COMMISSION STAFF WORKING DOCUMENT Accompanying the document Report from the Commission to the European Parliament and the Council on the review of the roaming market
Date: 2019-11-29
Institutions: Directorate-General for Communications Networks, Content and Technology, European Commission
Subjects: consumer protection, price regulations, regulation of telecommunications, roaming, single market, telecommunications policy, telephone charges, transmission network, wholesale trade

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 29.11.2019 SWD(2019) 416 final  COMMISSION STAFF WORKING DOCUMENT Accompanying the document Report from the Commission to the European Parliament and the Council on the review of the roaming market {COM(2019) 616 final}  
 
 
Table of Contents 

1 

2 

3 

4 

Introduction 

Scope of the Roaming Regulation and main provisions 

Scope of the roaming review 

The Commission’s approach to the roaming review 

4.1  Information and data gathering on wholesale and retail roaming markets 

4.1.1  Operators’ data collected for the BEREC International Roaming Benchmark Reports 
4.1.2  Online surveys 

4.2  Data analysis 

7 

8 

11 

12 

12 
12 
12 

12 

4.3  External studies 

12 
4.3.1  Study to estimate the costs of providing wholesale roaming services 
13 
4.3.2  Study to assess technological and market developments that might have an impact on the roaming 
13 
14 

4.3.3  Study on mobile broadband prices 

market 

4.4  BEREC input 

4.4.1  Benchmark Reports 
4.4.2  Transparency Reports 
4.4.3  BEREC Opinion on the roaming market (June 2019) and BEREC Supplementary analysis on 

wholesale roaming costs (September 2019) 

4.5  European Parliament study  

5 

Competition in retail roaming markets 

5.1  Evolution of retail (outbound) roaming volumes 

5.1.1  The introduction of RLAH has lead to an explosive increase in roaming traffic 
5.1.2  Retail (outbound) roaming traffic remains a small fraction of domestic traffic 

5.2  Implementation of fair use policy 

5.3  Application of the derogation mechanism 

5.3.1  The number of sustainability derogations is getting smaller every year 
5.3.2  The maximum surcharges granted by the NRAs are low and generally decreasing every year 
5.3.3  The share of EU/EEA roaming traffic subject to a surcharge due to the sustainability derogation 

has remained marginal 

5.3.4  Operators having been granted the derogation have used the surcharge with parsimony 
5.3.5  The application of the derogation mechanism should continue to decrease 

5.4  Use of alternative roaming tariff plans 

5.5  Evolution of domestic tariff plans 

5.5.1  Domestic prices 

1 

28 
29 
31 

31 

34 
34 

14 
14 
14 

15 

15 

15 

15 
15 
20 

22 

25 
26 
28 

 
 
 
 
5.5.2  Domestic-only tariff plans 

5.6  Quality of services  

5.7  Situation of MVNOs 

5.8  Rest of the World roaming 

5.9  Consumer perception 

6 

Assessment of the costs of providing wholesale roaming services 

6.1  Description of the Commission’s approach 

6.2  Previous estimates of wholesale roaming costs 
6.2.1  BEREC cost estimates from 2010 and 2012 
6.2.2  TERA consultants cost estimates from 2016 

6.3  The Axon Partners cost model 

6.3.1  The approach and methodology followed by Axon Partners 
6.3.2  Choice of cost standards and general cost allocation 
6.3.3  Treatment of seasonality 
6.3.4  The structure of the cost model 

6.4  Modelled scenarios 

6.5  Results derived directly from the cost model 

6.6  Estimated total costs including transit and termination 

6.7  BEREC response to the cost model and estimates 

7 

Competition in wholesale roaming markets 

7.1  Evolution of wholesale (inbound) roaming volumes 

7.1.1  Net inbounder and outbounder countries 
7.1.2  Inbound roaming traffic exhibits an explosive increase 
7.1.3  National  wholesale roaming markets are not overly concentrated 
7.1.4  Group operators keep part of their roaming traffic within the group 

7.2  Evolution of prices 

7.2.1  Wholesale roaming prices have been steadily decreasing 
7.2.2  In-group wholesale roaming rates are not necessarily lower than out-of-group rates 

7.3  Wholesale structural measures 

7.4  Situation of MVNOs 

7.4.1  The various types of wholesale roaming access for MVNOs 
7.4.2  Specific challenges reported by MVNOs in wholesale roaming agreements 
7.4.3  Wholesale roaming prices paid by MVNOs 
7.4.4  Possible measures to improve the situation for MVNOs 

7.5  Fraud 

8 

Technological developments 

8.1  The main developments with the prospect for a substantial impact on roaming 

2 

34 

36 

39 

42 

43 

45 

46 

47 
47 
48 

49 
49 
51 
52 
53 

54 

58 

61 

64 

66 

66 
66 
73 
75 
76 

78 
78 
82 

84 

84 
85 
86 
86 
90 

92 

93 

94 

 
 
8.2  The study concludes that there does not seem to be a case for significant changes to the 

regulatory rules for international roaming under the current review. 

8.3  The study suggests considering if developments relating to M2M and permanent roaming 

would call for immediate attention 

9 

Conclusion 

95 

96 

98 

3 

 
 
 
 
 
Figure 1: Regulated wholesale roaming data price cap, Q3 2017 – Q2 2022 ....................................... 10 

Figure 2: EEA retail roaming voice traffic (calls made), Q2 2016 – Q1 2019 (millions of minutes) ... 17 

Figure 3: EEA retail roaming data traffic, Q2 2016 – Q1 2019 (millions of GB) ................................. 17 

Figure 4: EEA average voice roaming consumption (calls made) per month per roaming subscriber, 

Q2 2016 – Q1 2019 (minutes per month) ................................................................................. 18 

Figure 5: EEA average data roaming consumption per month per roaming subscriber, Q2 2016 – Q1 

2019 (MB per month) ............................................................................................................... 19 

Figure 6: Voice services - Ratio between the total volumes after RLAH (Q4 2017 - Q2 2018) and the 

total volumes over the last period before RLAH (Q4 2016 - Q2 2017), for retail domestic 
traffic (blue bars) and outbound roaming traffic (red bars) ...................................................... 20 

Figure 7: Data services - Ratio between the total volumes after RLAH (Q4 2017 - Q2 2018) and the 

total volumes over the last period before RLAH (Q4 2016 - Q2 2017), for retail domestic 
traffic (blue bars) and outbound roaming traffic (red bars) ...................................................... 21 

Figure 8: Voice services - Cumulative density distributions of the retail (outbound) roaming voice 

traffic as % of the retail domestic voice traffic. ........................................................................ 22 

Figure 9: Data services - Cumulative density distributions of the retail (outbound) roaming data traffic 
as % of the retail domestic data traffic. ..................................................................................... 23 

Figure 10: Share of total EU/EEA retail roaming traffic which is subject to a surcharge in excess of 

FUP (%), Q4 2017 – Q1 2019 ................................................................................................... 24 

Figure 11: Development of % of voice and data roaming traffic in the EU/EEA subject to a surcharge, 
due to the sustainability derogation, Q3 2017 – Q1 2019 ......................................................... 29 

Figure 12: Development of % of voice roaming traffic subject to a surcharge due to the sustainability 
derogation in the Member States where derogations were granted to MNO(s), Q3 2017 – Q1 
2019 ........................................................................................................................................... 30 

Figure 13: Development of % of data roaming traffic subject to a surcharge due to the sustainability 

derogation, in the Member States where the derogation was granted to MNO(s), Q3 2017 – Q1 
2019 ........................................................................................................................................... 31 

Figure 14: % of roaming voice and data traffic from alternative tariffs in total EU/EEA roaming 

traffic, Q4 2016 – Q1 2019 ....................................................................................................... 33 

Figure 15: Cumulative density functions of the % of outbound voice traffic coming from alternative 

tariffs per operator ..................................................................................................................... 34 

Figure 16: Cumulative density functions of the % of outbound data traffic coming from alternative 

tariffs per operator ..................................................................................................................... 34 

Figure 17: % of domestic-only subscribers per country ........................................................................ 37 

Figure 18: Individual MVNOs’ market shares (1 dot = 1 MVNO) before and after RLAH ................. 41 

Figure 19: Total MVNO market share among the operators (MNOs and MVNOs) that responded to all 
19th to 22nd BEREC Benchmark Reports’ data collection, by country...................................... 42 

Figure 20: Average Retail Revenue Per User (ARRPU) of MVNOs, by country, Q4 2016 to Q1 2019

................................................................................................................................................... 43 

4 

 
 
Figure 21: Development of retail roaming prices for travelers roaming in non-EU/EEA countries, Q2 

2016 – Q1 2019 ......................................................................................................................... 44 

Figure 22: Roaming-related topics of consumer complaints received by NRAs and their relative 

importance ................................................................................................................................. 46 

Figure 23: Outgoing wholesale roaming voice – Estimated costs, TERA model in 2016 .................... 49 

Figure 24: Wholesale roaming data service – Estimated costs €cent/MB, TERA model in 2016 ........ 50 

Figure 25: Structural overview of the Axon Bottom-Up LRIC model .................................................. 55 

Figure 26: Cover sheet of the Axon cost model .................................................................................... 56 

Figure 27: Estimated data roaming unit costs in €/GB, transit costs not included ................................ 60 

Figure 28: Estimated voice roaming unit cost in €ents/min, transit and termination costs are not 

included ..................................................................................................................................... 61 

Figure 29: Estimated SMS roaming unit costs in €cents/SMS .............................................................. 62 

Figure 30: Estimated data roaming unit costs in €/GB including estimates for transit costs ................ 64 

Figure 31: Estimated voice roaming unit costs in €cents/min, including transit and termination costs 65 

Figure 32: Voice services, inbounder countries - Left panel: ratio between inbound and outbound 

roaming voice volumes. Right panel: net outbound roaming voice volumes (outbound voice 
volumes minus inbound voice volumes) as % of total domestic voice volumes, Q4 2016 – Q1 
2019. .......................................................................................................................................... 68 

Figure 33: Voice services, outbounder countries – Left panel:  ratio between inbound and outbound 
roaming voice volumes. Right panel: net outbound roaming voice volumes (outbound voice 
volumes minus inbound voice volumes) as % of total domestic voice volumes, Q4 2016 – Q1 
2019. .......................................................................................................................................... 70 

Figure 34: Data services, inbounder countries. Left panel: ratio between inbound and outbound 
roaming data volumes. Right panel: net outbound roaming data volumes (outbound data 
volumes minus inbound data volumes) as % of total domestic data volumes, Q4 2016 – Q1 
2019. .......................................................................................................................................... 72 

Figure 35: Data services, outbounder countries. Left panel: ratio between inbound and outbound 
roaming data volumes. Right panel: net outbound roaming data volumes (outbound data 
volumes minus inbound data volumes) as % of total domestic data volumes, Q4 2016 - Q1 
2019. .......................................................................................................................................... 73 

Figure 36: Inbound roaming voice traffic, Q4 2016 – Q1 2019 ............................................................ 75 

Figure 37: Inbound roaming data traffic, Q4 2016 – Q1 2019 .............................................................. 75 

Figure 38: HHI for the wholesale roaming market – Voice volumes ................................................... 76 

Figure 39: HHI for the wholesale roaming market – Data volumes ..................................................... 77 

Figure 40: Voice services - Cumulative density distributions of in-group outbound retail roaming 

voice traffic (calls made) as % of the total outbound retail roaming voice traffic (calls made), 
per operator, for Q3 2017-Q1 2019........................................................................................... 78 

Figure 41: Data services - Cumulative density distributions of in-group outbound retail roaming data 

traffic as % of the total outbound retail roaming data traffic, per operator, for Q3 2017-Q1 
2019 ........................................................................................................................................... 79 

5 

 
 
Figure 42: Voice services: development of the average wholesale roaming rate for voice in the EEA, 

Q2 2016 to Q1 2019 .................................................................................................................. 80 

Figure 43: Data services: development of the average wholesale roaming rate for data in the EEA, Q2 

2016 to Q1 2019 ........................................................................................................................ 81 

Figure 44: Voice services: average wholesale roaming rate for voice in the Member States, Q2 2017 

and Q1 2019 .............................................................................................................................. 82 

Figure 45: Data services: average wholesale roaming rate for data in the Member States, Q2 2017 and 
Q1 2019 ..................................................................................................................................... 82 

Figure 46: Average in-group wholesale voice roaming rates versus average out-of-group wholesale 

voice roaming rates (Q1 2019) .................................................................................................. 84 

Figure 47: Average in-group wholesale data roaming rates versus average out-of-group wholesale data 
roaming rates (Q1 2019) ........................................................................................................... 84 

Figure 48: Type of wholesale roaming access for full and light MVNOs ............................................ 87 

Figure 49: Wholesale roaming prices paid for voice by MNOs (blue dots) and MVNOs (red dots), 

2018 ........................................................................................................................................... 88 

Figure 50: Wholesale roaming prices paid for data by MNOs (blue dots) and MVNOs (red dots), 2018

................................................................................................................................................... 89 

Figure 51: Voice services - Average wholesale domestic price plus EU weighted average MTR (as of 
July 2018) versus average wholesale roaming price paid by MVNOs (1 dot = 1 MVNO), 2018
................................................................................................................................................... 90 

Figure 52: Data services - Average wholesale domestic price versus average wholesale roaming price 

paid by MVNOs (1 dot = 1 MVNO), 2018 ............................................................................... 91 

6 

 
 
 
 
 
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 are 
widely known as "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  the  roaming  provider that  issued  the 
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 abolition of 
roaming  charges  in  a  specific  market  could  lead  to  domestic  price  increases  for  the 
customers of the operator in question. 

In accordance with the mandate given by the co-legislators, the Commission adopted, on 15 
December  2016,  the  Commission  Implementing  Regulation  (EU)  2016/2286  laying  down 
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  derogation  (hereinafter  referred  to  as 
the 'Implementing Regulation (EU) 2016/2286')3. 

The above set of rules has been applicable in the EU/EEA4 since 15 June 2017.  

In line with its reporting obligations laid down in the Roaming Regulation5, the Commission: 

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  Introduced  by  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 Decisions of the EEA Joint Committee No 173/2012 (available here), 92/2016 (available here) and 105/2017 
(available  here)  respectively  add  Regulations  531/2012,  2015/2120  and  2017/920  to  Annex  XI  to  the  EEA 
Agreement “Electronic communications, audiovisual services and information society”. 
5  In  this  report,  Regulation  (EU)  531/2012  as  amended  by  Regulation  (EU)  2015/2120  and  Regulation 
(EU) 2017/920 is called the "Roaming Regulation". 

7 

 
 
                                                 
  adopted on 12 December 2018 an interim Report to the European Parliament and the 
Council on the implementation of those rules over the first 18 months (hereinafter ‘the 
interim Report’)6; 

  published on 28 June 2019 a Staff Working Document (SWD) on the findings of the 
review of the rules on fair use policy and the sustainability derogation laid down in the 
Implementing  Regulation  (EU)  2016/2286  (hereinafter  ‘the  SWD  on  fair  use  policy 
and the sustainability derogation’)7. 

The  interim  Report  concluded  on  the  overall  success  of  the  RLAH  reform  over  the  first  18 
months, showing in particular that the demand for mobile consumption while travelling in the 
EU/EEA  had  rapidly  and  massively  increased  since  RLAH  was  introduced.  The  SWD 
published on 28 June 2019 concluded that the safeguards foreseen in the Roaming Regulation 
to  avoid  distortions  on  domestic  markets,  namely  fair  use  policy  and  the  sustainability 
derogation, had so far worked adequately where needed. 

As a follow up to the interim Report and the review of the fair use policy and sustainability 
derogation,  the  Roaming  Regulation  further  mandates  the  Commission  to  submit,  by  15 
December 2019, a comprehensive report to the European Parliament (EP) and the Council to 
assess the functioning of the roaming market under the RLAH rules. This is the subject of the 
Report from the Commission to the European Parliament and the Council on the review of the 
roaming  market  (the  Roaming  Review  Report)  and  of  this  accompanying  Staff  Working 
Document (SWD). 

2  SCOPE OF THE ROAMING REGULATION 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  EU/EEA  country  to  have  access  to 
mobile services (voice, SMS or data) from an MNO in another EU/EEA country8. 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 another 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 

6 Report 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, COM(2018) 822 final, available here. 
7 Commission Staff Working Document on the findings of the review of the rules on roaming fair use policy and 
the sustainability derogation laid down in the Commission Implementing Regulation (EU) 2016/2286 of 15 
December 2016, SWD(2019) 288 final, available here. 
8 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. 

8 

 
 
                                                 
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 Roaming Regulation 
and annually decreasing for data (see below in this section). 

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 aims in particular at ensuring that roaming at domestic price is used only 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  it  provides  services 
and issues 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 home Member State than abroad. If such a 
fair use policy is applied and, during a time window of at least four months, the customer has 
roaming  consumption  prevailing  over  domestic  consumption  or  presence  in  other  Member 
States of the Union prevailing on domestic presence, the operator has to alert the customer to 
verify whether there is any abusive or anomalous use of roaming services at domestic prices . 
After  a  period  of  at  least  14  days  from  the  date  of  the  alert,  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  prices9.  Beyond  that  volume,  the  operator  may  apply  a  small 
roaming  surcharge  not  exceeding  the  wholesale  roaming  price  cap  on  data10  (see  in  more 
detail below in this section). 

In any event, even in excess of fair use policy, the sum of the domestic price plus the small 
roaming  surcharge  applicable  may  not  exceed  the  roaming  fees  in  place  in  the  first  quarter 
2016 (prior to the transitional period that led to RLAH in June 2017)11. 

9 Implementing Regulation (EU) 2016/2286 provides that such a volume limit on roaming data must be equal to 
or  greater  than  twice  the  retail  price  of  the  mobile  bundle  divided  by  the  wholesale  roaming  price  cap.  This 
means that the user can consume the double (or more) of the data volume that their operator can buy (with the 
price paid by the user) at wholesale level to the visited operator, if the latter charges at the level of the cap 
10  Exceeding  a  data  volume  safeguard  can  only  lead  to  the  imposing  of  roaming  surcharges  on  data  roaming 
retail services (see BEREC Retail Roaming Guidelines, BoR (17) 56, point 70). 
11 For calls received, the maximum retail roaming surcharge applicable in excess of fair use policy is defined as 
the  weighted  average  Mobile  Termination  Rate  across  Member  States  and  is  therefore  revised  downwards 
annually by the Commission. It is equal to 0.0085 EUR/min in 2019. 

9 

 
 
                                                 
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  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  were  substantially  reduced  in  2017  by  the  Roaming 
Regulation12: as of 15 June 2017, the wholesale roaming price caps were reduced from 0.05 
€/min to 0.032 €/min for outgoing calls (voice), from 0.02 €/SMS to 0.01 €/SMS, and from 50 
€/GB to 7.7 €/GB for data. The data price caps are programmed, in the Roaming Regulation, 
to further decline every year until 2022 as displayed in Figure 1, 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. 

Figure 1: Regulated wholesale roaming data price cap, Q3 2017 – Q2 2022 

7,70 

6,00 

B
G
/
R
U
E

9

8

7

6

5

4

3

2

1

0

4,50 

3,50 

3,00 

2,50 

Q3'17

Q1'18

Q1'19

Q1'20

Q1'21

Q1'22

Note: Prior to 15 June 2017, the wholesale roaming data price cap was 50 €/GB (not shown because out of scale) 

12  In  2019,  the  following  wholesale  roaming  price  caps  are  applicable:  0.032  €  /minute  for  calls  made,  0.01 
€/sms, 4.5 €/GB. From 1 January 2020, the new cap for data will be 3.5 €/GB. 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. 

10 

 
 
 
                                                 
 
Being established by a Regulation, the roaming rules are directly applicable in all EU Member 
States  and  also  apply in  the  EEA  countries13.  The  Roaming  Regulation  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 Guidelines14 in March 2017 and 
Wholesale  Roaming  Guidelines15  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. 

3  SCOPE OF THE ROAMING REVIEW 

The review requirements are laid down in Article 19(3) of the Roaming Regulation: 

“The  Commission  shall  (…),  after  consulting  BEREC,  submit  biennial  reports  to  the  European 
Parliament  and  to  the  Council,  accompanied,  if  appropriate,  by  a  legislative  proposal  to  amend  the 
maximum wholesale charges for regulated roaming services laid down in this Regulation. The first such 
report shall be submitted by 15 December 2019. 

Those biennial reports shall include, inter alia, an assessment of: 

(a) the availability and quality of services, including those which are an alternative to regulated retail 
voice, SMS and data roaming services, in particular in the light of technological developments; 

(b)  the  degree  of  competition  in  both  the  retail  and  wholesale  roaming  markets,  in  particular  the 
competitive  situation  of  small,  independent  or  newly  started  operators,  and  MVNOs,  including  the 
competition effects of commercial agreements and the degree of interconnection between operators;  

(c) the extent to which the implementation of the structural measures provided for in Articles 3 and 4, 
and, in particular, on the basis of the information provided by the national regulatory authorities, of the 
procedure  for  prior  authorisation  laid  down  in  Article  3(6),  has  produced  results  the  development  of 
competition in the internal market for regulated roaming services; 

(d) the evolution of the retail tariff plans available; 

(e) changes in data consumption patterns for both domestic and roaming services; 

(f)  the  ability  of  home  network  operators  to  sustain  their  domestic  charging  model  and  the  extent  to 
which exceptional retail roaming surcharges have been authorised pursuant to Article 6c; 

(g)  the  ability  of  visited  network  operators  to  recover  the  efficiently  incurred  costs  of  providing 
regulated wholesale roaming services; 

13 Norway, Iceland, Liechtenstein. 
14  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. 
15  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. 

11 

 
 
                                                 
(h)  the  impact  of  the  application  of  fair  use  policies  by  operators  in  accordance  with  Article  6d, 
including the identification of any inconsistencies in the application and implementation of such fair use 
policies.” 

All elements listed above are analysed and assessed in the remainder of this report. 

4  THE COMMISSION’S APPROACH TO THE ROAMING REVIEW 

In  order  to  cover  all  review  requirements  of  the  Roaming  Regulation  listed  above,  the 
Commission  services  have  conducted  the  following  work  streams  and  used  the  following 
inputs and data sources. 

4.1 

Information and data gathering on wholesale and retail roaming markets  

4.1.1  Operators’ data collected for the BEREC International Roaming Benchmark Reports 

BEREC is mandated by the co-legislators in the Roaming Regulation to regularly collect data 
from NRAs on roaming developments at retail and wholesale levels. For that purpose BEREC 
and NRAs run a dedicated questionnaire twice a year to collect the relevant data from mobile 
operators  throughout  the  EU,  in  particular  data  on  volumes  of  roaming  traffic  (retail  and 
wholesale),  wholesale  roaming  revenues,  wholesale  roaming  rates  and  information  on 
wholesale roaming contracts. For the purposes of this review, the Commission services have 
had  access  to,  and  analysed,  these  data.  Such  data  are  confidential  and  are  published  at 
country and EU aggregate levels. Data shown at operator level are anonymised. 

