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MVNO Europe

MVNO Europe

MVNO Europe was created to represent the interests of companies which are active on the European mobile and IoT markets and independent, in terms of ownership and control, from established mobile network operators.

Lobbying Activity

Meeting with Peter Stuckmann (Head of Unit Communications Networks, Content and Technology)

28 Oct 2025 · Exchange of views on the upcoming Digital Networks Act

Response to Digital Networks Act

11 Jul 2025

Please find MVNO Europes detailed response in the attached document. A key element of MVNO Europes feedback, based on the very nature of its membership, is that MVNOs - already today - successfully develop their activities within Member States as well as across Member State boundaries. MVNOs expect to be able to continue to do so under improved conditions in application of the Digital Networks Act, and not to be faced with measures that result in the pursuit of scale at the expense of competition. Simplification of EU legislation is welcome, notably the conditions attached to authorisations and preventing the extension of consumer protection rules to business customers, facilitating the creation of a true Single Market for consumer, B2B, IoT and Connected Vehicle Connectivity services, and more generally recognising MVNOs as a vector of competition. Spectrum assignment procedures and wholesale access regulation must continue to provide an explicit path towards mandating fit-for-purpose wholesale mobile access. MVNO Europe considers that mandated wholesale mobile access is a precondition for consolidation between mobile network operators. MVNO Europe also wishes to emphasise that in the absence of fit-for-purpose wholesale access, there can be no realistic expectation of achieving an EU Single Market for electronic communications.
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Response to Impact assessment on retention of data by service providers for criminal proceedings

18 Jun 2025

Please find the feedback in the document attached.
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Response to International Digital Strategy

19 May 2025

Please find the feedback in the document attached.
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Meeting with Jörgen Warborn (Member of the European Parliament, Shadow rapporteur)

14 Apr 2025 · Digital infrastructure

Response to How to master Europe’s digital infrastructure needs?

28 Jun 2024

MVNO Europe is the trade association representing Mobile Virtual Network Operators: http://mvnoeurope.eu/ MVNOs currently supply +/- 10% of SIM cards in the European Union to millions of consumers, many thousands of small and medium sized enterprises (SMEs), and supporting Internet of Things (IoT), for millions of connected cars and trucks, for shipping, transport and containers, for security applications, and for many other types of enterprise communications requirements. Please find a paper attached, in which MVNO Europe provides its feedback on the European Commission's White Paper, with a focus on the suggestions contained in Pillar II. MVNO Europe considers that any envisaged policy changes, legislative proposals, or other measures need to be associated with strong safeguards to preserve and promote competition. Our paper highlights that it is essential to maintain and enhance pro-competitive conditions associated with the licensing of scarce radio spectrum contained in Article 52(2) of the EECC, making it expressly obligatory for the authorities granting radio spectrum licences (be they national or European) to give adequate and reasoned consideration to the appropriateness of imposing wholesale access obligations to networks utilizing radio spectrum. We also provide detailed suggestions on replacing the spectrum peer review process created by Article 35 of the EECC with a more adequate mechanism. Overall, MVNO Europe considers that the European Commission's White Paper does not contain persuasive arguments for an overhaul of the European Electronic Communications Code (EECC), for the urgent adoption of an EC legislative proposal for a potential Digital Networks Act (DNA), and for modifications to the Commission's Recommendation on Relevant Markets Susceptible to Ex-Ante Regulation.
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Meeting with Paul Tang (Member of the European Parliament) and Google and

26 Feb 2023 · Participant at EIF-GSMA Roundtable discussion: "‘Connecting Europe to its 2030 Digital Decade Targets’"

Response to Improving access to emergency services through the single European emergency number ‘112’

