Belgium’s IBPT found that customers who accept whatever their operator offers at renewal, instead of checking if they still need the extra data, lose hundreds of euros a year. The Netherlands’ ACM went further and put a number on it: 79% of fixed internet contracts and 60% of mobile contracts are “dormant” – past their initial period, and costing their holders up to 250EUR a year more than a fresh contract would. France’s ARCEP found a paradox: 89.4% of mobile plans now carry no commitment at all, yet portability fell by a quarter in one year. And the UK’s Ofcom has spent a decade building a whole vocabulary around this – the “loyalty penalty” – priced at up to 1,114GBP a year per household across mobile, broadband and other services.

Four markets, one pattern: customers who don’t switch are subsidising the ones who do. Until recently, most operators could simply count on that.

Why this matters more than it looks

It is easy to file this under consumer-protection news. That would miss the point. What these four regulators are showing, together, is a structural feature of incumbent economics. Acquisition discounts need funding. Back-book customers on old tariffs provide it. This is not a pricing mistake by one operator. It is close to the operating model of scale telecom in mature markets.

That changes the picture for anyone who isn’t a scale incumbent.

First, inertia is now measured and named. It is no longer a private inefficiency operators can manage on their own schedule. Second, and more useful strategically: the very thing that has protected incumbent margins for years can now work against them.

From consumer protection to competitive weapon

MVNOs and alternative operators have usually treated churn and switching friction as a threat. The pattern above suggests a different move: treat anti-inertia as a selling point, not a cost to manage.

In practice, that means a few things.

Make leaving easy, and say so. Regulators are moving toward mandatory end-of-contract notices, best-tariff alerts and easier switching. An operator who already does this earns trust that a low price alone can’t buy. For an operator built around solving one specific problem well, visible fairness on exit is cheap to deliver and hard to fake.

Build onboarding for switchers, not just new customers. Every dormant contract flagged by ACM, every out-of-contract customer flagged by Ofcom, every non-switcher counted by ARCEP is a named prospect. The winners won’t be the cheapest. They’ll be the ones who make switching itself painless: number portability handled end to end, no penalty to navigate, one clear page instead of a forty-page tariff sheet.

Compete on the metric regulators are watching. If the direction of travel is mandatory comparison and proactive notification, an operator built on transparency from day one is compliant by design. That’s a story worth telling.

From best practice to hard rule

The four regulators are not at the same stage, and that gap is useful. Belgium and the Netherlands are in guidance mode: publishing data, naming the bias, encouraging better information, with enforcement building slowly. The UK has already moved to binding rules: mandatory notifications, a ban on inflation-linked price rises since January 2025, and a new Consumer Hub pushing switching data straight to consumers. France sits in between, with no mandate yet but a regulator visibly worried about falling portability.

Read together, this looks less like four separate policies and more like a staggered rollout of the same expectation across Europe. What Belgium and the Netherlands are doing today looks like where the UK stood a few years back. Operators who wait for their own regulator to catch up will end up building under pressure. Operators who build now are simply early.

The bottom line

The “loyalty penalty” that regulators frame as a consumer problem is, from an operator’s chair, a market with a price tag already attached in every country that has bothered to measure it. For an MVNO or a niche alternative operator, that’s not background noise. It’s a target list, a story to tell, and a hedge against regulation that’s coming either way.

Sources & reference points

• IBPT/BIPT :” La passivité des utilisateurs de téléphonie mobile peut leur coûter des centaines d’euros: www.ibpt.be
• ARCEP :” Observatoire des marchés des communications électroniques, T4 2025 (portability and no-commitment plan data): www.arcep.fr
• ACM (Netherlands) :” ACM: telecomaanbieders moeten consumenten duidelijker en transparanter voorlichten over vast internet: www.acm.nl
• ACM (Netherlands) :” Marktbeschouwing telecommarkt 2024 (dormant contract data : 79% fixed, 60% mobile): www.acm.nl
• Ofcom (UK) :” Consumer Hub launch and switching/money-saving guidance (2026): www.ofcom.org.uk
• Smart Data Council / UK Government : loyalty penalty estimate across mobile, broadband and mortgages : reporting via techradar.com
• Ofcom :” Ban on inflation-linked mid-contract price rises, effective January 2025: www.ofcom.org.uk

The post The Loyalty Penalty Isn’t a UK Problem — It’s a European Business Model appeared first on AskGreg.

