There are multiple approaches you can take when it comes to running research, but I always ensure I have demographic, attitudinal, quantitative, and qualitative data when building new mobile services and products.  

Combined, they always reveal insights you hadn’t anticipated and can give you an edge over the competition. Not only that, research validates facts, and disproves a hypothesis built on a ‘hunch’. 

You can use the following methodologies and logic below in any industry, but they are especially useful in mobile, simply because it’s a category where a product built on assumptions will fail fast.  

 
1. Always use research to help identify and validate market needs 

Despite all the evidence to say the best propositions are built on research, most mobile propositions get built from a) the network out, using known capability, or b) to match a competitor offering.  

I’ve even seen the ‘HPPO’ method be used, the one where the Highest Paid Person’s Opinion is the deciding factor and it often doesn’t go well. 

In fact, more generally, the repercussion of these three approaches is that they lead to ‘me-too’ offers that compete on price ie they use structurally lower costs. This just erodes margin and value and, other than a better price, doesn’t give consumers any reason to remain loyal after joining. They’ll just keep an eye on the market and switch if they can get the same thing elsewhere for less.  

In my experience the propositions that attract loyal customers and thrive in the market are those that started with a consumer problem and used technology to solve it. When tech is the enabler, not the reason to buy, there’s a bigger pull to the brand. For instance, nobody sets out to buy an eSIM for the love of the tech. They buy one because it’s quick to get join a network and start making calls. But even with this convenience on hand, consumers only really latched on when they realised they could avoid rip off roaming charges. 

The very best propositions don’t just solve the pain point they also add a layer of value too. Note, value isn’t always about price, it might be the product is more expensive but the reliability, experience of joining and using the service, and added extras make the price worth paying. 

2. Research should cover both demographic and attitudinal based insight 

Demographics tell you who someone is (age, gender etc) and this is essential for media planning, sizing and targeting. No argument there. 

But two women who live in the same postcode, similar age and earning roughly the same income can have a different attitude to mobile. One might want the cheapest possible option because they use it as a utility, the other might be willing to pay more because the brand reflects her personal values of fairness. 

This is why attitudinal segmentation is so important. It picks out motivation to use a service or buy from a brand, rather than personal circumstance like income. And that’s important for determining potential behaviours. So that’s things like how people feel about switching, what they think they’re buying, what they’re worried about, what they’d happily trade away. 

When you understand this, you can build more certainty into launching the proposition, because you know you’ve built something that meets a need and can appeal to those audiences with specific messages.  

To give an example, on a recent launch the segment that looked most attractive demographically – younger, heavy data users, price sensitive – turned out to be the least valuable attitudinally. It was full of chronic switchers, with no loyalty and little cash.  

The segment that was best to pursue was demographically unremarkable but attitudinally very distinct. They were looking for a brand they could trust so they could make one decision and stop thinking about it and feel confident they made the right decision for their core values. We built the proposition for them and it’s flown.  

You can read more about our approach to segmentation and the proven model we’ve developed here. 

3. When looking at the market opportunity think quantitative first, then qualitative as they reveal different things 

Quantitative gives you the whole market view, not just the bit you already know about. Segment sizes, price architecture, feature priorities against a representative base. The sorts of things it will include are current behaviour and spend, current provider, tariff type, contract length, handset commitments, SIM only preference, household and multi-SIM patterns. 

The key point is that quantitative tells you where the value is and how much of it there is to go after. Qualitative then tells you why it matters. Once the numbers have pointed you at the segments that matter, then you can test and refine the proposition by sitting down with real people who are representative of those segments.  

You’ll hear why someone scores an idea 7 out of 10 rather than 3 out of 10 or 10 out of 10, as it reliably surfaces the beliefs sitting behind that score, along with what people don’t prioritise in life and therefore won’t pay for. 

This research will uncover pain points, what they consider value for money, customer service expectations, frustrations related to contract length, flexibility, roaming, coverage, where they buy from, and how far a brand can stretch.  

The crucial thing to appreciate is that if you skip qualitative research completely, or skimp on it, you’re in danger of creating a proposition for a segment you can’t really define and might not even be able to reach, rather than building something based on research that surfaced genuine features people want.  

4. Research underpins negotiations with wholesale partners 

When you understand your target customers’ world you can produce messaging that will resonate. It helps you sell the idea more succinctly and identify the routes to market. This in turn helps to build the business case and work out how much it will cost to acquire a customer. This is vital for margin, driving growth and minimising churn.  

But more crucially, it puts you in a strong negotiating position with wholesale partners because your MVNO brand is based on fact not fiction. It builds a compelling case for an operator to back you and invest in making it happen. Our blog on negotiation covers more detail on this imperative. 

5. Research removes risk no start-up needs  

My final thought on research is that until you launch there are no guarantee you have a winning proposition. Sales and a loyal base tell you that. But doing thorough market analysis, segmentation and testing removes the propositions that were never going to work before you’ve spent the money finding out.  

