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  COM(2025) 324 final  REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL  on the review of the roaming market {SWD(2025) 164 final}  
 
 
REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT 
AND THE COUNCIL 

on the review of the roaming market 

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 in their daily life. Since 15 June 2017, EU 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  set  out  in  the  recast 
Regulation  (EU)  2022/612  (the  Roaming  Regulation) (1)  which  also  extended  their 
application for an additional 10 years until June 2032.  

In  2022,  the  following  novelties  were  introduced  to  increase  consumer  benefits  and 
protections:  

•  The  new  quality  of  service  (‘QoS’)  measures,  which  clarified  the  previous 
provisions, ensure that roaming customers can at least have the same level of roaming 
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  visiting  mobile  operators  access  to  all  network 
technologies  and  generations,  if  they  make  a  reasonable  wholesale  roaming  access 
request. 

•  Improved  rules  were  introduced  for  emergency  communications  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  contacting 
emergency  services,  including  those  designed  for  users  with  disabilities,  in  the 
EU/EEA country they are visiting. 

•  To protect roaming customers from unexpected surcharges, new rules were introduced 
to  ensure 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  two  automatic  cut-off  limits  once  they  have  consumed 

(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). 

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EUR  50  and  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 RLAH regime has been made sustainable for operators. At wholesale level, 
the  price  caps  were  further  substantially  reduced  in  2022,  in  particular  for  data 
traffic. The wholesale glidepath ensures progressive reductions of the caps every year 
until 2027 (reaching EUR 1 per GB), to ensure that market players can benefit from 
wholesale  rates  that  allow  for  the  sustainable  provision  of  roaming  services  to  their 
the  domestic  price.  
customers  without 

levying  any  charge  on 

top  of 

The  wholesale  roaming  price  caps,  based  on  a  cost  model  study (2)  that  takes  into 
account  operators’  costs,  also  ensure  that  wholesale  costs  are  fully  recovered  by  the 
operator  providing  the  wholesale  roaming  service.  Additionally,  the  decreasing 
wholesale caps provide benefits on the retail side. Surcharges exceptionally applied to 
consumers are constantly decreasing, given that the wholesale caps set the maximum 
retail surcharge that operators can apply.  

Figure 1: Decreasing trend in the data surcharge operators can apply over the years (€/GB) 

Source: Regulation (EU) 2022/612  

In  line  with  its  reporting  obligations  laid  down  in  the  Roaming  Regulation  (3),  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 
sustainability  derogation  laid  down  in  the  Commission  Implementing  Regulation  (EU) 
2016/2286. This 2023 Review Report concluded that, overall, the fair use policies (FUP) 
were effective (4).  

(2)  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, 18 December 2024. 

(3)  Article 7 of the Roaming Regulation  

(4)  The review confirmed that the vast majority of EU residents enjoy mobile services while travelling in 
the  EU/EEA  under  RLAH  conditions.  The  existing  fair use  policy  has  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 domestic markets: the tariff 
structure and availability of domestic mobile subscription remained unchanged. 

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The Roaming Regulation further mandates the Commission to submit, by 30 June 2025, 
a  comprehensive  review  report  to  the  European  Parliament  and  to  the  EU  Council 
assessing the functioning of the roaming market. This is the purpose of this Report and 
its accompanying Staff Working Document.  

2.  FUNCTIONING OF THE ROAMING MARKET 

2.1.  Compliance with the rules  

In  addition  to  conducting  comprehensive  data  collection  in  line  with  Article  17  of  the 
Roaming  Regulation,  the  national  regulatory  authorities  (‘NRAs’)  must  monitor  and 
supervise compliance with the Roaming Regulation.  

A high level of compliance with the Roaming Regulation has been identified, based on 
inputs from NRAs and the Body of European Regulators for Electronic Communications 
(BEREC).  NRAs  are  using  reactive  (e.g.  treatment  of  consumer  complaints)  and 
proactive (e.g. periodic reviews) approaches to monitor the implementation of the RLAH 
provisions.  

At the same time, the level of consumer satisfaction appears high, based on input from 
the  two  most  recent  Eurobarometer  studies(5)  (around  80%  of  travellers  across  the  EU 
consider  that  they  are  benefiting  from  roaming  rules),  and  complaints  received  by 
NRAs (6) are relatively low.  

Finally, in the nine countries that reported non-compliance cases since 2022, most issues 
were promptly resolved by the NRAs, reflecting effective enforcement. NRAs have not 
yet  reported  monitoring  of  the  quality-of-service  provisions  introduced  in  2022.  The 
findings of the Quality-of-Service Study (7) suggest that the level of compliance could be 
significantly  improved.  However,  further  monitoring  and  assessment  of  the  underlying 
circumstances is required. 

2.2.  Retail roaming market 

The continuous increase in roaming consumption is led by data consumption 

In 2017, the introduction of RLAH had triggered an immediate and massive increase in 
retail  roaming  traffic  compared  to  pre  RLAH  values.  In  the  first  year  after  the 
introduction  of  RLAH,  compared  to  the  same  period  the  previous  year,  roaming  data 
consumption increased by a factor of 5 (8) and roaming phone calls made increased by a 
factor of 2.5 (9).  

