15 April, 2022

ETNO’s submission to the public consultation on BEREC early call for input on BEREC Work Programme 2023

ETNO welcomes the opportunity to provide early inputs towards BEREC’s Work Programme 2023. We believe that BEREC should in general focus on the ongoing tasks as mandated by EU legislation, as defined in the EECC, the Open Internet Regulation, roaming and intra‐EU calls, for example. We support BEREC’s commitment to establish structured cooperation mechanisms with EU institutions and other competent authorities.

Concerning the strategic priorities and carry-over projects from 2022 and potential work for 2023, ETNO will hereby provide some initial views:


Strategic priority 1: “promoting full connectivity”

ETNO strongly supports BEREC’s strategic priority 1 that aims at promoting full connectivity and access to electronic communication networks. To achieve that, a successful implementation of the EECC should be pursued and pro-competitive infrastructure sharing promoted. ETNO supports BEREC’s intention to take stock of national experiences of the implementation of the EECC and to exchange good practices in this regard. We would also encourage BEREC to include stakeholders in this exercise to capture different perspectives in the initial assessment.

  • In the light of European Commission Digital Compass, 5G and Gigabit connectivity goals remain a priority for Europe and its economic recovery. However, as already indicated in previous ETNO submissions, ETNO believes that 5G does not trigger a general need for additional While ETNO acknowledges that 5G is important for the European economy and society as a whole, we firmly believe that market dynamics will ultimately determine the balance between supply and demand as well as any new business models. ETNO has been consistently highlighting the importance of new and innovative business models to accelerate roll-out of VHCN and 5G networks. We would urge BEREC to let the 5G ecosystem reach maturity and to then carry out a proper analysis before concluding on any action. ETNO members are open to contribute to the discussion on the current status and experiences of 5G deployment based on existing use cases.
  • As stated in the ETNO-GSMA response to BEREC’s 5G Radar, we agree that the role of 5G in the digitisation of wide sectors of the economy could result in changes in the value chain, giving telecom operators the opportunity to provide new services beyond connectivity, particularly in the business segment. Conversely, providers of IT solutions and technology are a potential new provider of connectivity services. We caution BEREC from taking a silo approach to the detriment of providers of ECN and ECS and any action that is not complementary to the overall direction the EU will take in this space. Voluntary wholesale agreements between mobile operators and new intermediaries are a possible welfare enhancing development that should not be prevented by BEREC or NRAs. Room must be given for potential new business models and value chains to actually emerge. Considering this evolution of roles along the value chain, it would be premature to regulate before the market has even properly developed or markets (namely mobile markets) where commercial agreements already in place have so far not required and continue not to require regulatory intervention. Any intervention should be based on analysis of the market and the need for regulatory intervention to be demonstrated with the three criteria test.


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© ETNO 2022
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