & Competitive Landscape. p 14. 

40 

 
 
 
 
 
                                                           
5.  ASSESSMENT OF THE COST OF PROVIDING WHOLESALE ROAMING SERVICES IN THE 

EEA 

5.1. Introduction 

This  section  describes  the  approach  to  assessing  the  costs  of  providing  wholesale  roaming 
services in the EEA. This section is structured as follows: 

  Description of the Commission's approach in assessing the costs of providing 

wholesale roaming services in the EEA; 

  brief overview of previous estimates of costs of wholesale roaming services; 
  description of the TERA Consultants' model that was commissioned to estimate the 

costs of wholesale roaming services; 

  description of the approach to assessing the termination rates that should be 

considered for the purposes of assessing the costs of originating voice calls by a 
visited network operator; 

  assessment of international transit costs, relevant for roaming services; 
  sense-checks conducted on the estimates of wholesale roaming costs; 
  approach to assessing the costs of wholesale roaming SMS services; and 
  conclusions on the costs of providing wholesale roaming services in the EEA. 

This section should be read jointly with the TERA Consultants' report on the cost model used 
as an input to assess the costs of providing wholesale roaming services in the Final report of 
the study59. 

5.2. Description of the Commission's approach  

The Commission has relied on several sources of information to assess the costs of providing 
wholesale roaming services in the EEA.  

Firstly, an independent study to assess the level of costs incurred by visited network operators 
when providing wholesale roaming services was  commissioned60. The study was conducted 
from end of October 2015 to the end of March 2016. When developing the cost model, the 
contractor had to take into account, as far as possible, the methodologies and approaches used 
by NRAs in EU Member States to estimate mobile network costs. The aim was to build a cost 
model  that  facilitated  as  far  as  possible  the  estimation  of  wholesale  roaming  costs  in  every 
EEA Member State.  Information on NRAs' cost models and relevant cost data necessary to 
form  a  view  on  the  costs  of  mobile  network  operators  in  the  EEA  were  obtained  via  two 
questionnaires sent  in  September 2015 by the Commission  and BEREC to  M(V)NOs in  all 
Member  States  and  NRAs,  as  well  as  via  additional  requests  from  the  Commission  on  the 
characteristics and inputs of NRAs' mobile termination rates cost models in the course of the 
study  (December  2015  and  January  2016).  The  public  consultation  itself  did  not  have  the 
objective of providing information on wholesale roaming costs. 

In addition, the Commission has relied on other sources of information, namely: 

59 European Commission, Assessment of the cost of providing wholesale roaming services in the EEA, Final 
report, study conducted by TERA Consultants, to be published 
60 Study SMART 2015/006 "Assessment of the cost of providing wholesale roaming services in the EU", TERA 
Consultants 

41 

 
 
 
                                                           
  Data on fixed and mobile termination rates currently in place in MS; and 
 

Information on domestic retail prices. 

These sources are described in more detail below. 

5.2.1.  Questionnaires to NRAs and operators 

For  the  purpose  of  assessing  the  cost  of  providing  wholesale  roaming  services  in  the  EU, 
NRAs were requested to provide data and information about: (i) the cost model they use to 
estimate mobile network costs, including detailed information on characteristics of their cost 
model (e.g. equipment utilisation factor, radio access network sites), and inputs to their cost 
model  (e.g.  commercial  traffic,  busy  hour  traffic,  geotypes,  spectrum,  cell  radii);  (ii)  their 
estimated 
SMS 
origination/termination, data); (iii) any applicable wholesale price regulation for MVNOs in 
their  country;  (iv)  market  data  on  overall  volumes  of  retail  consumption  of  each  service 
(minutes, SMS, MB) in their country.  

origination/termination, 

network 

service 

(voice 

cost 

per 

For  the  purpose  of  assessing  the  cost  of  providing  wholesale  roaming  services  in  the  EEA, 
operators  were  requested  to  provide  data  and  information  about:  (i)  current  wholesale 
roaming  agreement  structures  and  tariffs,  including  the  situation  of  light  MVNOs;  (ii) 
specific wholesale and retail roaming costs; (iii) wholesale roaming payments, revenues and 
volumes  by  Member  States  of  destination  and  origin;  (iv)  average  wholesale  prices  for 
balanced and unbalanced traffic, (v) expected wholesale roaming prices for the year 2016. 

5.2.2.  External study to estimate wholesale roaming costs 

5.2.2.1. 

The call for tenders 

On  24  July  2015,  the  Commission  services  published  an  advance  notice  for  a  contract  to 
assess the cost of providing wholesale roaming services in the EEA, to be awarded under the 
negotiated procedure. On 11 August 2015, the Commission services invited eight companies 
that had expressed interest to submit an offer. Four companies responded to the call and sent 
their respective tenders by the deadline of 7 September 2015 set in the invitation to tender. 
The contract was awarded to TERA Consultants and signed by the latest party on 21 October 
2015. The last deliverable under this contract is due within 5 months after that date. 

5.2.2.2. 

The objectives of the study 

The  study  has  estimated  the  efficient  costs  (including  proportionate  allocation  of  joint  and 
common  costs)  of  providing  wholesale  roaming  services  (including  voice,  SMS  and  data 
roaming services) by mobile network operators in 28 MS plus Norway.61  

5.2.2.3. 

Consultation with NRAs and mobile operators 

During  the  development  phase  of  the  cost  model  by  the  contractor,  NRAs  were  regularly 
consulted  via  the  International  Roaming  Expert  Working  Group  of  BEREC  on  the 
methodological approach.  In order to take into account, as far as possible, the methodologies 

61 The 29 countries included in the TERA cost model are: Austria (AT), Belgium (BE), Bulgaria (BG), Cyprus 
(CY), Czech  Republic (CZ),  Germany (DE),  Denmark (DK), Estonia (EE), Greece (EL), Spain (ES),  Finland 
(FI),  France  (FR),  Croatia  (HR),  Hungary  (HU),  Ireland  (IE),  Italy  (IT),  Lithuania  (LT),  Luxembourg  (LU), 
Latvia (LV), Malta (MT), Netherlands (NL), Poland (PL), Portugal (PT), Romania (RO), Sweden (SE), Slovenia 
(SI), Slovakia (SK), United Kingdom (UK) and Norway (NO). 

42 

 
 
 
                                                           
and approaches used by NRAs in EEA Member States, NRAs were asked to provide detailed 
information  on  characteristics  of  their  respective  cost  models  used  for  mobile  termination 
rates.  

On 28 January 2016 the Commission and the contractor organised a public workshop where 
the  contractor  presented  the  interim  results  of  the  study  in  order  to  obtain  feedback  on  the 
cost model from NRAs and operators. The feedback from stakeholders has been incorporated 
into  the  final  version  of  the  cost  model  (described  in  more  detail  in  Final  report  of  the 
study62).  In  addition,  between  March  –  April  2016,  the  cost  model  developed  by  TERA 
Consultants  was  shared  with  the  NRAs  from  the  countries  included  in  the  study.  TERA 
Consultants incorporated, as far as possible, the comments from NRAs into the final version 
of the model.   

5.3. Previous estimates of wholesale roaming costs 

In December 2010 BEREC estimated the following upper bound, average and lower bound of 
wholesale costs for wholesale roaming services63 : 

Table 3 - BEREC's estimations for upper bound, average and lower bound of wholesale costs 
for wholesale roaming services (2010) 

Outgoing voice call 
Incoming voice call 
SMS 
Data 

Maximum  
€9.7cents/min 
€3cents/min 
€2.7cents/SMS 
€15cents/MB 

Average 
€5.4cents/min 

Minimum 
€3cents/min 

€0.8cents/SMS 
€8.1cents/MB 

€0.6cents/SMS 
€1.6cents/MB 

These  cost  estimates  were  used  in  the  Impact  Assessment  accompanying  the  Commission 
proposal for Roaming Regulation III. 

In  February  2012,  BEREC  updated  its  analysis  of  wholesale  roaming  costs.  BEREC's  new 
estimations were64:  

Table 4 - BEREC's estimations wholesale costs for wholesale roaming services (2012) 

Outgoing voice call 
SMS 
Data 

Maximum  
€5cents/min 
€1cent/SMS 
€5cents/MB 

These  new  cost  estimates  were  used  during  the  negotiations  on  Roaming  Regulation  III 
between  the  co-legislators,  and  informed  the  setting  of  new  wholesale  roaming  price  caps 
after 1 July 2014 set in Roaming Regulation III adopted in June 2012. 

5.4. The TERA Consultants cost model  

62 European Commission, Assessment of the cost of providing wholesale roaming services in the EEA, Final 
report, study conducted by TERA Consultants, to be published 
63 BEREC (2010), International Mobile Roaming Regulation BEREC Report, BoR(10)58, December 2010. 
64 BEREC (2012), BEREC Analysis of Wholesale Roaming Costs, BoR(12)14, February 2012 

43 

 
 
 
 
 
 
 
 
 
 
                                                           
This  section  briefly  describes  the  main  features  of  the  TERA  Consultants  cost  model 
(hereinafter,  the  cost  model).  For  additional  information  on  the  approach  followed  and  the 
results of the cost model, please refer to the TERA Consultants' Final report of the study65. 

5.4.1.  The approach followed by TERA Consultants 

The  TERA  Consultants  cost  model  estimates  the  costs  of  providing  wholesale  roaming 
services in 28 MS plus Norway. Two EEA countries, notably Iceland and Liechtenstein were 
not part of the study as no information as part of the autumn information request was received 
and  due  to  the  lack  of  publicly  available  information  on  the  cost  models  used  by  these 
countries'  NRAs  to  set  mobile  termination  rates.  In  addition,  little  information  from  certain 
MS of the EU (e.g. Germany or Estonia) was provided. 

The cost model focuses on the costs of providing wholesale roaming services by the visited 
network operator and, in particular, on the following five mobile services: 

 
Incoming voice calls (i.e. voice termination on the visited network); 
  Outgoing voice calls (i.e. voice origination on the visited network); 
 
Incoming SMS (i.e. termination of SMS on the visited network); 
  Outgoing SMS (i.e. origination of SMS on the visited network); and 
  Data services. 

It should be noted at the outset that the TERA cost model has mainly focused on estimating 
the  costs  of  voice  and  data  services,  as  these  are  the  most  important  wholesale  roaming 
services. Therefore the cost model's estimates of wholesale SMS costs are not considered as 
robust  as  the  estimates  of  voice  and  data  services  and  therefore  the  approach  followed  to 
assessing the costs of wholesale SMS services is described below. In addition, the TERA cost 
model does not assess the costs of international transit, which are also relevant for roaming 
voice  and  data  services.  The  approach  to  estimating  the  costs  of  international  transit  is 
described in more detail in section 5.6 below. 

The cost model distinguishes between two different types of costs relevant for the provision 
of wholesale roaming services, notably: 

  Network costs: the costs of rolling out the mobile network to provide mobile services 
to both domestic and roaming customers in each of the 29 countries considered; and 
  Roaming specific costs: network and non-network costs that a mobile company incurs 

in order to provide wholesale roaming services. 

In  addition,  the  cost  model  also  estimates  the  impact  of  seasonality  on  the  allocation  of 
underlying  network  costs  between  domestic  and  roaming  customers.  Seasonality  can  be 
described as follows. Mobile network operators typically make decisions about network built 
up (e.g. the capacity they need to build in certain areas) based on the traffic they expect in a 
specific area at peak hour. A significant share of roaming traffic is seasonal, meaning that is 
concentrated  in  certain  periods  of  the  year  (typically,  the  summer  period)  and  is  also 
concentrated in certain geographic locations (i.e. touristic areas). Thus, some operators (50% 
in the public consultation) argue that roaming traffic drives operators' investment decisions to 

65 European Commission, Assessment of the cost of providing wholesale roaming services in the EEA, Final 
report, study conducted by TERA Consultants, to be published 

44 

 
 
 
 
 
 
                                                           
build  additional  capacity  in  certain  areas  to  accommodate  the  additional  roaming  traffic 
received over the summer period. Furthermore, these operators argue that the investment cost 
of  building  this  additional  capacity  in  touristic  areas  should  be  recouped  from  the  roaming 
traffic  received  over  the  short  seasonal  period,  as  roaming  customers  drive  operators' 
investment  decisions.  In  practice,  this  approach  would  mean  that  a  significant  share  of  the 
investment  costs  in  touristic  areas  has  to  be  recovered  from  a  relatively  low  annualised 
volume  of  traffic  (the  seasonal  roaming  traffic)  and  may  therefore  result  in  significantly 
higher unit cost for roaming traffic than for domestic traffic.  

In contrast, 40% of the operators responding to the public consultation defend the view that 
there is no impact of seasonality on the costs of providing wholesale roaming services. These 
operators argue that seasonality would concern only a very small part of the network, which 
has no effect on the total network costs.  They note that domestic traffic is also seasonal and 
that  the  costs  of  meeting  roaming  capacity  are  not  different  than  the  costs  of  domestic 
capacity. They finally underline that roaming seasonality also works in favour of the visited 
operator,  by  optimising  the  use  of  some  sites  as  domestic  users  move  away  while  tourists 
arrive  ('inverse  peaks’).  The  remaining  10%  of  the  responding  operators  do  not  pronounce 
themselves on this question.  

Finally,  TERA  Consultants  have  run  several  sensitivities  on  their  estimated  costs  of 
wholesale roaming services (see the Final report of the study for further details). In particular, 
they have assessed the impact on the estimated costs of changing several of the assumptions 
used66. This sensitivity analysis shows that the costs estimated by the model are robust, as the 
changes in the unit costs estimated by the model are consistent with the expected changes in 
the underlying assumptions and the unit costs estimated under these sensitivity scenarios are 
broadly in line with those estimated under the main base case scenario.  

The sections below look into these issues in more detail.  

5.4.2.  High level assumptions in TERA's cost model 

When developing a cost model there are several decisions that need to be made regarding the 
approach  chosen  to  estimate  costs.  In  developing  their  cost  model  TERA  has  made  a 
significant number of assumptions and modelling choices, however, this section only briefly 
summarises and explains the justifications for some choices made in  the  TERA cost  model 
that were considered particularly important, namely: 

  The choice of  cost standard; 
  The approach to cost modelling; and 
  The choice between modelling the costs of an existing operator or an hypothetical 

efficient operator (HEO). 

For  further  information  on  the  modelling  assumptions  used  by  TERA  Consultants  in  their 
cost model, please refer to the Final report of the study67. 

5.4.2.1.  The choice of cost standard  

66 In particular, as regards the assumption of (i) Single RAN; (ii) cost allocation (in Erlang vs Mbps); (iii) 
VoLTE; and (iv) volumes forecasts.  
67 European Commission, Assessment of the cost of providing wholesale roaming services in the EEA, Final 
report, study conducted by TERA Consultants, to be published 

45 

 
 
 
 
 
 
                                                           
The two most common cost standards used to derive the costs of providing a service are the: 

  Long-Run Incremental Cost (LRIC); and 
  Long-Run Incremental Cost plus some allocation of common cost (LRIC+). 

The LRIC is the cost of producing a specified additional increment of output in the long run 
(the long run meaning that all production inputs, including capital investment, are considered 
variable).  The  relevant  increment  considered  may  encompass  the  entire  output  of  just  one 
service or that of a group services. Another way to look at it is that the incremental cost of a 
service is the difference between the total costs in a situation where the service is provided 
and the costs in another situation where the service is not provided (i.e. the incremental costs 
are the costs avoided by no longer supplying the specific service).  

In  contrast,  the  LRIC+  cost  standard  includes,  in  addition  to  the  incremental  costs  of  the 
specific  service,  a  contribution  to  costs  that  are  common  or  shared  with  other  services 
provided  by  the  company.  In  the  case  of  a  mobile  network,  the  incremental  costs  of  data 
services will be those costs that are solely driven by the provision of data services whereas 
common  costs  would  be  costs  associated  with  activities  or  equipment  that  are  shared 
between, say, data services  and voice services.  A  LRIC+ approach  ensures that all costs of 
provision are fully allocated to services. In general, companies need to recover common costs 
to ensure that their business is sustainable in the long term. For this reason, common costs are 
typically allocated or shared among the different services that generate them, and recovered 
in the prices for those services. 

The  TERA  cost  model  estimates  service  costs  using  a  combination  of  both  cost  standards: 
LRIC and LRIC+. As a rule, it estimates costs based on LRIC+, as this is consistent with the 
Roaming Regulation's Article 19, notably that: 

"In assessing measures necessary to enable the abolition of retail roaming surcharges, 
the  Commission  shall  take  into  account  the  need  to  ensure  that  the  visited  network 
operators  are  able  to  recover  all  costs  of  providing  regulated  wholesale  roaming 
services, including joint and common costs."   

Thus, TERA's cost model estimates costs for the following services based on LRIC+: 

  Outgoing voice calls; 
  Outgoing SMS; and 
  Data services. 

In the case of incoming voice (i.e. voice termination), the TERA cost model estimates these 
costs  based  on  pure  LRIC.  This  is  to  ensure  consistency  with  the  Commission's  2009 
Recommendation  on  Termination  Rates,  which  recommends  the  estimation  of  termination 
rates based on a bottom-up pure LRIC approach,68 and which has been implemented by the 
majority  of  MS  in  the  EU  and  consistently  supported  by  BEREC.  For  incoming  SMS 
services, the TERA cost model does not allocate any cost to these services. This is to ensure 
consistency with  Regulation No 531/2012  which states that  "roaming customers should not 
be required to pay any additional charge for receiving a regulated roaming SMS or voicemail 

68 Commission Recommendation of 7 May 2009 on the Regulatory Treatment of Fixed and Mobile Termination 
Rates in the EU, available here. 

46 

 
 
 
 
 
 
                                                           
message  while  roaming  on  a  visited  network,  since  such  termination  costs  are  already 
compensated  by  the  retail  charge  levied  for  the  sending  of  a  roaming  SMS  or  voicemail 
message".69 

In practice, the approach for voice termination and incoming SMS means that some costs that 
would  have  been  otherwise  allocated  to  these  services  have  to  be  recovered  from  other 
services. The approach to re-allocating costs between services to ensure full cost recovery of 
joint and common service costs, consistent with the Roaming Regulation, is explained below. 

 There are two main approaches to modelling costs: 

5.4.2.2.  The approach to cost modelling 

  Top-down cost modelling based on the accounts of an existing operator; and 
  Bottom-up cost modelling based on a hypothetical efficient operator. 

Top-down  cost  models  derive  the  costs  from  the  operator's  accounts  and  allocate  these  to 
each service using some allocation rule. In contrast, bottom-up cost models use detailed data 
and engineering rules to build an hypothetical network of an efficient operator using the most 
advanced and efficient  technologies available in  the timeframe  considered by the model,  to 
the extent they can be identified.  

The TERA cost  model uses a mix of both  approaches.  For network costs it estimates these 
costs using a bottom-up approach, consistent with the approach followed by the majority of 
NRAs  when  estimating  mobile  termination  costs.  In  the  case  of  roaming  specific  costs, 
however,  as  there  is  no  data  and/or  engineering  rules  available  to  derive  the  efficient  costs 
bottom-up, TERA relied instead on the data provided by operators in the autumn information 
request.  

There  have  been  some  operators  that  have  disagreed  (both  during  the  January  2016 
Workshop and in response to the public consultation) with the use of a bottom-up approach 
based  on  efficient  costs  to  estimate  wholesale  roaming  costs,  advocating  instead  for  a  top-
down approach based on actual  costs.  It  does not  seem  possible to  agree  with  the views of 
these operators, however, for the following reasons.  

First of all, the purpose of the cost model is to provide an estimation of costs for the provision 
of  wholesale  roaming,  as  one  of  the  input  for  the  overall  assessment  of  the  functioning  of 
wholesale  roaming markets  and  eventually the adoption of appropriate  measures to  address 
any  failure  in  this  regard.  In  this  regard,  a  bottom-up  approach  based  on  efficient  costs  is 
more  appropriate  as  it  would  reflect  the  workings  of  a  competitive  market  and  therefore 
represents a reliable benchmark to  assess how the wholesale roaming market is functioning 
and  which  appropriate  measures  may  be  needed.  In  a  competitive  environment,  operators 
would be forced to be productively efficient and would not be compensated for inefficiently 
incurred  costs.  Furthermore,  in  the  context  of  two-way  access  services  such  as  roaming 
services, where operators need to purchase wholesale access from each other, it would not be 
appropriate  to  compensate  some  operators  for  being  inefficient  to  the  detriment  of  more 
efficient operators. Moreover, network costs are already subject to cost modelling across the 

69 Regulation No 531/2012 of 13 June 2012 on roaming on public mobile communications networks within the 
Union, available here. 

