REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the implementation of Regulation (EU) 531/2012 of the European Parliament and of the Council of 13 June 2012 on roaming on public mobile communications networks within the Union, as amended by Regulation (EU) 2015/2120 and Regulation (EU) 2017/920
Date: 2018-12-12
Institutions: Directorate-General for Communications Networks, Content and Technology, European Commission
Subjects: EU Member State, European Economic Area, consumer protection, mobile phone, price regulations, regulation of telecommunications, roaming, single market, telephone charges, wholesale price

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 12.12.2018 COM(2018) 822 final  REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the implementation of Regulation (EU) 531/2012 of the European Parliament and of the Council of 13 June  2012 on roaming on public mobile communications networks within the Union, as amended by Regulation (EU) 2015/2120 and Regulation (EU) 2017/920  
 
 
1 

INTRODUCTION  

In  October  2015,  the  European  Parliament  and  the  Council  adopted  Regulation  (EU) 
2015/21201  which  mandated  the  end  of  retail  roaming  charges  in  the  Union  from  15  June 
2017, subject to fair use policy and a sustainability derogation. These new roaming rules have 
been dubbed "Roam-Like-At-Home" (RLAH). 

For  RLAH  to  be  provided  in  a  sustainable  manner  throughout  the  Union,  the  co-legislators 
have agreed to have in place the following measures: 

  substantially reduced wholesale roaming price caps2; 
 

the possibility for operators to apply a fair use policy to prevent abusive or anomalous 
use of roaming services at domestic prices, such as the permanent use of a SIM card in 
other Member States than the Member State of that SIM card; 

  an  exceptional  and  temporary  derogation  system  for  operators  to  be  used  only  if 
authorised  by  the  national  regulator,  under  strict  circumstances  when  the  end  of 
roaming  charges  in  a  specific  market  could  lead  to  domestic  price  increases  for  the 
customers of the operator. 

In  accordance with  the  mandate  given by the  co-legislators, the Commission  adopted on 15 
December 2016 detailed rules on the application of fair use policy and on the methodology to 
be used for submitting and assessing a request for a sustainability derogation3. 

The above set of rules has been applicable in the EU/EEA since 15 June 2017. 

In accordance with Article 19 (3) of the Roaming Regulation4 the Commission has to submit 
to the co-legislators by 15 December 2018 "an interim report summarising the effects of the 
abolition of retail roaming charges"5. This is the purpose of this report.6 

1 Regulation (EU) 2015/2120 of the European Parliament and of the Council of 25 November 2015 laying down 
measures concerning open  internet access and amending  Directive 2002/22/EC on universal service  and users' 
rights relating to electronic communications networks and services and Regulation (EU) 531/2012 on roaming 
on public mobile communications networks within the Union.   
2  Regulation  (EU) 2017/920  of  the  European Parliament  and  of  the  Council  of  17 May  2017  amending 
Regulation (EU) No 531/2012 as regards rules for wholesale roaming markets. 
3 Commission Implementing Regulation (EU) 2016/2286 of 15 December 2016 laying down detailed rules on the 
application of  fair  use policy  and on the  methodology for  assessing the sustainability of the abolition of retail 
roaming  surcharges  and  on  the  application  to  be  submitted  by  a  roaming  provider  for  the  purposes  of  that 
assessment 
4  In  this  report,  Regulation  (EU)  531/2012  as  amended  by  Regulation  (EU)  2015/2120  and  Regulation 
(EU) 2017/920 is called the "Roaming Regulation". 
5 Article 19(3) in Regulation (EU) No 531/2012 as amended by Regulation (EU) 2017/920. 
6  In  advance  of  this  mandated  Commission  interim  Report,  the  European  Parliament  published  an  analysis 
entitled "Roaming: One Year After Implementation", November 2018. 

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2  THE ROAMING REGULATION’S SCOPE AND MAIN PROVISIONS  

Roaming in the meaning of the Roaming Regulation is a service that allows a customer of a 
Mobile  (Virtual)  Network  Operator  (M(V)NO)  in  one  country,  to  have  access  to  mobile 
services  (voice,  SMS  or  data)  from  an  MNO  in  another  country7.  The  service  provider  (the 
mobile  operator)  ensures  that  its  customers  remain  connected  to  a  mobile  network  when 
travelling abroad while using the same mobile handset (or possibly laptop or tablet in case of 
data roaming) and the same phone number. The service provider that wants to offer roaming 
services  to  its  customers  ("retail  roaming  services")  in  a  country  has  to  buy  them  from  an 
MNO located in the visited country ("wholesale roaming services"). To this end, commercial 
wholesale roaming agreements between service providers have to be concluded. In practice, 
when  a  customer  places  a  call  or  uses  mobile  data  while  roaming  abroad,  that  service  is 
provided by a mobile operator in the visited country. The roaming customer’s home operator 
has to pay the visited operator for that service. This is called wholesale roaming charges. The 
level of those charges is capped by the EU Roaming Regulation and annually decreasing for 
data (see below). 

Since 15 June 2017 mobile operators have not been allowed to levy any charges in addition to 
the  domestic  price  for  the  provision  of  roaming  services  (voice,  SMS  and  data)  to  their 
customers  when  they  periodically  travel  in  the  EU/EEA.  In  order  to  prevent  abusive  or 
anomalous use of roaming services - such as permanent roaming - at domestic prices that may 
have  detrimental  effects  on  the  domestic  markets,  mobile  operators  may  apply  a  fair  use 
policy.  

Fair  use  policy  is  to  prevent  abusive  or  anomalous  usage  of  roaming  services  at  domestic 
price.  It  aims  in  particular  at  ensuring  that  roaming  at  domestic  price  is  used  when 
periodically travelling in the EU/EEA. For this purpose, an operator may ask its customers for 
a proof of residence in, or stable link with, the EU/EEA country where they buy the SIM card 
to be used at domestic price when travelling abroad. An operator may also check that the SIM 
card is used more in its country than abroad. If, during a time window of at least four months, 
the customer has been more abroad in the EU than at home and has consumed mobile services 
more abroad in the EU than at home, the operator may contact the customer to verify it. After 
an  alert  period  of  14  days  from  the  date  of  contact,  the  operator  may  apply  small  roaming 
surcharges  linked  to  the  wholesale  price  caps  if  the  customer  continues  to  consume  mobile 
services abroad. In addition, in order to allow for the continuous development of the best data 
offers on domestic markets (e.g. unlimited data), an operator may apply a volume safeguard 
on roaming data consumed at domestic prices. Beyond that volume, the operator may apply a 
small roaming surcharge not exceeding the wholesale roaming price cap. 

7 A roaming service can be provided domestically (national roaming), i.e. a mobile operator uses the network of 
another  operator  to  provide  mobile  services  to  its  customers  domestically.  However,  national  roaming  is  not 
within the scope of the Roaming Regulation. The latter only regulates international roaming in the EU/EEA, i.e. 
roaming on a foreign network within the EU/EEA. 