In  recent  years,  mobile  data  consumption  while  roaming  has  continued  to  massively 
increase. Looking at Q3 for each year, the most roaming-intense quarter, a continuation 

(5)   Flash Eurobarometer 521, European Commission,  July 2023 and Special Eurobarometer 560 (still to 

be published) 

(6)  In  2023,  most  NRA  reported  fewer  than  50  consumer  complaints.  Even  in  the  most  populated 

countries, the reported complaints remained below 300. 

(7)  See pages 11-12. 

(8)  In the first three quarters after the introduction of RLAH (Q3 2017, Q4 2017 and Q1 2018) compared 

to its level one year before.  

(9)  Q3 2017 compared to one year before. 

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of  the  data-consumption  growth  can  be  observed,  with  a  48-fold  increase  since  the 
introduction of the RLAH regime in 2017(10).  

However,  retail  roaming  voice  traffic  has  been  slightly  but  steadily  declining  since  Q3 
2019. This trend could be attributed to the rise of Over-The-Top (OTT) platforms, which 
offer  voice  and  messaging  services  over  the  internet,  increasingly  supplementing 
traditional voice calls and SMS messages, while contributing to the increase of roaming 
data consumption. 

The  massive  increase  in  retail  roaming  data  volume  confirms  how  successful  and 
effective the RLAH regime is in bringing concrete benefits to the EU residents, allowing 
them  to  stay  connected  in  the  same  way  as  in  their  home  country  while  they  are 
periodically travelling in the RLAH area.  

Consumers have benefited from increased roaming data allowances, which have risen as 
a result of the progressive reduction of wholesale caps 

As wholesale caps progressively decrease, with a target of EUR 1 per GB by 2027, EU 
consumers are directly benefiting from the resulting lower prices at retail level.  In fact, 
71% of operators in 2024 applied a fair use policy to “open data bundle”, for which the 
data  allowance  while  roaming  is  directly  linked  to  the  wholesale  caps,  which  are 
currently falling. Hence, EU consumers are benefiting from a higher data allowance, year 
after year, as shown by Figure 2 below. 

Figure  2:  Future  evolution  of  FUP  data  limits  (GB/month)  for  various  retail  prices  (excl. 
VAT) where the data limit on unlimited bundles was applied in 2025-2032 (11). 

Source: European Commission. Calculation based on Article 4(2) of Commission Implementing 
Regulation (EU) 2016/2286 in conjunction with Article 11(1) of the Roaming Regulation (EU) 
2022/612 (12). 

(10) Q3 2017 compared to Q3 2024. 

(11)  Figure  2  indicates  cases  of  operators  applying  open  data  bundle  limits  as  allowed  by  the  Commission 
Implementing  Regulation,  showing  the  link  between  a  decreasing  wholesale  cap  and  the  increasing  roaming 
allowance  under  the  Fair  Use  Policy,  for  users  with  a  subscription  that  has  a  constant  monthly  price  over  the 
years.  The  relevant  formula  used  is  the  following:  FUP  data  allowance  =  (price  of  the  tariff  plan  without 
VAT/wholesale roaming cap) 

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The decreasing trend in wholesale caps has led to a constant and continuing increase in 
the  roaming  data  allowance  that  is  benefiting  EU  consumers  and  has  addressed  the 
increasing  need  for  roaming  volumes.  As  the  wholesale  cap  continues  to  decrease,  it 
should  be  noted  that  the  additional  benefit  for  consumers  will  depend  on  the  type  of 
subscription  the  consumer  has.  Consumers  subscribing  to  unlimited  data  bundle  plans 
(i.e.  where  the  subscription  does  not  include  any  domestic  data  volume  limit)  will 
progressively benefit from higher allowances, in line with the lower wholesale caps (13). 

Fair use policies are fit for purpose, and surcharges beyond any fair use policy limits are 
only exceptionally applied 

FUPs are widely implemented by operators (80% of operators applied at least one of the 
FUP  measures  in  2024).  While  the  FUP  remain  commonly  applied  by  operators,  it  is 
worth noting that the majority of roaming customers never reach these limits (only 4.65% 
of roamers in Q3 2024), making the application of the surcharges beyond any FUP limits 
or measures exceptional.  

Since 2022, operators acknowledged the effectiveness of FUP mechanisms but the results 
from operators decreased in 2024. The reasons behind this evolution are not evident from 
the available data or the BEREC Opinion(14), and will be monitored by the Commission. 
Additionally,  the  technical  complexity  and  cost  of  some  FUP  measures  have  also  been 
highlighted  by  stakeholders.  However,  the  difficulties  to  implement  the  FUP  mainly 
affect  new  entrants,  as  most  existing  operators  have  already  implemented  FUPs  since 
2017.  

Surcharges imposed by  operators can apply  on the very rare occasions  when safeguard 
mechanisms are activated or users exceed the set fair use policies, but these surcharges 
are  limited  to  the  level  of  the  wholesale  caps.  As  described  above,  the  caps  follow  the 
decreasing glidepath set in 2022. As of 2025, the caps are set at EUR 1.30 per GB (and 
will further decrease to EUR 1 in 2027), EUR 0.003 per SMS, and EUR 0.019 per minute 
of call. 