47 

 
 
 
 
 
 
 
                                                           
Union,  in  the  context  of  the  determination  of  MTRs,  and  the  adoption  of  the  hypothetical 
efficient operator approach for the calculation of the network costs would ensure that any cost 
estimation of roaming costs across the Union is generally consistent with the cost-modelling 
approach usually adopted for MTRs across Europe70.      

5.4.2.3.  Estimation of network costs 

The  first  step  in  TERA's  cost  model  is  to  estimate  the  network  costs  in  each  of  the  29 
countries  considered.  Estimating  the  network  costs  consists  of  several  steps  in  which  the 
model takes into account the costs of building up the network for the expected future demand, 
as shown in Figure 15 below. 

Figure 15. Steps in the estimation of costs in the TERA cost model 

Source: TERA Consultants report. 

The estimation of the network costs in the cost model consists of the 8 steps shown above. As 
described  in  more  detail  in  TERA's  report71,  the  approach  followed  by  TERA  is  consistent 
with the typical approach used by NRAs to estimate mobile termination costs in the EEA. In 
order to populate the model with relevant national data TERA relied on: 

  Publicly available cost models used by NRAs to estimate mobile termination costs;72 

and/or 

70 Also in previous cost estimation exercises related to roaming, one of the indicators was based on the cost-
modelling exercise carried out by NRAs, see for instance BEREC Analysis of Wholesale Roaming Costs carried 
out in 2012, BoR(12)14, also based on the assumption of the efficient network operator. 
71 European Commission, Assessment of the cost of providing wholesale roaming services in the EEA, Final 
report, study conducted by TERA Consultants, to be published 
72  TERA  relied  on  publicly  available  cost  models  from  9  countries,  namely:  Portugal,  Spain,  France,  UK, 
Netherlands, Norway, Sweden, Czech Republic and Romania.  

48 

 
 
 
 
                                                           
 

Information provided by NRAs in response to a questionnaire prepared by TERA;73 
and/or 

  Other publicly available information sources (e.g. Eurostat, CISCO studies, etc.) 

In  order  to  test  the  cost  model,  TERA  sense-checked  its  results  against  those  obtained  by 
several  NRAs  using  their  respective  cost  models,  as  further  described  in  the  study's  Final 
report74. 

As explained above, the costs of two services (voice and SMS termination) are estimated at 
pure LRIC and at zero, respectively. In order to ensure full recovery of costs (including joint 
and common costs), as required by the Regulation, this implies that the costs not recovered 
through these two services need to be re-allocated to other services. In this case, the TERA 
cost  model  re-allocates  the  joint  and  common  costs  from  voice  termination  to  voice 
origination  and  those  of  SMS  termination  to  SMS  origination.  This  is  shown  in  Figure  16 
below.  

Figure 16: Re-allocation of costs not recovered through voice and SMS termination 

Source: TERA Consultants report. 

In addition to this re-allocation of costs between services, the TERA cost model also includes 
a  re-balancing  of  costs  to  take  into  account  the  mobile  termination  rates  effective  in  every 
country. This works as follows. The TERA cost model calculates the total cost of the voice 

73  Eight  countries  with  no  publicly  available  cost  model  replied  to  TERA's  questionnaire,  namely:  Belgium, 
Denmark, Estonia, Austria, Croatia, Bulgaria, Greece and Malta. 
74 European Commission, Assessment of the cost of providing wholesale roaming services in the EEA, Final 
report, study conducted by TERA Consultants, to be published 

49 

 
 
 
 
 
 
                                                           
services,  including  the  pure  LRIC  and  common  costs  of  both  voice  termination  and 
origination.  However,  the  model  includes  three  different  scenarios  regarding  termination 
rates: 

  Voice termination rates are equal to mobile termination rates effective in each country 

on the second semester of 2015 (Scenario A in the model);  

  Voice termination rates are capped at the highest pure LRIC rate effective in the EEA 
as of the second semester of 2015 (the Slovak termination rate at €1.23c/min). In 
other words, if the national termination rate is lower than that level, then the national 
rate applies but if it is higher, the Slovak termination rate applies (Scenario B in the 
model).  

  Voice termination rates are considered to be equal to the pure LRIC for each country 

estimated by the cost model from TERA Consultants (Scenario C). 

In practice, the impact of the above re-balancing is that if the termination rate considered is 
higher than the pure LRIC estimated by TERA, then the model considers that the termination 
rate contributes towards the joint and common costs (and potentially the costs of origination 
if the termination rate considered is higher than the LRIC+ cost of termination estimated by 
TERA). This is shown in Figure 17 below. 

Figure 17: Example of re-balancing of costs with effective mobile termination rates  

Figure  18  below  shows  TERA's  estimates  of  the  network  costs  in  Scenario  B  (taking  into 
account national MTRs when lower than the Slovak pure LRIC MTR or the latter if higher) 
for voice origination. 

50 

 
 
 
 
 
 
Figure 18: TERA's cost estimates for voice origination after re-balancing for national MTRs 
under Scenario B (€c/min) 

Figure 19 presents the costs estimated by TERA for data services. 

Figure 19: TERA's cost estimates for data services (€c/MB) 

In  addition,  the  unit  cost  estimates  from  TERA  have  been  sense  checked  against  the  retail 
unit prices derived from a Commission study for each of the 29 countries considered.75 This 
section relied on the study's assessment of the prices for 5 mobile baskets in the 29 countries, 
namely: 

75 The study Mobile Broadband prices was prepared for the European Commission by Van Dijk Management 
Consultants 
https://ec.europa.eu/digital-single-
2015),  March 
from 
market/en/news/mobile-broadband-prices-february-2015 

February 

(prices 

2016: 

51 

 
 
 
 
 
 
                                                           
Table 5: Allowances included in the baskets of the study considered to estimate retail prices 

Voice calls 
51 min 
191 min 
576 min 
1809 min 
191 min 

Handset use 
SMS 
100 
140 
225 
350 
140 

Data 
100 MB 
500 MB 
1 GB 
2 GB 
2 GB 

Basket 1 
Basket 2 
Basket 3 
Basket 4 
Basket 5 

The  baskets  used  in  the  study  are  consistent  with  the  OECD  methodology  for  mobile 
telecommunications price baskets.76 Domestic retail prices have been derived by subtracting 
from  the VAT-inclusive  prices the  VAT in  every MS considered in  the analysis. The VAT 
rates considered were as follows: 

Table 6: Country VAT rates used to derive domestic retail prices excluding VAT 

Country 
AT 
BE 
BG 
CY 
CZ 
DE 
DK 
EE 
EL 
ES 
FI 
FR 
HR 
HU 
IE 
IT 
LT 
LU 
LV 
MT 
NL 
PL 
PT 
RO 
SE 
SI 
SK 
UK 

VAT rate 
20% 
21% 
20% 
19% 
21% 
19% 
25% 
20% 
23% 
21% 
24% 
20% 
25% 
27% 
23% 
22% 
21% 
17% 
21% 
18% 
21% 
23% 
23% 
24% 
25% 
22% 
20% 
20% 

76  Namely  OECD  (2012),  “Methodology  for  Constructing  Wireless  Broadband Price  Baskets”,  OECD  Digital 
Economy Papers, No. 205, OECD Publishing. http://dx.doi.org/10.1787/5k92wd5kw0nw-en and OECD (2009), 
“Revision 
basket” 
(DSTI/ICCP/CISP(2009)14/FINAL). 

telecommunications 

methodology 

construction 

price 

the 

for 

of 

52 

 
 
 
 
                                                           
NO 

25% 

Source: 
http://ec.europa.eu/taxation_customs/resources/documents/taxation/vat/how_vat_works/rates/vat_rates_en.pdf 
(page 16)] 

In  order  to  allocate  basket  prices  to  each  service,  we  use  the  average  wholesale  roaming 
prices effective in the 28 MS plus Norway that were gathered during the autumn information 
request  to  derive relative prices between services (voice, SMS and data).  The basket prices 
have  been  allocated  to  each  service  ensuring  that  the  relative  retail  prices  derived  are  the 
same as for average wholesale roaming prices in the 29 countries considered. 

Table 7 below presents the retail prices for each of the 29 countries considered. 

Table 7: Country retail prices using the relative prices of wholesale roaming prices 

AT 
BE 
BG 
CY 
CZ 
DE 
DK 
EE 
EL 
ES 
FI 
FR 
HR 
HU 
IE 
IT 
LT 
LU 
LV 
MT 
NL 
PL 
PT 
RO 
SE 
SI 
SK 
UK 
NO 

Voice (€c/min) 
3.84 
3.87 
8.74 
5.77 
7.43 
4.41 
3.09 
3.83 
6.21 
5.86 
3.91 
3.75 
5.24 
8.61 
4.69 
4.04 
1.77 
4.80 
4.33 
8.54 
5.60 
3.72 
7.16 
3.88 
3.80 
4.69 
5.40 
2.91 
3.80 

SMS (€c/SMS) 
1.18 
1.19 
2.70 
1.78 
2.29 
1.36 
0.95 
1.18 
1.92 
1.81 
1.21 
1.16 
1.62 
2.66 
1.45 
1.25 
0.55 
1.48 
1.34 
2.64 
1.73 
1.15 
2.21 
1.20 
1.17 
1.45 
1.67 
0.90 
1.17 

Data (€c/MB) 
1.31 
1.32 
2.99 
1.98 
2.54 
1.51 
1.06 
1.31 
2.13 
2.01 
1.34 
1.29 
1.79 
2.95 
1.61 
1.38 
0.61 
1.64 
1.48 
2.93 
1.92 
1.27 
2.45 
1.33 
1.30 
1.61 
1.85 
1.00 
1.30 

In  order  to  compare  TERA's  cost  estimate  for  voice  origination  against  retail  unit  prices, 
Figure 20 below compares TERA's cost estimates for voice origination after re-allocation of 
termination  common  costs  but  before  the  re-balancing  against  effective  national  mobile 
termination  rates,  as  this  is  the  TERA  cost  estimate  that  is  more  appropriate  to  compare 
against retail prices. 

53 

 
 
 
 
 
 
 
Figure  20:  Comparison  of  TERA's  voice  origination  costs  against  retail  unit  voice  prices 
(€c/min) 

Figure 20 shows that the costs estimated by TERA Consultants for voice origination are well 
below  estimated  retail  prices  in  all  countries  considered.  It  also  shows  that  countries  for 
which  TERA  Consultants  have  estimated  relatively  low  voice  costs  (e.g.  Lithuania,  Poland 
and  Romania)  similarly  have  relatively  low  retail  prices.  There  are  however  countries  for 
which TERA Consultants have estimated relatively low costs in contrast to relatively higher 
retail  prices.  This  is  not  necessarily  an  inconsistency  of  the  costs  estimated  by  TERA 
Consultants,  given  that  retail  prices  are  not  solely  determined  by  underlying  costs  but  also 
other  factors  such  as  competitive  conditions  present  in  every  country.  No  country  was 
identified where very low domestic retail prices would directly put in question the plausibility 
of the underlying TERA cost estimates. 

54 

 
 
 
 
 
Figure 21: Comparison of TERA's data costs against retail unit data prices (€c/MB) 

The comparison of TERA Consultants' cost estimates with the data retail prices estimated for 
each country (Figure 21) yields similar results to the comparison of voice services.  

TERA Consultants conducted additional sensitivity checks on its estimates that are explained 
in detail in its Final report77. 

5.4.2.4.  Roaming-specific costs 

Roaming-specific costs are considered as mobile operators' costs that can be solely attributed 
to the provision of wholesale roaming services (as opposed to domestic mobile services). In 
other words, mobile network and non-network costs that are incremental to the provision of 
the wholesale roaming service. 

In  order  to  assess  the  magnitude  of  these  costs,  data  from  mobile  operators  on  roaming-
specific  costs  were  included  in  the  autumn  information  request.  Following  this  request,  90 
operators  replied  with  data  on  roaming-specific  costs.  TERA  Consultants  analysed  the 
information provided by operators and identified four separate categories of roaming-specific 
costs, namely: 

  Roaming  network  related  costs:  operating  network  costs  specific  to  roaming 
services such as roaming route testing/monitoring and route provisioning. No capital 
expenditures specific to roaming services were identified at the network level.  

  Roaming Operation and Management (O&M) costs: costs relating to all business 
intelligence systems and software dedicated for roaming O&M, including: accounting, 

77 European Commission, Assessment of the cost of providing wholesale roaming services in the EEA, Final 
report, study conducted by TERA Consultants, to be published 

55 

 
 
 
 
 
 
 
                                                           
payment,  fraud  prevention,  revenue  assurance,  roaming  steering  and  quality 
assurance. 

  Roaming data clearing and payment costs: costs relating to roaming clearing costs 
including  both  data  clearing  costs  (DCH:  Data  Clearing  House)  incurred  with  the 
exchange of TAP/RAP files between the home and the visited operator, as well as the 
financial clearing of payments between operators.  

  Roaming  contract  negotiation  costs:  costs  relating  to  the  administration  and 
negotiation  of  wholesale  roaming  contracts,  including  external  fees  (consulting 
services)  or  internal  expenses  (e.g.  settlement  of  roaming  agreements,  contract 
monitoring and regulatory expenses).  

The  approach  followed  by  TERA  Consultants  to  derive  roaming-specific  costs  consists  of 
two  steps.  First,  for  each  of  the  cost  categories  of  roaming-specific  costs  described  above, 
using  regression  analysis  they  derive  a  relationship  between  the  total  cost  provided  by 
operators  in  response  to  the  information  request  and  its  assumed  underlying  cost  driver.  In 
particular: 

  For roaming network-related costs, TERA assumes that these costs are driven by the 

total roaming traffic (expressed in GB).  

  For  O&M  and  data  clearing  and  payment  costs,  TERA  assumes  that  these  costs  are 

driven by the number of TAP records78 generated; 

  For contract negotiation costs, TERA assumes that the costs are fixed and independent 

of traffic or any other underlying driver. 

Using regression analysis, TERA estimates a fixed and variable (i.e. depending on the value 
of the underlying cost driver) cost for each category of roaming-specific costs. This is shown 
in Table 8 below.  

Table 8: Roaming-specific costs estimated by TERA 

Network costs 

O&M costs 

Fixed cost 
Cost driver 

Variable cost 

Capex 

Opex 
€225K 
Traffic 
(GB) 
€2.1/GB 

Capex 
€14K 
TAP 

€10/100K 
TAP 

Opex 
€55K 
TAP 

€30/100K TAP 

Clearing 
costs 
Opex 
€70K 
TAP 

€40/100K 
TAP 

Negotiation 
costs 
Opex 
€190K 
No 

No 

Second, using the relationships obtained in the first step, TERA calculates roaming-specific 
costs for each country based on the size of the operators (i.e. the number of TAP records and 
traffic GB of the operators) in the country. 

Figure  22  and  Figure  23  below  present  the  roaming-specific  unit  costs  estimated  by  TERA 
for both voice and data services respectively. 

78  Transferred  Account  Procedures  (TAP)  records  are  a  collection  of  procedures  used  by  mobile  operators  to 
send billing records on roaming subscribers from the visited network operator to the home network operator of 
the roaming subscriber.  

56 

 
 
 
 
 
 
 
  
 
                                                           
Figure 22: Mark-ups on voice services for roaming-specific costs (€c/min) 

Figure 23: Mark-ups on data services for roaming-specific costs (€c/MB) 

In  general,  TERA  Consultants  have  estimated  higher  roaming-specific  cost  mark-ups  for 
smaller  size  countries  with  relatively  high  wholesale  roaming-in  traffic.  This  is  because  a 
significant proportion of roaming-specific costs are fixed, thus, resulting in relatively higher 
unit  costs  for  small  countries  with  small  mobile  operators.  Similarly,  countries  with 
proportionally  higher  wholesale  roaming-in  traffic  (when  compared  to  their  size)  are  also 
likely to have a relatively higher unit cost for roaming-specific costs, as the variable part of 
these costs is mainly driven by the level of roaming-in traffic. 

57 

 
 
 
 
 
 
 
5.4.2.5. 

Impact of seasonality 

As  explained  in  section  5.4.1  above,  half  of  the  operators  in  the  public  consultation  have 
argued  that  the  seasonal  character  of  roaming  traffic  and  its  geographic  concentration  in 
certain touristic areas implies that roaming traffic may drive network investment decisions in 
certain  areas  to  accommodate  the  additional  network  capacity  required  by  roaming 
subscribers  over  the  short  holiday  period  (typically  the  summer  period  running  from  June 
until August). These operators argue that a relatively higher share of network costs in these 
areas should be allocated to roaming traffic (rather than domestic traffic) in order to reflect 
the impact of roaming traffic on mobile operators' decisions to invest in additional capacity. 

TERA Consultants investigated the impact  of seasonal roaming traffic on mobile operators' 
underlying network costs. In a nutshell, the approach followed by TERA Consultants consists 
of: 

 

Identifying the month with the highest total traffic (roaming and domestic), as the 
month with highest total traffic will drive the mobile operator's investment decision 
(i.e. the maximum capacity that it needs to build to accommodate for the traffic on the 
network);   

  Assessing the share of traffic corresponding to domestic and roaming subscribers in 

the month with the maximum total traffic; and 

  Allocating total network costs to domestic and roaming traffic based on their relative 

share of traffic in the month with the maximum total traffic.  

In order to estimate the impact of seasonality, TERA Consultants has used different sources 
of information: 

  data from Eurostat on the number of nights spent by non-residents in EU countries; 
  quarterly inbound traffic per country in 2014 obtained from BEREC; 
  publicly available data on roaming from ANACOM (Portugal), ARCEP (France), 

MCA (Malta) and HAKOM (Croatia); 

  national monthly domestic and roaming traffic from an operator active in several 

Southern Member States; and 

  monthly domestic and roaming traffic disaggregated by geographical location in (a 

Southern European country obtained from (the NRA of that country).  

Based on the evidence analysed, TERA concludes that seasonal roaming traffic: 

  has  a  significant  effect  only  in  suburban  and  rural  areas,  excluding  cities  from  the 
scope of the analysis. In cities, the peak of network traffic is typically in months other 
than  the  summer  period,  given  that  the  traffic  generated  by  seasonal  roaming 
subscribers is balanced out by a reduction in the traffic of domestic subscribers, which 
move to touristic areas outside of the cities; 

  only has a significant impact on voice traffic but not on data traffic. This is due to the 
fact that the structural increase observed in data traffic from domestic users is likely to 
have a more significant weight on operators' network-build decisions than the increase 
in  data  traffic  from  seasonal  roaming  subscribers  during  the  holiday  period.  Thus, 
seasonal roaming data traffic during the summer period is  unlikely to  determine the 
decision  to  build  additional  capacity  by  mobile  operators.  Instead,  this  decision  is 
likely  to  be  driven  by  the  growth  in  demand  for  data  services  from  domestic  users; 
and 

58 

 
 
 
 
 
 

is only relevant in a sub-set of EU countries. Based on TERA Consultants' analysis, 
the  impact  of  seasonality  is  only  significant  in  9  countries  out  of  the  sample  of  29, 
namely: Croatia, Greece, Bulgaria, Spain, Malta, France, Italy, Slovenia and Cyprus.    

Using the above information, TERA Consultants have modelled two different scenarios:  

  Scenario 1: assumes that domestic traffic in touristic areas remains constant over the 

year (i.e. does not show seasonality); and 

  Scenario 2: assumes that domestic traffic in touristic areas also increases over the 

summer period, in parallel to seasonal roaming traffic.  