Best of all you can be more focused on your target audience knowing it exists and build a brand with real purpose and values that matter.  

If you’re looking for a proposition that can be the next growth engine for your MVNO, or need help validating ideas to design a winning formular then get in touch. I’m happy to talk you through the steps for your specific business and set you on the right path to success.  

The post Brands that use research to build propositions, build success too. Here’s how to get it right.  appeared first on Graystone Strategy.

It’s certainly a valid concern to have on the risk register, especially in mature markets, where we see market consolidation more regularly happen. 

For those that face a migration, the fear is generally linked to how they can move customers from one platform to another without losing any. 

Often the assumption is that success will come down to getting the technology right. But in truth, tech has little to do with whether a migration goes well or not. Yes, you need to do number ports and SIMs need to be activated and billing needs to be accurate. But that’s all hygiene. The customer experience whilst all of that is going on, is what will really push someone to stay or go. 

I know, because I’ve picked up the pieces when it’s gone wrong (often spectacularly wrong), undoing years of hard-won loyalty and growth. Eye watering churn of 20-30% isn’t unheard of, but it is avoidable by making the right set of decisions. From the pace of the migration and who is moved when, to having early warning systems in place to flag when there’s the slightest of signs that things are going off track.  

It means MVNOs need to think of a migration project as a customer continuity project, not a technology one. The more the project focuses on speed, the greater the risk the customer experience is forgotten, and the propensity for churn simply goes up. Ultimately, the customer should have no idea anything is happening. They want their phone to just work. The slightest hint of a wobble and customers will walk.

That’s why we recommend clients adopt a 7-step plan for success

Step 1. Recognise the measure of success is having all your customers at the end

Do you want to save 20-30% of operating costs from a new tech stack or a host network agreement? Yes. Do you want to lose 20-30% of your customers, as a result? No. You must set out to keep every customer, and then you’ll reap the efficiency gains you expect the migration to deliver. 

The best approach is to commit to upfront segmentation and risk profiling. First, think about how customers differ by value, handset and SIM type, account structure and engagement. Each difference affects their view of your brand. Some will be highly engaged, others won’t be. Some might be high value, some might be dependent on you. 

Then overlay the risk. A high-value business customer with multiple lines has a very different risk profile from a low-engagement consumer customer, and a family account cannot necessarily be treated as a collection of independent numbers. 

It’s important to see this segmentation exercise not as an analytical one but as a fundamental part of the migration strategy determining not just who is moved when, but also how they are moved. 

Step 2. Plan to manage the risk you’ve identified

After profiling you’ll know which customer types pose the greatest risk to your brand. In my experience, creating a personalised journey, with personal handling, assisted authorisation, proactive retention offers and a direct escalation route is best.

Complex accounts need similar consideration. Multi-SIM, family, and shared data accounts should migrate as a unit wherever possible. Moving individual lines can create ‘orphaned’ services and broken accounts that are difficult to reverse.

Also be aware that a physical-SIM migration can create problems too. Customers who receive a SIM but never activate it are some of the trickiest to remedy. Typically, 3–8% of your migration base can sit in this group, making reminders, alternative delivery and assisted activation essential. 

You also need to scenario plan the impact data quality could have on your plan. For example, how will you handle the customers who don’t have to register an address (like in the UK), or move house without telling you?

Step 3. Test small, learn fast, scale accordingly 

When there are financial savings riding on a migration then the pressure to move quickly is inevitable. But scaling before you really understand how customers behave during a migration is one of the easiest ways to introduce unnecessary churn.

I usually advise starting your migration with a set of employees and friendly customers. You can test the journey end-to-end under real conditions and then define the clear go/no-go criteria for every wave of customer segment. 

Taking this first step will allow you to move to the next, which is to move a small, representative live cohort. Then you can observe, adjust, and go again with another wave. 

Skipping the pilot to save a fortnight may feel like acceleration but it can be the most expensive mistake in the project. So always, migrate, observe, learn and adjust, then scale.

Step 4. Give customers a choice

On occasions, it’s best practice to let customers choose a migration slot. This gives them some control and generally creates less friction than simply telling them it’s happening.

That’s the perfect world. But nothing can be assumed, and usually in every migration there are customers who remain unresponsive despite multiple opportunities to pick a slot.

That’s where push communications, hard deadlines and, in extreme cases, service restrictions have a role. The key is to escalate progressively rather than treat the whole base this way – we’ve seen some clumsy implementations in our time where restrictions created 8–15% churn spike.

Step 5. Communicate the benefit, not the technology

If your plan does require customer communications, then keep it simple and related to the benefits. Customers do not care about HLRs, SIM profiles or the architecture. 

Instead, answer these basic hygiene questions: Will my phone work? Will I keep my number? Will my bill make sense? And then address the service fundamentals: Will I get better coverage, network experience and value for money?

This will help you explain what is happening, when and what people need to do, if anything. It builds confidence and reduces the temptation to churn. 

