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Structural Solutions and the Evolution of International Mobile Roaming (IMR) in Europe: Where are We Headed?

In response to long-standing European concerns over high prices for international mobile roaming (IMR) within the European Union (EU), the European institutions have imposed progressively more rigorous Roaming Regulations, the most recent of which took effect in July 2012. The support for structural solutions (to enable separate provision of roaming services by firms other than the Mobile Network Operator (MNO) in the Home country) in the Roaming Regulation of 2012 represented a first serious attempt to address root causes of high IMR prices, rather than solely by intrusively regulating wholesale and retail prices. The structural solutions will not come into force until July 2014. Meanwhile, there is considerable doubt about the degree to which market players will offer the services, whether consumers will adopt them, and even if they were to be fully effective, over the degree to which they would actually influence the price of international mobile roaming services. Meanwhile, the Commission’s “Connected Continent” proposal for a Single Market Regulation proposes to phase out structural solutions before they have even begun to come into effect. We assume that the business plans of firms that otherwise might have offered the services have already been impacted, perhaps fatally. Against this backdrop, traffic off-load using public or private Wi-Fi and small cells (e.g. femtocells) is growing in popularity by leaps and bounds. Traffic off-load could conceivably serve as a partial substitute for international mobile roaming, inasmuch as it is primarily suitable for nomadic use (from a changing fixed location) rather than truly mobile service. Despite this and other limitations in its applicability to IMR, it is a promising development in an area where European policy now appears to be in a state of serious confusion.