From BNetzA to the ACM — what each regulator actually allows, and why going direct is still the safer route

In August, Germany’s BNetzA — the federal network agency — published a notice reaffirming the legal framework for reselling geographic and mobile numbers, after uncovering chains of unauthorized resellers.
It’s not an isolated case. Across Europe, number resale is a topic regulators watch closely — and regulate far more tightly than many operators building their market entry around a local intermediary tend to assume.

I checked, country by country, what’s actually allowed in Germany, France, Belgium, Luxembourg, and the Netherlands. The results are instructive.Germany: the warning shot

BNetzA’s Mitteilung 90/2026 doesn’t create new law — it reaffirms that the existing framework applies, after uncovering unauthorized reseller chains for geographic and mobile numbers. A clear signal: regulatory scrutiny on numbering is tightening, not loosening.

France: sub-allocation is the exception, not the rule

Arcep‘s text is blunt (§2.2.3 of the annex to decision n° 2018-0881, amended in 2021): “operators allocated telephone numbering resources may not make them available, in whole or in part, to other operators.” Only two exceptions exist: resources already made available before 31 July 2018, and narrow sector-specific carve-outs for geographic numbers and extended-length mobile numbers — reserved for a declared operator acting as depositary, and only for resources the depositor was itself directly allocated. In every case, the original allottee stays responsible for all obligations, and number portability must remain guaranteed.

Belgium: sub-allocation exists, but no resale chains

The Royal Decree of 27 April 2007 (Art. 5) lets a number holder “make available” numbers to another operator — under strict procedural conditions: prior notification to the BIPT, proof of agreement between the parties, the depositary’s identity reported to the regulator. The original holder stays responsible for all legal and regulatory obligations. Here’s the key point: the operator put in possession cannot, in turn, make that capacity available to yet another company — unless it can prove the ban would make an existing or planned service impossible, and submit the contract for the Institute’s approval. A full transfer of the capacity (change of holder) must also be justified by something beyond the mere transfer itself, and requires the Institute’s authorization (Art. 5 §3) — a de facto anti-speculation clause. Article 9 settles the rest: numbering capacity can never become property, nor be protected by any intellectual property right. In short: operator-to-operator sub-allocation exists; resale chains don’t. Even this legitimate route runs through a dedicated BIPT notification form — this isn’t a casual arrangement between two private companies.

Luxembourg: the strictest rule on paper — and a real case to prove it

The ILR‘s stated principle is blunt: numbering resources “may not be transferred, assigned, or made available to any third party other than end users” (Règlement ILR/14/174 of 14 July 2014, on numbering). This isn’t a theoretical clause: on 27 March 2026, the ILR sanctioned DIDWW Ireland Limited (Decision ILR/T26/3) precisely for assigning and making available to third parties Luxembourg numbering resources. A telling detail on top of it: a consultants’ report commissioned by the ILR itself flags lingering ambiguity around the rules for supplying numbers to commercial resellers, and recommends clarifying them — a sign the regulator wants to tighten this area, not loosen it.

The Netherlands: the more flexible exception — but not a free-for-all

The Telecommunicatiewet works on two levels. Article 4.9 lets a number holder (“nummerhouder”) put numbers to use by a third party (“in gebruik geven”), provided it’s done “in a non-discriminatory and transparent manner, using objective criteria” — the holder stays responsible for the numbers being used lawfully. Article 4.6 goes further: on the joint request of the holder and a third party, the ACM can approve a full transfer of the allocation itself. It’s the most flexible route in the group — but it isn’t unregulated: objective criteria, ongoing accountability, and for certain designated number categories, Article 4.9 explicitly bans sub-letting down the chain.

At a glance

The common thread

With the Netherlands as the one partial exception, the European trend points one way: restrict resale and hold the original allottee accountable. For an operator that actually wants to establish itself in a market — not just route traffic through it — the safer route, and often the faster one over time, is to request its own number blocks directly from the local regulator and set up local interconnection, rather than depend on a fragile, legally exposed sub-allocation chain.

