Roaming Regulation

- MVNO Europe welcomes the EC’s proposal to prolong the Roam-Like-At-Home Regime; - MVNO Europe nevertheless considers that the wholesale caps proposed by the Commission are disconnected from market reality and need to be further reduced to allow for a more competitive regime; - More acceptable caps for data would be 0.75 EUR/GB for 2022, 0.50 EUR/GB for 2023, 0.25 EUR/GB for 2024 with a cost-based review in 2025…

1) Introduction APRITEL, the association that represents the Portuguese electronic communications services operators, welcomes the opportunity to comment on the Commission’s adoption of the review and prolongation of the Roaming Regulation. This document presents the comments and views of our associates regarding such proposals.

The EC adopted a legislative proposal amending the Roaming Regulation. It extends and amends many of Regulation´s material provisions, first and foremost wholesale caps. It introduces the obligation for network operators to offer end customers roaming services under the “same conditions as … domestically, in particular in terms of quality of service” as well as the obligation to offer other network operators access…

Telefónica welcomes the opportunity to comment on the EC’s adopted act on the review and prolongation of the roaming regulation. Due to the format limitations for the feedback, more information is provided in the attachment. The reduction of more than 20% of the price caps is clearly disruptive, particularly under the current circumstances.

We welcome the revision and recast of the RLAH regulation and the lifting of certain regulatory obligations providing for more clarity. However, the RLAH proposal presents some critical issues concerning the value of the wholesale caps for data and voice and the inclusion of certain provisions concerning quality of service, value-added services and access to emergency services that could generate more costs and…

Dear Sir, Madam, Please see attached the ETNO contribution to the review of the Roaming Regulation. Could you please acknowledge receipt of the contribution? Should you have any questions on our submission, please don’t hesitate to get in touch. Kind regards, [name removed]

Good afternoon, Please find attached GIGAEurope's response to the Public Consultation on Adoption of the Review and Prolongation of the Roaming Regulation. Please do not hesitate to contact us for any details or clarification in relation to our response. Sincerely yours, [name removed] Managing Director GIGAEurope

TIM welcomes the possibility to express its views on the recent Commission’s proposal for recast of the Roaming Regulation, extending the Rome Like at Home (RLAH) regime and introducing several additional measures. In particular, TIM wishes to comment on the following particularly relevant aspects: 1.

Liberty Global welcomes the opportunity to provide feedback on the European Commission’s proposal for an extension of and revisions to the Roaming Regulation. Below is a summary of our positions - our full position is attached. We consider that the wholesale roaming markets are functioning well and that the current caps have been effective as a backstop in the negotiation of wholesale roaming rates.

The Estonian Information Technology and Telecommunications Association (ITL), representing Estonian ICT companies and organisations, presents a proposal for an amendment to the Regulation of the European Parliament and of the Council COM(2021) 85 final on roaming on public mobile communications networks within the Union (hereinafter: Proposal for a Regulation), the following comments and positions: 1.

Filed in Estonian · English published by the European Commission

Orange considers that while some adjustments could be introduced to the Roaming Regulation, there is no justification for additional or new type of intervention, especially regarding the wholesale caps. The Roam Like At Home has been a great success for EU citizens and has been delivered by Mobile operators under the current Regulation thanks to the efficient functioning of the wholesale market.

Telenor Bulgaria EAD (“Telenor Bulgaria”) welcomes the overall approach taken in the legislative proposal for amending the Roaming regulation (EU) No 531/2012 (“The Proposal”) to step on the achievements of current act without significant amendments, while eliminating unnecessary and not working solutions such as the obligation for the separate sale of regulated retail roaming services, the so called “ local data…

WIND Hellas welcomes the revision and codification of the European roaming regulatory framework as well as the lifting of certain regulatory obligations, such as the separate sale of regulated roaming data services.

We support option 3 as proposed in the working document of 24.02.2021 as a solution, but compulsorily supplemented with economic measures to strengthen competition from option 2. Strengthening competition is absolutely necessary, especially since a MVNO still cannot offset the costs arising from outgoing roaming traffic against incoming costs.

In light of the importance of sustainable mobile roaming rules for European consumers and businesses, MVNO Europe welcomes the opportunity offered by the European Commission to stakeholders to comment on its inception impact assessment concerning the review of the Roaming Regulation - Ares(2020)2005722.

No reduction of Wholesale rates. We are convinced that even if the Commission decides to keep wholesale regulation, the caps should stay at the 2022 level and not be further reduced. The information gathered by the Commission and BEREC throughout the last years clearly shows that commercially agreed discounts bring WS rates to significantly below the regulated caps.

eir has a number of preliminary comments in relation to the Commission’s initiative and some of the issues raised within the roadmap. Transparency on Quality of Service (QoS) and Roam-Like-At-Home quality eir agrees that there has been a rapid increase in roaming consumption and as noted by the Commission’s November 2019 report on the implementation of the Roaming Regulation, there is a high level of general…

We are concerned that the Commission does not intend to review Regulation 2286/2016 and wishes to maintain the RLAH rule beyond 2022. the mechanisms contained therein need to be improved — not to address the problems arising from the application of RLAH to low-cost ‘no limit’ packages in Poland. The observation mechanism (Article 4.4) — the rate of predominant use is not an objective one.

Filed in Polish · English published by the European Commission

ETNO welcomes the European Commission’s (hereinafter ‘’the EC’’) initiative to consult stakeholders on the inception impact assessments of the Roaming Regulation review. Since the Regulation entered into force, EU roaming markets have evolved substantially. The competition dynamics based on commercial negotiations are important elements of the market evolution.

Dear Madam/Sir, BEUC – The European Consumer Organisation welcomes the opportunity to comment on the European Commission’s inception impact assessment to extend and review the current EU roaming rules, as appropriate. Please find attached BEUC's response to the consultation. We thank you in advance for your time and consideration. Best regards, [name removed], on behalf of BEUC

The GSMA’s preliminary remarks on the current roaming market and on specific items mentioned by the EC with regards to the possible revision of the roaming Regulation: Functioning of the roaming market in the EU The regulation of roaming services in the EU is one of the most intrusive regulatory measures undertaken in the mobile market.