4.1.2  Online surveys 

In  order  to  complement  the  quantitative  market  information  provided  by  the  BEREC 
Benchmark data collection, the Commission and BEREC have jointly run two online surveys 
of  MNOs,  MVNOs  and  NRAs  in  June  2018  and  March  2019  to  gather  information  on  the 
implementation of fair use policy, of the sustainability derogation, as well as other elements to 
be assessed under this review such as quality of services or misuses/fraudulent usage of roam-
like-at-home16. 

4.2  Data analysis  

The  analysis  of  the  operators’  data  collected  for  the  BEREC  Benchmark  exercise  and  the 
analysis of the data collected through the online surveys were conducted by DG CNECT and 
the Competence Centre on Microeconomic Evaluation (CC-ME) of the Joint Research Centre 

16 91 MNOs, i.e. most MNOs in the EU/EEA, and 89 MVNOs replied to the online survey in March 2019. 87 
MNOs and 81 MVNOs responded to the survey in June 2018. 

12 

 
 
                                                 
(JRC)17. DG CNECT has also relied on BEREC's analysis of this data carried out in parallel 
to the Commission's analysis (see section 4.4). 

4.3  External studies  

4.3.1  Study to estimate the costs of providing wholesale roaming services 

In  order  to  estimate  the  costs  of  providing  wholesale  romaing  services  in  the  EU/EEA,  the 
Commission  ordered  an  external  study  to  AXON  Partners18.  The  study  was  conducted 
between  March  2018  and  June  2019.  Building  upon  cost  models  used  by  NRAs  for  mobile 
networks  and  on  the  cost  model  developed  during  the  last  roaming  review19,  the  contractor 
has developed a cost model to estimate the costs of providing wholesale roaming services in 
each  EU  Member  State  and  EEA  country20.  The  cost  model  was  developed  in  close 
collaboration  with  the  BEREC  International  Roaming  Expert  Working  Group,  BEREC 
experts on terminationrates and NRAs, in particular via the coordination of the study work by 
the Steering Commmittee composed of DG CNECT and 8 NRAs21.  

The methodology, input data gathering exercise, consultation process and final results of the 
study  are  described  in  section  6.  The  final  version  of  the  cost  model  developed  by  the 
contractor is described in more detail in the final report of the study, which was published on 
24 July 2019 together with the final results and a public version of the model accompanied by 
the necessary documentation22. 

4.3.2  Study to assess technological and market developments that might have an impact on 

the roaming market 

The  Commission  ordered  to  WIK  Consult  an  external  study  on  technological  and  market 
developments that might have an impact on the roaming market23. The purpose of the study 
was  to  assess  the  availability  and  quality  of  services,  which  are  an  alternative  to  regulated 
retail  voice,  SMS  and  data  roaming  services,  in  particular  in  the  light  of  technological 
developments.  The  study  was  conducted  between  December  2018  and  June  2019.  The 

17 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/.  
18 Study SMART 2017/0091 'Assessment of the cost of providing mobile telecom services in the EU/EEA' by 
AXON, July 2019, available here. 
19 Study SMART 2015/006 "Assessment of the cost of providing wholesale roaming services in the EU", TERA 
Consultants, published in June 2016, available here. 
20 Except Iceland, Liechtenstein and Luxembourg which have not provided the necessary data to build the model 
in these three countries 
21 ACM (Netherlands), AGCOM (Italy), EETT (Greece), Arcep (France), BNetzA (Germany), CNMC (Spain) 
DBA (Denmark), Ofcom (UK) 
22 Available here. Note that the public version of the model is based on a hypothetical operator in hypothetical 
country in order to preserve the confidentiality of the input data to the model. 
23 Study SMART 2018/0012 "Technological developments and roaming" by WIK Consult, July 2019, available 
here. 

13 

 
 
                                                 
contractor  followed  a  modified  greenfield  approach  to  assess  the  competitive  impact  of 
various technological developments in the roaming market, including: 

(a)  Technologies and services that enable roaming bypass: wi-fi and wi-fi aggregation, Over-

the-top (OTT) voice and messaging, Rich Communication Services. 

(b) Technological  developments  and  platforms  facilitating  competition  in  the  roaming 
services: virtual SIM, embedded SIM, 5G and network slicing, wholesale capacity trading 
platforms, Local Break-Out. 

(c)  The role of new business models and players in the roaming space: verticals, equipment 
manufacturers  and  Operating  Systems  providers,  communication  application  providers 
etc. 

The  findings  of  the  study  are  presented  in  detail  in  the  final  report24  published  on  24  July 
2019. An overview of these findings and main conclusions is presented in section 8. 

4.3.3  Study on mobile broadband prices 

The Commission publishes every year the “Mobile Broadband Prices in Europe” which reports on 
the  level  of  domestic  retail  mobile  prices  in  EU  Member  States  and  in  a  number  of  non-EU 
countries.  For  the  purpose  of  cross-country  comparisons,  the  study  uses  the  standard  mobile 
internet usage baskets defined by the Organisation for Economic Co-operation and Development 
(OECD).  The  results  of  this  study  have  been  used  to  monitor  the  evolution  of  domestic  mobile 
prices in the EU over the last years. 

4.4  BEREC input 

The  Commission  services  have  worked  continuously  and  closely  with  the  International 
Roaming  BEREC  Expert  Working  Group  (EWG)  for  the  purposes  of  this  review. 
Implemention-related  work  and  questions  raised  by  operators,  end  users  and  NRAs  since 
RLAH  rules  have  been  adopted  have  been  discussed  with  the  EWG  and  have  fed  in  this 
review. In addition, NRAs were closely involved in the Commission’s external study to assess 
the costs of providing wholesale roaming services (see section 4.3.1).  

4.4.1  Benchmark Reports 

BEREC is mandated by the co-legislators in the Roaming Regulation to regularly collect data 
from NRAs on roaming developments at retail and wholesale level (e.g. traffic, prices). Based 
on  these  data,  BEREC  publishes  twice  a  year  country-level  results  in  the  BEREC 
International  Roaming  Benchmark  Report  in  March  and  October  every  year.  BEREC 
Benchmark Reports published since June 2017 have been used for the purposes of this review. 

24Available here 

14 

 
 
                                                 
4.4.2  Transparency Reports 

BEREC  is  mandated  by  the  co-legislator  in  the  Roaming  Regulation  to  collect  data  from 
NRAs  on  transparency  and  comparability  of  roaming  tariffs  once  a  year.  For  this  purpose 
NRAs are running another data collection from mobile operators in August every year. Based 
on these data, BEREC publishes country-level results in the BEREC Report on Transparency 
and  Comparability  of  International  Roaming  Tariffs  in  December  every  year.  BEREC 
Transparency  Reports  published  since  June  2017  have  been  used  for  the  purposes  of  this 
review. 

4.4.3  BEREC  Opinion  on  the  roaming  market  (June  2019)  and  BEREC  Supplementary 

analysis on wholesale roaming costs (September 2019) 

In line with the obligation to consult BEREC before submitting the review Report to EP and 
Council in December 2019, the Commission services requested BEREC to provide its formal 
Opinion on the functioning of the roaming market by 19 June 2019. The Review Report and 
this  SWD  take  utmost  account  of  the  BEREC  Opinion25  and  BEREC  Supplementary  cost 
analysis26 published on 19 June 2019 and 20 September 2019 respectively.  

4.5  European Parliament study  

In November 2018, the European Parliament published a study entitled “Roaming: One year 
after  implementation”,  which  was  prepared  at  the  request  of  the  European  Parliament’s 
Committee  on  Industry,  Research  and  Energy27.  The  study  reviews  the  retail  and  wholesale 
roaming  markets  during  the  first  year  after  the  introduction  of  the  RLAH  regime.  It 
acknowledges  its  benefits  to  the  retail  roaming  market  and  makes  certain  recommendations 
focusing  mainly  on  the  wholesale  regulation,  including  adjusting  the  wholesale  caps.  The 
European Commission has taken note of the study, some recommendations of which are also 
reflected in theBEREC Opinion. 

5 

 COMPETITION IN RETAIL ROAMING MARKETS 

5.1  Evolution of retail (outbound) roaming volumes  

5.1.1  The introduction of RLAH has lead to an explosive increase in roaming traffic 

The  introduction  of  RLAH  and  the  ensuing  elimination  of  roaming  charges  in  the  EU/EEA 
from 15 June 2017 has triggered an immediate and massive increase in retail roaming traffic. 
The volume of roaming phone calls made increased by 2.5 times in Q3 2017, compared to one 
year before and by almost 2 times in Q4 2017, Q1 2018 and Q2 2018, compared to one year 
before (Figure 2). In summer 2018 (Q3 2018), the volume of roaming phone calls made was 

25 BEREC Opinion on the functioning of the roaming market as input to EC evaluation, BoR(19)101, 19  June 
2019, available here (hereinafter ‘BEREC Opinion’). 
26 BEREC Supplementary analysis on wholesale roaming costs, BoR(19)168, 20 September 2019, available here. 
27 Available here. 

15 

 
 
                                                 
about 3 times higher than in the last summer before RLAH (Q3 2016). The increase of traffic 
continues, though at a much lower level, even when comparing quarters after the introduction 
of RLAH (12% in Q4 2018 and 9% in Q1 2019, compared to one year before). 

Figure 2: EEA retail roaming voice traffic (calls made), Q2 2016 – Q1 2019 (millions of 
minutes) 

Source: Based on 23rd International Roaming BEREC Benchmark Report 

In the first three quarters from the introduction of RLAH (Q3 2017, Q4 2017 and Q1 2018), 
mobile data consumption while roaming was around 5 times above its level one year before 
(5.3,  5  and  4.9  times  respectively,  see  Figure  3).  In  Q2  2018  and  Q3  2018,  mobile  data 
consumption while roaming was respectively 15 and 12 times more compared to its level two 
years before. In Q4 2018 and Q1 2019 the increase compared to one year before remains high 
(above 80%), even though both comparisons are entirely after the introduction of RLAH. 

Figure 3: EEA retail roaming data traffic, Q2 2016 – Q1 2019 (millions of GB) 

Source: Based on 23rd International Roaming BEREC Benchmark Report 

16 

 
 
 
 
During  the  first  year  of  RLAH,  travellers  called  on  average  about  1.7  times  more  while 
roaming  than  before  the  implementation  of  RLAH  (Figure  4)28.  During  that  first  year,  they 
used on average almost 4 times more data while roaming than before RLAH (Figure 5)29. In 
Q4 2018 and Q1 2019 we observe a decrease in the average consumption of voice traffic per 
roamer (6% and 7%), which should be attributed to the increase in the number of subscribers 
using  roaming.  In  contrast,  the  average  consumption  of  data  traffic  per  roamer  continues  to 
increase at a high pace (51% in Q4 2018 and 38% in Q1 2019 compared to one year before). 

Figure 4: EEA average voice roaming consumption (calls made) per month per roaming 
subscriber, Q2 2016 – Q1 2019 (minutes per month) 

Source: Based on 23rd International Roaming BEREC Benchmark Report 

28 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. 
29 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 

 
 
 
 
                                                 
Figure 5: EEA average data roaming consumption per month per roaming subscriber, 
Q2 2016 – Q1 2019 (MB per month) 

Source: Based on 23rd International Roaming BEREC Benchmark Report 

All  Member  States  experienced  a  considerable  increase  in  roaming  consumption  by 
subscribers  during  the  first  year  of  RLAH30.  Particularly  high  increases  in  customers' 
EU/EEA  roaming  consumption  for  voice  (by  3  to  5  times)  were  observed  by  Bulgarian, 
Croatian,  Polish  and  Romanian  operators  (red  bars  in  Figure  6).  In  contrast,  domestic 
consumption  has  been  stable  over  the  same  period  (blue  bars  in  Figure  6).  The  increase 
observed in roaming voice consumption is therefore entirely due to the introduction of RLAH.  

30 The comparison is made on the roaming consumption in the period from Q4 2016 to Q2 2017 on the one hand 
(before RLAH) and in the period from Q4 2017 to Q2 2018 on the other hand (after RLAH). 

18 

 
 
 
                                                 
Figure  6:  Voice  services  -  Ratio  between  the  total  volumes  after  RLAH  (Q4  2017  -  Q2 
2018) and the total volumes over the last period before RLAH (Q4 2016 - Q2 2017), for 
retail domestic traffic (blue bars) and outbound roaming traffic (red bars) 

Source: Data collected for the 19th-22nd International Roaming BEREC Benchmark Reports. JRC calculations. 

The  increase  in  roaming  data  consumption  during  the  first  year  of  RLAH  was  even  higher. 
Bulgarian,  Croatian,  Czech  and  Polish  operators  observed  an  increase  in  roaming  data 
consumption by 9 times or more, while in several other countries operators have observed an 
increase  in  roaming  data  consumption  by  5 times  and  more (Austria,  Cyprus,  Greece,  Italy, 
Latvia,  Slovenia  and  Spain)  (red  bars  in  Figure  7).  In  all  Member  States,  the  increase  in 
domestic consumption has been much smaller than the increase in roaming consumption over 
the same period (blue bars in Figure 7). The increase observed in roaming data consumption 
is therefore mostly due to the introduction of RLAH. 

19 

 
 
 
Figure  7:  Data  services  -  Ratio  between  the  total  volumes  after  RLAH  (Q4  2017  -  Q2 
2018) and the total volumes over the last period before RLAH (Q4 2016 - Q2 2017), for 
retail domestic traffic (blue bars) and outbound roaming traffic (red bars) 

Source: Data collected for the 19th-22nd International Roaming BEREC Benchmark Reports. JRC calculations 

In  the  three  Member  States  where  all  MNOs  have  been  granted  sustainability  derogations 
since  15  June  2017  (Finland,  Lithuania  and  Estonia31,  see  section  5.3),  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. Data consumption in Estonia and 
Finland  has  increased  by  almost  3  times  while  in  Lithuania  by  almost  4  times.  Voice 
consumption has increased by 2 times in Lithuania and more than 1.5 times in Estonia. This is 
because  operators  which  were  granted  derogations  nonetheless  provided  roaming  services 
without  surcharges  to  some  extent  (section  5.3)  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 consequently with increased demand.  

5.1.2  Retail (outbound) roaming traffic remains a small fraction of domestic traffic 

The evidence from BEREC International Roaming Benchmark Reports shows that, despite its 
massive increase, roaming traffic remains only a small fraction of domestic traffic. As shown 

31  In  Poland,  three  MNOs  were  granted  the  derogation  in  the  course  of  the  first  semester  2018.  The  effect  of 
these derogations is progressively becoming visible from Q2 2018 data. Therefore, its impact in the period under 
consideration here is still marginal. 

20 

 
 
 
                                                 
in Figure 8, in the first year of RLAH, the retail roaming voice traffic represented less than 
6.8%  of  the  retail  domestic  voice  traffic  for  90%  of  the  operators.  The  increase,  since  the 
introduction of RLAH, is visible: before RLAH, the retail roaming voice traffic was less than 
4.2% of the retail domestic voice traffic for 90% of the operators. The seasonality of roaming 
can  be  observed  as  the  curve  representing  the  summer  period  under  RLAH  (Q3  2018)  is 
shifted to the right, showing that retail roaming voice traffic represents a higher proportion of 
domestic  voice  traffic  during  summer  for  most  operators  than  during  the  rest  of  the  year. 
However,  even  in  summer  2018  with  the  highest  roaming  traffic  recorded  so  far,  the  retail 
roaming voice traffic was still less than 6.8% of the retail domestic voice traffic for 90% of 
the operators. 

Figure  8:  Voice  services  -  Cumulative  density  distributions  of  the  retail  (outbound) 
roaming voice traffic as % of the retail domestic voice traffic32. 

Source: Data collected for the 19th-23rd International Roaming BEREC Benchmark Report. JRC calculations. 
Note: 'pre-RLAH' covers the last period before RLAH (Q4 2016 - Q2 2017), 'post-RLAH’ covers the 
corresponding period after RLAH (Q4 2017 - Q2 2018). Q3 2018 is the last summer available. Q1 2019 is the 
last available quarter. 

32 The pre RLAH value is the average for the periods Q4 2016 to Q2 2017. The post RLAH value is the average 
for the periods Q4 2017 to Q2 2018. 

21 

 
 
 
 
                                                 
The same can be observed for retail roaming data traffic. As shown in  Figure 9, in the first 
year of RLAH, the retail roaming data traffic represented less than 6.2% of the retail domestic 
data traffic for 90% of the operators. Again, the increase since the introduction of RLAH is 
visible: before RLAH, the retail roaming data traffic was less than 2.8% of the retail domestic 
data  traffic  for  90%  of  the  operators.  In  the  case  of  data,  seasonality  is  much  more  marked 
than in the case of voice. The corresponding ratio for Q3 2018 (post-RLAH) is 10.7%.  

Figure  9:  Data  services  -  Cumulative  density  distributions  of  the  retail  (outbound) 
roaming data traffic as % of the retail domestic data traffic33. 

Source: Data collected for the 19th-23rd International Roaming BEREC Benchmark Reports. JRC calculations. 
Note: 'pre-RLAH' covers the last period before RLAH (Q4 2016 - Q2 2017), 'post-RLAH covers the 
corresponding period after RLAH (Q4 2017 - Q2 2018). Q3 2018 is the last summer available. Q1 2019 is the 
last available quarter. 

5.2 

Implementation of fair use policy  

Regulation (EU) 2016/2286 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.  

The Staff Working Document on the findings of the review of the rules on roaming fair use 
policy  and  the  sustainability  derogation  laid  down  in  the  Implementing  Regulation  (EU) 

33 The pre RLAH value is the average for the periods Q4 2016 to Q2 2017. The post RLAH value is the average 
for the periods Q4 2017 to Q2 2018. 

22 

 
 
 
 
                                                 
2016/228634  published  on  28  June  2019  (hereinafter  ‘the  SWD  on  fair  use  policy  and  the 
sustainability  derogation’)  analyses  in  detail  the  application  of  fair  use  policy,  based  on  the 
joint survey by the Commission and BEREC (see section 4.1.2). The analysis shows that the 
overwhelming  majority  of  operators,  i.e.  95%  of  MNOs  and  78%  of  MVNOs  have  utilised 
one of the FUP criteria to address abusive or anomalous use of roaming services at domestic 
prices (such as permanent roaming) by individual customers.  

A significant majority of operators (87% of MOs and 80% of MVNOs offering data bundles) 
have relied on the open data bundle limits35. A sizeable number of mobile operators rely on 
other  criteria,  notably  the  residence/stable  link  criterion36  (52%  of  MNOs  and  44%  of 
MVNOs),  the  4-month  window37  (41%  of  MNOs  and  26%  of  MVNOs)  and  the  pre-paid 
limits38 (32% of MNOs and 33% of MVNOs offering pre-paid tariff plans). 

While fair use policy is now a common practice among mobile operators, the overwhelming 
majority of roaming customers stay abroad for much shorter time periods and therefore do not 
need  to  worry  about  these  control  mechanisms.  As  noted  by  BEREC  in  its  Opinion  on  the 
roaming  market,  MNOs  that  have  responded  to  the  Joint  Commission/BEREC  survey  of 
March 2019 have alerted in total approximately 0.6% of their subscribers and have imposed a 
surcharge after the alert to half of them (i.e. approximately 0.3%).  

Also,  operators’  data  collected  in  the  framework  of  the  International  Roaming  BEREC 
Benchmark Data Reports, indicate that hardly more than 5.5% of the total roaming data traffic 
in  the  EU/EEA  and  slightly  below  4%  of  the  roaming  voice  traffic  is  subject  to  a  FUP 
surcharge  (Figure  10).  The  fact  that  the  share  of  roaming  voice  traffic  subject  to  a  FUP 
surcharge is significantly higher than the share of subscribers subject to a surcharge under the 
4-month control mechanism shows that this small proportion of long-term travellers generates 
a significantly higher proportion of the roaming voice traffic.  

34 Commission Staff Working Document on the findings of the review of the rules on roaming fair use policy 
and the sustainability derogation laid down in the Commission Implementing Regulation (EU) 2016/2286 of 15 
December 2016, SWD(2019) 288 final, available here. 
35 A mobile bundle is a subscription to a package of mobile services, usually including voice calls, SMS and data 
services. Operators may 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 (€4.5/GB in 2019). For a more detailed description as well as the other FUP criteria, please refer to the 
Regulation (EU) 2016/2286 (here) and the Commission’s Q&A on Roaming (here). 
36 Roaming customers should be be either normally residents or have any other stable link entailing frequent and 
substantial presence in the territory, where the operator is established.  
37  A  4-month  window  may  be  used  to  assess  prevailing  domestic  consumption  over  roaming  consumption  or 
prevailing domestic presence of the customer over presence in other Member States of the Union.  
38 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.  

23 

 
 
                                                 
Figure 10: Share of total EU/EEA retail roaming traffic which is subject to a surcharge 
in excess of FUP (%), Q4 2017 – Q1 2019 

Source: Based on data from 20th-23rd International Roaming BEREC Benchmark Data Report. 

Table 1 shows the Member States exhibiting the highest percentage of traffic subject to a FUP 
surcharge. In these Member States, FUP obviously plays a major role in mitigating the effects 
of abusive or anomalous use of roaming services at domestic price. 

Table 1: Member States with more than 10% of traffic being subject to FUP surcharge 

Member  States,  where  >10%  of 
voice traffic is  subject to a FUP 
surcharge 

Member  States,  where  >10%  of 
data  traffic  is  subject  to  a  FUP 
surcharge 

  Sweden (20%) 

  Bulgaria (15%) 

  Sweden (22%) 

  Poland (20%) 

  Bulgaria (18%) 

  Latvia (14%) 

  Romania (14%)  

  UK (11%) 

Source: Based on data from 23rd International Roaming BEREC Benchmark Data Report. 

Both  Figure  10  and  Table  1  indicate  that  the  proportion  of  data  traffic  subject  to  FUP 
surcharge is higher than the respective proportion of voice traffic. This is consistent with the 
fact  that  many  operators  use  the  open  data  bundles  limits,  beyond  which  the  operator  may 
impose a FUP surcharge only to roaming data traffic. 

The analysis in the SWD on fair use policy and the sustainability derogation shows that FUP 
measures have overall enabled operators to successfully address abusive or anomalous use of 
roaming  services  at  domestic  prices  (such  as  permanent  roaming)  by  individual  customers., 

24 

 
 
 
 
although  this  entails  some  costs  and  complexity.  According  to  the  data  from  the  joint 
Commission/BEREC survey of March 2019, less than 15% of respondents assesses any of the 
open  data  bundles,  4-month  window  or  stable link  as  unnecessary.  Also,  more  than  75%  of 
the  operators  that  have  applied  each  of  these  criteria  assess  them  as  effective  or  partially 
effective. 