12 Sept 2022

II. MVNOs are not in charge of generating and providing location information Please allow us to emphasize that, given that MVNOs do not operate their own Radio Access Network (RAN), they are not in charge of generating and providing network-based location information. This function is handled by their Host operator (a mobile network operator with whom they have concluded a wholesale access agreement). MVNO Europe considers that major improvements are possible and necessary to handset-derived emergency caller location. We address this point, as well as 2G/3G sunset and related issues with emergency calling, in the remainder of this response. III. Improvements needed to handset-derived caller location information MVNO Europe believes that handset-derived information (including, but not exclusively, on caller location) will gain importance going forward, as it will enable the most rich forms of emergency communication and contextual information. MVNO Europe agrees with, and supports, the definitions put forward by the European Commission for ‘effective emergency communication’ and ‘contextual information’ in draft Article 2. The reference made in the same article to ‘information derived and transmitted automatically from the device of the end-user’ is also very relevant. MVNO Europe also considers it most welcome that national PSAPs will be put on a path towards upgrades to packet-switched technologies, as provided for in draft Article 7(2). In this context, and in the interests of improving reliability of mobile caller location, and well as the quality of interaction with PSAPs, MVNO Europe considers that the European Commission should take the opportunity of this Delegated Regulation to promote (in the text itself or at least in the accompanying Explanatory Memorandum) an important extension to Advanced Mobile Location (AML). The current AML standard (ETSI TS 103 625 V1.2.1) only enables transmission via SMS or HTTPs, thus requiring a functioning SMS Switching Centre (SMSc) or a working data connection with the end-users’ device, also while the end-user is roaming. This is not always the case: an SMSc may fail, or fail to be reachable, and a data connection may not be available, e.g. if there is no working SIM card, if the user has turned off data while roaming, if prepaid credit has expired or if the user has been cut off for whatever reason, etc. If the AML standard were (mandatorily) extended to organize signalling via SIP/IMS, this would have major advantages (provided that modernized PSAPs are able to receive and process it), enabling AML to function even when no SIM card/active eSIM is in the handset, in case no data connection is available with the end-users’ device, and removing a potential point of failure, which is the provider’s SMSc or the roaming provider’s SMSc. If AML relying on signalling via SIP/IMS would be (mandatorily) implemented, the information will always be relayed over the local SOS emergency APN of the VPLMN, which is able to deliver messages to the local PSAPs. Introducing/mandating AML signalling via SIP/IMS would significantly boost the reliability of mobile caller location, removing failure scenarios that are widespread in the current AML implementations. IV. 2G and 3G shut-down – insufficiently addressed risks – action needed MVNO Europe believes that the European Commission should take the opportunity of the Delegated Regulation, or at least the final text of its Explanatory Memorandum, to encourage or mandate that OEM vendors make sure that all VoLTE capable handsets shall offer VoLTE/packet-based voice services under all circumstances and will make sure all capable handsets (during their reasonable economic lifespan) will be updated to use the SOS emergency APN.
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Meeting with Thierry Breton (Commissioner) and

8 Apr 2022 · Endorsing the Joint statement on Roaming and International calls between EU and Ukraine

Meeting with Thierry Breton (Commissioner) and

29 Mar 2022 · Efforts to facilitate Roaming with Ukraine

Response to Initiative for reviewing and prolonging the “Roaming Regulation”

4 May 2021

- 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 that will allow 5G cost efficiencies to be taken into consideration; - MVNO Europe is of the view that the new glide-path should further match the rapid increase of roaming volumes which is to be expected once the travel restrictions related to the pandemic are lifted; - MVNO Europe considers that the future reviews of the caps should not be completed by way of delegated act (as proposed by the European Commission in Articles 22 and 23) so as to take the views from the European Parliament and the Members States into consideration; - MVNO Europe regrets that the Commission has not been as ambitious as it suggested in its inception impact assessment of April 2020 on issues concerning permanent roaming and the development of Pan-European IoT services.
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Response to Digital Services Act package: ex ante regulatory instrument of very large online platforms acting as gatekeepers

20 Apr 2021

MVNO Europe welcomes the Commission’s intention to deal with unfair practices and lack of contestability that it has identified for a number of core platform services – including operating systems – and that have led to inefficient outcomes in the digital sector in terms of higher prices, lower quality, as well as less choice and innovation to the detriment of European consumers. In particular, MVNO Europe welcomes Article 6.1 (e) as well as recitals 50 and 51, which are intended to promote the principles of freedom of choice concerning the services that are accessed via the core service platform offered by the gatekeeper and rights of end users to access an open internet. These provisions also intend to ensure that end users can effectively switch and choose between different internet access service providers, given that limitations that gatekeepers could unduly impose in this respect would distort competition for the provision of internet access services and ultimately harm end users. MVNO Europe is of the view that these provisions should be rephrased, so as to make sure that situations similar to the one identified by the European Commission in slide 13 of its presentation to the Working Party meeting on Competition on 19 February 2021 are regulated by the Digital Markets Act. As the recitals abovementioned show, the text’s intention is to guarantee freedom of choice and enable end users to openly access online content and services. MVNO Europe considers that the provisions should explicitly address usage restrictions electronic communications services may face as a result of decisions made by gatekeepers running operating system. This way, end-users will be able to select the provider of their choice and enjoy the full functionality of the electronic communications services they choose to utilise. In addition, MVNO Europe believes that more emphasis should be placed on the ability of end users to actually access and use all the features available via the operating system of the gatekeeper, and this regardless of the electronic communications service provider (not only internet access service provider) they have chosen (or their employer or other intermediary has selected for them). In parallel, we should not take the risk of missing the objectives of recitals 50 and 51 by solely prohibiting restrictions imposed by operating systems for technical reasons. Device manufacturers and providers of operating systems should not be able to impose restrictions on mobile operators’ customers and app developers, limiting access to key device functionalities (e.g. the generation of mobile technology to be used such as 4G and 5G, mobile Internet, Voice over LTE, Voice over Wi-Fi, GPS, or voice commands, etc.) for purely commercial reasons.
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Response to Voice call termination rates in the EU (Eurorates)