Step 6. Don’t forget an error can cause upheaval beyond your control

Mobile migrations create a particular challenge because you are dealing with a person’s primary way of contacting people and use of important services. One-time passcodes delivered by SMS underpin banking, payments and government services, so if SMS breaks, you have a much bigger problem on your hands. Managing this risk needs to be a core component of your plan. 

Step 7. The first billing cycle marks the end of the project

Everyone in the project team needs to understand that the migration is only finished when the customers are happy, not when the technical delivery has happened. 

The first bill should be a test of happiness. That’s because changes to billing dates and how discounts and credits are displayed can create confusion even if the bill is technically correct. The first post-migration bill should therefore be planned carefully. Get it wrong and your churn spikes again. 

My final piece of advice is to oversee the management with a control room so you can see exactly what is happening, when, and what has happened and how it went. You’ll then be able to react in real-time, and you’ll have a ready-made reporting process for senior leaders. 

Let us guide your migration for you. We’ve delivered and advised on successful migration projects for many clients. We’re here to make yours a success too. Contact us to discuss your requirements and we’ll provide tailored advice to make it happen. 

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There’s no doubt that MVNOs offer a brilliant way to reach customers, and household names are leading the way. Telecoms has become the ‘go-to’ for any brand that wants to create a new revenue stream or give existing customers a new benefit and reason to spend money with the core business. 

And it’s happening at scale and pace. Lidl plans entry to the market in 30 territories, and the likes of Revolut, Klarna, N26, Media Markt are deliberately placing their bets on this strategy, with good reason too. It’s expected the overall global MVNO market will grow to 155Billion USD in 2031, according to Prescient & Strategic Intelligence.

If you want a slice of this, then I personally think you should look at the UK first and foremost. 

Not just because it’s my home country, but because it’s a market where the levers for success are proven, bringing more certainty to a successful and strategic outcome. 

There are nine attributes that the UK has that few other territories can boast. 

1. Maturity: The UK is the home of the very first MVNO, Virgin Mobile on 11 November 1999. I still remember where I was when it was announced. It was a daring and exciting move. 

27 years on, and the market has matured beyond expectation all those years ago. The diversity and innovation that continue to propel the market are important signals that the MVNX ecosystem in the UK is better developed than most. 

We also have a whole generation of customers who have grown up understanding that there is an alternative to the main MNOs. That is especially important if you’re a brand that couldn’t be further from telecoms, like a sports club with a big fan base, or a charity with a loyal base of donors. 

• Regulation: From a regulatory perspective, the UK is very MVNO friendly. Firstly, new entrants don’t need to apply and pay for an MVNO licence, because there are no licences, which by virtue means there’s no limitation to the number of MVNOs that can be in market 

Secondly, the UK is light-touch on red tape. There are no extreme government checks or legal hoops to jump through. This makes for low-cost entry compared to other places in the world.

Put simply, if you can secure an MVNO wholesale deal and adhere to the regulator’s general conditions of supplying telecoms services, then you can launch an MVNO.

• Frictionless journeys: In many countries, applicants for a telecoms service must undertake Know Your Customer (KYC) identity checks before provisioning a service. Typically, this includes providing your national identity card number and various other forms of ID. This adds complexity to joining journeys for customers. Happily there’s no such ID scheme in the UK so the problem goes away. 

Not only that, but in the UK, ID checks are not mandated, and so a more relaxed approach to regulation makes it much easier to enroll customers. 

MVNOs can choose to do credit checks if they plan to bill in arrears or supply a handset, but in the case of prepaid and subscription services, KYC isn’t a requirement. This reduces friction in joining journeys and makes for a far simpler app, web or retail experience.

• Mandated wholesale access: When the Vodafone and Three networks merged, the Competition and Markets Authority (CMA) placed binding provisions on the new company to provide regulated wholesale access. This was a response to the reduction in MNOs from four to three, and therefore the reduction in choice MVNOs have for a wholesale partner.

Before the merger, MNOs were free to decide their wholesale pricing and whether to grant access. However, for a period limited to three years, VodafoneThree must give an MVNO sight, under NDA, of a regulated wholesale commercial reference offer (WRO) to anyone applying.

Now that doesn’t mean the market has become a ‘free for all’ where anyone can join, but it has reduced barriers in the short term. And that’s a critical point to grasp for any brand considering entry. By taking advantage of the Wholesale Reference Offer mandate now you could get to market faster. 

• Vibrant MVNx market: Not only are there three MNOs, all of whom have a wholesale strategy in place, but there is also a vibrant local market of MVNAs or Mobile Virtual Network Aggregators, and MVNEs or Mobile Virtual Network Enablers. 

This means there are more hosting options for MVNOs. The aggregators in particular are competing to grow their market share so have some competitive offers to entice new MVNOs. Not only that, the aggregators also have a more ‘productised’ approach to launching MVN:s compared to MNOs, meaning that smaller MVNOs can find a route to market more quickly and easily.