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In  exceptional  and  specific  circumstances,  in  order  to  avoid  a  domestic  price  increase,  an 
operator  may  obtain  from  its  national  regulatory  authority  (NRA)  a  so-called  sustainability 
derogation. For this purpose, the operator must demonstrate to the NRA that the provision of 
roaming  services  without  the  application  of  a  surcharge  would  not  be  sustainable  with  its 
current domestic charging model. In that case the NRA may authorise the operator to apply a 
small roaming surcharge for one year. In order to prolong such an authorisation the operator 
must renew its application yearly. 

At wholesale level,  the  price  caps have been substantially reduced in  2017 by  the Roaming 
Regulation8, in particular for data whose price caps are programmed to further decline every 
year until 2022, in order to ensure that market players can benefit from  wholesale rates that 
allow for the provision of roaming services to their customers without levying any charge on 
top of the domestic price. The wholesale roaming price caps also ensure that wholesale costs 
are fully recovered by the operator providing the wholesale roaming service. 

3  RLAH IMPLEMENTATION: OVERALL COMPLIANCE  

The Roaming Regulation is directly applicable in all EU Member States and EEA countries9. 
It entrusts NRAs with the task of monitoring, supervising and enforcing the roaming rules in 
Member States. In order to ensure a consistent approach of all NRAs, the Body of European 
Regulators  in  Electronic  Communications  (BEREC)  issued  Retail  Roaming  Guidelines10  in 
March  2017  and  Wholesale  Roaming  Guidelines11  in  June  2017,  prepared  in  close 
collaboration  with  the  Commission  and  after  consulting  stakeholders.  While  not  binding  in 
themselves,  BEREC  Guidelines  support  the  NRAs  in  the  monitoring,  supervision  and 
enforcement of the new roaming rules in practice. BEREC Guidelines also serve as detailed 
guidance  for  mobile  operators  on  how  to  implement  the  new  roaming  rules  in  their  various 
offers. 

Responding to the call by the Commission to ensure a proper implementation of RLAH rules 
from the first day (15 June 2017), each NRA actively reached out to its mobile operators in 
the course of the  first  semester 2017 in order to  ensure  full  compliance  with  the new rules. 
NRAs  and  the  Commission  remained  in  close  contact  throughout  the  period  in  order  to 
respond  to  practical  implementation  questions  from  mobile  operators  ahead  of  the 
implementation date.  

8 In 2018, the following wholesale roaming price caps have been applicable: 0.032 € /minute for calls made, 0.01 
€/sms, 6 €/GB. From 1 January 2019, the new cap for data will be 4.5 €/GB and 3.5 €/GB as of 1 January 2020. 
It will then decrease to 3 €/GB in 2021 and 2.5 €/GB in 2022. In comparison, those caps were 0.05 €/minute, 
0.02 €/sms and 50 €/GB until 15 June 2017. 
9 Norway, Iceland, Liechtenstein. 
10  BEREC  Guidelines  on  Regulation  (EU)  No  531/2012,  as  amended  by  Regulation  (EU)  2015/2120  and  by 
Regulation (EU) 2017/920 (Retail  Roaming Guidelines), BoR(17)56, available here. 
11  BEREC  Guidelines  on  Regulation  (EU)  No  531/2012,  as  amended  by  Regulation  (EU)  2015/2120  and  by 
Regulation (EU) 2017/920 (Wholesale Roaming Guidelines), BoR(17)114, available here. 

3 

 
 
                                                 
As  a  result  of  this  preparatory  work,  general  compliance  of  mobile  operators  with  the  new 
roaming rules has been observed. Where a potential breach of the rules had been detected in a 
Member  State,  the  NRA  swiftly  solved  the  issue  with  the  operator  concerned,  often  before 
starting any  formal proceedings or in  the course of such proceedings.  In a few  cases12  fines 
had to be imposed. As required by the Roaming Regulation, the NRAs have to be conferred in 
all  Member  States  with  the  appropriate  sanctioning  powers  in  case  of  non-compliance  with 
roaming rules. Where, after 15 June 2017, new implementation questions arose in relation to 
new types of offers which were not specifically addressed in the BEREC Guidelines, NRAs 
have  coordinated  their  approach  in  collaboration  with  the  Commission  via  the  dedicated 
BEREC International Roaming Expert Working Group13.  

Sustainability derogations have been granted by NRAs to operators that were expected to be 
likely  candidates  for  the  derogation  due  to  their  particular  situation,  i.e.  some  MVNOs  in 
some Member States and some MNOs in some of the very low-data-price Member States with 
high roaming imbalances and/or low revenue per user (Estonia, Lithuania, Poland, Finland). 
Despite  the  derogation,  many  MNOs  and  MVNOs  still  offer  large  volumes  of  roaming 
services  without  surcharges  to  their  subscribers  in  order  to  remain  competitive  on  their 
domestic  market.  Where  they  apply  the  allowed  roaming  surcharge,  the  latter  is  drastically 
reduced compared to before 15 June 2017 (by more than 90% for data), so that the concerned 
customers do substantially benefit from the new rules even in such cases (see section 4). In all 
cases, the surcharges authorised by the NRA and applied by the operator are below, and often 
well  below,  the  wholesale  roaming  price  cap,  in  accordance  with  the  rule  whereby  any 
surcharge  should  be  applied  only  to  the  extent  necessary  to  recover  the  costs  of  providing 
regulated retail roaming services which could otherwise provoke a domestic price increase.  

4  EFFECTS OF RLAH ON END-USERS  

While  successive  Roaming  Regulations  since  2007  had  brought  tangible  benefits  to 
consumers in  the form  of price reductions for voice, SMS and data roaming services, many 
Europeans continued to avoid, or curtail, usage of their mobile phones and data services when 
travelling  outside  of  their  home  Member  State  in  order  to  avoid  incurring  mobile  roaming 
charges.  In  2014,  more  than  half  of  Europeans  switched  off  their  data  roaming  capability 
while travelling in the EU, and only one in ten Europeans made or received calls as often as in 
their country14. The RLAH rules have finally allowed to radically change that situation and to 
unleash the untapped demand for mobile consumption among travellers in the EU.  

12  As  of  June  2018,  in  five  cases  fines  were  imposed  on  mobile  operators  by  NRAs  for  non-compliance  with 
RLAH rules, according to responses to the Commission's survey of NRAs, June 2018. 
13  For  instance  on  how  to  treat  new  zero-rated  services  under  RLAH,  e.g.  decisions  by  BNetzA  (Germany), 
ANACOM (Portugal) 
14Special  Eurobarometer  414,  E-communications  and  telecom  single  market  household  survey,  March  2014, 
http://ec.europa.eu/commfrontoffice/publicopinion/archives/ebs/ebs_414_en.pdf 

4 

 
 
                                                 
In sections 4.1, 4.2 and 4.3 below the figures quoted are from the latest BEREC International 
Roaming (IR) Benchmark Reports15. 