The  second  seasonality  Scenario  2  appears  more  appropriate  to  assess  the  true  impact  of 
seasonality. This is because the first Seasonality 1 scenario assumes that domestic traffic in 
touristic areas over the holiday periods is  similar to  the domestic traffic in  these areas over 
the  rest  of  the  year.  In  contrast,  it  should  be  considered  that  domestic  traffic  in  these  areas 
over the holiday period is likely to increase, as national mobile users typically share the same 
touristic areas as roaming subscribers over the same period. In other words, domestic traffic 
is  likely  to  reflect  some  seasonality  and  geographic  concentration,  in  the  same  way  as 
roaming traffic. Thus, the Seasonality 1 scenario is  likely to  overestimate the proportion of 
network costs in touristic areas that should be allocated to roaming subscribers, whereas the 
Seasonality 2 scenario more accurately reflects that domestic traffic is also likely to increase 
in touristic areas over the holiday periods. 

In addition, there are other factors that suggest that the impact of seasonality is likely to be 
relatively  small.  In  particular,  seasonal  roaming  traffic  is  typically  concentrated  in  a  small 
number  of  geographic  locations.  This  implies  that  roaming  traffic  is  only  likely  to  affect 
mobile  operators'  investment  decisions  in  a  small  proportion  of  their  network  locations, 
limiting  any  impact  of  roaming  traffic  on  the  mobile  operators'  total  costs  of  building  their 
national mobile network. 

Figure 24 presents  the impact  of seasonality on  voice origination  costs estimated by TERA 
for each country under the Seasonality 2 scenario. 

Figure 24: Mark-ups on voice services for seasonality (€c/min) 

59 

 
 
 
 
 
 
 
 
5.4.2.6. 

Total estimated wholesale roaming costs 

The total costs for wholesale roaming services estimated by TERA are the sum of the three 
different components described above, namely, the: 

  network costs; 
 
  a re-allocation of network costs between roaming and domestic customers to take into 

roaming-specific costs; and 

account the impact of seasonality. 

The  figure  below  presents  the  total  wholesale  roaming  costs  estimated  by  TERA  for  voice 
and data services, respectively. 

Figure 25: Total estimated wholesale roaming unit costs for voice origination (€c/min) 

60 

 
 
 
 
 
  
 
Figure 26: Total estimated wholesale roaming unit costs for data services (€c/MB) 

5.5. Termination rates  

When a roaming customer originates a call on a visited network, this call is then terminated 
on the network of the customer receiving the call. Similarly to the situation with a domestic 
call, the originating network operator pays the terminating network operator for terminating 
the call. In this sense, the termination rate charged by the terminating network operator is part 
of the total cost of originating the call for the visited network operator, as the latter has to pay 
the terminating network operator for terminating the call.  

Fixed and mobile termination rates are currently regulated in all countries of the EEA, with 
the  exception  of  Finland  for  fixed  termination  rates.  However,  the  rates  applicable  are 
different in every MS, as shown in Figure 27 and Figure 28, respectively.   

61 

 
 
 
 
 
Figure  27:  Fixed  termination  rates  applicable  in  MS  (S2  2015)  –  BU-LRIC  rates  in  blue 
(€c/min) 

Source:  BEREC  Report  on  the  implementation  of  the  Termination  Rate  Recommendation,  BoR  (15)  209, 
December 2015.  

Figure  28:  Mobile  termination  rates  applicable  in  MS  (S2  2015)  –  BU-LRIC  rates  in  blue 
(€c/min) 

Source:  BEREC  Report  on  the  implementation  of  the  Termination  Rate  Recommendation,  BoR  (15)  209, 
December 2015.  

62 

 
 
 
 
 
 
For the purposes of assessing the cost that needs to be considered to compensate the visited 
network  operator  for  paying  the  terminating  network  operator's  termination  rate,  the 
following assumptions were made: 

  13% of calls are likely to be terminated on landlines and 87% on mobiles79; 
  only mobile and fixed termination rates that have been set by NRAs using a BU-LRIC 
approach were considered, consistent with the Commission's 2009 Termination Rates 
Recommendation (i.e. only the MTRs in blue in Figure 27 and Figure 28 were 
considered); and 
for the fixed and mobile termination rates considered, in the interests of prudence, an 
average of the five highest BU-LRIC fixed and mobile termination rates, respectively, 
currently in place in the EEA was used. 

 

Table 9 presents the calculation of the termination rates that were considered for the purposes 
of  assessing  the  total  costs  of  originating  a  roaming  call  by  a  visited  network  operator, 
including a compensation for the termination rate  paid  to  the terminating network operator. 
As shown in Table 9 the termination rate to be accordingly considered should be €1.02c/min. 

Table 9:  Termination rate to  be considered within the cost  of originating  a mobile roaming 
call (€c/min) 

Country 
Mobile termination rate 
Average mobile termination rate 
Country 
Fixed termination rate 
Average fixed termination rate 
Weighted average termination rate 

SK 
1.23 

BG 
0.256 

BE 
1.18 

LU 
0.14 

SI 
1.14 
1.15 
RO 
0.14 
0.16 
1.02 

EL 
1.1 

ES 
1.09 

HU 
0.131 

SK 
0.123 

Note: In each case the five highest BU-LRIC fixed and mobile termination rates were considered, their averages 
and finally the weighted average assuming 13% mobile-to-fixed and 87% mobile-to-mobile calls. 
Source:  BEREC  Report  on  the  implementation  of  the  Termination  Rate  Recommendation,  BoR  (15)  209, 
December 2015. 

The  above  termination  rate  estimations  are  likely  to  be  relatively  conservative  for  the 
following reasons: 

 

the M/FTRs effective on the second semester of 2015 were considered, however, 
RLAH will only be implemented in June 2017. We expect that by that time both 
M/FTRs will be lower due to efficiency savings that are likely to reduce termination 
price caps in EU countries; and 

  a significant share of calls will be terminated in countries with M/FTRs lower than the 
five highest considered in the analysis. Thus, the weighted average termination rate 
effectively paid by the visited network operator is likely to be lower than the one 
estimated above.  

5.6. Transit costs 

79 This assumption is based on data collected from NRAs and Eurostat by TERA Consultants in the context of 
the  study  SMART  2015/0008  –  Assessment  of  the  2009  Termination  Rates  Recommendation  and  costing 
methodologies for estimating termination rates. 

63 

 
 
 
  
 
                                                           
International transit costs are also relevant for voice and data services: 

  Voice services: when originating a call on a visited network operator, the originating 

operator interconnects with an international transit carrier of its choice that then routes 
the call to the terminating network operator; and 

  Data services: data traffic needs to be routed back to the home network for real-time 
billing and measures for customer protection (e.g. to prevent bill shock) and charging 
transparency. 

In  the  case  of  data,  several  mobile  network  operators  were  consulted  and  there  is  currently 
very little use of Local Break-Out (LBO), a technical development that would avoid the need 
to route data traffic back to the home network, in the EEA80. All operators consulted agreed 
that it is very unlikely that LBO will develop to any significant extent in the EEA by the time 
of implementation of RLAH in June 2017. In contrast, all roaming data traffic is routed to the 
home network using a IPX/GRX provider, and each network pays a charge that covers both 
sending and receiving data traffic. It is therefore appropriate to  account for transit costs for 
both voice and data services. 

In  its  report  on  International  Mobile  Roaming  Regulation  of  December  201081,  BEREC 
concluded  that  transit  costs  "represent  an  insignificant  share  of  the  total  cost  of  roaming 
services"  and  therefore  excluded  transit  costs  from  the  quantitative  analysis  of  wholesale 
roaming costs.  

In order to estimate transit costs, data provided by operators in their response to the autumn 
information request were used. Based on this evidence, it is concluded that it is appropriate to 
consider the following transit costs: 

  Voice services: a cost of €0.4c/min; and 
  Data services: a cost of €0.2c/min. 

5.7. Comparison of the voice cost estimates derived from TERA's study against 

an alternative approach based on national mobile termination rates 

In light of the above, we present in Figure 29 and Figure 30 the cost estimates for wholesale 
roaming  voice  and  data  services,  respectively,  including  an  allowance  for  termination  rates 
and transit costs (in the case of voice) and transit costs (in the case of data), as described in 
the previous sections. 

Figure  29:  Total  estimated  costs  of  wholesale  roaming  voice  origination  including  the 
termination rate and transit costs (€c/min) 

80 See also the evidence provided in International Roaming BEREC Benchmark Data Report April – September 
2015 BoR(16)28, page 11, reporting only one operator offering LBO services submitting data to BEREC.  
81 BEREC Report on International Mobile Roaming Regulation, BoR(10)58, December 2010, section 5 
"Assessment of costs", p 137. 

64 

 
 
 
 
 
 
 
 
                                                           
Figure  30:  Total  estimated  costs  of  wholesale  roaming  data  services  including  transit  costs 
(€c/MB) 

The  cost  estimates  derived  from  TERA's  study  have  been  sense  checked  against  an 
alternative approach to estimating wholesale roaming voice costs based on NRAs' estimated 
mobile termination costs. In particular, wholesale roaming voice costs under this  alternative 
approach were estimated as follows: 

 

the  cost  of  origination  is  assumed  equal  to  the  cost  of  termination.  Also,  in  each 
country  the  cost  of  origination  will  be  equal  to  the  BU-LRIC  cost  estimated  by  the 

65 

 
 
 
 
 
 
 
NRA  (MS  that  do  not  estimate  mobile  termination  costs  based  on  a  BU-LRIC 
approach were excluded from this analysis); 
the  average  joint  and  common  costs  estimated  by  TERA  Consultants  for  voice 
services were added (equal to €0.55c/min); 
the  roaming-specific  costs  estimated  by  TERA  Consultants  for  each  country  were 
included; 

 

 

  a  mark-up  to  account  for  the  seasonality  impact  estimated  by  TERA  Consultants, 

where relevant, was included; 

  a compensation was included for the termination rates that visited network operators 
are, on prudent assumptions, exposed to paying to terminating network operators for 
terminating calls on their network (€1.02c/min, as estimated above); 
transit costs equal to €0.4c/min, as described above, were added. 

 

Figure  31  presents  below  a  comparison  of  the  wholesale  roaming  cost  for  voice  services 
estimated  using  this  alternative  approach  against  the  estimated  wholesale  roaming  cost  for 
voice services derived from the TERA study and the average wholesale roaming market price 
for unbalanced traffic. 

Figure  31:  Comparison  between  the  TERA-based  estimated  cost  for  wholesale  roaming 
voice,  an  alternative  approach  to  estimating  costs  for  wholesale  roaming  voice,  average 
wholesale roaming market price for unbalanced traffic (€c/min) 

The  comparison  between  the  cost  estimates  for  voice  derived  from  TERA's  study  and  the 
estimates using an alternative approach in Figure 31 above shows that: 

 

the  TERA-derived  cost  estimates  are  always  below  the  cost  estimates  using  the 
alternative  approach,  with  the  only  exception  of  Malta  and  Sweden.  In  the  case  of 

66 

 
 
 
 
 
 
 

 

Malta,  the  TERA  approach  estimates  a  cost  of  €4.20c/min  and  the  alternative 
approach  shows  a  cost  of  €3.10c/min.  In  the  case  of  Sweden,  the  TERA  approach 
estimates  a  cost  of  €3.22c/min  and  the  alternative  approach  shows  a  cost  of 
€3.03c/min.  In  both  cases,  the  lower  cost  estimate  using  the  alternative  approach  is 
mainly due to the low termination rates effective in Malta and Sweden (€0.4c/min and 
€0.81c/min, respectively, in the second semester of 2015); 
the maximum cost estimate derived from TERA (€4.20c/min in Malta) is above, but 
broadly  consistent  with,  the  maximum  cost  estimate  derived  using  the  alternative 
approach (€3.81c/min in Spain);  
the  cost  estimates  derived  using  the  TERA  cost  model  exceed  the  average  market 
price for wholesale roaming voice services in several countries (namely: Malta, Spain 
and  France).  Similarly,  the  cost  estimates  derived  using  the  alternative  approach 
exceed  the  prices  in  several  countries  (namely:  Spain,  France  and  Greece).  This 
supports the view that both the TERA cost model and the alternative approach provide 
the  costs  of  wholesale  roaming  voice  services82. 
conservative  estimates  of 
Furthermore,  it  suggests  that  in  the  case  of  voice  services,  the  effective  wholesale 
roaming prices should be given due weight when assessing the costs of voice services. 

5.8. Cost estimates for SMS services 

As described above, TERA Consultants' cost estimates for SMS services do not appear robust 
enough to derive conclusions on actual SMS costs. For this reason, it is more appropriate to 
rely  on  other  sources  of  information.  Figure  32  below  presents  the  average  wholesale 
roaming  prices  for  SMS  services  currently  in  place  in  EEA  MS  obtained  in  the  autumn 
information request.  

82 The alternative approach uses the country's effective MTR to estimate the cost of origination, the other 
components of the costs being derived from TERA's model (i.e. average common costs, average roaming-
specific costs, country-specific seasonality) and from operators' data on transit costs. 

67 

 
 
 
 
                                                           
Figure 32: Current wholesale roaming prices for SMS in MS (€c/SMS) 

Based on the above evidence it is appropriate to assume a cost for wholesale roaming SMS 
services equal to €1c/SMS. 

5.9. Conclusion on the costs of wholesale roaming services 

This  section  assessed  the  costs  of  wholesale  roaming  services  based  on  several  sources  of 
evidence, namely: 

the TERA Consultants' cost model; 

 
  an alternative approach to estimate the costs of wholesale roaming voice services 

based on national mobile termination rates; and 
retail unit prices in MS from a Commission study on retail prices in the EEA. 

 

Based on the evidence described in this section, Table 10 presents the cost estimates in each 
of the 28 MS plus Norway including: 

 

the total wholesale roaming costs estimated by TERA (including network costs, 
roaming-specific costs and the impact of seasonality on roaming costs), as discussed 
in section 5.4 above; 

  an allocation for the termination rate that the visited network operator needs to pay the 
terminating network operator for terminating a call on its network, as discussed in 
section 5.5 above; and 

  an allocation for the transit costs that the visited network operator needs to pay for 
routing a call to the terminating network operator or to send data traffic back to the 
home network, as discussed in section 5.6 above.  

68 

 
 
 
 
 
 
 
Table 10: Wholesale roaming services' cost estimates in each of the 29 countries considered 
in TERA Consultants' cost model 

AT 
BE 
BG 
CY 
CZ 
DE 
DK 
EE 
EL 
ES 
FI 
FR 
HR 
HU 
IE 
IT 
LT 
LU 
LV 
MT 
NL 
PL 
PT 
RO 
SE 
SI 
SK 
UK 
NO 

Voice (€c/min) 
2.60 
1.85 
2.74 
1.63 
1.86 
1.70 
1.86 
1.82 
1.94 
2.81 
1.65 
2.79 
2.31 
2.39 
1.24 
1.75 
1.62 
2.63 
2.81 
4.20 
2.57 
1.72 
1.78 
1.79 
3.22 
2.52 
1.63 
2.65 
1.96 

SMS (€c/SMS) 
1.00 
1.00 
1.00 
1.00 
1.00 
1.00 
1.00 
1.00 
1.00 
1.00 
1.00 
1.00 
1.00 
1.00 
1.00 
1.00 
1.00 
1.00 
1.00 
1.00 
1.00 
1.00 
1.00 
1.00 
1.00 
1.00 
1.00 
1.00 
1.00 

Data (€c/MB) 
0.30 
0.41 
0.53 
0.35 
0.42 
0.31 
0.29 
0.34 
0.35 
0.41 
0.28 
0.39 
0.36 
0.39 
0.31 
0.31 
0.43 
0.44 
0.52 
0.67 
0.37 
0.32 
0.36 
0.59 
0.29 
0.57 
0.55 
0.36 
0.38 

Section  6  below  presents  evidence  on  current  prices  for  wholesale  roaming  services  and 
national  wholesale  prices  for  MVNOs.  This  evidence  is  broadly  consistent  with  the  costs 
estimated by TERA Consultants for wholesale roaming services presented in this section. In 
addition, evidence on wholesale roaming services' prices and MVNO rates supports the level 
of the wholesale price caps used in each of the options considered in the Impact Assessment.  

6.  DEGREE OF COMPETITION IN WHOLESALE ROAMING MARKETS  

In this section the Commission describes the functioning of wholesale roaming markets and 
assesses  the  degree  of  competition  currently  existing  in  these  markets.  The  section  is 
structured as follows: 

  First the Commission's approach to analysing developments in wholesale roaming 

markets is described; 

69 

 
 
 
 
 
  Second, the market failures that have been traditionally associated with wholesale 

roaming markets are reviewed;  

  Third, an overview of wholesale roaming agreements is provided;  
  Fourth, the wholesale roaming markets in the EU is described;  
  Finally, the degree of competition in wholesale roaming markets is assessed; 

6.1. Description of the Commission's approach  

6.1.1.  Literature review and previous studies 

Market  failures  that  have  been  associated  with  wholesale  roaming  markets  in  the  literature 
(section 6.2) have been confronted in the subsequent sections with the data and information 
provided  by  EEA  operators  during  the  autumn  2015  data  gathering  exercise  described  in 
section 6.1.2. 

6.1.2.  Questionnaire to operators and analysis of the data 

The necessary data to analyse the functioning of, and level of competition in, the wholesale 
roaming markets  in  the  EU were obtained via the questionnaire sent  in  September 2015 by 
the Commission and BEREC to M(V)NOs in all Member States. 

For  the  purpose  of  assessing  the  degree  of  competition  in  wholesale  roaming  markets, 
operators  were  requested  to  provide  data  and  information  about:  (i)  current  wholesale 
roaming agreement structures and tariffs, including the situation of light MVNOs; (ii) current 
and  future  wholesale  competition  situation,  (iii)  aggregated  retail  domestic  and  (intra-
EU/extra-EU)  roaming  data  consumption  and  revenue,  (iv)  wholesale  roaming  payments, 
revenues and volumes by Member States of destination and origin, (v) aggregated balanced-
unbalanced  traffic  volumes  and  related  average  wholesale  prices,  (vi)  expected  wholesale 
roaming prices for the year 2016. In this questionnaire, operators were also asked to provide 
their  views  about  the  current  functioning  of  the  wholesale  roaming  market  in  the  EU  and 
about future wholesale roaming price regulation. 

127 operators provided at least part of the quantitative data requested above. The CC-ME of 
the  JRC  extracted  the  original  data  and  organized  them  in  a  unified  database.  Several 
inconsistencies in the way data were reported were corrected, in particular as regards the unit 
of measurement.  

In order to analyse the representativeness of the sample of operators with respect to the whole 
market  and  the  presence  of  potential  response  bias,  NRAs  were  asked  through  BEREC  to 
provide information on where the operators that provided data appeared in the distribution of 
national  operators,  when  sorted  according  to  size.  This  information  was  provided  for  all 
Member States that contributed data for the analysis; the Member States that did not provide 
data were: CY, DE, HU, IT, LU, SI, UK. 

For Member States contributing some data, the fraction of operators providing data over the 
total was on average equal to 79%. When restricting attention to the largest 50% of operators, 
this fraction was equal to 93%. This means that the sample of 127 operators providing data 
slightly over-represents large operators. Due to the small absolute number of operators, this 
difference does not appear to be large.  

In  the  remainder  of  this  section,  the  results  of  the  analysis  are  shown  by  operator  and  by 
country. For each variable of interest (e.g. inbound wholesale roaming volume as % of retail 

70 

 
 
 
 
domestic  consumption)  the  operators'  graph  represents  the  distribution  of  the  operators' 
values in the sample of operators providing the necessary data as a cumulative fraction of the 
sample (expressed as %). This means that for each value of the variable of interest on the x-
axis,  the  graph  shows  what  %  of  the  operators'  sample  is  below  that  value.  Operators  are 
looked at  on a per-country basis, which means  per subsidiary for the multi-country  groups. 
The countries' graphs show the aggregated value of the variable of interest over all operators 
operating in a given country that have provided the necessary data. 

6.1.3.  Public consultation 

The first part83  of the 12-week public consultation was dedicated to  gathering views on the 
functioning of, and level of competition in, the wholesale roaming markets in the EU, on the 
need to regulate them in view of the abolition of retail roaming surcharges by 15 June 2017, 
on possible options for doing so, and on the possible risks associated with permanent roaming 
and the ways to address them. The results of the consultation concerning the functioning of 
national wholesale roaming markets are analysed in sections 6.5.1 and 6.5.2. 

