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: 2025-06-23
Institutions: Directorate-General for Communications Networks, Content and Technology, European Commission
Subjects: 5G, consumer protection, price regulations, regulation of telecommunications, retail trade, roaming, technological change, telecommunications policy, telephone charges, wholesale trade

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 23.6.2025  SWD(2025) 164 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(2025) 324 final}  
 
 
Table of Contents 

1. 

Introduction ......................................................................................................................... 4 

2. 
Scope of the roaming regulation and main provisions ..................................................... 5 
2.1.  What is roaming? .................................................................................................................. 5 
2.2.  What is “Roam-Like-At-Home” (RLAH)? ........................................................................... 6 
2.3.  How is "Roam-Like-At-Home" regulated in order to be sustainable over time? .................. 6 
2.4.  Main new provisions introduced under the 2022 recast ........................................................ 6 

3. 

Scope of the review requirements ...................................................................................... 7 

4. 
Methodology ........................................................................................................................ 9 
4.1.  BEREC’s data collection ...................................................................................................... 9 
4.2.  Eurobarometer studies  ....................................................................................................... 10 
4.3. 
Study on “Mobile and fixed broadband prices in Europe” ................................................. 10 
4.4.  Axon Cost Model ................................................................................................................ 11 
IoT/M2M Study .................................................................................................................. 12 
4.5. 
4.6.  Quality of Service Study ..................................................................................................... 12 
4.7.  Technological development ................................................................................................ 12 

5.5.1. 
5.5.2. 

5. 
Competition in the retail markets .................................................................................... 13 
5.1.  Evolution of retail (outbound) roaming volumes ................................................................ 13 
5.1.1. 
The increase in roaming traffic is led by mobile data consumption ................... 13 
Retail outbound roaming traffic remains a small fraction of overall traffic ....... 16 
5.1.2. 
5.2. 
Implementation of fair use policy ....................................................................................... 18 
5.3.  Application of the derogation mechanism .......................................................................... 23 
5.4.  Use of alternative roaming tariff plans................................................................................ 26 
5.5.  Evolution of domestic tariff plans ....................................................................................... 27 
Domestic prices .................................................................................................. 28 
Domestic-only tariff plans.................................................................................. 29 
5.6.  Third country roaming ........................................................................................................ 30 
Extending roam-like-at-home to third countries ................................................ 30 
Rest of the World (RoW) roaming prices .......................................................... 31 
Impact of BREXIT on roaming with the United Kingdom ................................ 32 
5.7.  Consumer protection and perception .................................................................................. 33 
Consumer perception ......................................................................................... 33 
5.7.1. 
5.7.2. 
Transparency measures ...................................................................................... 34 
5.7.2.1.  Welcome message .............................................................................................. 34 
5.7.2.2.  Value-added  services  (VAS)  and  the  implementation  of  the  database  of 
numbering ranges for VAS ................................................................................ 38 
5.7.2.3.  Emergency communications .............................................................................. 39 
Inadvertent roaming ........................................................................................... 40 
5.7.2.4. 

5.6.1. 
5.6.2. 
5.6.3. 

6. 
Assessment of the costs of providing wholesale roaming services ................................ 43 
6.1.  Cost of providing wholesale roaming service ..................................................................... 43 
The approach and methodology followed by Axon ........................................... 44 

6.1.1. 

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6.1.2. 

Choice of cost standards and general cost allocation ......................................... 46 
6.2.  Modelled scenarios ............................................................................................................. 46 
6.3.  Results derived from the cost model ................................................................................... 48 
6.4.  Estimated total costs including transit and termination. ..................................................... 51 
6.5. 
Impact of 5G ....................................................................................................................... 54 
6.6.  BEREC opinion on the cost model and estimates ............................................................... 55 

7. 
Competition in wholesale roaming markets ................................................................... 56 
7.1.  Evolution of wholesale (inbound) roaming volumes: inbounder and outbounder countries
 ............................................................................................................................................ 56 
7.2.  Evolution of wholesale prices ............................................................................................. 59 
7.2.1.  Wholesale roaming prices have been steadily decreasing .................................. 59 
Situation of MVNOs .......................................................................................... 64 
7.2.2. 

8. 
Quality of Service (QoS) ................................................................................................... 65 
8.1.  QoS Study ........................................................................................................................... 66 
8.2.  Consumer perspective ......................................................................................................... 67 
8.3.  BEREC Opinion ................................................................................................................. 68 
8.4.  Conclusion on QoS ............................................................................................................. 69 

9.2.1. 
9.2.2. 
9.2.3. 

Technological developments............................................................................................. 69 
9. 
9.1. 
5G deployment in the EU/EEA area and its impact on roaming QoS ................................. 69 
9.2.  The evolution of the M2M/IoT roaming market ................................................................. 70 
The roaming connectivity market for M2M/IoT ................................................ 71 
The currently applicable regulatory framework to roaming for M2M/IoT ........ 72 
Assessment of the permanent roaming (non)regulation for M2M/IoT .............. 74 
9.3.  Wi-Fi and Wi-Fi aggregation .............................................................................................. 77 
9.4.  OTT voice and messaging .................................................................................................. 79 
9.5.  Embedded SIM (eSIM) ....................................................................................................... 79 
9.6. 
Satellite communications .................................................................................................... 81 
9.7.  Online Trading platforms .................................................................................................... 82 

10. 
Conclusion ......................................................................................................................... 83 
10.1.  The Roaming Regulation effectively provides  benefits ..................................................... 83 
10.2.  The Roaming Regulation is efficiently enabling end users to benefit from mobile services 
cross borders throughout the single market ........................................................................ 84 
10.3.  The Roaming Regulation is still the most relevant instrument ........................................... 84 
10.4.  The Roaming Regulation is coherent with the other legal tools ......................................... 85 
10.5.  The Roaming Regulation delivers uncontested EU Added value ....................................... 85 
10.6.  The Commission will continue to monitor the implementation of the  Roaming Regulation
 ............................................................................................................................................ 85 

11. 

Annex ................................................................................................................................. 87 

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Figure 1: EU27 retail roaming data traffic, Q4 2016 – Q3 2024 (millions of GB) ....................... 15 
Figure 2: EU27 average data roaming consumption per roaming subscriber, Q4 2016 – Q3 2024 
(MB per month)  ............................................................................................................................ 16 
Figure 3: EU27 retail roaming voice traffic (calls made), Q4 2016 – Q3 2024 (millions of minutes). 
 ....................................................................................................................................................... 17 
Figure 4: EU27 retail roaming data traffic over total traffic, Q4 2016 – Q3 2024 ........................ 18 
Figure  5:  EU27  retail  roaming  data  traffic  in  2018  compared  to  2024  (histogram  on  the  left). 
Roaming data traffic compared to total traffic in 2024 (histogram on the right) .......................... 18 
Figure 6: Percentage of operators (MNOs and MVNOs combined) applying each FUP mechanism 
over the total number of respondents, by instrument and year.  .................................................... 20 
Figure 7: Percentage of users with usage going beyond periodic travel (control mechanism and 
stable link criterion) or exceeding FUP on data (open data bundle or pre-paid data limits), over 
users who roamed at least once in the reference period, by quarter (2018-2024). ........................ 21 
Figure 8: Percentage of data roaming volumes reported as usage beyond periodic travel (control 
mechanism and stable link criterion) or exceeding FUP on data (open data bundle or pre-paid data 
limits), over total data roaming volumes, by quarter (Q1 2018 – Q3 2024). ................................ 22 
Figure 9: Sustainability derogations granted by NRAs since RLAH, MNOs and MVNOs.......... 25 
Figure  10:  Percentage  of  roaming  voice  and  data  traffic  from  alternative  tariffs  in  total  EU27 
roaming traffic, Q4 2016 – Q3 2024 ............................................................................................. 28 
Figure 11: Evolution of domestic prices ....................................................................................... 30 
Figure 12: Percentage of domestic-only subscribers per country.................................................. 31 
Figure 13: Decreasing trend of the data surcharge operators can apply over the years (€/GB))  .. 36 
Figure 14: Estimated data roaming unit costs in EUR/GB, transit costs not included .................. 51 
Figure 15: Estimated voice roaming unit costs in EURcents/min, transit and termination costs not 
included ......................................................................................................................................... 52 
Figure 16: Estimated SMS roaming unit costs in EURcents/SMS ................................................ 53 
Figure 17: Estimated data roaming unit costs in EUR/GB, including transit costs ....................... 55 
Figure 18: Estimated voice roaming unit costs in EURcents/min, including transit and termination 
costs ............................................................................................................................................... 56 
Figure  19:  Data  services,  classification  of  inbound/outbound  countries  based  on  net  outbound 
roaming data volumes.  ................................................................................................................. 59 
Figure  20:  Voice  services,  classification  of  inbound/outbound  countries  based  on  net  outbound 
roaming voice volumes. ................................................................................................................ 60 
Figure 21: Inbounder and outbounder EEA countries (2019 vs 2024).......................................... 61 
Figure 22: Data services: development of the average wholesale roaming rate for data in the EEA, 
Q4 2016 to Q3 2024 ...................................................................................................................... 62 
Figure 23: Voice services: development of the average wholesale roaming rate for voice in the 
EEA, Q4 2016 to Q3 2024 ............................................................................................................ 63 
Figure 24: SMS services: development of the average wholesale roaming rate for SMS in the EEA, 
Q4 2016 to Q3 2024 ...................................................................................................................... 64 
Figure 25: Voice services: average wholesale roaming rate for voice in the Member States, Q2 
2017, Q1 2019 and Q1 2024 ......................................................................................................... 65 
Figure 26: Data services: average wholesale roaming rate for data in the Member States, Q2 2017, 
Q1 2019 and Q1 2024 ................................................................................................................... 65 
Figure 27: Average wholesale permanent roaming charges for data services against EU regulated 
caps ................................................................................................................................................ 78 
Figure 28: Wi-Fi Coverage in Europe ........................................................................................... 80 
Figure 29: Commercial availability of smartphones ..................................................................... 82 

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1.  INTRODUCTION  

The  roaming  policy  is  a  European  success  story,  giving  millions  of  consumers  and 
businesses in the EU the benefits of staying connected without surcharges in the Digital 
Single Market. Since 15 June 2017, Union residents have access to mobile services (voice, 
SMS  and  data)  at  no  extra  costs  when  travelling  periodically  in  the  European  Union 
(‘EU’)/European Economic Area (‘EEA’). In these cases, mobile operators are not allowed 
to levy any charges in addition to the domestic price for roaming services. These roaming 
rules are widely known as "Roam-Like-At-Home" (‘RLAH’).  

In 2022, the RLAH rules were revised. These rules are now included in Regulation (EU) 
2022/612 (hereinafter ‘Roaming Regulation’) (1) which also extended their application for 
an  additional  10  years  till  June  2032.  The  Roaming  Regulation  includes  provisions 
regulating roaming both at wholesale and retail levels.  

At the wholesale level,  mobile network operators must meet all reasonable requests for 
wholesale roaming access, in particular in a manner that allows the roaming providers to 
replicate the retail mobile services offered domestically where it is technically feasible to 
do so on the visited network (2).  

At  the  retail  level,  this  translates  into  the  fact  that  roaming  providers  must  not  apply 
surcharges to the domestic retail price to customers in any Member States for (i) making 
and  receiving  calls,  (ii)  sending  and  receiving  SMS  messages,  (iii)  using  an  internet 
connection, for non-permanent journeys.  

The  Roaming  Regulation  also  defines  the  safeguards  rules  –  fair  use  policy  and  the 
sustainability  derogation  –  whose  aim  is  to  ensure  sustainability  for  operators  while 
allowing for a high level of consumer protection. The application of these safeguards was 
further detailed in the Commission Implementing Regulation (EU) 2016/2286 (hereinafter 
the ‘Implementing Regulation’ or ‘CIR’) (3) adopted in December 2016 (4). 

Finally,  the  Roaming  Regulation  reflects  the  specific  characteristics  of  Union-wide 
roaming services and therefore complements Directive (EU) 2018/1972 establishing the 

(1)  Regulation (EU) 2022/612 of the European Parliament and of the Council of 6 April 2022 on roaming 

on public mobile communications networks within the Union (OJ L 115, 13.4.2022, p. 1–37). 

(2)  Mobile  network  operators  may  refuse  requests  for  wholesale  roaming  access  only  on  the  basis  of 
objective criteria, such as technical feasibility and network integrity. Commercial considerations are not 
grounds for refusing requests for wholesale roaming access in order to limit the provision of competing 
roaming services. 

(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)  These  measures  were  adopted  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. In 
these  scenarios,  mobile  operators  may  apply  a  fair  use  policy.  The  Implementing  Regulation  (EU) 
2016/2286 also provided complementary measures aiming to ensure that operators can provide regulated 
retail roaming services in a sustainable way. In this context the term “sustainable” means that operators 
can either fully recover the cost of providing retail roaming services or at least that the incurred negative 
retail roaming margin is very small (less than 3%) compared to their domestic profits. 

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European  Electronic  Communications  Code  (‘Code’  or  ‘EECC’) (5) 
introducing 
exceptional  measures  departing  from  the  rules  otherwise  applicable  under  the  Code, 
namely that prices for service offerings are to be determined by commercial agreement in 
the absence of significant market power (6).  

Since the adoption of the recast Roaming Regulation in 2022 and in line with its reporting 
obligations laid down in the Regulation (7), on 15 January 2024, the Commission published 
a Staff Working Document (‘SWD’) on the findings of the 2023 periodic review of the 
rules  on  roaming  fair  use  policy  and  the  sustainable  derogation  laid  down  in  the 
Commission  Implementing  Regulation  (EU)  2016/2286  (hereinafter  ‘2023  Review 
Report’). The 2023 Review Report concluded on the overall success of the fair use policy 
(‘FUP’) mechanisms as they currently exist. Union residents enjoy mobile services while 
travelling  in  the  EU/EEA  under  RLAH  conditions.  The  existing  fair  use  policy 
mechanisms  have  been  widely  implemented  by  operators  and  allowed  them  to  ensure 
RLAH  benefits  to  periodic  travellers  while  addressing  abusive  or  anomalous  use  of 
roaming. Finally, no major impact has been observed on the domestic markets: the tariff 
structure and availability of domestic mobile subscriptions remained unchanged. 

The Roaming Regulation further mandates the Commission to submit, by 30 June 2025, a 
comprehensive review report to the European Parliament (EP) and the Council assessing 
the functioning of the roaming market under the RLAH rules. This SWD and the related 
Report are submitted by the Commission to the European Parliament and the Council for 
the purposes of reviewing the functioning of the roaming market. 

2.  SCOPE OF THE ROAMING REGULATION AND MAIN PROVISIONS  

2.1.  What is roaming? 

Roaming, in the meaning of the Roaming Regulation, is a service that allows a roaming 
customer  (consumer  or  business)  of  a  Mobile  (Virtual)  Network  Operator  (M(V)NO) 
(operator A) in one EU/EEA country (country A) to have access to mobile services (voice, 
SMS  and  data)  provided  by  an  MNO  (operator  B)  via  a  terrestrial  public  mobile 
communications network in another Union/EEA country (country B) when travelling (8). 
The mobile operator A ensures that its customers remain connected to a mobile network 
of  the  operator  B  when  travelling  abroad  and  using  a  mobile  device  for  making  and 
receiving calls, SMS and using data services within the EU. Operator A, offering roaming 
services  to  its  own  customers  ("retail  roaming  services")  in  another  country  has  to  buy 
them  from  an  MNO,  Operator  B,  located  in  the  visited  country  ("wholesale  roaming 
services").  To  this  end,  commercial  wholesale  roaming  agreements  between  service 
providers A and B have to be concluded. In practice, when a customer of Operator A places 

(5)  Directive  (EU)  2018/1972  of  the  European  Parliament  and  of  the  Council  of  11  December  2018 
establishing the European Electronic Communications Code (OJ L 321, 17.12.2018, p. 36–214). 

(6)  See Recital (11) of the Roaming Regulation. 
(7)  Article 7 of the Roaming Regulation  
(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. 

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a call or uses mobile data while roaming abroad in country B, that service is provided by 
a mobile Operator B in the visited country B. The roaming customer’s home Operator A 
has to pay the visited Operator B for that service, at wholesale level. These payments are 
called wholesale roaming charges. The level of those charges is capped by the Roaming 
Regulation and subject to a decreasing glidepath.  

2.2.  What is “Roam-Like-At-Home” (RLAH)? 

Since 15 June 2017 customers can have access to mobile services (voice, SMS and data) 
at  no  extra  cost  when  they  travel  periodically  in  the  EU/EEA.  In  these  cases,  mobile 
operators have, as a main principle, 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.  Pursuant  to  Article  5  of 
Regulation (EU) 2022/612, in order to prevent abusive or anomalous usage of regulated 
roaming  services  by  roaming  customers  -  such  as  the  use  of  such  services  by  roaming 
customers in a Member State other than that of their domestic provider for purposes other 
than periodic travel, mobile operators may apply a fair use policy, which shall enable the 
roaming provider’s customers to consume volumes of regulated retail roaming services at 
the applicable domestic retail price that are consistent with their respective tariff plans.  

2.3.  How is "Roam-Like-At-Home" regulated in order to be sustainable over 

time? 

For the implementation of ‘Roam-Like-At-Home’ in a sustainable manner for operators 
throughout the Union, the following safeguards have been set out: 

At retail level, where operators have the obligation to provide roaming services at the same 
conditions as domestically for periodic travelling, they were given the possibility to apply: 
(a) a fair use policy to prevent abusive or anomalous use of roaming services at domestic 
prices  (such  as  permanent  roaming);  and  (b)  exceptional  and  temporary  derogations  to 
forestall any risk of domestic price increases. 

At  wholesale  level,  where  operators  have  a  wholesale  access  obligation  to  ensure  the 
provision of roaming services, in order to make wholesale costs sustainable in a Roam-
Like-at-Home regime, there has been a substantial reduction of wholesale roaming price 
caps applicable to wholesale agreements between operators, while ensuring that operators 
providing the wholesale service can recover their costs.  

2.4.  Main new provisions introduced under the 2022 recast 

In 2022, the recast Regulation introduced some new provisions in the regulation to increase 
consumer benefits and protection. The validity of the Roaming Regulation is set for 10 
years,  until  2032,  extending  the  RLAH  regime  and  therefore  providing  certainty  in  the 
market.  The  new  quality  of  service  (‘QoS’)  measures,  that  clarified  the  previous 
provisions,  ensure  that  roaming  customers  can  at  least  have  the  same  level  of  roaming 

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quality abroad, e.g. speed and network generation, as they normally have at home, when 
this is technically feasible. Moreover, mobile network operators in the visited country are 
required  to  give  visited  mobile  operators  access  to  all  network  technologies  and 
generations upon a reasonable wholesale roaming access request. 

When it comes to emergency communications, improved rules were introduced to ensure 
that customers who are roaming can seamlessly access emergency services without the risk 
of being charged. They can, for example, call the single European emergency number, 112, 
all over the EU or use SMS or emergency applications without any surcharges. In addition, 
travellers should be informed about the means of reaching emergency services, including 
those designed for end users with disabilities, in the EU/EEA country they are visiting. 

To protect roaming customers from unexpected surcharges, new rules were introduced 
to ensure that roaming providers give sufficient information to their customers about the 
increased costs they might incur from using value-added services while roaming as well 
as connecting to a non-terrestrial network such as on a ship or plane. Roaming customers 
now benefit from automatic cut-off limits once they have consumed EUR 50 or EUR 100 
of roaming services, instead of having to opt-in to such a service as was the case in the 
previous regulation.  

Lastly, the Roaming Regulation continues to ensure that roaming without surcharges and 
the enhanced benefits for consumers is sustainable for operators. At wholesale level, the 
price caps have been further substantially reduced in 2022, in particular for data traffic. 
The wholesale glidepath ensures progressive reductions of the  data roaming  caps every 
year until 2027 (reaching EUR 1 per GB), in order to ensure that market players can benefit 
from wholesale rates that allow for the sustainable 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.  Additionally, the decreasing  wholesale caps ensure  also 
benefits  on  the  retail  side,  since  surcharges  exceptionally  applied  to  consumers  are 
constantly  decreasing,  given  that  the  wholesale  cap  also  represents  the  maximum  retail 
surcharge applicable by operators. 

3.  SCOPE OF THE REVIEW REQUIREMENTS  

The review requirements are laid down in Article 21(1) of the Roaming Regulation and 
include, inter alia, an assessment of:  

(a)  the  impact  of  the  roll-out  and  implementation  of  next  generation  mobile 
communications networks and technologies on the roaming market;  

(b) the effectiveness of the quality of service obligations with regard to roaming customers, 
the availability and quality of services, including those which are an alternative to regulated 
retail  voice,  SMS  and  data  roaming  services,  in  particular  in  light  of  technological 
developments and of the access to the different network technologies and generations;  

(c) the degree of competition in both the retail and wholesale roaming markets, in particular 
the  actual  wholesale  rates  paid  by  the  operators  and  the  competitive  situation  of  small, 
independent or newly started operators, and MVNOs, including the competition effects of 

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commercial  wholesale  roaming  agreements,  of  traffic  traded  on  trading  platforms  and 
similar instruments and the degree of interconnection between operators; 

(d) the evolution of the machine-to-machine roaming, including roaming on IoT devices; 

(e) the extent to which the implementation of the measures provided for in Article 3, 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 in 
the development of competition in the internal market for regulated roaming services;  

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

(g)  changes  in  data  consumption  patterns  for  both  domestic  and  roaming  services, 
including changes in travel patterns of European end-users caused by circumstances such 
as pandemics, for example COVID-19, or natural disasters;  

(h) 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 6;  

(i)  the  ability  of  visited  network  operators  to  recover  the  efficiently  incurred  costs  of 
providing regulated wholesale roaming services, taking into account the latest information 
on network deployment, as well as developments in technical capabilities, pricing models 
and  constraints  of  the  networks,  for  instance  the  possibility  of  including  cost  model 
calculations based on capacity rather than consumption;  

(j) the impact of the application of fair use policies by operators, including on consumption 
by  end-users,  in  accordance  with  the  implementing  acts  adopted  pursuant  to  Article  7, 
including the identification of any inconsistencies in the application and implementation 
of such fair use policies; as  well as  the effectiveness  and proportionality  of the general 
application of such policies;  

(k) the extent to which roaming customers and operators face problems in relation to value-
added  services  and  the  implementation  of  the  database  of  numbering  ranges  for  value-
added services established pursuant to Article 16, first paragraph, point (a);  

(l) the application of the measures of this Regulation and complaints related to the use of 
emergency communications while roaming;  

(m) complaints related to inadvertent roaming. 

All the elements listed above are analysed and assessed in this SWD. 

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4.  METHODOLOGY 

This SWD and the Report to the European Parliament and the Council were prepared based 
on  a  range  of  inputs,  including  BEREC's  data  collection  exercises,  two  Eurobarometer 
surveys, as well as external and internal studies and analyses. 

4.1.  BEREC’s data collection  

BEREC  has  established  an  articulated  and  well-functioning  monitoring  system  for  the 
Regulation  (EU)  2022/612 that  provides  a  considerable  amount  of  data  collected  for 
roaming policy and monitoring purposes. The data collection is managed by BEREC on 
the basis of the legal obligations laid down in Art. 17 and 21 of the Roaming Regulation. 
BEREC  has  coordinated  regular  data  collections  initially  on  a  biannual  basis  and  since 
2022, due to the simplification and administrative burden reduction brought by the roaming 
regulation review, on an annual basis. BEREC published these data and analysed them in 
its International Roamign Benchmark Data and Monitoring reports as well as in its Opinion 
on the functioning of the roaming market. The analysis presented in this SWD is based on 
the  Commission  analysis  of  the  results  of  these  data  collections  and  on  the  BEREC 
Opinion (9). 

In  2023,  25  EU/EEA  National  Regulatory  Authorities 
(‘NRAs’)  and  133 
telecommunications operators, including 79 MNOs and 54 MVNOs replied to the surveys. 
Therefore, they ensure a complete representation of the EEA mobile market in terms of 
MNOs, and they offer a good coverage of the MVNOs segment. 

Among  other  topics,  the  “transparency  questionnaires”  conducted  by  BEREC  serve  to 
monitor in detail whether and how operators have implemented fair use policy measures. 
Over the years, the reference questionnaire has been changed; therefore, any inconsistency 
in  data  availability  between  questions  has  to  be  attributed  to  such  changes.  The  “data 
questionnaire” presents detailed information on volumes and revenues of both domestic 
and  roaming  volumes  as  reported  by  mobile  operators  in  the  EEA.  More  specifically, 
roaming volumes and revenues are reported at the retail as well as at the wholesale level.  