Where AskGreg comes in

This is exactly the path I help operators navigate: requesting number blocks, setting up local interconnection, staying compliant across jurisdictions (BIPT, Arcep, ILR, ACM, BNetzA…). For an operator or MVNO looking to enter Benelux, France, or beyond properly, it’s a far more solid foundation than a reseller chain you don’t control.

Happy to talk if you’re planning an entry into one of these markets.

The post Reselling Numbers in Europe: A Market Far More Regulated Than You Would Think appeared first on AskGreg.

What ANCOM and IBPT’s roaming alerts reveal about the real market for travel connectivity

This summer, two regulators — Romania’s ANCOM and Belgium’s BIPT — published near-identical warnings about roaming charges outside the European Economic Area (EEA). Read separately, they look like routine consumer-protection notices. Read together, they say something more interesting about where the travel connectivity market is actually heading.

The problem regulators keep rediscovering

ANCOM’s numbers are worth sitting with: up to €2.62 per minute for calls and €4.76 per megabyte outside the EEA, with some operators billing a full data package the moment a single megabyte is used — even if usage stops seconds later. IBPT flags the same pattern from the Belgian side, naming the UK, Andorra, and Turkey as destinations where “Roam Like at Home” simply doesn’t apply. Neither regulator is describing an edge case. They’re describing what happens to an ordinary traveler on an ordinary summer trip.

RLAH progress hasn’t closed the gap

Roam Like at Home has genuinely worked inside the EEA, and its extension to Ukraine and Moldova on 1 January 2026 is a real step forward for Eastern European corridors. But the exclusion list hasn’t shrunk where it matters most for volume: the UK, Switzerland, Turkey, Bosnia, Albania… These aren’t fringe destinations — they’re some of the highest-traffic outbound routes for European travelers, which means the regulatory blind spot and the travel market overlap almost perfectly.

Why this matters beyond the occasional traveler ?

Travel eSIM marketing has largely targeted frequent flyers and digital nomads — people who already think about connectivity before they board. But the regulatory pattern here describes a much wider exposure: residents of border regions, once-a-year holidaymakers heading to Turkey or the UK, business travellers who’ve never touched an eSIM setting in their life. That’s not a niche. That’s most of the outbound European travel market, and it’s currently underserved by anyone selling connectivity as an afterthought.

What this means for operators and eSIM providers

From a go-to-market angle, the opportunity isn’t just reaching people who already know they need an eSIM. It’s building trust with a much larger segment that doesn’t yet default to eSIM as the obvious fix for a well-documented, regulator-confirmed pricing gap. Operators and MVNOs that still treat travel eSIM as commodity data will miss this. The ones building around clear pricing and honest fair-use terms — rather than the “unlimited, terms apply” model much of the category still leans on — have real room to build category leadership, not just market share.

Lessons for the industry

• Regulatory warnings are a signal, not a substitute for marketing — but they validate the problem at a market-wide scale.
• The addressable market for travel eSIM is wider than “frequent travelers”: border residents, once-a-year holidaymakers, and business travelers who never touch their own APN settings all sit inside it.
• Transparent pricing and fair-use policy are becoming real differentiators, not footnotes — especially as comparison content around “hidden roaming fees” gains search traction.
• The UK, Switzerland, Turkey, Monaco and the Balkan region remain the highest-risk zone for bill shock and, not coincidentally, the highest-opportunity zone for eSIM adoption.

I’ve spent the last few years helping operators and MVNOs think through go-to-market and carrier relations across Benelux and France. This is exactly the kind of regulatory signal that should shape a roadmap, not just a blog post — it tells you where the addressable market actually sits, not where the category has historically marketed itself.

If you’re building or refining a travel eSIM offer and want a second opinion on positioning or market entry, happy to compare notes.

The post Two Regulators, One Warning: Why Travel eSIM Isn’t a Niche Product Anymore appeared first on AskGreg.

What alternative operators can do — and what the big ones rarely do

Across Europe, consumer protection obligations are multiplying. Tariff transparency, simplified cancellation, complaint handling deadlines, end-of-contract notifications — each new directive or national regulatory decision adds another line to the compliance checklist.