6.2. Market failures in wholesale roaming markets 

This  section  provides  an  overview  of  the  market  failures  that  have  been  traditionally 
associated with wholesale roaming markets, in particular: 

Imperfect wholesale roaming substitutes;  

  Natural oligopoly structure, which fosters low intensity of competition 
 
  Double marginalisation and coordination problem;  
  Bilateral nature of wholesale roaming agreements:  
  Exclusion of MVNOs from wholesale roaming market. 

6.2.1.  Natural oligopoly structure, which fosters low intensity of competition 

An argument generally raised is  that the roaming market  presents  many  characteristics of a 
natural oligopolistic market.84 High infrastructural costs of mobile communications limit the 
entrance of players, and the situation creates low competitive pressure. There seems not to be 
indications  that  this  has  substantially  changed,  in  one  direction  or  another.  In  wholesale 
domestic roaming markets,  there is  generally more than one operator effectively competing 
for attracting visiting network, but the number does not rise to substantial competitive levels 
so that the overall structure of the market is affected. Moreover, the number of competitors is 
significantly  reduced  when  it  comes  to  those  who  offer  full  coverage,  network  quality,  or 
traffic exchange deals (see section 6.2.4) which is seen by operators as key factors explaining 
their  final  roaming  deals,  generally  tide  to  only  one  preferred  network  (see  section  6.3). 
Moreover,  according  to  investigations  carried  out  by  the  Commission  services,  access 
measures applied at the domestic level do not significantly change this situation, as MVNOs 

83 The two other sections of the public consultation covered respectively fair use policy and the sustainability 
mechanism provided for in the Regulation. 
84 Alkatheeri, S. (2013). The Economics of Mobile International Roaming. Doctoral Dissertation. University of 
East Anglia School of Economics. WIK-Consult (2010), Study on the Options for addressing Competition 
Problems in the EU Roaming Market, SMART 2010/018, December, p. 9. European Commission (2011), 
Commission Staff Working Paper – Impact Assessment of Policy Options in Relation to the Commission's 
Review of the Functioning of Regulation EC No 544/2009 of the European Parliament and of the Council of 18 
June 2009 on Roaming on Public Mobile Telephone Networks within the Community, 6 July 2011, SEC(2011) 
871. p. 15. 

71 

 
 
 
                                                           
do not resell, in the wholesale roaming market, their domestic wholesale access (a different 
situation is the role played by Global MVNOs, analysed below).  

6.2.2.  Imperfect wholesale roaming substitutes 

Similarly  to  the  situation  at  the  retail  level,  where  end  users  have  limited  alternatives  to 
retail roaming services, operators have only imperfect substitutes at the wholesale level as 
well,  a  situation  that  a  previous  report  ordered  by  the  Commission  already  analysed  85. 
Developments  in  steering  technology,  which  give  control  to  operators  over  which  visited 
mobile  network  their  clients  attached  to,  sparked  an  “internalisation”  trend  in  the  form  of 
growing  roaming  alliances,  hubs  and  other  groupings86.  These  changes,  however,  do  not 
seem to have, in view of many operators, contributed much in perfecting the functioning of 
the  wholesale  market  (see  section  6.4)87,  nor  did  it  improve  the  incentives  to  pass-by 
potential savings to the consumers via retail discounts88.  

“Localization” (where roaming is offered to costumers at local terms) is another trend that 
does  not  seem  to  have  had  much  impact  at  the  wholesale  level.  Beside  all  the  limits 
analysed  in  the  retail  dimension  of  these  trend  (see  section  4.2.1),  it  does  not  seem  that 
operators have so far designed localization strategies with  a mass-market impact  (for how 
eSims might or might not change this situation, see section 4.4). A special case in point are 
global  MVNOs.  Global  MVNOs  have  access  to  networks  in  different  countries  on  local 
terms and conditions based on domestic wholesale agreements or MVNO regulations. They 
typically use these agreements to interconnect their customers at local terms and conditions, 
thereby bypassing the IOT system. At the retail level, this enables local pricing for roaming 
services.  However,  global  MVNOs  typically  target  a  niche  market  of  mainly  business 
customers  and  subscribers,  who  then  need  to  pass  on  different  numbers  to  business 
associates for each country they travel to. Given this level of inconvenience, it is unlikely 
that  global  MVNOs  may  develop  into  a  fully  effective  roaming  substitute  for  the  mass 
market of residential users.89  

6.2.3.   Double marginalisation and difficulties in coordination 

The  problem  of  double  marginalisation  has  also  been  invoked  as  a  possible  market  failure 
operating  in  the  wholesale  roaming  market.90  Prices  in  the  roaming  market  might  be  even 
above the monopoly price, it is  argued, due to  separate uncoordinated mark-ups applied by 
both  retail  suppliers  and  providers  of  wholesale  roaming  access.  MNOs  charge  an 
oligopolistic price at wholesale, and at retail level, each MNO takes as given the wholesale 

85 WIK-Consult (2010), Study on the Options for addressing Competition Problems in the EU Roaming Market, 
SMART 2010/018, December, p. 20-23. 
86 Alkatheeri, S. (2013). The Economics of Mobile International Roaming. Doctoral Dissertation. University of 
East Anglia School of Economics. WIK-Consult (2010), Study on the Options for addressing Competition 
Problems in the EU Roaming Market, SMART 2010/018, December, p. 21. 
87 In fact, they might have even further harmed competition: see Buhler, B. (2009) Do international roaming 
alliances harm consumers? In Institutions and Markets Series (ed. Fausto Panunzi).  
88 WIK-Consult (2010), Study on the Options for addressing Competition Problems in the EU Roaming Market, 
SMART 2010/018, December, p. 21. 
89 WIK-Consult (2010), Study on the Options for addressing Competition Problems in the EU Roaming Market, 
SMART 2010/018, December, p. 22-23. 
90 Lupi, P. and Manenti, F. (2008). Traffic Management in Wholesale International Roaming: Towards a More 
Efficient Market?. Paper presented in the 2007 Annual Conference of the European Economic Association , 
Budapest.  WIK-Consult (2010), Study on the Options for addressing Competition Problems in the EU Roaming 
Market, SMART 2010/018. P 39 

72 

 
 
 
                                                           
price  and  adds  a  retail  mark-up  to  the  wholesale  tariff.  Ultimately,  market  agents  prefer  to 
charge oligopolistic mark-ups to a small volume of roaming transactions than expanding the 
market with lower prices.   

It  has therefore been argued that both  social  welfare and overall profits  could  improve if it 
was  possible  to  coordinate  an  outcome  with  lower  retail  and  wholesale  prices  that  increase 
roaming demand and profits for both parties. However, there are difficulties in coordinating 
such an outcome due to uncertainties in future roaming demand and the sharing of risks from 
uncertain  roaming  demand  following  the  reduction  in  prices  at  wholesale  and  retail  level. 
This idea is supported by the evidence showing that RLAH-type of offers have been typically 
offered  by  MNOs  active  in  several  national  markets,  where  this  trans-national  vertical 
integration would reduce the risks and costs of coordination 

It is also the case that the difficulties in coordination between a wholesale and retail provider 
might  have  been  somewhat  mitigated  with  the  improvement  in  steering  technologies  (see 
previous section), which have enabled MNOs to direct traffic generated by their customers to 
a visited network of their choice, making other market problems more prominent. 

6.2.4.  Bilateral nature of wholesale roaming agreements 

Wholesale  roaming  agreements  are  generally  driven  by  the  amount  of  traffic  that  that  the 
visiting  operator  is  able  to  offer  during  bilateral  negotiation91.  Operators  typically  agree  to 
"balance" their respective traffic, and then the net sender of traffic gets an additional discount 
on the amount of traffic that exceeds the amount of traffic received from the roaming partner 
(see Section 6.3.4). It has been argued that this creates a situation where operators with low 
traffic are in practice unable to both, obtain a good price during the negotiations with visited 
networks, and effectively compete for visiting traffic, no matter their price offers.92 The fact 
that they cannot offer significant "traffic balancing" deals reduce their negotiation power, as 
operators  are  ultimately  interested  not  so  much  on  lowering  costs,  but  on  meeting  overall 
revenue  targets.  This  is  in  principal  maximized  by  exchanging  traffic,  thus  effectively 
hampering  those  who  cannot  deal  in  such  terms.  Section  6.3  of  the  report  analyses  current 
bilateral agreements.  

6.2.5.  Exclusion of MVNOs from wholesale roaming markets 

The exclusion of full MVNOs from the wholesale inbound market is another problem often 
raised  by  these  operators.  This  problem  arises  from  the  fact  that  bilateral  negotiations  for 
roaming  services  are  most  often  based  on  Standard  Terms  for  International  Roaming 
Agreements  (STIRA)  (i.e.  standard  documents  regularly  amended  giving  a  general 
framework to conclude agreements with foreign MNOs), which can currently only be used by 
GSMA  members.  In  contrast,  MVNOs  cannot  have  the  required  GSMA  membership. 
Although in theory, other types of contracts could be concluded, in practice these introduce 
higher  uncertainty  resulting  in  greater  transaction  costs  for  MVNOs.  To  improve  this 

91 European Commission (2011), Commission Staff Working Paper – Impact Assessment of Policy Options in 
Relation to the Commission's Review of the Functioning of Regulation EC No 544/2009 of the European 
Parliament and of the Council of 18 June 2009 on Roaming on Public Mobile Telephone Networks within the 
Community, 6 July 2011, SEC(2011) 871. p. 38. WIK-Consult (2010), Study on the Options for addressing 
Competition Problems in the EU Roaming Market, SMART 2010/018, December, p. 10. 
92 Shortall, T. (2010). A Structural Solution to Roaming in Europe. Robert Schuman Centre for Advanced 
Studies. 

73 

 
 
 
 
                                                           
situation,  the  GSMA  mentioned  that  they  were  preparing  to  allow  MVNOs  use  standard 
commercial documents such as STIRA.93  

The exclusion of MVNOs implies that they typically buy roaming services from a domestic 
MNO, most of the time their host MNO. As there are no price caps on the wholesale resale 
market,  and MNOs  are  at  the same time suppliers for the MVNOs (at  wholesale level) and 
competitors  of  these  MVNOs  (at  retail  level),  MVNOs  often  encounter  margin  squeeze 
problems.94 

6.3. Overview of wholesale roaming agreements 

BEREC  has  provided  the  following  description  of  the  wholesale  roaming  agreements  that 
operators  negotiate  for  roaming  in  the  EEA,  based  on  the  information  provided  by  EEA 
operators during the autumn 2015 data collection 95. 

6.3.1.  Standard Roaming Agreements and roaming discount agreements 

Operators  report  that  they  sign  two  types  of  wholesale  roaming  agreements.  The  first  type 
called  International  Roaming  Agreements  or  Standard  Roaming  Agreements  defines  the 
operational and technical aspects of the roaming relationship. In addition, roaming discount 
agreements are annexes to the international roaming agreements and specify the commercial 
aspects  of the agreement including the prices  that  have to  be paid.  While standard roaming 
agreements are ongoing (with the possibility to terminate them after a period of notice of six 
months), the discount agreements typically have a duration of 12 months (one calendar year). 
These bilateral roaming agreements are based on common principles developed by the GSM 
Association.96 

Operators  regularly  renegotiate  discount  agreements  because  of  the  unpredictable  nature  of 
the  market  with  a  high  degree  of  regulatory  uncertainty,  unpredictable  traffic  volumes  and 
frequent mergers and other changes of ownership. These uncertainties need to be balanced by 
the transaction cost of negotiating agreements. Some discount agreements are automatically 
renewed every year unless one party objects.  

6.3.2.  Bilateral and unilateral roaming agreements 

Roaming  agreements  are  usually  negotiated  bilaterally,  so  that  each  operator  gets  roaming 
access to the other operator’s network. Operators describe a number of advantages of bilateral 
agreements:  they  build  partnerships,  enlarge  roaming  coverage  to  the  benefit  of  customers 
and not least secure inbound roaming traffic and revenue that can (partly) offset the outbound 
roaming  cost.  Sometimes,  bilateral  agreements  are  (initially)  used  unilaterally  by  one 

93 European Commission (2011), Commission Staff Working Paper – Impact Assessment of Policy Options in 
Relation to the Commission's Review of the Functioning of Regulation EC No 544/2009 of the European 
Parliament and of the Council of 18 June 2009 on Roaming on Public Mobile Telephone Networks within the 
Community, 6 July 2011, SEC(2011) 871, p. 14-15. 
94 European Commission (2011), Commission Staff Working Paper – Impact Assessment of Policy Options in 
Relation to the Commission's Review of the Functioning of Regulation EC No 544/2009 of the European 
Parliament and of the Council of 18 June 2009 on Roaming on Public Mobile Telephone Networks within the 
Community, 6 July 2011, SEC(2011) 871, p. 15. 
95 BEREC (2016), BEREC Report on the wholesale roaming market, BoR(16)33, February 2016, section 3.1 
96 WIK-Consult (2010), Study on the Options for addressing Competition Problems in the EU Roaming Market, 
SMART 2010/018, December, p. 7. 

74 

 
 
 
 
 
                                                           
roaming  partner.  Unilateral  agreements  are  signed  when  the  requesting  MNO  has  bad 
geographical coverage or network quality, or is a late entrant, or when a full MVNO requests 
access. 

Typically,  operators  who  are  part  of  a  group  negotiate  international  roaming  agreements 
individually but negotiate discount agreements as a group. By negotiating commercial terms 
for  the  whole  group  companies  can  get  more  attractive  terms  and  prices  because  of  higher 
volumes. However, in some cases these operators negotiate discount agreements individually 
when it is commercially relevant or for practical reasons. MNOs that are not part of a group 
negotiate individually.  

6.3.3.  Number of roaming agreements in each destination country 

Generally,  operators  have  agreements  with  more  than  one  operator  in  each  EU  country,  in 
order  to  address  gaps  in  geographic  coverage  and  get  more  inbound  roaming  revenue. 
Operators  in  big  groups  report  that  they  have  agreements  with  almost  all  operators. 
Nevertheless, operators typically have one preferred network in each country to which they 
try to steer their traffic. 

Some smaller operators or operators from small countries only sign more than one agreement 
in  countries  where  they  have  a  lot  of  traffic  (inbound  or  outbound)  in  order  to  prioritize 
resources.  

6.3.4.  Pricing models 

Operators  tend  to  apply  a  range  of  discount  price  models.  The  following  are  the  most 
common types: 

  Fixed  rate  model  where  there  is  a  fixed  (discounted)  rate  per  unit  per  service  or  a 

discount as a percentage of the regulated cap. 

  The  balanced/unbalanced  model  is  a  typical  pricing  method  in  bilateral  discount 
agreements.  Each  party  exchanges  traffic  and  the  net  sender  of  traffic  gets  an 
additional  discount  on  the  amount  of  traffic  that  exceeds  the  amount  of  traffic 
received from the roaming partner. This gives both parties an incentive to send more 
traffic  to  each  other  since  additional  outbound  traffic  will  reduce  the  net  sender’s 
average  cost  and  the  net  receiver  will  increase  its  average  revenue  if  it  sends  more 
traffic.  

  When using  traffic or  volume commitments the roaming party commits  to  sending a 
certain amount of traffic for a discounted price. A version of this often used is tiered 
pricing  where  the  price  goes  down  if  a  certain  volume  threshold  is  reached. 
Sometimes  prices  go  down  from  the  first  unit  or  just  for  the  incremental  volume 
above  the  threshold.  Tiered  pricing  mean  that  higher  outbound  volumes  result  in 
lower per unit cost for the home operator. 

  With  a  financial  or  revenue  commitments  or  send-or-pay  the  visiting  operator 
commits to paying at least a minimum amount in wholesale roaming charges across 
all services. This can be based on defined tariffs for each service or bundled volumes 
for  each  service.  Additional  discounts  may  apply  if  these  thresholds  are  exceeded. 
These agreements secure a certain level of revenue for the visited network and lower 
prices for the net buyer if the included volumes are consumed. Typically, the higher 
the committed revenue the higher discounts can be achieved. 

75 

 
 
 
 
  For voice services sometimes a per destination pricing model is applied where prices 
vary depending on the destination of calls made in order to account for differences in 
interconnection cost. 

in  many  cases  combined.  For  example  a 
These  different  pricing  models  are 
balanced/unbalanced  agreement  might  include  a  minimum  volume/revenue  commitment. 
There can also be different price models for different services in the same discount agreement 
– e.g. one for voice and one for data services. 

A number of elements specific to each individual negotiation determine the choice of pricing 
model  and  the  level  of  discounts  that  can  be  negotiated.  These  elements  include  traffic 
volumes  and  the  level  of  imbalances  in  inbound  and  outbound  volumes.  Other  important 
elements are national market share, network quality and MTR cost. An operator with a high 
national market share and good network quality will, ceteris paribus, secure better discount 
agreements. Alliance networks are more likely to offer discounts.97  

Some  operators  report  that  a  high  amount  of  outbound  traffic  gives  operators  bargaining 
power that can result in higher discounts for the net buyer of roaming services than they have 
to  give  to  the  net  receiving  party.  Other  operators  report  that  the  net  seller  of  roaming 
services has the advantage since it is usually the seller who has the geographical advantage 
e.g. the best network in a popular roaming country. 

Some  operators  report  that  if  they  compete  in  the  domestic  market  with  an  operator  that  is 
part  of  a  pan-European  group  they  are  not  able  to  negotiate  reasonable  roaming  discounts 
with other members of this group in visited markets and thus have to rely on agreements with 
smaller operators in those countries. 

Most group operators report that they apply internal transfer pricing that is based on an arm’s 
length  principle.  In  these  cases  the  internal  rate  is  based  on  the  market  rates  offered  to 
external  partners.  One  group  reports  that  this  market  rate  is  calculated  as  the  average  rate 
charged to the main trading partners. One group apply bill and keep while another group uses 
zero pricing between subsidiaries. 

6.3.5.  Permanent roaming  

A  majority  of  MNOs  responded  that  they  have  so  far  not  implemented  any  measure  to 
prevent a foreign operator from permanently roaming on their network. They claim that there 
has so far been no compelling reason to  implement  any such measure since under past  and 
current wholesale roaming caps wholesale roaming providers have been able to recover their 
costs with a good margin. Some even highlight that they seek to increase the roaming traffic 
on their network by using mechanisms  like volume commitments, revenue commitments in 
their wholesale roaming agreements.    

About  20%  of  the  responding  MNOs  have  however  some  kind  of  mechanism  in  their 
wholesale roaming agreement which could be used to discourage permanent roaming. This is 
usually  done  by  excluding  permanent  roaming  from  any  price  discount.  The  difference 
between  discounted  and  non-discounted  wholesale  roaming  prices  therefore  seems  to  be  a 
crucial element for operators to control permanent roaming. In one case, the operator includes 

97 Alkatheeri, S. (2013). The Economics of Mobile International Roaming. Doctoral Dissertation. University of 
East Anglia School of Economics. 

76 

 
 
 
                                                           
a maximum number of days per year per visiting SIM card in some of its wholesale roaming 
agreements: beyond that number of days, the roaming traffic generated on its network by a 
visiting  SIM  card  is  charged  at  the  wholesale  roaming  cap  level  by  the  operator  to  the 
operator owning that visiting SIM card. In another example given by a respondent, individual 
roaming  data  consumption  beyond  10  GB  per  month  is  subject  to  revised  commercial 
negotiations, and if the parties do not agree on a less discounted price, the wholesale roaming 
cap is applied beyond the monthly 10 GB limit. 

Some  operators  indicate  that  they  might  introduce  mechanisms  in  the  future  to  prevent 
unwanted permanent roaming if wholesale roaming caps are decreased below relevant costs. 

A  few  operators  also  mention  that  they  have  mechanisms  in  their  wholesale  roaming 
agreement  to  prevent  losses  on  terminating  calls  to  destination  with  high  MTRs.  Countries 
with  high  MTRs  might  be  excluded  from  special  negotiated  low  wholesale  rates  or  a 
consumption limit can be added for the total number of minutes to specific countries. 