Therefore,  the  FUP  measures  remain  fit  for  purpose,  striking  a  balance  between  the 
benefits  for  EU  consumers  on  the  one  hand,  and  the  sustainability  and  cost-recovery 
needs  of  operators  on  the  other,  without  prejudice  to  the  exercise  of  the  fundamental 
freedoms.  The  Commission  analysis  confirms  the  findings  of  the  2023  Review 
Report (15)  and  does  not  call  for  immediate  action.  It  should  be  noted  that  the 

(12)  If the FUP roaming data limit exceeds the domestic volume limit, the  domestic volume is the limit that applies. 
All  prices  and  caps  are  illustrative  and presented  solely  for  example.  The  FUPs  presented  are  the  results of  the 
formula applied. Application of the FUP depends on whether the subscription is considered an open data bundle 
or an unlimited data subscription. 

(13)  In  contrast,  consumers  of  other  open  data  bundle  plan  (i.e.  where  the  price  per  GB  included  in  the 
domestic  subscription  is  lower  than  the  regulated  wholesale  price)  would  not  benefit  from  increased 
data  allowance. In this case, the roaming customer will be able to consume  their  total domestic data 
volume even when roaming – as it is already the case. For the roaming customer, the lower wholesale 
price  will not lead to additional data  roaming volumes. The roaming provider is not obliged to offer 
more data roaming than the domestic data volume. 

(14)  BoR(25)48. 

(15)  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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Commission  continues  to  periodically  review  the  rules  on  fair  use  policy  as  provided 
under Article 7 of the Roaming Regulation. 

The  derogation  mechanism  is  acting  as  an  effective  safety  net  for  the  few  remaining 
operators requiring such measures 

Since  the  introduction  of  the  RLAH  rules,  the  sustainability  derogation  rules  have 
worked  effectively.  In  recent  years,  there  has  been  a  clear  decrease  in  the  number  of 
operators  in  need  for  derogations.  Since  2022,  no  mobile  network  operators  (‘MNOs’) 
have  requested  or  applied  for  sustainability  derogations(16).  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 
caps and the fact that, in some cases, the wholesale roaming charges effectively applied 
were even below the caps. 

However, for other operators such as  mobile virtual network operators (‘MVNOs’), the 
derogation  mechanism  is  still  used  and  is  useful  as  an  effective  safety  net.  It  allows 
operators  to  avoid  domestic  price  increases,  if  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 the Implementing Regulation (EU) 2016/2286 as a minimal condition for 
the  NRAs  to  grant  derogations,  has  not  hindered  the  sustainability  objectives  of  the 
derogations. 

RLAH does not affect domestic tariff price trends or structure  

Despite  increasing  volumes  of  roaming  traffic,  the  RLAH  regime  does  not  negatively 
impact the domestic tariff structure and price trends in EU/EEA countries.  

BEREC  data  shows  that  from  2019  to  2024,  the  Average  Revenue  Per  Paying  User 
(ARRPU)  has  remained  stable,  with  constant  prices  and  expanded  services,  like  larger 
data  volumes.  Increases  in  ARRPU  cannot  be  solely  linked  to  RLAH,  as  pricing  is 
affected by inflation and competition. BEREC observes a trend towards unlimited tariff 
plans and emphasises the importance of FUP for sustaining RLAH.  

NRAs and BEREC cannot accurately assess the Roaming Regulation's effects on national 
markets  due  to  the  dynamic  nature  of  these  effects.  They  cannot  determine  which 
changes  on  the  national  market  are  caused  by  the  roaming  intervention  versus  other 
factors. BEREC has found no evidence of mobile providers exiting the market because of 
Roaming Regulation obligations. 

The  findings  of  the  2017-24  study  “Mobile  Broadband  Price  in  Europe” (17)  confirm  a 
downstream trend in prices across the EU following the implementation of RLAH. The 

(16)  In 2024, only 9 MVNOs were granted a sustainability derogation.  

(17)  Empirica’s  studies  apply  the  minimal  normalised  prices  in  euro  (€/purchasing  power  parity)  across 
each EU Member State for a collection of baskets. The details regarding the consumption included in 
each analysed basket can be found in Section 3 (Methodology) 

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prices for the least expensive offers for all mobile baskets assessed decreased by 19-86% 
on average between 2017 and 2024. 

Only a small percentage of users subscribe to the domestic-only tariff plans. The BEREC 
opinion  indicates  that  the  average  share  of  domestic-only  tariffs  within  the  EU/EEA 
using roaming-enabled SIM cards has declined from 4.4% to 3.2% between Q4 2021 and 
Q3 2024. As of Q3 2024, the percentage of subscribers on domestic-only tariffs is 3% for 
MNOs and 2% for MVNOs.  