The typical reaction in most organisations: hand it to legal, implement the minimum required, move on.

That is a mistake. And for alternative operators, it is a missed opportunity — twice over.

What Regulators Mandated Without Realising It

Look at what the regulation actually requires.

In Belgium, the BIPT clarified in early 2026 the application of Articles 108, 109 and 110 of the Electronic Communications Code: operators must proactively recommend the most advantageous tariff to their customers, at least once a year, based on their actual consumption profile — including at contract renewals.

In other words: the regulator has made mandatory what a good retention programme should have been doing all along.

Analyse customer consumption. Identify the most suitable offer. Reach out at the right moment. Document the process.

That is exactly the sequence of a well-designed loyalty programme. Except most operators treat it as an administrative formality rather than a commercial touchpoint.

The Raw Material Everyone Is Sitting On

Here is where it gets interesting — and where I’ll be direct.

CDR data and billing records are, in my view, one of the most underexploited raw materials in telecoms. Operators generate this data continuously. It tells you exactly how a customer uses their service, when usage patterns shift, whether they are consistently over or under their plan, and when the conditions for churn — or upsell — are forming.

Most operators use this data for billing. Full stop.

The tariff transparency obligation essentially forces operators to do what they should have done with this data from day one: run a structured analysis, compare it against the available tariff portfolio, and act on the result.

The data is already there. The regulatory framework now requires you to use it. The only question is whether you use it minimally — to comply — or intelligently — to retain.

Every Obligation Is a Disguised Customer Moment

Tariff transparency is not the only example.

Simplified cancellation — a requirement in several European markets — is a moment of truth. Treat it as a form to fill in, and you lose the customer in silence. Treat it as a conversation opportunity, and you can recover a portion of churn with a relevant offer, at the right moment, without friction.

Complaint handling — imposed timelines, required traceability — is documented as one of the most powerful loyalty levers in the industry. A customer whose complaint is handled quickly and well is often more loyal than one who never had a problem at all.

End-of-contract communications — mandatory in many jurisdictions — are direct customer touchpoints, at the precise moment when the decision to stay or leave is being made. Few operators design them as anything other than a legal notification.

In every case, regulation has defined the moment. It has not defined what you do with it.

Why Large Operators Don’t Capitalise

The reason is structural. In large groups, compliance and customer retention operate in separate silos. Legal handles the obligations. Commercial handles retention. The two rarely connect.

The result: obligations are met, but the opportunity is left on the table.

Alternative operators — MVNOs, challenger fixed operators, VoIP providers — have a structural agility that incumbents do not. Fewer silos. Shorter decision cycles. And crucially, the ability to build a process end-to-end, without organisational legacy to work around.

But there is something else. A smaller operator can go further: by automating these regulatory touchpoints intelligently, they can establish a more direct, more personalised relationship with each customer than any large operator realistically can. Not a mass communication. A relevant, data-driven conversation — triggered by actual usage, at the right moment, through the right channel.

That is differentiation that does not require a bigger budget. It requires a smarter operating model.

What This Means in Practice

Turning a regulatory obligation into a retention lever is not a marketing project. It is an operational one.

It requires consolidated, actionable consumption data — starting with your CDRs. A structured and documented tariff comparison logic. Customer communication workflows triggered at the right moments. And a traceability layer that is audit-ready, but designed well enough to be commercially useful at the same time.

None of this is trivial. But operators who get it right earn two benefits for the price of one: compliance, and a retention programme their competitors have not built.

The Bottom Line

Consumer protection obligations are not a constraint to absorb. They are customer touchpoints that regulation has made mandatory — and that most operators still manage as paperwork.

For alternative operators, the window is clear: design these moments as retention processes, not compliance checkboxes. Use your billing data as the raw material it actually is. And build the kind of direct, personalised customer relationship that larger operators — by design — cannot easily replicate.

Customer retention is hidden in your regulatory obligations. You just have to decide to find it.

If you are working on structuring your consumer obligations — and want to turn them into an operational advantage rather than a compliance cost — I am available to discuss.