Furthermore, as noted by BEREC in its Opinion on the roaming market, operators generally 
comply with the legal provisions when applying a FUP. In the few cases where breaches of 
those  rules  have  been  observed,  operators  have  corrected  their  offer  as  requested  by  the 
NRA.39  

BEREC has however noted the increasing number of zero-rated offers in the mobile market40 
and the need to clarify how such offers should be treated under RLAH. NRAs, in the context 
of  the  BEREC  International  Roaming  Expert  Working  Group  and  in  coordination  with  the 
Commission services, have agreed on a common approach to enforce the fair use policy rules 
on such offers. According to NRAs, applying the same domestic charging mechanism while 
roaming like at home implies that the consumption of zero-rated services may not be counted 
against the domestic data allowance while roaming in the EU/EEA, as it is the case at home. 
However,  a  fair  use  data  volume  limit  can  be  applied  while  roaming  in  the  EU/EEA,  in 
accordance  with  the  formula  provided  in  the  Regulation  (EU)  2016/2286  for  open  data 
bundles. Consumption of normal (non-zero-rated) services and of zero-rated services can be 
counted against this fair use limit41. In its Opinion on the roaming market, BEREC proposes 
to revise its Retail Roaming Guidelines accordingly, in order to facilitate a common approach 
on the assessment of zero-rated tariffs within the EU. 

Based on the analysis performed, the Commission services observed in the SWD on fair use 
policy  and  the  sustainability  derogation  that  the  evidence  available  would  not  support  a 
change in the scope of FUP - be it the duration of the time window, the level of the volume 
limit on data or the introduction of a volume limit on voice. Since the publication of the SWD 
in June 2019, the Commission services have not received any information nor additional data 
that would change that conclusion. 

Operators that, with a FUP designed in accordance with the Regulation (EU) 2016/2286, have 
faced  or  would  have  faced  levels  of  roaming  usage  that  threaten  their  domestic  charging 
model have been granted a sustainability derogations (section 5.3). As to fraud activities using 

39 In the BEREC Report on Transparency and Comparability of International Roaming Tariffs (December 2019) 
BEREC also refers to the complaints received by NRAs on FUP. 
40  Zero-rated  data  services  are  not  counted  against  the  data  allowance  of  the  subscription.  Consuming  such 
services  therefore  does  not  reduce  the  volume  of  data  available  to  the  user  in  a  given  billing  period.  In  most 
cases, zero-rated services are unlimited. 
41  This  interpretation,  followed  by  the  German  telecom  regulator  BundesNetzAgentur,  has  been  confirmed  by 
different  courts  in  Germany,  namely  the  Verwaltungsgericht  Köln  on  20  November  2018  (see  the  judgement 
here) and Landgericht Düsseldorf on 19 June 2019 (see the judgement here) 

25 

 
 
                                                 
roaming services, they can be tackled by specific appropriate measures that do not fall under 
the scope of FUP (section 7.5). 

5.3  Application of the derogation mechanism  

In  exceptional  and  specific  circumstances,  in  order  to  avoid  a  domestic  price  increase,  an 
operator  may  obtain  from  its  NRA  a  sustainability  derogation,  after  demonstrating  that  the 
provision of roaming services without the application of a surcharge would not be sustainable 
with its current domestic charging model.  

The  SWD  on  fair  use  policy  and  the  sustainability  derogation  analyses  in  detail  the 
application  of  sustainability  derogations,  based  on  the  joint  survey  by  the  Commission  and 
BEREC of March 2019. The analysis shows that the derogation mechanism has acted as an 
effective safeguard against possible distortions on the few markets where domestic charging 
model could have been at risk. The analysis also show that operators authorised by the NRA 
to apply a surcharge still largely offer RLAH. 

5.3.1  The number of sustainability derogations is getting smaller every year 

The  table  below  presents  the  number  of  derogations  that  have  been  granted  during  the  first 
two years of RLAH (June 2017 to May 2018, June 2018 to May 2019) and between June and 
October 2019, per Member State, split by type of operator (MNO and MVNO).  

Table  2:  Sustainability  derogations  granted  by  NRAs  during  the  first  two  years  of 
RLAH and between June and October 2019, split by MNOs and MVNOs  

Derogations granted 
between June 2017 and 
May 2018  

Derogations granted 
between June 2018 and 
May 2019 

Derogations granted 
between June 2019 and 
October 2019 

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

MVNO 
MNO 
2 
0 
AT 
1 
0 
BE 
1 
0 
DK 
0 
3 
EE 
0 
0 
ES 
1 
3 
FI 
3 
0 
FR 
4 
0 
IT 
1 
3 
LT 
3** 
4 
PL 
0 
1 
RO 
1 
0 
SI 
17 
14 
Total 
* In October 2019, for the first time a request from an MNO was rejected. One more request from an MNO is 
pending and the remaining 2 have not requested a derogation until now. 

MVNO 
2 
1 
0 
0 
0 
1 
6 
3 
1 
7 
0 
1 
23 

MVNO 
2 
1 
1 
0 
1 
1 
11 
4 
1 
8 
0 
1 
30 

MNO 
0 
0 
0 
0 
0 
3 
0 
0 
2 
0* 
1 
0 
6 

26 

 
 
 
 
  
** 3 more requests are pending.  
Sources: Commission's survey of NRAs, June 2018 (first year), Joint Commission/BEREC survey of NRAs, 
March 2019 (second year), NRA inputs (June 2019 to October 2019) 

Since  June  2019  (until  October  2019),  derogations  have  been  granted  to  6  MNOs42  and  17 
MVNOs43. Some derogations might still be renewed for some MNOs and MVNOs during the 
first semester of 202044. 

As expected, MVNOs have been the primary users of the sustainability derogation given their 
specific situation on the wholesale roaming market45. Over the first year of RLAH, about 2/3 
of the derogations have been granted to MVNOs (30 vs 14). Over the second year of RLAH, 
more than 60% of the derogations have been granted to MVNOs (23 vs 14). Since June 2019,  
74% of the derogations have been granted to MVNOs (17 vs 6). 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  during  the  first  two  years  of  RLAH,  namely,  Estonia,  Finland, 
Lithuania  and  Poland  (in  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  (i.e.  operators  in  these  countries 
have much more roaming traffic by their customers abroad than they receive roaming traffic 
from  foreign  users  on  their  networks).  However,  since  June  2019  (start  of  the  third  year  of 
RLAH), there has been a significant decrease in the number of derogation requests from the 
MNOs  in  these  Member  States.  In  Lithuania,  one  MNO  (the  incumbent)  did  not  request  to 
renew  the  derogation  anymore,  and  in  Estonia  none  of  the  MNOs  decided  to  renew  the 
derogation. Additionally, according to the most recent data, the Polish MNOs have started to 
record  a  profit  from  roaming  services  provided  in  the  EU  Member  States46,  and  in  October 
2019, for the first time a request for derogation from a Polish MNO was rejected. Hence, as 
expected by the Commission and BEREC, with the decreasing wholesale price caps on data, 
the  need 
joint 
Commission/BEREC survey of March 2019, NRAs are expecting to grant in total around 20 
derogations in 2020, which would amount to less than 50% of the derogations granted during 
the first year of RLAH. 

is  decreasing.  According 

sustainability  derogations 

the 

for 

to 

As  expected,  no  derogation  has  been  granted  to  MNOs  in  Member  States  which  are  net 
recipients of inbound roaming traffic. 

42 3 in FI, 2 in LT, 1 in RO.  
43 2 in AT, 1 in BE, 1 in DK, 1 in FI, 3 in FR, 4 in IT, 1 in LT, 3 in PL and 1 in SI.  
44 The last derogations to 3 PL MNOs were granted in the first semester of 2019 and are therefore still valid in 
December 2019. Their renewal will be at stake during the first semester of 2020. 
45 See section 7.4. 
46  The  analysis  of  Roam  Like  At  Home  functioning,  Office  of  Electronic  Communications,  1  August  2019, 
available here.  

27 

 
 
 
                                                 
5.3.2  The  maximum  surcharges  granted  by  the  NRAs  are  low  and  generally  decreasing 

every year 

The  maximum  surcharges  allowed  by  the  NRAs  are  normally  at  or  –  sometimes  even 
significantly – below the wholesale roaming price caps, so that, when a surcharge is applied, 
the  customers  concerned  pay  only  a  small  fraction  of  what  they  used  to  pay  for  roaming 
services before June 2017 (less than 10% for data). As a result of the partial application of the 
surcharge and its modest level, increases in retail roaming traffic by subscribers from Finland, 
Lithuania, Estonia and Poland are comparable to that observed in the other Member States. 

In  most  cases,  the  new  maximum  surcharges  allowed  by  NRAs  are  lower  than  those  of  the 
first  and  second  derogations.  One  reason  is  the  decreasing  wholesale  roaming  prices.  For 
example, in Lithuania, the maximum surcharges for the outgoing calls granted for the period 
2019-2020 for the two MNOs and the MVNO which were granted the derogation decreased 
by 100%, 20% and 71% respectively compared to the year before. For data, the decrease was  
57%, 27% and 43% respectively for the same periods.   

5.3.3  The share of EU/EEA roaming traffic subject to a surcharge due to the sustainability 

derogation has remained marginal  

Figure 11 shows the development, in the EU/EEA, of roaming voice and data traffic subject to 
a surcharge due to the sustainability derogation, as % of the total roaming traffic. Both remain 
at  marginal  levels,  below  3.5%  and  1.5%  respectively.  The  increase  observed  since  2018  is 
likely to be linked to several of the first derogations granted only in Q1-Q2 2018 in Poland, 
the  biggest  market  with  derogations,  and  the  progressive  application  of  these  derogations 
since then in that Member State (see the start of the derogation in Poland in Q1 and Q2 2018 
in Figure 12).   

Figure 11: Development of % of voice and data roaming traffic in the EU/EEA subject 
to a surcharge, due to the sustainability derogation, Q3 2017 – Q1 2019 

Source: Based on data from the 20th-23rd International Roaming BEREC Benchmark Report 

28 

 
 
 
Note: The Q3’17 figures take on board data updates, provided by some operators after the publication of the 20th 
International Roaming BEREC Benchmark Report 

5.3.4  Operators  having  been  granted  the  derogation  have  used  the  surcharge  with 

parsimony 

Figure 12 and Figure 13 show, in the specific Member States where the derogation has been 
granted to one or more MNOs, the development of roaming voice and data traffic subject to a 
surcharge due to the sustainability derogation, as % of the total outbound roaming traffic from 
these  Member  States.  In  all  other  Member  States47  the  corresponding  percentages  are  at  (or 
close to) zero.  

Figure 12: Development of % of voice roaming traffic subject to a surcharge due to the 
sustainability  derogation  in  the  Member  States  where  derogations  were  granted  to 
MNO(s), Q3 2017 – Q1 2019 

Source: Based on data from the 20th-23rd International Roaming BEREC Benchmark Report 
Note: The Q3’17 figures take on board data updates, provided by some operators after the publication of the 20th 
International Roaming BEREC Benchmark Report. 

47 Where the derogation has been granted to MVNOs. 

29 

 
 
 
                                                 
Figure 13: Development of % of data roaming traffic subject to a surcharge due to the 
sustainability  derogation,  in  the  Member  States  where  the  derogation  was  granted  to 
MNO(s), Q3 2017 – Q1 2019 

Source: Based on data from the 20th-23rd International Roaming BEREC Benchmark Report 
Note: The Q3’17 figures take on board data updates, provided by some operators after the publication of the 20th 
International Roaming BEREC Benchmark Report. 

First  of  all,  the  figures  show  that  even  in  those  Member  States  where  all  MNOs  have  been 
granted  the  derogation  (Estonia,  Finland,  Lithuania),  in  general  only  a  minority  of  the 
outbound  roaming  traffic  has  been  subject  to  a  surcharge  (exceptions  observed  only  in 
Lithuania for some quarters of 2018). This shows that MNOs in those countries have used the 
derogation in a limited manner and have provided large amounts of RLAH to their customers.   

Second,  the  trend  in  using  the  surcharge  is  overall  decreasing  in  Estonia,  Finland  and 
Lithuania,  where  derogations  were  granted  from  the  beginning  of  RLAH.  In  these  three 
Member States voice traffic subject to a surcharge due to the derogation has been decreasing 
either from the beginning (Finland) or from Q1 2018 (Estonia, Lithuania). In Finland the drop 
is  more  than  half.  Roaming  data  traffic  subject  to  a  surcharge  due  to  the  derogation  is  also 
presenting a decreasing trend either from Q1 2018 (Finland), Q3 2018 (Estonia) or Q4 2018 
(Lithuania). In Romania the proportion of voice and data traffic subject to a surcharge due to 
derogation  decreased  for  the  first  time  in  Q1  2019.  The  decreasing  trend  in  these  Member 
States  can  be  attributed,  on  the  one  hand,  to  the  reduced  negative  impact  of  wholesale 
roaming  costs  and,  on the other hand, to an increasing expectation of consumers for RLAH 
services, which could act as a competitive pressure. 

In  contrast, in  Poland, roaming  traffic subject to a surcharge due to the derogation, as  % of 
total  roaming  traffic, continues to  present an increasing trend, for both  voice and data. This 
evolution is due to the late granting of most of the derogations in Q1-Q2 2018 only and to the 
application of the surcharge to new contracts. 

30 

 
 
 
Given that none  of the Estonian operators has renewed its  request for derogation from June 
2019,  no  roaming  traffic  from  Estonia  is  expected  to  be  subject  to  a  surcharge  due  to  the 
derogation since June 2019 (data not available yet). In Lithuania, the share of roaming traffic 
subject to a surcharge due to the derogation is expected to be significantly reduced since June 
2019  compared  to  the  two  Figures  above,  following  the  non-renewal  of  the  incumbent’s 
derogation in June 2019. The first rejection of a request for derogation by an MNO in Poland 
in October 2019 should also lead to a decrease of the overall share of roaming traffic subject 
to a surcharge due to the derogation. 

5.3.5  The application of the derogation mechanism should continue to decrease 

Based on the analysis performed, the Commission services observed in the SWD on fair use 
policy and the sustainability derogation that the sustainability mechanism has been applied as 
intended  by  the  co-legislator  and  adequately  worked  as  a  safeguard  to  avoid  distortions  on 
domestic markets where needed. In its Opinion on the roaming market, BEREC notes that it 
has been a useful tool for some operators to achieve the overall sustainability of the RLAH. In 
addition, the derogation has not prevented the concerned end users to massively benefit from 
the new roaming rules. 

As  concluded  in  the  SWD  on  fair  use  policy  and  the  sustainability  derogation,  the 
Commission  expects  the  application  of  the  derogation  to  continue  to  decline,  as  further 
reductions  in  regulated  wholesale  roaming  price  caps  for  mobile  data  services  take  effect, 
improving  the  sustainability  of  RLAH  in  the  countries  concerned.  In  its  Opinion  on  the 
roaming market, BEREC notes that the derogation mechanism concerns a small and shrinking 
part of the market and that NRAs too expect the number of derogations to further decrease in 
the coming years. 

5.4  Use of alternative roaming tariff plans  

Pursuant to Article 6e(3) of the Roaming Regulation, mobile operators may offer alternative 
tariffs,  which  deviate  from  the  RLAH  requirements  laid  down  in  Articles  6a,  6b  and  6c. 
Mobile  subscribers  can  choose  such  tariffs  but  this  choice  must  be  deliberate  and  requires 
awareness  about  the  existence  of  the  regulated  tariff  (i.e.  RLAH  in  the  EU/EEA)  and  the 
nature  of  the  roaming  advantages  which  would  thereby  be  lost.  Furthermore,  subscribers 
using  alternative  tariffs  should  have  the  possibility  to  switch  back  to  the  regulated  RLAH 
tariffs, at no extra charge and without any conditions or restrictions pertaining to elements of 
the subscriptions other than roaming.   

As  assessed  in  the  BEREC  Report  on  Transparency  and  Comparability  of  International 
Roaming  Tariffs48,  such  tariffs  are  mostly  addressed  to  the  business  segment  providing  for 
example  special  pay-as-you  go  tariffs,  customized  price  plans  for  large  customers,  pooling 
tariffs and day-passes. According to the above report, 31% of the operators that responded to 

48 BEREC Report on Transparency and Comparability of International Roaming Tariffs (December 2019) 

31 

 
 
                                                 
the  BEREC  questionnaire  offer  alternative  roaming  tariffs,  in  the  form  of  daily,  weekly, 
monthly or other packages. 

Nevertheless  users’  interest  in  alternative  tariffs  has  substantially  decreased,  since  the 
introduction  of  RLAH.  As  reflected  in  Figure  14,  roaming  traffic  from  alternative  tariffs 
dropped in Q3 2017 to less than half of its level before. Roaming voice traffic from alternative 
tariffs  has  remained  stable  since  Q1  2018  to  around  6%  of  the  total  roaming  voice  traffic. 
Roaming data traffic from alternative tariffs has further decreased from around 6% in the first 
three quarters of RLAH (Q3 2017 to Q1 2018) to around and even below 5% as of Q2 2018.  

Figure 14: % of roaming voice and data traffic from alternative tariffs in total EU/EEA 
roaming traffic, Q4 2016 – Q1 2019 

Source: Based on data from the 19th-23rd International Roaming BEREC Benchmark Report 

In the majority of countries the use of alternative tariffs is marginal and remains well below 
5%  for  either  voice  or  data.  Only  in  few  cases  the  share  of  EU/EEA  roaming  traffic  under 
alternative tariffs exceeds 10% of roaming traffic (Estonia, Germany, Ireland, Italy, Lithuania 
and  Luxembourg  for  voice;  Estonia,  Germany,  Ireland, Italy,  Luxembourg  and  Slovakia  for 
data). 

The declining trend of EU/EEA roaming traffic from alternative tariffs is also reflected in the 
following figures, depicting the cumulative density function for the proportion of retail traffic 
coming from alternative tariffs for voice (Figure 15) and for data (Figure 16) 

32 

 
 
 
Figure 15: Cumulative density functions of the % of outbound voice traffic coming from 
alternative tariffs per operator49 

Source: Data collected for the 19th-23rd International Roaming BEREC Benchmark Reports. JRC caculations. 

Figure 16: Cumulative density functions of the % of outbound data traffic coming from 
alternative tariffs per operator50 

Source: Data collected for the 19th-23rd International Roaming BEREC Benchmark Reports. JRC calculations. 

49 'pre-RLAH' covers the last period before RLAH (Q4 2016 - Q2 2017), 'post-RLAH covers the corresponding 
period after RLAH (Q4 2017 - Q2 2018). Q1 2019 is the last available quarter. 
50 : 'pre-RLAH' covers the last period before RLAH (Q4 2016 - Q2 2017), 'post-RLAH covers the corresponding 
period after RLAH (Q4 2017 - Q2 2018). Q1 2019 is the last available quarter. 

33 

 
 
 
 
                                                 
5.5  Evolution of domestic tariff plans 

5.5.1  Domestic prices 

As  noted  by  BEREC  in  its  Opinion  on  the  roaming  market,  operators  report  to  have 
maintained the overall availability of their tariff plans under RLAH. Less than 15% of MNOs 
and 10% of MVNOs report to have ceased offering certain domestic tariff plans. According to 
BEREC,  in  most  cases,  the  overall  domestic  tariff  structure  has  not  changed.  Tariff  plans 
which  have  been  removed  relate  to  certain  data-only  tariffs,  certain  pre-paid  plans,  legacy 
tariffs with unitary roaming prices or tariff plans with high SMS volumes. 

Furthermore, BEREC observes that domestic consumption patterns have remained relatively 
stable  following  the  introduction  of  RLAH,  and  so  has  the  average  retail  revenue  per  user 
(ARRPU).  

In the same direction, according to the study “Mobile Broadband Prices in Europe”51, between 
2018 and 2019 (i.e. the second year of application of the RLAH rules) there  is no trend for 
increasing  domestic  prices.  On  the  contrary,  the  overall  trend  on  average  EU  prices  is 
decreasing for all voice and data baskets except the one with unlimited calls as well as for all 
data-only baskets, as reflected in the following table. A similar observation was made in the 
interim Report52; 

Table 2: Change in the average EU price for mobile services, 2018-2019. 

Change in average EU 
price for voice and data 
baskets, 2018-2019 

Change in average EU 
price for data only 
baskets, 2018-2019 

100MB, 
30 calls 

500MB, 
100 calls 

1GB,  
300 calls  

2GB,  
900 calls  

2GB,  
100 calls 

5GB,  
300 calls 

5GB,  
unlim calls 

-14% 

-2% 

-4% 

-1% 

-7% 

-10% 

7% 

512MB 

1GB 

2GB 

5GB 

10GB 

20GB 

50GB 

-8% 

-12% 

-11% 

-14% 

-15% 

-14% 

-13% 

Source:  Empirica/TUV  study  on  Mobile  broadband  prices  in  Europe  2018-2019  (2019  not  published  yet) 
commissioned by the European Commission. 
The comparison is between prices collected in July 2018 and in February 2019. 

5.5.2  Domestic-only tariff plans 

According  to  the  most  recent  BEREC  International  Roaming  Benchmark  Reports53,  the 
proportion of EU/EEA subscribers that had a roaming-enabled SIM card has remained stable 

51 “Mobile Broadband Prices in Europe in 2018” available here and “Mobile Broadband Prices in Europe 2019” 
(to be published), conducted for the European Commission by Empirica/TUV. 
52 Report 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, COM(2018) 822 final, available here. 
53  20th, 21st,22nd  and 23rd International Roaming BEREC Benchmark Data Report, covering respectively April 
2017 to March 2019. 

34 

 
 
 
 
                                                 
above  95%  since  summer  2017.  SIM  cards  restricted  to  domestic  use  (i.e.  SIM  cards 
providing  no  roaming  service  abroad  at  all)  are  in  most  cases  serving  local  communication 
needs  and/or  data-only  plans  or  fixed  wireless  access  products  that  can  only  be  used  at  a 
specific location54.  

As  Figure  17  shows,  this  proportion  has  declined  in  Bulgaria  (from  30.9%  to  16%),  Latvia 
(from 23.7% to 22%) and Estonia (from 13.1% to 12%) but has increased in Romania (from 
21% to 48%). From the other Member States, the proportion of domestic-only subscribers has 
evolved substantially over the same period in Austria (increase from from 3.2% to 9%) and in 
the Netherlands (decline from 5.4% to almost 0).  

54 BEREC Report on Transparency and Comparability of International Roaming Tariffs (December 2019). Only 
2% of operators declared having removed roaming services from some specific tariff plans, compared to 17% the 
year before. 

35 

 
 
                                                 
Figure 17: % of domestic-only subscribers per country 

(*) Data for Hungary are not presented. 
Source: Data collected for the 20th and 23rd International Roaming BEREC Benchmark Reports. JRC 
calculations. 

In the last quarter available (Q1 2019), MVNOs have a substantially higher share of domestic-
only  subscribers  than  MNOs  in  Cyprus,  Lithuania  and  Spain,  while  the  opposite  is  true  in 
Romania.  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.  

5.6  Quality of services  

The Roaming Regulation includes obligations on mobile operators concerning roaming prices 
at retail level and wholesale levels. It does not include any explicit obligation on the quality of 

36 

 
 
 
service (QoS) as such. However, the quality of service is an integral part of the product whose 
price  is  regulated.  By  paying  a  certain  price,  the  user  has  access  to  a  given  mobile  service 
domestically. The Roaming Regulation requires that the user have access to the same service 
abroad  in  the  EU/EEA  for  the  same  price,  as  long  as  such  service  can  be  delivered  on  the 
visited  network.  The  quality  of  service,  in  particular  data  speed,  while  roaming  does  not 
depend entirely on the home operator, it largely depends on the QoS provided by the visited 
network. However, as 4G technology is now covering almost all of the Union's territory, 4G 
can normally be expected to be provided while roaming. As noted in the BEREC Opinion on 
the roaming market, BEREC considers that domestic operators should not deliberately lower 
the  QoS  compared  to  the  QoS  offered  in  the  home  country,  so  that  the  end-users  could 
genuinely ‘roam like at home’.  