• Consumers are MVNO ready: The near 30-year history of MVNOs means that UK consumers are very happy to consider and buy MVNO products. In fact, many don’t even know they are using an MVNO, such is the brand-pull. Indeed, some of the UK’s biggest mobile brands are pioneers in legitimising MVNOs in place of network operators. 

The British love a plucky underdog too, so MVNOs that are taking on the establishment always get kudos. Look at brands like Honest Mobile as proof of this.

• Market growth: Don’t get me wrong, joining the UK market is not a walk in the park. It’s a constant battle to compete for share and margin. But despite this, MVNOs are still forecast to increase market share, as FDM CCS Insight recently emphasised when it said that the UK market will grow from 23% MVNO penetration to 30% by 2031. Remarkably that’s in a market of over 85m mobile connections.

To illustrate the gulf between MVNOs and MNOs, you just need to look at a recent Which? survey with 5000 consumers in which Tesco Mobile was rated at 81% for satisfaction, in contrast to O2 at 67%. Even more telling is that Tesco Mobile, Asda Mobile, iD Mobile and Sky Mobile all score higher than their hosts. 

• Breadth of verticals: Growth comes from just about every vertical in the UK including sports brands, digital-first companies, utilities, financial services and retail. Success is not exclusive to consumer segments either, with plenty of buoyancy in the enterprise, IoT/ M2M arenas. All these verticals prove it’s possible to launch, refine, improve, and grow when you have the right mix of ingredients. 

Let’s not be naive to think every launch succeeds but when you understand the dynamics and lean into the market conditions to build the right proposition, service model and leadership team, then there is certainly every opportunity for a challenger vertical to succeed. 

The nine points above make the UK market the best to use as a test ground before moving into other markets around the world. I know because we’ve helped UK MVNOs take proven concepts worldwide.

Our team of UK and global experts help brands navigate market dynamics, launch and sustain brands in the UK and then take them to a global stage. Those brands might be in the UK, or on the other side of the world, but every single one is given the strategic advice they need to succeed here and stretch to other countries. 

So, no matter if you are a local or international brand pondering a UK / multi-market MVNO launch, then talk to us. We’ll help you design a strategy, from commercial deals to technical infrastructure, that delivers sustained results.  Want to find out more, book a call now.

p.s. Maybe that is the tenth reason why you should choose the UK market!

The post 9 reason the UK is the best market for new MVNOs appeared first on Graystone Strategy.

MVNO Nation’s Industry Icon award is part of a new category of leadership awards that’s been introduced to honour exceptional individuals making a lasting impact on the industry.

From actively shaping the future of the industry through innovation, leadership and disruption, to those who show a long-term contribution to the global MVNO ecosystem. The winner will be decided by a jury of industry leaders and analysts, and announced at the MVNO Nation conference, held in Alicante on 4th November. 

James Gray, managing director at Graystone Strategy, is delighted to have been nominated “Being shortlisted for the inaugural MVNO Nation leadership awards is hugely humbling and I am delighted to be recognised in this way. I’m very much looking forward to being at the conference and celebrating everything I love about the industry.” 

The following month, Telecom.com’s Global Telecoms Awards, or ‘Glotels’, will celebrate international innovation and achievement in the telecoms sector. Graystone Strategy has been shortlisted to win the Telecoms Excellence Award, which celebrates an overarching, standout achievement that pushes the boundaries of capabilities, operational efficiency, or service delivery across the global telecommunications sector. 

Winners will be chosen by a panel of judges comprising Telecoms.com editors, industry analysts and telco leaders, and announced in London on 1st December. 

James says the nomination is a gratifying acknowledgement of the team’s expertise and commitment to deliver excellence every day, “The Graystone consultants are experts in their field, working with all types of organisation, at all phases in their growth. From start-ups to household brands, we’re working side by side with leaders, helping them make the right decisions at the right time for continued success.”

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Graystone Strategy, the specialist strategic advisory firm to MVNOs, operators and vendors, announces it will form part of the expert team of MVNO leaders, analysts, and commercial specialists chairing MVNO Nation Europe 2026, taking place from 3–5 November in Alicante, Spain.

Taking the theme of ‘The Next Chapter of MVNO Growth’, this year’s event will explore how MVNOs can compete and grow in an increasingly complex European market. With more than 2,000 MVNOs now operating globally, the sector continues to evolve rapidly, while European operators face intense competition, regulatory complexity, tight margins and rising customer expectations.

The conference will focus on a range of topics including practical strategies for sustainable margins, explore the impact of market consolidation and regulation on the sector, consider how AI can be used to unlock customer growth, highlight the new opportunities presented by technologies like eSIM and look at how the network and connectivity landscape is changing and the impact it will have.

Graystone Strategy’s managing director, James Gray, and commercial and customer growth consultant, Jo Hermon, will bring their vast MVNO experience and commercial expertise to the event, by chairing days one and three of the event, and hosting panel sessions and workshops. 

