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© Cullen International SA 2015
The regulation of roaming
Peter Dunn – Cullen International
BICS Mobility in Action 2015
Antwerp, September 21-23, 2015
© Cullen International SA 2015
An amazing service!
Making calls:
convenience, home bill
Receiving calls:
using your normal number
Access to data services:
without extra subscription
© Cullen International SA 2015
Roaming regulation worldwide
ITU-T D.98
(transparency and market-based solutions)
© Cullen International SA 2015
EU approach has evolved over time
Market review
– market 15
First Roaming
Regulation
Roaming
Regulation II
Competition law
– sector enquiry
June 15, 2017
2000 2017 2015 2012 2009 2007 2003
Roaming
Regulation III
Telecoms Single Market
Regulation
failure to address
price controls
ABOLITION
© Cullen International SA 2015
Lessons to learn?
Think which issues could become
politically “interesting”
fight / defend
or just walk back slowly?
© Cullen International SA 2015
Implementation in practice
Uncertainty dampens investment
and can be highly costly
Get creative - alternatives and ways around
the regulation normally exist!
© Cullen International SA 2015
Regulation of roaming is seldom a policy issue – it’s political
Different types of regulation apply worldwide
• but beware of a trend to abolish roaming surcharges
In the EU, the regulation of roaming has evolved over time
• attempts to use existing tools failed
• price caps and transparency were applied
• de-coupling was (nearly) attempted to find a structural solution
• finally, political patience ran out
Have a regulatory strategy that recognises upcoming political issues
Avoid uncertainty, look for loopholes
Summary
© Cullen International SA 2015 14 14
Cullen references
Trackers on EU roaming regulation
EU Roaming Regulation
Telecoms Single Market Regulation
Reports on the TSM debates
Flash on Council position of June 2015
Flash on TSM agreement
Legislation
Roaming III Regulation
TSM compromise text