6.3.6.  Machine-to-Machine communications (M2M) 

SIM  cards  are  introduced,  possibly  soldered,  in  the  connected  object  at  manufacture.  The 
manufacturer  of  connected  objects  often  sells  them  globally  and  cannot  predict  in  which 
country  a  particular  object  will  be  sold  and  used  ultimately.  As  a  result,  once  sold,  the 
connected  object  may  well  have  to  be  permanently  roaming  on  a  network  of  the  country 
where  it  is  used.  Permanent  roaming  may  therefore  be  an  important  feature  of  many  M2M 
applications98. In addition, the traffic patterns many of them generate, with a lot of signalling 
and  less  data,  are  different  from  those  of  traditional  communications  generated  by  humans 
where data traffic largely dominates over signalling traffic. Permanent roaming and different 
traffic patterns might be two reasons why M2M communications could be subject to specific 
roaming 
traditional  person-to-person 
those 
communications. 

agreements,  distinct 

covering 

from 

About 20% of the responding MNOs indicate that they have signed separate agreements for 
M2M communications. This shows that most operators do not, under the current regulatory 
regime, see the scope of such traffic as significant enough to enter into specific negotiations 
with  their  roaming  partners.  Many  operators  explicitly  state  that  separate  agreements  for 
M2M are not necessary. 

The majority of operators do not  apply  specific  prices or  conditions  for  M2M  traffic.  They 
seem to treat this traffic the same way as ordinary traffic when it comes to financial terms in 
the contracts. However, some operators also express concerns as they see some challenges in 
covering the production costs of traffic generated by some M2M communications because of 
the small amount of data they generate. In those cases, signalling traffic dominates the traffic, 
which is hard to recover from their roaming partners within today’s standard roaming prices 
structure.  A  few  operators  have  special  conditions  and  rates  for  M2M  traffic,  one  operator 
says that M2M is typically excluded from discounts. 

98 This is different from the case of mobile phones for which the SIM card is introduced only when the phone is 
sold to the end-user.  Usually the smartphone is sold by the operator itself to the customer, together with its own 
SIM card. 

77 

 
 
 
 
 
 
 
                                                           
None of the respondents that engage into M2M agreements employ any exclusivity clause for 
the use of their network. One operator states that such clauses would harm the M2M services, 
since the offered quality could suffer if the applications could not select the best network at 
any given time. 

Several  respondents  call for transparency regarding the type of traffic  generated by visiting 
SIM  cards  (i.e.  traditional  traffic  generated  by  a  person  or  M2M  communication).  This  is 
necessary to implement a specific M2M roaming contract if there is one. And those who do 
not  have  any  specific  roaming  contract  for  M2M  still  want  to  monitor  the  extent  and 
evolution of M2M traffic. Some respondents reveal that they intend to more and more closely 
monitor SIM cards that visit their network for longer periods.  

Such monitoring is foreseen to become a necessity in the RLAH regime. National networks 
are  dimensioned  and  built  to  host  domestic  SIM  cards  and  if  RLAH  is  introduced  without 
proper  safeguards,  some  see  a  risk  that  foreign  SIM  cards  will  be  located  on  a  permanent 
basis  on  their  networks  –  creating  problems  of  capacity  management  and  possible  network 
congestion. 

A couple of MNOs  refer to  agreements that aim to  reduce the risk of having many  foreign 
M2M  devices  in  their  network  on  a  permanent  basis.  These  agreements  allow  a  maximum 
percentage  of  traffic  out  of  the  total  observed  from  that  visiting  operator  to  permanently 
roam. It is pointed out however, that for the visited network this percentage/limit is difficult 
to detect and control. 

6.4. Description of the wholesale roaming market in the EU 

6.4.1.  Wholesale roaming traffic flows between Member States 

As noted in BEREC's Report on the wholesale roaming market99, observed patterns of voice 
roaming traffic between EEA countries reflect to some extent particular historical, linguistic, 
cultural and economic links between countries (see Table 14 in Annex 3 showing the detailed 
roaming voice traffic flows between countries). 

There  has  also  traditionally  been  a  North-South  divide  in  Europe  between  high-tourism 
Southern  locations  (e.g.  Spain,  Italy,  Greece,  Malta,  Cyprus)  and  lower-tourism  Northern 
locations (e.g. the UK, Germany, Netherlands). In this regard, roaming traffic flows are likely 
to be highly influenced by the patterns of tourism and travelling in the EU. 

In order to assess the countries that are net senders and net receivers of roaming traffic, one 
can look at the ratio of inbound-to-outbound wholesale roaming traffic. A ratio greater than 1 
(or 100%) implies that the country is a net receiver of roaming traffic whereas a ratio below 1 
(or 100%) implies that the country is a net sender.  

Table  11  below  shows  the  inbound/outbound  ratio  for  each  country  for  each  of  the  three 
services. Cyprus, Greece, Malta and Spain stand out as very pronounced net receivers in all 
three services. Bulgaria, Croatia, Hungary, Poland and Portugal have a particularly high data 
unbalance. This is likely to be due to low data consumption of customers from these countries 

99 BEREC's Report on the wholesale roaming market, BoR(16)33, 29 February 2016 

78 

 
 
 
 
 
 
 
 
 
                                                           
when they roam abroad, and lower outbound travel patterns, in addition to a large inflow of 
tourists  in  some  of  these  countries;  Belgium  and  Luxembourg  as  well  are  marked  net 
receivers in data, which might be related to the intensive data usage by business users coming 
to these countries all over the year. 

In contrast, Ireland, the Netherlands, Norway, Romania, Slovakia and the UK are pronounced 
net  senders  in  all  three  services.  Other  important  net  senders  are  Denmark,  Finland  and 
Poland, (voice and SMS), Czech republic and Slovenia (data and SMS), and Austria (data).  

The other countries have a more balanced situation (France, Italy, Latvia, Lithuania, Sweden) 
or operators have not provided the necessary data (Estonia, Germany). 

Table  11  -  Inbound/Outbound  ratio  for  roaming  services:  voice,  data  and  SMS  (in  green 
values above 150%, in blue values below 75%) 

Country 
Austria 
Belgium 
Bulgaria 
Croatia 
Cyprus 
Czech 
Republic 
Denmark 
Estonia 
Finland 
France 
Germany 
Greece 
Hungary 
Ireland 
Italy 
Latvia 
Lithuania 
Luxembourg 
Malta 
Netherlands 
Poland 
Portugal 
Romania 
Slovakia 
Slovenia 
Spain 
Sweden 
UK 
Iceland 
Liechtenstei
n 
Norway 
Switzerland 
Min 
Mean 
Median 
Max 

Voice (Inbound/ outbound 
ratio) 
2014 
87% 
131% 
117% 
155% 
177% 

2013 
81% 
114% 
124% 
144% 
153% 

1H2015 
96% 
168% 
82% 

Data (Inbound/ outbound 
ratio) 

SMS (Inbound/ outbound  
ratio) 

2013 
2014  1H2015 
30% 
78% 
57% 
247% 
161% 
170% 
147% 
383% 
670% 
1400% 
122%  3610%  4238% 
1025% 
165%  1053% 
180% 

2013 
120% 
102% 
191% 
91% 
186% 

2014  1H2015 
120% 
115% 
127% 
107% 
145% 
190% 
91% 
61% 
154% 
170% 

107% 
72% 

90% 
77% 

86% 
79% 

52% 
119% 

77% 
152% 

121% 
157% 

48% 
48% 

72% 
144% 

77% 
141% 

72% 
149% 

96% 
219% 

84% 
125% 

78% 
113% 

55% 
102% 

49% 
43% 

55% 
80% 

289% 
101% 
37% 
98% 
88% 
85% 
104% 
330% 
45% 
63% 
150% 
72% 
51% 
115% 
325% 
100% 
75% 

323% 
94% 
45% 
95% 
100% 
96% 
120% 
305% 
51% 
61% 
100% 
40% 
46% 
99% 
373% 
111% 
76% 

240% 
80% 
55% 
116% 
97% 
94% 
145% 
343% 
58% 
65% 
88% 
21% 
43% 
88% 
350% 
117% 
90% 

559% 
229% 
27% 
110% 
123% 
113% 
153% 
800% 
23% 
108% 
348% 
86% 
62% 
34% 
523% 
107% 
58% 

709% 
255% 
39% 
100% 
123% 
115% 
176% 
760% 
34% 
219% 
237% 
37% 
18% 
31% 
531% 
116% 
55% 

497% 
269% 
40% 
128% 
105% 
98% 
247% 
722% 
49% 
503% 
219% 
20% 
14% 
49% 

890% 
733% 
111% 
101% 
42% 
41% 
152% 
125% 
58% 
52% 
57% 
51% 
137% 
131% 
277% 
274% 
70% 
62% 
38% 
42% 
143% 
128% 
30% 
35% 
42% 
46% 
55% 
62% 
391%  1445%  1692% 
56% 
52% 
63% 
63% 

76% 
70% 

50% 
40% 

51% 
70% 

658% 
124% 
48% 
186% 
47% 
47% 
151% 
314% 
77% 
38% 
136% 
24% 
39% 
58% 
1913% 
61% 
74% 

54% 

55% 

71% 

37% 

48% 

97% 

53% 

57% 

60% 

37% 
100% 
100% 
330% 

40% 
101% 
96% 
373% 

21% 
100% 
90% 

18% 
23% 
311% 
270% 
123% 
113% 
350%  3610%  4238% 

79 

14% 
218% 
121% 

30% 
152% 
70% 
1400%  1445%  1692% 

35% 
139% 
63% 

24% 
152% 
70% 
1913% 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Source: BEREC report on the wholesale roaming market, BoR(16)33, February 2016 
Data: operators' replies to the autumn 2015 data collection 

6.4.2.  Wholesale roaming traffic compared to retail domestic traffic 

Figure  33  to  Figure  36  show,  per  operator,  the  relative  importance  of  wholesale  roaming 
revenues and traffic compared to retail domestic revenues and traffic, based on operators' data 
from the autumn 2015 data collection. 

Figure 33 – Intra-EEA wholesale roaming (inbound) revenue as % of retail domestic revenue 
all services (x-axis) 

Data: operators' replies to the autumn 2015 data collection 
JRC's calculations 

Intra-EEA wholesale roaming revenues represent less than 2% of retail domestic revenues, all 
three services included,  for all operators that provided this information  in the autumn 2015 
data  collection.  The  size  of  wholesale  roaming  revenues  compared  to  domestic  retail 
revenues has decreased since 2013, reflecting the two reductions in wholesale roaming caps 
that  took  effect  in  July  2013  and  July  2014100  as  well  as  ongoing  commercial  trends  at 
wholesale level. 

100 There was no reduction of wholesale roaming cap for SMS in July 2014. 

80 

 
 
 
 
 
                                                           
Figure 34 – Intra-EEA wholesale roaming (inbound) traffic as % of retail domestic traffic (x-
axis) (outgoing voice)  

Figure  35  –  Intra-EEA  wholesale  roaming  (inbound)  traffic  as  %  of  retail  domestic  traffic 
(outgoing SMS) 

81 

 
 
 
 
Figure 36 – Intra-EEA wholesale roaming (inbound) traffic as % of retail domestic traffic (x-
axis) (data) 

Data: operators' replies to the autumn 2015 data collection 
JRC's calculations 

Intra-EEA  wholesale  roaming  traffic  represents  less  than  2%  of  retail  domestic  traffic  for 
voice services and less than 5% for SMS services (with a few exceptions above 5% for SMS). 
This  has  been  relatively  stable  since  2013.  For  data  services  however,  wholesale  roaming 
traffic represents less than 1% of retail domestic traffic only. As noted in the comparison of 
retail roaming consumption to total retail consumption in section 4.4, this reflects the larger 
propensity  of  roaming  subscribers  to  refrain  from  using  data  services,  relative  to  voice  and 
SMS  services,  while  roaming.    One  can  also  note  that  the  size  of  wholesale  roaming  data 
traffic compared to retail domestic data traffic has been increasing since 2013.  As noted in 
the  comparison  of  wholesale  roaming  consumption  to  total  retail  domestic  consumption  in 
section 6.4.2, this reflects the more rapid increase in roaming data consumption than domestic 
data consumption, due inter alia to retail roaming cap reductions in 2013 and 2014. 

82 

 
 
 
 
Figure  37  –  Intra-EEA  wholesale  roaming  (inbound)  revenues  and  traffic  as  %  of  retail 
domestic revenues and traffic (y-axis), 2014  

Data: operators' replies to the autumn 2015 data collection 
JRC's calculations 

In all countries, intra-EEA wholesale roaming revenues and traffic represent less than 4% of 
retail  domestic revenues and traffic, except for SMS services in  some countries.  Countries 
where  intra-EEA  wholesale  roaming  revenues  are  the  highest  compared  to  domestic  retail 
revenues  as  Luxembourg  (almost  4%),  Croatia  (3%),  Spain  and  Malta  (both  slightly  below 
2%). 

6.4.3.  Wholesale roaming payments and revenues balance 

Figure  38  shows  the  total  (i.e.  the  three  services  included)  intra-EEA  wholesale  roaming 
balance  (i.e.  revenues  minus  payments)  expressed  as  a  %  of  total  retail  domestic  revenues, 
per operator, based on operators' data from the autumn 2015 data collection.  

83 

 
 
 
 
Figure 38 - Total intra-EEA wholesale roaming balance (revenues minus payments) as a % of 
total retail domestic revenues (x-axis), all services included 

Data: operators' replies to the autumn 2015 data collection 
JRC's calculations 

About 60% of the operators providing the data have balanced intra-EEA wholesale roaming 
revenues and payments within the [-1%; +1%] range of total retail domestic revenues. About 
20%  of  them  have  a  negative  intra-EEA  wholesale  roaming  imbalance  below  -1%  of  total 
retail  domestic  revenues  and  about  20%  a  positive  imbalance  above  +1%.  The  EEA 
wholesale roaming balance has stayed relatively stable since 2013.  

Figure  39  shows  the  total  intra-EEA  wholesale  roaming  balance  expressed  as  a  %  of  total 
retail domestic revenues per country. 

84 

 
 
 
 
 
Figure 39 - Total intra-EEA wholesale roaming balance (revenues minus payments) as a % of 
total retail domestic revenues (y-axis), all services included, per country 

Data: operators' replies to the autumn 2015 data collection 
JRC's calculations 

Operators  in  Croatia  have  the  largest  positive  imbalance  (i.e.  wholesale  roaming  revenues 
exceeding wholesale roaming out-payments), which however decreased from slightly above 
3%  to  slightly  less  than  3%  of  total  retail  domestic  revenues.  Other  inbound  roaming 
countries  are  Spain,  Greece,  Malta  and  Luxembourg,  with  a  positive  imbalance  wholesale 
roaming  representing  about  +1%  of  total  retail  domestic  revenues  in  2014.  In  contrast, 
operators in Slovenia, the Netherlands, Denmark, have the strongest negative imbalances (i.e. 
wholesale roaming payments exceeding wholesale roaming revenues), followed by Norway, 
Poland,  Slovakia.  The  data  therefore  illustrate  the  North/South  divide  of  outbound/inbound 
countries  in  Europe.  They  also  show  the  modesty  of  the  size  of  the  wholesale  roaming 
imbalance in either direction compared to total retail domestic revenues. 

6.4.4.  Wholesale roaming prices  in the EU 

Section 6.3 above described the process of negotiating wholesale access roaming prices and 
the  contractual  agreements  typically  observed  between  wholesale  roaming  operators  in  the 
EU. This section describes the wholesale roaming prices resulting from those negotiations, as 
well as the revenues derived from wholesale roaming services in different Member States.  
In general, two MNOs in two different Member States will have a certain amount of roaming 
traffic (minutes, SMS, MB) that balance out  ("balanced traffic")101 and a certain  amount of 

101 In certain cases however an MNO may not receive any in-coming roaming traffic. This is typically the case 
of late entrants that entered domestic markets after the existing MNOs had already reached wholesale access 
agreements with all MNOs abroad. 

85 

 
 
 
 
                                                           
roaming  traffic  that  one  MNO  has  to  provide  to  the  other  in  excess  of  the  balanced  part 
("unbalanced traffic")102.  

MNOs  typically  agree  on  different  rates  for  balanced  and  unbalanced  traffic.  Figure  40  to 
Figure 42 below show the operators' average wholesale roaming prices for (i) balanced traffic 
and (ii) unbalanced traffic in inbound and outbound roaming situations. 

The  variability  of  the  value  among  EEA  countries  is  illustrated  by  using  box  plots  which 
indicate  the  first  and  third  quartile  values  (Q1  and  Q3  respectively)  as  well  as  the  median 
value. 

Figure 40 - Average wholesale roaming prices for balanced and unbalanced traffic (inbound 
and outbound): voice services (2015) 

Source: BEREC Report on the wholesale roaming market, BoR(16)33, February 2016 
Data: operators' replies to the autumn 2015 data collection 

In the case of voice, the median wholesale roaming prices for balanced traffic (4.3 €c/min) 
are  below  the  cap103.  The  median  wholesale  roaming  prices  for  unbalanced  traffic  (at  3.7 
€c/min)  are  significantly  lower  than  the  cap  with  less  variability  compared  to  the  balanced 
traffic average prices.  

Roaming-in  (inbound  roaming)  tariffs  are  comparable  to  the  ones  applied  in  roaming-out 
(outbound  roaming)  situation.  The  slight  differences 
the 
incompleteness  of  the  collected  data,  since  not  all  the  operators  replied  to  the  addressed 
questionnaire. 

that  appear  are  due 

to 

102 In other words, 'balanced traffic' between two operators A and B designates the part of roaming traffic 
generated by operator A's customers roaming on operator B's network that matches the roaming traffic 
generated by operator B's customers on operator A's network. 'Unbalanced traffic' designates the part of roaming 
traffic that one of the two operators sends to the other operator in excess of the balanced part. 
103 There are few values (the last quartile of operators, not shown) above the wholesale roaming cap. This could 
be explained by the calculation perimeter considered by these operators in their response, taking into account the 
average of regulated (EU) and non-regulated (outside EU) tariffs. 

86 

 
 
 
 
 
 
 
 
 
                                                           
Figure 41 - Average wholesale roaming prices for balanced and unbalanced traffic (inbound 
and outbound): SMS services (2015) 

Source: BEREC Report on the wholesale roaming market, BoR(16)33, February 2016 
Data: operators' replies to the autumn 2015 data collection 

In  the  case  of  SMS,  both  average  prices  for  balanced  and  unbalanced  traffic  are  below  the 
cap.  The median of the average price for unbalanced traffic is slightly above half the cap (1 
€c/SMS).  Like  in  the  case  of  voice,  the  variability  of  the  average  price  across  operators  is 
smaller for unbalanced traffic104.  

Figure 42 - Average wholesale roaming prices for balanced and unbalanced traffic (inbound 
and outbound): data services (2015) 

Source: BEREC Report on the wholesale roaming market, BoR(16)33, February 2016 
Data: operators' replies to the autumn 2015 data collection 

In the case of data services, the difference between the average prices and the cap is large: the 
median of these average prices is about half the cap (2.5 €cents/MB) for balanced traffic and 
about 1.3 €/MB for unbalanced traffic, i.e. less than one third of the cap. Like for voice and 

104 In the case of roaming-out SMS, the higher variability observed for unbalanced traffic might be partly due to 
the lower response rate for this particular data. 

87 

 
 
 
 
 
 
 
 
                                                           
SMS, the variability of the average prices across operators is smaller for unbalanced traffic 
than for balanced traffic. 

The general pattern observed for the three services is that for balanced traffic MNOs usually 
agree to mutually charge each other a higher price than for unbalanced traffic.  

Since  the  number  of  minutes,  (or  SMS  or  MB)  of  balanced  traffic  is  the  same  for  both 
operators, and the price is the same for both operators, this price can be considered altogether 
irrelevant – the flow of payments in one direction (from operator A to operator B) is netted 
off  by  the  flow  of  payments  in  the  opposite  direction  (from  operator  B  to  operator  A).105 
Operators  have  therefore  limited  incentives  to  negotiate  a  lower  price  for  that  part  of  the 
traffic. 