4.1  RLAH triggered a massive and rapid increase in roaming consumption  

European  consumers  have  immediately  and  massively  started  to  take  advantage  of  the 
elimination of roaming charges in the EU/EEA from 15 June 2017. Already in summer 2017, 
the  use  of  mobile  data  services  while  roaming  in  the  EU/EEA  was  multiplied  by  5.35 
(+435%)  compared  to  summer  2016,  and  the  volume  of  roaming  phone  calls  by  2.45 
(+145%). In the next two quarters (Q4 2017 and Q1 2018), the use of roaming data remained 
almost  5  times  above  its  level  one  year  before  (Figure  1).  In  those  two  quarters,  the  total 
volume  of  roaming  voice  calls  has  remained  almost  twice  as  high  as  prior  to  RLAH.  As 
concluded  by  BEREC  in  the  21st  Benchmark  IR  Report,  these  figures  clearly  show  that  the 
RLAH rules have significantly contributed to stimulate the demand for roaming services and 
the development of the international roaming market in the EU/EEA. 

Figure 1: EEA retail roaming data traffic, Q2 2016 – Q1 2018 (millions of GB) 

Source: Based on 21st International Roaming BEREC Benchmark Report, October 2017- March 2018 

Travellers  now  use  on  average  almost  4  times  more  data  while  roaming  than  before  RLAH 
(see Figure 2)16. They also call on average about  1.7 times more while roaming than before 
the implementation of RLAH17. 

15 20th International Roaming BEREC Benchmark Data Report, April 2017  - September 2017, published on 14 
March 2018, BoR(18)31, available here; 21st International Roaming BEREC Benchmark Report, October 2017- 
March 2018, published on 10 October 2018, BoR(18)160, available here. 
16 The increase in total roaming data volumes in the EEA results from larger average consumption by roaming 
customers but also from more travellers switching on data roaming. 
17 The increase in total roaming voice volumes in the EEA results from larger average consumption by roaming 
customers but also from more travellers switching on voice roaming. 

5 

7,0715,7812,5614,1433,9684,3761,8570,340102030405060708090Q2 '16Q3 '16Q4 '16Q1 '17Q2 '17Q3 '17Q4 '17Q1 '18million GBRLAH 
 
 
 
                                                 
Figure  2:  EEA  average  data  roaming  consumption  per  month  per  roaming  subscriber 
(in MB), Q2 2016 – Q1 2018 

RLAH 
242,53 

259,22 

218,93 

300

250

200

B
M

150

100

50

0

108,58 

62,41  58,54 

68,2 

39,94 

Q2 '16 Q3 '16 Q4 '16 Q1 '17 Q2 '17 Q3 '17 Q4 '17 Q1 '18

Source: Based on 21st International Roaming BEREC Benchmark Report, October 2017-March 2018 

All  Member  States  have  experienced  a  considerable  increase  in  roaming  consumption  by 
subscribers  since  June  2017.  Particularly  high  increases  in  customers'  EU/EEA  roaming 
consumption  have  been  observed  by  Polish,  Romanian,  Bulgarian,  Croatian  and  Spanish 
operators  for  voice  (increases  by  more  than  3  times),  and  by  Bulgarian,  Croatian,  Czech, 
Polish, Spanish, and Latvian operators for data (increases by about 10 times and more)18. 

In  the  three  Member  States  where  all  MNOs  have  been  granted  sustainability  derogations 
since 15 June 2017 (Finland, Lithuania and Estonia19, see section 3), users have also markedly 
increased their consumption of mobile services abroad in the EU/EEA in proportions that are 
similar  to  many  other  Member  States.  This  is  because  operators  which  were  granted 
derogations nonetheless provided roaming services without surcharges to some extent (section 
4.2)  and,  when  applied,  the  roaming  surcharges  authorised  by  the  NRA  were  substantially 
lower  than  the  surcharges  in  place  prior  to  15  June  2017.  Therefore  customers  of  these 
operators have substantially benefitted from the new roaming rules as well and have reacted 
accordingly with increased demand.  

4.2  RLAH is widely available in the EU/EEA 

Already  in  summer  2017,  virtually  all  Europeans  could  avail  of  a  mobile  subscription 
providing  RLAH  services:  1.8%  of  the  EU/EEA  subscribers  were  subject  to  a  roaming 

18 Comparing Q1 2018 and Q4 2017 to Q1 2017 and Q4 2016 respectively. See Figures 30-31 and 71-72 in 21st 
International Roaming BEREC Benchmark Report, October 2017-March 2018. 
19  In  Poland,  three  MNOs  were  granted  the  derogation  in  the  course  of  the  first  semester  2018.  The  effect  of 
these derogations is not yet visible in Q1 2018 data. 

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surcharge  due  to  a  derogation  granted  by  the  national  regulator,  and  1.6%  for  not  being 
resident in, or having no stable links with, the country of the operator. All other subscribers 
benefitted  from  RLAH  or  deliberately  chose  an  alternative  roaming  tariff  in  order  to  meet 
their particular roaming needs in non-EU countries.   

As a result, in Q1 2018 RLAH accounted for more than 90% of the voice and data roaming 
traffic  by  EU/EEA  subscribers  travelling  in  the  EU/EEA20.  Even  in  Finland,  Lithuania  and 
Estonia,  where  all  MNOs  had  the  right  to  derogate  from  RLAH  from  15  June  2017,  those 
MNOs  actually  provided  large  volumes  of  roaming  services  without  surcharges  (to  a  lesser 
extent  in  Lithuania).  As  a  result,  the  vast  majority  of  the  roaming  traffic  by  Finnish  and 
Estonian subscribers does benefit from RLAH21. 

4.3  Overall,  domestic-only  mobile  offers  are  limited  and  mostly  in  the  pre-paid 

segment of the market 

According  to  the  most  recent  BEREC  IR  Benchmark  Reports22,  the  proportion  of  EU/EEA 
subscribers  that  had  a  roaming-enabled  SIM  card  has  remained  stable  around  96%  since 
summer  2017.  SIM  cards  restricted  to  domestic  use  (i.e.  SIM  cards  providing  no  roaming 
service  abroad  at  all)  are  in  most  cases  pre-paid  cards  serving  local  communication  needs 
and/or  data-only  plans  or  fixed  wireless  access  products  that  can  only  be  used  at  a  specific 
location23. Domestic-only tariff plans have therefore remained marginal, except in Romania, 
Estonia, Latvia and Bulgaria where more than 10% of the users have taken up domestic-only 
offers. This proportion has been declining in Bulgaria and Latvia since summer 2017 but has 
substantially  increased  in  Romania24.  Austria  is  the  only  other  Member  State,  in  which  the 
share  of  domestic-only  subscribers  has  substantially  increased  (from  4%  to  9%  between 
summer  2017  and  the  first  quarter  2018,  mainly  MVNO  subscribers).  In  general,  MVNOs 
have a higher share (and sometimes a significantly higher share) of domestic-only subscribers 
than  MNOs,  which  is  likely  to  be  attributable  in  part  to  the  customer  segments  that  they 
typically  target.  In  all  EU/EEA  countries  however,  the  proportion  of  domestic-only  mobile 
subscribers remains well below the proportion of the population that has not travelled abroad 
over the last year. The Commission will monitor the evolution of domestic-only tariff plans as 
the wholesale roaming data price cap continues to decline.    