Most of the analyses presented in this SWD are performed on a subsample of operators, 
namely those that have always replied to the Benchmark questionnaire since 2016 Q4. This 
choice  has  been  made  to  ensure  comparability  over  time  of  the  figures  presented.  It 
explains why there are some discrepancies between data presented by the Commission to 
ensure comparability and data presented by BEREC in its reports. 

(9)  BEREC input on EC’s request for expert views on Regulation (EU) 2022/612 on roaming on public 
mobile communications networks within the Union published on 28 March 2025 (BoR(25)), hereinafter 
“BEREC Opinion”. 

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4.2.  Eurobarometer studies  

Results from two different Eurobarometer studies are considered in this report. It should 
be noted that the two studies differ in methodology and are therefore not comparable. The 
data cannot be used to interpret increases or decreases at face value but can serve as good 
indications of trends from one to the other Eurobarometer.  

Flash Eurobarometer 521(10)  

The Flash Eurobarometer 521 on roaming targets EU residents. In each of the 27 Member 
States,  Ipsos  European  Public  Affairs  interviewed  a  representative  sample  of  residents, 
aged  16  and  over,  who  had  travelled  to  another  country  in  the  EU  or  EEA  (Iceland, 
Liechtenstein or Norway) in the past two years and who are able to call, text or use mobile 
internet  on their mobile phone when travelling  in the EU.  It  should be noted  that these 
roamers represent approximately 43% of the overall population of mobile users, given that 
some EU customers do not travel outside their country. Between 27 February and 3 March 
2023, 5 271 interviews were conducted via mobile phones.  

Special Eurobarometer 560 (11)  

In 2025, the Special Eurobarometer 560 on e-communications was conducted and covered 
some chosen questions on roaming QoS and roaming usage. It was conducted between 09 
January  and  4  February  2025  and  26,354  respondents  from  different  social  and 
demographic groups were interviewed in the appropriate national language in all Member 
States. Out of the total respondents 31% had travelled in the EU/EEA in the last two years 
and replied to questions about roaming. 

4.3.  Study on “Mobile and fixed broadband prices in Europe” 

The price analysis in Section 5.5.1 has been carried out using data presented in the study 
“Mobile  and  fixed  broadband  prices  in  Europe”. (12)  Once  a  year,  the  contractor  who 
authored this study (Empirica) collects information on mobile prices by scanning the three 
largest mobile operators’ websites in each Member State. They collect information on the 
price and the characteristics of tariff plans offered by operators. Based on this information 
they build mobile baskets that are representative of different levels of voice minutes, SMS 
and data consumption. (13) Even though data refer to only the three largest  operators in 

(10)  Flash Eurobarometer 521, European Commission, July 2023. 
(11)  Not yet published. Reference: Specific contract SC CNECT/2024/02.  
(12)   Study  SMART  number  2019/0018,  ISBN  978-92-76-53077-0.  See  the  following  links  for  further 
details:https://digital-strategy.ec.europa.eu/en/news/mobile-broadband-prices-went-down-europe-
2018;https://digital-strategy.ec.europa.eu/en/library/mobile-broadband-prices-europe-2019; 
https://digital-strategy.ec.europa.eu/en/library/mobile-and-fixed-broadband-prices-europe-
2020;https://digital-strategy.ec.europa.eu/en/library/mobile-and-fixed-broadband-prices-europe-2021; 
https://www.digital-strategy.ec.europa.eu/en/library/mobile-and-fixed-broadband-prices-europe-2022  ; 
The  data  used  for  2023  and 2024  is  taken  from  the  databases  that  will  feed  into  the  2023  and  2024 
broadband prices studies that are yet to be published.  

(13)   As an example, the highest consumption level for 2017-2021 period is associated with Basket ’20 GB 

and 300 calls’. 

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each Member State (14), given their combined positions on the markets, they are deemed 
to  be  representative  of  the  overall  country  specific  price  dynamics.  Based  on  the 
information collected, Empirica estimates the price of each basket in each Member State. 

Following the market  evolution  of mobile services  and consumption patterns, Empirica 
updated  the  usage  baskets  in  2022  by  removing  less  used  baskets  and  including  more 
representative baskets in their data set. Therefore, some of the baskets were renamed, while 
others  were  removed.  New  baskets  were  also  added  to  the  2022  data  set  to  reflect  the 
increased needs of some categories of consumers (e.g. a basket with 50GB allowance) and 
more detailed analysis of their price evolution will be included in the next review report 
that will cover the price changes between 2022 and 2024. The composition of the baskets 
analysed in Section 5.5.1 is presented in the following table: 

Table 1: Mobile basket description  

Usage basket  
MBB2  (changed  to  MBB1  in 
2022) 
MBB3 (not available in 2022) 
MBB4  (changed  to  MBB2  in 
2022) 
MBB5 (MBB4 in 2022) 
I2 (I1 in 2022) 
I3 (not available in 2022) 
I5 (changed to I4 in 2022) 
I6 (changed to I2 in 2022)  
I7 (not available in 2022) 

Volumes included 

1 GB mobile data with no calls 
2 GB mobile data with no calls 

5 GB mobile data with no calls 
20 GB mobile data with no calls 
1 GB mobile data with 30 calls 
2 GB mobile data with 100 calls 
20 GB mobile data with 300 calls 
5 GB mobile data with 30 calls 
20 GB mobile data with 100 calls 

Source: Empirica Mobile prices database 

4.4.  Axon Cost Model 

In order to assess the costs of providing wholesale roaming services in the  30 EU/EEA 
countries  for  the  purposes  of  the  roaming  review,  an  independent  study  was 
commissioned (15).  The  objective  of  the  study  was  to  build  on  the  experience  of  the 
previous review of the Roaming Regulation and enhance the existing bottom-up cost model 
to estimate the efficient costs of providing wholesale roaming services and mobile voice 
call termination services by mobile network operators in the EEA, under the current market 
conditions. 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 (hereinafter, ‘Axon’) from May 
2023  to  December  2024.  At  the  start  of  the  study,  a  first  workshop  with  all  relevant 
stakeholders  was  organised  on  21  June  2023  in  order  to  collect  feedback  on  the 
methodology proposed by Axon. A comprehensive data gathering was then conducted in 
August-September  2023,  via  the  NRAs,  in  order  to  obtain,  from  mobile  operators,  the 

(14)  Except when only two operators are available in a country. 
(15)  Study  CNECT/2022/OP/0065:  “Assessment  of  the  cost  of  providing  mobile  telecom  services  in  the 

EU/EEA countries”, Axon Partners Group Consulting, published 18/12/2024, available here. 

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relevant  information  and  inputs  needed  to  populate  a  country-specific  model  for  each 
Member State. 

4.5. 

IoT/M2M Study  

For  assessing  the  evolution  of  machine-to-machine  roaming,  including  roaming  on  IoT 
devices, the Commission used as a reference source an independent study (16) conducted 
by the consortium of Axon Partners Group Consulting S.L.U. (hereinafter, ‘Axon’), ICF 
S.A. (hereinafter, ‘ICF’) and Consultores de Automatización y Robótica S.A. (hereinafter, 
‘CARSA’). The commissioned consortium conducted the study in the period from March 
2023 to July 2024, covering both past evolution and future trends.  

The main purpose of this  study  was  to  identify IoT-related deficiencies in  various IoT-
related  EU  regulatory  areas  (e.g.,  spectrum,  numbering,  competition,  etc.),  including  in 
relation to the provision of roaming services. The study analysed the structure of the IoT 
market, and the relevant technologies, challenges and competitive situation, distinguishing 
between four market layers in the IoT value chain (i.e., IoT hardware, IoT connectivity, 
including roaming connectivity providers, IoT applications, and IoT consumer or business 
users).  The  study’s  results  built  on  desk  data  research,  including  on  BEREC’s  publicly 
available data, assessment of relevant stakeholders’ inputs, and workshop exchanges with 
relevant stakeholders, including one roaming-dedicated workshop. 

4.6.  Quality of Service Study  

To assess the Quality-of-Service (QoS) performance of roaming services, the Commission 
used as its basic resource the independent study (17) performed by Mozark. The objective 
of the study was to assess the effectiveness of the QoS obligations by performing specific 
QoS  measurements  of  the  service  for  domestic  and  roaming  data  services.  The  study 
included  measurements  of  the  download  and  upload  speeds,  latency,  as  well  as 
measurements  regarding  the  time  for  the  handover  when  crossing  the  borders  between 
countries. Conclusions were drawn after the comparison of the values of the parameters 
between  the  roaming  end-users  and  (i)  the  same  users  in  their  home  networks,  (ii)  the 
domestic  end-users  of  the  visiting  network  and  (iii)  other  roamers  in  the  same  visited 
network.  The  study  covered  20  Member  States  -  2  cities  per  Member  State,  with 
measurements  from  approximately  50  mobile  operators  (changing  roles  home/visiting, 
depending on the country), through drive test covering approximately 12,000 km. 

4.7.  Technological development  

The starting point for the evaluation of the technological trends and how they are expected 
to affect wholesale and retail roaming during the next period, was the independent study 

(16)  Study on an enabling framework for IoT ecosystem development in Europe, published on 20/12/2024, 

available here. 

(17)  Not published yet. Reference number: EC-CNECT/2024/OP-0084. 

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performed by WIK (18) for the Commission in the context of the previous review of the 
roaming  regulation.  The  conclusions  of  the  study  were  validated  with  input  from  more 
recent studies, such as the study on wholesale mobile connectivity, trends and issues for 
emerging mobile technologies and deployments (19) performed by WIK for BEREC, while 
valuable input was also taken from the independent study on an enabling framework for 
IoT ecosystem development in Europe (20) performed by Axon Partners Group, ICF and 
CARSA for the Commission. Finally, desk research was used for complementing and re-
evaluating the interim conclusions, as well as for input regarding the technological trends 
that have emerged in the period following the previous review of the roaming regulation. 

5.  COMPETITION IN THE RETAIL MARKETS 

5.1.  Evolution of retail (outbound) roaming volumes 

In 2017, the introduction of RLAH had triggered an immediate and massive increase in 
retail roaming traffic in the first year, for both mobile data consumption while roaming 
(increase  by  a  factor  of  5 (21)  and  roaming  phone  calls  made  (increase  by  a  factor  of 
2.5 (22)). 

5.1.1.  The increase in roaming traffic is led by mobile data consumption  

The analysis of the mobile data consumption while roaming shows a continuous increase 
in  volume since the introduction of RLAH in  2017.  Notably,  the most roaming-intense 
quarter (Q3) has seen a significant increase in data consumption, with a 48-fold increase 
since the introduction of the RLAH regime in 2017 (23), demonstrating the important 
demand from EU consumers for roaming services and its relevance in achieving a digital 
single market. 

(18) FinalReportSMART20180012.pdf 
(19)  https://www.berec.europa.eu/en/document-categories/berec/reports/study-on-wholesale-mobile-

connectivity-trends-and-issues-for-emerging-mobile-technologies-and-deployments 

(20) Study on an enabling framework for IoT ecosystem development in Europe, published on  20/12/2024, 

available here. 

(21)  Q3 2017 compared to one year before. 
(22)  Ibid. 
(23)  Q3 2017 compared to Q3 2024. 

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Figure 1: EU27 retail roaming data traffic, Q4 2016 – Q3 2024 (millions of GB) 

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Source: BEREC BMK data processed by JRC 

Since the previous review exercise in 2019 (24), the consumption increased by 267% (Q3 
2019 compared to Q3 2024), indicating that EU consumers’ demand is still increasing. 

This  trend  is  further  underscored  by  looking  at  the  data  consumption  by  roaming 
customers:  since  the  introduction  of  RLAH  in  Q3  2017,  the  average  data  roaming 
consumption per roaming subscriber for the same period (Q3) increased by 616%, reaching 
1704 MB in Q3 2024 (25). 

(24)  See COM(2019) 616 final & SWD(2019) 416 final.  
(25)  Ibid. 

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Figure 2: EU27 average data roaming consumption per roaming subscriber, Q4 2016 – Q3 2024 
(MB per month)  

Source: BEREC BMK data processed by JRC 

Over the last 5 years, the average quarterly (Q3) consumption has steadily increased by 
around 32.5% per year, showing an increasing demand.  

On  the  other  hand,  a  notable  trend  has  emerged  for  roaming  voice  traffic:  seasonal 
fluctuations aside, the retail roaming voice traffic has been steadily decreasing, with a peak 
of 6,350 million minutes in Q3 2019, followed by 5,290 million minutes in Q3 2020, 5,900 
million minutes in Q3 2021, 5,700 million minutes in Q3 2022, 5,050 million minutes in 
Q3 2023 and 5,400 million minutes in Q3 2024 (See Figure 3). 

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Figure 3: EU27 retail roaming voice traffic (calls made), Q4 2016 – Q3 2024 (millions of 
minutes).  

Source: BEREC BMK data processed by JRC 

These  two  parallel  trends  (i.e.  continuous  increase  of  roaming  data  consumption  and 
decreasing consumption of retail roaming voice services) are consistent with the broader 
patterns observed at the domestic level (26). They might be attributed to the evolution of 
digital  usages  in  the  EU  with  the  continuous  development  of  Over-The-Top  (OTT) 
platforms,  which  offer  voice  and  messaging  services (27)  over  the  internet  gaining 
increasing importance as a complement to traditional calls and SMS.  

5.1.2.  Retail outbound roaming traffic remains a small fraction of overall traffic 

The evidence shows that, despite the massive increase in data roaming consumption, the 
latter remains only a small fraction of the overall traffic. In the latest data, in Q3 2024, data 
roaming consumption represented 2.2% of the overall data traffic in the RLAH area.  

(26)  BEREC Opinion BoR(25) 48. 
(27)  See also BEREC Opinion BoR(25) 48: commenting on the decline in SMS usage (while roaming and at 
domestic level), BEREC considers that this “can be attributed to a large extend to an increasing reliance 
on OTT messaging services”. 

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Figure 4: EU27 retail roaming data traffic over total traffic, Q4 2016 – Q3 2024 

Source: BEREC BMK data processed by JRC 

Figure 5: EU27 retail roaming data traffic in 2018 compared to 2024 (histogram on the left). 
Roaming data traffic compared to total traffic in 2024 (histogram on the right) 

Source: BEREC BMK data processed by JRC 

A  comparison  of  data  roaming  volumes  between  2018  and  2024  –  two  years  after  the 
introduction of the RLAH regime – demonstrates that data roaming volumes represent a 
small fraction of total traffic in the EU, well below 2.5% of the total traffic. The consistent 

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growth in MB consumed by roamers, as shown in Figure 2 , underscores the significant 
benefit that this small fraction of traffic brings to EU consumers (see Section 5.7), in an 
efficient manner. 

5.2. 

Implementation of fair use policy  

Roaming  providers  should  be  able  to  apply  FUP  mechanisms  to  the  consumption  of 
regulated retail roaming services provided at the applicable domestic retail price.  Under 
Article 21(j) of the Roaming Regulation, the Commission shall assess “the impact of the 
application of fair use policies by operators” when conducting its reviews. 

Implementing  Regulation  (EU)  2016/2286 (28)  lays  down  detailed  rules  to  ensure  a 
consistent implementation of fair use policies that roaming providers may apply in order 
to avoid anomalous or abusive use of regulated retail roaming services under the RLAH 
regime that could have detrimental effects on domestic markets. The 2023 Review Report 
(29)  published  on  15  January  2024  analysed  in  detail  the  application  of  FUP 
mechanisms (30) and demonstrated that these measures continue to be effective and widely 
implemented by all operators (31). The updated analysis – including 2023 and 2024 data – 
confirms the general findings of the 2023 Review Report (i.e. FUPs are fit for purpose and 
have limited impact on consumers) while identifying new trends. 

(28)  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, 
OJ L 344, 17.12.2016, p. 46–62. 

(29)  SWD(2024) 8, Commission Staff Working document on the findings of the 2023 periodic 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.  

(30)  For detailed explanations on the Fair Use Policy mechanisms, please refer to the  section 4.1 of the Commission 
Staff Working Document on the findings of the 2023 periodic 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(2024)8). 

(31)  MNOs and MVNOs. 

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Figure  6:  Percentage  of  operators  (MNOs  and  MVNOs  combined)  applying  each  FUP 
mechanism over the total number of respondents, by instrument and year.  

Source: JRC elaborations on BEREC Transparency data 

In the last three years, more than 80% of the MNOs and MVNOs (combined) applied at 
least one of the instruments. A significant majority of operators (79% of the MNOs and 
61% of the MVNOs in 2024) have applied the open data bundle limits. A sizeable number 
of mobile operators apply other criteria, notably the control window mechanism (58% of 
the MNOs and 53% of the MVNOs in 2024), the stable link criterion (36% of the MNOs 
and 36% of the MVNOs in 2024) and the pre-paid limits (32% of the MNOs and 43% of 
the MVNOs in 2024). It is noteworthy to mention that MVNOs are more inclined to apply 
FUP  measures  on  pre-paid  tariffs  than  MNOs.  The  preferred  FUP  measure  used  by 
MVNOs is the fair use limit on open data bundles (61% in 2024). The usage of all the other 
FUP measures by MVNOs is rather stable. (32) 

(32)  See Table A in the Annex on individual data for MNOs and MVNOs. 

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Figure 7: Percentage of users with usage going beyond periodic travel (control mechanism and 
stable link criterion) or exceeding FUP on data (open data bundle or pre-paid data limits), over 
users who roamed at least once in the reference period, by quarter (2018-2024). 

Source: JRC calculation on BEREC Benchmark questionnaires data. 

While the FUP limitations remain commonly applied by operators,  the vast majority of 
roaming customers never reach these limits. Overall, among all roaming consumers, the 
share that consume roaming services beyond periodic travel (33) was lower than or equal 
to  3% (34)  in  all  quarters  since  2018.  Similarly,  the  number  of  roaming  customers 
exceeding the FUP limit on data (35) was less than or equal to 4% (36) in the last four 
years (Figure 7).  

In total, only 4.65% of the data roamers went above their fair use policies in Q3 2024. 
These numbers confirm that FUP is applied in exceptional cases and that the RLAH regime 
is effective in covering EU consumers’ needs when travelling, while being sustainable for 
the roaming providers.  

(33)  i.e. going above the control mechanism and/or the stable link criterion. 
(34)  In Q3 2024, 0.87% of the roamers were identified with usage going beyond periodic travel. 
(35)  i.e. going above their roaming data allowance, either on pre-paid or open data bundles. 
(36)  In Q3 2024, the share of users exceeding their FUP data limit was 3.78%. 

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Figure 8: Percentage of data roaming volumes reported as usage beyond periodic travel (control 
mechanism and stable link criterion) or exceeding FUP on data (open data bundle or pre-paid 
data limits), over total data roaming volumes, by quarter (Q1 2018 – Q3 2024). 

Source: JRC calculation on BEREC Benchmark questionnaires data. 

Similarly,  data  collected  on  overall  roaming  traffic  show  that  exceeding  FUP  data 
volumes (37)  stayed  around  3%  of  the  total  roaming  data  consumption  in  the  last  years 
(3.33% in Q3 2023 and 2.6% in Q3 2024). Likewise, the roaming data volumes identified 
as going beyond periodic travel (38) represented less than 1.5% of the total data roaming 
consumption in the last years (0.86% in Q4 2024). Overall, only 3.46% of the total data 
roaming  volume  in  Q3  2024  exceeded  the  fair  use  policies,  underlying  again  how 
exceptional these measures are. 

In its Opinion (39), BEREC confirms that the FUP successfully limits excessive use while 
ensuring the vast majority of roaming volumes are provided under domestic terms. BEREC 
also notes that the percentage of data roaming volume going above the FUP is very low 
making  it  exceptional.  In  addition,  BEREC  recalls  that  any  amendment  should  be 
approached with  caution. BEREC also notes that there is some room for improvements 
while  maintaining  most  of  the  current  mechanisms  (for  details,  see  section  BEREC 
Opinion) further below). 

Effectiveness of the FUP mechanisms  

In  the  data  collected  by  BEREC  over  the  last  years  (last  one  in  2024),  the  operators 
acknowledged  the  effectiveness  of  the  FUP  when  it  comes  to  successfully  addressing 
abusive or anomalous use of regulated roaming services at domestic prices by individual 
users. 96% of the operators (40) considered the stable link criterion as either effective or 

(37)  i.e. above the open bundle allowance or the pre-paid data limits. 
(38)  i.e. going above the control mechanism and/or the stable link criterion. 
(39)  BoR(25) 48, p.25. 
(40)  MNOs and MVNOs combined. 

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partially  effective  in  2024 (41).  Regarding  the  open  data  bundle  limits,  99%  of 
operators (42)  considered  it  as  either  effective  or  partially  effective  in  2022 (43)  and 
2023 (44). This number dropped to 49% in 2024 with 50% of respondents considering it 
ineffective  (but  not  unnecessary) (45).  A  similar  trend  can  be  observed  for  the  control 
mechanism: 92% of the respondents considered it effective or partially effective in 2023 
while only 40% in 2024. The drop in the perceived effectiveness of the open data bundle 
limits and control mechanisms is not fully corroborated by the BEREC Opinion and will 
therefore be further monitored in the next reporting exercise(46). Finally, on the “other FUP 
mechanisms”  (also  known  as  “other  objective  indicators”) (47)  only  three  respondents 
provided an answer in 2024 (and six in 2023) making the results difficult to interpret and 
assess.  

Cost and complexity of the FUP mechanisms  

The FUP enable operators to successfully address abusive or anomalous use of roaming 
services  at  domestic  prices,  for  other  purposes  than  periodic  travelling,  by  individual 
customers (48).  However,  some  operators  consider  that  these  instruments  are  costly  and 
complex to implement. 39% of the respondents find the control window mechanism to 
be  very  difficult  to  implement.  On  the  open  data  bundle  limits,  49%  of  the  operators 
consider  it  either  relatively  difficult  or  very  difficult  to  implement  while  this  number 
reaches  67%  for  the  “other  FUP  mechanisms”  (49).  The  Commission  notes  that  costs 
incurred by the control window mechanism mostly arose during the implementation phase 
and  any  amendment  would  also  generate  extra  costs.  BEREC  confirms  this  in  its 
Opinion (50).  Now  that  most  of  the  operators  are  applying  the  fair  use  policies,  the 
constraints are limited but it could be more problematic for new entrants.  

BEREC Opinion (51)  

In  its  2025  Opinion (52),  BEREC  acknowledges  that  FUP  mechanisms  have  been 
instrumental and remain necessary for the functioning of the RLAH. In addition, BEREC 
recalls that any amendment should be approached with caution. BEREC also notes that 
there is some room for improvements while maintaining most of the current mechanisms. 

(41)  See Table B2 in the Annex. 
(42)  MNOs and MVNOs combined. 
(43)  See 2023 Review Report. 
(44)  See Table B1 in the Annex. 
(45)  See Table B2 in the Annex.  
(46)  See Tables B in the Annex. 
(47)  It refers to two indicators listed under Article 4(4), subparagraph 7 of the Commission Implementing 
Regulation (EU) 2016/2286: (i) long inactivity of a given SIM card associated with use mostly, if not 
exclusively, while roaming and (ii) subscription and sequential use of multiple SIM cards by the same 
customer while roaming. 

(48)  BEREC  considers  that  “the  current  FUP  measures  address  effectively  the  consumption needs  of  EU 
consumers travelling in the EU/EEA while protecting operators from anomalous and abusive usage” 
(See BoR(25)48, p.26). 
(49)  See Table C2 in the Annex.  
(50)  BEREC notes that it must also be taken into account that roaming providers have already implemented 
costly measures, especially with view to FUPs. These investments should not be devalued by significant 
changes, BoR(25)48.  

(51)  BoR(25)48. 

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On the FUP for open data bundles, BEREC noted that there is an increasing number of 
instances  where  the  calculation  methodology  results  in  cases  where  the  roaming  data 
allowance  exceeds  the  total  data  volume  included  in  the  domestic  plan.  BEREC 
recommends that the data roaming allowance should, at most, correspond to the total data 
volume included in the customer’s domestic offer. The Commission recalls that the RLAH 
principle gives the roaming customers the right to use roaming services in the same way 
as  at  home.  Therefore,  a  roaming  provider  would  not  need  to  offer  more  roaming  data 
volume than at home in the case where the FUP calculation formula would lead to such a 
case. Regarding the control mechanism, BEREC notes that it is generally considered as 
useful  in  preventing  anomalous  and  abusive  usage.  However,  stakeholders  expressed 
concerns  about  its  complexity,  both  in  terms  of  implementation  and  in  effectively 
communicating it to customers. BEREC notes that the fair use policy mechanisms for pre-
paid offer and “organised resale” are quite complex to implement and to communicate 
to the customers. This is consistent with the Commission findings in this report. BEREC 
proposes  to  clarify  this  in  the  Regulation.  Additionally,  BEREC  proposes  that  the 
Commission could reassess whether the two-week warning period remains necessary after 
an  abusive  or  anomalous  usage  has  been  proven.  Finally,  BEREC  suggests  that  the 
provisions  on  the  maximum  wholesale  charges  in  currencies  other  than  euro  could  be 
streamlined (53).  