In  contrast,  the  price  for  the  unbalanced  traffic  matters  as  this  part  of  the  traffic  is  paid  by 
only  one  MNO  to  the  other.  For  this  part  of  the  traffic,  the  interests  of  the  MNOs  in  the 
negotiation are therefore not aligned: the MNO that expects to sell more traffic (i.e. the net-
receiver of roaming traffic) will tend to seek a high rate for excess traffic, whereas the MNO 
that expects to buy more minutes (i.e. the net sender of roaming traffic) will tend to seek a 
low rate.106  

It  results  from  the  above  that  price  negotiation  in  wholesale  roaming  agreements  is  mostly 
about the unbalanced part of the traffic.  The price for balanced traffic is by definition never 
paid, in the sense that it cannot lead to a payment deficit; only the rate for unbalanced traffic 
can lead to a payment deficit. For this reason, it can be considered that the lower, negotiated 
price  for  unbalanced  traffic  is  the  one  that  sets  an  effective  lower  bound  on  wholesale 
roaming prices.107  

6.5. Degree of competition in national wholesale roaming markets 

It has traditionally been assumed that the incentives as regards wholesale roaming pricing are 
aligned  with  the  specific  position  of  the  MNO  as  a  net-receiver  or  net-sender  of  traffic. 
According to this view, mobile operators which are net-senders of traffic and net out-payers 
(e.g.  in  Northern  location),  therefore  viewing  wholesale  roaming  as  a  cost  rather  than  a 
source of revenue, will have an incentive in setting and seeking low wholesale access prices. 
In  contrast,  net  receivers,  for  whom  wholesale  roaming  prices  are  a  source  of  revenue,  are 
likely  to  favour  keeping  wholesale  rates  higher,  and  might  be  reluctant  to  enter  into 
alliances.108 

6.5.1.  Operators' views of the functioning of the national wholesale roaming 

markets 

105 WIK-Consult (2010), Study on the Options for addressing Competition Problems in the EU Roaming 
Market, SMART 2010/018, December, p. 36. 
106 WIK-Consult (2010), Study on the Options for addressing Competition Problems in the EU Roaming 
Market, SMART 2010/018, December, p. 36. 
107 WIK-Consult (2010), Study on the Options for addressing Competition Problems in the EU Roaming 
Market, SMART 2010/018, December, p. 38. 
108 WIK-Consult (2010), Study on the Options for addressing Competition Problems in the EU Roaming 
Market, SMART 2010/018, December, p. 34. 

88 

 
 
 
 
 
 
                                                           
The responses to the public consultation shows that mobile operators are split as regards their 
view  of  the  functioning  of  national  wholesale  roaming  markets  currently:  50%  of  MNOs 
replied that they are well functioning for voice, SMS and data, and another 6% that they are 
well  functioning  for  voice  and  SMS  only.  75%  of  MNOs  are  able  to  negotiate  prices  well 
below  the  cap  for  voice,  62.5%  for  SMS  and  97%  for  data.  MVNOs  claim  they  never  get 
prices well below the caps. 

Only 10% of MNOs and MVNOs combined do not steer traffic over one or more networks in 
the visited country. MVNOs in particular say they have no incentive to steer traffic since they 
get  a  unique  price  from  visited  networks.  61%  of  the  operators  which  steer  traffic  steer  all 
traffic,  and  39%  steer  only  a  fraction.  However,  most  of  the  latter  specify  that  they  steer  a 
very large part of their traffic (typically 95%), claiming that there is always a residual traffic 
that cannot be steered (coverage, capacity).  

There  is  a  Sender/Receiver  divide  among  MNOs  (i.e.  incumbent/operators  with    large 
footprint  vs  smaller  operators,  operators  with  large  inbound  vs  large  outbound  roaming 
traffic)  in  the  appreciation  of  the  functioning  of  national  wholesale  roaming  markets: 
operators sending out more roaming traffic and/or with smaller roaming volumes to offer find 
the  wholesale  roaming  market  not  properly  functioning  (smaller  operators,  MVNOs,  large 
outbound  operators),  while  operators  receiving  more  roaming  traffic  and/or  with  large 
roaming  volumes  to  offer  (incumbents/operators  with  large  footprint,  large  inbound 
operators) find it properly functioning. All MVNOs find the market not properly functioning. 

Operators that consider the national wholesale roaming markets as well-functioning 'function 
well' mainly argue that: 

  Regulated  wholesale  caps  serve  as  references  from  which  operators  commercially 

negotiate the prices; 

  Actual negotiated prices are below regulated caps and have decreased continuously in 

between two successive cap changes; 

  The visiting operator can choose between several operators in the visited country and 

steer traffic to its chosen partner(s) only; 

  Continuous and expected growth of retail roaming volumes increases the competition 
among visited operators in a country in order to obtain those volumes (and the related 
revenues) on their own networks; 

  Because  they  only  have  roaming-out  wholesale  volumes  to  buy  and  cannot  offer 
roaming-in wholesale traffic in return, full MVNOs are in a good negotiation position, 
as visited operators compete with each other to offer their best prices to get this net 
traffic on their network and the corresponding additional revenue; 

  There  are  already  true  RLAH  offers  on  the  market  which  shows  that  the  wholesale 

roaming markets currently enable RLAH already. 

Operators  that  consider  the  national  wholesale  roaming  markets  as  not  well-functioning 
mainly argue that: 

  Prices  obtained  by  some  market  players  (MVNOs,  smaller  operators  not  part  of  a 

group) are at or close to cap level; 
  Prices are much higher than the costs; 
  Prices  are  much  higher  than  domestic  wholesale  MVNO  access  prices,  which  are 
unregulated; this shows that MNOs do not compete for MVNO roaming traffic, while 
they do compete for MVNO domestic traffic; 

89 

 
 
  Prices are much higher than domestic retail prices; 
  Even if there are several operators to choose from in each national market, the visiting 
operator  is  dependent  on  certain  operators  (coverage,  capacity),  which  in  practice 
limits  the  bargaining  power  of  the  visiting  operator  and  hence  competition  on  the 
visited market; 

  There are structural differences in negotiation positions of different market players:  

o  Operators in  travel  surplus countries  attract  inbound  roamers  anyway  and do 
not  need  to  decrease  prices;  they  seek  to  maximise  their  inbound  roaming 
revenues; in these countries, all network operators have a common interest in 
keeping wholesale rates at a high level; 

o  Discount  rates  from  the  cap  depend  on  roaming  volumes,  so  that  smaller 
operators  and  MVNOs,  which  send  less  traffic  than  bigger  MNOs,  benefit 
from no or very limited discount rates;  

o  For coverage and quality of service reasons, the visiting operator may have to 
negotiate  roaming  agreements  with  several  operators  in  a  given  visited 
countries,  which  reduces  its  roaming  volume  commitments  to  each  visited 
network, and thereby reduces its ability to negotiate discount rates; in addition, 
for  the  same  reasons  of  coverage  and  quality  of  service,  there  is  always  a 
residual part of the roaming traffic that the visiting operator cannot steer to the 
visited network(s) with which it has a wholesale roaming discounted rates;  
o  Large  groups  with  significant  footprints  in  several  countries  can  take 
advantage  of  the  imbalance  in  European  roaming;  they  have  stronger 
negotiation power against smaller groups or individual operators; 
  MVNOs are unilateral buyers, as they cannot host any inbound roaming, hence they 

do not have any traffic to trade; 

  As  shown  by  the  much  higher  international  non-EU  wholesale  roaming  prices,  the 
market needs caps to deliver lower prices, which implies that the market is not well-
functioning by itself but is structurally not well-functioning. 

It  is  interesting  to  note  that  although  voice  and  SMS  prices  are  closer  to  the  cap  than  data 
prices  are,  voice  and  SMS  markets  are  judged  well-functioning  by  slightly  more  operators 
than data. This may be an indication that these operators are of the view that voice and SMS 
prices are approaching a (cost) floor. These operators are also of the view that, although data 
prices  are  usually  well  below  the  cap  (a  sign  of  competition  dynamics),  there  is  still  large 
room for further decrease while remaining above costs, a sign of lack of competition on this 
market. 

For  most  operators,  the  functioning  of  the  market  does  not  depend  on  the  Member  State. 
According to most operators what matters are the relative positions and bargaining powers of 
the  two  operators  in  roaming  negotiations,  more  than  the  visited  country  itself.  However, 
many  operators  also  argue  that  the  relative  bargaining  power  of  two  operators  heavily 
depends  on  geographical  features  that  structurally  make  some  countries  large  inbound 
countries while others are large outbound countries. 

NRAs  and  governments  express  views  similar  to  those  of  the  operators  of  their  countries. 
Large  inbound  roaming  countries  see  national  wholesale  roaming  markets  as  well-
functioning, while large outbound roaming countries are of the opposite view. 

As  regards  consumers  and  their  associations,  they  are  cautious  in  expressing  views  on 
wholesale roaming markets since they do not face these markets directly. More than half and 
up to 72% of consumers and up to 6 out of 7 consumers' associations do not express views 

90 

 
 
about some of the wholesale review related questions of the consultation. When they do, their 
perspective is similar to  that of smaller operators and MVNOs, as they tend to see national 
wholesale roaming markets as not well-functioning. 

6.5.2.  Operators' views about the ability of the current functioning of national 

wholesale roaming markets to enable RLAH in the EU 

According to the responses to the public consultation, only 30% and slightly more than 25% 
of  MNOs  and  MVNOs  combined  are  of  the  view  that  the  wholesale  roaming  market  can 
deliver sustainable RLAH without regulation or under current regulation respectively. 

In  general,  those  operators  that  find  the  wholesale  roaming  market  well-functioning 
(incumbents/operators  with  large  footprint,  operators  with  large  inbound  vs  large  outbound 
roaming  traffic)  also  defend  the  view  that  current  national  wholesale  roaming  markets  can 
deliver  sustainable  RLAH  without  regulation  or  with  current  regulation,  and  vice-versa. 
However,  there  are  also  operators  that  are  of  the  view  that  under  current  regulation  the 
wholesale roaming market is rather well-functioning, but not sufficiently to deliver RLAH or 
that  the  market  would  not  be  well-functioning  anymore  under  RLAH.  Hence,  for  those 
operators,  the  wholesale  roaming  market,  although  functioning  relatively  well  now,  would 
not deliver sustainable RLAH. 

About  half  of  MNOs  and  MVNOs  combined  are  of  the  view  that  the  lack  of  bargaining 
power  of  smaller  operators  (i.e.  with  a  low  market  share  and/or  low  amounts  of  roaming 
traffic negotiated and/or limited footprint) and too high wholesale caps are the main obstacles 
to RLAH. 

The above analysis in sections 6.5.1 and 6.5.2 is fully consistent with the analysis made by 
BEREC  of  operators'  replies  to  the  autumn  2015  data  collection  in  its  Report  on  the 
wholesale roaming market109. 

6.5.3.  MVNOs' views of the functioning of the national wholesale roaming 

markets 

Light  MVNOs  buy  roaming  from  their  host  MNO110.  Full  MVNOs  can  buy  wholesale 
roaming  either  by  establishing  direct  roaming  agreements  with  foreign  operators  or  by 
contracting  with  a  sponsor  operator  (not  necessarily  their  host  MNO)  who  already  has 
roaming agreements.  Because they are usually small operators, full MVNOs tend to favour a 
unique roaming sponsor to manage their traffic: indeed, besides the complexity of negotiating 
direct  agreements,  multiple  roaming  providers  also  means  lower  volumes  per  provider  and 
therefore less bargaining power. In practice the tariff structures offered by roaming sponsors 
do  not  reflect  the  granularity  of  prices  per  visited  operators.  In  particular,  buyers  have 
generally one unique tariff for the group of EU countries. 

BEREC  provides  the  following  summary  of  MVNOs's  views  of  the  functioning  of  the 
national  wholesale  roaming  markets  expressed  in  the  autumn  2015  data  collection.111  This 
summary is confirmed by MVNOs' replies to the Commission's public consultation. 

109 BEREC report on the wholesale roaming market, BoR(16)33, February 2016, section 3. 
110 This is because light MVNOs do not have their own Mobile Network Code which identifies a particular 
operator on another operator's network. 
111 BEREC Report on the wholesale roaming market, BoR(16)33, February 2016, section 3.2. 

91 

 
 
 
 
                                                           
Full and light MVNOs report that they have access to the wholesale roaming market  at the 
level  of  the  current  wholesale  roaming  caps.  They  therefore  do  not  benefit  from  the  lower 
wholesale  roaming  prices  observed  on  the  current  wholesale  roaming  markets.  In  addition, 
MVNOs most often buy from the MNO providing them with roaming services the different 
services necessary to comply with the retail roaming obligations set in Roaming Regulation 
III (e.g. bill shock measure, welcome SMS). The prices for these services are not covered by 
the wholesale roaming caps. These services therefore have to  be paid  by  the MVNO to  the 
host  MNO  in  addition  to  the  capped  wholesale  roaming  price.  As  a  result,  in  practice 
MVNOs  often  pay  higher  wholesale  roaming  prices  than  the  wholesale  roaming  caps.  A 
minority  of  MNOs  offer  all  services  needed  to  comply  with  Roaming  Regulation  III  at  the 
level of current wholesale roaming caps. 

MVNOs  with  a  dual  IMSI  platform  who  are  member  of  a  group  are  usually  in  a  more 
favourable  situation  as  the  group  can  bundle  their  individual  volumes  and  therefore  has 
buying power to enjoy the benefits of the lower wholesale roaming tariffs in the market. 

6.5.4.  Wholesale roaming prices vs wholesale and retail domestic prices and 

underlying costs 

Domestic  unit  prices  at  retail  and  wholesale  level  are  expected  to  be  above  the  costs  of 
providing the domestic wholesale service. 

  Domestic retail prices 

Deriving domestic retail prices per service implies some assumption about the allocation of 
the  domestic  bundle  prices  to  the  three  services  (voice,  SMS,  data)  usually  including  in 
domestic bundles.  

As shown in Table 7 in section 5, based on a recent Commission study on mobile broadband 
prices112, retail domestic prices for voice vary considerably across countries, from less than 2 
€c/min to more than 9 €c/min, depending on the allocation method considered.  

Retail domestic prices for data in the least expensive domestic bundles are mostly between 1 
€c/MB  and  2  €c/MB.  As  to  retail  domestic  data  prices  in  the  least  expensive  data-only 
domestic  tariff  plans  of  5  GB  and  10  GB  for  laptops  and  tablets,  they  are  always  below  1 
€c/MB in all countries.113 However, the latter prices are likely to include certain assumptions 
about customers' actual use of the full data package, so effective aggregate unit prices may be 
higher.  

Retail  domestic  prices  for  SMS  in  bundles  are  mostly  between  0.8  €c/SMS  and  2  €c/SMS. 
However,  since  more  and  more  domestic  bundles  include  unlimited  SMS,  the  actual  unit 
price of SMS entirely depends on the actual consumption of the subscriber. 

  Domestic wholesale prices 

112 European Commission, Mobile Broadband Prices (prices from February 2015), study conducted by van Dijk 
Management Consultants, March 2016: https://ec.europa.eu/digital-single-market/en/news/mobile-broadband-
prices-february-2015 
113 Ibid.  

92 

 
 
 
                                                           
According  to  information  provided  by  MVNOs  to  the  Commission,  domestic  wholesale 
prices  for  data  are  usually  below  0.8  €c/MB  on  national  wholesale  markets  and  may  be  as 
low as0.1 €c/MB.  

For voice, the domestic wholesale prices are usually below 1 €c/min for call origination. For 
a direct comparison to wholesale roaming caps, termination and transit costs need to be added 
to origination. Adding transit costs and an allocation for the termination rate that the visited 
network operator needs to pay the terminating network operator for terminating a call on its 
network, as discussed in sections 5.6 and 5.5 respectively, gives a total below 2.4 €c/minute.  

As  to  SMS,  0.2-0.3  €c/SMS  is  commonly  observed  on  national  wholesale  markets.  The 
sample  of  prices  provided  to  the  Commission  is  however  limited  and  relates  to  countries 
which are not at the higher end of the TERA Consultants' cost estimates. 

  Estimated wholesale roaming costs 

Wholesale roaming costs estimated in TERA Consultants' cost model for voice (including re-
allocation of joint and common costs of incoming calls, roaming specific costs, seasonality, 
and  transit  costs)  is  at  4.2  €c/minute  in  Malta,  3.2  €c/minute  in  Sweden,  and  below  3 
€c/minute in all other Member States and Norway (see Table 10  in section 5). Based on an 
alternative method using the national effective MTR as an estimate of origination costs114, the 
highest cost estimates are below 4 €c/minute for all countries.  

For  data,  wholesale  roaming  costs  estimated  in  TERA  Consultants'  cost  model  (including 
roaming-specific  costs)  and  including  transit  costs  to  be  borne  by  the  visited  operator  are 
below 0.67 €c/MB in all Member States and Norway. 

  Wholesale roaming market prices 

As shown in section 3.2, in the third quarter of 2015, according to BEREC's last Benchmark 
Report on roaming115, the EEA average wholesale prices for intra-EEA roaming voice, SMS 
and data services were respectively: 

  3.6  €c/minute  (minimum  =  2.1  €c/minute  in  Portugal,  maximum  =  5  €c/minute  in 

Malta),  

  1.2 €c/SMS (minimum = 0.8 €c/SMS in Portugal, maximum = 1.8 €c/SMS in Cyprus, 

Finland, Iceland, Latvia, Lithuania),  

  1.7 €c/MB (minimum = 1.0 €c/MB in Portugal, maximum = 4.4 €c/MB in Malta).  

Section  6.4.4  shows  that  average  prices  for  wholesale  roaming  unbalanced  traffic  range 
from: 

  2.7 to 3.9 €c/min for voice (median at 3.7 €c/min),  
 
from 1 to 1.4 €c/SMS (median at 1.1 €c/SMS),  
 
from 1 to 1.9 €c/MB for data (median at 1.3 €c/MB)  

114 And using TERA's estimates of average common costs, average roaming-specific costs and country 
seasonality effect, as well as the same transit cost estimate as in the first method. 
115 International roaming BEREC Benchmark Data Report April – September 2015, BoR(16)28, February 2016 

93 

 
 
 
 
 
 
                                                           
according  to  the  data  provided  by  operators  in  the  autumn  2015  data  collection.  Standard 
deviations of these prices are relatively small for voice and SMS (0.32 and 0.12 respectively), 
larger for data (0.6). 

Wholesale roaming prices for SMS and data are therefore above cost estimates as they can be 
inferred  from  the  cost  model  and  domestic  wholesale  prices.  For  voice,  wholesale  roaming 
prices are closer to the cost estimates. 

6.5.5.  Presence of pan-European mobile operators 

Nine  operators  in  the  EEA  provide  mobile  services  in  three  or  more  EEA  countries.  Their 
respective footprints are shown in Table 12. As shown in section 6.5.6, these group operators 
have the possibility and the ability to steer roaming traffic on the networks of their affiliates 
in  the  countries  where  they  are  present,  thereby  internalising  wholesale  roaming  costs  and 
reducing  their  wholesale  roaming  out-payments  to  other  operators.  In  addition,  the  group 
operators are usually able to negotiate better wholesale roaming prices with other operators, 
as  they  usually  negotiate  at  the  group  level,  thereby  benefiting  from  higher  volume 
commitments. The different affiliates of a group can then benefit from the wholesale roaming 
prices obtained by that group.  

94 

 
 
 
 
 
 
Table 12 - Presence of pan-European mobile operators 

BE  BG  CZ  DK  DE  EE 

IE  EL  ES  FR  HR 

IT 

LV 

LT 

LU  HU  MT  NL  AT  PL  PT  RO  SI  SK  FI  SE  UK  NO 

LI 

IS 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

Deutsche 
Telekom 

Hutchison 
Europe 

Orange 

x 

x 

x 

x 

x 

x 

x 

Tele2 

Telefonica 

Telekom 
Austria 
Group 
Telenor 

TeliaSonera 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

Vodafone 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

Sources: Company annual reports 2014 (2015 for Vodafone) – 11 January 2016 

95 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
6.5.6.  Inside vs outside group roaming 

6.5.6.1.  Steering roaming traffic inside the group 

Operators  with  a  presence  in  different  countries  steer  the  roaming  traffic  of  their  roaming 
customers  (outbound  roaming  traffic)  on  their  own  network  (inside  group  traffic  or  on-net 
roaming  traffic)  (Figure  43  to  Figure  45).  For  voice  and  SMS,  when  an  operator  owns  a 
network  in  the  destination  country,  the  ratio  between  on-net  and  off-net  roaming  traffic  in 
that destination country is respectively above 9 and 7 in 80% of the cases (i.e. below 9 and 7 
in  20%  of  the  cases).  This  means  that  when  an  operator  owns  a  network  in  a  destination 
country, in 80% of the cases it steers 9 times more of its outbound roaming voice traffic on its 
own  network  than  on  another  network  in  that  destination  country.  This  on-net/off-net  ratio 
can go above 100 for the top 20% of the cases as shown in Figure 43 and Figure 44. For data, 
the ratio is even higher: above 17 for 80% of the cases and goes beyond 100 for the top 40% 
of the cases.  