Jo and James will work as a team  leading the conversation on new growth opportunities including a panel discussion ‘From tech addicts to tech-savvy—how MVNOs can make a real impact on society’, before heading to the changemakers’ roundtable with James to discuss the topic: “Show me the value of AI. How MVNOs use AI tools”. 

James will also chair day three, focused on sharing stories that will inspire MVNOs to build strategies that meet customer expectations.

The event also includes the prestigious MVNO Nation Awards at which the winners of the inaugural MVNO leadership awards will be announced. James has been nominated in the category of ‘Industry Icon’ for his long-term contribution, leadership and impact on the progress of the global MVNO industry. 

James Gray, managing director, says the event and awards are a chance to propel the industry into a new era of growth, and celebrate the incredible achievements of the last year: “MVNOs are entering another fascinating phase of growth. The opportunities are significant, but success increasingly depends on having a clear proposition, understanding customers, and building commercially sustainable strategies. MVNO Nation is therefore perfectly timed and will allow visitors to genuinely evaluate what role their business will play in shaping future success and celebrate what they have already achieved.”

Graystone Strategy will be available throughout MVNO Nation Europe to meet with MVNOs, MNOs, technology providers and other organisations looking to develop, launch, scale or transform their business. To book a meeting with the team drop us a message or click here.

The post Graystone Strategy chairs MVNO Nation Europe in Alicante appeared first on Graystone Strategy.

The proposed acquisition of TalkTalk by BT is fast becoming one of those stories where what seems to be the obvious answer to bailing out an ailing brand may not be a perfect or complete one. 

If you’ve been reading all the analysis in the last 24 hours, then you might also have concluded that BT’s decision to step in to rescue TalkTalk from administration with a £400m deal is understandable. TalkTalk has been struggling for some time, and the business has reportedly been unable to find an alternative buyer despite an extended sales process.  

Its long-term difficulties are well documented: declining retail customer numbers, cashflow problems, and a substantial debt burden. The business also operates in an intensely competitive broadband market, with ridiculous pressure on margins that are hard to remedy. 

So, BT stepping in and saving the day (and cash on the purchase value), is a sensible strategy for a brand that wants to grow its customer numbers and affirm its place in one of the world’s most complex and competitive telecoms markets.  

The intervention protects services for around 2.5 million customers and around 900 jobs, with continuity for customers who rely on broadband and voice services every day, including vulnerable customers and organisations providing essential public services. 

When a rescue risks restructure  

That really matters, as Culture Secretary, Lisa Nandy MP, made clear when she issued a Public Interest Intervention Notice to speed up the regulatory process for the BT deal, citing risks to public services and vulnerable customers if the TalkTalk’s services were disrupted. 

But alarm bells ring. Could this intervention inadvertently increase market power? Let’s not forget that the week before this story broke, the CMA provisionally said that the £2bn acquisition of Substantial Group by nexfibre might diminish competition in the wholesale fixed broadband market (the inquiry continues). 

So, with that context, and given the scenario the BT / TalkTalk deal presents, at what point does giving the go ahead on the grounds of protecting the connectivity of millions of customers give way to a permanent restructuring of the market?  

Here lies the dilemma and the debate.  

Could TalkTalk’s failure actually be the right outcome for healthy market competition here? Hard as it is to comprehend, should any company bail it out? 

Lutz Schüler, CEO of Virgin Media O2, has made precisely this distinction in his open letter to Lisa Nandy MP. He argues that there is a difference between ensuring short-term continuity for vulnerable customers and allowing a permanent ownership solution that effectively hands the business to a dominant incumbent without a proper competitive process.  

It could be argued that setting a deadline of October 19^th to the CMA to decide the market fate, undermines the regulatory due diligence process the UK is known and celebrated for. Not only that, it doesn’t address the market dynamics of ‘distress’ that have led to TalkTalk’s plight. 

To summarise the views expressed, Lutz has called for credible alternatives to be explored and for the longer-term implications for competition to be properly assessed. 

And here lies the crux of the debate we see unfold before us. It raises a legitimate question about consistency in UK telecoms regulation. But will these alarm bells be dismissed as cynical because they come from a competitor? 

Is a staged approach the only approach? 

If you look at the Vodafone–Three merger, a commercially driven transaction, the CMA conducted a detailed investigation to decide whether it could go ahead over the course of 14 months (not 14 days).  

When the CMA granted the merger, there were stipulated remedies, including a £11bn network investment programme, protections for certain retail tariffs and wholesale access commitments for MVNOs.  

These aren’t small things. They are significant and protect market dynamics, competition and consumers. 

Though the TalkTalk situation is different by nature of it being a rescue of a business in administration, rather than a conventional strategic acquisition, there’s a strong argument that governance should still apply i.e. the implications for competition cannot be neglected simply to keep the router lights on, and nor can it be an afterthought, otherwise you set a precedent that there’s a backdoor to CMA approval. 

Where does that leave us then?  

I asked at the beginning, is letting TalkTalk fail altogether the right thing to do? 