Conclusion  

The FUP mechanisms remain essential for ensuring sustainable  RLAH in the EU/EEA. 
These mechanisms benefit operators while allowing EU residents to use mobile services 
in  the  same  way  when  travelling  as  they  do  in  their  home  country.  However,  the 
Commission also takes note of BEREC’s suggestions and shares BEREC’s view that any 
amendments should be approached with caution and should not alter the current regime. 

5.3.  Application of the derogation mechanism  

Overview of the sustainability derogation mechanism  

The derogation mechanism has acted as an effective safeguard against possible distortions 
in  the  few  domestic  markets  where  such  a  risk  had  been  identified.  The  derogation 
mechanism is still used and useful as a safety net. In this way, operators can avoid domestic 
price increases in case they are able to demonstrate a likely relevant negative margin for 
providing regulated roaming services. The sustainability derogation system may have also 
contributed to  preventing the increase  in  domestic prices when RLAH came into force. 
The 3% limit for the negative margin, set in CIR as a minimal condition for the NRAs to 

(53)  In its Opinion, BEREC explains: “For currencies other than the euro, the maximum charges are subject 
to an annual revision starting from 2023, based on the average of the reference exchange rates published 
on three specified dates in the Official Journal of the European Union. These annually adjusted limits 
for  non-euro  currencies  take  effect  from  15  May.  Conversely,  reductions  in  the  maximum  regulated 
wholesale charges (denominated in euro) come into effect from 1 January. To enhance consistency and 
streamline the derivation of the fair use allowance adjustments, BEREC recommends aligning both dates 
to 1 January”. 

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grant  derogations,  has  not  introduced  issues  to  the  sustainability  objectives  of  the 
derogations. 

Mobile operators that have demonstrated that they are not able to recover their actual and 
projected costs of providing regulated roaming services without increasing their domestic 
prices in order to provide RLAH have been granted a sustainability derogation by the NRA, 
at their request. Unless renewed, a sustainability derogation expires after one year time. 

Figure  9  below  presents  the  number  of  derogations  granted  in  all  years  of  RLAH 
application, by type of operator (MNO and MVNO).  

Figure 9: Sustainability derogations granted by NRAs since RLAH, MNOs and MVNOs 

30

14

15

8

19

2

12

2

RLAH YEAR 1 
(Q3 2017 -
Q32018)

RLAH YEAR 2 
(Q3 2018 -
Q32019)

RLAH YEAR 3 
(Q3 2019 -
Q32020)

RLAH YEAR 4 
(Q3 2020 -
Q32021)

12

11

9

0
RLAH YEAR 5 
(Q3 2021 -
Q32022)

0
RLAH YEAR 6 
(Q3 2022 -
Q32023)

0
RLAH YEAR 7 
(2024)

MNOs

MVNOs

Source: For the interval 15 June 2017 – 30 September 2023 (i.e., RLAH YEAR 1 to 6), based 
on data collected by BEREC for Transparency report (2018, 2019, 2020, 2021, and 2022 and 
2023). For 2024 (i.e., RLAH year 7), based on the information recorded in the 2025 BEREC 
Opinion. 

MVNOs have been the main recipients of the sustainability derogation given their specific 
situation in the wholesale roaming market (54). Since 2022, no MNOs have been granted 
sustainability  derogations.  Likewise,  since  2022,  operators  that  were  granted  a 
sustainability derogation have had a very small market share in their respective countries.  

The  improvement  of  the  sustainability  conditions  may  explain  the  declining  number  of 
derogations granted. Contributing factors are the lowering of wholesale roaming charges 
and the ability of operators to negotiate better terms for their roaming access agreements. 

The actual roaming voice and data traffic that is subject to surcharges due to sustanability 
derogations  is  marginal  and continues to  decrease. Since the third quarter of 2022, this 

(54)  MVNOs do not have their own mobile networks and therefore cannot host roaming traffic from foreign operators’ 
subscribers. Consequently, in bilateral wholesale roaming negotiations, where the price of wholesale roaming traffic 
is negotiated (below the regulated wholesale price cap set in the Roaming Regulation), MVNOs cannot exchange 
roaming traffic with their counterpart. They must buy the full roaming traffic that their subscribers generate on a 
MNO’s network. 

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traffic  is  below  0.82%  in  each  country  where  sustainability  derogations  have  been 
granted (55). 

Effectiveness of the sustainability derogation mechanism 

In its 2025 Opinion (56), BEREC notes that the sustainability derogationm mechanism is 
effective  but  that  its  complexity  impacts  its  efficiency.  The  number  of  applications  for 
sustainability derogations is decreasing but the mechanism remains a relevant component 
of the RLAH framework. BEREC underlines that the mechanism is difficult to apply in 
practice  as  regards  the  effect  on  competitiveness  it  can  have  on  operators  applying  the 
authorised surcharges. 

In general, end-users have a low incentive and are less likely to switch operators for the 
reason of prices applied to roaming services. Most end users use roaming services for the 
purpose  of  periodic  travelling.  Consequently,  the  prices  applied  by  the  operator  for 
domestic services are a more decisive factor for the choice of tariff and subscription than 
roaming.  

In its 2025 Opinion (57) BEREC repeats some of the suggestions made in the 2019 Opinion 
(58)  to  clarify  what  could  be  made  with  regard  to  the  sustainability  rules.  BEREC’s 
proposals concern improvements in the text of the CIR’s, and will be considered by the 
Commission in the next review of the CIR. 

BEREC also proposes the introduction of a derogation mechanism at the wholesale level, 
accessible  to  visited  mobile  network  operators  that  are  unable  to  recover  their  costs  of 
providing  roaming  services  from  the  applicable  roaming  wholesale  caps.  This  new 
proposal is closely linked with BEREC’s suggestion for setting the roaming wholesale caps 
by  disregarding  the  costs  of  outlier  countries/operators.  The  Commission  continues  to 
monitor  the  developments  in  the  wholesale  roaming  market  to  ensure  that  wholesale 
roaming caps are set at a level that provides cost recovery for operators. 

Conclusion on sustainability derogations 

Since the introduction of the RLAH rules, the sustainability derogation rules have worked 
effectively  as  also  confirmed  by  BEREC’s  2025  Opinion (59).  There  is  a  clear  trend  of 
decreasing the number of operators in need of sustainability derogations. Of the submitted 
derogation requests, most have been granted to providers with a small market share, and 
very  few  were  rejected.  In  some  Member  States  where  derogations  were  granted, 
surcharges were not applied. The volumes of voice and data roaming services subject to 
sustainability surcharges have dropped below 0.82% in every considered Member State. 
These positive outcomes can mainly be explained by the lowering of wholesale roaming 

55)  For  more  detailed  data  and  analysis  on  the  sustainability  derogation  mechanism,  please  refer  to  the 
section 5 of the Commission Staff Working Document on the findings of the 2023 periodic 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(2024)8). 

(56)  BoR(25) 48. 
(57)  BoR(25) 48. 
(58)  BoR (19) 101. 
(59)  BoR(25) 48. 

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caps and the fact that, in some cases, the wholesale roaming charges effectively applied 
were even below the caps.  

The derogation mechanism is acting as an effective safeguard against possible distortions 
in the few domestic markets where such a risk could emerge and has also allowed operators 
in these markets to keep their competitive domestic charging model and in particular their 
very low-price level for domestic mobile data services, while allowing end-users to still 
greatly benefit from the roaming reform. 

5.4.  Use of alternative roaming tariff plans  

The needs of roaming customers vary based on their travel purpose and destination. As a 
result,  any  roaming  provider  can  offer  alternative  roaming  tariffs,  and  customers  may 
actively select options other than the default RLAH conditions. While a roaming provider 
is not obligated to provide roaming services, in the case that an operator does so, RLAH 
has to be offered by default. All roaming customers who choose an alternative tariff instead 
of a regulated RLAH offer must be made aware of the roaming benefits that they would 
forfeit. According to Article 8 of the Roaming Regulation any roaming customer may, at 
any time, request to switch back to or from a regulated roaming tariff free of charge. 

One-third  of  operators  provide  alternative  roaming  tariffs,  which  come  in  daily  (14 
operators),  weekly  (18  operators),  monthly  (39  operators),  or  other  package  types  (19 
operators), designed for particular needs or customer categories. These tariffs may include 
surcharges for EEA roaming as well as added voice/data allowances or reduced rates for 
countries outside of the  EEA,  for  example the  United Kingdom  (UK), Switzerland, the 
United States of America (USA), and Türkiye among others. According to the 31st BEREC 
International  Roaming  Benchmark  Data  and  Monitoring  Report,  19  %  of  the  operators 
offering alternative tariffs indicated that they apply a surcharge for roaming in EU/EEA 
destinations to some of the alternative tariffs. For these alternative tariffs with a surcharge 
for EEA roaming, 41 % of the respondents with such surcharges indicated that they include 
non-EU/EEA destinations with no surcharge or at a reduced rate.  

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Figure 10: Percentage of roaming voice and data traffic from alternative tariffs in total EU27 
roaming traffic, Q4 2016 – Q3 2024  

Source: BEREC BMK data processed by JRC 

Despite one-third of operators having alternative offerings, in Q3 2024, the proportion of 
roaming call minutes made within the EU27 by subscribers on alternative tariffs is as low 
as 5.5%, while the corresponding data usage share is 4.2%. Both figures are following a 
consistent downward trend. Estonia reports the highest percentage of roaming calls made 
on alternative tariffs, followed by Luxembourg, Slovakia, Ireland, Poland and Germany. 
The highest retail EU/EEA roaming data volumes from alternative tariffs are found among 
Estonian users, followed by Poland, Germany, Slovakia and Luxembourg. In 15 Member 
States  for  calls  and  18  for  data.  This  percentage  is  less  than  1%  of  all  the  volumes 
consumed. According to BEREC in Q3 2024, an average of 4.17 % EEA roaming enabled 
customers are subscribed to an alternative tariff. 

5.5.  Evolution of domestic tariff plans  

BEREC data indicates that the Average Revenue Per Paying User (ARRPU) has remained 
stable from 2019 to 2024, with constant prices and expanded services, such as larger data 
volumes. In any case, changes in ARRPU could not be solely attributed to the introduction 
of RLAH, as pricing is influenced by factors like inflation and competition. BEREC notes 
a  trend  towards  unlimited  tariff  plans  and  highlights  the  FUP  for  open  data  bundles  as 
crucial  for  the  sustainability  of  the  RLAH  framework.  Regarding  the  Roaming 
Regulation's  impact  on  domestic  markets,  NRAs  and  BEREC  can't  precisely  assess  its 
effects due to the dynamic nature of the electronic communications services and networks 
markets,  influenced  by  various  external  factors.  They  cannot  clearly  identify  which 
changes are due to the introduction of the RLAH regime versus independent developments. 

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BEREC continues to monitor these markets but has found no evidence of mobile providers 
exiting due to the Roaming Regulation's obligations. 

5.5.1.  Domestic prices 

The findings  from  the study “Mobile Broadband Prices in  Europe” (60) conducted from 
2017  to  2024  reveal  a  downward  trend  in  average  prices  across  the  EU  following  the 
implementation of RLAH. As illustrated in Figure 11, the EU average minimal prices for 
all baskets decreased by 19 to 86% between 2017 and 2024. Notably, the prices for higher 
data  allowance  baskets  dropped  more  significantly  compared  to  those  with  lower 
allowances. This points to a significant reduction in prices for mobile broadband plans that 
offer higher data allowances, providing more value to consumers. 

Figure 11: Evolution of domestic prices 

Source: Empirica data processed by JRC 

Based on the information in the table below, mobile broadband prices have decreased in 
2024 compared to 2022. On average, mobile broadband prices, for the usage baskets shown 
below, are roughly 16% lower. Only the price of the lowest allowance of 1GB data-only 
basket increased slightly.  

(60)  Empirica’s studies adhere to the minimal normalized prices in euro (€/Purchasing Power Parity) across 
each EU Member State for a collection of baskets. The details regarding the consumption included in 
each analyzed basket can be found in Section 3 (Methodology). 

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Table 2: Change in the average EU price for mobile services, 2022-2024. 

Change 
for data only baskets 

in  average  EU  price  

Change 
for data and voice baskets 

in  average  EU  price  

1 GB  

5 GB 

20 GB  

50 GB  

3.63% 

-14.14% 

-26.03% 

-26.20% 

1 GB, 30 
calls 

5 GB, 30 
calls 

20 GB, 
300 calls 

50 GB, 
100 calls 

-8.11% 

-12.26% 

-22.85% 

-23.11% 

Source: Empirica data processed by JRC 

5.5.2.  Domestic-only tariff plans  

The Roaming Regulation does not oblige operators to provide roaming services. Mobile 
operators can provide tariff plans that do not include regulated roaming services. BEREC 
notes in its Opinion (61) that these plans are primarily used as fixed-mobile substitutes in 
areas  without  fixed  broadband  access  (e.g.,  due  to  high  connection  costs  for  fixed 
broadband),  as  well  as  for  regional  applications  such  as  public  Wi-Fi  hotspots  (e.g.,  in 
public transportation). This highlights the continued relevance of domestic-only plans in 
addressing specific connectivity gaps and use cases, while also confirming that such plans 
are not designed for roaming purposes. 

Figure 12: Percentage of domestic-only subscribers per country 

Source: BEREC BMK data processed by JRC 

A  small  percentage  of  EU/EEA  users  subscribe  to  domestic-only  plans.  The  BEREC 
Opinion (62) indicates that the average share of domestic-only tariffs within the EU/EEA 

(61)  BoR(25)48. 
(62)  Ibidem. 

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using roaming-enabled SIM has declined from 4.4% to 3.2% from Q4 2021 to Q3 2024. 
SIM cards designated for domestic-only use (i.e., those that do not offer roaming services 
abroad) may include SIM cards intended for fixed locations (such as in routers), prepaid 
options,  low-cost  tariffs  aimed  at  domestic  consumption,  or  specific  plans  (e.g.,  for 
corporate clients, children, machine-to-machine (M2M), or business-to-business (B2B)). 
As of Q3 2024, the percentage of subscribers on domestic-only tariffs in EU/EEA countries 
is 3% for MNOs and 2% for MVNOs.  

There has been no significant variation over time in the average number of subscribers to 
domestic-only  plans  in  EU/EEA  countries,  although  country-specific  figures  show 
considerable differences. Domestic-only tariff options remain limited, except in Poland, 
Romania, Austria, Latvia, and Bulgaria, where over 10% of users are on such plans. From 
Q2 2020 to Q3 2024, this percentage has significantly decreased in Romania, Estonia and 
Latvia, but has seen a slight increase in Finland. Based on data from Q3 2024, in 20 Union 
countries, the share of subscribers on domestic-only plans is very minimal, reaching up to 
5%. 

5.6.  Third country roaming  

The benefits of the RLAH policy for consumers are so visible that the EU roaming policy 
has  paved  the  way  for  several  regions  outside  the  EU  to  introduce  measures  to  lower 
roaming  charges  in  cross-border  settings  to  address  similar  market  failures.  The  six 
Western Balkan countries replicated in  their  Regional Roaming Agreements  (RRA) the 
EU roaming policies in the region and a full RLAH regime between themselves since July 
2021, including the detailed fair use policies.  

Since the introduction of RLAH, several third countries – also geographically located quite 
far from the EU – have expressed their interest in joining the EU RLAH area or at least 
reducing roaming prices with the EU (63). Beyond the economic benefits for third country 
consumers, it also seems that in certain cases, especially for candidate countries, being able 
to freely use mobile devices while periodically travelling in the RLAH area represents a 
symbolic value of belonging to the “EU family”. Moreover, operators in Ukraine, Moldova 
and Western Balkans, respectively, have voluntary arrangements in place with some EU 
operators for lowering roaming charges.  

5.6.1.  Extending roam-like-at-home to third countries 

The Roaming Regulation encourages initiatives that aim to lower the roaming charges for 
roaming services between the Union and third countries on a reciprocal basis. International 
roaming  plays  a  significant  and  strategic  role  in  geopolitical  position  of  the  European 
Union in relations with its neighbours, capable of gaining citizens’ support. The EU has 
already  made  steps  towards  extending  the  RLAH  area  to  countries  entering  the  single 
market,  like  in  the  case  of  the  EEA  and  lately  also  to  some  candidate  countries.  The 
extension of RLAH benefits to third countries requires the incorporation in these countries’ 
legal order of the roaming acquis. This acquis includes, beyond the mere roaming rules, 

(63)  Interest has been expressed by Western Balkan countries, Ukraine, Moldova, Georgia, Azerbaijan, UK, 

Switzerland, Israel, Morocco and Japan. 

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also parts of the Code, the BEREC Regulation and the Delegated Act on termination rates. 
Any such arrangement also needs to fully respect the EU’s international trade obligations.  

Several  third  countries  have  expressed  interest  in  joining  the  RLAH  area,  including 
Ukraine,  Moldova  and  the  Western  Balkans.  Ukraine  and  Moldova  have  Association 
Agreements with the EU that allow for their internal market access. The RLAH policy can 
thus  be  extended  to  the  association  partners  before  enlargement,  subject  to  full 
incorporation  in  the  national  law  of  the  “EU  roaming  acquis”  and  EU  Council 
endorsement. The association partners can then request access to the internal market for 
the roaming sub-sector that is part of the telecom sector.  

Ukraine has notified the national law approximated to the EU roaming acquis in November 
2024  and  in  June  2025  and  the  Commission  adopted  its  positive  assessment  and  draft 
decision  for  including  Ukraine  into  the  EU  Roam  Like  at  Home  (RLAH)  area.  The 
Commission’s proposal requires approval by the EU Council before a final decision can 
be adopted, to effectively extend the EU RLAH area to Ukraine. Moldova has notified to 
the Commission its alignment with the EU roaming acquis and could also join the RLAH 
area, subject to a positive assessment of the degree of alignment.  

The Commission will observe the outcome of extending the RLAH to the two candidates 
and other potential candidates such as in the Western Balkans, in the short and long term 

5.6.2.  Rest of the World (RoW) roaming prices  

BEREC collects data on roaming rates outside the EU/EEA in order to assess the potential 
impact  of  the  Roaming  Regulation  on  these  roaming  services.  The  data  is  presented  in 
BEREC’s  International  Roaming  Benchmark  Reports (64).  The  data,  which  is  collected 
annually, indicates that the retail rest of the world roaming prices have been quite stable 
for voice, SMS and data services since 2021.  

Between  Q4  2020  and  Q3  2024,  the  average  retail  rates  for  data  roaming  in  the  RoW 
decreased from EUR 10.87/GB to EUR 5.16/GB. The average retail price per minute for 
RoW roaming voice calls received and made decreased in the same period  by 13% and 
8%, respectively. The average EEA price for RoW roaming SMS services declined from 
10.98 to 5.71 EUR cents/unit. 

Consumer benefits  

However,  high  roaming  surcharges  in  third  countries  remain  an  obstacle  to  seamless 
connectivity and the unreasonably high prices lead to increasing risks of bill shocks for 
end-users (65).  The  Roaming  Regulation  lays  down  transparency  and  consumption 
monitoring rules to protect roaming users from bill-shocks. For example, operators apply 
an automatic cut-off limit for roaming consumption once surcharges reach 50 EUR and 
100 EUR (See Section 5.7.2). In addition, BEREC suggests that the Roaming Regulation 
should introduce tools enabling roaming customers to opt out of consuming data roaming 

(64)  BoR (24) 38. 
(65)  The  Commission  has  received  in  2022  a  complaint  for  a  bill  shock  while  roaming  in  the  Western 

Balkans, where an EU consumer was charged 1400€ for a 12 hour stay in Serbia.  

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services  when  connected  to  Rest  of  the  World  networks  (see  also  Section  5.7.2.4  on 
inadvertent roaming).  

In  its  2025  Opinion (66),  BEREC  notes  that  many  operators  include  non-EU/EEA 
destinations  in  their  RLAH  FUP.  BEREC  also  recalls  that  FUP  volumes  for  open  data 
bundles are in general quite high so that extending it (always on a voluntary basis) to cover 
non-EEA countries will not result in subscribers not having the volumes they need when 
travelling  in  the  EU/EEA.  In  this  context  BEREC  proposes  to  explicitly  include  this 
possibility in the Roaming Regulation. 

The Commission recalls that the Roaming Regulation lays down the rights and obligations 
for  roaming  in  the  EU.  It  lays  down  the  right  for  any  roaming  customer  to  consume  a 
minimum  amount  of  regulated  roaming  services  within  the  Internal  Market.  It  is  not 
consistent  that  these  minimum  rules  include  also  roaming  in  third  countries.  It  is 
undoubtedly a benefit for the consumer to use roaming services at RLAH conditions also 
in a third country. However, consuming roaming services outside of the EU/EEA should 
not  lead to  the consumption of the minimum  guaranteed  volumes of  regulated roaming 
services in the EU/EEA.  

5.6.3.  Impact of BREXIT on roaming with the United Kingdom 

The United Kingdom (UK) officially left the EU at the end of the transitional regime on 1 
January 2021. In the fields of electronic communications, a Notice (67) had been published 
by the Commission on 18 December 2020, to  prepare  for the actual withdrawal  and its 
consequences on the electronic communications markets.  

The UK ceased to be bound by EU rules, including the Roam-Like-at-Home regime and, 
by inference, the fair use policies. Since then, UK and EU operators, respectively, can levy 
additional roaming charges for roaming between the UK and EU and therefore surcharge 
consumers. 

After the end of the RLAH regime, most of UK’s main MNOs have reintroduced retail 
surcharges  for  roaming  in  the  EU  for  their  customers,  while  many  European  operators 
maintained  favourable  conditions  and  preserved  roaming  without  surcharges  within  the 
United  Kingdom  for  their  subscribers,  to  the  benefit  of  European  consumers.  The 
Commission welcomes those initiatives to apply RLAH in third countries, on a voluntary 
basis.  However,  the  Commission  recalls  that  third  country  roaming  traffic  cannot  be 
deducted from the minimum roaming data allowance that the end-user is ensured to enjoy 
under the roaming rules while travelling in the EU. While extending the RLAH benefits to 
third countries is beneficial for consumers, it should not negatively affect the minimum 
rights that consumers have for roaming in the EU. 

A snapshot of the roaming conditions in subscription plans offered by some of the major 
UK mobile operators reveals that roaming in the RLAH area often incurs a daily charge 
for the UK end user (e.g., £2/day for one major MNO). Additionally, when the roaming 
customer  exceeds  the  “data  allowance”,  the  retail  surcharges  applied  are  consistently 

(66)  BoR (25)48. 
(67) European Commission, Notice to stakeholders: withdrawal of the United Kingdom and EU rules in the 
fields of electronic communications, 18 December 2020. 

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higher (around £3 - £3.5/GB) than those regulated in the RLAH area, set at the wholesale 
cap levels (EUR 1.30/GB in 2025 and decreasing to EUR 1/GB as of 2027). 

5.7.  Consumer protection and perception  

5.7.1.  Consumer perception 

Consumer awareness of the RLAH regime 

On the consumer side, awareness of the RLAH benefits is increasing, as confirmed by the 
Eurobarometer 521 study, with an overwhelming majority of travellers acknowledging that 
they  are  aware  they  can  use  roaming  services  without  surcharges  while  periodically 
travelling (83% for calls, 81% for messages, and 82% for data). In terms of transparency, 
EU  residents  also  found  useful  the  welcome-message  (so-called  “Welcome  SMS”)  – 
improved under Regulation (EU) 2022/612 - including personalised pricing information 
on  roaming  while  abroad.  European  consumers  consider  that  they  are  benefiting  from 
Roam-Like-at-Home rules (84%) and that they have been able to stay connected abroad as 
in their home country (80%). The more recent Eurobarometer 560 confirms these findings, 
as  78%  of  respondents  feel  that  they  benefit  from  roaming  without  surcharges. 
Eurobarometer 521 results also showed that 49% of respondents still occasionally or even 
in some cases for the whole time of their stay abroad, limit their roaming data usage. In 
that regard, Eurobarometer 521 results indicated that customers with lower awareness of 
the  rules  are  more  likely  to  limit  their  usage.  (68)  The  more  recent  Eurobarometer  560 
shows that 40% of the respondents have limited the amount of mobile data used to avoid 
surcharges when travelling in the EU/EEA. It also shows that 34% of the respondents have 
switched  off  data  roaming  to  avoid  surcharges  and  27%  have  activated  a  special  data 
roaming plan offered by their mobile operators to avoid surcharges.  