For all three services, this ratio has markedly increased between 2013 and 2015, showing an 
increase in intra-group traffic steering over the last years. This is likely to reflect an increase 
in geographical coverage of the operators in destination countries where they are present and 
possibly some acquisitions. Such high on-net/off-net ratios show that only residual roaming 
traffic  is  hosted  by  a  roaming  partner  when  an  operator  owns  a  network  in  the  destination 
country.  The  size  of  this  residual  off-net  roaming  traffic  depends  on  the  coverage  of  the 
operator's network in the destination country.  

Figure  43  –  Ratio  inside  group  over  outside  group  roaming  volumes  per  operator  and 
destination country (voice - outbound roaming traffic) 

Data: operators' replies to the autumn 2015 data collection 
JRC's calculations 

96 

 
 
 
 
 
Figure  44  -  Ratio  inside  group  over  outside  group  roaming  volumes  per  operator  and 
destination country (SMS - outbound roaming traffic) 

Data: operators' replies to the autumn 2015 data collection 
JRC's calculations 

Figure  45  -  Ratio  inside  group  over  outside  group  roaming  volumes  per  operator  and 
destination country (data - outbound roaming traffic) 

Data: operators' replies to the autumn 2015 data collection 
JRC's calculations 

97 

 
 
 
 
 
 
6.5.6.2. 

Inside vs outside group wholesale roaming 

prices 

Operators with a presence in different countries charge the wholesale roaming traffic of their 
roaming customers (outbound roaming traffic) at a lower price on their own network (inside 
group traffic or on-net roaming traffic) than the price they have to pay to other networks of 
the same destination (visited) country.  

This is confirmed by the operators' data shown in Figure 46 to Figure 48. These figures show, 
for  each  service, 
the  effective  wholesale  roaming  unit  price 
(payments/revenues)  inside  the  group  and  outside  the  group.  A  ratio  below  1  indicates  a 
smaller price inside the group than outside the group. 

the  ratio  between 

Figure 46 – Ratio between inside group and outside group wholesale roaming unit prices per 
operator and destination country (voice - outbound roaming traffic) 

Data: operators' replies to the autumn 2015 data collection 
JRC's calculations 

98 

 
 
 
 
 
Figure 47 - Ratio between inside group and outside group wholesale roaming unit prices per 
operator and destination country (SMS - outbound roaming traffic) 

Data: operators' replies to the autumn 2015 data collection 
JRC's calculations 

Figure  48 Ratio between inside group  and outside group wholesale roaming unit prices per 
operator and destination country (data - outbound roaming traffic) 

Data: operators' replies to the autumn 2015 data collection 
JRC's calculations 

99 

 
 
 
 
 
For  voice  and  SMS,  the  ratio  between  inside  group  and  outside  group  wholesale  roaming 
prices homogeneously ranges from 0 to 1, with a median at 0.6 for voice in the first semester 
2015  (0.5  for  SMS),  across  operators  and  destination  countries  with  on-net  (inside  group) 
traffic.  In  other  words,  in  half  of  the  operator-destination  country  pairs,  wholesale  roaming 
prices for voice are more than 1.7 (twice for SMS) cheaper inside group than outside group; 
and in the other half of the cases they are less than 1.7 (twice for SMS) cheaper. One can note 
than in 10% of the cases, the inside group price is higher than outside group (ratio above 1) 
bot for SMS and data. 

For data the median is at 0.2. The inside group discount on data is therefore much larger than 
on voice and SMS: for data, in half of the cases, the inside group wholesale roaming price is 
more than 5 times cheaper than the outside group wholesale roaming price. For data there is 
no case where the price is higher inside group than outside group. 

Finally, the ratio between inside and outside group prices has increased since 2013 for voice 
and data. This reflects decreasing outside group prices following the reductions in wholesale 
roaming caps in July 2013 and July 2014. 

6.5.7.  Competitive situation of operators with limited geographic scope 

In the system of bilateral negotiations summarised above, operators with limited geographic 
scope (e.g. present  in  one country) structurally  face a number of challenges as they tend to 
have:  

  no possibility to internalise roaming costs while operators with a footprint in several 
countries may internalise those costs in their countries of operation (see section 6.5.6 
above). 

  higher  unit  costs  of  bilateral  negotiations  and  contract  management:  operators  with 
limited geographic scope tend to be smaller in size and thus do not benefit to the same 
extent from  economies of scale because, as shown by the cost  analysis in  section 5, 
the costs of bilateral negotiations and contract management are overall approximately 
the same for larger and smaller operators116 
less  favourable  discounted  prices  due  to  smaller  volume  commitments:  smaller 
operators  are  not  able  to  secure  as  beneficial  discounts  as  larger  operators  because 
discounts  are  highly  influenced  by  the  amount  of  outbound  traffic  that  can  be 
committed. This is the object of the analysis below. 

 

In addition, as they may also not be able to secure discount agreements with several operators 
in some visited countries (lack of resources, insufficient volume commitments to be split on 
several  networks),  smaller  operators  may  more  often  have  their  roaming  traffic  hosted  on 
networks  with  which  no  bilateral  agreement  have  been  passed  and  where  the  price  cap  is 
therefore automatically applied. 

Due to the anonymity of the data collected in the autumn 2015, it is not possible to analyse 
any  relationship  between  wholesale  roaming  prices  and  the  actual  geographical  scope  of 

116 Consistent with the finding of TERA Consultants, WIK-Consult (2010), Study on the Options for addressing 
Competition Problems in the EU Roaming Market, SMART 2010/018, December, p. 22, also found that 
bilateral negotiations and contract management costs are similar for larger and smaller operators. 

100 

 
 
 
 
 
 
 
                                                           
operators.  As  a  proxy,  it  was  used  the  number  of  subscribers  to  account  for  the  size  of  the 
operators, as several of the group operators have a large domestic customer base. 

Figure  49  to  Figure  51  show,  for  each  service,  the  relationship  between  the  size  of  the 
operator,  expressed  in  number  of  subscribers,  and  the  average  wholesale  roaming  price  for 
unbalanced traffic paid by that operator for outbound roaming traffic. It should be noted that 
operators  are  looked  at  on  a  per-country  basis,  which  means  per  subsidiary  for  the  multi-
country groups. 

Figure 49 – Average wholesale roaming price for unbalanced traffic vs operator size (voice - 
outbound traffic) 

101 

 
 
 
 
Figure 50 – Average wholesale roaming price for unbalanced traffic vs operator size (SMS - 
outbound traffic) 

Figure 51 – Average wholesale roaming price for unbalanced traffic vs operator size (data  - 
outbound traffic) 

Data: operators' replies to the autumn 2015 data collection 
JRC's calculations 

102 

 
 
 
 
 
The average wholesale roaming price paid for unbalanced outbound traffic tends to be lower 
for  larger  operators  than  for  smaller  operators.  This  negative  correlation  between  average 
price and size is more marked for data. While some of the smaller operators may on average 
obtain  comparable  prices  to  larger  operators,  there  is  no  large  operator  with  high  average 
prices.  In  addition,  several  of  the  smaller  operators  benefitting  from  average  prices  in  the 
same price range as larger operators (e.g. below 0.025 €c/MB) are affiliates of larger groups 
which  provided  consolidated  group  average  prices  for  their  different  affiliates,  while  the 
number  of  subscribers  reported  is  that  of  the  country  affiliate  itself.  Smaller  independent 
operators and MVNOs are mostly represented by the dots in the upper left part of the graphs 
above,  which  shows  that  the  operators  are  subject  to  higher  wholesale  roaming  prices  for 
unbalanced traffic on average. 

Figure 52 shows the average difference between  the effective wholesale  roaming unit price 
for  data  paid  by  the  operator  to  an  EEA  country117  and  the  unit  price  received  from  the 
operator  from  that  EEA  country118  (outside  group).  This  average  difference  between  the 
effective unit price paid and received for data is represented against the size of the operator, 
expressed in terms of number of subscribers. For all larger operators, the difference is null, 
which  indicates  that  larger  operators  effectively  pay  the  same  price  to  their  partners  for 
outbound roaming as they receive from them for inbound roaming. This is also the case for 
most  of  the  smaller  operators.  However,  some  of  the  smaller  operators  do  experience 
effective higher prices to be paid than received. For voice and SMS, the difference between 
prices paid and received is about zero for all operators (see Figure 53 and Figure 54 in Annex 
2).  

Figure  52 -  Difference between effective unit prices  (payments/volumes)  paid  and received 
(data - outside group traffic) 

Data: operators' replies to the autumn 2015 data collection 

117 Total wholesale roaming payments of the operator to country A / total wholesale roaming volumes sent by 
the operator to country A 
118 Total wholesale roaming charges received by the operator from country A / total wholesale roaming volumes 
received by the operator from country A 

103 

 
 
  
 
                                                           
JRC's calculations 

Altogether, the data shown in the figures above indicate higher wholesale roaming prices paid 
by smaller independent MNOs than group MNOs. 

6.6. Conclusions 

In  this  section,  different  types  of  information  have  been  used  to  assess  the  competitive 
dynamics  under  current  regulation:  a  description  of  roaming  traffic  flows  in  the  EU  plus 
Norway, a description of wholesale roaming agreements between operators and the different 
pricing models used, the description and assessment of the functioning of wholesale roaming 
markets  by  operators,  different  sources  of  effective  wholesale  roaming  prices  compared  to 
cost estimates and to domestic wholesale and retail prices. 

The analysis shows that, due to a number of identified market failures (oligopolistic character 
of  national  wholesale  markets,  bilateral  nature  of  roaming  agreements,  imperfect  wholesale 
roaming  substitutes,  exclusion  of  MVNOs  from  wholesale  roaming  markets),  wholesale 
roaming  markets  under  current  regulation  continue  to  not  function  correctly  despite  some 
competitive dynamics. 

The  different  sources  of  wholesale  roaming  prices  that  are  available  and  have  been 
considered119 show that:  

i) 

ii) 

iii) 

average wholesale roaming prices have remained below successive regulated caps 
for all three services over the last years. This is a sign of competition dynamics in 
the three markets. The gap between the cap and market prices is particularly high 
and continuously growing for data.  
wholesale  prices  for  balanced  roaming  traffic  are  substantially  larger  than  for 
unbalanced roaming traffic; only the prices for unbalanced roaming traffic are the 
real focus of bilateral roaming negotiations and subject to competition and one of 
the  main  negotiation  drivers  in  bilateral  roaming  agreements  is  the  amount  of 
inbound and outbound traffic that can be balanced between each pair of operators.  
considerable  difference  between  intra-  and  extra-group  wholesale  prices  and  the 
resulting  advantage  in  providing  RLAH  services  for  group  operators  with 
footprint in several countries. 

Overall, the comparisons of the sources of wholesale roaming prices with the costs estimates 
of  the  cost  model  summarized  in  section  5.9  and  with  domestic  retail  and  wholesale  prices 
analysed  in  section  6.5.4  lead  to  the  same  conclusion:  wholesale  roaming  prices  remain 
appreciably  above  costs.  This  is  a  sign  that  wholesale  roaming  markets  under  current 
regulation  are  not  functioning  well  –  wholesale  roaming  charges  are  not  yet  at  a  level  that 
reflects  underlying  costs.  The  analysis  shows  that  the  gap  between  prices  and  estimated 
underlying costs is likely to be larger for data than for voice.  

119 i.e. (i) BEREC Benchmark report's average wholesale roaming prices in the EU and per EEA country per 
quarter, and their evolution compared to successive caps;  (ii) Autumn 2015 data from operators on their 
individual average wholesale roaming prices collected for the purpose of this wholesale roaming review. These 
data distinguish between average prices for balanced and unbalanced roaming traffic; (iii) Autumn 2015 data on 
operators' effective wholesale roaming prices obtained by dividing wholesale roaming payments by wholesale 
roaming volumes. These data allow distinguishing in particular between intra- and extra-group prices. 

104 

 
 
 
 
 
 
 
 
 
                                                           
The report also shows that a number of market players, in particular smaller operators with 
less  traffic  volumes  and  MVNOs,  do  not  generally  benefit  from  lower  wholesale  roaming 
prices than the caps.  

7.  RLAH IN 2017 

In the public consultation, 70% of mobile operators (including MVNOs) anticipate an effect 
of retail RLAH obligation on the functioning of the wholesale roaming market. However they 
have different and opposite views as to what this effect will be. 

Operators  note  that  RLAH  will  objectively  modify  two  aspects  of  the  bilateral  roaming 
negotiations  between  two  mobile  operators.  First  it  will  increase  wholesale  roaming  traffic 
due  to  increased  retail  roaming  demand.  Second  it  will  limit  one  degree  of  freedom  in  the 
wholesale roaming negotiations, namely a certain capacity of the home (visiting) operator to 
influence,  via  its  retail  roaming  offers,  the  volume  of  traffic  it  will  send  to  the  visited 
operator: since RLAH will (save in exceptional cases) be an obligation of the home operator, 
the latter will have fewer means to restrict or boost the retail roaming demand created by its 
customers on the visited operator's network. As explained in the remainder of this section, the 
overall impact on wholesale roaming prices of these two new features is ambivalent and may 
vary according to the relative situations of the two negotiating operators.  

  RLAH will increase competition on the wholesale roaming markets 

On  the  one  hand,  the  RLAH-triggered  increase  in  roaming  traffic  at  the  wholesale  level  is 
likely  to  reduce  wholesale  roaming  unit  costs  due  to  economies  of  scale.  Since  in  a  given 
national market, a number of wholesale roaming providers are potentially in competition to 
obtain  the  increased  inbound  roaming  traffic  generated  by  RLAH  from  a  given  visiting 
operator,  that  competition  may  drive  wholesale  roaming  prices  downwards  as  unit  costs 
decrease in the country.  

  RLAH will decrease competition on the wholesale roaming markets 

On the other hand, it is also claimed that even if there are several operators to choose from in 
each  national  market,  the  visiting  operator  is  dependent  on  certain  operators  in  the  visited 
country (e.g. for coverage, capacity) and that there are relatively high switching costs for the 
provision of wholesale roaming services, which may limit competition on the visited market 
in  practice.  If  the  visiting  operator  is  small  and  only  brings,  under  RLAH,  small  volumes 
relative  to  those  brought  by  larger  operators,  it  might  find  even  less  competition  in  the 
provision of wholesale roaming services.  

Some operators have also expressed concerns that the visited operator may attempt to recover 
part of the lost revenues on their retail roaming side (as home operators) through wholesale 
roaming  prices.  Therefore  the  willingness  of  visited  operators  to  provide  discounts  may 
decline. This  would imply that RLAH would exert some upward pressure on the wholesale 
roaming prices currently observed in the market.  

In addition, the retail degree of freedom lost by the home operator implies that, for the visited 
operator,  the  RLAH  inbound  roaming  traffic  sent  by  the  home  operator  will  take  place 
whatever  the  wholesale  roaming  price  the  visited  operator  imposes  on  the  home  operator. 
Under RLAH, the home operator may keep a certain capacity to influence the roaming traffic 

105 

 
 
 
 
 
 
volumes  it  sends to  the visited  operator,  but  it  will  lose the  bargaining  power  linked  to  the 
current possibility not to provide RLAH at all. 

  RLAH will have no effect on competition on the wholesale roaming markets 

Under the hypothesis that RLAH would have no effect on competition dynamics in wholesale 
roaming  markets  and  current  wholesale  roaming  prices  obtained  by  the  different  market 
players  could  be  maintained  under  RLAH,  some  stakeholders  argue  that  RLAH  would 
mechanically  increase  the  impact  of  the  wholesale  roaming  prices  discrimination  between 
market players (i.e. large groups vs smaller operators and MVNOs), as the negative impact of 
paying  higher  wholesale  roaming  prices  will  not  be  mitigated  by  retail  roaming 
surcharges/margins and RLAH will increase roaming volumes.  

Finally, as increased roaming volumes under RLAH would contribute to reduce unit costs of 
providing  wholesale  roaming  services,  under  this  hypothesis  of  unchanged  wholesale 
roaming  prices,  the  wholesale  roaming  margins  of  the  wholesale  roaming  provider  would 
increase.  

  Conclusion 

Altogether,  it  seems  that  RLAH  may  intensify  both  the  competitive  and  anti-competitive 
dynamics that may be at work on the wholesale roaming market. Increased roaming volumes 
under RLAH may contribute to strengthen competition for those volumes between wholesale 
roaming  providers  in  the  visited  market.  At  the  same  time,  by  increasing  roaming  volumes 
considerably  and  associating  them  to  certain  obligations  for  the  home  (visiting)  operator, 
RLAH  could  exacerbate  and  aggravate  the  structural  differences  and  imbalances  in  the 
relative  negotiation  positions  of  market  players  in  bilateral  roaming  negotiations  (North  vs 
South,  large  operators  with  footprint  vs  smaller  operators  and  MVNOs).  RLAH  could 
therefore  strengthen  further  the  negotiation  position  of  net  receivers  of  roaming  traffic  and 
weaken that of net senders, potentially allowing net receivers to reduce discount rates on the 
wholesale caps compared to the current situation.  

From  the  above  considerations,  it  is  not  possible  to  anticipate  with  certainty  a  unique  and 
unidirectional  effect  of  the  retail  RLAH  obligation  on  competition  on  wholesale  roaming 
markets.  It  is  simply  uncertain  whether  RLAH  volumes  by  themselves  will  contribute  to  a 
general  decrease of wholesale roaming prices of a magnitude that would reduce the cost  of 
RLAH to an acceptable level, especially for countries where this cost is high in comparison to 
domestic  revenues.  Even  if  the  evolution  of  new  business  models  and  of  negotiation 
dynamics among operators with the establishment of RLAH is not excluded, the risk that the 
negotiation position of the net sender of roaming traffic, including the weaker market players 
on  wholesale  roaming  markets,  would  in  fact  deteriorate  due  to  the  obligation  to  impose 
RLAH cannot be excluded in the absence of countervailing measures. 

8.  CONCLUSIONS  

This  report  provides  an  analysis  of  competition  in  retail  and  wholesale  roaming  markets  in 
the EU, from which the following conclusions can be drawn. 

With  specific  regard  to  the  developments  of  retail  roaming  markets,  the  conclusions  in 
Section  4.7  indicate  that  there  have  been  some  important  developments  recently,  with 
domestic  offers  proposing  more  and  more  affordable  roaming  prices  to  the  customers. 
However,  most  of  the  new,  RLAH-like,  retail  roaming  offers  are  not  RLAH  offers  in  the 

106 

 
 
 
 
 
sense of the Roaming Regulation, i.e. covering the full of the EU for no additional surcharge 
at all (no add-on) within fair-use limits. In addition, some Member States have experienced 
much  less  of  these  developments  than  others.  With  the  current  levels  of  competition  in 
wholesale roaming markets, therefore, the retail markets have not been capable of delivering 
full EU-wide RLAH. 

Regarding the wholesale roaming market in the EU, the report looked at different types of 
information  in  order  to  assess  the  competitive  dynamics  under  current  regulation:  a 
description  of  roaming  traffic  flows  in  the  EU  plus  Norway,  a  description  of  wholesale 
roaming agreements between operators and the different pricing models used, the description 
and  assessment  of  the  functioning  of  wholesale  roaming  markets  by  operators,  different 
sources  of  effective  wholesale  roaming  prices  compared  to  cost  estimates  and  to  domestic 
wholesale and retail prices. 