20 The majority of the rest of the EU/EEA roaming traffic is made under alternative roaming tariffs deliberately 
chosen by consumers. It is noticeable that the proportion of the latter has decreased substantially compared to the 
pre-RLAH period (by a factor 2.5 for voice and almost 2 for data), a sign that the new default regime (RLAH) 
meets the roaming needs of Europeans who need less to resort to alternative roaming tariffs than before. 
21  See  Figures  25-26  (voice)  and  66-67  (data)  in  the  21st  International  Roaming  BEREC  Benchmark  Report, 
October 2017 – March 2018. In addition, when applied under the derogation, the surcharges are much lower than 
surcharges before RLAH, a reduction by more than 90% for data in 2018 compared to May 2017. 
22 20th and 21st International Roaming BEREC Benchmark Data Report, covering April 2017 – March 2018. 
23 BEREC Report on Transparency and Comparability of International Roaming Tariffs, December 2018. Only 
17% of operators declared having removed roaming services from some specific tariff plans. 
24 The share of domestic-only subscribers in Estonia in Q3 2017 provided in the 20th BEREC Benchmark Report 
is incorrect due to problems with the underlying data. Therefore, for Estonia, it is not possible to compare with 
Q3 2017. 

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4.4  Consumer satisfaction is high  

In  2017,  the  Commission,  the  European  Parliament  and  national  partners  (e.g.  NRAs, 
consumer  associations)  mobilised  important  resources  and  channels  to  appropriately  inform 
European citizens about their new rights as regards roaming when they travel in the EU/EEA. 
The  RLAH  reform  is  widely  recognised  and  appreciated  by  Europeans.  One  year  after  the 
introduction of RLAH, a Eurobarometer survey showed that 62 % of Europeans were aware 
that  roaming  charges  had  ended  in  the  EU/EEA  and  69%  thought  they,  or  someone  they 
know,  benefit  or  will  benefit.  Awareness  of  the  new  rules  rises  to  81%  amongst  those  who 
had travelled during the preceding 12 months25. In Finland, Lithuania and Estonia where all 
MNOs have been granted sustainability derogations since 15 June 2017, the derogation, used 
with some parsimony by operators, did not alter the recognition by consumers of the benefits 
of the reform, which is even above the EU average in those countries. 

The survey also shows a marked change in behaviour while roaming since RLAH rules are in 
place.  Since  June  2017,  travellers  are  less  likely  to  make  a  restrictive  use  of  their  mobile 
phone abroad in the EU (53%) than before 15 June 2017 (66%). The share of travellers who 
considered  that  they  used  their  mobile  data  while  roaming  as  often  as  at  home  increased  to 
34%  compared  to  15%  before  15  June  2017.  In  contrast,  the  share  of  travellers  who  never 
used mobile data abroad dropped to 19% compared to 42% before 15 June 2017 (and 52% in 
2014). As regards calls made, the share of travellers who used their mobile phone for calling 
while roaming as often as at home increased to 26% compared to 11% before 15 June 2017. 

A  recent  study  by  BELTUG26  confirms  that  RLAH  has  also  brought  significant  benefits  to 
businesses and their employees, as it has triggered gains in both productivity and expenditures 
for business travellers, when outside their home country. One conclusion of the study is that 
the introduction of RLAH has changed the way that employees use mobile communications 
while on business travel. This calls for businesses to adapt to such changing patterns in order 
to reap the full benefits of RLAH. 

5  EFFECTS OF RLAH ON OPERATORS  

5.1 

Introduction 

The introduction of RLAH has greatly facilitated the consumption of mobile services by EU 
consumers when travelling within the Union, as shown in section 4. This section focuses on 
the  effects  of  the  end  of  roaming  surcharges  from  the  perspective  of  the  mobile  (including 
virtual) network operators in the Union27.  

25 Flash Eurobarometer 468, The end of roaming charges one year later, June 2018, available here. 
26 BELTUG, Roam Like at Home in the Business Market, October 2018  
27 The RLAH rules have by definition removed the retail roaming source of revenue for operators (except retail 
roaming surcharges applicable in excess of fair use policy and under the derogation). As a consequence, during 
the first year of RLAH, an operator's quarterly revenues include no retail roaming surcharges anymore and are 
compared to this operator's quarterly revenues that included retail roaming surcharges one year before. This has 

8 

 
 
                                                 
 
Roaming services require a bilateral agreement between two mobile network operators, each 
present  in  a  different  country,  so  that  their  customers  can  use  the  other  operator’s  network 
when travelling to that country. In this sense, the impact of RLAH can vary markedly between 
operators depending on the traffic flows of the given operator’s customer base. Based on its 
traffic flows, an operator can be classified as an outbounder or inbounder operator.  

An  outbounder  operator  has  a  customer  base  which  consumes  more  mobile  services  abroad 
(i.e. on the networks of partner operators in other EU countries), than those consumed by the 
partner operators’ customer base on its own network. Conversely, an inbounder operator has a 
customer  base  which  consumes  less  mobile  services  abroad  than  those  consumed  by  the 
partner operators' customer base on its own network. The analysis below looks at the impact 
of the introduction of RLAH on outbounder and inbounder countries separately. Due to tourist 
flows,  typically,  operators  in  Northern  European  countries  are  net  outbounder  operators  of 
roaming traffic, whereas operators in Southern European countries are typically inbounders of 
roaming traffic, although there are some exceptions.  

In this section, the figures are based on the data collected from mobile operators by NRAs for 
the purposes of the 19th, 20th and 21st BEREC International Roaming (IR) Benchmark Reports 
covering  Q4  2016  to  Q1  2018,  and  on  a  survey  of  NRAs  conducted  by  the  Commission  in 
May-June  2018.  Data  analysis  was  conducted  by  the  Joint  Research  Centre  (JRC)  of  the 
Commission28. 

5.2  Regulation has triggered competitive dynamics driving considerable reductions in 

wholesale prices that have benefited net outbounder operators 

When a customer from  one operator roams on the network of a roaming partner operator in 
another  EU  country,  the  first  operator  needs  to  pay  charges  to  access  the  network  of  the 
second,  the  so-called  wholesale  roaming  charges.  The  introduction  of  RLAH  was 
accompanied by considerable reductions in maximum wholesale roaming prices, and appears 
to have triggered further reductions in actual wholesale prices.  

The average EEA wholesale roaming price for voice services was EUR 2.93c/min in Q3 2016 
compared to EUR 2.41c/min in Q3 2017 and 2.06c/min in Q1 201829. Similarly, the average 
EEA wholesale price for data services was EUR 9.9/GB in Q3 2016 compared to EUR 4/GB 
in Q3 2017 and EUR 2.7/GB in Q1 201830. Wholesale prices for net outbound (unbalanced) 
roaming  traffic,  which  is  the  part  of  the  roaming  traffic  generating  net  payments  from  one 

the  mechanical  effect  of  reducing  the  operator's  revenues  during  the  first  year  of  RLAH  in  year-on-year 
comparisons.  From  the  second  year  of  RLAH  onwards,  this  mechanical  effect  disappears  since  year-on-year 
comparisons are made for periods fully under RLAH. What remains is the demand for growing volumes of data, 
including while on travel in the EU/EEA, which grows operators' mobile revenues. 
28 The Joint Research Centre carries out research on behalf of the Commission in order to provide independent 
scientific advice and support to EU policy (see its website here). 
29 20th and 21st International Roaming BEREC Benchmark Reports, covering April 2017- March 2018. 
30 20th and 21st International Roaming BEREC Benchmark Report, covering April 2017- March 2018. 