Sources & references

• BIPT/IBPT — Clarification of Articles 108, 109 and 110 of the Electronic Communications Code (January 2026)
• BEREC — Consumer empowerment and pricing transparency guidelines
• European Electronic Communications Code (Directive 2018/1972)

The post Customer Retention Is Hidden in Your Regulatory Obligations appeared first on AskGreg.

Telecom compliance is no longer confined to administrative reporting or legal documentation. Across Europe, regulators are stepping up enforcement and demanding that operators demonstrate operational readiness, responsiveness and governance.

Recent decisions by regulators in Belgium, Luxembourg and the UK confirm this trend: telecoms compliance is becoming a core operational discipline rather than a back-office exercise.

In Belgium, for example, the BIPT recently fined Colt Technology for failing to provide the requested information within the required timeframe under Belgian telecoms regulations. Similarly, the ILR issued fines in Luxembourg in 2025 against three operators for failing to provide the required regulatory information within the expected timeframes. Meanwhile, in the UK, Ofcom’s recent enforcement actions continue to demonstrate a broader regulatory shift towards stricter operational accountability. Whether relating to reporting obligations, operational resilience, customer protection, or market integrity, regulators are increasingly expecting operators to maintain robust governance frameworks and cooperate efficiently with the relevant authorities.

Compliance is becoming more complex

Compliance obligations continue to expand for telecom operators, especially MVNOs, VoIP providers, international carriers and new market entrants :

• Number portability processes and databases
• Lawful intercept readiness
• Data retention obligations
• Regulatory reporting
• Customer identification requirements
• Security obligations under NIS2 frameworks
• Coordination with public authorities and regulators
• Wholesale and interconnection obligations
• Operational documentation and audit readiness

Each requirement often involves multiple stakeholders, including regulators, incumbent operators, portability platforms, carriers, technical providers, legal teams and internal operations departments. Delays in one process, or an inability to provide accurate information within regulatory deadlines, can quickly lead to operational issues, delay market launches and expose operators to sanctions and reputational risks.

From Reactive Compliance to Strategic Compliance

A common pattern behind recent regulatory actions is the difference between reactive and proactive compliance. Operators that only address their obligations once issues arise often face higher operational pressure, greater remediation costs and unnecessary escalation with regulators. By contrast, operators that integrate compliance into their operational and go-to-market strategy are generally better positioned to:

• Accelerate market entry
• reduce regulatory friction
• improve operational coordination
• strengthen carrier and regulator relationships
• anticipate regulatory evolution
• Reduce pressure on management teams

Compliance is therefore evolving from a support function into a strategic operational capability

The value of fractional carrier relations and regulatory expertise

Many operators, particularly MVNOs, international groups and growing telecoms providers, do not require an entire internal regulatory department. However, they do require experienced guidance to bridge technical, operational, commercial and regulatory discussions. This is where a fractional carrier relations and regulatory advisory model can add real value.

At AskGreg, I support interconnection and carrier relations projects and help operators navigate increasingly complex compliance environments in a pragmatic and efficient manner. This includes:

• supporting interactions with regulators
• representing operators during meetings with authorities
• coordinating portability and operational obligations
• facilitating lawful intercept readiness discussions
• assisting with compliance processes and documentation.
• Bridging management, technical teams, carriers and regulators

The objective is simple: to transform compliance from a source of operational friction into a structured, manageable process that supports business continuity and growth.

In the telecoms industry, compliance is about more than just avoiding fines. It is increasingly about operational credibility, trust and the ability to operate efficiently within a highly interconnected ecosystem.

The post Compliance in Telecom: From Regulatory Obligation to Operational Resilience appeared first on AskGreg.

The last communication from BIPT – IBPT is an important moment for customer protection and tariff transparency in Belgium. Link to Press Release

With its decision of 28 January 2026, the Regulator clarifies how Articles 108, 109 and 110 of the Electronic Communications Act must actually be applied. In doing so, it brings more order and structure to provisions that existed in the Law but were not always implemented in a consistent way.

Belgium now stands out in Europe. It is currently the only EU country requiring operators to proactively inform customers every year about their most advantageous tariff plan. Other Member States have transparency obligations, but not with this level of recurring, structured requirement.