Beyond  the  intrinsic  performance  of  the  mobile  network  itself,  there  are  multiple  factors, 
influencing the QoS, and in particular the data speed, experienced by an end-user at a specific 
location  and  a  specific  point  in  time  (e.g.  network  capacity  solicited  by  other  users 
simultaneously, particular end-user equipment used, meteorological conditions). On any given 
network, the QoS may vary across end-users and time, be they local or roaming end-users. 

The  BEREC  Opinion  on  the  roaming  market  notes  a  lack  of  transparency  of  a  number  of 
operators  as  regards  the  data  speed  provided  to  their  customers  while  they  roam  abroad55. 
According  to  it,  23  NRAs  have  reported  that  some  operators  provide  no  information  about 
QoS on their websites, some do have roaming QoS information available (and almost half of 
them  clarify  that  they  do  not  impose  any  limitations  regarding  QoS  while  roaming),  while 
some are transparent about the fact that they limit roaming to 3G access (3G only availability; 
3G only for specific countries or 3G only for specific networks in specific countries). BEREC 
however underlines in its Opinion that the information is incomplete. Therefore, the research 
is not conclusive at this stage.  

In its Report on Transparency and Comparability of International Roaming Tariffs (December 
2019)  BEREC  asked  the  operators  whether  they  offer  3G  roaming  when  4G  roaming  is 
available. 46% of the respondents gave a positive answer. However, BEREC acknowledges in 
this report that the question did not specify that operators replying positively offer 3G across 
all  roaming  networks  and  all  member  states.  Therefore,  it  is  not  clear,  if  those  operators 
responding yes, apply this restriction to all countries and networks or only in few instances. 
This  inconclusiveness  is  further  supported  by  the  findings  of  the  joint  BEREC/Commission 
survey of NRAs that took place in March 2019. According to the BEREC Opinion, almost all 
operators surveyed (98 % of MNOs and 94 % of MVNOs) report that they do not themselves 
limit QoS or data speeds of roaming services to 3G besides exceptional circumstances (brief 
limitation of data roaming speeds in order to provide a consistent level of service, lack of 4G 

55  For  the  QoS  section,  BEREC  used  feedback  from  NRAs  and  operators  about  complaints  of  end-users  and 
information about transparency on QoS and wholesale agreements as well as third-party surveys. 

37 

 
 
                                                 
roaming implementation for one MVNO, dependence on the speed from the selected MNO in 
the host country).  

In  fact,  there  is  no  particular  evidence  that  roaming  users  get  lower  data  speed  than  local 
users. According to the joint Commission/BEREC survey of NRAs March 2019, the number 
of  consumer  complaints  regarding  roaming  has  not  increased  in  most  Member  States 
following  the  introduction  of  RLAH  and  end-users’  dissatisfaction  with  the  QoS  while 
roaming ranks low among the consumer complaints received by NRAs (see also section 5.9). 
Only  3  NRAs  found  it  necessary  to  undertake  some  investigations  on  the  speed  of  data 
roaming services. None of them concluded on a specific problem in that regard. The above are 
to  a  large  degree  confirmed  in  the  BEREC  Report  on  Transparency  and  Comparability  of 
International  Roaming  Tariffs  (December  2019).  According  to  it,  fewer  than  half  of  the 
responding NRAs (14 out of 30) reported that they received complaints regarding quality of 
service  between  July  2018  and  August  2019  and  only  one  of  them  received  more  than  10 
compaints (30).  

According  to  the  BEREC  Opinion,  a  few  MNOs  and  MVNOs  reported  problems  with  the 
QoS regarding available data speeds of roaming services for their customers while roaming in 
the EEA (lower data speeds due to poor capacity, overloaded networks during summer time, 
low  data  speed,  possible  data  throttling  by  some  visiting  operators)56.  However,  the 
overwhelming  majority  of  MNOs  and  MVNOs  (89  %  of  MNOs  and  96  %  of  MVNOs) 
reported that the introduction of RLAH did not have an impact on their QoS.  

At  wholesale  level,  98  %  of  all  MNOs  answered  that  they  do  not  offer  different  prices  for 
wholesale  roaming  access  based  on  the  QoS.  According  to  the  BEREC  Opinion,  almost  all 
MNOs  do  not  differentiate  in  the  QoS/data  speeds  for  roaming  services  in  their  reference 
wholesale agreement for roaming access for operators in the EU. MVNOs reported mostly to 
have  a  wholesale  roaming  resale  contract  without  restrictions  towards  the  quality  of  data 
roaming (72 %). Almost all MVNOs reported no price difference between 3G or 4G in their 
wholesale resale roaming access agreement with their host operator. 

As for the external studies quoted in the BEREC Opinion, both the Monroe Project and the 
Speedtest  study  regarding  the  quality  of  mobile  broadband  access57  note  that  routing  data 
traffic through the user’s home network has always been the norm for handling SIM cards that 
visit  foreign  networks58  and  that  this  may  naturally  introduce  short  delays  for  the  roaming 
end-users. The Speedtest study focused on comparing general speeds in a home country and 
speeds experienced while roaming and concluded that the differences are at least partially due 
to  different  speeds  offered  in  different  countries  in  general,  i.e.  not  due  to  the  artificial 
lowering  of  speeds  for  roaming  customers.  Therefore,  the  conclusions  of  both  projects 

56 Based on the Joint Commission/BEREC survey of MNOs and MVNOs, March 2019  
57 https://www.speedtest.net/insights/blog/roaming-in-europe-2019/ 
58 So called home routing: the end-user’s traffic is serviced by their home network. 

38 

 
 
                                                 
indicate that different experiences while roaming are influenced by different speeds available 
in different EEA countries.  

BEREC indicated in its Opinion that its open internet measurement tool, which will allow to 
measure certain QoS parameters for internet access, could be used for further monitoring the 
QoS while roaming with the EU/EEA, at least for data. Its specification already mentions that 
internet  access services quality measurements  need  to  reflect the transnational topology  and 
usage  of  the  Internet,  which  makes  it  relevant  to  measure  performance  across  borders,  and 
check  the  ability  to  access  content  from  different  parts  of  Europe  when  the  end  user  is  at 
home, in his domestic network, and when connecting from a visited network when roaming. 

Additionally, it is worth noting that when it comes to the use of mobile data, according to the 
EU  rules  on  the  open  internet59  all  traffic  should  be  treated  equally.  Therefore,  if  end-users 
travel  within  the  EEA,  their  use  of  data  is  additionally  protected  by  the  open  internet  rules 
except  for  limited  exceptions  (such  as  temporary  congestion  management).  Finally,  in  2020 
BEREC will adopt guidelines detailing the relevant QoS parameters pursuant to Article 104 of 
the EECC aimed to ensure further transparency and comparability of the services offered.  

5.7  Situation of MVNOs  

Because MVNOs do not own a radio access network in the country(ies) where they operate, 
MVNOs  cannot  exchange  roaming  traffic  with  MNOs  and  are  therefore  in  a  structurally 
different situation from MNOs on the wholesale roaming market (see more details in section 
7.4). This particularity, inherent to MVNOs’ business model, renders the provision of RLAH 
more  challenging  for  MVNOs  than  for  most  MNOs.  It  is  therefore  useful  to  monitor  the 
evolution of MVNOs’ competitive situation on domestic markets following the introduction 
of RLAH. 

The  data  on  MVNOs  from  the  International  Roaming  BEREC  Benchmark  reports  seem  to 
indicate that for most of the countries for which data is available, MVNOs have been able to 
broadly  maintain  or  slightly  increase  their  domestic  market  share  (in  subscriber  numbers) 
(Figure  18  and  Figure  19).  This  tends  to  indicate  that  MVNOs  have  overall  been  able  to 
maintain their competitive position in their respective markets under RLAH. 

59 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) No 531/2012 on 
roaming on public mobile communications networks within the Union (Text with EEA relevance), OJ L 310, 
26.11.2015, p. 1–18 

39 

 
 
                                                 
 
Figure  18:  Individual  MVNOs’  market  shares  (1  dot  =  1  MVNO)  before  and  after 
RLAH 

Source: Data collected for the 19th-23rd International Roaming BEREC Benchmark Reports. JRC calculations. 
Note 1: Each MVNO market share is calculated over the population of MNOs and MVNOs, in that MVNO’s 
country,  that  have  provided  the  number  of  subscribers  in  all  19th  to  22nd  BEREC  Benchmark  Reports’  data 
collection. 
Note  2:  'pre-RLAH'  covers  the  last  period  before  RLAH  (Q4  2016  -  Q2  2017),  'post-RLAH  covers  the 
corresponding period after RLAH (Q4 2018 – Q1 2019), as Q2 2019 was not available at the time this analysis 
was made. 

40 

 
 
 
Figure 19: Total MVNO market share among the operators (MNOs and MVNOs) that 
responded to all 19th to 22nd BEREC Benchmark Reports’ data collection, by country 

Source: Data collected for the 19th-23rd International Roaming BEREC Benchmark Reports. JRC calculations. 
Note: 'pre-RLAH' covers the last period before RLAH (Q4 2016 - Q2 2017), 'post-RLAH covers the 
corresponding period after RLAH (Q4 2018 – Q1 2019), as Q2 2019 was not available at the time this analysis 
was made. 

Figure  20  shows  an  overall  stability  of  the  Average  Retail  Revenue  Per  User  (ARRPU)  of 
MVNOs that have replied to all International Roaming BEREC Benchmark data collections.  

41 

 
 
 
Figure 20: Average Retail Revenue Per User (ARRPU) of MVNOs, by country, Q4 2016 
to Q1 2019 

Source: Data collected for the 19th-23rd International Roaming BEREC Benchmark Reports. JRC calculations. 

The  above  Figures  however  can  only  partially  represent  the  situation  of  MVNOs  on  the 
various  markets  as  the  population  of  MVNOs  having  provided  sufficient  data  for  such 
calculations since Q4 2016 is a small sample of all MVNOs operating in Europe. 

Section 7.4 below assesses the challenges faced by MVNOs at wholesale level in providing 
RLAH  to  their  customers  and  looks  at  several  options  to  improve  their  position  on  the 
wholesale roaming market. 

5.8  Rest of the World roaming  

According to data from the most recent BEREC International Roaming Benchmark Reports60, 
retail roaming prices of EU/EEA mobile operators in non-EU/EEA countries have continued 
to decline (Figure 21). Seasonal variations, especially in the rates for calls made, do not affect 
this  conclusion.  Between  Q1  2017  and  Q1  2019,  rates  for  data  roaming  services  in  non-
EU/EEA  countries  fell  by  78%  while  rates  for  voice  services  fell  by  more  than  30%.  The 

60  19th,  20th,  21st,22nd  and  23rd  International  Roaming  BEREC  Benchmark  Data  Report,  covering  respectively 
September 2016 to March 2019. 

42 

 
 
 
                                                 
sharp  declining  trend  for  data  roaming  prices  in  non-EU/EEA  countries  has  therefore 
continued after the introduction of RLAH.  

Figure 21: Development of retail roaming prices for travelers roaming in non-EU/EEA 
countries, Q2 2016 – Q1 2019 

Source: Based on data from the 19th-23rd International Roaming BEREC Benchmark Report 

Overall  therefore,  abolishing  intra-EU/EEA  roaming  charges  has  not  come  at  the  price  of 
higher  roaming  prices  in  the  rest  of  the  world  (so-called  "waterbed  effect")61  In  particular, 
many  operators  include  some  popular  non-EU/EEA  destination  countries  in  their  RLAH 
offering or apply a reduced roaming fee to those countries62.  

5.9  Consumer perception  

The interim Report63 noted that the RLAH reform was widely recognised and appreciated by 
Europeans. One year after the introduction of RLAH, a Eurobarometer survey64 showed that 
81 % of the travelers were aware that roaming charges had ended in the EU/EEA and 69% of 
all Europeans thought that they, or someone they know, benefit or will benefit. The feedback 

61  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. 
62  According  to  the  BEREC  Report  on  Transparency  and  Comparability  of  International  Roaming  Tariffs 
(December 2019), almost half of the operators do so. 
63 Report 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, COM(2018) 822 final, available here 
64 Flash Eurobarometer 468, The end of roaming charges one year later, June 2018, available here. 

43 

 
 
 
                                                 
received  by  the  Commission  from  consumer  associations  since  June  2017  has  overall  been 
very positive. 

The  study65  performed  on  request  by  the  European  Parliament  one  year  after  the 
implementation of RLAH (see section 4.5) reports positive feedback not only from consumers 
but  also  from  business  users.  It  specifically  refers  to  an  increase  in  the  productivity  of 
employees  because  they  can  connect  with  their  corporate  network  and  interact  with  their 
company more frequently when they are abroad in the EU. 

The joint Commission/BEREC survey of NRAs of March 2019 indicates that the volume of 
roaming-related  complaints  received  by  NRAs  has  generally  not  increased  following  the 
introduction of RLAH in June 2017. 17 NRAs found that the number of consumer complaints 
related to roaming in 2017 was comparable to the previous year, 6 NRAs that it was higher 
and 1 NRA that it was lower. One year later, only 4 NRAs found that the number of roaming-
related  consumer  complaints  had  increased.  Overall,  the  total  annual  number  of  roaming 
related  complaints  received  by  NRAs  remains  very  small  (from  a  few  complaints  to  a  few 
hundreds of complaints depending on the NRA) compared to the number of users66. 

Figure  22  shows  the  relative  importance  of  roaming-related  topics  of  consumer  complaints 
received by NRAs. The most important ones have been inadvertent roaming67, fair use policy 
volume on data and incorrect billing of roaming volumes, which are among the top complaint 
topics  for  close  to,  or  more  than,  25%  of  the  responding  NRAs,  which  actually  received 
roaming-related complaints.        

65 “Roaming: One year after implementation”, available here 
66  In  2018,  out  of  30  NRAs,  26  received  a  total  of  4028  complaints  compared  to  close  to  505  million  active 
subscribers reported by the NRAs as of June 2018. According to the BEREC Transparency Report of December 
2019, the number of consumer complaints to NRAs remained stable between July 2018 and August 2019. 
67  Inadvertent  roaming  happens  near the border  between two  countries when  the  mobile phone of  an  end user 
located in one country captures the signal of the network of an operator of the neighbouring country.  

44 

 
 
                                                 
Figure 22: Roaming-related topics of consumer complaints received by NRAs and their 
relative importance 

Source: Joint Commission/BEREC survey of NRAs (March 2019). 
All figures are % of NRAs who have received complaints relating to roaming (total 26). 

In  the  joint  Commission/BEREC  survey  of  operators  of  March  2019  all  responding  MNOs 
report to have received a total of approximately 9000 complaints and MVNOs about 1220 in 
2018.  BEREC  noted  in  its  Opinion  that,  in  comparison  with  the  total  number  of  active 
subscribers from responding operators (several hundreds of millions) this number seems to be 
rather  negligible.  In  addition,  the  total  number  of  consumer  complaints  is  highly  unevenly 
distributed over operators and a few operators have received much more complaints than the 
others. 

6  ASSESSMENT OF THE COSTS OF PROVIDING WHOLESALE ROAMING SERVICES  

45 

 
 
 
 
 
This  section  describes  the  approach  to  assessing  the  costs  of  providing  wholesale  roaming 
services  in  the  EU/EEA.  It  begins  by  a  description  of  the  Commission’s  approach  to  cost 
modelling, followed by a reference to previous relevant estimates provided for these services. 
The  cost  model  developed  for  the  purposes  of  this  review  is  then  described,  including  the 
assumptions  and  methodological  decisions  made.  The  results  under  a  specific  scenario  are 
then explained, followed by a discussion on additional necessary costs that must be taken into 
account  when  evaluating  the  total  costs  faced  by  a  visited  mobile  network  operator  for 
providing roaming services. The sections ends with a summary of BEREC’s assessment of the 
cost model and estimates produced. 

Cost assessment and in particular the cost estimates produced by the cost model are one input 
among other inputs and considerations when it comes to deciding on the appropriate level of 
wholesale  roaming  caps,  which  in  any  event  are  not  mandated  to  be  set  at  cost  orientation 
levels. 

6.1  Description of the Commission’s approach 

In  order  to  assess  the  costs  of  providing  wholesale  roaming  services  in  the  31  EU/EEA 
countries for the purposes of the roaming review, an independent study was commissioned.68 
The  study’s  dual  objective  was  to  assess  the  cost  of  providing  both  wholesale  roaming 
services and voice call termination rates. For the purposes of this SWD, the main focus of this 
summary of the study is on the estimated costs related to roaming. 

The  cost  study  was  conducted  by  Axon  Partners  Group  from  mid-March  2018  to  mid-July 
2019. At the start of the study, a first workshop with all relevant stakehoders was organised 
on  10  April  2018  in  order  to  collect  feedback  on  the  methodology  proposed  by  Axon.  A 
comprehensive data gathering was then conducted in June-July 2018, via the NRAs, in order 
to  obtain,  from  mobile  operators,  the  relevant  information  and  inputs  needed  to  populate  a 
country-specific model for each Member State. The aim was to built 31 models with a similar 
skeleton,  based  on  country-specific  input  where  relevant,  facilitating  as  best  possible  the 
estimation  of  the  relevant  mobile  wholesale  costs  in  each  of  the  31  Member  States.69  The 
models  would  rely  on  country-specific 
input  where  relevant  and,  where  not,  on 
averages/common values across the EU/EEA. On 29 October 2018 the first draft cost model 
was  shared  with  stakeholders  for  consultation,  followed  by  a  second  version  of  the  draft 
model shared on 15 February 2019 for a second round of consultation. The relevant comments 
and suggestions received during both consultations were implemented in the draft final model, 
which was presented to stakeholders at a second workshop on 28 May 2019. The cost model 
was then finalised and published on 24 July 2019. 

68  Study  SMART  2017/0091:  “Assessment  of  the  cost  of  providing  mobile  telecom  services  in  the  EU/EEA 
countries”, Axon Partners Group Consulting, published on 24 July 2019, available here. 
69 Iceland, Liechentsein and Luxembourg decided not to participate in the data collection process and therefore 
the  estimation  of  costs  was  not  possible  for  these  countries.  Accordingly,  the  full  set  of  models  produced  by 
Axon is 28. 

46 

 
 
                                                 
To  ensure  transparency  throughout  the  project,  several  steps  were  taken  to  associate  the 
NRAs, operators and other stakeholders. First, two workshops were held and two rounds of 
consultation  were  organised  over  the  period  going  from  October  2018  to  March  2019.70 
Stakeholders were also consulted on the structure and content of the data gathering exercise of 
June-July  2018  itself  .  Also,  a  steering  committee  composed  by  experts  from  NRAs  was 
established and regular meetings between the Commission, Axon and the Steering Committee 
were held throughout the project. The steering committee consisted of representatives from 8 
NRAs  and  was  composed  of  members  of  the  two  BEREC  Expert  Working  Groups  dealing 
with roaming and with termination rates. 

6.2 

 Previous estimates of wholesale roaming costs 

Prior  to  the  Axon  cost  model,  the  costs  of  providing  wholesale  roaming  services  were 
assessed by the Commission based on two inputs in particular: BEREC cost estimates in 2010 
and  2012,  followed  by  a  cost  model  developed  by  TERA  consultants  in  2016.  This  section 
briefly summarises these cost estimates.  

6.2.1  BEREC cost estimates from 2010 and 2012 

In  2010  BEREC  estimated  the  upper  bound,  average  and  lower  bound  of  the  costs  for 
wholesale  roaming  services.71  In  2012  BEREC  updated  its  analysis  of  wholesale  roaming 
costs.72 The then estimated costs are shown in Table 3 below. 

Table 3 - BEREC's estimations for upper bound, average and lower bound of wholesale 
costs for wholesale roaming services in 2010 and maximum for 2012. 

Minimum (2010)  Average (2010)  Maximum (2010)  Maximum (2012) 

Voice call (out) 

€3cents/min 

€5.4cents/min 

€9.7cents/min 

€5cents/min 

Voice call (in) 

€3cents/min 

SMS 

Data 

€0.6cents/SMS 

€0.8cents/SMS 

€2.7cents/SMS 

€1cents/SMS 

€1.6cents/MB 

€8.1cents/MB 

€15cents/MB 

€5cents/MB 

Source:  BEREC  International  Mobile  Roaming  Regulation  Report  BoR(10)58  (2010  estimates)  and  BEREC 
Analysis of Wholesale Roaming Costs BoR(12)14 (2012 estimates) 

These  cost  estimates  informed  the  setting  of  the  wholesale  roaming  price  caps  adopted  in 
2012.73 Table 3 shows that the costs have decreased throughout the period. 

70 See the full publication for all the documents related to interaction with stakeholders, from the two workshops 
and the two consultation processes here.  
71  BEREC  (2010),  International  Mobile  Roaming  Regulation  BEREC  Report,  BoR(10)58,  December  2010, 
available here 
72 BEREC (2012), BEREC Analysis of Wholesale Roaming Costs, BoR(12)14, February 2012, available here:  

47 

 
 
 
 
 
 
                                                 
6.2.2  TERA consultants cost estimates from 2016 

In  order  to  prepare  for  the  then  upcoming  RLAH  regime,  TERA  was  commissioned  to 
estimate the costs of providing wholesale roaming services for a mobile network operator in 
29  EU/EEA  countries74.  For  this  purpose,  TERA  built  a  bottom-up  cost  model  -  using  the 
relevant inputs from operators and NRAs and a selection of scenarios75. The costs estimated 
by TERA are represented in Figure 23 and Figure 24 below76. 

The wholesale cost  for outgoing roaming  voice services  was estimated between 0.2 and 2.8 
€cents per minute in the TERA cost model. The model showed great differences between the 
lowest and highest cost countries, with Malta having the highest estimated cost. 

Figure 23: Outgoing wholesale roaming voice – Estimated costs, TERA model in 2016 

Source: TERA Consultants, SMART 2015/0006 

For wholesale roaming data services, the estimated costs are shown in Figure 24 below. The 
trend seen from above is also visible here, albeit the variations are smaller, ranging from 0.1 
to 0.45 €cents per MB. For data as well, Malta is the country with highest estimated costs.   

73 Regulation (EU) No 531/2012 of the European Parliament and of the Council of 13 June 2012 on roaming on 
public mobile communications networks within the Union, available here. 
74 The 28 European Member States and Norway. 
75 The full publication is available here.  
76  Results  derived  under  the  following  scenario:  For  termination,  the  minimum  of  either  the  actual  MTR 
applicable in every country as of the second semester of 2015 or the MTR applicable in Slovakia (the highest 
BU-LRIC MTR in the second semester of 2015 in the EU) is used to re-balance the costs of call origination. For 
seasonality, it is assumed that both roaming and domestic traffic exhibit seasonality. See SMART 2015/0006 for 
more explanation on the scenarios and results. 