Overall, data suggest that RLAH is benefiting most people in the Union, but the situation 
for consumers could still be improved. In that regard, the Commission already noted in its 
2023  FUP  Review  Report  (69)  that  transparency  (See  Section  5.7.2)  and  access  to 
information is of particular importance to increase awareness of the EU consumers on the 
RLAH regime. 

In its Opinion BEREC noted that the majority of NRAs reported fewer than 50 consumer 
complaints. In the most populated countries, where the highest numbers were recorded, the 
reported  figures  consistently  remained  below  300.  The  most  common  complaint  in  the 
period Q4 2022 to Q3 2024 is about inadvertent roaming (70) (35%), followed by lack of 
transparency about tariffs and roaming conditions (19%), complaints about the application 
of RLAH tariffs (14%) and FUP (7%). The low number of complaints confirms that the 
roaming rules generally work well and that consumers benefit from RLAH conditions, but 
that issues often arise where consumers are not sufficiently aware or informed about the 
roaming conditions. 

(68)   Flash Eurobarometer 521 – Roaming. 
(69)  SWD(2024) 8 final. 
(70) Inadvertent roaming is when a roaming user unintentionally connects to a network, e.g. to a third country 

network in a border region or to a network on a ship or plane.  

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Enhanced consumer benefits under the FUP with the current wholesale charges glidepath 

The wholesale glidepath (until 2027) improved roaming conditions for EU consumers, in 
particular regarding two aspects: 

•  There  is  an  automatic  and  progressive  increase  in  consumers’  roaming  data 
allowance  for  subscribers  of  unlimited  data  plans,  resulting  from  the  annual 
reduction in wholesale data caps (i.e., a glidepath towards EUR 1/GB by 2027 – See 
Figure  13  below).  This  mechanism  enhances  conditions  for  users  of  unlimited  data 
bundles (71) and further reduces the potential for surcharges (72). 

•  Additionally, in exceptional cases where fair use limits are exceeded, any applicable 
surcharges imposed by operators are  capped at the level of the wholesale caps. 
These surcharges will follow the glidepath, reaching EUR 0.019 per minute for voice 
and EUR 0.003 per SMS by 2024, and EUR 1/GB for data by 2027. 

Figure 13: Decreasing trend of the data surcharge operators can apply over the years (€/GB))  

4,5

3,5

3

5

4,5

4

3,5

3

2,5

2

1,5

1

0,5

0

2

1,8

1,55

1,3

1,1

1

2019

2020

2021

2022

2023

2024

2025

2026

2027

Source: Regulation (EU) 2022/612 of the European Parliament and of the Council 

5.7.2.  Transparency measures  

The Roaming Regulation introduced new enhanced transparency measures under Articles 
13, 14, 15 and 16 covering, in particular (i) the welcome message but also (ii) value-added 
services, (iii) emergency communications, (iv) inadvertent roaming and (v) QoS.  

5.7.2.1.  Welcome message  

(71)  There two types of open bundles: (i) unlimited data tariffs (also called unlimited data plans – mentioned 
here), and (ii) tariffs where the implicit domestic unit price for data is lower than the regulated maximum 
wholesale caps. 

(72)  For more detailed explanations, please refer to the Figure 2 of the Section 4.1 of the Commission Staff 
Working Document on the findings of the 2023 periodic 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(2024)8). 

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Each time a roaming customer crosses a border, the operator is obliged to send a so-called 
“welcome-message”.  This  is  an  automated  message  with  clear  personalised  pricing 
information, any applicable fair use policy (which includes any roaming data allowance) 
and applicable surcharges as well as information about services that are not covered by the 
roaming rules and information about emergency communications. All the elements to be 
listed in this “Welcome-message” are listed under articles 13, 14 and 15 of the Roaming 
Regulation.  

In the Roaming Regulation, the elements  to  be listed under the welcome message have 
been  extended,  to  the  benefit  of  the  EU  consumers.  It  should  now  include  (i)  basic 
personalised pricing information and information about surcharges, (ii) information about 
Value-Added Services (VAS), (iii) information on pricing which applies for voice, SMS 
and  data  roaming  services  when  connecting  to  a  non-terrestrial  public  mobile 
communications network and (iv) emergency communications.  

 Information to be included:  

o 

o  basic personalised pricing information, expressed in the currency of the home bill, 
on  the  roaming  charges  for  making  and  receiving  calls  and  for  sending  SMS 
messages (Article 13(1)),  
that the customer can obtain more detailed personalised pricing information about 
calls and SMS by means of call or SMS to a free-of-charge number (Article 13(2)),  
o  The  potential  risk  of  increased  charges  due  to  use  of  value-added-services, 
including  a  link  to  access  free  of  charge  to  a  dedicated  webpage  providing 
information  about  the  types  of  services  that  may  be  subject  to  increased 
costs (Article 13(1)), 

o  On  the  occasion  of  each  message,  customers  shall  have  the  opportunity  to  give 
notice to the roaming provider, free of charge and in an easy manner, that they do 
not require the automatic message (Article 13(1)), 

o  Alert that the customer is using regulated data roaming services (Article 14(2), 
o  basic personlised tariff information on the charges for regulated data roaming, in 

the currency of the home bill (Article 14(2)),  

o  Any fair use policy that the roaming customer is subject to within the Union and 
the  surcharges  which  apply  in  excess  of  any  limits  under  that  fair  use  policy 
(Articles 13(1) and 14(2)), 

o  any surcharge applied (Articles 13(1) and 14(2)), 
o  That  the  customer  can  access  emergency  services  free  of  charge  by  calling  the 
single European emergency number ‘112’ as well as a link to access, free of charge, 
a  dedicated  webpage,  accessible  to  persons  with  disabilities,  which  provides 
information on alternative means of access to emergency services (Article 15), 
o  Where  public  warning  mobile  applications  are  deployed,  information  indicating 
that  public  warnings  may  be  received  by  a  public  warning  mobile  application 
(Article 15). 

When entering a third country: 

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o  basic personalised pricing information, expressed in the currency of the home bill, 
on  the  roaming  charges  for  making  and  receiving  calls  and  for  sending  SMS 
messages (Article 13(1)),  

o  basic personalised pricing information, expressed in the currency of the home bill, 

on the roaming charges for sending SMS messages (Article 13(1)),  

o  On  the  occasion  of  each  message,  customers  shall  have  the  opportunity  to  give 
notice to the roaming provider, free of charge and in an easy manner, that they do 
not require the automatic message (Article 13(1)), 

o  Alert that the customer is using data roaming services (Article 14(2), 
o  basic  personlised  tariff  information  on  the  charges,  in  the  currency  of  the  home 

o 

bill (Article 14(2)),  
In case the cut-off facility is not available, the customer shall be informed by SMS 
when crossing the border (14(7)).  

When connecting to a non-terrestrial network:  

o  basic personalised pricing information, expressed in the currency of the home bill, 
on  the  roaming  charges  for  making  and  receiving  calls  and  for  sending  SMS 
messages (Article 13(1)),  

o  basic personalised pricing information, expressed in the currency of the home bill, 

on the roaming charges for sending SMS messages (Article 13(1)),  

o  On  the  occasion  of  each  message,  customers  shall  have  the  opportunity  to  give 
notice to the roaming provider, free of charge and in an easy manner, that they do 
not require the automatic message (Article 13(1)), 

o  Alert that the customer is using data roaming services (Article 14(2), 
o  basic  personlised  tariff  information  on  the  charges,  in  the  currency  of  the  home 

o 

bill (Article 14(2)),  
In case the cut-off facility is not available, the customer shall be informed by SMS 
when crossing the border (14(7)).  

Roaming providers shall provide customers with disabilities with the basic personalised 
pricing information automatically, by voice call, free of charge, if they so request. 

In general, 71% of the respondents to the Eurobarometer 2023 (73), said that they find the 
welcome  message  with  information  about  roaming  conditions  and  personalised  pricing 
information  useful,  going  up  to  even  92%  of  respondents  in  some  Member  States, 
demonstrating its added value for EU residents. The welcome message is informative and 
comprehensive, ensuring that roaming customers can make informed choices about their 
roaming consumption. Customers who do not wish to receive the message can opt out from 
it. 

BEREC data shows that the compliance with these transparency rules is not sufficient. In 
many cases roaming customers do not receive all the relevant information that is mandated 
by the Roaming Regulation.  

(73)   Q15 – Eurobarometer 521 

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Table 3: Information provided by operators in the Welcome SMS (74) (2023) 

In the EU/EEA Welcome SMS, do you provide information about… 

Application of the domestic tariff to roaming consumption 

The FUP volume limit 

The level of surcharges when exceeding FUP 

The possibility of different charges when using VAS 

Public warning systems 

How to reach local emergency services 
Pricing on non-terrestrial networks (in case of Welcome SMS on non-
terrestrial network) 
Link to website or app with further information 

Number of 
operators that 
replied (75) 

113 

99 

98 

87 

96 

105 

98 

105 

Percentage of 
operators 
replying 
positively 
91% 

74% 

74% 

67% 

63% 

77% 

78% 

76% 

Source: 2023 BEREC Transparency data processed by JRC. 

When it comes to the completeness of the welcome message, data suggests that there are 
big discrepancies between the operators. Table 3 shows that apart from the application of 
the  domestic  tariff  to  roaming  consumption,  all  the  other  items  to  be  included  in  the 
Welcome message are not widely being communicated to the customers: around 37% and 
22%  of  the  operators  are  still  not  communicating  all  the  relevant  information  to  the 
consumers. It is noticeable that most of the information still has a high rate of inclusion in 
the message. By not giving all relevant information to customers, they lose the possibility 
to  make  informed  choices  about  their  roaming  consumption.  In  light  of  the  above,  the 
Commission considers that NRAs need to ensure that the rules are properly implemented.  

In contradiction to the findings of the Commission, in its Opinion, BEREC noted that the 
content  of  the  welcome  message  has  been  significantly  extended  by  the  Roaming 
Regulation. According to BEREC, this may have undermined the objective of providing 
information  in  a  clear  and  effective  manner  to  the  customers.  In  this  context,  BEREC 
proposes  to  limit  the frequency (76)  and/or the  content of the welcome message only  to 
essential  information  (pricing  conditions,  European  emergency  number  ‘112’,  operator 
customer  service)  and  a  link  to  an  operator’  s  dedicated  roaming  webpage  that  would 
provide  additional  information,  regarding  VAS  and  alternative  means  to  contact 
emergency services. 

The  welcome  message  serves  to  give  roaming  customers  immediate  and  complete 
information about the roaming conditions that they are subject to. It is a valuable way for 
roaming  customers  to  stay  informed  and  take  informed  decisions  about  their  roaming 
usage. Citizens confirm that they find this information useful to a high degree. Customers 
who do not wish to receive such information have the possibility to opt out from receiving 
such  messages.  Ensuring  the  completeness  and  correctness  of  the  information  in  the 
welcome messages is necessary for the consumer protection. It is the responsibility of the 
NRAs and BEREC to monitor the implementation of these obligations.  

(74)  Here SMS is understood as “message”. The welcome message can be delivered in different forms and 

does not necessarily need to be in the form of an SMS message.  

(75)  Over 119 operators in total. 
(76)  BEREC considers that crossing intra EU/EEA border should not generate another welcome message, 
with the exception of cases when customer is crossing non-EU/EEA borders or generally countries when 
different pricing applies.  

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5.7.2.2.  Value-added services (VAS) and the implementation of the database of numbering 

ranges for VAS 

The Commission found in the 2022 Impact Assessment on the Roaming Regulation (77), 
that roaming customers often incurred large bills due to a lack of transparency about value-
added service numbers and their associated higher charges across the Union. 

In order to tackle this issue, the recast introduced several new provisions:  

•  Under  Article  13(1)  of  the  Roaming  Regulation (78),  the  roaming  provider  shall 
provide their roaming customers with information on the potential risk of increased 
charges due to the use of VAS. This information shall also include a link to access 
a dedicated webpage providing additional information about services that may be 
subject to increased costs and, where available, about numbering ranges for VAS. 
This  information  can  be  retrieved  from  the  dedicated  database  on  VAS,  where 
NRAs  provide  information  about  such  services.  The  webpage  shall  also  include 
information about charges applicable to freephone numbers while roaming.  

•  Under  Article  16  of  the  Roaming  Regulation (79),  a  Union-wide  database  of 
numbering ranges for value-added services was established by BEREC, in order to 
address the issue of non-harmonization across the Union.  

BEREC  data  collection  results  show  that  only  a  limited  number  of  NRAs  received 
complaints on VAS in 2023: among the 20 respondents, 12 did not receive any complaint, 
6 received up to 10 complaints, 1 received between 11 and 50 complaints and 1 received 
between 51 and 100 complaints (80). The number of complaints has decreased compared 
to the data collected in 2022(81), prior to the introduction of the new transparency rules. 
Among the various categories  of complaints,  those related to VAS  are  among  the least 
frequently  reported  and  have  a  low  occurrence  rate  (i.e.  most  NRAs  reported  up  to  10 
complaints). This suggests that the new measures introduced on VAS are working well and 
EU consumers are better informed.  

Table 4: Informing consumers on value-added services (2023)  

Which type of information do you provide on 
VAS charges in a roaming context? 

Exact VAS charges 
General information 
Other 

Number of  
operators 
 that 
replied (82) 
77 
82 
35 

% of 
operators 
replying 
yes 
36% 
76% 
20% 

Source: 2023 BEREC Transparency data processed by JRC. 

(77)  Impact assessment report - SWD(2021)28. 
(78)  See also recital 37. 
(79)  See also recital 59. 
(80)  See Table E in the Annex.  
(81)  In 2022, among the 11 NRAs that answered the question, 9 NRAs reported “up to 10” complaints related 
to VAS, 1 NRA “between 11 and 50” complaints and 1 NRA “between 51 and 100” complaints. 

(82)  Over 119 operators. 

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Aside from the low number of complaints, operators are also informing their customers on 
VAS as demonstrated by data provided under Table 4. Operators either communicate on 
the exact applicable VAS charges (36%) or provide “general information” (76%) to their 
customers.  

While  the  Commission  acknowledges  that  informing  EU  consumers  is  of  utmost 
importance, the data collected does not allow for a thorough assessment of the provisions 
on VAS. Under Article 13 of the Roaming Regulation, “roaming providers shall provide 
roaming customers (…) with information on the potential risks of increased charges due 
to  the  use  of  value-added  services  by  means  of  an  automatic  message  (…).  Such 
information shall include a link to access, free of charge, a dedicated webpage providing 
up-to-date information”. However, the data collected does not fully cover these specific 
points. The available data does not give sufficient information about the compliance with 
the transparency obligation. It is not possible to conclude whether operators do inform their 
customers about VAS or not. From the data available it seems that only 76% give general 
information  about  VAS.  The  compliance  with  this  transparency  obligation  should  be 
further monitored.  

In  its  Opinion (83),  BEREC  proposes  to  enhance  the  clarity  of  the  VAS  provision  by 
including a specific provision in the Roaming Regulation stating that the RLAH principle 
does not apply to calls made or SMS sent by roaming subscribers towards numbers used 
for  value-added  services,  such  as  free-phone  numbers.  In  addition,  BEREC  suggests 
enhancing clarity on the current requirements on VAS. To avoid any duplication with the 
BEREC  VAS  database,  BEREC  suggests  making  it  sufficient  for  operators  to  include 
instructive  information  on  their  websites  (and  via  the  customer  service)  indicating  that 
VAS  might  not  be  charged  under  RLAH  especially  for  free  phone  number (84)  and  to 
provide  a  link  to  the  BEREC  database.  However,  it  should  be  noted  that  the  BEREC 
database on VAS as it currently stands, is not created as a tool for consumers.  

Assessing its database on VAS, BEREC also notes that the VAS provisions in the Roaming 
Regulation  may  have  been  subject  to  divergent  interpretation  by  operators,  leading  to 
different results (85). Therefore, BEREC would welcome a clarification and simplification 
of the provisions to ensure a uniform application of the rules.  

5.7.2.3.  Emergency communications  

The  Roaming  Regulation  includes  additional  provisions  on  the  access  to  emergency 
communications.  Aside  from  the  wholesale  obligation  to  include  the  (free  and 
unconditional)  access  to  emergency  services  in  the  reference  offers  negotiated  between 
operators (86), new provisions were also adopted at retail level, to the benefit of the EU 
consumers. This includes: 

•  The obligation to adequately inform roaming consumers about the means of access 
to emergency services in the visited Member States (Article 15). Information on 

(83)  BoR(25) 48. 
(84)  which are the VAS number the more often subject to complaints. 
(85)  According to BEREC, some operators do not include detailed information on a dedicated webpage but 

refer to the BEREC database. 

(86)  Article 3(6) and Article 12 of the Roaming Regulation. 

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emergency services, including the availability of 112, is part of the elements to be 
covered in the Welcome message. Customers shall also be informed of alternative 
ways to contact emergency services, including options for people with disabilities. 
Member  States  with  public  warning  mobile  apps  should  also  notify  roaming 
customers about their availability in the visited country. 

•  The establishment of a single database of access points to emergency services by 

BEREC, as required by Article 16. 

The results from the BEREC data collection show that the number of complaints received 
on emergency services is very low: only 1 NRA received up to 10 complaints in 2024. This 
is the category for which NRAs received the least of complaints in 2024 (87). This suggests 
that the new provisions introduced in the 2022 recast are efficiently working and benefiting 
the EU consumers.  

On  the  operators’  side,  only  2% (88)  of  the  operators  have  encountered  obstacles  in 
ensuring access to emergency services for roaming subscribers in 2023. 

In its Opinion, BEREC also noted that the complaints submitted to NRAs regarding the 
use of emergency services while roaming are very rare. On the industry side, operators did 
not identify any major difficulty in the implementation of the new measures. Some of them 
reported that only few consumers read additional information provided through the link in 
the Welcome message, suggesting that this could be streamlined.  

When it comes to the database, comments expressed under Section 5.7.2.2 are also relevant 
for emergency services. In addition, BEREC suggests that the Roaming Regulation could 
clarify  that  only  the  Single  European  Emergency  Number  ‘112’  number  should  be 
explicitly  mentioned  in  the  welcome  message  (and  no  national  numbers).  Alternative 
means of access to emergency services should only cover means other than calling “112”, 
such as  texting  112, app designed for users with disabilities, etc.  When it comes to  the 
BEREC database on emergency services, BEREC reiterates its suggestions expressed for 
the VAS database, in terms of clarification of its scope and possible simplification in its 
implementation (e.g. allowing operators to insert a direct link) (See Section 5.7.2.2).  

5.7.2.4.  Inadvertent roaming  

A  roaming  customer  can  connect  to  a  non-terrestrial  public  mobile  communications 
network, such as on-board marine vessels (89) or on aircraft (90), that are provided through 
types of radio networks other than terrestrial networks. These types of services are outside 
the scope of the roaming price regulation. Charges incurred by roaming customers when 
they  intentionally  or  inadvertently  connect  to  non-terrestrial  networks  are  significantly 
higher than tariffs for regulated roaming services. Roaming customers are accustomed to 
benefiting  from  RLAH  and  the  use  of  roaming  services  at  domestic  prices.  Due  to  the 
absence of a consistent approach to transparency and safeguard measures for connections 
to  non-terrestrial  networks,  roaming  customers  are  at  greater  risk  of  bill-shock. 

(87)  See Table E in the Annex. 
(88)   2024 BEREC Transparency data processed by JRC.  
(89)  MCV services are defined in Commission Decision 2010/166/EU (17). 
(90)  MCA services are defined in Commission Decision 2008/294/EC (18). 

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Transparency  measures  are  necessary  in  order  to  protect  end-users  from  inadvertent 
roaming.  

Inadvertent roaming can have significant consequences in two scenarios. Firstly, near the 
EU's  external  borders,  there  is  a  risk  of  inadvertently  connecting  to  a  third-country 
network,  where  roaming  surcharges  can  be  significantly  higher  than  RLAH  conditions, 
even if the customer is still physically located within the EU (91). Secondly, connecting to 
a non-terrestrial network on board marines’ vessels and aircraft, can result in exceptionally 
high charges for the customer (92).  

Therefore, additional transparency rules were added to the Roaming Regulation to enhance 
the end user protection. The Roaming Regulation lays down that, in addition to informing 
roaming customers about how to avoid inadvertent roaming in border regions and on-board 
vessels  and  aircraft,  roaming  providers  are  to  take  all  reasonable  steps  to  avoid  these 
connections.  Measures  that  operators  should  take  include  network  operation  measures, 
financial limits and an opt-out mechanism. Moreover, a roaming customers should receive 
an automatic message with price information every time a connection to such a network is 
made. NRAs also have a responsibility to monitor and take measures against inadvertent 
roaming within their Member States.  

BEREC  data  collection  results  show  that  inadvertent  roaming  is  the  most  common 
subject of consumers’ complaints before the NRAs: in 2024, 1 NRAs received between 
101 and 200 complaints, 2 NRAs between 51 and 100 complaints, 6 NRAs between 11 
and 50 complaints and 10 NRAs up to ten complaints. This was already the case in 2023 
(see Table E2 in the Annex).  

The  2023  Eurobarometer  confirms  that  inadvertent  roaming  is  a  concern  for  roaming 
customers. The findings indicate that 23% of consumers travelling close to an external EU 
border  and  13%  travelling  on  a  boat  actively  restrict  their  roaming  usage  to  avoid 
surchargers for roaming outside the EU (93). 

Table 5: Non-EU/EEA destinations, inadvertant roaming and non-terrestrial 

Do you provide information on how to avoid inadvertent roaming in border 
regions? 

Do you provide information on how to avoid inadvertent roaming on non-
terrestrial networks? 

Do you provide measures to protect consumers from paying for inadvertent 
roaming in the EU/EEA? 

Number of  
operators 
 that replied 

% of 
operators 
replying 
yes 

99 

90 

100 

81% 

76% 

89% 

Source: 2023 BEREC Transparency data processed by BEREC 

(91)  See Recital 48 of the Roaming Regulation. 
(92)  See Recital 46 of the Roaming Regulation.  
(93)  In total 25% of the respondents replied that they took restrictive measures during their stay, and 49% 
replied that they took restrictive measures occasionally during their stay. Restrictive measures include 
switch off their mobile phone, switch off data roaming and limit the amount of data used. 

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Data suggest that operators are taking measures to address the issue of inadvertent roaming 
(89%  provide  consumers  with  measures  to  avoid  unexpected  surcharges),  especially  in 
border  regions  (81%  of  them  provide  information  on  how  to  avoid  it)  and  also  when 
connecting to non-terrestrial networks (76% of the operators provided information to their 
customers  on  how  to  avoid  it).  However,  compliance  with  the  transparency  obligations 
must be improved  and should  be further monitored and supervised.  Roaming providers 
have an obligation to inform their customers about inadvertent roaming, to empower end-
user to make active choices about their consumption. The fact that compliance with this 
obligation  is  81%  and  76%,  respectively,  cannot  be  considered  a  sufficient  level  of 
compliance.  

Similarly, BEREC's Opinion found that inadvertent roaming remains the  first source of 
consumer  complaints,  often  occurring  in  EU  border  regions (94).  While  operators  have 
taken extra  steps to  protect  consumers, such  as  disabling roaming (70%  of respondents 
mentioned  this  mitigating  measure),  BEREC  believes  that  current  provisions  can  be 
improved.  BEREC  suggests  introducing  tools  enabling  roaming  customer  to  opt-out  of 
consuming data roaming services when connected to third countries’ networks (See section 
5.6.2). In addition, when it comes to non-terrestrial networks and in order to prevent bill 
shocks,  BEREC  suggests  introducing  an  opt-in  system  for  roaming  services  on  these 
networks. The Commission also recalls that according to the Roaming Regulation national 
regulatory authorities shall monitor and collect information on inadvertent roaming and 
take appropriate measures. 

(94)  Almost half of these were submitted by end users who inadvertently roamed on a non-EEA network 

while remaining within EEA territory. 

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6.  ASSESSMENT OF THE COSTS OF PROVIDING WHOLESALE ROAMING SERVICES 
According  to  the  Roaming  Regulation  the  wholesale  caps  should  be  set  at  a  level  that 
ensures that visited network operators are able to recover the efficiently incurred costs of 
providing  regulated  wholesale  roaming  services.  The  Commission  therefore  needs  to 
assess the costs of providing wholesale roaming services in the EU/EEA. This section will 
present  the  Commission’s  approach  to  cost  modelling  that  is  based  on  an  updated  cost 
model developed for the purposes of this review following a coherent approach with the 
previous  relevant  estimates  provided  for  these  services.  The  section  will  describe,  the 
assumptions and methodological decisions made, the results under different scenarios and 
information 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. 