I’m not sure it is. Perhaps the real debate is more about who should save it, under what conditions, and with what safeguards for the markets. 

That’s why I think there may be a way that protects both customers and the competitive structure of the market. The process could potentially happen in stages. 

Pritoritise, stabilise, future proof 

The immediate priority has to be the customers and employees currently caught in the middle. They should not become collateral damage in a debate about market structure. So, stage one would be to allow BT to stabilise the business and protect customers, while allowing the CMA sufficient time to assess the permanent ownership question.  

Then, if deemed appropriate to allow BT to complete the deal, the CMA can assert the appropriate structural or commercial remedies needed to protect consumer interests – the very core of its remit – before a permanent transfer of assets to BT.  

And if it’s declared uncompetitive, then we all know where we stand, and the credible alternatives Lutz calls for can be found.  

Not only that, with such an approach you protect the vulnerable and critical today without weakening competition in the future.  

And that matters. That really matters.  

 Want to gameplan how this significant and incomplete story might affect your business? We’re here to help, drop us a message, or book a meeting here. 

The post When is telecoms M&A in the public interest? appeared first on Graystone Strategy.

I raised the point, because, unlike other regulators that use MVNOs to rebalance competition, the announcement from the PTA carried no stipulations on reference offers, access pricing, or even a wholesale obligation of any kind.  

The intent was reliant on MNOs voluntarily accepting approaches for an MVNO on their network and playing nicely if they went ahead. This also included trust that an MNO wouldn’t blur the lines between MVNO, flanker and sub-brands.  

This week, we witnessed the impact few guardrails have, when the PTA ordered Pak Telecom, owner of Ufone, to stop trading ONIC, because it was deemed to be an MVNO not a sub-brand. As part of its ruling, PTA noted that Pak had in effect circumnavigated the MVNO rules. Pak has three months to migrate the ONIC customers on to the core MNO.  

It looks like a duck, sounds like a duck…  

The PTA edict sends a firm message to the market: Pakistan is looking for real MVNO competition, not new brands operated by an existing MNO under a different commercial and operational structure. 

That distinction is important. ONIC was positioned as a digital-first proposition, with its own brand, price plans, app and customer proposition. But the PTA argued that when you lift the bonnet the underlying operating model tells a different story, leaving the PTA to conclude that the proposition falls within the MVNO framework. 

It highlights that even experienced teams can get it wrong, especially if the rules are left to interpretation. Circles, which underpins ONIC, is not new to MVNOs. It operates its own digital telco propositions while also providing technology and platform capabilities to other MVNO businesses.  

The fact that an experienced telecoms organisation, working alongside an established operator, has ended up on the wrong side of the regulator’s mandate is therefore a surprise. 

And there lies the lesson for every MNO considering its next move. 

Wholesale needs to be a strategy, not a side project 

The Pakistan’s MVNO framework still presents a significant opportunity for new market entrants. But if operators want to capture new wholesale revenues, they need to treat wholesale as a singular business unit.  

That means MNOs must separate the wholesale business away from the core business, so the wholesale team sits independently, with clear governance, dedicated commercial capability, and, above all, awholesale strategy. 

The PTA will not tolerate those who take an existing retail proposition and wrap another brand around it. Instead, operators need to consider how they can use MVNOs to grow their business, and as part of this decide which types of customers they want to bring onto their network through wholesale and, perhaps more crucially, why. 

All around the world are examples of MNOs who use MVNOs to reach segments that the core brand will never attract. They’ve tapped into the power of brands in retail and consumer electronics, even sport clubs, to win share in specific verticals, meet the needs of underserved customer groups, and launch digital propositions that appeal to different demographics. More often than not, they’ve also included strategic distribution partnerships to generate genuine incremental growth. 

Being selective is the key to success.  

A well-designed wholesale strategy allows an operator to identify the types of partners that add value, target the segments where there is a gap in the market, and structure propositions that grow network revenues without simply cannibalising the existing retail base. 

But I cannot stress enough the importance of recognising the distinct difference between selective wholesale and protecting the retail business, because as we’ve seen with ONIC, getting the boundaries between commercial, operational and regulatory wrong is expensive. 

Operators have a huge amount to gain, but they can only achieve success if they build an exclusive wholesale strategy, one that sets a clear direction for growth. It needs to be built on critical insights, underpinned by a carefully designed wholesale commercial model.  

It also requires a clear technology roadmap and the supporting infrastructure MVNOs need to succeed beyond a good deal on wholesale pricing, such as customer service and marketing support. The relationship will then work two ways. MVNOs will get value from the partnership and grow, creating growth for the host.  

I’m in no doubt that Pakistan’s new MVNO regime can bring new brands, new distribution models and new sources of incremental growth into a mature mobile market. But to make it a reality, it’s clear operators need to start playing by the new rules sooner rather than later.  