Use  of  alternative  tariffs  follows  a  consistent  downward  trend.  Despite  one-third  of 
operators offering alternative tariffs, in Q3 2024 the proportion of roaming call minutes 
made  within  the  EEA  by  subscribers  on  alternative  tariffs  was  5.5%,  while  the 
corresponding data usage share was 4.2%. According to BEREC, in Q3 2024 an average 
of 4.17% EEA roaming enabled customers were subscribed to an alternative tariff. 

Overall, this shows that the RLAH regime has brought benefits to EU residents without 
impacting the tariff structure at the national level, further confirming the success of the 
RLAH initiative.  

Extension of “roam-like-at-home” benefits beyond EU borders 

The benefits of the RLAH policy for consumers are so visible that several regions outside 
the  EU  have  decided  to  introduce  measures  to  lower  roaming  charges  in  cross-border 
settings.  In  the  Western  Balkans,  a  regional  RLAH  regime  has  been  established  since 
2021. 

The Roaming Regulation encourages initiatives that aim to lower the roaming charges for 
roaming services between the EU and third countries on a reciprocal basis. Beyond the 
economic benefits, it also seems that in certain cases, especially for citizens of candidate 
countries, being able to freely use mobile devices while periodically travelling in the EU 
represents has a symbolic value of belonging to the “EU family”. 

The EU has already made steps towards extending the RLAH area to countries within the 
EEA and lately also to some candidate countries. The extension of Roam-Like-at-Home 
benefits  to  non-EU  countries  requires  these  countries  to  incorporate  the  so-called  “EU 
roaming acquis”  in  their  national  law. The  “EU roaming acquis” includes  the Roaming 
Regulation,  Commission  Implementing  Regulation  (EU)  2016/2286 (18),  Commission 

(18)  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  EU  L  344,  17.12.2016,  p.  46,  ELI:  https://eur-
lex.europa.eu/eli/reg_impl/2016/2286/oj). 

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Delegated  Regulation  (EU)  2021/654 (19),  as  well  as  certain  provisions  of  Regulation 
(EU) 2018/1971 (20) and of Directive (EU) 2018/1972 (21). 

Ukraine and Moldova have progressed well on the path towards joining  the EU RLAH 
area.  Ukraine  has  fully  aligned  with  EU  roaming  legislation,  and,  on  this  basis,  the 
Commission proposed to the Council the inclusion of Ukraine into the EU RLAH area, 
with a transition period for the operators to adapt. This 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. 

The  Commission  is  exploring  legally  viable  solutions  to  extend  the  RLAH  area  to  the 
Western Balkans, as follow-up to the Western Balkan Growth Plan. In parallel, operators 
in Ukraine (22), Moldova (23) and the Western Balkans (24) have voluntary arrangements 
in place with some EU operators for lowering roaming charges. 

Rest of the world roaming  

To  keep  track  of  potential  increases  in  roaming  rates  outside  the  EU/EEA,  BEREC 
collects  data  for  its  International  Roaming  Benchmark  Reports.  No  indications  were 
found of increase in non-EEA roaming prices after the implementation of RLAH. In fact, 
operators  report  a  general  trend  of  declining  average  retail  prices  for  roaming  services 
outside the EU/EEA.  

Between Q4 2020 and Q3 2024, operators indicated that their average retail rates for data 
roaming  in  the  “rest  of  the  world”  decreased  from  EUR  10.87/GB  to  EUR  5.16/GB, 
while  the  prices  for  calls  received,  calls  made  and  SMS  messages  saw  a  more  gradual 

(19)  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 
(OJ EU L 137, 22.4.2021, p. 1, ELI: https://eur-lex.europa.eu/eli/reg_del/2021/654/oj). 

(20)  Regulation  (EU)  2018/1971  of  the  European  Parliament  and  of  the  Council  of  11  December  2018 
establishing  the  Body  of  European  Regulators  for  Electronic  Communications  (BEREC)  and  the 
Agency for Support for BEREC (BEREC Office), amending Regulation (EU) 2015/2120 and repealing 
Regulation (EC) No 1211/2009 (OJ L 321, 17.12.2018, p. 1–35).  

(21)  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. 

(22)  The EU-Ukraine voluntary agreement for affordable or free roaming and international calls was signed 

in April 2022, https://ec.europa.eu/commission/presscorner/detail/en/ip_22_2371. 

(23)  The Joint Declaration by EU and Moldovan mobile operators to reduce roaming charges was signed in 
May  2023,  https://digital-strategy.ec.europa.eu/en/library/joint-declaration-eu-and-moldovan-mobile-
operators-reduce-roaming-
charges#:~:text=Thanks%20to%20the%20declaration%2C%20from,tariffs%20and%20data%20roami
ng%20tariffs.  

(24)  The  EU-Western  Balkan  roaming  declaration  was  signed  in  December  2022,  https://neighbourhood-

enlargement.ec.europa.eu/system/files/2022-12/eu-wb-roaming-declaration.pdf.  

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drop (25).  Despite  this  positive  declining  trend,  some  consumer  complaints  received  by 
NRAs indicate that there are still occasionally problems with very high charges billed to 
consumers  roaming  outside  the  EU,  especially  when  they  do  not  benefit  from  special 
arrangements (add-ons, special offers, holiday packages). 

