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Roaming Consulting Company Ltd

Telephone: +447730047777
E-Mail: HQ@roamingconsulting.com

“ROCCO” , “Roaming360” and “True Roaming” are Registered Trademarks of the Roaming Consulting Company Ltd.

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Last month BEREC issued the “BEREC report on wholesale mobile roaming” which also includes an analysis on MNOs implementing RLAH (Roam Like At Home) tariff plans prior to the date set out in the Roaming Regulation (June 2017).

Here at ROCCO HQ we think that the most interesting finding of this study is related to the fact that the RLAH tariffs implemented by EU operators do not comply with the current definition of the new Regulation for 2017, therefore they are not precisely what a RLAH tariff should be.

In fact, while about half of the operators replied that they offer some sort of RLAH tariff plan which includes roaming services in the domestic bundle, they have several restrictions:

  • Some of those restrictions consist of add-ons’, i.e. daily, weekly or monthly roaming packages at a separate price that provide specific roaming units.
  • Some others are restricted to a specified geographical scope (for example offers that include countries where the operator is present and/or countries where good deals were concluded), but not all EU countries: to this purpose, it’s interesting to highlight that other operators are able to also include non-EEA countries in their RLAH package, for example the USA, Switzerland or Turkey (e.g. offers from Norwegian, Spanish and French operators).
  • Some RLAH offers are restricted only to specific services, i.e. they only include roaming data whereas other offers only include voice and SMS.
  • A few operators mentioned some additional volume restriction: they apply a maximum limit on the call duration (e.g. 1 hour) or they cap the daily data usage when a significant amount of mobile data is consumed in a single day.

According to BEREC’s findings, the amount of mobile roaming data included in the RLAH offers varies a lot between operators in the EEA and it depends on the price of the tariff plan. In most countries, the data volumes in RLAH offers are rather low, below 500MB.

Data allowances of 15GB (Norway) or 20GB (France) can be observed as well but can be considered as outliers. The roaming data allowance is always capped and once the FUP (Fair Usage Policy) is exceeded, users can continue to use roaming services out of the bundle on the basis of regulated prices or daily/weekly passes whilst data roaming is often throttled.

It’s interesting to point out that restrictions to the RLAH offers may also depend on the combination of different FUPs: typically, the FUP depends on the price of the offer and is a volume-based limitation (per month). Some operators include roaming in the domestic volume (e.g. 3GB per month including roaming at an additional small mark-up), some offer provide for an extra specific roaming volume independent of the domestic allowance (for example 6GB of roaming per year). By way of contrast, FUP in terms of days has been only observed by BEREC in France and Poland: operators in these countries define roaming units which can be used within a range of 10 to 60 days per year. However, in most of the French and Polish RLAH tariff plans, the FUP in terms of days comes in addition to a FUP in terms of volume.

Finally, a few comments about a possible impact on the demand of roaming services connected to the offer of the abovementioned RLAH-type offers.

BEREC also asked operators whether they could report such an impact and about 75% of the operators who launched some sort of RLAH offer were not able to report any because of the lack of any stable evidence to indicate any trends since

“they were not able to extract reliable before-and-after traffic volumes for customers migrating to the RLAH products”

However, all operators noticed an increase in voice and SMS usage, and a huge increase in data usage with regard to roaming.

According to BEREC analysis:

“about 25% of the operators were able to report some elasticities as a result of the introduction of RLAH-type offers, which varied between them. On average, the operators reported:

  • Voice traffic: an increase of about 20%-23%. Some operators mentioned voice traffic doubled or tripled.
  • SMS traffic: an increase of 10%-20%. Some operators mentioned SMS traffic doubled.
  • Data traffic: 90%-200% increase. Some operators reported a much higher increase, for example 550% or more.”

However, BEREC believes that because of the little data available, no solid conclusion can be drawn and it points out several other reasons to nuance these observed elasticities:

  • Customers who subscribe to RLAH offers are often frequent roamers…

“the elasticities operators currently report might be an overestimation of the actual impact that operators will face from July 2017 onwards, when RLAH will be in place due to the Roaming Regulation”

  • It is also likely that there will be an increasing demand of roaming service also from current silent roamers or from low-end users as they will no longer have the perception of high roaming prices.
  • Operators who responded to the questionnaire may have used different methodologies;
  • Finally, the data traffic increases cannot be attributed directly to the RLAH tariffs, since domestic data usage is also still showing an upwards trend in all types of tariff plans.

ROCCO believes this feedback provides an interesting gauge for what to expect June 2017 when the abolition of Roaming will begin in EU Member states.

Reporting for ROCCO, Federica Romano, Head of Legal and Regulatory


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