6.1.  Cost of providing wholesale roaming service 
This section briefly describes the main features of the new Axon cost model (hereinafter, 
the ‘Cost Model’). This cost model published by the Commission on 18 December 2024 
is an update of the model previously developed by Axon in 2019 for the purpose of the 
2019  Roaming  Review (95).  The  methodology  used  in  this  exercise  has  not  changed 
significantly  and  largely  remains  the  same,  except  for  the  incorporation  of  5G  and 
Machine-to-Machine (‘M2M’) services into the model. 

The objective of the study was to build on the experience of the previous review of the 
Roaming  Regulation  and  enhance  the  existing  bottom-up  cost  model  to  estimate  the 
efficient costs of providing wholesale roaming services and mobile voice call termination 
services by mobile network operators in the EEA, under the current market conditions. In 
addition, the cost model also covers 5G services that have not been covered by the old cost 
model. Additional information on the methodological approach followed and the results of 
the  cost  model  are  included  in  the  full  list  of  materials  published  with  the  Axon’s  cost 
model (96).  The  aim  was  to  build  30  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 30 countries. 

The  models  would  rely  on  country-specific  input  where  relevant  and,  where  not,  on 
average/common values across the EU/EEA. On 8 January 2024 the first draft cost model 
was shared with stakeholders for consultation, followed by a second version of the draft 
model  shared  on  17  April  2024  for  a  second  round  of  consultation (97).  The  relevant 
comments  and suggestions received during both  consultations were implemented in  the 

(95)  SWD(2019)416, Commission Staff Working Document – Report from the Commission to the European 

Parliament and the Council on the review of the roaming market. 

(96)  Finalisation of the mobile cost model for roaming and the delegated act on a single EU-wide mobile 

voice call termination | Shaping Europe’s digital future. 

(97)  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 January to May 2024. 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 4 NRAs proposed by BEREC Working group dealing with roaming. 

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draft final model, which was presented to stakeholders at a second workshop on 4 July 
2024. The cost model was then finalised and published on 18 December 2024. 

6.1.1.  The approach and methodology followed by Axon 

The Axon cost model estimates the costs of providing wholesale mobile roaming services 
as well as voice termination (98) in 23 EU/EEA countries (99). 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  current  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 

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 6.4. 

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  6,  an 
overview of each methodological aspect is presented together with the approach adopted. 

(98)  Cost estimates for termination services are not presented in this report. They can be found in the the 

Axon study’s material published here. 

(99)  Iceland, Liechtenstein, Netherlands, Finland, Estonia, Latvia and Lithuania decided not to participate in 

the data collection. 

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Table 6: The methodological aspects considered in the Axon cost model 

Methodological aspect 

Approach Adopted 

Cost standard 

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

Cost categories 

considered 

►  Network CapEx. 

►  Network OpEx. 

►  General and administration costs (G&A). 

►  Wholesale specific costs 

Modelled operator 

►  Hypothetical Efficient operator, with a market share equal to 

1/#MNOs (subject to a minimum of 20%). 

Depreciation 

methodology 

►  Economic depreciation. 

►  Two economic depreciation scenarios are included based on (i) 

demand or (ii) revenues as the relevant production factors. 

Modelled period 

►  2022-2032 

Volume forecasts 

►  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). 

Allocation of joint and 

common costs 

Two cost allocation modules are available in the model: 

►  Network module: Joint and common costs are allocated to 

services based on their network usage, by using a routing 

factors matrix. 

►  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.  

Treatment of seasonality 

►  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. 

Source: Axon, CNECT/2022/OP/0065 

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

6.1.2.  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  cover  such  costs,  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  Commission's  2009 
Recommendation on Termination Rates, which recommends the estimation of termination 
rates based on a bottom-up pure LRIC approach (100). 

6.2.  Modelled scenarios 

The Axon cost model estimates costs for mobile services under a given set of scenarios. 
Understanding these scenarios is key to assess the costs produced by the model, as different 
scenarios  produce  different  results.  Furthermore,  some  scenarios  have  proven  not  to 

(100) Commission  Recommendation  of  7  May  2009  on  the  Regulatory  Treatment  of  Fixed  and  Mobile 

Termination Rates in the EU (OJ L 124, 20.5.2009, p. 67–74), available here. 

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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. 

Table 7: List of different Cost Model Scenarios 

Scenario 

Alternatives 

Description 

Annualisation criteria 

Economic depreciation based on 
ARPU (101) 

►  Revenues act as the modulation factor in 

economic depreciation 

Economic depreciation based on demand 

►  Demand acts as the modulation factor in 

economic depreciation 

Roaming increment 

Allocation of wholesale 
specific costs 

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/TAPs (102) 

Threshold to identify 
seasonal patterns 

10% 

30% 

50% 

Demand 

Conservative 

►  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% YoY reduction 

in the annual growth rate 

(101) Average revenue per user. 
(102) 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). 

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Scenario 

Alternatives 

Description 

Base-case 

Aggressive 

Common costs allocated based on traffic 

Allocation of common costs 

►  …Considering a 20% YoY reduction in the 

annual growth rate 

►  …Considering a 10% YoY reduction in the 

annual growth rate 

►  It allocates the common costs of data 

services between traditional services to end-

customers and M2M services by taking into 

account their split of traffic (volumes of GB) 

Common costs allocated based on 
customers 

services between traditional services to end-

customers and M2M services by taking into 

►  It allocates the common costs of data 

account their split of customers 

Source: Axon, CNECT/2022/OP/0065 

6.3.  Results derived from the cost model 

This section shows the results from the Axon cost model, as published together with the 
full set of materials (103). 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  6  scenarios. 
Specifically,  the  results  throughout  this  section  are  derived  under  the  following 
assumptions (see Table 7 for a description of each scenario): 

•  Annualization criteria ‘Economic depreciation based on demand’ 
•  Roaming increment ‘Specific roaming increment’ 
•  Allocation of wholesale specific costs ‘Allocation based on drivers’ 
•  Threshold to identify seasonal patterns ‘50%’ 
•  Demand ‘Base case’ 
•  Common cost allocation ‘Common costs allocated based on traffic’ 

The unit cost estimates shown in this section in Figure 14 (for data), Figure 15 (for voice) 
and Figure 16 (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 

(103) The “Presentation of results” sheet is available here. 

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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, ranging between 0.2 
and 1 €/GB in 2024, and converging downward to a range of 0.2 to 0.6 €/GB by 2032. The 
EU/EEA average in 2024 is estimated at 0.4 €/GB, while the average in 2032 is expected 
to decrease to 0.2 €/GB. 

Throughout the entire modelled period, the highest cost of providing data roaming services 
is observed in Belgium. This is primarily due to lower consumption patterns in Belgium 
compared  to  the  EU/EEA  average,  which  result  in  reduced  economies  of  scale  and, 
consequently,  higher  unit  costs  for  services.  Additionally,  certain  network  elements  in 
Belgium have higher unit costs than the EU/EEA average, further driving the overall costs 
upwards. 

Figure 14: Estimated data roaming unit costs in EUR/GB, transit costs not included 

Source: Axon, CNECT/2022/OP/0065 

In 2024, voice roaming costs are estimated between 0.1 and 1 EURcents/minute, without 
including  costs  of  transit  and  termination  (Figure  15).  Czech  Republic  and  Slovakia 
display the lowest costs whereas Luxembourg and Malta are the two highest cost countries. 
The estimated costs for 2032 converge to a range of 0.1 to 0.5 EURcents/minute for almost 
all countries, with Luxembourg and Malta being the only countries remaining above 0.2 
€cents per minute throughout the period.  

The higher wholesale cost of providing mobile services in Luxembourg compared to the 
EU  average  can  be  attributed  to  several  factors.  As  one  of  the  smallest  EU  countries, 
Luxembourg's  limited  market  size  results  in  lower  economies  of  scale,  driving  up  unit 
costs. Additionally, the country faces higher infrastructure costs per user due to its small 
population  and  specific  geographic  and  demographic  conditions.  Similarly,  Malta  also 

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experiences limited economies of scale due to its small population, which raises per-user 
costs for operators. Furthermore, high estimates for Malta are driven by the thickness of 
walls  in  Maltese  buildings,  requiring  operators  to  build  and  maintain  a  comparatively 
larger number of sites  than elsewhere seen. Together, these factors contribute to  higher 
wholesale costs in both countries.  

Figure 15: Estimated voice roaming unit costs in EURcents/min, transit and termination costs 
not included 

Source: Axon, CNECT/2022/OP/0065 

The  cost  model  estimates  for  wholesale  SMS  roaming  between  2024  and  2032  show  a 
moderate  downward  trend,  but  with  less  significant  convergence  compared  to  roaming 
voice and data. For 2024, unit costs across EU/EEA countries range between 0.05 and 0.44 
EURcents/SMS, with  the highest costs observed in  smaller markets,  such as  Malta and 
Luxembourg. By 2032, costs are projected to converge slightly, ranging between 0.05 and 
0.28 EURcents/SMS, indicating a reduction in the disparity between high-cost and low-
cost countries. 

While  a  few  countries  display  slight  downward  convergence  in  costs,  the  difference 
between the highest and lowest-cost countries remains notable. The sixfold difference seen 
in  2024  is  projected  to  decrease  by  2032,  but  less  significantly  than  the  convergence 
observed for roaming voice and data. This stability is likely attributed to the simpler cost 
structure of SMS services compared to more complex services like voice or data. 

In summary, wholesale  SMS roaming costs exhibit relative stability  and only  moderate 
convergence between 2024 and 2032, with variations across countries reflecting market-
specific conditions and economies of scale. 

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Figure 16: Estimated SMS roaming unit costs in EURcents/SMS 

Source: Axon, CNECT/2022/OP/0065 

6.4.  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 operator’s network (cost shown in Figure 15) 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  messages  are  transited  without  extra  costs  incurred  by  the  visited 
network,  for  the  purpose  of  comparison,  no  further  costs  need  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. 

In the context of termination rates, the Commission has established a union-wide mobile 
termination rate, of 0.2 EURcent/min as of 2024, pursuant to its Delegated Regulation on 

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termination  rates  (EU)  2021/654 (104)  (the  ‘Delegated  Regulation’).  Although  the 
Commission has reassessed the costs associated with providing call termination services 
as part of its new cost model project, for the purposes of this review, it will rely solely on 
the currently applicable mobile termination rate, as stipulated in the Delegated Regulation, 
of 0.2 EURcent/min. 

The  estimated  transit  costs  used  are  based  on  a  data  collection  performed  by  Axon 
Consulting and the Commission, where operators provided transit costs incurred in year 
2022 and 2023. 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 services, 2023: 0.095 EUR/GB  
•  Transit price for roaming voice services, 2023: 0.40 EURcents/minute 

As these estimates are only available for year 2023, these costs are applied to each year 
under evaluation here. The above transit costs were consulted with operators during the 
second consultation round in April 2024, where 79% of stakeholders agreed or partially 
agreed with these estimates. It must be noted that those who disagreed had contradictory 
views and considered the estimate to be either too high or too low. These differing views 
were further discussed during the stakeholder workshop, where the Commission services 
addressed  questions  and  provided  clarifications  on  the  methodology.  As  no  compelling 
evidence was provided to justify an alternative quantification, the estimates were retained 
as a balanced and pragmatic reference point for the model. 

Taking the transit prices as described above into account, the resulting costs of providing 
wholesale roaming data services are presented in Figure 14. The trends observed above 
still remain, with the range of estimates shifted upwards. Adding the estimated transit costs 
results in costs between 0.3 and 1 EUR/GB in 2024, converging towards a range of 0.2 and 
0.7 EUR/GB in 2032. 

The estimated costs in Figure 17 represent values more accurately displaying how much 
the visited network must be paid by the visiting network to ensure cost recovery. 

(104) Commission Delegated Regulation (EU) 2021/654 of 18 December 2020 supplementing Directive (EU) 
2018/1972 of the European Parliament and of the Council by setting a single maximum Union-wide 
mobile voice termination rate and a single maximum Union-wide fixed voice termination rate (CDR) 
(OJ L 137, 22.4.2021, p. 1–9). 

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Figure 17: Estimated data roaming unit costs in EUR/GB, including transit costs 

Source: Axon, CNECT/2022/OP/0065 

Comparing the unit costs presented in Figure 17 (i.e. including transit) with the estimates 
solely from the model in Figure 14, it is clear that transit costs contribute significantly to 
the total costs estimates (in the range of 8% for the highest estimated costs and 33% 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 18. In 2024, costs in all countries were roughly between 
0.7  and  1.6  EURcents/min,  converging  towards  a  range  of  0.6  and  1  EURcents/min  in 
2032. As was the case in Figure 16, almost all countries have seen decreasing estimates of 
costs, with Luxembourg and Malta maintaining a comparatively high estimate throughout 
the period. 

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Figure  18:  Estimated  voice  roaming  unit  costs  in  EURcents/min,  including  transit  and 
termination costs 

Source: Axon, CNECT/2022/OP/0065 

Regarding voice roaming services, the impact  of adding  transit and termination is  even 
more  significant  than  for  data.  Compared  with  Figure  15,  it  is  clear  that  transit  and 
termination costs significantly increase the estimated costs faced by the visited operator. 
In Figure 18, costs estimates ranging between 0.1 and 0.6 EURcents/min were presented, 
illustrating the significant impact of an additional 0.6 EURcents/min 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. 

6.5. 

Impact of 5G  

The  cost  model  demonstrates  that  the  implementation  of  5G  has  led  to  a  significant 
decrease in unit costs for the efficient operator. The model shows that the average unit cost 
per GB has decreased by 60-70% over the 10-year period, from EUR 0.10-0.20 in the pre-
5G  era  to  EUR  0.02-0.05  in  the  5G  era.  This  decrease  in  unit  costs  is  driven  by  the 
improved  network  efficiency  and  capacity  utilization  enabled  by  5G,  as  well  as  the 
increased adoption of software-defined networking and network functions virtualization. 

The  cost  model  suggests  that  the  implementation  of  5G  has  been  a  key  driver  of  the 
decrease in unit costs, and that the efficient operator has been able to take advantage of the 
improved network efficiency and capacity utilization to reduce its costs. The model also 
suggests that the operator's investment in 5G has been a sound one, as it has enabled the 
operator to reduce its costs and improve its profitability. 

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Overall, the cost model  demonstrates that the implementation  of 5G has  had a positive 
impact on the efficient operator's cost structure, leading to a significant decrease in unit 
costs and improved profitability. The model provides a clear and compelling case for the 
adoption of 5G and suggests that operators who invest in 5G will be able to reduce their 
costs and improve their competitiveness in the market. 

6.6.  BEREC opinion on the cost model and estimates 

In its Opinion, BEREC provided analysis regarding the relation between wholesale prices 
and costs. BEREC's analysis involves comparing current and estimated wholesale costs 
and  wholesale  caps  for  the  relevant  roaming  services.  The  analysis  combines  estimates 
from the Axon cost model with estimates for transit and termination costs, using the best 
available estimates of the full range of costs implied in the provision of wholesale roaming 
services.  These  results  are  then  compared  with  the  wholesale  price  caps  set  out  in  the 
Roaming  Regulation  and  the  reported  actual  charges  operators  apply  for  all  roaming 
services. This comparison is made separately for unbalanced traffic and total traffic.  

BEREC concludes that for roaming voice services, the price caps established by the 2022 
Regulation adequately cover the wholesale costs for providing roaming voice calls, with a 
sufficient margin to allow for potential further reductions in the price cap.  

Regarding roaming data services, BEREC notes that the data price cap is higher than all 
Axon cost calculations for all 23 countries for all modelled years, with the exception of 
Belgium, where the maximum data unit costs are close to the price caps for the years 2026-
2032. BEREC also observes that the actual unbalanced rates and costs are generally in line, 
with the average EEA unbalanced rate being almost equal to the average EEA maximum 
cost in 2023, and the average EEA maximum cost being 12% higher than the average EEA 
unbalanced rate in 2024.  

BEREC highlights that there are some cases where unit costs are higher than the price cap. 
For example, in Luxembourg, the costs of voice roaming are higher than  the wholesale 
price cap for 2022 and 2023, although only in 36 out of 72 scenarios. Similarly, in Malta, 
the unit cost for roaming SMS services is always higher than the price cap for all scenarios 
considered in the model. Furthermore, Belgium's costs of data roaming services are very 
high compared to those of other Member States and are close to the price cap for the whole 
period 2022-2032. 

BEREC considers that further reductions in wholesale roaming caps have been an effective 
and transparent tool for fostering fair competition and ensuring sustainable conditions for 
RLAH,  particularly  for  MVNOs.  However,  it  also  notes  that  lower  wholesale  caps  can 
create new challenges. For instance, in the case of open data bundles, operators may be 
obliged  to  offer  higher  data  volumes,  which  could  potentially  undermine  the  long-term 
sustainability of RLAH offers. 

In light of this, BEREC recommends that the setting of wholesale caps should be based on 
the  most  representative  cost  scenario,  while  excluding  outliers  where  appropriate.  This 
approach  would  allow  for  a  reasonable  margin  that  enables  both  competition  and  offer 
differentiation. To avoid  a situation where wholesale caps fall below actual  cost  levels, 

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BEREC proposes the introduction of a sustainability mechanism at the wholesale level. 
Such  a  mechanism  would  provide  for  a  targeted  derogation  for  MNOs  who  can 
demonstrate, with substantiated evidence, that they are unable to offer wholesale roaming 
services within the cap due to higher network costs. While acknowledging that outlier costs 
may be excluded from the cap-setting process,  BEREC emphasizes that any derogation 
should be strictly limited to exceptional cases. 

7.  COMPETITION IN WHOLESALE ROAMING MARKETS 

7.1.  Evolution  of  wholesale  (inbound)  roaming  volumes:  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 and time of the year. 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.  

Based on the data gathered for the BEREC’s International Roaming Benchmark Reports, 
the following figures show the relation between inbound and outbound traffic, for data - 
inbounder and outbounder countries (Figure 19), for  voice - inbounder  and outbounder 
countries  (Figure  20).  Inbounder  (resp.  outbounder)  countries  are  defined  as  countries 
whose  total  inbound  roaming  volume  is  greater  (resp.  smaller)  than  the  total  outbound 
roaming volume since the first year of RLAH (2017). 

For data services, in 2019, southern European countries like Portugal, Spain, Greece and 
Croatia, were strong inbounders, reflecting their role as key destinations for inbound data 
traffic. Meanwhile, northern and eastern European countries, such as Poland and the Baltic 
States, were primarily strong or moderate outbounders, reflecting higher  outbound  data 
usage. Central Europe showed a mix of inbound and outbound roles, reflecting balanced 
traffic patterns. 

By  2024,  eastern  Europe  strengthened  its  role  as  strong  outbounder,  with  increased 
outbound data roaming activity. Southern Europe, particularly Spain and Greece, remained 
key  inbounders,  though  their  intensity  slightly  decreased.  Central  European  countries 
shifted toward weak outbound roles, indicating a rebalancing of traffic dynamics. For data 
services,  10  out  of  the  27  countries  (AT,  BE,  CY,  EL,  ES,  HR,  IT,  MT,  PT,  and  SE) 
included in the exercise (i.e. the 27 EU Member States plus Norway) are net inbounders 
of roaming data traffic, 13 are net outbounders (CZ, EE, HU, IE, LT, LU, LV, NL, PL, 
RO, SI and SK) while the remaining 6 (BG, DE, DK, FI, FR, and NO) are without clear 
outbound/inbound pattern. 

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Figure 19: Data services, classification of inbound/outbound countries based on net outbound 
roaming data volumes.  

Source: Data collected for the 19th – 31st International Roaming BEREC Benchmark Reports. 
JRC calculations 

Between  2019  and  2024,  there  have  been  noticeable  shifts  in  inbound  and  outbound 
roaming  classifications  for  voice  services  across  Europe.  In  2019,  many  western  and 
southern European countries, such as Germany, Italy, and France, were classified as strong 
or moderate inbounders, indicating they were key receivers of inbound  roaming traffic. 
Conversely,  northern  and  eastern  Europe  displayed  a  mix  of  moderate  inbound  and 
outbound classifications.  

By 2024, there is a marked shift towards stronger outbound classifications in northern and 
eastern  European  countries,  such  as  Poland  and  the  Baltic  States.  At  the  same  time, 
southern European countries like Spain and Greece have maintained their strong inbound 
roles,  though  some  areas  show  reduced  intensity.  Notably,  France  and  Germany 
transitioned to more balanced traffic levels. For voice services, 9 (AT, BE, CY, DE, EL, 
ES, HR, MT, and PT) out of the 26 countries providing the data (i.e. the 25 Member States 
plus Norway) are net inbounders of roaming voice traffic, 13 countries (EE, FI, HU, IE, 
LU, NL, NO, LT, LV, PL, RO, SI and SK) are net outbounders while the remaining 4 are 
without clear outbound/inbound pattern (DK, FR, IT, and SE). 

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Figure 20: Voice services, classification of inbound/outbound countries based on net outbound 
roaming voice volumes. 

Source: Data collected for the 19th – 31st International Roaming BEREC Benchmark Reports. 
JRC calculations 

The analysis of both voice and data roaming services between 2019 and 2024 highlights a 
clear  shift  in  traffic  dynamics  across  Europe.  Northern  and  eastern  European  countries 
have increasingly taken on stronger outbound roles, reflecting higher outbound activity for 
both voice and data services. Conversely, southern European countries, particularly Spain 
and  Greece  have  remained  dominant  inbounders,  although  with  some  reductions  in 
intensity over time. Central Europe has shown a rebalancing, transitioning towards more 
moderate roles in both inbound and outbound classification. 

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Figure 21: Inbounder and outbounder EEA countries (2019 vs 2024) 

Source: JRC calculations based on BEREC BMK data 

7.2.  Evolution of wholesale prices 

7.2.1.  Wholesale roaming prices have been steadily decreasing 

When  a  customer  from  a  visiting  operator  roams  on  the  network  of  a  visited  roaming 
partner operator in another EU country, the visiting operator needs to pay charges to access 
the  network  of  the  visited  operator,  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 data services, after the sharp drop following 
the implementation of RLAH in 2017, remained relatively stable between 2018 and 2021. 
However, it began decreasing in 2021, coinciding with the reduction in the regulated price 
cap.  The  price  further  declined  between  2022  and  Q3  2024  due  to  the  next  step  in  the 
regulated  glide  path  (Figure  22).  Specifically,  the  average  wholesale  price  for  data  fell 
from 1.7 EUR/GB in Q1 2019 (105) to 0.7 EUR/GB in Q1 2024, representing a decrease of 
nearly 60%. 

As demonstrated in the figure, wholesale prices for net outbound (unbalanced) roaming 
traffic were even lower, with rates at 0.6 EUR/GB in Q1 2024 compared to 1.5 EUR/GB 
in  Q1  2019,  a  reduction  of  40%.  The  wholesale  prices  actually  applied  throughout  the 

(105)  The Roaming Regulation has been previously reviewed in 2019. 

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observed period were more than 50% lower than the regulated wholesale roaming caps, 
resulting in a difference of nearly 76% in Q3 2024 (106). 

Figure 22: Data services: development of the average wholesale roaming rate for data in the 
EEA, Q4 2016 to Q3 2024 

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Source: Data collected for the 19th – 31st International Roaming BEREC Benchmark Reports. 
JRC calculations 

The average EEA wholesale roaming price for voice services shows a decreasing  trend 
(Figure 23). The average wholesale roaming price for outgoing voice traffic fell from 2.02 
EUR cents/min in Q1 2019 to 1.34 EUR cents/min in Q1 2024, representing a decrease of 
34%. Wholesale prices for net outbound (unbalanced) roaming traffic—which refers to the 
portion of roaming traffic generating net payments from one operator to another—are even 
lower, showing a decrease of 27% (from 1.77 EUR cents/min in Q1 2019 to 1.29 EUR 
cents/min in Q3 2024).  

Similarly to the data services, throughout the observed period, the actual applied wholesale 
roaming prices were approximately 50% lower than the regulated wholesale voice roaming 
cap imposed by the Roaming Regulation. Furthermore, the decline in applied wholesale 
prices corresponds to the decrease in wholesale caps from Q2 2022, with actual applied 
prices remaining around 50% lower than the wholesale caps in Q3 2024 (107). 

(106)  In 2024 the wholesale roaming data cap was 1.55 EUR/GB and the average price charged in Q3 2024 

was 0.68 EUR/GB. 

