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.