48 

 
 
 
                                                                                                                                                         
Figure 24: Wholesale roaming data service – Estimated costs €cent/MB, TERA model in 
2016 

Source: TERA Consultants, SMART 2015/0006 

6.3  The Axon Partners cost model 

This section briefly describes the main features of the Axon Partners’ cost model (hereinafter, 
the cost model). For additional information on the methodological approach followed and the 
results of the cost model, the reader is referred to the full list of materials published with the 
Axon Partners' cost model77. 

6.3.1  The approach and methodology followed by Axon Partners 

The  Axon  Partners’  cost  model  estimates  the  costs  of  providing  wholesale  mobile  roaming 
services as well as voice termination78 in 28 EU/EEA countries79. Each cost model contains a 
number of adaptable scenarios, allowing the Commission services to evaluate many different 
scenarios in each country. 

Any  cost  model  enables  the  user  to  evaluate  costs  of  all  elements  required  to  offer  mobile 
services. For the purposes of the roaming review, the relevant costs to be estimated are those 
related to wholesale roaming services, specifically the estimated costs for: 

  Data roaming 
  Outgoing voice calls 
  Outgoing SMS  

77 Full publication available here. 
78  Cost  estimates  for  termination  services  are  not  presented  in  this report.  They  can  be  found  in  the  the  Axon 
study’s material published here. 
79 27 EU Member States and Norway. Iceland, Liechentsein and Luxembourg decided not to participate in the 
data collection process. 

49 

 
 
 
                                                 
Each service and related costs can be evaluated under a number of scenarios. For this purpose 
it must be noted, that not all scenarios reconcile and as a result, any estimated cost should be 
evaluated  together  with  the  full  list  of  materials  published  to  avoid  conclusions  based  on 
scenarios  which  do  not  reconcile.  Furthermore,  one  should  bear  in  mind  that  the  results 
produced  by  the  model  do  not  include  the  costs  of  international  transit  nor  the  cost  of 
terminating a roaming call. Hence, these costs need to be added to the costs estimated by the 
model when assessing the total costs of providing wholesale roaming services. This addition 
of transit and termination costs is described further in section 6.6. 

The Axon cost model is based on a number of methodological choices. First of all, the model 
is  a  bottom-up  model,  calculating  the  provision  of  a  service  under  a  given  set  of 
methodologies and scenarios. A bottom-up model involves a reasonable approximation of the 
network  that  a  reference  operator  would  need  in  order  to  meet  the  coverage  and  capacity 
requirements  of  the  users.  It  produces  a  reasonable  approximation  of  the  costs  that  such  an 
operator would bear and provides service-level results under different scenarios.  

A  bottom-up  model  resorts  to  a  number  of  methods  dealing  with  various  aspects  of  the 
economics  of  a  communications  network.  These  methodological  considerations  include  the 
choice  of  cost  standard,  the  type  of  operator  modelled,  the  method  to  forecast  the  volumes, 
allocation of joint and common costs as well as seasonality. In Table 4, an overview of each 
methodological aspect is presented together with the approach adopted.  

Table 4: The methodological aspects considered in the Axon cost model 

METHODOLOGICAL 
ASPECT 

COST STANDARD 

COST CATEGORIES 
CONSIDERED 

MODELLED 
OPERATOR 

DESCRIPTION 
METHODOLOGY 

APPROACH ADOPTED 
Pure LRIC (termination) and LRIC+ (rest of the services). 

Network  CapEx,    Network  OpEx,  General  and  administration  costs 
(G&A) and Wholesale specific costs 

Hypothetical Efficient operator, with a market share equal to 1/#MNOs 
(subject to a minimum of 20%). 

Economic depreciation, where two economic depreciation scenarios are 
included based on (i) demand or (ii) revenues as the relevant production 
factors. 

MODELLED PERIOD  2015-2025 

VOLUME FORECAST 

Projections are based on an assessment of historical traffic patterns and 
data provided by the stakeholders. A total of three scenarios are included 
to  assess  alternative  volume  forecasts  (conservative,  base  case  and 
aggressive). 

Two cost allocation modules are available in the model: 

1: Network module: Joint and common costs are allocated to services 

ALLOCATION OF 

50 

 
 
 
 
 
JOINT AND 
COMMON COSTS 

based on their network usage, by using a routing factors matrix. 

2: Regulatory policy module: The allocations performed in the network 
module are adjusted to take into account regulatory policy decisions 
(e.g. re-allocation of the joint and common costs initially allocated to the 
voice/SMS termination service to voice/SMS origination). Please refer 
to the descriptive manual for further indications on how this is 
implemented. 

The  impact  of  seasonality  on  all  domestic  and  roaming  services  was 
assessed  (when  data  was  provided)  based  on  the  monthly  evolution  of 
traffic. A total of 11 Member States provided the required information to 
assess  the  impact  of  seasonality  in  their  networks.  Three  alternative 
seasonality  scenarios  are  included  in  the  model  depending  on  the 
minimum  threshold  required  between  monthly  fluctuations  and  the 
yearly average to consider that seasonality exists. 

TREATMENT OF 
SEASONALITY 

Source: Axon Consulting, SMART 2017/0091 

The following section further describes the choice of cost standards, general cost allocation, 
followed  as  well  as  the  approach  followed  to  take  seasonality  into  consideration.  The  full 
description  of  the  methodological  approaches  taken  by  Axon  Partners  is  to  be  found  in  the 
methodological approach document available here. 

6.3.2  Choice of cost standards and general cost allocation 

The Axon cost model allocates costs related to wholesale roaming services following the so-
called  Long-Run  Incremental  Cost  (LRIC)  plus  some  allocation  of  joint  and  common  costs 
(LRIC+).  This  cost  standard  can  be  divided  in  two  parts,  essentially  the  LRIC  and  the  plus 
(+). LRIC is a way to derive the cost of producing an additional increment of a given output, 
when assessed over a long period of time (long-run). In economic theory, the long-run means 
that all inputs relevant to the production of the output are considered variable. The increment 
refers to the relevant part (service) of interest in the specific situation, here roaming services. 
The  LRIC  cost  standard  encompasses  solely  the  elements  needed  to  provide  this  specific 
service. As an illustrative example, the incremental cost of data roaming is therefore the total 
cost for a fully functioning mobile network minus the cost of an identical network unable to 
provide data roaming. Accordingly, the LRIC cost standard leaves out any joint and common 
costs needed in this case for both e.g. data and voice, as only the elements solely linked (i.e. 
not  shared  by  other  services)  to  data  roaming  are  considered  relevant  in  the  LRIC  cost 
standard. 

The LRIC+ cost standard allows for including joint and common costs which are relevant for 
other services as well. Clearly, costs estimated under the LRIC+ cost standard are higher than 
costs  derived  under  LRIC.  However,  as  these  shared  elements  are  also  necessary  for  the 
relevant service, and in line with the regulatory obligation for the wholesale roaming cap to 

51 

 
 
 
cover such costs80, the Axon Cost model deploys the LRIC+ standard for all services related 
to roaming. This approach ensures that for shared equipment needed for e.g. data and voice 
the  costs  are  captured  in  the  estimation.  As  companies  need  to  recover  joint  and  common 
costs  to  ensure  long-term  sustainability,  joint  and  common  costs  are  shared  among  the 
services  that  generate  them  and  accordingly  recovered  by  any  price  cap  set  above  the 
estimated costs for those services.  

In contrast, incoming voice (voice termination) is calculated purely on the basis of the LRIC 
cost standard (pure LRIC), in accordance with the the Commission's 2009 Recommendation 
on  Termination  Rates,  which  recommends  the  estimation  of  termination  rates  based  on  a 
bottom-up  pure  LRIC  approach.81  For  incoming  SMS,  the  Axon  cost  model  follows  the 
approach adopted in the previous cost model82, where no costs are allocated to termination of 
incoming  roaming  SMS.83  To  ensure  cost  recovery  for  these  services,  the  cost  of  incoming 
roaming SMS is re-allocated to outgoing roaming SMS. 

6.3.3  Treatment of seasonality 

The  Axon  cost  model  incorporates  seasonality  patterns  for  five  Member  States84,  following 
analysis of the 11 Member States85 who provided the required “high-priority information” to 
assess  the  impact  of  seasonality  on  their  networks.  For  these  5  countries,  country-specific 
seasonality  can be evaluated under a number of scenarios and thresholds. For the remaining 
countries  where  seasonality  was  not  proven  to  have  an  /relevance,  no  assessment  of 
seasonality is done. 

When  proven  to  be  relevant,  seasonality  is  taken  into  consideration  to  design  a  network 
capable of accommodating the demand requirements at all relevant points in time. Essentially, 
any  network  must  support  the  peak  demand  and  the  seasonality  assessment  determines 
whether traffic is distributed evenly across months or whether it peaks at specific months (e.g. 
summer period or winter period). Therefore, seasonality is assessed on a country-by-country 
basis to ensure that the relevant peak-time of the country is considered.  

The Data Request Form from Axon requested operators to provide information on traffic per 
site  and  month.  This  exercise  reveals  whether  traffic  is  evenly  distributed  over  the  months 
(and therefore not subject to seasonality) or if patterns of seasonality exist in the network, to 
ultimately assess the potential impact on underlying costs. Based on the information collected, 

80 Article 19(1) in the Roaming Regulation. 
81 Commission Recommendation of 7 May 2009 on the Regulatory Treatment of Fixed and Mobile Termination 
Rates in the EU, available here. 
82 TERA Consultants, SMART 2015/0006 
83 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  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", available here. 
84 Croatia, France, Greece, Malta and Spain 
85 Croatia, France, Germany, Greece, Hungary, Ireland, Malta, The Netherlands, Poland, Slovakia and Spain. 

52 

 
 
                                                 
seasonality  can  be  further  divided  into  geotypes.  The  whole  process  from  evaluating  the 
existence of seasonality to allocating the relevant costs to services includes four phases: 

  Phase 1: Identification of seasonality 
  Phase 2: Assessment of the relevance of seasonality per geotype 
  Phase 3: Identification of traffic in the busy month per service 
  Phase 4: Cost allocation to services 

The four phases are described in detail in the Methodological Approach Document86 supplied 
by Axon, under section 3.1.10. A short overview is presented below.  

The  first  phase  would  conclude  whether  the  specific  country  is  eligible  for  any  seasonality 
assessment. In this phase, steps were taken to identify the busiest month of the year, defined 
as  a  month  with  50%  more  traffic  than  the  yearly  average87.  In  this  assessment,  the  annual 
growth  in  traffic  was  taken  into  account,  to  evaluate  whether  any  structural  growth  and 
resulting  increase  in  traffic  by  the  end  of  the  year  would  exceed  the  peak  traffic  of  the 
seasonal month. Seasonality should only be a cost driver when it is clearly demonstrated that 
seasonality triggers the extra capacity requirement.   

In  the  second  phase,  all  the  reported  data  from  operators  on  seasonality  were  assessed  to 
determine the level of details required to properly model the possible effects of seasonality on 
costs. Each country is, for the purpose of modelling, divided into a subset of geotypes. The 
purpose  of  phase  2  is  to  assess  the  existence  of  seasonality  per  geotype.  Seasonality  is 
therefore  decided  per  geotype  in  each  country.  Where  relevant,  seasonality  is  eventually 
included in the cost calculation.  

Phase  3  assesses  the  traffic  in  the  seasonal  months  per  service  and  geotype.  For  roaming 
voice,  roaming  data,  domestic  voice  and  domestic  data,  the  traffic  in  the  busiest  month  per 
geotype is divided by the yearly traffic per geotype. From this, the total percentage of traffic 
generated in the busiest month is derived and used as input to the seasonality cost allocation.  

The busy month traffic is finally determined in Phase 4. Here, the model obtains the number 
of network elements required to meet the coverage and capacity constraints in each geotype 
and the annual costs generated by these  elements. From this, the costs per network element 
and geotype are derived and the model allocates costs to seasonal and non-seasonal geotypes, 
allocating  costs  to  services  based  on  the  busy  hour  traffic  demand.  As  mentioned  above, 
seasonality  was  found  relevant  for  Croatia,  France,  Greece,  Malta  and  Spain  and  costs  are 
evaluated under three potential thresholds: 10%, 30% and 50%88. 

86 Available here.  
87  This  percentage  was  defined  so  as  to  ensure  the  representativeness  of  the  analysis.  and  that  a  potential 
consideration of seasonality would become relevant in the dimensioning of the network. 
88  For  effect  on  results  under  the  various  thresholds,  please  refer  to  the  full  set  of  published  results,  available 
here. 

53 

 
 
                                                 
6.3.4  The structure of the cost model  

As described above, the Axon cost model is a Bottom-Up LRIC model comprising a number 
of  functioning  blocks.  Costs  are  estimatd  per  service  following  the  specific  cost  allocation 
required. The structure of the model is graphically represented in Figure 25. 

Figure 25: Structural overview of the Axon Bottom-Up LRIC model 

Source: Axon Consulting, SMART 2017/0091 

The  model  functions  by  incorporating  the  demand  -  and  network  inputs  from  stakeholders 
initially  -  and  then  dimensioning  these  through  a  set  of  modules.  The  first  step  is  the 
“Dimensioning Drivers”, whereby traffic is converted into dimensioning drivers which help to 
perform  the  network  calculations.  The  “Dimensioning  module”  calculates  the  resources 
needed  to  supply  the  main  services  provided  by  the  reference  operator.  Additionally, 
geographical  data  is  introduced  in  the  dimensioning  module  to  take  into  consideration  the 
relevant  geographical  aspects  of  the  EU/EEA  countries.  The  “OPEX  and  CAPEX  costing 
module”  addresses  the  costs  of  ressources  for  operational  expenses  (OPEX)  and  capital 
expenditures  (CAPEX)  respectively.  This  module  also  includes  factors  related  to  economic 
depreciation  to  properly  incorporate  the  lifetime  of  investments  by  annualising  the  capital 
investments  over  the  years.  In  “Cost  allocation  to  services”  the  costs  of  services  are 
calculated,  by  allocating  the  incremental,  fixed  and  common  costs  to  each  distinct  service. 
Finally, in the “Regulatory policy allocation module”, the costs are allocated (and reallocated) 
to reflect the relevant costing methodology as described in section 6.3.2. 

The following section presents the scenarios the user can choose in the cost model, followed 
by a presentation of the wholesale costs produced by the model. 
54 

 
 
 
6.4  Modelled scenarios 

The Axon cost model estimates costs for mobile services under a given set of scenarios. These 
scenarios were defined at the outset of the project and adjusted during the modelling period to 
reflect feedback from stakeholders89. Understanding these scenarios is key to assess the costs 
produced  by the model, as  different scenarios produces different results. Furthermore, some 
scenarios  have  proven  not  to  reconcile  optimally,  so  any  results  obtained  through  these 
scenarios  should  be  treated  with  the  utmost  caution.  The  remainder  of  this  section  presents 
and discusses the various scenarios and highlights the scenarios that do not reconcile. 

The  cover  sheet  of  the  cost  model  allows  the  user  to  choose  between  the  scenarios.  The 
scenario  chosen  will  implement  a  number  of  calculations  within  the  cost  model.  All  NRAs 
have  received  a  cost  model  tailored  to  the  specific  country  but  with  similar  modules  and 
possibilities  for  changing  the  scenarios.  The  cover  sheet  of  the  publicly  available  model  is 
shown in Figure 26. 

Figure 26: Cover sheet of the Axon cost model 

 Source: Axon Consulting, SMART 2017/0091 

The first two options (“Execution mode” and “Selected Country”) can be modified only in the 
cost  model  available  to  the  European  Commission,  as  the  models  shared  with  NRAs  only 
contain  information  specific  to  their  own  country.  For  the  others,  Table  5  presents  the 
description of the 18 scenarios that can be selected in the cover sheet.  

89  For  instance,  following  the  first  consultation  round,  Axon  implemented  the  possibility  to  choose  between 
country-specific  and  EEA  averages  for  traffic  disaggregation  per  technology.  A  similar  approach  was  also 
adopted for cell-radii. Further information  can be found in the full list of consultation documents, specifically 
“Outcomes of the 1st consultation” and “Outcomes of the 2nd consultation” available here.  

55 

Assessment of the cost of providing mobile telecom services in the EU/EEA countriesSMART 2017/0091Quick controlsExecution modeAll countriesexecution.modeSelected CountryReference countryselected.countryVoLTE ScenarioTerminal Adoptionselected.volte.adoptionTraffic split per technology forecastsSame percentages across EEA from 2020selected.traffic.split.technologyAnnualisation criteriaEconomic depreciation based on demandselected.production.factorsGeneral checkRoaming incrementSpecific roaming incrementOKselected.roaming.increment.scenarioSpecific cost allocationAllocation based on driverselected.specific.cost.allocationCell RadiiMix EEA Average – Country specific figuresselected.cell.radii.scenarioThreshold to identify seasonality50%selected.seasonality.scenarioDemand ForecastConservativeselected.demand.scenarioRUNCONTENTSMAP 
 
 
 
 
 
 
 
 
 
 
 
                                                 
Table 5: Scenarios of the Axon cost model 

Scenario 

Alternatives 

Description 

VoLTE90 scenario 

Traffic split per 
technology 
forecasts 

Annualisation 
criteria 

Roaming 
increment 

Specific costs 
allocation 

Cell Radii 

4G Operator 

All traffic goes through the 4G network 

Terminal Adoption 

Percentage  of  VoLTE  traffic  based  on 
the adoption of VoLTE ready handsets 

Same percentages across 
EEA from 2020 

The traffic split per technology forecasts 
from 2020 are the same for all countries 

Country-specific 
projections 

Traffic split per technology forecasts 
from 2020 are set at country level 

Economic depreciation 
based on ARPU91 

Revenues act as the modulation factor in 
economic depreciation 

Economic depreciation 
based on demand 

Demand acts as the modulation factor in 
economic depreciation 

Specific roaming 
increment 

Roaming traffic is grouped in a single 
increment 

Joint roaming and 
domestic increment 

Roaming and domestic traffic are 
assessed within the same increment 

Allocation based on GB 

Wholesale specific costs allocated to 
services based on equivalent GB 

Allocation based on 
drivers 

Wholesale specific costs allocated to 
services based on equivalent GB/TAPs92 

Mix EEA Average-
Country specific figures 

Cell radii based on EEA averages except 
when deviations from EEA average were 
justified due to country-specific 
conditions 

Country specific figures 
only 

Cell radii always set based on data 
reported by NRAs for each country  

90 Voice over Long Term Evelolution network – also known as 4G 
91 Average revenue per user 
92  Transferred  Account  Procedure.  In  order  to  use  GBs  and  TAPs  as  the  selected  regression  drivers,  services’ 
demand (in terms of minutes, SMSs or MB) needs to be converted into these units. A TAP record is generated 
for each data session. Therefore, the number of TAP records generated depends on the traffic, measured in MB 
and the average size of a data session (measured in MB per session). 

56 

 
 
                                                 
Threshold to 
identify seasonal 
patterns 

Demand 

10% 

30% 

50% 

Conservative 

Base-case 

Aggressive 

Areas  are  considered  as  seasonal  when 
the  traffic  in  the  peak  month  (net  of 
structural  growth)  is  above  the  traffic  in 
the average month by 10% 

…The threshold is set at 30% 

…The threshold is set at 50% 

Domestic  data  traffic  forecast  based  on 
the historic growth rate with a 30% year-
on-year  reduction  in  the  annual  growth 
rate 

…Considering  a  20%  year-on-year 
reduction in the annual growth rate 

…Considering  a  10%  year-on-year 
reduction in the annual growth rate 

Source: Axon Consulting, SMART 2017/0091 

During  the  consultation  rounds,  stakeholders  expressed  various  methodological  preferences 
and  approaches  to  cost  allocation.  The  inclusion  of  5G  in  the  model,  in  particular,  was 
discussed  at  the  first  workshop  in  April  2018.  Axon  and  the  Commission  services  invited 
stakeholders to provide information on 5G during the data collection process, in June 2018, to 
be included in  the cost model. However,  no stakeholder could  provided the complete set of 
data requested on 5G and only a few provided some information. Consequently, 5G could not 
be included in the model93. 

The scenarios described above allow the Commission services to properly evaluate the effects 
of various inputs and thereby gain a better understanding of the effect of various elements on 
the  estimated  costs.  There  is  no  preferred  combination  of  scenarios  and  the  Commission 
services  will  consider  the  results  obtained  under  all  reconciled  scenarios  to  inform  any 
regulatory policy proposal that could be made. 

A  scenario  is  said  to  reconcile  when  both  the  parameters  number  of  sites  and  cost  base  are 
within ± 20% of the reference value in a country. For the number of sites, the reference is the 
average number of sites per MNO in a country. For the cost base, the reference is the average 
cost base of MNOs in the country or that of a similar operator in terms of market share.  

Not all scenarios reconcile for all EU/EEA countries.The results derived under these scenarios 
should therefore be treated with extra caution. The results may reconcile and be reasonable for 
a  given  country,  but  may  not  show  a  proper  behaviour  for  all  28  countries.  Specifically, 
results derived under scenario(s) set to: VoLTE scenario ‘4G operator’, Cell Radii ‘Country 

93 See “outcomes of 1st consultation round”, published with the full set of materials, available here. 

57 

 
 
                                                 
specific  figures  only’  and/or  demand  ‘Aggressive’  (see  Table  5)  should  be  treated  with 
caution  in  terms  of  the  costs  per  service  and  country.  In  addition,  the  scenario  for  cost 
allocation ‘based on GB’ had a very low acceptance by the industry, although the results for 
this scenario are reconciling for all countries. 

6.5  Results derived directly from the cost model 

This section shows the results from the Axon cost model, as published together with the full 
set  of  materials94.  As  results  are  derived  under  various  scenarios  and  assumptions  affecting 
the results, this section should be read together with the full set of information contained in 
the  materials  published.  The  costs  shown  below  indicate  the  efficiently  incurred  costs,  as 
defined in the published materials, of providing regulated wholesale roaming services for the 
visited  network  in  a  specific  country.  Costs  are  shown  both  including  and  excluding 
termination and/or transit and each presentation of results must be carefully evaluated to avoid 
incorrect conclusions.  

The  results  and  scenarios  shown  below  do  not  necessarily  reflect  the  Commission  services’ 
preferences and do not need to represent the combination of scenarios that reconciles the best 
with MNOs’ financial and operational reality. The combination of scenarios considered here, 
represents stakeholders’ preferred option for each of the 8 scenarios. Specifically, the results 
throughout  this  section  are  derived  under  the  following  assumptions  (see  Table  5  for  a 
description of each scenario):  

  VoLTE scenario ‘Terminal Adoption’ 
  Annualisation criteria ‘Economic depreciation based on demand’ 
  Roaming increment ‘Specific roaming increment’ 
  Allocation of wholesale specific costs ‘Allocation based on drivers’ 
  Traffic split per technology forecasts ‘Country-specific projections’ 
  Cell Radii ‘Mix EEA Average-Country specific figures’ 
  Threshold to identify seasonal patterns ‘50%’ 
  Demand ‘Conservative’ 

The unit cost estimates shown in this section in Figure 27 (for data), Figure 28 (for voice) and 
Figure  29  (for  SMS)  are  the  network  costs  as  produced  by  the  Axon  cost  model  under  the 
above-mentioned scenario, without the estimated additional costs for termination and transit. 
Therefore,  these  estimates  do  not  show  the  full  costs  incurred  by  the  visited  operator  for 
providing wholesale roaming services.  

