ETNO response to the Public consultation on the review of national wholesale roaming markets, fair use policy and the sustainability mechanism referred to in the Roaming Regulation 531/2012 as amended by Regulation 2015/2120

Read the full questionnaire here

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Question 36: What are the risks associated with permanent roaming for a mobile operator, if any? Please explain your response and provide examples:

Each MNO manages its network on the domestic side with full control of its quality and performance according to its customer base size, strategy and offers. All MNOs welcome visiting roamers in general as long as there is no risk associated to this traffic. MNOs distinguish between business and technical risks and following non-exhaustive examples can be given:

Business risks:

- Frauds, misuse or abnormal usage that lead to loss/higher costs especially on voice.
- Bypass of EU regulation by Rest of World MNOs willing to benefit from the EU Roaming Regulation for their own non-EU customers, while they would not provide the same benefit in return to EU customers/MNOs.

Two potential national market distortions:
1) Domestic market disruption: when in a given country a non-domestic MNO delivers retail offers that target the domestic market, but based on roaming. This is the main risk especially for data services, since it is totally transparent in terms of customer experience.

2) When home operators, with low domestic prices, have other countries’ customers buying SIMs in their own countries and thus create very low domestic revenues for that operator.
Both of these potential disruptions will impact network investment incentives.

Technical risks:
- Quality of service,
- Network congestion,
- Degraded service for domestic customers due to roaming, etc.

The difficulty is to ascertain the difference between unwanted permanent roaming and agreed permanent roaming.

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Read the full questionnaire here