Finally, it should be noted that following Brexit, most of the main MNOs in the United 
Kingdom have reintroduced retail surcharges for roaming in the EU for their customers, 
showing  how  relevant  the  current  RLAH  regime  is.  The  Commission  also  welcomes 
initiatives  from  many  EU  operators  to  maintain  favourable  conditions  and  preserve 
roaming  without  surcharges  within  the  United  Kingdom  for  their  subscribers,  to  the 
benefit of European consumers. 

2.3. Wholesale roaming market 

Wholesale roaming prices have been steadily falling 

As presented in the accompanying SWD, the average EEA wholesale roaming prices for 
data services dropped from 2.2 EUR/GB in 2018 to 1.3 EUR/GB in 2021, representing a 
decrease of 41%. This decrease aligns with the reduction of the regulated wholesale data 
cap,  which  was  lowered  in  the  same  period  from  6  EUR/GB  in  2018  to  3  EUR/GB  in 
2021 (26).  

The recast Roaming Regulation in 2022 established a new glidepath to further lower the 
wholesale caps, setting it at 2 EUR/GB in 2022,1.8 EUR/GB in 2023 and 1.55 EUR/GB 
in 2024 for data roaming services. These reductions in the regulated wholesale caps were 
reflected in the actual applied wholesale prices, which decreased to 0.7 EUR/GB in Q3 
2024.  This  represents  a  reduction  of  50%  compared  to  the  wholesale  prices  of  1.3 
EUR/GB that were actually applied in Q3 2021 (27). 

For roaming voice services, the regulated wholesale caps have decreased gradually from 
3.2 EUR cents/min in 2017 to 2.2 EUR cents/min in 2022 (28). Despite this steady glide 
path,  the  actually  applied  prices  have  been  progressively  declining  over  the  past  five 
years. Prices dropped from 2.14 EUR cents/min in Q2 2018 to 1.97 EUR cents/min in Q2 
2021, representing a decrease of 8%. By Q3 2024, the prices had further decreased to 1.3 
EUR cents/min, marking a 34% reduction compared to the 2021 value. 

The decline in  wholesale roaming prices was primarily driven by several  factors. First, 
new and progressively decreasing maximum wholesale roaming prices introduced in the 
2017 roaming regulation, along with further cap reductions introduced in the 2022 recast 
of the Roaming Regulation, have set increasingly lower caps for  wholesale prices. This 
triggered  competitive  market  dynamics  among  operators  offering  wholesale  roaming 
access below those caps.  

(25)  A  comparison  of  the  period  from  Q4  2022  to  Q3  2023  for  calls  and  SMS  reveals  a  slight  increase, 
which  is  attributed  to  a  methodological  change  implemented  in  2021  concerning  roaming,  which 
reclassified  UK  providers  (at  the  wholesale  level)  and  UK  subscribers  (at  the  retail  level)  from  the 
‘EEA’ group to the ‘Rest of World’ (RoW) category, impacting roaming prices for the UK.  

(26) Further wholesale roaming caps introduced in the 2022 Roaming regulation are 1.55 EUR/GB in 2024, 

1.3 EUR/GB in 2025, 1.1 EUR/GB in 2026 and 1 EUR/GB from 2027 onwards. 

(27)  30th  BEREC  International  Roaming  Benchmark  Data  and  Monitoring  Report,  BoR  (24)  38,  March 

2024. 

(28)  From 2025 onwards, the wholesale cap for voice roaming services is set at 1.9 EUR cent/min. 

9 

 
 
Second, the implementation of RLAH led to a substantial increase in roaming volumes, 
as  demonstrated  in  the  first  section.  In  this  context,  operators  increasingly  offer  price 
discounts  based  on  roaming  traffic  volumes,  a  practice  that  has  further  pushed  down 
wholesale  roaming  prices  below  the  regulatory  caps.  The  combination  of  increased 
volumes and volume-based pricing incentives has intensified competition, further driving 
wholesale roaming prices down in a highly competitive market environment. 

The Commission welcomes these market dynamics that can lead to improved and stable 
functioning  of  the  roaming  markets.  Such  market  trends  can  contribute  to  a  more 
dynamic  and  beneficial  wholesale  roaming  market  but  will  require  further  observation 
and assessment.  

Finally,  the  evolution  of  5G  technology  has  significantly  reduced  the  general  costs  of 
providing  network  services,  enabling  operators  to  offer  even  lower  wholesale  roaming 
rates.  Together,  these  factors  have  prevented  adverse  effects  of  RLAH  on  outbound 
operators. 

The new cost model indicates economic potential for further reductions in the wholesale 
caps 

The Commission has published an external study to build a cost model for an efficiently 
operating  mobile  network  in  each  EU/EEA  country (29).  The  estimates  that  can  be 
inferred from the model and from additional transit price data provided by operators (30) 
show that the caps on wholesale roaming prices set in the Roaming Regulation in 2017, 
along  with  further  cap  reductions  introduced  in  the  2022  recast  of  the  Roaming 
Regulation, have allowed a full recovery of costs at wholesale level plus margin.  