At Graystone, we’ve developed high growth wholesale strategies for operators, MVNOs, MVNAs and MVNEs across multiple global markets. We’re well-placed to help Pakistan’s MNOs capitalise on early mover advantage, so contact me to discuss how we’d do it for you.  

The post Pakistan’s MVNO rules just got real. Operators need a distinct wholesale strategy.  appeared first on Graystone Strategy.

At almost the same time as the merger closed, the Pakistan PTA opened applications for MVNO licences. Since then, enquiries to our team have centred on which route-to-market strategy to follow, given the significant drop in the licence fee from $5m to $140,000 and some of the licensing framework arrangements that are in play. 

What’s driving this?

Usually, MVNO licensing is opened when a regulator wants to rebalance competition after
consolidation has handed a single operator significant market power. Pakistan’s timing fits that pattern almost too neatly: the licensing window opened in late June, days before the merger closed. But the framework itself tells a different story. It carries no reference offer, no access pricing, no wholesale obligation of any kind. Whatever it is, it isn’t a remedy.

The real drivers sit upstream, in economic policy. Uraan Pakistan, the government’s National
Economic Transformation Plan 2024–29, makes “E-Pakistan” one of its five pillars and hangs an
ambition to double exports to around $60 billion by 2029 on digitalisation.

The Digital Nation Pakistan Act, in force since January 2025, created the Pakistan Digital Authority under a commission chaired by the Prime Minister. Both need digital services to reach people that telco retail hasn’t.

With the sector past 200 million subscribers and growth now coming from data rather than SIMs,
MVNOs are the cheapest instrument available: fintechs, ISPs, cable operators and technology firms brought into mobile without a rupee of new spectrum or infrastructure.

This is growth policy wearing competition policy’s clothes and is precisely why the wholesale terms were left to the market. 

No regulated wholesale access 

As approvals and integration work for the merged entity progress, we could expect to see some regulatory remedies tied to it. Until then, and unlike other jurisdictions around the world, Pakistan hasn’t introduced regulated wholesale access. 

MNOs are under no obligation to accept MVNO applications, publish wholesale pricing or offer standard commercial terms. They decide who they partner with, on what terms, and at what price. 

For MVNOs, this means entry depends on finding an MNO partner willing to use MVNOs to reach a market segment they can’t otherwise serve, and one who will offer fair terms. 

Narrow safeguards 

The safeguards that do exist are narrow. An MNO cannot degrade, suspend or terminate an MVNO’s service without PTA approval. And every commercial agreement must be submitted to PTA and approved before it takes effect. Once approved, neither party can change it without PTA’s written consent.  

That is protection of a kind, but it is procedural, not economic. Nothing in it guarantees fair wholesale pricing. It also cuts both ways: an MVNO that negotiates badly will not be walking away from that agreement quickly. 

Proving strategic value is critical 

It means every MVNO needs to prove the value they will bring in terms of incremental subscribers and be ready to negotiate terms that make the ambition a reality. More importantly, every operator will need to set fundamental strategic foundations to ensure participation in the new MVNO era supports growth. 

It’s worth noting that MNOs who have done this in other parts of the world use a strategic scorecard for the type of MVNOs they will partner with. This gives clarity of purpose, enables the wholesale teams to understand who they should work with, and gives clear strategic reasons to MVNOs and regulators why an MVNO may not have got a deal. 

There are some ‘watchouts’ for MNOs in all of this. Price too high, or with too many complex clauses and not enough support built in, and MVNOs could fail before they even start. Not only that, if MVNOs discover there are better terms to be had elsewhere, they will leave at the first opportunity the agreement allows. 

Getting this right is crucial. Let’s not forget, MVNOs don’t come in one size. Full, light, MVNE-enabled and even MVNA models are all viable options. The framework itself is silent on this. It licenses a single MVNO category and says nothing about technical models, so which of them gets built in Pakistan is a matter of MNO strategy, not regulation. And that strategy could be just as varied as the models themselves. 

What paths might the remaining MNOs follow? 

For Jazz, the market leader, wholesale could become a strategic imperative. It’s a controlled way of expanding into adjacent customer segments (ie ones it can’t reach otherwise) and do so without diluting its own retail brand. It’s also a way to protect retail margins, a perpetual problem for operators everywhere. 

Above all, Jazz needs to be acutely aware it can’t operate in a vacuum. The ‘prisoner’s dilemma’ can’t be overstated, and the margin here is thinner than most. With less than half a point separating Jazz from the merged entity, a single well-executed MVNO deal on a competitor’s network could change who leads this market. It therefore makes sense to have the traffic remain on its network, with control of the deal and value through wholesale pricing, rather than be a victim of a competitor’s strategy. 

For Zong, which has a lower market share, wholesale could be exactly what it needs. Following an MVNO strategy would open the distribution channel and help drive incremental growth in a mature market. 

In our experience, the smallest operator almost always has the most aggressive wholesale strategy. They have the most to gain and the least to lose. Virgin Mobile proved this when it became the world’s first major MVNO. It happened because One2One, later T-Mobile UK, was the smallest operator in the UK in 1999, and was full of growth ambition. 