(107)  In 2024 the wholesale roaming voice cap was 2.2 EURcent/min and the average price charged in Q3 

2024 was 1.29 EURcent/min. 

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Figure 23: Voice services: development of the average wholesale roaming rate for voice in the 
EEA, Q4 2016 to Q3 2024 

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Source: Data collected for the 19th – 31st International Roaming BEREC Benchmark Reports. 
JRC calculations 

For wholesale SMS roaming services (Figure 24), total costs dropped significantly during 
the initial years of RLAH. Between 2017 and 2021, the actual prices paid for wholesale 
SMS  roaming decreased by 75% (from 0.76  EUR cents/SMS in  Q4 2016 to  0.19 EUR 
cents/SMS in Q4 2021). Prices continued to decline, reaching 0.12 EUR cents/SMS in Q3 
2024, with the difference between the actual prices applied and the regulated wholesale 
roaming cap remaining around 85%. 

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Figure 24: SMS services: development of the average wholesale roaming rate for SMS in the 
EEA, Q4 2016 to Q3 2024 

Source: Data collected for the 19th – 30th International Roaming BEREC Benchmark Reports. 
JRC calculations 

The decline in wholesale roaming prices is observed in all Member States (Figure 25 and 
Figure 26), showing the last quarter before RLAH, Q2 2017, and the last quarter available, 
Q3  2024).  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. 

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Figure 25: Voice services: average wholesale roaming rate for voice in the Member States, Q2 
2017, Q1 2019 and Q1 2024 

Q2'17

Q1'19

Q1'24

EU average Q1'19

EU average Q1'24

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

Source: Data collected for the 19th – 31st International Roaming BEREC Benchmark Reports. 
JRC calculations 

Figure 26: Data services: average wholesale roaming rate for data in the Member States, Q2 
2017, Q1 2019 and Q1 2024 

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Source: Data collected for the 19th – 31st International Roaming BEREC Benchmark Reports. 
JRC calculations 

The decreasing  wholesale roaming prices  have had  considerably  positive impact  on the 
market  dynamics.  Firstly,  lower  wholesale  roaming  prices  have  greatly  mitigated  any 
potential  impact  from  the  introduction  of  RLAH  on  outbounder  operators  (See  Section 
7.1), as they have contributed to reduce their wholesale roaming payments and therefore 
increased sustainability of RLAH. Secondly, such reductions, together with the fact that 
average  wholesale  market  prices  have  been  below  the  regulated  maximum  wholesale 
tariffs, confirm that net inbounder operators have been able to meet the increasing demand 
in roaming services, while at the same time recover 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. These market dynamics are going in the positive 
direction and the Commission will continue to monitor their developments also in view of 
the evolving and changing telecommunications landscape. 

7.2.2.  Situation of MVNOs 

An MVNO, operates without owning a radio access network in the country or countries 
where it provides services. Consequently, an MVNO cannot accommodate roaming traffic 
from foreign MNOs in exchange for the roaming traffic it sends to those MNOs. Instead, 
MVNOs must purchase outbound roaming traffic generated by their customers abroad at 
wholesale rates, without the ability to trade or exchange this traffic for inbound roaming 
traffic. 

This  structural  difference  places  MVNOs  in  a  distinct  position  from  MNOs  when 
negotiating wholesale roaming access, as noted by BEREC in its Opinion as well as its 
previous opinions (2019 and 2021). These challenges contribute to MVNOs' difficulty in 
competing with MNOs. The primary reason lies in their reliance on MNOs for network 
access, both domestically and internationally. Additionally, due to their typically smaller 
size, MVNOs often lack significant purchasing power and do not have access to significant 
volume-based discounts. 

Compared  to  MNOs,  MVNOs  have  weaker  negotiating  power  to  conclude  bilateral 
wholesale  agreements  with  MNOs.  Hence,  many  MVNOs  are  constrained  to  paying 
wholesale prices at regulated caps. In BEREC's recent call for input to NRAs in September 
and October 2024, concerns were raised by MVNOs regarding the current operation of the 
wholesale market, particularly in anticipation of future trends. They point out that MVNOs, 
as buyers without reciprocal arrangements, frequently face charges close to the regulated 
price caps. 

While the Commission acknowledges these trends, the available data is not sufficient to 
bring full understanding of the issue. The annual BEREC benchmark data collection lacks 
sufficient data as less than 25% of MVNOs report information on the lowest and highest 

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prices paid, with only approximately 1% reporting data on the lowest and highest prices 
charged. 

8.  QUALITY OF SERVICE (QOS) 

RLAH means that roaming customers should be able to use their mobile services on the 
same conditions  also  when roaming in  the EU/EEA  without additional charges,  i.e. the 
same service abroad for the same price. QoS (108) is an integral part of the product whose 
price is regulated. The CIR, in its Article 3 (2), lays down that any fair use policy applied 
by  a  roaming  provider  shall  ensure  that  all  such  roaming  customers  have  access  to 
regulated  retail  roaming  services  at  domestic  price  during  periodic  travel  in  the  Union 
under the same conditions as if such services were consumed domestically.  

In the Impact Assessment (109) to the Roaming Regulation, the Commission demonstrated 
the need to introduce rules to ensure that operators can provide roaming services with the 
same QoS and that their wholesale roaming access is not limited by the access givers. It 
would  further  enable  home  operators  to  access  the  same  network  generations  that  they 
offer domestically and hereby tackle also the issue of some M(V)NOs only being granted 
access to 3G services (110). This new measure was supported by BEREC (111).  

The Roaming Regulation lays down QoS obligations at both retail and wholesale levels. 
At retail level, roaming providers have to ensure that roaming customers at least have the 
same  quality  of  their  roaming  service  as  they  normally  have  at  home,  when  this  is 
technically feasible. At wholesale level, visited operators have to ensure that all reasonable 
wholesale access requests are met and that a wholesale access seeker is given access to all 
technologies and networks in order to be able to provide the QoS level that they normally 
provide  their  customers  at  home.  The  wholesale  level  obligation  ensures  that  visited 
operators  do  not  limit  wholesale  access  to  certain  networks  or  technologies.  With  the 
increasing 5G coverage and deployment, it is expected that the current discrepancies in 
QoS  between  domestic  and  roaming  services  will  disappear.  The  Roaming  Regulation 
foresees a level of flexibility for roaming services to catch up with gradual technological 
developments.  

(108) 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. 

(109) SWD(2021) 28, Commission Staff Working Document Accompanying the Proposal for a Regulation of 
the European Parliament and of the Council on roaming on public mobile telecommunications networks 
within the Union (recast), 24.02.2021. 

(110) SWD(2021) 28, Commission Staff Working Document Accompanying the Proposal for a Regulation of 
the European Parliament and of the Council on roaming on public mobile telecommunications networks 
within the Union (recast), 24.02.2021, p. 39. 

(111) BEREC Opinion on the proposal of the Commission for amending the Roaming Regulation BoR (21) 

59, p. 2.  

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8.1.  QoS Study  

The QoS that the roaming users enjoy compared to their home network performance and 
the visited network’s domestic performance was  assessed and evaluated via a dedicated 
study, which involved specific QoS measurements (including download (DL) and upload 
(UL) speeds, latency, user experience, etc.) across several Member States and using SIM 
cards from different mobile operators. The study covered 20 countries (112). The results 
showed  that  the  roaming  regulation  does  not  have  yet  the  desired  effect,  as  far  as  the 
specific requirements for QoS are concerned.  

It is important to emphasize that this is the first study of its kind on QoS within the context 
of the RLAH regime. All the findings presented below should be carefully evaluated and 
will be closely monitored by the Commission. 

Table 8: Roaming performance according to Download (DL) and Upload (UL) speeds KPI  

DL speed  

UL speed  

Comparison with the home network 

Roaming performance worse 

Roaming performance better 

Roaming performance at the same level 

76% 

7% 

17% 

Comparison with the visited network 

Roaming performance worse 

Roaming performance better 

Roaming performance at the same level 

80% 

6% 

14% 

Source: QoS Study conducted by the Commission (113) 

63% 

7% 

30% 

68% 

8% 

24% 

When it comes to download (DL) speed, in more than 3 out of 4 cases (76%) of the tests 
performed showed that the roaming end-users do not enjoy the same performance as they 
do on their home network. The same behaviour was exhibited when comparing the roaming 
end-user  DL  speed  to  the  DL  speed  experienced  by  the  visited  network’s  end-users: 
performance was poorer in 80% of the test cases. The opposite results, i.e., roaming end-
users outperforming in terms of DL speed their home network, or the visited network were 
apparently significantly less: 7% for the former and only 6% for the latter. In the rest of 
the cases, DL speed for the roamer was at the same level (within a range of ± 10%) with 
the home (17%) or the visited network (14%).  

The same trend – with a slight improvement for end users – was also exhibited when testing 
the upload (UL) speed: in 63% of the tests, the roaming user’s upload speed was lower 

(112) France,  Luxembourg,  Belgium,  Netherland,  Germany,  Sweden,  Finland,  Latvia,  Poland,  Czech 

Republic, Austria, Slovakia, Hungary, Croatia, Romania, Bulgaria, Greece, Italy, Spain and Portugal. 

(113) Not published yet. Reference number: EC-CNECT/2024/OP-0084. 

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than the home network upload speed, in 7% better and in 30% at the same level. Compared 
to the visited network, the performance was worse in 68% of the cases, better in 8% and at 
the same level 24%. 

In the vast majority of the cases where roaming performance was poorer than the home, it 
was also poorer than the visited network (84% for DL speed, 78% for UL speed and 91% 
for latency). This is the worst scenario for an end user, where the roaming performance is 
poorer  than  the  home  network,  even  though  the  visited  network  could  offer  better 
performance.  

With  minor  exceptions,  latency  also  exhibits  a  degradation  (i.e.,  it  increases)  while 
roaming (92% of the test cases compared to the home network and 90% compared to the 
visited network). The same behaviour stands also true for internet browsing. However, it 
should be noted that the increased latency values for roaming end users can at least partially 
be attributed to the home routing configuration, where all data traffic is routed back to the 
end users home network before being delivered at the handset.  

The availability of the 5G network to roaming end users was at a “good” but not “perfect” 
level: in over 70% of the test instances roamers were registered in 5G networks.  

Finally, data from tests performed show that handover between mobile networks across 
borders remains inconsistent, with some regions experiencing significant delays in network 
reconnection, exceeding 10 minutes to re-establish service. 

8.2.  Consumer perspective  

The most recent BEREC BMK data shows that access seekers still encounter issues with 
gaining wholesale roaming access to all technologies. Similar problems were reported by 
some stakeholders, in particular MVNOs, also during the previous review of the Roaming 
Regulation. The improved wholesale roaming access rules should help to facilitate such 
problems. Further monitoring will be necessary to assess the full effects of the new rules. 
At wholesale level 20% of access seekers have experienced problems with gaining access 
to 5G technologies and 14% have encountered problems when it comes to 4G technologies. 
10% have encountered implementation problems with 5G and 30% with 5G standalone.  

At retail level 72% of respondents confirm that they offer 5G technologies to their roaming 
customers, while 20% offer 5G standalone. The corresponding number is 100% for 4G 
roaming.  

In the 2023 Review Report (114), the Commission presents detailed findings on QoS from 
the  consumer  perspective.  According  to  the  findings  of  the  Eurobarometer  survey 
approximately  one  in  four  consumers  have  experienced  lower  quality  of  their  roaming 
service than what they usually have at home, such as lower speed and different network 
generation. The more recent Eurobarometer 560 shows that 34% of the respondents who 
had  travelled  in  the  past  two  years  (11%  of  total  respondents  to  Eurobarometer)  have 
experienced lower mobile internet speed compared to what they usually have domestically. 

(114) SWD(2024) 8, Commission Staff Working document on the findings of the 2023 periodic 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.  

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32%  of  the  respondents  have  experienced  a  lower  broadband  standard  compared  to 
domestically.  

The Roaming Regulation lays down detailed rules on transparency measures to ensure that 
end users are informed about their roaming services and can make informed choices about 
their  roaming  usage.  Roaming  providers  have  to  give  their  customers  clear  and 
comprehensible information on the conditions and the quality of the roaming service when 
roaming. In addition, roaming providers shall publish information about the reasons why 
the roaming service is potentially offered under conditions that are less advantageous than 
those offered domestically. That information shall include factors that can have an impact 
on the quality of the roaming service to which the roaming customer subscribes, such as 
network  generations  and  technologies  available  to  the  roaming  customer  in  a  visited 
Member  State.  The  latest  BEREC  BMK  data  shows  that  53%  operators  inform  their 
customers  about  the  difference  between  the  network  technologies  and  generations 
available when roaming. Even less, only 45% of the operators provide their customers with 
information about QoS while roaming.  

These  findings  show  that  roaming  customers  are  not  adequately  informed  about  their 
service  when  roaming.  The  implementation  of  these  obligations  requires  further 
monitoring  and  supervisions  by  the  NRAs.  This  is  particularly  important  taking  into 
account  the  identified  issues  with  regard  to  considerably  lower  levels  of  QoS  when 
roaming than compared to domestic QoS, as described in section 8.1.  

8.3.  BEREC Opinion 

BEREC  anticipates  that  as  2G  and  3G  technologies  are  phased  out  and  5G  adoption 
becomes more widespread the number of subscribers able to access 5G while roaming will 
increase.  Simultaneously,  the  proportion  of  domestic  tariffs  without  5G  services  is 
expected  to  decline.  5G  Standalone  (SA)  is  expected  to  be  the  next  evolutionary  step, 
gradually becoming available on networks that have fully implemented this technology 
and for users with subscriptions that allow domestic access to a 5G SA network. 

BEREC  considers  that  the  QoS  obligation  set  out  in  Article  4  of  the  Regulation  is  a 
fundamental  component  of  the  RLAH  regime,  constituting  an  essential  element  in 
empowering end-users and fostering the development of the internal telecommunications 
market.  Consequently,  BEREC  supports  maintaining  the  current  obligations  without 
amendments. Because NRAs have received next to no consumer complaints on roaming 
QoS, BEREC considers that the rules are effective. However, the Commission QoS study 
indicates that there are in fact identified issues. Consumers may be less inclined to take 
action in case of QoS variations, or they may be less sensitive to such variations as long as 
they can still access and use their services even when the overall QoS is not as good as 
domestically. Nevertheless, it is necessary to explore the underlying reasons for the lower 
roaming  QoS.  BEREC  also  notes  that  there  are  not  any  end-user  complaints  regarding 
systematic or unreasonable delays in handover between networks at internal Union border 
crossings. Finally, QoS does not seem to be a problematic issue at the moment for M2M 
services, but it is envisaged that demands for QoS requirements will increase in the future. 

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8.4.  Conclusion on QoS  

The assessment of the roaming performance and the implementation of the QoS obligations 
clearly show that there is room for improvement towards the goal of achieving similar QoS 
performance  for the roaming users, as they enjoy in  their home networks.  However, in 
most cases, the latest available technology (5G) is available in the visited networks and 
most of the consumers have not complained about experiencing lower QoS while roaming. 
In  addition,  BEREC  supports  maintaining  the  current  QoS  obligations  without 
amendments.  

The available data and the Study on QoS roaming do not offer insights into the reasons for 
the lower QoS when roaming. Better understanding the results of the Study would require 
further  monitoring  and  assessment.  Moreover,  the  available  data  shows  that  roaming 
customers are not adequately informed about the QoS when roaming. It would therefore 
be  recommended  to  closely  monitor  the  compliance  of  the  operators  with  the  QoS 
obligations  at  national level, i.e., by the NRA, to  identify whether  there is  a  systematic 
degradation  of  the  QoS  that  roamers  enjoy,  and  if  yes,  to  identify  the  exact  limitation 
(technical or commercial). 

9.  TECHNOLOGICAL DEVELOPMENTS  

9.1.  5G deployment in the EU/EEA area and its impact on roaming QoS 

5G coverage in the EU has reached 94.35% and roll out is still ongoing. High quality 5G 
coverage extends to 67.72% of the EU territory (based on main pioneer bands), with the 
large majority of the deployment of 5G not being standalone. (115)  

The  Roaming  QoS  obligations  aim  to  ensure  that  access  seekers  can  provide  their 
customers with relevant QoS levels of roaming services, subject to technical availability. 
As  explained  in  Section  8  (QoS  section),  the  Roaming  Regulation  ensures  gradual 
implementation of the QoS obligations in view of the gradual technological developments 
such  as  ongoing  5G  roll  out.  Specifically  for  roaming,  5G  network  slicing  could  give 
MNOs and MVNOs the possibility to extend the reach of their networks in other countries 
and offer their subscribers mobile connectivity services while they are travelling abroad, 
with no roaming costs and – in the case that the service is provided by their home operator 
– without the need to change the number they could be reached at. The administrator of 
the 5G-slice may offer services with improved QoS and experience due to their level of 
freedom in configuring the network parameters. Services can be customized to meet the 
exact  needs  of  the  subscribers,  while  careful  planning  minimises  the  risk  of  network 
congestion or unavailability. The operators could even offer a seamless environment, no 
matter if their subscribers are in their home country or if they are currently roaming. In 
addition, network slicing offers increased security as user traffic is isolated from the rest 
of the visited network.  

5G network slicing can also be a fit-for-purpose solution for IoT services, since it allows 
full  flexibility  for  the  creation  of  a  dedicated  environment  with  configurable 

(115) Report on the State of the Digital Decade 2025, European Union, 2025. 

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characteristics. Therefore, the slice may address the needs of different types of subscribers, 
human or M2M/IoT, offering that way enhanced customer experience. On the other hand, 
this solution requires extensive collaboration between operators, providers of equipment 
and  hardware  and  other  stakeholders  that  will  finally  enable  the  use  of  5G  slicing  in 
roaming. Apart from  this, during the implementation phase, a  great  number of bilateral 
agreements will have to take place in order to allow 5G slicing to be used to a large extent. 
To this day, 5G network slicing solutions have not been adopted massively in the market, 
neither are there any indications that these are expected to be used in the near to mid-term 
future.  While  5G  network  slicing  could  have  an  impact  on  regulated  roaming,  this 
technology  has  not  been  widely  adopted  yet.  In  this  context,  it  does  not  exert  any 
competitive  constraint  or  behave  as  a  constraint  on  regulated  roaming.  Therefore,  5G 
network slicing has not contributed to any change in the regulated roaming landscape. 

BEREC also recognizes in its Opinion (116) that 5G network slicing is in an incipient state 
and  there  are  currently  very  few  –if  any-  roaming  agreements  in  place.  Both  technical 
interfaces and the integration of roaming value-added services delivered by third parties 
need  further  harmonisation,  while  to  take  full  advantage  of  slicing,  demanding 
configuration  at  both  5G  core  and  5G  radio  network  has  to  be  implemented,  while 
implementation  should  be  widespread  in  most  European  networks.  Under  this  light, 
BEREC concludes that it is still premature to take slicing into account in the next Roaming 
Regulation review. 

9.2.  The evolution of the M2M/IoT roaming market 

Both recital (21) of the Roaming Regulation and recital (249) of the EECC, define machine 
to machine (M2M)  as services involving an automated transfer of data and information 
between  devices  or  software-based  applications  with  limited  or  no  human  interaction. 
From a technical perspective, Internet of Things (IoT) and M2M are not the same. Recital 
(12) of the EECC also implies this. Generally, M2M may be regarded as a subset of IoT. 
However, recital (68) of the Roaming Regulation puts IoT and M2M on equal footing, due 
to their similar role as important drivers for digitising the EU’s industry and builders of 
EU’s  policies  in  sectors  such  as  health,  energy,  environment,  and  transport.  Therefore, 
across this section, M2M and IoT will be used with the same broad understanding. 

Roaming, a facility offered by cellular-based technologies only, is not the sole connectivity 
solution  for  M2M/IoT  devices.  Recital  (68)  of  the  Roaming  Regulation  calls  upon  the 
Commission to “regularly assess the role of roaming in the market for machine-to-machine 
connectivity and in the IoT market” while BEREC should “collect the necessary data to 
allow the monitoring of the elements to be assessed in the Commission’s reports on the 
development  of  machine-to-machine  roaming  and  IoT  devices  provided  for  in  this 
Regulation,  taking  into  account  cellular  connectivity  solutions  based  on  unlicensed 
spectrum”.  

(116) BoR(25)48. 

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There are various technologies able to provide connectivity for M2M/IoT devices, which 
may  be  divided  into  short-range (117)  and  wide-area (118).  These  technologies  compete 
against each other to a higher or lesser degree, depending on the specific connectivity needs 
of the M2M/IoT use cases. Highly elaborated M2M/IoT use cases require the constant use 
of  more  than  one  connectivity  technology (119).  By  2028,  the  connectivity  market  in 
Europe (120)  for  M2M/IoT  is  likely  to  drop  from  its  2025  peak,  at  which  time  it  will 
represent only 8% of the total M2M/IoT value chain revenues. This indicates an intense 
price  competition  in  the  M2M/IoT  connectivity  market  to  which  cellular  technologies 
supporting roaming are also largely exposed (121). Only a limited number of M2M/IoT use 
cases  are,  in  fact,  highly  reliant  on  cellular  technologies  supporting  roaming  (e.g., 
automotive,  some  niche  health  applications,  under  certain  circumstances,  some  energy 
sector applications, etc.) (122) while, in many instances, the M2M/IoT customers may exert 
a countervailing buying power.  

Against this background, any potential regulatory intervention on the roaming market for 
M2M/IoT should consider the wider connectivity environment for M2M/IoT, in order to 
maintain, as much as possible, the same level playing field between the various providers 
of connectivity solutions for M2M /IoT use cases. This section is divided into three main 
parts, as follows: (i) an overview of the roaming connectivity market for M2M/IoT (i.e., 
9.2.1.,  below),  (ii)  a  summary  of  the  current  regulatory  framework  of  roaming  for 
M2M/IoT  (i.e.,  9.2.2.,  below),  and  (iii)  a  brief  assessment  of  the  permanent  roaming 
(non)regulation for M2M/IoT (i.e., 9.2.3., below). 

9.2.1.  The roaming connectivity market for M2M/IoT 

The basic functionality that roaming may offer to M2M/IoT use cases is the provision of 
cross border connectivity. Usually, short range technologies are not able to provide cross 
border connectivity. On the other hand, all wide-area technologies can provide cross border 
connectivity either on the basis of roaming agreements (2/3/4/5G networks, LPWAN-LTE, 
LPWAN-NB-IoT),  extension  of  a  global  network  (LPWAN-Sigfox),  complex  network 
server  configurations  (LPWAN-LoRaWAN),  or  due  to  their  in-built  nature  (satellite 
technologies).  

Therefore,  if  basic  cross-border  connectivity  is  the  main  requirement  of  a  specific 
M2M/IoT  use  case,  then  all  wide-area  technologies,  including  those  based  on 

(117) Short-range largely consists of unlicensed radio technologies, with a typical range of up to 100 meters, 
and include Wi-Fi, Mesh protocols, Bluetooth and Bluetooth Low-Energy (‘BLE’) and Radio Frequency 
Identification (‘RFID’). More details are available on Axon-ICF-Carsa study, pages 51 and 203 to 206. 
(118)  Wide-area comprises licensed cellular networks (2/3/4/5G), licensed or unlicensed low-power wide area 
network  technologies (‘LPWAN’), with a  typical range of more than 100 meters, as well as  satellite 
connectivity technologies. More details are available on Axon-ICF-Carsa study, pages 52 and 207 to 
209. 

(119)  One  example  is  that  of  connected  cars  requiring,  at  the  same  time,  both  short-range  and  wide-area 

connectivity solutions. More details are available on Axon-ICF-Carsa study, pages 63 and 64. 

(120)  In  this  context  Europe  covers  the  EU  Member  States  (except  for  Cyprus  and  Malta),  Iceland, 

Montenegro, Norway, Russia, Serbia, Switzerland, Turkey, Ukraine, and the United Kingdom. 

(121) More details are available on Axon-ICF-Carsa study, pages 44 and 45. 
(122)  More details are available on Axon-ICF-Carsa study, pages 56 and 63. 

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unlicensed  spectrum  (e.g.,  LPWAN-Sigfox,  LPWAN-LoRaWAN),  compete  against 
each other. However, other additional requirements (e.g., reliability, throughput, coverage, 
power consumption, etc.) may render cellular technologies using licensed spectrum at least 
a technical competitive advantage over the other wide-area technologies, emphasising thus 
the roaming factor’s role.  