9 

 
 
                                                                                                                                                         
operator  to  the  other,  are  even  lower  (1.84  c/min  for  voice  and  EUR  2.6/GB  for  data  on 
average in Q1 2018). The average across operators of the five lowest wholesale prices for net 
outbound  (unbalanced) roaming traffic  reached EUR 1.39 c/min  for voice and EUR 1.1/GB 
for data in Q1 2018. 

The  decline  in  wholesale  roaming  prices  was  determined  mainly  by  two  factors.  First,  the 
introduction of RLAH has resulted in significant increases in roaming volumes (as shown in 
the  section  4.1),  thereby  fuelling  competition  in  wholesale  roaming  prices.  Second,  in  line 
with the objective of the Roaming Regulation, regulated maximum wholesale roaming prices 
have  acted  as  ceilings,  triggering  competitive  market  dynamics  between  operators  offering 
wholesale roaming access below those ceilings. 

These  declines  in  wholesale  roaming  prices  should  be  welcomed  for  three  reasons.  First, 
lower  wholesale  roaming  prices  have  greatly  mitigated  any  potential  impact  from  the 
introduction  of  RLAH  on  outbounder  operators,31  as  they  have  reduced  their  wholesale 
roaming payments. Secondly, such reductions, together with the fact that average wholesale 
market  prices  have  been  below  the  regulated  maximum  wholesale  tariffs,  are  persuasive 
evidence  that  net  inbounder  operators  have  been  able  to  meet  the  increasing  demand  in 
roaming  services  while  at  the  same  time  recovering  the  cost  of  their  network  investments, 
including the cost of capital. Third, such reductions in wholesale roaming prices are a sign of 
a better functioning internal market at wholesale level, at least as regards a significant share of 
bilateral  relationships  between  operators.  The  impossibility  to  maintain  excessive  prices  for 
retail roaming services on the various national markets, combined with the release of pent-up 
demand through the application of RLAH at retail level, appears to have played a positive role 
in that regard. 

5.3  Net inbound operators have benefited from increased roaming demand  

In relation to operators in net inbound countries, data gathered from BEREC’s IR Benchmark 
Reports shows that out  of the 29 countries included in the exercise (i.e. the 28 EU Member 
States  plus  Norway),  13  are  net  inbounders  of  roaming  data  traffic.32  There  are  some 
differences  in  terms  of  the  increase  in  incoming  roaming  data  traffic  experienced  by  these 
countries after the introduction of RLAH. For some (e.g. Spain, Cyprus or Italy), the increase 
in outbound roaming data traffic, starting from low levels compared to inbound roaming data 
traffic, has been proportionally greater than that in inbound roaming traffic. A similar pattern 
can be observed with roaming voice traffic.  

Net  inbound  roaming  traffic  represents  typically  between  1%  and  8%  of  domestic  traffic  in 
inbound countries. For data, it represented more than 10% of domestic traffic in summer 2017 

31 According to the data from the 21st International Roaming BEREC Benchmark Report, 16 countries out of the 
28 Member States plus Norway are net outbounders of data roaming traffic, namely: DE, DK, EE, FI, IE, LT, 
LU, LV, NL, NO, PL, RO, SE, SI, SK and UK.   
32 Net inbounder countries of roaming data traffic include: AT, BE, BG, CY, CZ, EL, ES, FR, HR, HU, IT, MT 
and PT.   

10 

 
 
                                                 
in Croatia, Malta, Portugal, and up to around 20% in Cyprus and Greece. Operators in all net 
inbound countries have benefited from the increase in demand for wholesale roaming services 
at market prices that have allowed operators in net inbound countries to recover the costs of 
providing wholesale roaming access, including an appropriate return on their investments (as 
described in section 5.2 above).  

5.4 

In spite of the considerable increase, net outbound roaming traffic still represents 
a small fraction of domestic demand 

When  assessing  the  potential  impact  of  increasing  roaming  demand  on  net  outbounder 
operators, it is helpful to analyse the net outbound traffic in these countries. In other words, 
the  difference  between  the  outbound  and  inbound  roaming  traffic  is  likely  to  give  an 
indication  of  the  size  of  the  (net)  wholesale  roaming  payments  of  these  operators.  The 
evidence from BEREC’s IR Benchmark Reports shows that, in spite of the massive increase 
in  roaming  data  traffic,  the  net  outbound  data  roaming  traffic  (i.e.  outbound  roaming  data 
minus  inbound  data  roaming  traffic)  only  represents  a  small  fraction  of  the  domestic  data 
traffic  of  these  operators,  typically  below  3%  and  not  greater  than  6%  of  the  domestic  data 
traffic consumption for any country.  

Similarly, in the case of roaming voice traffic, in spite of the fact that a Polish, Romanian or 
Bulgarian  subscriber  consumes  on  average  4  to  5  times  more  roaming  voice  calls  in  the 
EU/EEA  than  the  average  EU/EEA  subscriber33,  the  net  outbound  roaming  voice  traffic  in 
these countries still represents less than 5% of these operators’ domestic voice traffic. 

5.5  Most mobile operators have implemented fair use policies  
Commission’s Implementing Regulation (EU) 2016/228634 laid down detailed rules to ensure 
a consistent  implementation  of fair use policies (FUP) that  roaming providers may  apply in 
order  to  avoid  anomalous  or  abusive  use  of  regulated  retail  roaming  services  under  RLAH 
that  could  have  detrimental  effects  on  domestic  markets.  In  this  regard,  the  Commission 
surveyed NRAs in May-June 2018 on the extent of the application of FUPs by their domestic 
operators.  

As shown in Table 1 below, the vast majority of operators have applied a FUP, particularly 
operators from outbound countries.  

33 See Figure 7 in the 21st BEREC International Roaming Benchmark Report, October 2017- March 2018. The 
forthcoming price  cap on intra-EU calls  from May 2019 onwards  may have an effect on this particularly high 
consumption of roaming voice calls.  
34 Commission Implementing Regulation (EU) 2016/2286 of 15 December 2016 laying down detailed rules on 
the application of fair use policy and on the methodology for assessing the sustainability of the abolition of retail 
roaming  surcharges  and  on  the  application  to  be  submitted  by  a  roaming  provider  for  the  purposes  of  that 
assessment (CIR),.  