So what does this mean in practice?
Any operator offering more than one standardised tariff plan must:
Inform each customer at least once per year about the best tariff plan
Base this tariff recommendation analysis using 3 months of usage data
Apply the same logic at contract renewal
Be able to explain and justify the calculation methodology if audited
Be fully compliant within 9 months

This concerns large and small operators alike
And it also applies to B2B customers served through standardised offers

Two things really matter here :
1⃣ Methodology. It’s not enough to say a tariff is “better”. Operators must define how they calculate that, apply it consistently and be able to document it.
2⃣ Timing. Nine months may sound comfortable, but when data flows, internal processes and possibly IT systems are involved, the clock moves fast.

The legal framework is now clearer. Expectations are more structured. The countdown has started.

If you’d like to exchange views on what this means in practice, feel free to contact AskGreg

The post Customer protection and tariff transparency in Belgium – Latest decision from the Telecom Regulator appeared first on AskGreg.

Why Vonage Was Fined ?

Ofcom’s investigation concluded that Vonage lacked adequate change management, testing, and oversight processes within its VoIP network. These weaknesses left business customers unable to dial emergency numbers for nearly two weeks.

Analysis: The Vonage case highlights the risks of reactive compliance. Ofcom provides early signals through consultations and draft regulations, yet Vonage acted only after a failure occurred. That approach left customers vulnerable, regulators dissatisfied, and the company exposed to sanctions.

Belgium: Proximus and Nationwide Failures

In April 2019, Belgium’s incumbent operator Proximus suffered a nationwide outage that disrupted access to emergency services 100, 101, and 112. The regulator BIPT investigated the incident, published a report, and in 2023 launched a public consultation on introducing a redundancy system for emergency calls. This shows regulators are moving from sanctioning after failures to designing structural safeguards to ensure resilience nationwide.

Australia: Optus, Fines and Renewed Concern

In Australia, the Australian Communications and Media Authority (ACMA) investigated Optus after its nationwide outage in November 2023 disrupted access to Triple Zero (000). The outage was directly linked to the deaths of several people who were unable to reach emergency services.

Following its inquiry, ACMA fined Optus A$12 million for breaching emergency call rules — one of the largest telecom penalties in Australia.

More recently, in September 2025, ACMA announced it was deeply concerned after reports of another disruption to Triple Zero. The regulator launched a new official inquiry, warning: “Australians must be able to contact emergency services whenever they need help.”

Lessons for Operators

Across the UK, Belgium, and Australia, the message is consistent:

1. Anticipate early — consultations and draft rules are advance warnings.
2. Engineer redundancy — resilience must be built into networks, not bolted on later.
3. Test and monitor rigorously — ongoing testing and change management prevent catastrophic failures.
4. Communicate transparently — during outages, timely updates sustain public trust.

Turning Compliance into Leadership

Emergency call obligations are not regulatory checkboxes — they are lifelines. The Vonage fine, the Proximus outage, and the Optus penalty demonstrate that regulators across continents are tightening standards and demanding accountability.

Operators who anticipate regulation, invest in resilience, and engage proactively will position themselves as leaders in trust and reliability. Those who wait until enforcement arrives risk financial, reputational, and — in the worst cases — human costs.

At @AskGreg, I help operators across Europe navigate regulation, secure interconnections, and build agile go-to-market strategies that protect both business momentum and public safety.

The post Emergency Calls and Telecom Regulation: Lessons from the Vonage Case appeared first on AskGreg.

The Telecom Angle – Updated Description

Welcome to The Telecom Angle, a space where real-world telecom experience meets fresh perspective. Here, I share insights, field notes and reflections shaped by more than two decades inside the industry’s most complex environments.

If you’re curious about how interconnect really works behind the scenes, why number portability still keeps operators awake at night, or how regulatory decisions quietly reshape business models, you’re in the right place.

This isn’t a place for generic trends or recycled buzzwords. It’s a blog built for people who want clarity, context and practical takeaways — with a touch of candid commentary from someone who has sat on both sides of the table.

Whether you are an operator, a challenger, a partner or just telecom-curious, stay tuned. You might discover angles you didn’t even know existed.

The post The Telecom Angle appeared first on AskGreg.