The  reduction  in  wholesale  roaming  prices,  whereby  average  wholesale  market  prices 
have  continued  to  undershoot  the  declining  regulated  maximum  wholesale  tariffs, 
demonstrates that operators have been able to meet the increasing demand in wholesale 
roaming services while at the same time recovering the cost of their network investment, 
including the cost of capital.  

Based on the Commission’s external study, BEREC assessed that there is some economic 
space for further reducing the wholesale caps while keeping them above the underlying 
costs in all Member States and including some space for negotiations below the caps.  

The Commission will consider these inputs in its assessment of the wholesale caps. The 
Commission will also consider the impact of the extension of the RLAH area to countries 
outside the EU, as described above. 

Specific  situation  of  mobile  virtual  network  operators  (MVNOs)  on  the  wholesale 
roaming market 

by 

(29)  Study  CNECT/2022/OP/0065  'Assessment  of  the  cost  of  providing  mobile  telecom  services  in  the 
https://digital-

EU/EEA' 
strategy.ec.europa.eu/en/library/finalisation-mobile-cost-model-roaming-and-delegated-act-single-eu-
wide-mobile-voice-call-0. Latvia, Lithuania, Estonia, Netherlands, Iceland and Liechtenstein have not 
provided  the  necessary  data  to  build  the  model  in  these  countries.  The  study  was  run  in  close 
collaboration with NRAs and BEREC. 

December 

available 

AXON, 

2024, 

(30)  The  cost  model  and  its  outputs,  as  well  as  estimates  of  transit  prices,  are  presented  in  the 

accompanying staff working document. 

10 

 
 
Due  to  their  specific  nature (31),  MVNOs  cannot  accommodate  roaming  traffic  from 
foreign  MNOs  in  exchange  for  the  roaming  traffic  they  send  to  those  MNOs.  Instead, 
they  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 recognised by BEREC in 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.  This  is  further  described  in  the 
accompanying SWD to this report.   

Quality of service 

Since  2022,  the  Roaming  Regulation  lays  down  new  and  clarified  QoS  obligations  at 
retail and wholesale level. At retail level, roaming providers have to ensure that roaming 
customers have at least the same quality of the 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,  to  be  able  to  provide  the  QoS 
level that they normally provide for 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  deployment  it  is 
expected that the discrepancies explained below in terms of QoS between domestic and 
roaming  services  will  gradually  decrease.  The  Roaming  Regulation  includes  a  level  of 
flexibility for roaming services to catch up with gradual technological developments.  

In its Opinion, BEREC does not identify any issue with the QoS provisions and considers 
them  to  be  fundamental  to  the  functioning  of  the  RLAH  principle.  NRAs  have  not 
reported any disputes between roaming providers (access  seekers and access  providers) 
concerning QoS, either on regulated roaming services or on Machine-to-Machine (M2M) 
roaming services.  

Stakeholders who contributed to the call for input to the BEREC Opinion consider that 
the  obligations  regarding  QoS  rules  are  effective  in  ensuring  that  roaming  customers 
benefit from same QoS as domestically. Some operators have expressed concerns about 
discriminatory  practices.  BEREC  confirms  that  QoS  is  an  issue  that  requires  ongoing 
monitoring  and  may  necessitate  further  attention  and  review  in  the  future,  as  well  as 
identifying the factors that contribute to variations.  

In  the  2023  Review  Report,  the  Commission  presented  detailed  findings  on  QoS. 
According to the findings, approximately 1 out of 4 consumers have experienced lower 
quality  with  their  roaming  service  than  what  they  usually  have  at  home,  such  as  lower 
speeds and different network generation.  

(31)  An  MVNO  operates  without  owning  a  radio  access  network  in  the  country  or  countries  where  it 

provides services. 

11 

 
 
The 2025 Eurobarometer survey confirms that roaming customers continue to experience 
differences between their domestic and roaming QoS. 1 in 3 of the respondents who had 
travelled in the past two years (11% of total respondents to the survey) have experienced 
lower mobile internet speeds compared to what they usually have domestically. Almost 1 
in  3  of  the  respondents  have  experienced  a  lower  broadband  standard  compared  to 
domestically. 

BEREC  confirms  that  QoS  is  one  of  the  categories  where  the  fewest  consumer 
complaints are received (3%).  

The  2025  QoS  study(32,)  conducted  by  the  contractor  Mozark  for  the  Commission, 
brought more accurate data on that topic. The study finds that for download speeds, 76% 
of  roaming  end  users  do  not  enjoy  the  same  performance  as  they  do  on  their  home 
network and in  80%  of the cases  the download speeds were  lower than the  ones  of the 
local  subscribers  of  the  visited  network.  Results  are  slightly  better  for  upload  speeds, 
where in 63% and 68% of the cases, roaming customers had lower speeds compared to 
their  home  network  and  the  visited  network,  respectively.  Performance  in  terms  of 
latency was also worse for roaming users compared to both their home network (in 92% 
of the cases) and the visited network’s end users (in 90% of the cases).  