The cost model estimates that costs are declining across all countries, with estimates between 
0.5 and 4 €/GB in 2017 and converging downwards to a range of 0.5 to 1.5 €/GB in 2025. The 
convergence is most apparent for Spain and Malta where the largest decreases are observed, 
followed by Belgium and Hungary. A number of countries, e.g. in Poland, have very limited 

94The “Presentation of results” sheet is available here:  

58 

 
 
                                                 
developments  in  costs  throughout  the  period.  For  2025,  the  highest  estimated  costs  for 
roaming data services are found in Hungary.  

Figure 27: Estimated data roaming unit costs in €/GB, transit costs not included 

Source: Axon Consulting, SMART 2017/0091 

In  2017,  voice  roaming  costs  are  estimated  between  0.2  and  1.3  €cents/minute,  without 
including  costs  of  transit  and  termination  (Figure  28).  Poland  displays  the  lowest  costs 
whereas Belgium and Malta are the two highest cost countries. The estimated costs for 2025 
converge to a range of 0.2 to 0.6 €cents/minute for almost all countries, with Malta being the 
only  country  remaining  above  1.2  €cents  per  minute  throughout  the  period.  Looking  at  the 
other  high-cost  country  in  2017,  Belgium,  convergence  is  observed  already  in  2018  and 
continues downwards until 2025. For Malta, these high estimates are driven by the thickness 
of  walls  in  Maltesian  buildings,  requiring  operators  to  build  and  maintain  a  comparatively 
larger number of sites than elsewhere seen95. 

95 See p. 136 in the “Methodological approach document” accompanying the full publication of materials. 

59 

0,000,501,001,502,002,503,003,504,004,50201720182019202020212022202320242025EUR/GBATBEBGHRCYCZDKEEFIFRDEELHUISIEITLVLILTLYMTNLNOPLPTROSKSIESSEUKDATA ROAMING -Unitcosts (EUR/GB)1,502,002,50EUR/GB 
 
 
                                                 
Figure 28: Estimated voice roaming unit cost in €ents/min, transit and termination costs are 
not included 

Source: Axon Consulting, SMART 2017/0091 

For roaming wholesale SMS, the estimated costs are presented in Figure 29, showing a more 
constant  level  across  countries  than  for  roaming  voice  and  data.  Unlike  voice  and  data,  the 
cost  estimates  for  roaming  SMS  derived  from  the  cost  model  are  not  subject  to  additional 
costs,  such  as  termination  or  transit,  due  to  the  construction  of  the  SMS  wholesale  regime. 
This follows from the roaming regulation, attributing any termination costs for incoming SMS 
to the equivalent outgoing service to ensure cost recovery96. Incoming roaming SMS are not 
charged  at  neither  retail  nor  wholesale  level,  which  means  that  the  costs  generated  are 
reallocated to roaming SMS outgoing (origination of roaming-SMS). This approach towards 
roaming SMS considered in the cost model is consistent with the previous approach taken in 
the TERA Consultants cost model97 

As shown in  Figure  29, the cost model estimates  unit costs for roaming SMS between 0.05 
and 0.4 €cents/SMS in 2017, i.e. a factor 8 between the lowest and highest costs. A couple of 
countries display some downwards convergence, but not to the extent seen for roaming voice 
and data. By 2025, the costs are estimated between 0.05 and 0.3 €cents/SMS, indicating a six-
fold difference between high- and low- cost countries98.  

96 Regulation (EU) No 531/2012, recital 63. 
97 See p. 49 in COM(2016) 398 Staff working document accompanying the “review of the wholesale  roaming 
market.  
98 Top-three high cost countries for SMS: Estonia, Latvia and Malta 

60 

0,000,200,400,600,801,001,201,40201720182019202020212022202320242025EURCents/minATBEBGHRCYCZDKEEFIFRDEELHUISIEITLVLILTLYMTNLNOPLPTROSKSIESSEUKVOICEROAMING -Unitcosts (EURCents/min)0,600,801,00EURCents/min 
 
 
                                                 
Figure 29: Estimated SMS roaming unit costs in €cents/SMS  

 Source: Axon Consulting, SMART 2017/0091 

6.6  Estimated total costs including transit and termination 

The Axon cost model estimates network costs incurred by an efficient operator. Accordingly, 
any additional (non-network) costs incurred by the visited network when providing wholesale 
roaming services must be considered in order to ensure full cost recovery.  

For  roaming  data  services,  transit  rates  must  be  added  to  the  estimated  network  costs.  For 
voice  roaming,  transit  and  call  termination  rates  must  also  be  taken  into  account.  This  is 
because  the  visited  network  is  paying  the  network  operator  where  the  call  placed  by  the 
roaming customer will terminate. For example, a Spanish customer visiting Germany makes a 
call back to Spain. To complete the call, the German (visited) operator must first originate the 
call  on  the  German  operators  network  (cost  shown  in  Figure  28)  and  then  transit  the  call 
through  a  number  of  countries  back  to  Spain  where  the  call  is  finally  terminated  at  the 
receiver. The German operator must cover these transit and termination costs, therefore these 
costs must be considered to ensure cost-recovery by the German (visited) operator.   

As  roaming  SMS  are  transited  without  extra  costs  incurred  by  the  visited  network,  for  the 
purpose of comparison, no further costs needs to be added to these estimates. For this purpose 
and  to  illustrate  a  more  complete  estimate  of  the  cost  of  providing  roaming  voice  and  data 
services, this section describes these results of the model including transit and call termination 
costs.  

It  must  be  noted,  that  the  transit  and  termination  costs  added  here  are  estimates  performed 
outside  of  the  Axon  cost  model  and  not  subject  to  the  same  modelling  exercise.  The 

61 

0,200,250,30EURCents/SMS 
 
 
 
 
 
 
 
 
 
 
 
 
Commission  services  acknowledge  the  need  to  consider  call  termination  and  transit  costs 
when assessing the appropriate level of any potential wholesale roaming price cap. For these 
reasons, these costs are added below to the cost estimates from the Axon model. 

For  the  cost  of  call  termination,  the  Commission  services  rely  on  the  latest  weighted  EU 
average  of  Mobile  Termination  Rates  (MTRs)  reported  by  BEREC.  In  July  2018,  the 
weighted average MTR in the EU was 0.8541 €cents/min99. This rate, being the most recent at 
the time, was included in estimates presented at the second workshop in May 2019. For the 
purpose  of  this  SWD,  the  Commission  services  rely  on  the  latest  published  average  MTR 
published in June 2019. Here, BEREC calculated a weighted average MTR as applied from 
January  2019  across  EU  Member  States  of  0.79  €cents/min100.  This  most  recent  MTR  is 
applied  to  all  estimates  of  voice  roaming  service  from  year  2019  and  forward101.  Although 
MTRs  generally  decline  each  year,  the  purpose  of  this  section  is  to  illustrate  the  need  for 
additional costs beyond the estimates from the Axon cost model. 

The Commission services also apply transit costs derived from estimations outside the Axon 
cost model. The estimated transit costs used are based on a data collection performed jointly 
by BEREC and the Commission, where operators provided transit costs incurred in year 2018. 
These  calculations  are  subject  to  some  uncertainty,  as  not  all  operators  (or  even  countries) 
were able to reply to this specific data collection. However, from the reported data available 
to the Commission services, the following average transit costs have been estimated: 

  Transit price for roaming data service, 2018  : 
  Transit price for roaming voice service, 2018 :  

0.20 €/GB 
0.50 €cents/minute 

As these estimates are only available for year 2018, these costs are applied to each year under 
evaluation  here.  The  above  transit  costs  were  consulted  with  operators  during  the  first 
consultation round in November 2018, where 75% of NRAs and 48% of MNOs agreed with 
these  estimates.  For  MNOs  it  must  be  noted,  that  although  less  than  half  agreed  with  the 
estimates,  those  who  disagreed  had  contradictory  views  and  considered  the  estimate  to  be 
either too high or too low102.  

Taking  the  transit  prices  as  described  above  into  account,  the  resulting  costs  of  providing 
wholesale roaming data services are presented in  Figure 30. The trends observed above still 
remain, with the range of estimates shifted upwards. Adding the estimated transit costs results 
in costs between 0.7 and 4 €/GB in 2017, converging towards a range of 0.7 and 1.6 €/GB in 
2025.   

99 See p.2 in BoR (18) 218 - Termination rates at European level July 2018 
100 See p.2 in BoR (19) 91 - Termination rates at the European level January 2019 
101 For 2017, the Commission services applies a mobile termination rate of 0.9079, as published in BoR (17) 227  
- Termination rates at European level July 2017 
102 See on slide 16 in “Workshop 2 – Full consultation outcomes” available with the full set of publications. 

62 

 
 
                                                 
The estimated costs in Figure 30 represent values more accurately displaying how much the 
visited network must be paid by the visiting network to ensure cost recovery.  

Figure  30:  Estimated data  roaming  unit  costs  in  €/GB including  estimates for  transit 
costs 

Source: Axon Consulting, SMART 2017/0091 

Comparing  the  unit  costs  presented  in  Figure  30  (i.e.  including  transit)  with  the  estimates 
solely from the model in Figure 27, it is clear that transit costs contribute significantly to the 
total  costs  estimates  (in  the  range  of  5%  for  the  highest  estimated  costs  and  40%  for  the 
lowest). 

For voice roaming services, the additional costs faced by the visited network are transit and 
termination.  

The total costs for wholesale voice roaming, including transit and termination, are shown in 
Figure 31. In 2017, costs in all countries were roughly between 1.5 and 2.7 €cents/min, with 
an almost similar range between 1.4 and 2.5 €cents/min for 2025. As was the case in Figure 
28,  almost  all  countries  have  seen  decreasing  estimates  of  costs,  with  Malta  maintaining  a 
comparatively high estimate throughout the period.  

63 

1,502,002,50EUR/GB 
 
Figure 31: Estimated voice roaming unit costs in €cents/min, including transit and 
termination costs  

Source: Axon Consulting, SMART 2017/0091 

Regarding voice roaming services, the impact of adding transit and termination is even more 
significant than for data. Compared with Figure 28, it is clear that transit and termination costs 
significantly  increase  the  estimated  costs  faced  by  the  visited  operator.  In  Figure  28,  costs 
estimates ranging between 0.2 and 0.6 €cents/min were presented, illustrating the significant 
impact of an additional 1.3 €cents/min103 to the total cost.  

For  the  reasons  outlined  and  described  above,  transit  and  termination  costs  must  always  be 
included, whenever assessing the total costs faced (and to be recovered) by visited operators 
for hosting roaming customers from abroad on their network. 

6.7  BEREC response to the cost model and estimates 

As foreseen in the Roaming Regulation104, BEREC is to be consulted by the Commission for 
the  purposes  of  the  roaming  review.  In  June  2019,  BEREC  provided  its  opinion  based  on 
information  collected  from  NRA’s  and  operators105.  Following  the  publication  of  the  Axon 

103 The sum of transit costs (0.5 €cents/min) and termination costs (approx. 0.8 €cents/min). 
104 Regulation (EU) 531/2012 of the European Parliament, Article 19(3). 
105 BEREC opinion on the functioning of the roaming market as input to EC evaluation, BoR (19)101, available 
here. 

64 

0,600,801,00EURCents/min 
 
 
 
                                                 
cost  model  in  July  2019,  BEREC  published  in  September  2019  a  supplementary  analysis 
regarding the relation between wholesale prices (hereinafter ‘the supplementary analysis’)106. 

In BEREC’s supplementary analysis, a comparison between current and estimated wholesale 
costs and wholesale caps for the relevant roaming servive is conducted. BEREC analyses the 
estimates  from  the  Axon  cost  model  combined  with  estimates  for  transit-  and  termination 
costs,  hereby  taking  the  best  available  estimates  of  the  full  range  of  costs  implied  in  the 
provision of wholesale roaming services.  

BEREC  notes  some  limitations  to  the  cost  model  including  values  for  cell  radii,  some  few 
unexpected  fluctuations/reductions  in  number  of  sites  and  some  concerns  regarding 
reconciliation  of  the  cost  base  observed  for  some  modelled  operators.  Finally,  some 
fluctuations in the overall service results were also observed.  

Despite these potential limitations however, BEREC expresses overall confidence in the cost 
model and the estimates produced from it: BEREC considers that “the cost model provides a 
range  of  reliable  results  to  be  used  for  its  supplementary  analysis”.  The  supplementary 
analysis presents a number of results and comparisons based on the estimates from the cost 
model. 

By  defining  minimum  and  maximum  values  per  service  as  estimated  by  the  cost  model, 
BEREC  identifies  a  range  of  outcomes  for  which  one  can  evaluate  the  costs.  As  described, 
these costs are also added to the estimates for transit and termination. These results are then 
compared  with  the  wholesale  prices  for  unbalanced  roaming  traffic  where  possible  and  the 
corresponding caps. 

BEREC ends its analysis with the following observations: the maximum unit costs for voice 
roaming services are 40 % lower than the price cap imposed, with minimum unit costs being 
60 %  lower  than  the  cap  applicable  in  the  first  half  of  2022.  For  data  roaming  services, 
according  to  BEREC,  the  unit  costs  are  between  25-50 %  lower  than  the  caps  in  2022. 
Regarding  roaming  SMS,  BEREC  calculates  a  70 %  difference  between  the  imposed 
wholesale cap and the unit costs.  

BEREC concludes that “there is some room for further reduction of the wholesale caps, while 
still  guaranteeing  that  operators  are  able  to  recover  their  efficiently  occurred  costs  for 
providing wholesale roaming services, and at the same time still leaving room for negotiating 
prices  below  the  wholesale  caps.”  Finally  it  is  pointed  out,  that,  due  to  the  lack  of  data 
provided by operators at the time of building the cost model, 5G is not included in the Axon 
cost model, implying that any changes brought forward by 5G roll-out will affect the results 
and conclusion.  

106 BEREC Supplementary analysis on wholesale roaming costs, BoR(2019)168, 20 September 2019, available 
here. 

65 

 
 
                                                 
7  COMPETITION IN WHOLESALE ROAMING MARKETS 

7.1  Evolution of wholesale (inbound) roaming volumes 

7.1.1  Net inbounder and outbounder countries 

The impact of RLAH on operators can vary markedly 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/EEA 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.  

Based on the data gathered for the BEREC’s International Roaming Benchmark Reports, the 
left part of the following figures show the relation between inbound and outbound traffic, for 
voice  -  inbounder  countries  (Figure  32)  and  outbounder  countries  (Figure  33),  for  data  - 
inbounder  countries  (Figure  34)  and  outbounder  countries  (Figure  35).  Inbounder  (resp. 
outbounder) countries are defined as countries whose total inbound roaming volume is greater 
(resp. smaller) than the total outbound roaming volume over the first year of RLAH (Q3 2017 
to Q2 2018). The right part of the Figures show the share that the net (inbound or outbound 
depending  on  the  country)  roaming  traffic  represents  compared  to  the  domestic  traffic  for 
each country.  

For  voice  services,  16  out  of  the  29  countries  providing  the  data  (i.e.  the  28  EU  Member 
States plus Norway) are net inbounders of roaming voice traffic while the remaining 13 are 
net  outbounders  (Figure  32,  left  panel)107.  Figure  32  (right  panel)  also  shows  that,  in 
inbounder countries, the net inbound roaming voice traffic (i.e. inbound roaming voice minus 
outbound roaming voice traffic) has increased under RLAH compared to the period before. It 
represents typically between 1% and 5% of domestic voice traffic (Figure 32). Malta stands 
out with a share reaching 10% in summer. Croatia (in summer)  108 and Belgium follow with 
shares that can reach 7%, followed by Austria at 6% in winter.        

107 Net inbounder countries of roaming data traffic include: AT, BE, CY, DE, EL, ES, FR, HR, HU, IE, IT, MT, 
NO,  PT,  SE,  UK.  This  classification  is  based  on  the  average  inbound/ratio  over  the  first  year  of  RLAH.  This 
does  not  exclude  that  in  a  given  quarter,  an  inbounder  country  may  experience  larger  outbound  than  inbound 
traffic. 
108 Figure 32 shows that Croatia is an outbounder country in winter time. 

66 

 
 
                                                 
Figure 32: Voice services, inbounder countries - Left panel: ratio between inbound and 
outbound  roaming  voice  volumes.  Right  panel:  net  outbound  roaming  voice  volumes 
(outbound  voice  volumes  minus  inbound  voice  volumes)  as  %  of  total  domestic  voice 
volumes, Q4 2016 – Q1 2019.  

Source: Data collected for the 19th-23rd  International Roaming BEREC Benchmark Reports. JRC caculations. 

67 

 
 
 
 
Figure 33: Voice services, outbounder countries – Left panel:  ratio between inbound 
and outbound roaming voice volumes. Right panel: net outbound roaming voice volumes 
(outbound voice volumes minus inbound voice volumes) as % of total domestic voice 
volumes, Q4 2016 – Q1 2019.  

Source: Data collected for the 19th-23rd International Roaming BEREC Benchmark Reports. JRC caculations. 

68 

 
 
 
 
In  outbounder  countries,  although  it  has  increased  under  RLAH  compared  to  the  period 
before,  the  net  outbound  voice  roaming  traffic  (i.e.  outbound  roaming  voice  minus  inbound 
roaming  voice  traffic)  still  represents  a  small  fraction  of  the  domestic  voice  traffic  of  these 
operators, typically below 4% and not greater than 5% of the domestic voice traffic (Figure 
33)109.  

For data services, 12 out of the 29 countries included in the exercise (i.e. the 28 EU Member 
States plus Norway) are net inbounders of roaming data traffic while the remaining 17 are net 
outbounders (Figure 34, left panel)110.  

The  observations  concerning  data  services  are  similar  to  the  observations  made  above  for 
voice  services:  the  net  inbound  roaming  data  traffic  (i.e.  inbound  roaming  data  minus 
outbound roaming data traffic) represents in general a limited (though increasing with RLAH) 
share  of  the  domestic  traffic.  However,  in  the  smaller  inbounder  countries  (Malta,  Cyprus, 
Greece), the net inbound roaming data traffic represents in some quarters a very high share of 
domestic  data  traffic  (Figure  34,  right  panel).  In  Portugal  and  Croatia  too,  the  net  inbound 
roaming  data  traffic  represented  more  than  10%  of  the  domestic  traffic  in  summer  under 
RLAH, as well as in Belgium the rest of the year. 

In outbounder countries, in spite of the increase in roaming data traffic, the net outbound data 
roaming  traffic  (i.e.  outbound  roaming  data  minus  inbound  roaming  data  traffic)  only 
represents a small fraction of the domestic data traffic of these operators, typically below 3% 
of  the  domestic  data  traffic  and  only  exceptionally  up  to  5%  of  the  domestic  data  traffic  in 
some quarters in a couple of countries (Figure 35). 

109 With one exception in Slovenia (SI) in Q3 2018, where net outbound roaming voice traffic reached about 6% 
of the domestic voice traffic. 
110 Net inbounder countries of roaming data traffic include: AT, BE, CY, CZ, DE, EL, ES, FR, HR, HU, IT, MT, 
PT. This classification is based on the average inbound/ratio over the first year of RLAH. This does not exclude 
that in a given quarter, an inbounder country may experience larger outbound than inbound traffic. 

69 

 
 
                                                 
Figure 34: Data services, inbounder countries. Left panel: ratio between inbound and 
outbound roaming data volumes. Right panel: net outbound roaming data volumes 
(outbound data volumes minus inbound data volumes) as % of total domestic data 
volumes, Q4 2016 – Q1 2019. 

Source: Data collected for the 19th-23rd International Roaming BEREC Benchmark Reports. JRC calculations. 

70 

 
 
 
 
Figure 35: Data services, outbounder countries. Left panel: ratio between inbound and 
outbound roaming data volumes. Right panel: net outbound roaming data volumes 
(outbound data volumes minus inbound data volumes) as % of total domestic data 
volumes, Q4 2016 - Q1 2019. 

Source: Data collected for the 19th-23rd International Roaming BEREC Benchmark Reports. JRC calculations. 

71 

 
 
 
The  above  analysis  shows  that  operators  in  inbounder  countries  have  benefited  from  the 
increase  in  demand  for  wholesale  roaming  services  and  that,  for  operators  in  outbounder 
countries,  the  net  outbound  roaming  traffic  -  despite  the  increase  under  RLAH  -  only 
represents a small fraction of the domestic traffic. 

7.1.2 

Inbound roaming traffic exhibits an explosive increase  

The following two figures show, for inbounder and outbounder countries, the development of 
inbound  roaming  traffic  for  voice  (Figure  36)  and  data,  distinguishing  the  balanced  and 
unbalanced part of the traffic (Figure 37). The balanced roaming traffic is the traffic that both 
operators exchange (i.e. the roaming traffic equally and reciprocally generated by customers 
of  both  operators  on  both  networks).  The  unbalanced  roaming  traffic  is  the  additional 
(unmatched)  traffic  generated  by  the  customers  of  one  operator  on  the  other  operator’s 
network.  The  scale  on  the  vertical  axis  is  identical  in  the  two  panels  within  each  figure, 
allowing a direct comparison of the inbound roaming volumes in all countries. The explosive 
increase  in  roaming  traffic  (especially  data  traffic),  the  seasonality  (in  particular  for  data  in 
countries like Greece, Spain, Croatia, Italy, Portugal and France), and the respective sizes of 
the inbound roaming markets clearly stand out of the two figures. 

Figure 36: Inbound roaming voice traffic, Q4 2016 – Q1 2019 

Source: Data collected for the 19th-23rd International Roaming BEREC Benchmark Reports. JRC calculations. 

72 

 
 
 
Figure 37: Inbound roaming data traffic, Q4 2016 – Q1 2019 

Source: Data collected for the 19th-23rd International Roaming BEREC Benchmark Reports. JRC calculations. 

7.1.3  National  wholesale roaming markets are not overly concentrated 

The Herfindahl–Hirschman Index, (HHI) provides a measure of concentration in a market. It 
is  calculated  as  the  square  sum  of  the  market  shares  of  the  different  players.  When  such 
market shares are expressed as percentages (0-100) the index takes values between 0 (perferct 
competition) and 10 000 (absolute monopoly). A market with two equivalent players (i.e. with 
equal  market  shares)  is  characterised  by  an  HHI  of  5  000,  while  a  market  with  three 
equivalent players is characterised by an HHI of 3 333. 

The  HHI  in  the  wholesale  roaming  market  for  both  voice  (Figure  38)  and  data  (Figure  39) 
ranges  between  3  000  and  5  000  with  only  few  exceptions.  This  range  of  values  points 
towards markets with 2 to 3 strong competitors. The only countries with a post-RLAH HHI 
index below 3 000 are Denmark, Poland and Sweden (for both voice and data) as well as UK 
(only  for  data).  On  the  other  hand  HHIs  for  both  the  voice  and  data  markets  in  Bulgaria, 
Croatia, Lithuania, Malta and Norway are above 5 000 post-RLAH.  