11 

 
 
                                                 
Table 1: Operators applying a FUP 

Inbound countries 

Outbound countries 

NO 

20% 

6% 

YES 

80% 

94% 

Source: Commission’s survey to NRAs (June 2018) 

In the case of MVNOs, the share of these operators applying a FUP has been relatively lower 
than the average presented (67% for MVNOs in  inbound countries and 87% for MVNOs in 
outbound  countries).  This  suggests  that  MVNOs  have  been  generally  more  inclined  than 
MNOs to first see how their customers would use RLAH in order to determine whether or not 
to invest in fair use policy measures. 

In  terms  of  the  types  of  FUPs  applied,  about  half  of  the  operators  have  implemented  the 
residence/stable links criterion.35 Table 2 below shows that the vast majority of operators have 
relied on the open data bundle limits, albeit less so in the case of MVNOs. This fair use policy 
allows operators to set limits to the mobile data consumed by their customers while roaming 
at domestic price, based on the prices of their bundles and the regulated maximum wholesale 
roaming tariffs applicable at the time.36  

Table 2: Types of FUPs applied by operators 

NO 

YES 

a. 4-month window 

A 4 month window to assess prevailing domestic consumption over roaming consumption 
or prevailing domestic presence of the customer over presence in other MS of the Union 

Inbound countries 

Outbound countries 

74% 

55% 

26% 

45% 

b.  open  data  bundle 
limits 

Roaming customer shall be able to consume volumes equivalent to at least twice the 
volume resulting from dividing the domestic retail price by the max. wholesale caps 

Inbound countries 

Outbound countries 

21%* 

13%* 

79%* 

87%* 

c. pre-paid limits 

Roaming customer shall be able to consume volumes equivalent to at least twice the 
volume resulting from dividing the credit available by the max. wholesale caps 

35  See  Figure  3  in  BEREC  Report  on  Transparency  and  Comparability  of  International  Roaming  Tariffs, 
December 2018 
36  For  a  more  detailed  description,  please  refer  to  the  CIR  (here)  and  the  Commission’s  Q&A  on  Roaming 
(available here). 

12 

 
 
 
 
                                                 
Inbound countries 

Outbound countries 

75%** 

62%** 

25%** 

38%** 

d. other mechanisms 

Other objective indicators such as long inactivity of SIM card with use mostly while 
roaming or subscription and sequential use of multiple SIM cards by same roamer 

Inbound countries 

Outbound countries 

91% 

70% 

9% 

30% 

Source: Commission’s survey of NRAs (June 2018). 
* % of responding operators offering open data bundles (75% of the respondents). 
** % of responding operators offering pre-paid tariff plans (53% of the respondents). 

In  contrast,  other  FUPs  available  to  operators,  such  as  the  4-month  window  of  domestic 
prevalence,  data  limits  on  pre-paid  cards  or  other  control  mechanisms  linked  to  the  other 
objective indicators referred to in the Commission Implementing Regulation, have been used 
in practice by operators to a relatively modest extent. The main reason for not relying on these 
FUP mechanisms has been operators’ view that they lack sufficient effectiveness, as shown in 
Table 3 below.  

Table 3: Operators’ views on the effectiveness of some FUP mechanisms 

4-month window 

open bundle limits 

pre-paid limits 

other mechanisms 

Effective/Partially 
effective 
43.6% 

74.6% 

49.2% 

43.1% 

Source: Commission’s survey of NRAs (June 2018). 

Ineffective 

Unnecessary 

46.4% 

15.5% 

24.8% 

33.7% 

10% 

9.9% 

26.0% 

23.2% 

In  addition,  in  relation  to  the  4-month  window  mechanism,  a  significant  share  of  operators 
surveyed  have  indicated  that  they  consider  it  either  too  complex  (63%  of  operators)  or  too 
costly (23% of operators).  

Still, a slight  majority of MNOs  (54%) apply the 4-month window mechanism in  outbound 
countries. In addition, a number of operators have indicated that they are applying a wait-and-
see  strategy  and  that  they  could  consider  relying  on  this  FUP  mechanism  in  the  future 
depending on the number of customers exceeding the allowed roaming consumption/presence 
over the 4-month period.  

Fair  use  policy  is  transparently  communicated  to  roaming  customers.  Almost  all  operators 
applying open data bundles limits inform their customers about the actual value (in GB) of the 

13 

 
 
 
limit and the remaining volume available. They also alert them when they reach that limit.37 
When  applied,  the  4-month  window  control  mechanism  is  part  of  the  customer's  contract. 
About 2/3 of the operators inform their customers about their roaming and domestic usage via 
their personal customer page (93%) or the call centre (100%). The overwhelming majority of 
roaming customers however stay abroad for much shorter time periods and therefore do not 
need  to  worry  about  the  control  mechanism:  for  71%  of  the  operators  effectively 
implementing the 4-month window mechanism, between 0 and 1% of their subscribers were 
subject  to  an  alert  for  having  a  prevailing  roaming  presence/consumption38.  Subscribers 
effectively  subject  to  a  roaming  surcharge  after  being  alerted  are  even  less  numerous.  It 
should  be  noted  that  the  control  mechanism  is  in  itself  a  disincentive  for  customers  to  go 
beyond  the  4-month  window,  which  may  explain  the  low  proportion  of  customers  who  are 
effectively  alerted.  In  cases  where  no  control  mechanism  is  applied,  the  proportion  of 
customers  having  a  prevailing  roaming  presence/consumption  may  be  higher  than  in  cases 
where the control mechanism is in place. 

5.6  Overall, MVNOs maintain their position on the market  

The  Commission  has  analysed  the  data  on  MVNOs  gathered  for  the  Benchmark  reports. 
Unfortunately,  the  response  rate  from  MVNOs  is  lower  than  for  MNOs  and  unstable  over 
time,  with  a  different  number  of  MVNOs  replying  to  the  information  requests  of  each 
Benchmark report. This means that any conclusions from the analysis of MVNO data should 
be taken with caution.  

The  data  on  MVNOs  from  the  Benchmark  reports  seems  to  indicate  that  for  most  of  the 
countries  for  which  data  is  available,  MVNOs  have  successfully  maintained  their  domestic 
market share (in subscriber numbers) and, in some instances, they seem to have been able to 
improve it over the period considered. On average, MVNOs' so-called ARRPU39, which is a 
standard metric used for such comparisons, increased between Q4 2017 and Q1 2018, while it 
remained stable for MNOs.40  

The great majority of surveyed MVNOs obtain wholesale roaming access via their domestic 
host MNOs (71%), only 5% via direct bilateral negotiations with MNOs and 7% via a hub41. 
In  terms  of  MVNOs’  views  regarding  potential  impediments  to  MVNO  competition  with 
MNOs,  some  have  indicated  the  absence  of  wholesale  activities  (implying  no  income  from 
incoming roaming) and wholesale prices at the level of the regulated wholesale price  cap as 
the main factors (respectively 35% and 40% of MVNOs surveyed).  