The analysis shows that, due to a number of identified market failures (oligopolistic character 
of  national  wholesale  markets,  bilateral  nature  of  roaming  agreements,  imperfect  wholesale 
roaming  substitutes,  exclusion  of  MVNOs  from  wholesale  roaming  markets),  wholesale 
roaming  markets  under  current  regulation  continue  to  not  function  correctly  despite  some 
competitive dynamics.  

Overall, the comparisons of the sources of wholesale roaming prices with the costs estimates 
of the cost model and with domestic retail and wholesale prices lead to the same conclusion: 
wholesale  roaming  prices  remain  appreciably  above  costs.  This  is  a  sign  that  wholesale 
roaming markets are not functioning well – wholesale roaming charges are not yet at a level 
that reflects underlying costs. The analysis shows that the gap between prices and estimated 
underlying  costs  is  likely  to  be  larger  for  data  than  for  voice.  The  report  also  shows  that  a 
number  of  market  players,  in  particular  smaller  operators  with  less  traffic  volumes  and 
MVNOs, do not generally benefit from lower wholesale roaming prices than the caps.  

In  June  2017  Regulation  2120/2015  foresees  the  entry  into  force  of  the  RLAH  obligation, 
subject  to  outcome  of  the  review  of  wholesale  roaming  markets,  while  in  the  meantime 
during the transition period the possibility to impose roaming surcharges on top of domestic 
retail  price  equal  to  the  wholesale  roaming  cap  (s.c.  RLAH+)  ensures  full  recovery  of  all 
wholesale  costs  incurred  when  providing  roaming.  The  applicability  of  the  full  RLAH 
regime,  therefore,  depends  on  the  outcomes  of  the  wholesale  roaming  review  and  the 
adoption  by  co-legislators  of  measures  proposed  by  the  Commission  and  considered 
appropriate  in  view  of  the  functioning  of  wholesale  roaming  market  and  the  objective  to 
enable  RLAH  across  the  Union.  In  the  absence  of  adoption  of  these  measures  the  current 
transition regime will continue to apply, entailing on the one hand that a) cost recovery for 
both  the  visited  operator  (since  existing  wholesale  roaming  caps  would  remain  and  they 
ensure cost recovery) as well as for the visiting operator (since the retail roaming surcharge 
will allow to recover any wholesale roaming costs, plus a potential margin in the event of real 
wholesale roaming prices below the cap  level) is ensured but, on the other hand b) that the 
objective laid down in Regulation 2015/2120 (i.e. RLAH) will not be achieved. 

If,  on  the  contrary,  any  measure  proposed  by  the  Commission  as  a  consequence  of  the 
analysis of the wholesale roaming market is adopted, and RLAH enters into force, section 7 
concludes that the future retail RLAH obligation cannot be predicted per se to substantially 
increase competition on wholesale roaming markets and solve the observed market failures. 
The  opposite  situation  cannot  in  fact  be  completely  excluded.  RLAH  may  lead  to  less 

107 

 
 
 
 
 
 
competition  at  wholesale  level,  with  in  particular  a  weaker  position  of  market  players  not 
benefiting from lower prices and of net senders of roaming traffic, compared to the current 
situation. 

In conclusion, further regulation of the wholesale roaming market in the EU is necessary in 
order to enable RLAH in 2017. The accompanying impact assessment seeks to determine the 
best option for doing so. 

108 

 
 
 
 
 
 
 
 
 
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the 
International Telecommunications Society. 

Eurobarometer. (2007). Roaming. Special Eurobarometer no. 269. 

Eurobarometer  (2014),  E-Communications  Household  Survey  and  Telecom  Single  Market 
Survey. Special Eurobarometer no. 414.  

Europe  Economics.  (2008).  Review  of  the  Roaming  Regulation,  Study  for  the  European 
Parliament's 
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(IP/A/IMCO/FWC/2006-186 C). 

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committee 

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Geneva, Switzerland; 24 September 2013. 

110 

 
 
ANNEX 1: Existing 'Roam-Like-At-Home' (RLAH) offers 

Table 13 - RLAH offers per country (add-ons are excluded), September 2015 

Country 

Austria 
Belgium 
Bulgaria 
Czech Republic 
France 
Germany 
Greece 
Hungary 
Luxembourg 
Norway 
Poland 
Portugal 
Romania 
Slovakia 
Slovenia 
Spain 
United Kingdom 

Amount of 
operators that 
offer RLAH 
tariff plans 
2 
3 
1 
1 
6 
2 
1 
2 
4 
1 
3 
1 
1 
3 
2 
2 
2 

Total amount 
of tariff plans 
observed 

15 
12 
16 
1 
43 
10-15 
2 
±5 
58 
4 
16 
±7 
9 
14 
3 
6 
±7 

Source: BEREC report on the wholesale roaming market, BoR(16)33, February 2016 
Data: operators' replies to the autumn 2015 data collection 

111 

 
 
 
 
 
 
ANNEX 2:  Wholesale roaming price paid and received 

Average difference between the effective wholesale roaming unit price for voice and SMS 
paid by the operator to an EEA country and the unit price received from the operator from 
that EEA country (outside group prices) 

Figure 53 - Difference between effective unit prices paid and received (voice - outside group 
traffic) 

Figure 54 - Difference between effective unit prices paid and received (SMS - outside group 
traffic) 

Data: operators' replies to the autumn 2015 data collection 
JRC calculations 

112 

 
 
 
 
 
ANNEX 3:  Roaming traffic flows between countries 

Table 14 - Roaming voice traffic flow between countries in the second semester of 2014120 

Country of 
destination  

Country of origin 
 

a
i
r
t
s
u
A

m
u
i
g
l
e
B

a
i
r
a
g
l
u
B

a
i
t
a
o
r
C

s
u
r
p
y
C

.

R
h
c
e
z
C

k
r
a
m
n
e
D

i

a
n
o
t
s
E

d
n
a
n
i
F

l

e
c
n
a
r
F

y
n
a
m
r
e
G

e
c
e
e
r
G

y
r
a
g
n
u
H

d
n
a
e
c
I

l

d
n
a
e
r
I

l

y
l
a
t
I

a
i
v
t
a
L

i

n
e
t
s
n
e
t
h
c
e
i
L

g
r
u
o
b
m
e
x
u
L

i

a
n
a
u
h
t
i
L

a
t
l
a
M

s
d
n
a
l
r
e
h
t
e
N

y
a
w
r
o
N

d
n
a
o
P

l

l

a
g
u
t
r
o
P

i

a
n
a
m
o
R

a
i
k
a
v
o
l
S

i

a
n
e
v
o
l
S

n
e
d
e
w
S

i

n
a
p
S

K
U

Austria 
Belgium 
Bulgaria 
Croatia 
Cyprus 
Czech Rep. 
Denmark 
Estonia 
Finland 
France 
Germany 
Greece 
Hungary 
Iceland 
Ireland 
Italy 
Latvia 
Liechtenstein 
Lithuania 
Luxembourg 
Malta 
Netherlands 
Norway 

0,0% 

0,9%  0,7% 

4,9%  0,1% 

3,0% 

0,5% 

0,1%  0,3% 

3,0%  36,9% 

2,0%  6,4%  0,0% 

0,5%  18,5%  0,1%  0,7%  0,1%  0,1%  0,2% 

2,0% 

0,4%  2,3% 

0,5%  1,9% 

2,3%  2,3% 

4,1% 

1,1% 

3,9% 

2,1% 

0,0%  0,6% 

0,4%  0,1% 

0,5% 

0,5% 

0,1%  0,2%  34,1% 

9,2% 

1,6%  0,6%  0,1% 

0,3% 

6,4%  0,1%  0,0%  0,1%  4,4%  0,1%  17,6% 

0,3%  1,5% 

1,9%  0,8% 

0,2%  0,1%  11,5% 

0,7% 

3,8% 

6,1% 

4,2%  0,0% 

1,2%  0,6% 

2,0% 

1,2% 

0,1%  0,3% 

9,8%  19,6%  16,1%  2,9%  0,1% 

0,2% 

9,2%  0,1%  0,0%  0,1%  0,3%  0,4% 

2,9% 

0,5%  1,3% 

0,4%  5,4% 

0,6%  0,8% 

5,8% 

1,0% 

6,9% 

3,4% 

2,7%  0,5% 

0,0%  0,5% 

1,0% 

6,0% 

1,4%  7,8% 

6,4%  13,3% 

2,8%  1,3%  0,2% 

0,6% 

6,2%  2,5%  0,0%  1,9%  0,2%  0,3% 

2,4% 

7,2%  4,9% 

1,0%  0,5% 

0,3%  2,8%  12,5% 

3,2% 

6,1% 

0,0% 

0,0%  0,0% 

0,0%  0,0% 

0,0% 

0,0% 

0,0%  0,0% 

0,0% 

0,0% 

0,0%  0,0%  0,0% 

0,0% 

0,0%  0,0%  0,0%  0,0%  0,0%  0,0% 

0,0% 

0,0%  0,0% 

0,0%  0,0% 

0,0%  0,0% 

0,0% 

0,0% 

0,0% 

10,0% 

2,4%  1,2% 

4,7%  0,2% 

0,0% 

0,6% 

0,1%  0,2% 

5,9%  29,5% 

2,3%  2,5%  0,1% 

0,2% 

7,5%  0,1%  0,0%  0,1%  0,2%  0,1% 

2,6% 

0,6%  4,8% 

0,4%  0,9%  14,3%  0,6% 

3,6% 

0,9% 

3,5% 

2,7% 

1,3%  0,3% 

0,4%  0,2% 

0,7% 

0,0% 

0,2%  1,3% 

6,0%  18,0% 

1,5%  0,5%  0,5% 

0,6% 

4,7%  0,3%  0,0%  0,3%  0,1%  0,2% 

2,7% 

9,2%  2,1% 

0,8%  0,4% 

0,1%  0,1% 

7,9%  30,0% 

7,1% 

0,0% 

0,0%  0,0% 

0,0%  0,0% 

0,0% 

0,0% 

0,0%  0,0% 

0,0% 

0,0% 

0,0%  0,0%  0,0% 

0,0% 

0,0%  0,0%  0,0%  0,0%  0,0%  0,0% 

0,0% 

0,0%  0,0% 

0,0%  0,0% 

0,0%  0,0% 

0,0% 

0,0% 

0,0% 

1,6% 

1,9%  0,5% 

0,7%  0,3% 

1,0% 

2,6%  15,3%  0,0% 

4,5%  10,0% 

3,0%  1,1%  0,2% 

0,4% 

4,1%  1,0%  0,0%  0,6%  0,2%  0,3% 

2,4% 

3,3%  1,8% 

1,5%  0,2% 

0,2%  0,2%  16,9%  19,5% 

4,8% 

1,0%  14,8%  0,4% 

0,6%  0,1% 

0,9% 

0,6% 

0,1%  0,3% 

0,0%  10,2% 

2,2%  0,5%  0,1% 

1,0%  12,7%  0,1%  0,0%  0,2%  4,0%  0,3% 

3,5% 

0,5%  2,2% 

9,1%  1,8% 

0,2%  0,1%  20,1% 

1,0%  11,2% 

0,0% 

0,0%  0,0% 

0,0%  0,0% 

0,0% 

0,0% 

0,0%  0,0% 

0,0% 

0,0% 

0,0%  0,0%  0,0% 

0,0% 

0,0%  0,0%  0,0%  0,0%  0,0%  0,0% 

0,0% 

0,0%  0,0% 

0,0%  0,0% 

0,0%  0,0% 

0,0% 

0,0% 

0,0% 

2,7% 

3,5%  8,9% 

0,7%  6,5% 

1,1% 

0,9% 

0,1%  0,4% 

9,0%  15,7% 

0,0%  1,2%  0,3% 

0,3%  16,6%  0,1%  0,1%  0,1%  0,3%  0,5% 

4,0% 

0,6%  1,6% 

0,9%  3,6% 

0,5%  0,3% 

5,1% 

1,0%  13,6% 

22,2% 

2,6%  0,5% 

2,7%  0,2% 

3,0% 

0,6% 

0,0%  0,2% 

5,7%  28,4% 

1,8%  0,0%  0,3% 

0,0% 

7,7%  0,1%  0,0%  0,1%  0,2%  0,2% 

2,9% 

0,5%  1,8% 

0,2%  4,4% 

3,5%  1,7% 

2,8% 

1,1% 

4,8% 

0,0% 

0,0%  0,0% 

0,0%  0,0% 

0,0% 

0,0% 

0,0%  0,0% 

0,0% 

0,0% 

0,0%  0,0%  0,0% 

0,0% 

0,0%  0,0%  0,0%  0,0%  0,0%  0,0% 

0,0% 

0,0%  0,0% 

0,0%  0,0% 

0,0%  0,0% 

0,0% 

0,0% 

0,0% 

0,7% 

1,2%  0,3% 

0,2%  0,1% 

0,6% 

0,5% 

0,1%  0,2% 

5,4% 

4,2% 

0,5%  0,5%  0,0% 

0,0% 

3,0%  0,3%  0,0%  0,5%  0,1%  0,3% 

1,7% 

0,3%  2,1% 

3,3%  0,3% 

0,3%  0,0%  19,6% 

0,6%  53,1% 

4,7% 

3,1%  0,8% 

2,6%  0,1% 

1,4% 

0,7% 

0,1%  0,3%  22,4%  14,9% 

4,4%  1,4%  0,1% 

0,9% 

0,0%  0,1%  0,0%  0,2%  0,4%  1,4% 

2,7% 

0,5%  2,2% 

1,3%  4,6% 

0,4%  1,6%  13,9% 

0,8%  12,0% 

2,1% 

2,9%  0,5% 

1,1%  0,5% 

0,9% 

6,8% 

1,6%  9,0% 

6,8%  12,5% 

3,1%  0,9%  0,2% 

0,6% 

4,9%  0,0%  0,0%  2,2%  0,2%  0,3% 

2,5% 

8,2%  5,5% 

1,1%  0,4% 

0,2%  0,7%  14,1% 

3,6% 

6,6% 

0,0% 

0,0%  0,0% 

0,0%  0,0% 

0,0% 

0,0% 

0,0%  0,0% 

0,0% 

0,0% 

0,0%  0,0%  0,0% 

0,0% 

0,0%  0,0%  0,0%  0,0%  0,0%  0,0% 

0,0% 

0,0%  0,0% 

0,0%  0,0% 

0,0%  0,0% 

0,0% 

0,0% 

0,0% 

2,1% 

2,9%  0,5% 

1,1%  0,5% 

0,9% 

6,8% 

1,5%  8,9% 

6,7%  12,4% 

3,1%  0,9%  0,2% 

0,6% 

4,8%  2,8%  0,0%  0,0%  0,2%  0,3% 

2,4% 

8,2%  5,5% 

1,1%  0,4% 

0,2%  0,7%  14,0% 

3,6% 

6,6% 

2,0% 

3,8%  0,3% 

0,4%  0,1% 

0,6% 

0,5% 

0,1%  0,3%  35,0%  10,4% 

1,6%  0,6%  0,1% 

0,4% 

6,6%  0,1%  0,0%  0,1%  0,0%  0,1%  16,0% 

0,4%  1,3% 

2,5%  0,5% 

0,2%  0,1%  11,3% 

0,7% 

4,0% 

2,1% 

2,7%  0,8% 

0,6%  1,0% 

0,8% 

0,6% 

0,1%  0,3% 

6,3% 

9,4% 

2,0%  1,0%  1,2% 

0,3%  33,4%  0,3%  0,0%  0,2%  0,3%  0,0% 

2,9% 

0,6%  0,9% 

0,8%  0,9% 

0,3%  0,4% 

5,8% 

2,0%  22,2% 

3,2%  18,2%  0,5% 

0,6%  0,1% 

0,7% 

1,9% 

0,2%  1,3%  11,7%  24,9% 

1,6%  0,8%  0,2% 

0,7% 

6,3%  0,4%  0,0%  0,4%  0,5%  0,1% 

0,0% 

1,8%  2,5% 

1,5%  0,9% 

0,2%  0,2% 

8,7% 

1,9% 

8,3% 

1,0% 

0,9%  0,7% 

1,3%  0,6% 

0,5%  10,2% 

0,5%  1,9% 

4,5% 

5,7% 

3,4%  0,6%  0,4% 

0,7% 

3,3%  0,6%  0,0%  0,7%  0,0%  0,2% 

2,7% 

0,0%  3,1% 

1,0%  0,3% 

0,1%  0,1%  20,7%  25,9% 

8,4% 

120 The value is in green when the share of roaming voice traffic from the roamers is between 5% and 25%.The value is in red when the share is over 25%. 

113 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                           
Poland 
Portugal 
Romania 
Slovakia 
Slovenia 
Spain 
Sweden 
UK 

3,7% 

4,4%  0,7% 

1,6%  0,1% 

3,1% 

1,7% 

0,2%  0,5% 

8,0%  37,5% 

1,8%  1,3%  0,1% 

0,6% 

6,2%  0,3%  0,0%  0,8%  0,2%  0,1% 

6,0% 

3,5%  0,0% 

0,5%  0,6% 

2,0%  0,3% 

3,5% 

3,2% 

7,4% 

0,7% 

4,3%  0,2% 

0,2%  0,0% 

0,5% 

0,5% 

0,1%  0,2%  30,9% 

7,6% 

0,4%  0,3%  0,0% 

0,6% 

3,8%  0,1%  0,0%  0,1%  1,6%  0,1% 

2,7% 

0,5%  0,7% 

0,0%  0,5% 

0,1%  0,1%  34,1% 

0,5% 

8,5% 

7,1% 

4,6%  3,1% 

0,4%  0,3% 

1,4% 

1,0% 

0,0%  0,1%  10,5%  20,0% 

4,0%  6,7%  0,1% 

0,1%  11,7%  0,0%  0,0%  0,0%  0,4%  0,1% 

2,9% 

0,5%  1,1% 

0,4%  0,0% 

0,5%  1,0% 

4,4% 

1,4%  15,6% 

16,8% 

2,0%  0,6% 

3,0%  0,1%  32,6% 

0,4% 

0,0%  0,2% 

3,6%  16,9% 

0,7%  6,9%  0,0% 

0,3% 

4,7%  0,0%  0,0%  0,0%  0,1%  0,1% 

1,7% 

0,5%  2,7% 

0,1%  0,5% 

0,0%  0,5% 

1,5% 

0,5% 

3,0% 

20,0% 

1,5%  0,3%  34,9%  0,0% 

1,3% 

0,3% 

0,1%  0,1% 

2,9%  14,4% 

0,8%  1,6%  0,1% 

0,0%  13,6%  0,0%  0,0%  0,0%  0,2%  0,1% 

1,3% 

0,1%  0,6% 

0,3%  0,3% 

0,8%  0,0% 

1,9% 

0,5% 

1,7% 

1,2% 

3,6%  0,5% 

0,3%  0,1% 

0,8% 

0,6% 

0,1%  0,4%  31,6%  12,4% 

0,8%  0,6%  0,1% 

1,6%  11,7%  0,1%  0,0%  0,1%  0,3%  0,3% 

3,2% 

0,7%  1,5%  12,1%  1,8% 

0,2%  0,2% 

0,0% 

0,9%  12,5% 

2,0% 

2,1%  0,4% 

0,9%  0,6% 

0,9%  15,9% 

1,0%  6,8% 

6,1% 

9,9% 

2,6%  0,8%  0,3% 

0,5% 

4,7%  1,5%  0,0%  1,2%  0,2%  0,3% 

2,3%  13,3%  3,8% 

1,1%  0,3% 

0,2%  0,4%  13,8% 

0,0% 

6,4% 

1,8% 

2,7%  0,6% 

0,5%  1,3% 

0,8% 

1,4% 

0,1%  0,6%  17,7% 

8,3% 

2,9%  0,8%  3,2%  10,1% 

8,8%  0,2%  0,0%  0,3%  0,4%  0,6% 

4,6% 

1,5%  2,1% 

3,5%  0,8% 

0,2%  0,1%  21,7% 

2,0% 

0,0% 

Source: BEREC Report on wholesale roaming market, BoR(16)33, February 2016 
Data: operators' replies to the autumn 2015 data collection 

114