The relative stability of the HHI pre- and post-RLAH (blue and red bars respectively in Figure 
38 and Figure 39) shows that RLAH has not significantly impacted the level of concentration 
on the national wholesale roaming voice markets. If anything, the Member States where the 
HHI  tended  to  decrease  post-RLAH  are  more  numerous  than  the  Member  States  where  it 
tended to increase, indicating that the level of competition may have slightly increased on the 
wholesale roaming market under RLAH. 

73 

 
 
 
Figure 38: HHI for the wholesale roaming market – Voice volumes 

Source: Data collected for the 19th-23rd International Roaming BEREC Benchmark Reports. JRC calculations. 
Note: 'pre-RLAH' covers the last period before RLAH (Q4 2016 - Q2 2017), 'post-RLAH covers the 
corresponding period after RLAH (Q4 2018 – Q1 2019), as Q2 2019 was not available at the time this analysis 
was made. 

Figure 39: HHI for the wholesale roaming market – Data volumes 

74 

02,0004,0006,0008,000HHI - VoiceATBEBGCYCZDEDKEEELESFIFRHRHUIEITLTLULVMTNLNOPLPTROSESISKUKPre-RLAHPost-RLAH02,0004,0006,0008,000HHI - DataATBEBGCYCZDEDKEEELESFIFRHRHUIEITLTLULVMTNLNOPLPTROSESISKUKPre-RLAHPost-RLAH 
 
 
 
Source: Data collected for the 19th-23rd International Roaming BEREC Benchmark Report. JRC calculations. 
Note: 'pre-RLAH' covers the last period before RLAH (Q4 2016 - Q2 2017), 'post-RLAH covers the 
corresponding period after RLAH (Q4 2018 – Q1 2019), as Q2 2019 was not available at the time this analysis 
was made. 

7.1.4  Group operators keep part of their roaming traffic within the group  

Mobile operators belonging to a group have the ability of directing outbound roaming traffic 
to other companies within the group in countries where such companies are present (in-group 
roaming traffic).  

In  the  case  of  voice  (Figure  40),  around  60%  of  operators  responding  to  the  BEREC 
Benchmark questionnaire do not direct any traffic to in-group companies. These are likely to 
be mostly non-group operators111, i.e. MNOs that do not belong to any group and operate in 
one Member State only and MVNOs. Slightly less than 40% of the responding operators reply 
that they direct part of their outbound roaming traffic in-group and are therefore affiliates of a 
group operating in more than one Member State.  

The share of roaming traffic that a particular affiliate can send to other affiliates of the same 
group depends on the presence of the group in the countries where the customers of the given 
affiliate  travel.  The  in-group  share  of  outbound  roaming  traffic  of  an  affiliate  therefore 
depends both on the size of the geographical scope footprint of the affiliates' group and on the 
relative importance of that footprint in the travel destination of the customers of that particular 
affiliate. Figure 40 shows that, in practice, affiliates of a group direct only a minority of their 
roaming traffic in-group. Less than 10% of the group affiliates direct more than one third of 
their outbound roaming traffic within the group, and no affiliate sends more than 50%.    

111 Group operators have an interest to keep roaming traffic within the networks of the group. 

75 

 
 
                                                 
Figure 40: Voice services - Cumulative density distributions of in-group outbound retail 
roaming voice traffic (calls made) as % of the total outbound retail roaming voice traffic 
(calls made), per operator, for Q3 2017-Q1 2019 

Source: Data collected for the 19th-23rd International Roaming BEREC Benchmark Reports. JRC calculations. 

The  situation  is  similar  in  the  case  of  data  (Figure  41):  around  10%  of  operators  direct  one 
third of their outbound roaming traffic to in-group networks and none direct more than 50%.  

Figure 41: Data services - Cumulative density distributions of in-group outbound retail 
roaming  data  traffic  as  %  of  the  total  outbound  retail  roaming  data  traffic,  per 
operator, for Q3 2017-Q1 2019  

Source: Data collected for the 19th-23rd International Roaming BEREC Benchmark Reports. JRC calculations. 

7.2  Evolution of prices 

76 

 
 
 
 
7.2.1  Wholesale roaming prices have been steadily decreasing 

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  regulated  wholesale  roaming  prices, 
and appears to have triggered further reductions in actual wholesale roaming prices.  

The  average  EEA  wholesale  roaming  price  for  voice  services  presents  a  slowly  decreasing 
trend  (Figure  42).  The  average  wholesale roaming  price  for  outgoing  voice  traffic  fell  from 
€2.90  cents/min  in  Q1  2017  to  €1.97  cents/min  in  Q1  2019112.  Wholesale  prices  for  net 
outbound (unbalanced) roaming traffic, which is the part of the roaming traffic generating net 
payments  from  one  operator  to  the  other,  are  even  lower  (€1.75  cents/min  in  Q1  2019, 
compared to €2.42 cents/min in Q1 2017). 

Figure 42: Voice services: development of the average wholesale roaming rate for voice 
in the EEA, Q2 2016 to Q1 2019 

Source: Based on data from the 19th-23rd International Roaming BEREC Benchmark Report 

The average EEA wholesale roaming price for data services remained stable throughout 2016 
but  decreased  sharply  in  2017  following  the  sharp  reduction  in  the  regulated  price  cap.  It 
further  decreased  in  2018  with  the  next  step  in  the  regulated  glidepath  (Figure  43). 
Specifically,  the  average  wholesale  rate  for  data  decreased  from  €8.22  /GB  in  Q1  2017  to 
€1.78  /GB  in  Q1  2019.  As  in  the  case  of  voice,  wholesale  prices  for  net  outbound 
(unbalanced) roaming traffic are even lower (€1.59 /GB in Q1 2019, compared to €5.44 /GB 
in Q1 2017).  

112 19th-23rd International Roaming BEREC Benchmark Reports, covering October 2016 – March 2019. 

77 

 
 
 
                                                 
Figure 43: Data services: development of the average wholesale roaming rate for data in 
the EEA, Q2 2016 to Q1 2019 

Source: Based on data from the 19th-23rd International Roaming BEREC Benchmark Report 

The  decline  in  wholesale  roaming  prices  is  observed  in  all  Member  States  (Figure  44  and 
Figure 45, showing the last quarter before RLAH, Q2 2017, and the last quarter available, Q1 
2019). This decline is determined mainly by two factors. First, new (and, for data, annually 
decreasing) maximum wholesale roaming prices laid down in the Roaming Regulation have 
acted  as  much  lower  ceilings  on  prices,  triggering  competitive  market  dynamics  between 
operators offering wholesale roaming access below those ceilings. Second, the introduction of 
RLAH has resulted in significant increases in roaming volumes (as shown in section 5.1.1), 
thereby fuelling further competition in wholesale roaming prices. 

78 

 
 
 
Figure  44:  Voice  services:  average  wholesale  roaming  rate  for  voice  in  the  Member 
States, Q2 2017 and Q1 2019 

Source: Based on data from the 19th-23rd International Roaming BEREC Benchmark Report 

Figure 45: Data services: average wholesale roaming rate for data in the Member States, 
Q2 2017 and Q1 2019 

Source: Based on data from the 19th-23rd International Roaming BEREC Benchmark Report 

79 

 
 
 
 
 
As  observed  in  the  interim  Report113,  these  declines  in  wholesale  roaming  prices  should  be 
welcomed  for  three  reasons.  Firstly,  lower  wholesale  roaming  prices  have  greatly  mitigated 
any  potential  impact  from  the  introduction  of  RLAH  on  outbounder  operators  (see  section 
7.1.1), as they have contributed to reduce 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. Thirdly, 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. 

7.2.2 

In-group wholesale roaming rates are not necessarily lower than out-of-group rates 

Contrarily  to  what  one  might  expect,  the  data  gathered  for  the  BEREC  Benchmark  Reports 
show  that  wholesale  roaming  rates  within  groups  of  operators  (in-group  prices)  are  not 
necessarily lower than out-of-group wholesale roaming rates.  

Figure 46 depicts the relationship between the in-group average versus out-of-group average 
wholesale roaming rates for voice, per operator. For the majority of operators the two rates are 
close  to  each  other.  For  two  sizeable  subsets  of  group  operators,  in-group  rates  are 
respectively lower and higher than out-of-group rates.  

113 Report 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, COM(2018) 822 final, available here. 

80 

 
 
                                                 
Figure 46: Average in-group wholesale voice roaming rates versus average out-of-group 
wholesale voice roaming rates (Q1 2019) 

Source: Data collected for the 23rd International Roaming BEREC Benchmark Report. JRC calculations. 

Similarly,  Figure  47  depicts  the  relationship  between  the  in-group  average  versus  out-of-
group average wholesale data roaming rates, per operator. The same observations as for voice 
services apply. 

Figure 47: Average in-group wholesale data roaming rates versus average out-of-group 
wholesale data roaming rates (Q1 2019) 

Source: Data collected for the 23rd International Roaming BEREC Benchmark Report. JRC calculations. 

81 

 
 
 
 
The  above  Figures  show  that  in-group  wholesale  roaming  prices  are  not  necessarily  lower 
than out-of-group prices. 

7.3  Wholesale structural measures  

The Roaming Regulation provides the possibility to include conditions to prevent permanent 
roaming or anomalous or abusive use of wholesale roaming access in reference offers for such 
access.  The  Roaming  Regulation  also  provides  the  visited  network  with  the  possibility  to 
“terminate the wholesale roaming agreement unilaterally on grounds of permanent roaming or 
anomalous or abusive use of wholesale roaming access, only upon prior authorisation of the 
visited network operator’s NRA” (Article 3(6) paragraph 3). 

The joint Commission/BEREC online survey of March 2019 shows that 10 % of responding 
MNOs  (9  out  of  91)  have  included  explicit  measures  foreseen  in  Article  3(6)  to  prevent 
permanent  roaming  or  anomalous  or  abusive  use  of  wholesale  roaming  access  in  their 
reference  offers.  7%  of the  responding  MNOs  (6  out  of  91)  and  1 MVNO  (out  of  89)  have 
experienced cases of termination of wholesale agreements because of permanent roaming or 
abusive or anomalous use. 3 NRAs (Norway, Sweden and Germany) out of 30 NRAs replied 
that they received a request for authorisation to terminate a wholesale roaming agreement. In 
its Opinion, BEREC’s analysis of these NRAs’ replies shows that 2 of the 3 NRAs (Norway 
and  Sweden)  indicated  “permanent  roaming”  as  the  reason  for  the  operators’  request  for 
authorising the termination, 1 NRA (Germany) stated that the case concerned other facts that 
did  not  need  NRA’s  authorisation  since  it  was  a  case  of  an  ordinary  contract  termination. 
Norway’s NRA reported that the request for termination of the wholesale roaming agreement 
due to permanent roaming was approved on 6 March 2019. 

More generally, only 4 NRAs reported having received disputes regarding wholesale roaming 
access. The remaining 26 NRAs received no notice of roaming access conflicts. The 4 NRAs 
mentioned that the main reasons for the disputes were wholesale access, wholesale prices and 
permanent roaming114. 

The  above  shows  that  most  operators  see  no  need  to  include  specific  conditions  to  prevent 
permanent  or  anomalous  or  abusive  usage  of  wholesale  roaming  access  in  their  reference 
offer. In its Opinion, BEREC notes that in general, operators which have detected businesses 
based  on  permanent  roaming  have  decided  to  pursue  commercial  agreements  with  access 
seekers  rather  than  deny  access,  which  would  have  led  to  a  dispute  with  the relevant  NRA. 
BEREC  concludes  that,  with  the  measures  provided,  the  Roaming  Regulation  sufficiently 
prevents  permanent  roaming  or  anomalous  or  abusive  usage  at  wholesale  level.  These 
measures  are  useful  tools  to  promote  competition  and  enable  NRAs  to  solve  (potential) 
disputes between operators as well as prevent misuse on the wholesale roaming market. 

7.4  Situation of MVNOs  

114 See more details on these disputes in section 6.3.4 of BEREC Opinion 

82 

 
 
                                                 
An MVNO does not own a radio access network in the country(ies) where it operates. As a 
consequence,  an  MVNO  cannot  host  any  roaming  traffic  from  a  foreign  MNO  in  return  for 
the roaming traffic that the MVNO sends out to that foreign MNO. An MVNO can only buy 
at  wholesale  level  the  outbound  roaming  traffic  generated  by  its  customers  abroad,  without 
the  possibility  to  trade/exchange  (part  of)  this  outbound  roaming  traffic  against  inbound 
roaming traffic. MVNOs are therefore in a structurally different situation from MNOs when 
negotiating wholesale roaming access. 

7.4.1  The various types of wholesale roaming access for MVNOs 

As  described  in  the  BEREC  Opinion,  there  are  various  ways  of  establishing  wholesale 
roaming  access  agreements  for  MVNOs.  Article  3  of  the  Roaming  Regulation  imposes  an 
obligation  for  MNOs  to  meet  all  reasonable  requests  for  wholesale  roaming  access,  which 
includes direct wholesale roaming access115 and wholesale roaming resale access116.  

Full  MVNOs  have  their  own  IMSI117  numbering  range  and  can  negotiate  direct  bilateral 
agreements  with  MNOs.  They  can  also  buy  wholesale  resale  access  via  their  domestic  host 
MNO, or from another MNO, or from a hub118. Light MVNOs use the same IMSI number as 
their host MNO and must rely on a form of wholesale resale access. It should be noted that 
these categories may not be clear-cut and that overlaps between them may occur. Figure 48 
shows the distribution of types of access among the full and light MVNOs that responded to 
the  joint  Commission/BEREC  survey  of  March  2019.  The  most  common  way  of  getting 
wholesale  roaming  access  for  MVNOs  is  to  rely  on  their  domestic  host  MNO’s  wholesale 
roaming access. However, a substantial proportion of full MVNOs do buy wholesale roaming 
services from another MNO. 

115 Direct access means that the retail provider contracts directly with a foreign network in the EEA, allowing its 
roaming customers to use roaming services when they visit this network . 
116 Resale access means that the retail provider bases its retail service on the wholesale service provided by an 
MNO, usually, but not necessarily, in the end user’s home country.  
117 International Mobile Subscriber Identity.  
118  A  hub will  handle  the  technical  set  up for roaming.  Each operator  that is connected  to  the hub has to  sign 
agreements with the other operators connected to the hub and prices for traffic are negotiated between each of 
the connected operators .  

83 

 
 
 
                                                 
Figure 48: Type of wholesale roaming access for full and light MVNOs 

100%

90%

80%

70%

60%

50%

40%

30%

20%

10%

0%

91% 

45% 

30% 

13% 

4% 

8% 

5% 

4% 

Wholesale Resale
Access from domestic
host MNO

Wholesale Resale
Access from another
MNO

Wholesale access via
a hub

Direct bilateral
negotiations with
MNOs

Another channel

Source: Joint Commission/BEREC survey of MVNOs, March 2019 

Full MVNO

Light MVNO

7.4.2  Specific challenges reported by MVNOs in wholesale roaming agreements 

In its Opinion, BEREC provides a full description of the specific challenges reported by a few 
MVNOs119on the wholesale roaming market, depending on the type of wholesale access for 
roaming used. In some cases, MVNOs report having to pay wholesale charges in addition to 
the regulated wholesale roaming charges (e.g. annual platform fixed costs for hubs, in some 
cases additional charges to be paid to the MNO reselling the wholesale roaming access, be it 
the host MNO or another MNO).  One MVNO reported a lack of 4G access from the MNO 
and  delaying  tactics  in  negotiations  and  implementation  of  a  direct  bilateral  agreement. 
Around 16 % (7) of the responding light MVNOs had problems to get wholesale access from 
their  domestic  host  MNO  (e.g.  large  access  fees  and  bank  guarantees,  lack  of  4G  access). 
Several MVNOs report that they do not  get discounts  on the wholesale roaming  price  caps. 
12 %  of  the  MVNOs  (11  out  of  89)  reported  the  existence  of  disputes  with  their  wholesale 
provider after signing the access agreement. 

7.4.3  Wholesale roaming prices paid by MVNOs  

Figure  49  (for  voice)  and  Figure  50  (for  data)  below  present  the  lowest  wholesale  roaming 
prices paid by MNOs (blue) and the average prices paid by MVNOs (red) from each country, 
showing  these  prices  against  the  regulated  maximum  wholesale  roaming  tariffs  (solid  line). 
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, MVNOs 
typically pay wholesale roaming prices that are higher than those paid by MNOs; some pay 

119 Based on the Joint Commission/BEREC survey of MVNOs, March 2019 

84 

 
 
 
                                                 
prices broadly in line with the level of the wholesale roaming price caps, however 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  all  MVNOs 
necessarily 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 49: Wholesale roaming prices paid for voice by MNOs (blue dots) and MVNOs 
(red dots), 2018 

Source: Data collected for the 22nd International Roaming BEREC Benchmark Report (March 2019) and joint 
Commission/BEREC survey of MVNOs (March 2019). The chart uses the average of the 5 lowest prices paid by 
MNOs and the average price paid by MVNOs. JRC's calculations. 

85 

0.511.522.53EUR/cents per minATBEBGCYCZDEDKEEELESFIFRHRHUIEITLTLULVMTNLNOPLPTROSESISKUKCountryAverage of the five lowest voice rates - MNOsAverage EU price voice - MVNOs 
 
 
 
Figure  50:  Wholesale  roaming  prices  paid  for  data  by  MNOs  (blue  dots)  and  MVNOs 
(red dots), 2018 

Source: Data collected for the 22nd International Roaming BEREC Benchmark Report (March 2019) and joint 
Commission/BEREC survey of MVNOs (March 2019). 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  49  and  Figure  50  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. 

Figure 51 shows, for MVNOs providing the data in the joint Commission/BEREC survey of 
March  2019,  the  average  wholesale  price  paid  by  the  MVNO  for  domestic  access  and  for 
roaming access for voice services. Figure 52 shows the same for data services. As, in the case 
of voice services, the roaming access price covers termination, the weighted average MTR in 
the EU in 2018120 is added to the domestic price for comparison reasons.  

120 Maximum MTRs set in Member States as of 1 July 2018. 

86 

0123456EUR/GBATBEBGCYCZDEDKEEELESFIFRHRHUIEITLTLULVMTNLNOPLPTROSESISKUKCountryAverage of the five lowest data rates - MNOsAverage EU price data - MVNOs 
 
 
 
                                                 
The  two  Figures  show  that  MVNOs  usually  pay  substantially  lower  wholesale  prices  for 
domestic access than for roaming access, although it is not systematically the case for voice 
when termination is added to the domestic price. Moreover, it should be noted that wholesale 
roaming  access  does  entail  roaming-specific  costs121  and  usually  transit  costs  that  are  not 
encountered  in  domestic  access.  According  to  data  gathered  by  the  Commission  from 
operators  in  the  second  half  of  2018,  transit  prices  for  voice  and  data  services  amount  on 
average to 0.5 cent/min and 0.2 cent/GB respectively.122 These additional costs for wholesale 
roaming  access,  which  are  not  factored  in  in  the  two  Figures  below  do,  however,  not  fully 
explain the difference between the wholesale roaming and domestic prices paid for data by a 
number of MVNOs. 

Figure 51: Voice services - Average wholesale domestic price plus EU weighted average 
MTR123 (as of July 2018) versus average wholesale roaming price paid by MVNOs (1 dot 
= 1 MVNO), 2018 

Source: Joint Commission/BEREC survey of MVNOs, March 2019 

121 Such as network cost related to roaming provisioning, roaming route testing/monitoring and opening costs, 
roaming operation and management costs, roaming data clearing costs, roaming financial clearing costs, roaming 
negotiation and contract management/regulation costs.  
122 See section 6.6 above. 
123 Wholesale roaming services include both origination and termination of the call, while wholesale domestic 
services include only the origination of the call.  

87 

 
 
 
 
                                                 
Figure  52:  Data  services  -  Average  wholesale  domestic  price  versus  average  wholesale 
roaming price paid by MVNOs (1 dot = 1 MVNO), 2018 

Source: Joint Commission/BEREC survey of MVNOs, March 2019 

7.4.4  Possible measures to improve the situation for MVNOs 

In  its  Opinion,  BEREC  proposes  a  series  of  measures  that  could  be  considered  to  be 
introduced  in  the  Roaming  Regulation  in  order  to  improve  the  situation  of  MVNOs  in  the 
wholesale  roaming  market,  so  that  they  remain  competitive  on  their  respective  domestic 
markets.  The  benefits  and  difficulties  created  by  the  measures  suggested  by  BEREC  in  its 
Opinion are analysed below. 

Reduce the wholesale roaming price caps 

Pros 

Reduces the costs of outbound roaming traffic for MNOs and MVNOs. 

The  cost  assessment  produced  by  the  external  study  (section  6)  as  well  as  the 
market  prices  reported  in  the  BEREC  Benchmark  Reports  (section  7.2)  tend  to 
indicate that there is some room to lower the current price caps while ensuring cost 
recovery in all Member States. 

Cons 

The level of the price caps should give sufficient assurance of cost recovery for all 
visited  operators  in  the  EU/EEA  for  the  provision  of  wholesale  roaming  services, 
including  room  for  uncertainty  around  cost  estimates  and  for  further  commercial 
negotiations below the caps. 

While the market has been found not to function optimally, price regulation to cost 
is not the norm in the absence of significant market power, and the need to do so for 
the whole market in order to address the problems of an outlier group would need to 
be  carefully  assessed;  including  the  possible  knock-on  effects  in  (non-regulated) 

88 

0123456Average wholesale domestic price-data (EUR/GB)0246Average wholesale roaming price-data (EUR/GB) 
 
 
domestic wholesale negotiations. 

Impose an obligation on MNOs to pass on to their hosted MVNOs the discount for wholesale 
roaming services they get from any visited network 

Pros 

Cons 

Reduces  the  costs  of  outbound  roaming  traffic  for  MVNOs  to  the  same  extent  as 
their host MNOs. 

Does  not  take  into  account  the  costs  incurred  by  the  MNO  to  host  the  inbound 
roaming  traffic  which  is  a  key  determinant  of  the  discount  obtained  by  the  MNO 
from a visited network. 

Likely knock on effects  on domestic wholesale  markets (e.g. increase in domestic 
wholesale prices). 

As noted by BEREC, such an obligation would be: 

-  very  complex  to  implement  in  practice  (e.g.  MNOs  have  several  bilateral 
agreements  in  each  Member  State,  often  with  complex  price  structures; 
discounts  depend  on  volumes  and  are  often  granted  at  the  end  of  the 
specified periods) and  

-  difficult to monitor and enforce by NRAs  

Align wholesale roaming charges with national wholesale rates  

Pros 

Most favourable price for roaming that an MVNO can get. 

Cons  Wholesale  roaming  costs  are  objectively  higher  than  domestic  wholesale  costs 

(section 6). 