A  further  analysis  of  the  cases  where  roaming  performance  was  poorer  than  at  home 
shows that 84% experienced lower download speeds and 78% lower upload speeds than 
the performance usually  offered by the visited network.  In 91% of the  cases  where  the 
latency of a roaming user was worse than the home network, it was also worse than the 
latency in the visited network. 

On  the  other  hand,  17%  of  the  roaming  end  users  experienced  better  download  speeds 
than  the  home  network  and  30%  better  upload  speeds.  When  compared  to  the  visited 
network, roamers outperformed download speeds in 14% of the cases and upload speeds 
in 24% of the cases. Latency for roaming end-users was better in 4% of the cases when 
compared  to  the  latency  of  the  home  network,  and  3%  when  compared  to  the  visited 
network. 

When  it  comes  to  generation  of  cellular  network  technology,  the  2025  QoS  study 
concludes that roaming end users were able to access 5G technology in over 70% of the 
test instances.   

These results can be attributed to several factors, either technical or commercial. To get a 
better  overview  of  the  potential  problems,  it  would  be  necessary  for  NRAs  to  monitor 
and assess QoS practices by operators.  

2.4.  Market and technological developments  

5G deployments in Europe had a positive impact on roaming 

The  2025  Digital  Decade  report  shows  that  5G  coverage  reached  94.35% (33)  of  EU 
territory  in  2023.  This  technological  evolution  has  been  taken  into  account  by  the 
Commission in its assessment of the roaming markets.  

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

(33)  The  KPI  used  for  the  5G  target  does  not  take  into  account  quality  of  service,  and  therefore  most  of  the 
current 5G deployment can be categorised as “basic 5G”. "Stand-alone" 5G, which provides high reliability 

12 

 
 
 
At  retail  level,  the  recast  of  the  Roaming  Regulation  in  2022  aimed  to  ensure  that  EU 
consumers can directly benefit from the development of 5G networks while travelling in 
the  EU.  EU  users  roaming  in  the  EU/EEA  should  enjoy  the  same  quality  of  service, 
including mobile network generations and technologies, as in their home country. 

5G  technology  provides  networks  with  better  performance  and  easier  characteristics 
when it comes to speed, latency and virtualisation. The emerging “network slicing” is an 
important  technological  development  enabled  by  5G,  introducing  new  use  cases.  Up  to 
now  5G  slicing  solutions  have  not  been  adopted  massively  in  the  market,  neither  are 
there any indications that it is expected to be used in the near to mid-term future. This is 
also confirmed by BEREC in their Opinion, which notes that it is still premature to assess 
the impact of such developments on traditional roaming services. In terms of impact on 
new or innovative roaming services  and substitutes to  roaming, 5G has not  contributed 
significantly to a change of the roaming landscape.  

At wholesale level, the cost model demonstrates that the implementation of 5G standards 
has  led  to  a  significant  decrease  in  unit  cost  when  identifying  a  hypothetical  “efficient 
operator”. In concrete terms, this suggests that operators investing in 5G will be able to 
reduce their costs and become more competitive in the market. The overall sustainability 
of RLAH has  increased  since the reduction  in the cost  of providing wholesale roaming 
services  has  led  to  a  reduction  of  wholesale  prices  paid  by  visiting  operators.  This 
reduction  in  prices  does  not  seem  to  have  been  offset  by  an  equivalent  increase  in  the 
roaming volumes facilitated by 5G deployment. 

There  is  currently  no  compelling  evidence  supporting  the  need  to  regulate  permanent 
roaming for machine-to-machine (M2M)/internet of things (IoT) connectivity 

In  principle,  M2M/IoT  use  cases  are  subject  to  the  application  of  average  wholesale 
roaming caps and the fair use policies.  

However, permanent roaming for M2M/IoT use cases is subject to wholesale commercial 
negotiations,  while  operators  are  expected  to  increasingly  conclude  permanent  roaming 
agreements for this purpose (34). 

Regulation (EU) 2022/612 aims (35) to facilitate roaming for M2M/IoT use cases, since 
this  is  “an  important  driver  for  digitising  the  EU’s  industry”  and  indicates  that  the 
measures  facilitating  roaming  for  M2M/IoT  use  cases  “should  build  on  related  EU 
policies in sectors such as health, energy, environment and transport”.  

and low latency and is crucial for enabling advanced features, is still not deployed on any meaningful scale, 
except  in  a  very  few  cases  of  private  networks.  Meanwhile,  5G  coverage  in  the  3.4-3.8  GHz  band, 
considered the primary pioneer band for 5G in the  EU – and the only available mid-band on a large scale 
that offers a good balance between coverage and capacity – stands at 67.72% in 2024. 

(34)  Recital 22 of Regulation (EU) 2022/612: “[…] However, permanent roaming is subject to commercial 
negotiations and can be agreed by two roaming partners in a wholesale roaming agreement. In order to 
allow  the  development  of  more  efficient  and  competitive  markets  for  machine-to-machine 
communications, it is expected that mobile network operators will increasingly respond to and accept 
all  reasonable  requests  for  wholesale  roaming  agreements  on  reasonable  terms  and  explicitly  allow 
permanent roaming for machine-to-machine communications.” 