37 BEREC Report on Transparency and Comparability of International Roaming Tariffs, December 2018. 
38 For the remaining 30% of these operators, between 1% and 5% of their subscribers received an alert under the 
4-month mechanism. Source: Commission's survey to NRAs, June 2018. 
39 Average Retail Revenue per User. 
40 See Figure 90 in 21st International Roaming BEREC Benchmark Report, covering October 2017- March 2018. 
41  Commission's  survey  of  NRAs,  June  2018.  17%  of  responding  MVNOs  use  other  channels  which  however 
often  imply  the  host  MNO  as  part  of  the  solution.  A  roaming  hub  gives  access  to  hundreds  of  international 
roaming agreements. 

14 

 
 
                                                 
On  this,  Figure  3  (for  voice)  and  Figure  4  (for  data)  below  present  the  lowest  wholesale 
roaming prices paid by MVNOs and MNOs from each country, for each service respectively, 
showing  these  prices  against  the  regulated  maximum  wholesale  roaming  tariffs.42  Although 
the  evidence  does  not  represent  the  full  picture  in  all  countries,  as  many  operators  did  not 
provide  any  data,  the  following  conclusions  can  be  tentatively  drawn.  First,  while  it  is  true 
that  MVNOs  typically  pay  wholesale  roaming  prices  that  are  higher  than  those  paid  by 
MNOs, and that some pay prices broadly in line with the level of the wholesale roaming price 
caps, there are many examples of MVNOs that pay wholesale roaming prices well below the 
regulated tariffs in most EU countries. Thus, it cannot  be concluded from this evidence that 
MVNOs  necessarily  all  pay  wholesale  roaming  prices  at  the  level  of  the  regulated  caps. 
Second,  there  are  a  few  examples  of  MVNOs  that  pay  wholesale  roaming  prices  at  similar 
levels to those paid by MNOs. 

Figure 3: Wholesale prices paid for voice by MNOs (blue dots) and MVNOs (red dots) 

Source:  21st  International  Roaming  BEREC  Benchmark  Report  (October  2018)  and  Commission  survey  of 
MVNOs (June 2018). The chart uses the average of the 5 lowest prices paid by MNOs and the average price paid 
by MVNOs. JRC's calculations. 

42  The  information  presented  in  these  figures  was  collected  from  the  21st  International  Roaming  BEREC 
Benchmark  Report  (October  2018)  and  Commission  survey  to  MVNOs  (June  2018).  Thus,  information  from 
MNOs  and  MVNOs  may  not  be  entirely  comparable.  For example,  the  chart  uses  the  average  of  the  5  lowest 
prices paid by MNOs and the average price paid by MVNOs, and may therefore overstate the advantage enjoyed 
by MNOs.  

15 

 
 
 
                                                 
Figure 4: Wholesale prices paid for data by MNOs (blue dots) and MVNOs (red dots) 

Source:  21st  International  Roaming  BEREC  Benchmark  Report  (October  2018)  and  Commission  survey  of 
MVNOs (June 2018). The chart uses the average of the 5 lowest prices paid by MNOs and the average price paid 
by MVNOs. JRC's calculations. 

The evidence in Figure 3 and Figure 4 above seems to suggest that the prices paid by MVNOs 
can vary significantly depending on factors other than just their condition  of being a virtual 
operator. For example, an MVNO may be able to negotiate different prices depending on its 
size  or  its  negotiating  strategy  with  its  host  MNO.  On  the  latter,  an  MVNO  attaching  more 
weight to roaming services may be able to negotiate a better wholesale roaming access deal 
with  the  MNO  than  an  MVNO  that  does  not  attach  such  weight  to  roaming  services  and 
prefers to focus its strategy on domestic services.  

The second most important factor (35.3% of respondents) highlighted by MVNOs seems to be 
the fact that they do not own a network and therefore do not have associated revenues from 
incoming roaming traffic. This, together with the relatively lower volumes of (some) MVNOs 
(an  issue  pointed  out  by  11.8%  of  respondents  to  the  survey)  could  explain  the  relatively 
higher  prices  paid  by  MVNOs  when  compared  to  MNOs.  These  factors  are  inherent  to 
MVNOs’ business models. 

5.7 

 Derogations  have  been  limited  to  operators  in  a  few  countries  and  should 
gradually disappear 

Mobile  operators  that  have  demonstrated  that  they  are  not  able  to  recover  their  actual  and 
projected  costs  of  providing  regulated  roaming  services  without  increasing  their  domestic 

16 

 
 
 
prices in order to provide RLAH have been granted a sustainability derogation by their NRA. 
The  derogations  granted  are  strictly  in  order  to  recover  their  costs  of  providing  roaming 
services  to  their  customers  and  avoid  any  domestic  price  increase  (see  section  2).  Table  4 
below  presents  the  number  of  derogations  that  have  been  granted  during  the  first  year  of 
RLAH, per country, split by type of operator (MNO and MVNO).  

Table  4:  Sustainability  derogations  granted  by  NRAs  during  the  first  year  of  RLAH 
(June 2017-June 2018), split by MNOs and MVNOs  

Derogations granted in the 
first RLAH year 

AT 
BE 
DK 
EE 
ES 
FI 
FR 
IT 
LT 
PL 
RO 
SI 
Total 

MNO 
0 
0 
0 
3 
0 
3 
0 
0 
3 
4 
1 
0 
14 

MVNO 
2 
1 
1 
0 
1 
1 
11 
4 
1 
7 
0 
1 
30 

Source: Commission's survey of NRAs, June 2018 

As  expected,  MVNOs  are  the  primary  users  of  the  sustainability  derogation  given  their 
specific  situation  on  the  wholesale  roaming  market  (see  section  5.6).  Over  the  first  year  of 
RLAH, about 2/3 of the derogations have been granted to MVNOs (30 vs 14). Still, this is a 
small fraction of the more than 330 MVNOs existing in the Union. Most of the providers that 
were granted a derogation have a small market share in their respective countries. 

As  regards  MNOs,  there  are  four  Member  States  in  which  all  MNOs  have  obtained  a 
sustainability  derogation,  namely,  Estonia,  Finland,  Lithuania  and  Poland  (the  latter  only 
since  2018).  Romania's  smaller  MNO  was  also  granted  a  sustainability  derogation.  These 
countries  are  characterised  by  particularly  low  mobile  data  prices  and  high  net  outbound 
roaming traffic. Operators in these countries were therefore the most likely to have resort to 
the derogation foreseen in the Roaming Regulation in order not to affect the level of domestic 
prices on these markets. Conversely, as expected no derogation has been granted to MNOs in 
Member States which are net recipients of inbound roaming traffic. 

17 

 
 
 
 
  
 
In all of the above cases, operators have used the derogations with parsimony and introduced 
surcharges only in a subset of their tariff plans43, so that the majority of the outbound roaming 
traffic from these countries still benefits from RLAH (see section 4.2). In addition, in many 
cases, the maximum surcharges allowed by the NRAs are below the wholesale roaming price 
caps. 

No new derogation, other than the renewal of already granted derogations, has been granted in 
the second year of RLAH. In France, a few derogations, and in Denmark the only derogation, 
have  not  been  renewed.  In  the  other  Member  States,  the  derogations  that  have  lapsed  have 
been renewed by NRAs after examination of the new applications submitted by operators. In 
most cases, the new maximum surcharges allowed by NRAs are lower than those of the first 
derogations.  