22 Sept 2020

In attachment, MVNO Europe provides its written feedback on the European Commission’s Draft Delegated Regulation supplementing Directive (EU) 2018/1972, setting a single maximum Union-wide mobile voice termination rate and a single maximum Union-wide fixed voice termination rate.
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Meeting with Margrethe Vestager (Executive Vice-President)

30 Jun 2020 · To discuss together the challenges their companies face on the EU market.

Response to Initiative for reviewing and prolonging the “Roaming Regulation”

7 May 2020

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. Overall, our association shares the European Commission’s assessment that a legislative initiative is justified in the mobile roaming sector as well as its intention to prolong the Roaming Regulation beyond its expiry date of 30 June 2022. This is the case because competition at wholesale level is insufficient and operators cannot sustain retail Roam-Like-At-Home without regulated wholesale caps being in place. Regulated wholesale caps need to be set at adequate levels reflecting reality. MVNO Europe is in favour of the alternative policy option proposed by the Commission, which implies not only a simple prolongation of the Roaming Regulation, but also a review (strong reduction) of the wholesale price caps, as well as an assessment with regard to possible measures to address permanent roaming for IoT services. Conversely, MVNO Europe considers the baseline policy option as being disconnected from market reality and developments as it proposes to extend the 2022 values for data, voice and SMS wholesale caps into the longer term future. An extension and update of the existing glide-path for wholesale roaming charges is absolutely necessary. The glide-path should be revised in light of the following factors: 1) The sharp decline of the cost of providing wholesale roaming services; 2) The deployment of 5G technologies (which include use of additional spectrum bands as well as more advanced coding and antenna systems) leading to much higher spectral efficiency per bit transmitted; 3) The effective commercial prices at which operators trade wholesale roaming with one-another, as reported in BEREC monitoring; 4) The strong downward evolution of domestic retail prices (today, the wholesale roaming caps set in 2017 by EU Regulation far exceed retail prices in many EU Member States). In this respect, MVNO Europe invites the European Commission to take the particular situation of MVNOs on wholesale markets into consideration, and to propose a review of the accuracy of the glide-path every two years, so as to account for the efficiencies gained thanks to new network technologies (5G), and other factors. Having some IoT MVNOs among its members, MVNO Europe welcomes the European Commission’s intention to facilitate Machine to Machine Communication (M2M) notably by assessing if current roaming rules are sufficient to adequately support the development of IoT activities that often logically and legitimately involve permanent roaming.
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Response to Contract summary template for electronic communications service providers

9 Sept 2019

Dear Madam, Dear Sir, Please find attached the feedback provided by MVNO Europe (PDF file format). Sincerely, Yves Blondeel, T-REGS, on behalf of MVNO Europe
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Meeting with Mariya Gabriel (Commissioner)

29 May 2018 · Market access, Internet of Things

Meeting with Kamila Kloc (Cabinet of Vice-President Andrus Ansip)

21 Apr 2016 · Roaming: wholesale market review

Meeting with Friedrich Wenzel Bulst (Cabinet of Commissioner Margrethe Vestager)

8 Oct 2015 · Telecoms market access and merger remedies

Meeting with Markus Schulte (Digital Economy)

26 Mar 2015 · TSM

Meeting with Kamila Kloc (Cabinet of Vice-President Andrus Ansip)

26 Mar 2015 · TSM + upcoming review of telecom regulation