(35) In this respect, see recital (68) of Regulation (EU) 2022/612. 

13 

 
 
The roaming connectivity for M2M/IoT use cases raised questions  about the possibility 
of  changing  the  regulatory  approach  for  the  IoT  (beyond  periodic  travelling)  and  the 
possible  need  to  further  facilitate  machine-to-machine  roaming  and  internet-of-things 
roaming.  

The Commission has assessed the evolution of the connectivity market for M2M/IoT use 
cases  (see  the  SWD  for  detailed  analysis),  finding  a  generally  effective  competitive 
environment with both direct and indirect competitive constraints on the possible market 
power of roaming connectivity providers.  

Providers  of  M2M/IoT  use  cases  have  easy  access  to  permanent  roaming  connectivity 
solutions,  with  EU  coverage,  and  at  relatively  low  retail  prices  per  connected  device. 
Consequently, at this stage, there is no compelling evidence for regulatory intervention as 
regards permanent roaming connectivity conditions for M2M/IoT use cases.  

However, MVNOs reported that at least some of the MNOs with a strong national market 
position  have  put  in  place  potentially  restrictive  wholesale  practices  for  permanent 
roaming,  such  as  exclusive  roaming  access  agreements  or  hard-to-achieve  minimum 
purchasing  service  volumes,  as  a  (pre)condition  for  concluding  permanent  roaming 
agreements. For more detailed analysis of these issues, see the SWD.  

The Commission will continue to monitor the development of the M2M/IoT market and 
the Roaming Regulation’s adequacy for its specific needs.  

14 

 
 
 
Other technological developments  

In  the  2019  review  report (36)  the  Commission  assessed  the  impact  of  technological 
development on the roaming market. The assessment particularly looked at the impact of 
OTT services, Wi-Fi, eSIM and 5G. The Commission concluded that these technologies 
do  exert  some  competitive  pressure,  but  it  is  not  sufficient  to  change  the  competitive 
landscape  of  roaming  services.  In  this  review,  the  Commission  is  revisiting  that 
assessment.  

Technological developments that may affect regulated roaming can generally be divided 
into two main categories: (i)  those that enable end-users to  bypass  roaming (e.g. Wi-Fi 
and  Wi-Fi  aggregation,  OTT  services,  as  well  as  low  earth  orbit  (LEO)  satellite 
communications)  and  (ii)  those  that  enable  other  players  to  come  into  play  and  offer 
roaming services (e.g. eSIMs and 5G slicing). 

Each  type  has  certain  advantages,  but  none  appear  to  be  a  concrete  substitute  for 
regulated roaming services under the RLAH regime, neither are they exerting significant 
competitive  pressure.  In  its  Opinion,  BEREC  considers  that  the  various  technologies 
which could aspire to be substitutes for roaming services are only seen as complementary 
or specific to projects with well-defined terminal characteristics. While eSIMs could put 
some pressure on operators, they are currently mostly used for RoW roaming. 

For Wi-Fi, its increased availability and ease of use is counterbalanced by the lack of full 
coverage, as well as by the big advantages of 5G-increased quality and the flexibility of 
RLAH, that allows users to benefit from their domestic subscriptions. At the same time, 
5G slicing has not gained significant importance yet and has not been used extensively.  

OTTs  seem  to  be  gaining  in  importance  for  both  domestic  and  roaming  traffic,  but  the 
impact  specifically  on  roaming  cannot  be  regarded  as  a  step  change,  while  eSIMs  –  at 
least for the near future – will not impact roaming. The fact that an eSIM-based solution 
may  in  some  cases  require  the  user  to  change  mobile  number  while  roaming  is 
considered a major drawback.  

The eSIMs solution also requires extensive cooperation between different parties in the 
value  chain,  including  device  manufacturers,  MNOs,  MVNOs  and  consumers.  Despite 
their  significantly  increased  number,  eSIMs  are  expected  to  play  a  role  in  ‘rest  of  the 
world’ roaming rather than in a RLAH environment.  

LEO  satellites  may  offer  full  EU/EEA  coverage,  but  the  solutions  are  still  not  widely 
available for end-users. 

Finally, online trading platforms, although available, are only used by a limited number 
of  operators.  Consequently,  their  limited  reach  prevents  them  from  being  effective  in 
reducing  wholesale  prices  to  an  extent  sufficient  to  justify  lifting  the  regulatory 
obligations under the Roaming Regulation. 

Having  considered  the  above,  the  Commission  considers  that  there  will  be  no 
short-to-medium-term  technological  developments  that  would  seriously  act  as  a 

(36)  Commission Staff Working Document accompanying the Report from the Commission on the review 

of the roaming market (SWD(2019)416 final). 

15 

 
 
competitor  or  substitute  to  the  currently  applicable  RLAH  regime,  or  that  would  exert 
sufficient competitive pressure to make the current regime irrelevant.  

Therefore,  the  regulatory  measures  imposed  appear  to  still  be  appropriate  and  fit  for 
purpose in the current context. 

3.  Conclusion 

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. 

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.  

16