The  Axon-ICF-Carsa  study  assessed (123)  these  complex  interactions  for  four  key 
M2M/IoT  verticals,  namely  for  mobility,  health,  energy,  and  agriculture.  The  mobility 
sector  has  the  strongest  need  for  cross-border  connectivity,  usually  linked  with  high 
throughputs. For the mobility sector cellular technologies are crucial and cannot be easily 
replaced  by  other  alternatives.  M2M/IoT  applications  in  the  health  sector  also  rely  on 
cellular  technologies,  for  convenience  and  reliability  reasons,  with  cross-border 
connectivity an important requirement. As regards the energy sector the situation is more 
nuanced due to its more localised needs, sometimes in remote areas. For the energy sector, 
LPWAN and satellite may offer suitable alternatives to cellular technologies, although the 
latter  may  have  a  head  in  case  of  specific  M2M/IoT  applications  requiring  higher  data 
throughputs.  Finally,  for  the  agriculture  sector  the  cross-border  connectivity  is  not  a 
standard requirement. In this case, LPWAN is the most convenient technology due to its 
possibility of covering large distances and low power consumption, while in more remote 
areas may be complemented by satellite technologies. 

BEREC data (124) shows that the number of connected objects to cellular networks in the 
EU/EEA has constantly surpassed the 100 million-threshold since the last quarter of 2021. 
Of  these  the  vast  majority  (i.e.  around  90%)  are  roaming-enabled,  meaning  capable  of 
staying connected if ever passing the national border. A significant (around 30%) and ever-
increasing  number  of  roaming-enabled  objects  are  effectively  roaming  in  the  EU/EEA, 
while a notable share (i.e., most likely around 5%) are used in permanent roaming in the 
EU/EEA. On average, connected objects use more domestic data than in roaming in the 
EU/EEA (i.e. 0.81GB/month/connected object vs. 0.12 GB/month/connected object, in the 
latest  quarter  for  which  data  is  available).  The  same  is  true  for  calls  and  SMS  usage, 
although these services are less relevant for M2M/IoT scenarios. 

In  its  input,  BEREC  underlined  the  increasing  number  of  wholesale  roaming  access 
agreements for M2M/IoT, including those allowing permanent roaming for M2M/IoT (125).  

9.2.2.  The currently applicable regulatory framework to roaming for M2M/IoT 

The  Roaming  Regulation  does  not  exclude  roaming  for  M2M/IoT  from  its  application 
scope  (126).  Therefore,  equal  to  the  case  of  roaming  for  interpersonal  communications, 
roaming  access  providers  must,  for  instance,  meet  all  reasonable  access  requests  for 
wholesale roaming for  M2M/IoT use cases (127), while being  able to  impose conditions 
preventing  the  misuse  of  such  wholesale  roaming  access  services,  including  against 

(123) Axon-ICF-Carsa study, pages 61 to 63. 
(124) BoR (24) 165, BEREC Report on M2M and permanent roaming, Figures 3-6, pages 8 to 10, and 30th 

BEREC BMK. 

(125) BoR (25) 48, BEREC input on EC’s request for expert views on Regulation (EU) 2022/612 on roaming 

on public mobile communications networks within the Union, page 60.  

(126) Recital (21) of the Roaming Regulation.  
(127) Article 3(1) of the Roaming Regulation.  

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permanent  roaming(128).  Likewise,  on  the  retail  side,  providers  of  roaming  services  for 
M2M/IoT use cases must, for instance, observe the prohibition of levying any surcharge 
in addition to the domestic retail prices for roaming services provided to their end users in 
any other Member State(129), while being able to apply to their end users a roaming fair 
use policy(130). However, on the retail side, providers of roaming services for M2M/IoT 
use are expressly exempted(131) from the following obligations in relation to their end users 
of data services: (i) the automatic sending of messages containing basic personalised tariff 
information  every  time  end  users  enter  another  EU  Member  State(132),  and  (ii)  the 
application of the financial or volume limit facility to avoid end users suffering so called 
bill shocks(133). 

Without prejudice to the above-mentioned, permanent roaming for M2M/IoT is subject to 
commercial  negotiations  and  can  be  agreed  by  two  roaming  partners  in  a  wholesale 
roaming  agreement(134).  The  Roaming  Regulation  lays  the  ground  for  mobile  network 
operators  to  increasingly  respond  to  and  accept  all  reasonable  requests  for  wholesale 
roaming  agreements  on  reasonable  terms  and  explicitly  allow  permanent  roaming  for 
M2M/IoT(135). In the current sophisticated economic environment characterised by global 
supply chains spanning several countries or continents, permanent roaming may become 
increasingly important for several M2M/IoT use cases(136).  

Building  on  the  importance  of  cellular  technologies’  connectivity  for  M2M/IoT  for  the 
four critical verticals (i.e., mobility, health, energy, and agriculture, etc.), as mentioned in 
9.2.1., above, the Axon-ICF-Carsa study mapped the high and low relevance of permanent 
roaming for M2M/IoT use cases, as shown in the below table. (137)   

(128) Article 3(6) second subparagraph of the Roaming Regulation. 
(129) Article 4(1) of the Roaming Regulation. 
(130) Article 5 of the Roaming Regulation.  
(131) According to Article 14(5) of the Roaming Regulation.  
(132) Obligation set in Article 14(2) of the Roaming Regulation.  
(133) Obligation set in Article 14(4) of the Roaming Regulation.  
(134) Recital (21) of the Roaming Regulation.  
(135) Recital (21) of the Roaming Regulation. 
(136) BoR (24) 165, BEREC Report, on M2M and permanent roaming page 5. 
(137)  As  mentioned  in  the  Axon-ICF-Carsa  study,  the  relevance  of  permanent  roaming  is  not  necessarily 
limited  to  the  mentioned  M2M/IoT  use  cases  and  not  equal  to  all  undertakings  using  M2M/IoT 
applications. For instance, an aggressive business strategy for expansion beyond national borders may 
lead to a need of permanent roaming even in areas where this factor is of relatively low relevance. On 
the other hand, alternative connectivity solutions may diminish the relative dependence on roaming for 
certain undertakings or for specific M2M/IoT use cases.    

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Table 9: The relevance degree of permanent roaming for M2M/IoT use cases 

Relevance Degree 
High 

Low/No relevance 

Permanent roaming use cases 

Transport, asset and fleet tracking; (some) connected vehicles; other  
mobility use-cases, logistics; niche health applications 
Smart metering, smart lighting, smart homes; facility management, most  
environmental or animal monitoring; typical health and energy use cases; 
most agricultural use cases; most industrial use cases 

Source: The Axon-ICF-Carsa study, page 136 

Finally, as regards the M2M/IoT use cases, roaming partners may agree to apply alternative 
tariff schemes, for instance based on the number of connected devices per month, instead 
of the consumed data volumes(138).  

9.2.3.  Assessment of the permanent roaming (non)regulation for M2M/IoT  

In its input, BEREC invited the Commission to further study the M2M/IoT market and 
potential  regulatory  measures  in  order  to  prevent  competitive  imbalance  between  large 
groups and smaller operators across the EEA(139). The main area of interest for potential 
competitive  imbalances  is  the  permanent  roaming  for  M2M/IoT.  As  mentioned  before, 
according  to  the  Roaming  Regulation,  permanent  roaming  for  M2M/IoT  is  subject  to 
commercial  negotiations  between  roaming  partners.  In  case  of  proven  competitive 
constraints, a regulation of permanent roaming for M2M/IoT may be envisaged.  

Directive  (EU)  2018/1972  provides  the  basic  principle  of  regulatory  intervention  for 
electronic communications markets, according to which any regulation at wholesale level 
must be underpinned by competitive problems identified at the retail level(140). In this case, 
there may be two indicators for potential competitive problems at the retail level: (i) a lack 
of  availability  for  permanent  roaming  connectivity,  and  (ii)  high  prices  for  permanent 
roaming connectivity. The retail level mainly consists of M2M/IoT end users, as well as 
M2M/IoT application and platform providers, and to a lesser extent M2M/IoT hardware 
manufacturers. 

The exchanges carried out in the context of the Axon-ICF-Carsa study (i.e., interviews of, 
workshops with, and written feedback from the whole M2M/IoT value chain stakeholders) 
revealed no major concerns from the retail side of the market related to the availability for 
permanent roaming connectivity in the EU/EEA(141) or to its price level. The M2M/IoT 
industry expressed relaxed views about permanent roaming connectivity in the EU/EEA, 
due  to  its  relatively  easy  access  to  a  wide  range  of  alternative  technologies  to  avoid 
dependence on (permanent) roaming for its cross-border needs(142). In this respect, the IoT 

(138) Recital (21) of the Roaming Regulation. 
(139) BoR (25) 48, BEREC input on EC’s request for expert views on Regulation (EU) 2022/612 on roaming 

on public mobile communications networks within the Union, page 62. 

(140) Recital (29) of the Directive (EU) 2018/1972.  
(141) Axon-ICF-Carsa study, page 135. 
(142) Axon-ICF-Carsa study, pages 135 to 139. 

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industry  often  quoted  eSIM  cards (143),  LoRaWAN  technology,  LEO-based  satellite 
connectivity(144)  or  the  implementation  of  edge  technologies(145)  as  viable  solutions  to 
limit the dependence on (permanent) roaming, if not avoiding it alltogether. 

Based on IoT industry’s feedback and other assessed general statistical trends, the Axon-
ICF-Carsa study concludes that alternative technologies to cellular offer credible technical 
and commercial substitutes for many, and perhaps the majority, of IoT cross-border use 
cases.  While  cellular  roaming  may  remain  the  default  technical  option  for  specific 
M2M/IoT use cases, the clear competitive constraints exercised by alternative technologies 
should  also  reduce  the  roaming  connectivity  providers’  market  power.  In  fact,  the 
M2M/IoT use cases with limited alternative options to cellular technologies, and therefore 
potentially  exposed  to  retail  competitive  problems  as  regards  the  (permanent)  roaming 
connectivity, remain those with high bandwidth, and low latency and jitter requirements, 
such  as  certain  automated  mobility  applications  or  niche  cross-border  health 
applications(146).  

Moreover, the retail side of the M2M/IoT (permanent) roaming connectivity market may 
exert a real countervailing buyer’s power. In general, this limits the ability of providers of 
(permanent) roaming connectivity for M2M/IoT use cases, both MNOs and MVNOs, to 
raise their retail prices. 

As  regards  the  wholesale  side  of  the  market  (i.e.,  the  relationships  between  access 
providers and access seekers of permanent roaming connectivity for M2M/IoT use cases), 
according  to  BEREC  data,  the  EEA  average  price  for  wholesale  inbound  permanent 
roaming  (EUR  per  GB)  has  constantly  been  well  below  the  EU  regulated  wholesale 
roaming cap per GB, as shown in the below figure. 

(143) eSIM cards are embedded (pre-installed) into the hardware of a mobile device, by contrast to legacy, 
removable  SIM  cards.  eSIM  cards  offer  remote  provisioning  and  profile  management.  Moreover,  eSIM 
technology  can  support  multiple  profiles  on  a  single  device.  This  facilitates  the  switch  between  service 
providers  or  networks.  In  addition,  this  allows  IoT  users  to  optimize  their  connectivity  by  selecting 
dynamically,  based  on  their  location  and  usage,  the  most  cost-effective  network  and  service.  eSIM 
technology is suitable especially for the automotive industry, a sector for which permanent roaming is highly 
relevant. Source: Axon-ICF-Carsa study, page 137. 
(144)  Stakeholders  considered  LEO-based  satellite  connectivity  an  alternative  even  for  transportation  and 
logistics sectors which normally are heavily reliant on cellular connectivity, and therefore on (permanent) 
roaming. Source: the Axon-ICF-Carsa study, page 138. 
(145)  The  implementation  of  edge  technologies  means  moving  more  computation  power/resources  on  the 
edge, instead of loading massive amounts of data in a central command unit in the cloud. This is done mainly 
to speed up response time and to increase the level of security for M2M/IoT devices. The side effect of these 
techniques is to decrease data consumption, including in roaming. Source: the Axon-ICF-Carsa study, pages 
138-139. 
(146) Axon-ICF-Carsa study, pages 139 and 140. 

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Figure  27:  Average  wholesale  permanent  roaming  charges  for  data  services  against  EU 
regulated caps 

Average wholesale permanent roaming charges for data services 
against EU regulated caps

3

2,5

2,5

2

2

1,8

1,8

0,41

0,4

0,4

0,4

0,68

0,66

0,72

1,8

0,7

Q4 2021

Q1 2022

Q2 2022

Q3 2022

Q4 2022

Q1 2023

Q2 2023

Q3 2023

EEA average price for wholesale inbound permanent roaming (EUR/GB)

EU regulated cap (EUR/GB)

Source: 30th BEREC BMK 

This is likely to indicate a rather competitive wholesale market for M2M/IoT permanent 
roaming connectivity. There are both direct and indirect competitive constraints exerted 
against the wholesale charges for M2M/IoT permanent roaming connectivity. The fact that 
each  EU/EEA  country  has  at  least  three  MNOs  able  to  provide  (permanent)  roaming 
connectivity, including for M2M/IoT use cases, represents a direct competitive constraint, 
albeit this may vary according to the level of competition intensity between the existing 
MNOs  in  a  certain  EU/EEA  country.  Indirect  competitive  constraints  are  exerted  by 
wholesale access charges to alternative technologies, and even by wholesale access charges 
to periodic roaming connectivity since the latter are regulated. 

However, this general picture may obscure the difficulties access seekers, and especially 
MVNOs, could face when negotiating permanent roaming agreements with some MNOs. 
The Axon-ICF-Carsa study identified(147) a list of practices employed by MNOs to exploit 
their strong market position in relation to access seekers, as follows: (i) the imposition of 
exclusive  roaming  access  agreements,  (ii)  the  imposition  of  hard-to-achieve  minimum 
purchasing service volumes, as a condition for concluding permanent roaming agreements, 
or other unfavourable wholesale pricing conditions, (iii) restricting access seekers in their 
choice  of  technical  alternatives  (if  they  roam  through  a  mix  of  complementary 
technologies), and (iv) outright refusal to even negotiate a permanent roaming agreement.  

The Axon-ICF-Carsa study considered(148) that the described wholesale practices cannot 
be effectively tackled by ex ante or ex post regulatory intervention, due to the exclusion of 
the mobile markets from the list of EU market susceptible to ex ante regulation and the 
unlikely  reach  by  any  mobile  operator  in  the  EU/EEA  of  market  dominance  standard, 
according to the competition law criteria. 

(147) Axon-ICF-Carsa study, page 144. 
(148) Axon-ICF-Carsa study, pages 144-145. 

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In general, BEREC considers that, in light of the current situation of the market, no further 
regulatory  measures  should  be  taken  as  regards  permanent  roaming  and  M2M/IoT 
services. BEREC observes that the widespread use of permanent roaming for any service 
would blur the lines between the international roaming market and the domestic mobile 
access and origination markets. On the other hand, in BEREC’s view, the expected growth 
of the market could increase the competitive risks since large operators would be able to 
easily provide permanent roaming offers while smaller MNOs and MVNOs may be ousted 
from these deals, due to their more reduced bargaining power. 

In addition to the invitation addressed to the Commission to study the market and potential 
regulatory measures in order to prevent competitive imbalance between large groups and 
smaller  operators  across  the  EEA,  BEREC  made  some  suggestions  for  further 
clarifications on permanent roaming and the scope of the applications of the roaming rules 
related to IoT services.  

To conclude with, it seems there are no compelling reasons that would justify a strong and 
extensive  regulatory  intervention  as  regards  the  permanent  roaming  connectivity 
conditions  for  M2M/IoT.  The  corresponding  retail  side  seems  to  be  characterized  by 
intense  competition  and  countervailing  buyer’s  power,  while  the  wholesale  charges  for 
access seekers of permanent roaming connectivity appear to be relatively low. This does 
not  exclude  though  a  more  targeted  regulatory  intervention,  depending  on  the 
circumstances.  

9.3.  Wi-Fi and Wi-Fi aggregation 

Wi-Fi  technology  has  been  increasingly  used  as  a  direct  substitute  for  mobile  data,  or 
combined with OTT services, as an indirect substitute for mobile voice and SMS services. 
It remains attractive thanks to its cost, convenience and quality. Two different types of Wi-
Fi  networks can be identified:  (i) private/ in-building  Wi-Fi  networks,  such  as  the ones 
deployed  in  homes,  businesses  and  hotels  and  (ii)  public  Wi-Fi  hotspots,  offering 
connectivity services to wider open air, in many cases, areas. Both types have been used 
to offload mobile traffic, either domestic or roaming. 

In  domestic  use,  Wi-Fi  has  been  widely  used  for  replacing  mobile  data  in  private 
environments while some operators integrate “Wi-Fi calling” in their service offering to 
allow  users  to  make/receive  calls  and  send/receive  SMS  messages  in  areas  with  poor 
cellular coverage. Public Wi-Fi hotspots, especially when aggregated, may play a more 
significant role as a potential substitute for roaming services. 

The availability and coverage of Wi-Fi networks has increased significantly in Europe, as 
can be seen in the following picture. 

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Figure 28: Wi-Fi Coverage in Europe 

Source: WiGLE: Wireless Network Mapping 

The important role played by Wi-Fi in the EU connectivity landscape has been recognized 
and  addressed  by  the  WiFi4EU  initiative.  WiFi4EU  gives  free  internet  access  to  local 
residents  and  visitors  throughout  the  entire  EU  in  the  main  centres  of  community  life 
(parks, squares, libraries, public buildings, hospitals, etc.), powering also digital services 
(eHealth, eTourism, eLearning and eGovernment). 

The use of Wi-Fi as a replacement  for roaming has some clear advantages, such as the 
avoidance  of  roaming  costs,  the  Wi-Fi  global  availability  on  many  devices  and  the 
provision of better connectivity especially in indoor areas. On the other hand, the weakness 
is the Wi-Fi network’s reliability, accessibility, throughput and security. 

Even though Wi-Fi is a direct substitute, with increased availability in all Member States, 
it  is  not  expected  that  it  could  replace  mobile  data  roaming  connectivity.  The  mobile 
network has strong advantages that cannot be met by the Wi-Fi aggregated networks, such 
as the ubiquitous coverage and the smooth handover while moving. The availability of 5G 
networks to a large extent in all countries allows for data connections with better quality 
and increased speed. Many users have turned to unlimited data packages, removing that 
way an existing restriction for mobile networks. Over and above all, RLAH allows users 
to use the data of their home subscription without any additional charge, diminishing that 
way  the  need  of  the  users  to  find  ways  to  circumvent  roaming.  Figure  3,  showing  the 
increase of average roaming data consumption per user since 2016, confirms the above 
conclusion. 

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BEREC (149) also takes the view that despite Wi-Fi, as well as other technologies, such as 
LoRaWAN and satellite solutions, being alternatives technologies, they are not considered 
to  have  a  relevant  impact  on  traditional  roaming  services,  because  they  are  used  as  a 
complement, or for a specific implementation, but not as a substitute for traditional mobile 
roaming.  They  point  to  the  different  reach  and  indoor  coverage  capabilities  of  these 
technologies compared to terrestrial mobile services. 

9.4.  OTT voice and messaging 

The combination of Wi-Fi with OTT services may act as a replacement for traditional voice 
and SMS services. 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. 
The popularity of OTTs constantly increases, and many platforms have been introduced to 
cover the users’ needs, such as  WhatsApp, Facebook Messenger, iMessage, and Signal 
Messenger. At the same time other platforms/applications, like Instagram and Snapchat, 
are used also as OTT services for specific user groups. This popularity on the other hand 
has created a fragmentation of users, which in turn forms an additional burden on the caller: 
to  identify  the  application  with  which  a  certain  user  can  be  reached.  Thus,  the  lack  of 
interoperability  between  the  OTT  services  makes  any-to-any  communication  very 
difficult.  

On the other hand, OTTs have some big advantages compared to traditional voice calls, 
such as the creation and administration of user groups and the option of video calls, the 
latter especially in cases where the data connection is uncharged (e.g. Wi-Fi). Moreover, 
OTT  services  could  limit  the  potential  for  mobile  operators  to  increase  voice  and 
messaging prices, if cost-effective data roaming or alternatives are available.  

As a conclusion, OTT services will continue to be used both in the domestic environment 
and while roaming. However, with the development of unlimited data plans in the RLAH 
environment, it is highly unlikely that OTTs will replace traditional roaming mobile voice 
and SMS services in the mid-term future.  

9.5.  Embedded SIM (eSIM) 

The implementation of eSIMs allow the mobile subscriber to store and administer multiple 
SIM  profiles  in  the  same  device.  It  should  be  noted  though  that  until  now  and  in  most 
cases (150)the user of the eSIM may have only one active profile at a time. In the 2018 study 
on  technological  developments  this  was  raised  as  a  limitation  that  could  be  addressed 
through GSMA standards. 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 

(149) BoR(25)48. 
(150) Google has introduced the option of having 2 eSIMs active simultaneously in its Pixel 7/Pixel 7 pro 
smartphones. 

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MNOs to raise prices, but the adoption of eSIM in consumer devices for the purpose of 
bypassing roaming services, especially in a RLAH environment and its impact has yet to 
be seen. 

The growing numbers of eSIM-enabled smartphones/smartwatches and of operators with 
commercial  availability  of  eSIM  Service  for  Smartphones (151)  will  inevitably  lead  to 
higher penetration of eSIMs in the market. It is indicative that the number of new eSIM 
enabled devices increased by a factor of 10 between 2018 and 2023, reaching  231 new 
eSIM  enabled  devices  in  2023,  out  of  which,  60%  were  smartphones.  Smartphone 
manufacturers have followed different approaches to the introduction of eSIMs, varying 
from eSIM-only models (e.g. Apple in the US) and eSIM in all models (Google, Apple), 
to eSIM in some models (Samsung, Xiaomi, ZTE Motorola, Vivo, Huawei, Oppo etc. ) or 
not at all (152). 

Figure 29: Commercial availability of smartphones 

Source: 100+ eSIM statistics telecom service providers need to know in 2024 

The  most  significant  prospects  of  eSIM  could  be  in  connectivity  for  IoT  including 
connected  cars,  where  its  use  is  already  established.  One  of  the  most  remarkable 
advantages  of  an  IoT  eSIM  compared  to  an  IoT  traditional  SIM  is  that  it  can  be 
reprogrammed to switch between networks without requiring the user to replace a physical 
SIM  card.  With  this  characteristic,  eSIMs  may  be  used  as  an  alternative  to  permanent 
roaming.  For  instance,  a  connected  car  equipped  with  an  eSIM  may  not  need  to 
permanently  roam  in  the  country  it  is  sold,  if  its  eSIM  is  provisioned  with  a  mobile 
subscription  in  this  country.  This  functionality  would  not  be  possible  if  the  car  was 
equipped with a traditional SIM and the agreement for permanent roaming would be the 
only  option. On the other hand, eSIMs  require a  more complex and  costly set  up,  as it 
requires an infrastructure that supports eSIM provisioning and management within the car. 

(151) www.mobiliseglobal.com 
(152) GSMA-Welcome-and-eSIM-Market-China-and-Beyond.pdf 

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The eSIM technology continues to gain importance and will likely gain further importance 
in the forthcoming years. It 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. It is unlikely that eSIM will impact regulated roaming within the EU/EEA 
in a way that will change the market dynamics. Rather, it is more likely that eSIMs affect 
roaming in the rest of the world, since, there, the roaming costs for the subscribers increase 
significantly. On the issue of the eSIMs, BEREC notes that they may impact rest of the 
world roaming tariffs if they become widespread in the market, but security aspects relating 
to the use of travel eSIM should also be considered. 

In  both  consumer  and  IoT  segments,  the  penetration  of  eSIMs  mainly  depends  on  the 
willingness  of  the  device  manufacturers  to  include  eSIM  technology  in  more  of  their 
devices and the decision of the operators to take the risk of losing the strong bond with the 
subscriber through the traditional SIM card and adopt eSIMs. 

9.6.  Satellite communications 

Low  Earth  Orbit  (LEO)  satellite  communications  have  emerged  as  an  alternative  to 
traditional roaming services for several reasons, but especially for their global coverage, 
which allows users to roam without restrictions. The standardization of the integration of 
satellite  components  in  the  5G  architecture  (153)  played  a  key  role  in  enabling  Non-
Terrestrial Networks (NTN) to be used for, among others, extending the coverage of the 
networks,  addressing  specific  requirements  of  IoT  (e.g.  exchange  of  small  amounts  of 
traffic-  optimization  for  low  power  usage)  and  global  roaming,  allowing  e.g.  global 
tracking  and  tracing  to  be  globally  available.  Inclusion  of  satellite  technology  into  5G 
standards  (direct  to  device  –  D2D)  enables  users  to  communicate  through  the  LEO 
satellites with their standard industry consumer phones. The additional fact that, apart from 
the  radio  access  level,  standardization  covers  also  the  core  network  level,  allows  the 
interoperability of the terrestrial and non-terrestrial networks in the same way all standard 
terrestrial MNOs (Mobile Network Operators) do for wholesale roaming, i.e., by using the 
standardised  GSMA  technical  network  interfaces  and  commercial  processes  for 
International Wholesale Roaming. 