Does  not  take  into  account  the  actual  wholesale  roaming  price  paid  by  the  host 
MNO: the MNO may be obliged to re-sell wholesale roaming to its hosted MVNO 
at a lower price than the price it pays for wholesale roaming, therefore re-selling at 
a loss 

Likely knock on effects  on domestic wholesale  markets (e.g. increase in domestic 
wholesale prices). 

Make  sure  that  wholesale  caps  also  apply  to  alternative  wholesale  roaming  solutions,  like 
sponsored roaming124 
Pros 

This is already the case in the Roaming Regulation; it can be further clarified. 

Impose  an  obligation  on  MNOs  to  give  non-discriminatory  access  to  new  technologies  to 
MVNOs also for roaming 

124 Sponsored roaming is a wholesale solution where the applicant uses a dual IMSI solution, where one IMSI 
range belongs to the sponsored network. The effect is that the applicant’s end users have a second identity while 
roaming and they can make use of all the roaming agreements belonging to the sponsor network. Traffic prices 
are set by the sponsor network.   

89 

 
 
 
                                                 
Pros 

The  MNO  should  give  access  to  its  hosted  MVNO(s)  to  the  same  technology  for 
roaming as it gets from a visited  network; while the price for re-selling wholesale 
roaming access may differ from the price paid by the MNO (while being below the 
cap),  the  re-sold  product  itself  should  not  differ  from  what  the  MNO  buys  to  the 
visited network. 

Include time limits for signing roaming agreements and for technical implementation  

Pros 

Article  3  of  the  Roaming  Regulation  already  includes  time  limits  for  providing  a 
draft contract to the access seeker and for granting wholesale roaming access after 
the conclusion of the contract; a time limit for the contract negotiations themselves 
could  be  envisaged,  as  well  as  specifying  that  the  access  granted  should  be  fully 
operational within the time limit imposed. 

Include measures for incoming roaming calls for MVNOs 

Cons 

BEREC’s  Opinion  does  not  specify  what  such  measures  should  be  and  for  which 
benefits. 

7.5  Fraud  

The interim Report and the BEREC Opinion provide a description of the cases of fraudulent 
use/misuse of roaming services (other than abusive usage by individual users beyond fair use 
policy) reported by some MNOs and MVNOs125. The most common cases of such fraudulent 
use are: 

 

International Revenue Share Fraud, which consists in the artificial generation of traffic 
towards  international  destination  ranges  (within  the  EU/EEA)  with  high  termination 
rates that are subject to revenue share. This may concern calls to value added services 
as well as to operators charging high interconnection costs. 

  Abusive  use  of  SIM  cards  (typically  pre-paid),  where  the  entire  voice  or  SMS 
allowance was used in a very short time frame (often a few hours or even minutes) e.g. 
for  marketing  or  for  SMS  messages  sent  from  applications  to  persons  (A2P),  for 
roaming conference calls, etc 

  The  resale  of  SIM-cards  in  other  EU/EEA  countries  for  permanent  roaming  (though 

observed by less than 7% of the responding MNOs). 

The  lack  of  transparency  on  the  higher  charges  applied  to  calls  to  value-added  services 
numbers  has  been  also  reported  by  some  operators  as  an  issue:  23  %  of  the  responding 
operators referred having incurred extra costs at wholesale level from unexpected termination 
rates related to value-added roaming communications within the EU/EEA. As specified in the 

125 According to the Commission/BEREC survey of MNOs and MVNOs in March 2019, fraudulent use of SIM 
cards in voice and/or SMS messages in the EU/EEA has been observed by 24% of operators (34% of MNOs and 
15% of MVNOs). 

90 

 
 
 
                                                 
BEREC Retail Guidelines126, the Roaming Regulation does not apply to the whole tariff that 
is  charged  for  value  added  services  but  only  to  the  tariff  component  corresponding  to  the 
connection to such services. Numbering ranges for such value-added services cannot always 
be  recognized  by  an  operator  in  all  countries  in  advance,  hence  the  unexpected  additional 
costs incurred upon reception of wholesale roaming bills. 

Operators  have  generally  taken  measures  to  address  the  above-mentioned  problems  (e.g. 
blocking  or  suspending  SIM  cards  or  roaming  services,  barring  abusive/high-cost  number 
ranges,  new  contract  requirement  to  activate  SIM  cards  domestically  prior  to  roaming 
abroad).  In  addition  to  measures  taken  individually  by  operators,  BEREC  considers  in  its 
Opinion the possibility to create and maintain a European database of value-added services’ 
number  ranges127.  Additional  transparency  measures  could  also  be  considered  to  protect 
consumers against bill-shocks due to calls to value-added services while roaming, for instance 
including  information  in  the  “Welcome  SMS”  that  calls  to  such  services  are  subject  to 
specific tariffs linked to the service itself128.  

8  TECHNOLOGICAL DEVELOPMENTS  

A  variety  of  technological  and  market  developments  could  affect  competition  in  wholesale 
and/or retail roaming markets over the medium term (5-10 years). The study “Technological 
developments  and  roaming”129  assesses  such  developments  with  a  view  to  understanding 
whether  regulation  of  data,  voice  and  SMS  roaming  will  continue  to  be  necessary  going 
forwards. 

The developments examined in the study can be broadly categorised into: 

(i)  Developments  which  enable  end-users  to  bypass  data  roaming  or  roaming  calls  and 
SMS  by  using  alternative  technologies  to  traditional  mobile:  Wi-Fi  and  Wi-Fi 
aggregation  services;  Over-The-Top  (OTT)  services;  and  Rich  Communication 
Services (RCS). 

(ii) Technological  developments  and  platforms  which  could  facilitate  competition  in 
mobile  roaming  and  cross-border  connectivity:  Virtual  SIM  (VSIM);  Embedded 

126 Available here. 
127  One  NRA,  ComReg  (Ireland),  publishes  such  information  on  its  website:  https://www.comreg.ie/premium-
rate/about-premiumrate-services/what-are-premium-rate-services/   
128  BEREC  Opinion  also  suggests  making  compulsory  the  registration/identification  of  subscribers  of  pre-paid 
tariff plans available while roaming. However, it is not clear how such an obligation would address the misuse 
issues  raised  by  operators.  In  view  of  this  uncertainty,  such  a  measure  would  not  appear  as  proportionate. 
Finally,  BEREC  suggests  making  it  compulsory  to  apply  the  regulated  wholesale  termination  rates  to  all 
numbering  resources  for  the  conveyance  part  of  the  calls.  This  does  not  fall  under  the  scope  of  the  Roaming 
Regulation.  As  mandated  by  the  co-legislators  in  the  European  Electronic  Communications  Code,  the 
Commission will adopt by end of 2020 a delegated act setting maximum termination rates for mobile calls and 
fixed calls.  
129 SMART 2018/0012, available here 

91 

 
 
 
                                                 
SIM  (eSIM),  5G  and  5G  network  slicing;  Voice  over  LTE  (VoLTE);  Internet  of 
Things (IoT); Wholesale trading negotiating platforms; and Local data break-out. 
(iii) New  business  models  and  players  entering  the  roaming  space:  Multi-MVNO 
agreements  and  cross-border  MVNOs;  entry  of  equipment,  content  and  service 
providers into the roaming space. 

The  study  analyses  such  developments,  following  a  modified  Greenfield  approach130.  It 
concludes  that  OTT  voice  and  messaging  services  are  likely  to  present  the  greatest 
competitive threat to  traditional roaming  offers  for  mobile voice and SMS, while eSIM  and 
(especially for IoT) 5G and network slicing are also expected to disrupt roaming markets. 

8.1  The main developments with the prospect for a substantial impact on roaming 

Wi-Fi has gained popularity across Europe and is likely to remain attractive thanks to its cost, 
convenience  and  quality.  However,  it  is  unlikely  to  present  a  comprehensive  substitute  for 
mobile  data  “roaming”  for  consumers  or  mobile  IoT  because  it  lacks  complete  coverage. 
Moreover,  mobile  operators  may  increasingly  use  the  evolving  capabilities  to  integrate 
seamlessly  Wi-Fi  technologies  within  their  mobile  offer  in  a  5G  environment,  thereby 
encompassing some of its advantages. 

Over-The-Top  (OTT)  services  are  already  replacing  mobile  calls  and  SMS  for  certain 
purposes,  domestically as  well  as when  roaming,  in  both  the  business  and  consumer  sector. 
Conversely, more attractive roaming offers (based on RLAH) may have tempted end-users to 
switch  to  mobile  voice  rather  than  bypassing  the  network.  There  is  likely  to  be  residual 
demand  for  mobile  communications from users  without smartphones  and for calls  requiring 
any-to-any  connectivity.  However,  OTT  could  limit  the  potential  for  mobile  operators  to 
increase  voice  and  messaging  prices,  if  cost-effective  data  roaming  or  alternatives  are 
available. 

Embedded  SIM  (eSIM)  is  an  important  development  that  could  facilitate  competition  and 
switching in mobile connectivity including roaming. Its effects on competition may differ for 
different  market  segments,  and  depend  on  the  way  the  standard  is  implemented  and 
influenced  by  different  interest  groups  including  mobile  network  operators  and  device 
manufacturers.  The  most  significant  prospects  of  eSIM  could  be  in  connectivity  for  IoT 
including  connected  cars,  where  its  use  is  already  established.  eSIM  could  also  enable 
customers to select separate specialist roaming providers on their mobile handset, or facilitate 
their use of local mobile providers. However, customer take-up of specialist services might be 
limited, while the use of local mobile providers presents other challenges, including trust (for 
the  end-user),  identification  and  security.  It  is  possible  that  the  threat  of  such  competition 
could limit the ability of MNOs to raise prices, but eSIM in consumer devices is in its infancy 
and the impact has yet to be seen. The effects of eSIM on competition in consumer roaming in 

130  Following  the  modified  Greenfield  approach,  the  study  considers  the  competitive  constraints  that  each 
technology would introduce, under a hypothetical absence of the RLAH rules. 

92 

 
 
                                                 
the long term could be significantly improved if GSMA standards were to be revised so as to 
remove the current limitation of one profile per eSIM. 

5G technologies are likely to change the nature of roaming services. Among others, it could 
potentially affect the commercial model applied, e.g. basing pricing on bandwidth as opposed 
to  usage.  Network  slices  could  also  provide  options  for  MNOs  and  MVNOs  to  use  access 
agreements  as  an  alternative  to  traditional  roaming.  In  this  way  they  could  enhance  their 
flexibility  on  service  differentiation  (latency,  security  etc),  which  could  prove  to  be  very 
important  for  certain  vertical  use  cases.  However,  as  5G  roaming,  wholesaling  models  and 
vertical  use  cases  have  not  yet  been  defined,  the  impact  of  5G  on  competition  in 
roaming/global connectivity markets is not yet clear. 5G could provide increased potential for 
new  entry  and  retail  competition  if  MNOs  see  its  capabilities  as  an  opportunity  to  build  a 
diverse wholesaling model. On the other hand, some multi-national MVNOs have expressed 
fears, that 5G could potentially present a threat to them, obliging them to renegotiate existing 
arrangements, which are often tied to specific technology generations.    

The  development  of  new  models  for  wholesale  capacity  trading  could  also  affect  the 
roaming market. Their proponents claim two main benefits, which can help boost competition 
in  wholesale  roaming,  if  these  new  models  are  widely  adopted.  Firstly,  such  models  can 
anonymise  trading,  which  is  currently  conducted  through  face-to-face  bilateral  negotiations. 
Secondly,  they  can  break  the  link  between  outbound  and  inbound  traffic,  which  penalises 
operators  and  MVNOs  with  lower  countervailing  power.  If  such  new  models  were  indeed 
widely adopted and managed to achieve these expectations, they could in the long run abolish 
the need for regulating wholesale roaming rates. However, their case is still not proved. A key 
challenge  with  such  models  is  that  they  rely  on  participation  by  multiple  operators  in  each 
country, and there is a lack of incentive for larger mobile groups to participate.  

Finally the study notes that the separate sale of data roaming services (local data breakout) 
has not been used by the market. Since 2012, the Roaming Regulation has provided that end-
users may not be prevented by operators from accessing regulated data roaming services on a 
visited network by an alternative roaming provider. This structural measure, known as local 
data  breakout,  was  meant  to  foster  competition  on  the  roaming  market.  In  its  Opinion, 
BEREC also shows that this solution has not been deployed in practice131. Looking forward, 
based  on  surveys  of  the  market  conducted  in  2019  for  the  purposed  of  this  review,  both 
BEREC  and  the  study  note  the  lack  of  interest  by  market  players  in  implementing  such 
solution in the future.  

131  In  2016,  the  BEREC  International  Roaming  Benchmark  Report  identified  only  one  operator  offering  local 
data  breakout  services  in  the  EU.  It  seems  however  that  this  operator  from  Lithuania  (Cheap  Data 
Communications)  does  not  exist  anymore,  at  least  not  in  its  original  form.  Since  then,  according  to  the 
information available to the Commission, there has been no further use of the local data breakout solution. 

93 

 
 
                                                 
8.2  The study concludes that there does not seem to be a case for significant changes to 
the regulatory rules for international roaming under the current review.132 

As discussed above, while several of the examined developments are likely to disrupt roaming 
markets  in  the  future,  they  do  not  seem  likely  to  exert  sufficient  competitive  pressure  that 
would already call for immediate changes in the RLAH rules. 

In  the  medium  term,  the  study  considers  that  OTT  might  be  able  to  provide  a  sufficient 
constraint  on  pricing  to  enable  the  withdrawal  of  retail  roaming  obligations  on  voice  and 
SMS. Still, it expects that reliance on managed communications services is likely to continue, 
at  least  for  some  customers  and  for  some  types  of  communication.  The  prospective 
competitiveness of the retail market could also warrant the deregulation of wholesale markets. 
However,  in  this  case  additional  challenges  will  need  to  be  considered,  including  with  the 
migration  to  IP-based  services  by  means  of  VoLTE  and/or  RCS,  and  with  the  associated 
development  of  new  wholesale  offers.  All  the  above  could  be  the  subject  of  attention  for  a 
future review of the roaming rules.  

At the same time, the reliance of OTT on data connections suggests (according to the study) 
that the need for retail obligations on data roaming will continue. This need could be relaxed, 
only  if  there  is  evidence  that  competition  from  alternative  roaming  provision  (e.g.  eSIM  or 
local break-out) can effectively constrain retail data roaming prices.  

The study also considers that the need for data roaming regulation at the wholesale level will 
also  continue  in  the  medium  term  not  only  for  personal  communications  but  also  for  the 
growing  machine-to-machine  (M2M)  and  IoT  communications  market.  At  the  same  time, 
possible  future  bottlenecks,  regarding  the  wholesale  provision  of  roaming  services  with 
assured quality of service (e.g. for the M2M services), could call for additional interventions. 

8.3  The  study  suggests  considering  if  developments  relating  to  M2M  and  permanent 

roaming would call for immediate attention 

The  study  pinpoints  a  number  of  issues,  which  (according  to  the  study)  could  benefit  from 
immediate attention, relating to permanent roaming and M2M communications.  

Interviewees noted that there could be a lack of clarity about whether a roaming application 
was “M2M” or involved personal interaction, especially in cases – such as connected cars – 
where different applications may be provided by the same global connectivity provider under 
the same contract for different purposes in parallel (e.g. telemetry and in-car entertainment). 
While in most cases the distinction is clear, they claim that there is a grey area, notably the 
case  of  business-to-business  (B2B)  infotainment,  where  the  consumer  does  not  buy  the 
service. Some operators/regulators decide that it involves human intervention while others see 
it as an extension of M2M service. In general, they note that the approaches across different 

132 This conclusion is without prejudice to the review of maximum wholesale rates. 

94 

 
 
                                                 
countries and operators differ, resulting in a fragmented regulatory landscape that could affect 
the potential to deploy IoT services across the single market. 

MVNOs  and  Mobile  Virtual  Network  Aggregators  (MVNAs)  also  report  that  some  mobile 
operators have taken steps to block or limit permanent roaming to avoid the risk of domestic 
customers being targeted by multi-national connectivity suppliers. In this direction, some have 
started offering a higher cost product for permanent roaming for IoT – based on a fixed cost 
for accessing network, together with a service level agreement (SLA). 

The  proliferation  of  eSIM  may  bring  this  issue  into  a  renewed  focus  as  eSIM  is  likely  to 
support  the  expansion  of  connected  things  across  the  EU,  which  may  potentially  entail 
permanent roaming. At the same time, by facilitating the use by consumers of multiple mobile 
profiles each with different identifiers, eSIM could make it more difficult for MNOs in visited 
countries to track whether “roaming” consumers are genuinely visiting for a short period, or 
are permanently roaming.   

Therefore, the study suggests examining if there is a case for more explicit rules or guidelines 
on  permanent  roaming  and  the  use  of  non-national  IMSIs,  as  well  as  for  guidance  on  how 
M2M should be distinguished from personal communications. 

The  Commission  services  note  that,  while  the  Roaming  Regulation  was  designed  for  the 
benefit  of  end-users  using  their  mobile  device  while  periodically  traveling  abroad  in  the 
EU/EEA  and  by  reference  to  a  per-unit (volume-based)  type  of  charging  model,  it does  not 
exclude  machine-to-machine  communications  from  its  scope133.  Wholesale  roaming  access 
obligations laid down in Article 3 of the Roaming Regulation, as well as the wholesale data 
price cap, therefore also apply in case such access is sought for the purposes of machine-to-
machine communications as long as they are charged on a per unit, volume-based, basis like 
person-to-person communications. However, per unit price caps are not suited to other types 
of charging models that would be developed to better account for the use of the network by 
the  specific  traffic  patterns  generated  by  certain  machine-to-machine  applications,  such  as 
narrow-band  IoT.  According  to  information  available  to  the  Commission  services,  there  are 
on-going initiatives to develop such new types of charging models. 

As to permanent roaming, it is not prohibited as such by the Roaming Regulation and can be 
agreed  by  two  roaming  partners  in  the  wholesale  roaming  contract134.  According  to 
information  received  by  the  Commission  services,  operators  often  have  an  interest  to  host 
machine-to-machine  communications  traffic  on  their  networks,  including  on  a  permanent 
basis,  in  order  to  benefit  from  the  related  wholesale  revenues.  In  order  to  facilitate  the 

133 Except from specific provisions in Article 15 of the Roaming Regulation (transparency obligations). 
134  While  the  wholesale  level  measures  provided  in  Article  3  of  the  Roaming  Regulation  to  enable  a  visited 
operator  to  prevent  permanent  roaming  are  intended  to  be  useful  in  the  case  of  personal  communications  of 
travellers,  such  measures  may  also  be  used  in  the  case  of  machine-to-machine  communications.  It  is  however 
expected that, in general, visited operators have no interest to prevent permanent roaming in the case of machine-
to-machine communications. 

95 

 
 
                                                 
development  of  pan-European  machine-to-machine  services  in  particular,  the  European 
Electronic  Communications  Code  adopted  by  the  European  Parliament  and  the  Council  in 
December 2018 provides that Member States shall ensure that NRAs make available numbers 
that  may  be  used  on  a  permanent  basis  outside  of  the  Member  State  (known  as  “extra-
territorial  use of numbers”)135. The implementation of the roaming rules might benefit from 
the  relevant  clarifications  regarding  the  wholesale  access  conditions  for  permanent  roaming 
for the purposes of connectivity for machine-to-machine/Internet of Things.   

9  CONCLUSION  

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 
charges136. The RLAH reform has finally allowed to radically change that situation and met 
its  objective  to  unleash  the  demand  for  mobile  consumption  among  travelers  in  the  EU. 
Travelers  now use  roaming  services  in  the  EU without worry.  The total  volume  of roaming 
data in the EU was multiplied by a factor 5 already in the first year of RLAH compared to the 
last year before RLAH. It continued to increase by a factor 2 in the second year compared to 
the  first  year,  resulting  in  a  roughly  10-fold  increase  compared  to  the  last  year  before 
RLAH137.  As  to  the  volume  of  roaming  voice  calls,  it  has  been  multiplied  by  2  to  3 
(depending on the quarter of the year) compared to prior to RLAH. 

At  wholesale  level,  the  sharp  reduction  in  price  caps  together  with  competitive  dynamics 
below  the  caps  have  resulted  in  much  lower  wholesale  roaming  prices  since  RLAH  is  in 
place.  While  the pace of  the  decrease  in  the average  price seems  to  slow  down  at around  2 
€cent/min  for  voice,  the  decrease  in  the  average  price  continues  for  data  with  (and  below) 
each annual downward step of the cap. Similarly to the pre-RLAH period, under RLAH the 
regulated  price  caps  have  been  necessary  to  bring  prices  down  on  the  wholesale  roaming 
market.  The  price  caps  have  continued  to  act  as  benchmark  prices  in  wholesale  roaming 
negotiations.  Any  discount  on  the  wholesale  roaming  market  is  made  from  these  reference 
prices. In addition, parts of the market, in particular MVNOs and smaller operators operating 
in  one  country  and  with  large  outbound  roaming  imbalances,  often  pay  wholesale  roaming 
prices at, or close to, the cap level.  

In that perspective, BEREC “does not expect that the competitive conditions in the roaming 
market will change in the near future in a way that a regulatory intervention is not required 

135  Article  93(4)  of  the  European  Electronic  Communications  Code.  The  Code  is  to  be  transposed  in  national 
legislation by Member States by 21 December 2020 and applied from that date. 
136  Special  Eurobarometer  414,  E-communications  and  telecom  single  market  household  survey,  March  2014, 
http://ec.europa.eu/commfrontoffice/publicopinion/archives/ebs/ebs_414_en.pdf   
137 A 9- to 12-fold increase depending on the quarter of the second year of RLAH compared to the same quarter 
of the last year before RLAH. 

96 

 
 
                                                 
anymore.”  138 BEREC recommends that, “[b]ecause of the successful implementation of the 
regulation,  the  roaming  rules  should  remain  in  their  current  shape/structure  until  a  new 
assessment,  taking  into  account  future  market  developments,  is  done.”  BEREC  also 
recommends  to  “further  reduce  the  wholesale  caps,  in  order  to  increase  the  competitive 
strength for MVNOs in the years to come.” 139 

The above analysis, supported by the BEREC Opinion and an external study on ongoing and 
future technological developments, shows both the success of the reform and the need for the 
rules  to  continue  to  be  applicable  in  the  coming  years  in  order  for  end-users  to  continue 
benefitting  from  roaming  services  without  extra  charges  in  the  EU.  While  there  is  some 
evidence  of  economic  space  between  the  wholesale  price  caps  currently  programmed  until 
2022 and the level of costs of all operators (as also flagged in the European Parliament study 
– see section 4.5), the case for further reductions in order for the RLAH regime to function 
better  while  maintaining  domestic  competitive  dynamics  needs  to  be  further  analysed.  The 
analysis has also highlighted the aspects of the rules where clarifications could be beneficial 
to their implementation, namely on the quality of service while roaming, MVNOs’ access to 
roaming  services  and  the  applicability  of  the  roaming  rules  to  machine-to-machine 
communications. Finally, due to the lack of actual uptake by the market, local data breakout 
obligations no longer appear to be relevant.  

138 BEREC Supplementary analysis on wholesale roaming costs, BoR(2019)168, 20 September 2019, available 
here. 
139 Ibid. 

97