The  Commission  is  closely  monitoring  the  derogations  granted  and  renewed  by  NRAs  to 
ensure  consistency  in  the  application  of  the  Commission  Implementing  Regulation  (EU) 
2016/2286 across the Union. The Commission has invited NRAs to exercise the same acute 
scrutiny  when  reviewing  derogation  applications.  NRAs  have  the  power  to  reconsider  their 
decisions  during  the  validity  period  of  a  granted  derogation  in  view  of  new  developments 
and/or  information  regarding  the  situation  of  the  operator.  The  Commission  expects 
derogations to gradually disappear, particularly from 2019, when greater declines in regulated 
wholesale  caps  for  mobile  data  services  will  take  effect,  improving  the  sustainability  of 
RLAH in these countries.  

6  EFFECTS OF RLAH ON DOMESTIC MARKETS  

6.1  The declining trend in domestic prices persists overall in the EU/EEA 
According  to  the  study  “Mobile  Broadband  Prices  in  Europe  2018”44,  in  the  period  from 
February  2017  to  February  2018  (i.e.  from  3  months  before  the  introduction  of  RLAH  to  9 
months after) there is no trend for increasing domestic prices.  

On the contrary, between those two dates, the EU average price has decreased  for  all voice 
and data baskets as well as for all data-only baskets, as reflected in the following tables: 

100MB, 
30 calls 

500MB, 
100 calls 

1GB,  
300 calls 

2GB,  
900 calls 

2GB,  
100 calls 

5GB,  
100 calls 

Change in average EU price for 
voice and data baskets 

Change in average EU price for 
data only baskets 

-14% 
256MB  512MB  1GB 

-6% 

-6% 

-5% 

-16% 

2GB 

5GB 

10GB 

-20% 
20GB 

-10% 

-14% 

-5% 

-12% 

-4% 

-6% 

-16% 

43  See  section  3.2  in  BEREC  Report  on  Transparency  and  Comparability  of  International  Roaming  Tariffs, 
December 2018.  
44 Mobile Broadband Prices in Europe in 2018, a study conducted for the European Commission by Empirica 

18 

 
 
 
 
 
                                                 
According  to  this  study,  only  five  Member  States  exhibit  an  increasing  trend  in  prices  for 
packages that include voice and data (BG, IE, LV, MT, SE) while twelve exhibit a decreasing 
trend (AT, BE, FR, DE, HU, IT, NL, PL, PT, RO, ES, UK). Prices in the remaining Member 
States  either  remain  stable  or  present  a  mixed  trend,  decreasing  for  certain  baskets  and 
increasing for others. 

The  situation  is  quite  similar  for  data-only  packages.  Five  Member  States  exhibit  an 
increasing trend (HR, DK, EE, LT, MT) while eight Member States exhibit a decreasing trend 
(FI, FR, IE, IT, NL, PL, SE, UK). 

Such trends do not present major deviations from the ones of previous years, taking also into 
account the changing maturity level of the data services. 

6.2 

Increase in mobile broadband take up and 4G coverage continues 

The introduction of RLAH does not  seem  to  have influenced mobile broadband uptake in  a 
positive  or  negative  manner  nor  to  have  affected  mobile  operator's  investments  to  expand 
their 4G networks. 

According  to  the  DESI  study45,  mobile  broadband  uptake  continues  to  increase  EU-wide, 
reaching 90.2% in end 2017 compared to 83.8% in end 2016 and presenting a steady pace of 
increase compared to previous years46.  

At  the  same  time,  EU-wide  4G  population  coverage  has  reached  90.8%  in  end  2017 
(compared  to  85.6%  in  end  2016).  In  the  majority  of  Member  States  (see  Figure  5),  4G 
coverage exceeds 90% while in only four it is below 80%. From the Member States where 4G 
coverage was below 90% in end 2016 (11 in total) the increase achieved during 2017 was in 
all but two (Germany and Italy) higher than 5%. 

45 Digital Economy and Society Index (DESI) 2018. Connectivity – Broadband market developments in the EU, 
available here. 
46 Only two countries have experienced a slightly (insignificant) reduced mobile uptake, Finland (146.3% in end 
2017 compared to 147.2% in end 2016) and the UK (89.8% in end 2017 compared to 91.4% in end 2016). 

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Figure 5: 
Member States. 

4G  population  coverage  in  2018  and  increase  from  2017  in  the  EU 

Source: Digital Economy and Society Index (DESI) 2018. Connectivity – Broadband market developments in 
the EU 

6.3  On average non-EU/EEA roaming prices are decreasing  

According to  the last BEREC data, between Q1 2017 and Q1 2018 retail  roaming prices of 
EU/EEA mobile operators in non-EU/EEA countries have continued to decline on average: -
38%  for  data  services  and  -8%  for  calls  made.  Overall  therefore,  abolishing  intra-EU/EEA 
roaming prices  have not  come at  the price of higher roaming prices in  the rest  of the world 
(so-called "waterbed effect")47. In particular, more and more operators include some popular 
non-EU/EEA destination countries in their RLAH offering or apply a reduced roaming fee to 
those countries48.  

7  CONCLUSION 

With  the  implementation  of  RLAH  since  June  2017  the  demand  for  mobile  consumption 
while  travelling  in  the  EU/EEA  has  rapidly  and  massively  increased.  This  has  revealed  the 
considerable roaming needs of consumers that were previously unmet and, "has significantly 
contributed to the development of the single market" as noted by BEREC49. It is therefore not 
surprising  that  consumer  satisfaction  overall  has  been  high.  Mobile  operators  have  by  and 

47  This overall evolution  is an  average. It does not exclude  punctual increases in roaming prices in some  non-
EU/EEA countries in some tariff plans in some Member States. This may be the case in particular for less visited 
non-EU/EEA destination countries. 
48  According  to  the  BEREC  Report  on  Transparency  and  Comparability  of  International  Roaming  Tariffs 
(December 2018), almost half of the operators do so. 
49 
public-debriefing-on-the-outcomes-of-34th-plenary-meetings 

https://berec.europa.eu/eng/document_register/subject_matter/berec/press_releases/8019-press-release-on-

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large  abided by the new rules, accompanied by the vigilant  monitoring  from  NRAs and the 
Commission.  The  safeguards  foreseen  in  the  Roaming  Regulation  to  avoid  distortions  on 
domestic markets, namely fair use policy and the sustainability derogation, as expected have 
worked adequately where needed. The sharp decline in wholesale roaming price caps, and for 
some  the  authorisation  to  derogate,  have  in  general  significantly  mitigated  the  impact  of 
RLAH on outbounder MNOs and MVNOs. The  successive reductions of the data price cap 
established  in  the  Roaming  Regulation  will  further  facilitate  the  provision  of  RLAH  in  the 
years to come. Moreover, these reforms appear to have given significant  impetus to internal 
market dynamics at the wholesale level. In this context, NRAs will need to exercise additional 
scrutiny when assessing applications from mobile operators to renew derogations. 

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