LEO-based satellites are placed in orbit at a distance of between 160 to and 1 600 km from 
the Earth’s surface in a constellation arrangement which allows them to achieve relatively 
good connectivity performances, especially in terms of coverage and reduced latency (154). 
Although 5G still offers better network performance, including higher bandwidth, lower 
latency,  and  higher  efficiency,  LEO-based  satellite  connectivity  may  become  a  serious 
contender  for  cellular  connectivity  solutions.  In  any  event,  LEO-based  connectivity  is 

(153)  Specification # 21.917.  
(154) For example, the distance between the satellite and the smartphone in a specific implementation varies 
between 525Km and 951 Km, resulting at a round-trip delay of 7-16 msec for single-hop communication 
between  a  smartphone  and  a  Starlink  gateway.  This  calculation  considers  propagation  delay  only, 
excluding  additional  latency  from  active  equipment  such  as  protocol  packetization  and  doppler-shift 
compensation (Analysis Mason Satellite direct-to-device: the characteristics of D2D constellations will 
limit SpaceX’s ability to dominate). 

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suitable  for  IoT  use  cases  in  all  environments  including  remote,  rural,  and  maritime 
environments.  

Apart  from  the  clear  benefits  of  LEO  satellites  regarding  latency,  significant  effort  has 
been  put  into  increasing  the  available  capacity  of  the  satellites  to  accommodate  the 
continuously increasing demands for bandwidth.  

The first steps for the integrations of terrestrial and NTN have been taken, although still at 
a very early stage. For example, the agreement between T-Mobile and SpaceX (155) focuses 
on extending the coverage of the network by offering an additional layer of connectivity 
in  previously  unreachable  areas.  According  to  the  relevant  announcement,  in  the  areas 
covered only by satellite, the users will have access to text messaging services, including 
SMS,  MMS  and  participating  messaging  apps.  As  recently  announced  (156),  the 
functionality is under beta testing with real users, while the initial list with few Android 
smartphones as eligible devices to test the network has been enriched with Apple’s iPhone 
devices (157). Additionally, in case of a wide adoption of this solution, a denser network of 
satellites may be required to be implemented to be in position to cope with the total demand 
for traffic. 

It is noted that according to input that reached BEREC, non-terrestrial networks based on 
low Earth orbit satellite are an alternative from a technological perspective but are rather 
used in places where terrestrial roaming is not available. As the prices for such access are 
very high, they do not seem to be a substitute for EU regulated roaming.  

As a conclusion, LEO satellites and D2D communications, although in the long term may 
significantly affect roaming, they cannot be considered as an alternative to roaming in the 
RLAH environment in the short to medium term. 

9.7.  Online Trading platforms 

In its 2020 review of the Roaming Regulation, the Commission identified online trading 
platforms as a technological development that could boost competition. The 2022 recast 
of  the  Roaming  Regulation  includes  clarifications  to  facilitate  and  encourage  trading 
platforms as an alternative way of wholesale negotiations. The 2018 study on technological 
developments identified 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. Currently, there is one such platform available 
on the market providing trading services for operators. 

Under the most recent data collected by BEREC, only eight operators in EU/EEA reported 
having used trading platforms or hubs from October 2023 until the first quarter of 2024. In 

(155) T-Mobile Takes Coverage Above and Beyond With SpaceX - T-Mobile Newsroom. 
(156)  December  2024,  T‑Mobile  Opens  Registration  for  Direct‑to‑Cell  Satellite  Service  Beta  Test  with 
Starlink ‑ T‑Mobile Newsroom. 
(157) Apple's iPhones to support Starlink direct-to-cell coverage in US | Reuters. 

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contrast, more than 70 operators concluded direct roaming agreements in the same period. 
Operators did not report information on pricing schemes used.  

Although exchanges on platforms could potentially benefit roaming markets by enhancing 
price  transparency  and  promoting  competition,  their  limited  reach  prevents  them  from 
being  effective  in  reducing  wholesale  prices  to  a  sufficient  extent  to  justify  lifting  the 
regulatory obligations under the Roaming Regulation. 

10. CONCLUSION 

Since the entry into force of the recast Roaming Regulation, in 2022, the RLAH regime 
continues benefiting to the European consumers all around the EU/EEA and contributes to 
achieving a true digital single market.  

10.1.  The Roaming Regulation effectively provides benefits  

The Roaming Regulation has been and is still instrumental in creating a true digital single 
market, effectively addressing the main problem of roaming charges and bridging the gap 
between national markets, allowing Europeans to freely use mobile connectivity services 
while  traveling  in  the  EU/EEA.  Two  years  after  the  recast,  the  Roaming  Regulation 
continues to ensure the effective and sustainable provision of Roam Like at Home (RLAH) 
services, while maintaining essential safeguards, including the derogations mechanism and 
Fair  Use  Policy  (FUP),  which  have  proven  crucial  in  keeping  the  regime  sustainable 
(Section 5.2). The FUP measures are widely applied and considered effective by operators 
and have limited impact on consumers. 

The  2022  recast  has  also  led  to  a  significant  reduction  in  the  maximum  level  of  FUP 
surcharges for data, capping them with a glide path leading to EUR 1/GB in 2027, to the 
benefit  of  the  EU  consumers.  The  introduction  of  improved  transparency  measures  has 
empowered  consumers  to  make  informed  decisions  and  reduced  the  risk  of  incurring 
additional costs because of non-awareness (e.g. for value added services, for use on non-
terrestrial networks on ships and planes), while the establishment of BEREC’s databases 
has provided a valuable resource for monitoring the enforcement of these measures.  

In its Opinion (158), BEREC reiterated its position expressed in previous report, affirming 
that “the abolition of retail roaming charges within the EEA (…), has proven to be a clear 
and  tangible  success  for  consumers  and  of  European  integration,  and  a  substantial 
contribution to the further completion of the Single Market”. BEREC also assessed that 
the new provisions introduced in the 2022 recast of the Roaming Regulation have been 
effective.  

(158) BoR(25) 48. 

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10.2.  The Roaming Regulation is efficiently enabling end users to benefit from 

mobile services cross borders throughout the single market  

The abolition of roaming surcharges continues to bring relevant economic benefits to EU 
end-users and has continued to be accompanied by a regulation of wholesale prices for the 
roaming services. The 2022 recast introduced a further gradual reduction of the wholesale 
caps  for  SMS,  calls  and  data,  estimated  on  the  efficient  costs  of  providing  the  relevant 
roaming  services.  (Section  7).  This  has  enabled  operators  to  provide  RLAH  without 
incurring sustainability problems on the retail side, as demonstrated also by the reduced 
requests  for  derogation  (Section  5.3)  and  ensuring  cost  recovery  on  the  wholesale  side 
(Section 6). The revised glide path has therefore efficiently balanced the interests of those 
supplying the network service to other operators (wholesale side, where cost recovery is 
relevant)  and  those  supplying  the  roaming  service  to  end-users  (retail  side,  where  the 
sustainability  is  relevant).  Following  the  publication  of  the  latest  cost  model  study,  it 
appears that there may be room for improvement and possible further reductions of the 
caps. 

In  its  Opinion (159),  BEREC  declared  that  “BEREC  holds  that  the  regulatory  costs 
associated with the implementation of the roaming rules are unequivocally outweighed by 
the  tangible  benefits  of  the  RLAH  approach  for  European  citizens  and  businesses”. 
However, BEREC also recognised opportunities for further enhancements, particularly in 
reducing  the  administrative  burden  by  streamlining  the  annual  data  collection  process. 
These  improvements  can  be  implemented  at  a  "working  level"  and  do  not  necessitate 
changes to the existing regulation. 

10.3.  The Roaming Regulation is still the most relevant instrument  

As part of this review exercise, the Commission assessed all technological developments 
that  could  influence  the  Roam  Like  at  Home  (RLAH)  regime.  In  particular,  the 
Commission  analysed  all technologies that could  potentially  act  as a substitute or exert 
competitive constraints on the roaming services. The conclusion reached is that while there 
is potential, there is still no evidence of significant impact, substitutability, or competitive 
pressure. No significant developments have occurred since the last review. Even with the 
extensive coverage of 5G, its impacts on roaming markets in terms of services have yet to 
be seen. 

Therefore, the RLAH regime remains fit for purpose and is still the only instrument that 
allows  for  the  achievement  of  a  true  digital  single  market.  Furthermore,  this  is  a 
proportionate instrument, valid for a limited period of time (until 2032). As of today, the 
competitive  conditions  are  not  expected  to  change  within  this  timeframe,  but  the 
Commission will continue to monitor any developments. 

(159) Ibid. 

Report from the Commission to the European Parliament and the Council on the review of the roaming market - SWD(2025) 164 
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10.4.  The Roaming Regulation is coherent with the other legal tools  

No  inconsistencies  have  been  identified  between  the  Roaming  Regulation  and  other 
relevant legal instruments, which could potentially create redundancy and undermine the 
Regulation's effectiveness. This assessment is supported by the BEREC Opinion, which 
has not identified any significant contradictions between the roaming rules and other EU 
legal acts. In addition, no NRA, operator or stakeholder has reported any inconsistencies 
between the Roaming Regulation and other EU legislation. 

10.5.  The Roaming Regulation delivers uncontested EU Added value  

The benefits of the EU's action on roaming continue to be widely recognized by consumers 
and market players alike. European consumers declare that they are benefiting from Roam-
Like-at-Home rules (84%) and that they have been able to use their phone abroad as in 
their home country (80%). This success is also demonstrated by the evolution of volumes, 
with  data  consumption  while  roaming  continuously  increasing,  reaching  1495  MB  per 
month, per roaming subscriber in Q3 2023 (compared to 100 MB per month, per subscriber 
in Q2 2017, just before the introduction of the RLAH regime). 

It is widely recognized that the establishment of a true digital single market could only be 
achieved at the Union level, addressing the market failure that had been identified in the 
2020  impact  assessment.  At  the  same  time,  the  findings  of  this  report  show  that  this 
initiative  has  had  no  negative  impact  on  national  markets,  thereby  demonstrating  once 
again its relevance and added value. 

Consulted on the EU added value, BEREC claimed (160) that “it is  difficult  to  envisage 
how national-level legal instruments alone could have resulted in the current achievements 
in terms of pricing, quality, and transparency at the EU/EEA level”, supporting the results 
of the RLAH regime. The added value is even more evident when assessing third countries’ 
roaming prices:  while they have also  declined since the adoption of the RLAH regime, 
they remain substantially higher than in the EU/EEA.  

10.6.  The  Commission  will  continue  to  monitor  the  implementation  of  the 

Roaming Regulation 

This  review  covering  all  the  relevant  factors  outlined  in  Article  21  of  the  Roaming 
Regulation concludes that the RLAH regime remains fit for purpose, effectively achieving 
its  objectives  of  promoting  competition,  reducing  prices  and  improving  the  quality  of 
roaming services, for the benefit of European consumers.  

As in 2019, the review shows that, despite signs of competitive dynamics on both the retail 
and  wholesale  roaming  markets,  the  underlying  basic  competition  conditions  have  not 
changed substantially and are not likely to change in the foreseeable future. 

(160) BoR(25) 48. 

Report from the Commission to the European Parliament and the Council on the review of the roaming market - SWD(2025) 164 
Page 85 / 91 

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The  overall  framework  of  the  Roaming  Regulation  has  proven  to  be  effective,  also  in 
intensifying competition at wholesale level and creating dynamics in the wholesale market, 
with wholesale roaming prices steadily decreasing and remaining well below the regulated 
wholesale caps.  

The example of Brexit, with the full deregulation of roaming services between the EU and 
the  UK,  highlighted  the  importance  of  the  current  RLAH  framework  and  the  need  to 
maintain it to ensure free retail roaming services for EU consumers. In parallel, the RLAH 
area  is  likely  to  see  its  first  enlargement  in  the  next  months  to  include  Ukraine  and 
Moldova, subject to a positive assessment of its alignment with EU legislation – a process 
that will be monitored by the Commission. 

Based  on  the  cost  model  results  and  the  BEREC  opinion,  the  Commission  will,  in 
particular,  further  monitor  and  assess  the  market  dynamics  and  potential  impacts  of 
reductions in wholesale caps, given the economic space indicated by the cost model. 

BEREC suggested in its Opinion that other improvements to the already well-functioning 
roaming rules could be considered as regards clarifying certain FUP mechanisms, better 
designing the welcome message and transparency measures (including the databases) and 
ensuring that inadvertent roaming problems are effectively tackled. The implementation of 
these rules requires further monitoring. Similarly, the findings on QoS will require close 
monitoring  by  NRAs  and  the  Commission  of  the  currently  applicable  QoS  provisions. 
Additionally, some other improvements, suggested by BEREC, such as streamlining the 
data collection process with the NRAs and BEREC, could also be implemented without 
amending the Roaming Regulation.  

Overall,  the  suggested  improvements  do  not  call  into  question  the  general  principles 
underlying the Regulation, which remain relevant and effective and should be maintained. 
This  is  especially  important  as  this  successful  European  framework  is  soon  set  to  be 
extended to other non-EU countries. 

Report from the Commission to the European Parliament and the Council on the review of the roaming market - SWD(2025) 164 
Page 86 / 91 

- 

 
 
 
 
 
 
 
11. ANNEX 

Table A: Absolute number and percentage of operators applying each type of FUP mechanism 
over total respondents (excluding missing values), 2022-2024 

Year 

Mechanism 

MNO  MVNO 

Tot applying 
each 
mechanism 

MNO  MVNO 

Tot applying 
each 
mechanism 

Stable link criterion 

Open data bundle limits 

2022 

Data limit on prepaid 

Control window 

Other mechanism 

Stable link criterion 

Open data bundle limits 

2023 

Data limit on prepaid 

Control window 

Other mechanism 

Stable link criterion 

Open data bundle limits 

2024 

Data limit on prepaid 

Control window 

37 

82 

26 

53 

14 

30 

60 

21 

41 

12 

24 

52 

21 

38 

19 

32 

25 

31 

9 

18 

26 

22 

29 

10 

18 

30 

21 

26 

56 

114 

51 

84 

23 

48 

86 

43 

70 

22 

42 

82 

42 

64 

Other mechanism 

13 
Source: JRC calculation on BEREC Transparency data 

10 

23 

40% 

88% 

28% 

57% 

15% 

43% 

87% 

30% 

59% 

17% 

36% 

79% 

32% 

58% 

20% 

37% 

63% 

49% 

61% 

18% 

37% 

53% 

45% 

59% 

20% 

36% 

61% 

43% 

53% 

20% 

39% 

79% 

35% 

58% 

16% 

41% 

73% 

36% 

59% 

19% 

36% 

71% 

36% 

55% 

20% 

Table  B1:  Operator’s  views  on  the  effectiveness  of  FUP  mechanisms  –  only  operators 
implementing each type of FUP (2023) 

Stable 
link 

44% 

42% 

11% 

2% 

45 

Effective 

Partially effective 

Ineffective 

Unnecessary 
Total number of 
operators 
applying each 
mechanism 

Open data bundle 
limits 

Operators (MNOs and MVNOs included) 
Data 
pre-
paid 
60% 

Control 
mechanism 

47% 

36% 

Other 
FUP 
mechanisms 
17% 

52% 

0% 

1% 

83 

55% 

4% 

4% 

40% 

0% 

0% 

33% 

17% 

33% 

67 

15 

6 

Source: JRC calculation on BEREC Transparency data. 

Report from the Commission to the European Parliament and the Council on the review of the roaming market - SWD(2025) 164 
Page 87 / 91 

- 

 
 
 
 
 
 
 
 
 
 
Table  B2:  Operator’s  views  on  the  effectiveness  of  FUP  mechanisms  –  only  operators 
implementing each type of FUP (2024) 

Operators (MNOs and MVNOs included) 

Stable  
 link 

Open data  
 bundle limits 

Control   
 mechanism 

Data   
 pre-paid 

Other FUP  
 mechanisms 

Effective 

Partially effective 

Ineffective 

Unnecessary 

Total number of operators 
applying each mechanism 

55% 

41% 

5% 

0% 

22 

49% 

0% 

50% 

1% 

80 

33% 

7% 

57% 

3% 

60 

33% 

33% 

33% 

0% 

17 

53% 

24% 

24% 

0% 

3 

Source: JRC calculation on BEREC Transparency data. 

Table C1: Operator’s views on the complexity to apply each FUP mechanism  – only operators 
implementing each type of FUP.(2023) 

Operators (MNOs and MVNOs included) 

Stable 
link 
40% 

19% 

11% 

30% 

Open data 
bundle 
limits 
26% 

24% 

39% 

12% 

Control 
mechanism 
8% 

21% 

41% 

30% 

Data 
pre-
paid 
15% 

23% 

31% 

31% 

47 

85 

66 

39 

Source: JRC calculation on BEREC Transparency data. 

Other FUP 
mechanisms 
11% 

11% 

33% 

44% 

9 

Easy to implement 

Relatively easy 

Relatively difficult 
Very difficult to 
implement 
Total number of 
operators 
applying 
each mechanism 

Table C2: Operator’s views on the complexity to apply each FUP mechanism  – only operators 
implementing each type of FUP.(2024) 

Operators (MNOs and MVNOs included) 

Stable  
link 

Open data 
 bundle limits 

Control  
mechanism 

Data  
pre-paid 

Other FUP 
 mechanisms 

Easy to implement 

Relatively easy 

Relatively difficult 

Very difficult to implement 

Total number of operators 
applying each mechanism 

40% 

18% 

10% 

33% 

40 

30% 

21% 

38% 

11% 

80 

7% 

21% 

33% 

39% 

61 

16% 

24% 

24% 

35% 

37 

17% 

17% 

50% 

17% 

6 

Source: JRC calculation on BEREC Transparency data. 

Report from the Commission to the European Parliament and the Council on the review of the roaming market - SWD(2025) 164 
Page 88 / 91 

- 

 
 
 
 
 
 
  
  
 
 
 
 
 
 
Table D: Types of complaints related to FUP issues made by consumers and received at least once 
by European NRAs 

NRAs receiving 
 each complaint 
2022 

2021 

2023 

% over total number of 
 respondents 
2022 

2021 

2023 

2024 

2024 

2020 

11 

13 

8 

11 

29% 

39% 

62% 

38% 

58% 

7 

6 

12 

14 

8 

21% 

25% 

57% 

61% 

42% 

8 

10 

6 

14% 

21% 

44% 

45% 

30% 

2020 

8 

6 

4 

4 

3 

4 

3 

1 

14% 

11% 

22% 

14% 

5% 

2 

3 

4 

2 

1 

7% 

11% 

22% 

10% 

5% 

3 

5 

1 

7 

5 

11% 

18% 

6% 

33% 

25% 

End-users  were  not  aware  that  in 
 roaming  a  data  FUP  could  be 
applied 
End-users  complained  about  the 
 amount of volume included in the 
 FUP 
Surcharges  were  applied  despite 
users  being  unaware  that  the  fair 
use limit had been reached. 
Customers were alerted and in spite 
of changing their usage pattern, the 
 operator surcharged them once the 
 observational period had ended 
Customers  were  not  alerted  of 
 opportunities to change their usage 
 pattern  once 
the  observational 
period had ended 
Customers  were  unaware,  by 
looking  at  their  contracts,  of  the 
documents  they  would  need  to 
provide to prove normal residency 
is 
or  stable 
required) 

links  (where 

this 

Source: JRC calculation on BEREC Transparency data. 

Report from the Commission to the European Parliament and the Council on the review of the roaming market - SWD(2025) 164 
Page 89 / 91 

- 

 
 
 
 
 
 
up 
to 
10 

10 

10 

None 

8 

5 

10 

7 

How  many 
complaints 
to 
related 
roaming  have 
you  received 
in 
each 
category? 
Use 
Fair 
Policy (FUP) 
inadvertent 
roaming 
related to lack 
of 
information 
Value-added 
services 
(VAS), 
including 
premium  rate 
services 
(PRS) 
QoS 
emergency 
services 
non-terrestrial 
networks 

Table  E1:  How  many  complaints  related  to  roaming  have  you  received  in  each  category? 
(Consumer complaints) – 2024 

No. Countries 
 that replied 

% of the  
total respondents 

between 
11-50 

between 
51-100 

between 
101-200 

more 
than 
200 

Tot.  none 

up 
to 
10 

between 
11-50 

between 
51-100 

between 
101-200 

6 

6 

6 

0  

2 

1 

0  

1 

1 

0 

0 

0  

24 

33% 

42% 

25% 

0%  

0%  

24 

22%  

39%  

17%  

13%  

9%  

25 

17%  

46%  

29%  

8%  

0%  

0%  

more 
than 
200 

0%  

0%  

10 

12 

1 

0 

0  

0  

23 

60%  

30%  

5%  

5%  

0%  

0%  

10 

22 

14 

12 

1 

1 

8 

0  

3 

0  

0  

0 

0  

0  

0  

0  

0  

0  

23 

23 

48%  

48%  

5%  

90%  

10%  

0%  

0%  

0%  

25 

29%  

54%  

13%  

4%  

0%  

0%  

0%  

0%  

0%  

0% 

Source: 2024 BEREC data collection– Questionnaire for NRAs. 

Table  E2:  How  many  complaints  related  to  roaming  have  you  received  in  each  category? 
(Consumer complaints) – 2023 

No. Countries  
that replied  

% of the   
total respondents  

between 
11-50  

between 
51-100  

between 
101-200  

more 
than 
200  

Tot
.  

non
e  

up to 
10  

between 
11-50  

between 
51-100  

between 
101-200  

up 
to 
10  

9 

9 

8 

4 

11  7 

How  many  complaints 
related  to  roaming  have 
in  each 
you 
category?  

received 

Non
e  

5 

5 

4 

Fair Use Policy (FUP)  

inadvertent roaming  

related 
to 
information  
Value-added 
(VAS), 
premium 
(PRS)  

rate 

lack 

of 

services 
including 
services 

QoS  

emergency services  

12 

6 

1 

10 

19 

10  1 

2 

0 

non-terrestrial networks  

7 

13  3 

more 
than 
200  

0%  

0%  

0%  

0 

3 

2 

0 

0 

0 

1 

0 

2 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

22 

23 

24 

20 

21 

21 

24 

23
% 
22
%  
17
%  

60
%  

48
%  
90
%  
29
%  

41%  36% 

0%  

39%   17%  

13%  

46%   29%  

8%  

0%  

9%  

0%  

30%   5%  

5%  

0%  

0%  

48%   5%  

10%   0%  

0%  

0%  

54%   13%  

4%  

0%  

0%  

0%  

0%  

0%  

0% 

Source: 2023 BEREC data collection– Questionnaire for NRAs 

Report from the Commission to the European Parliament and the Council on the review of the roaming market - SWD(2025) 164 
Page 90 / 91 

- 

 
 
  
 
 
 
 
 
Table  E3:  How  many  complaints  related  to  roaming  have  you  received  in  each  category? 
(Consumer complaints) – 2022 

No. Countries  
that replied  

% of the   
total respondents  

How many complaints related to 
roaming  have  you  received  in 
each category?  

No
ne  

up  to 
10  

betwee
n 11-50  

betwee
n 
51-
100  

Fair Use Policy (FUP)  
inadvertent roaming  
related to lack of information  
Value-added  services  (VAS), 
including premium rate services 
(PRS)  
QoS  
emergency services  
non-terrestrial networks  

11  5 
10  7 
4 
9 

9 

1 

13  2 
6 
1 
11  3 

1 
1 
4 

1 

1 
0 
0 

1 
2 
1 

0 

0 
0 
0 

betwe
en 
101-
200  
0 
0 
0 

0 

0 
0 
0 

more 
than 
200  

To
t.  

non
e  

to 

up 
10  

between 
11-50  

0 
0 
0 

0 

0 
0 
0 

18  61%  28% 
20  22%   39%  
18  17%   46%  

6% 
17%  
29%  

11  60%   30%  

5%  

16  48%   48%  
7 
90%   10%  
14  29%   54%  

5%  
0%  
13%  

betwee
n 
51-
100  

0%  
13%  
8%  

betwe
en 
101-
200  
0%  
9%  
0%  

more 
than 
200  

0%  
0%  
0%  

5%  

0%  
0%  
4%  

0%  

0%  

0%  
0%  
0%  

0%  
0%  
0% 

Source: 2022 BEREC data collection– Questionnaire for NRAs 

Report from the Commission to the European Parliament and the Council on the review of the roaming market - SWD(2025) 164 
Page 91 / 91 

-