Whereas for e&, there’s a different dilemma. Does it use wholesale to shore up revenue in a business going through massive upheaval, bringing two brands, sets of processes, employees and infrastructure together? Or does it wait, get the foundations right, but risk missing the MVNO boat? 

It could viably take an easy route and only offer full MVNOs, assuming it has the capability to do the technical integrations to make it happen. 

Fortune rests on multiple factors 

For each of the operators, the answer will have a material impact on their own fortunes and on the overall market’s success. Pakistan’s economic and digital ambitions set a new tone for mobile, especially in a market which can no longer rely on subscriber growth. 

When you look at other regions around the world using MVNOs to unlock innovation and growth, success has come down to multiple factors. There’s never one single golden arrow. 

Brand differentiation from the competition, targeting a clear market segment with an innovative offer, managing channel costs and changing the overall model are all as important as each other. 

It’s also worth noting that in less developed markets there is always initial success with price challengers, but this isn’t sustainable in the long term. And absolutely nothing is possible until the market has foundation commercials that enable a reasonable level of margin to fuel business growth. 

MNOs are not competing with MVNOs.  

Pakistan faces a competitive dynamic it hasn’t seen before, and strategy directors need to reframe their thinking. This isn’t about MNOs competing with MVNOs. It is about MNOs competing to attract the MVNOs that will deliver incremental customers to their network and deny competitor networks the chance to take customers from their existing base. 

That is the paradox at the heart of this market opening. The regulator has opened the door to competition but made cooperation the only way through it, leaving the terms of cooperation entirely to the operators that the newcomers will compete against. 

Operators therefore need to set out what type of MVNOs they want to attract, and how. But most of all they need to commit and get it right first time. Afterall, fortune favours the brave.  

What’s your strategy? If you need help determining your wholesale approach, then get in touch.

We’ve done this analysis and strategic development in numerous markets facing the same market shift, with countless success stories to show for it.

The post Pakistan’s MVNO Cooperation Paradox  appeared first on Graystone Strategy.

Member only pricing sits at the core of the offer. Membership is £39.99, unlocking benefits that includes free delivery, extra savings, unpacking and recycling services for retail purchases, and finance deals on SIM free phones every 24 months. 

Plus there’s an exclusive ‘one size fits all’ member tariff for £12. It’s a straightforward 30 day SIM only deal with 500GB, unlimited calls and texts. It also includes a reasonable 15GB of roaming with an option to top up with boosters. 

The obvious comparison to make is with iD Mobile, which falls under the Curry’s brand. iD has led the way in terms of electronic retail MVNO models, introducing a range of price plans from monthly to SIM only, and device bundles. This leverages its retail strengths and heritage inherited from Carphone Warehouse.  

However, what iD has not achieved yet, is a full integration into the Currys shopper base, whereas it’s clear this is very much the intention of AO. 

It will be interesting to see how this plays out particularly as both MVNOs are on the Vodafone network. There is no difference in coverage or network service so it will come down to proposition and value. 

Will embedded member benefits and simplicity win, or will the more traditional MNO approach of a wide range of tariffs, offers and handsets be preferable? It’s perhaps not something you can split in such a black and white way. Each brand knows its customers and has a proposition to suit. That said, I suspect the cautious approach from AO will need to change to be more bullish and give people a wider range of price plans to choose from.

The trend for retail MVNOs shows no signs of slowing

Of course, AO’s launch is part of an ongoing global trend of retailers launching MVNOs to make loyal customers even stickier. UK examples include Tesco Mobile, Asda Mobile, Superdrug Mobile, Coop Mobile, and further afield I’d point to the German retailer MediaMarkt’s Let’s Go Mobile brand and Bait from Walmart in Mexico. 

We’ll see more over the next 12-24 months. Lidl is already well on its way to introducing mobile in 30 markets and I firmly expect more to follow suit in Europe, but also emerging markets where regulators want to open up competition. It all supports the predictions that the segment will grow by 50% from $4.8bn to 7.3bn by 2031.

Is that really possible? Yes. Everywhere you look there are retailers with a large footprint that can use mobile to convert customer footfall into additional value and loyalty. From supermarkets, through technology stores to fashion brands, they all have the ingredients provided they can create a proposition full of unique value and strike wholesale terms to underpin growth. 

I’m also sure that sooner or later one of the highstreet banks will realise that they need to address the impact of Lendable, Revolut and the Neo banks. Consumers are open to this type of ‘retail’ offer too and with the right help, brands have it in their gift to capitalise on the opportunity quickly. 

But whichever brand is next, one thing is for sure, the UK MVNO environment remains as vibrant as ever. Just the way I like it! 

We have worked with retail brands in developed and emerging markets around the world, helping them understand the scale of the local opportunity and how to bring it to market (you can see how we’ve done it with Apple Premium Re-seller here). If you are a brand trying to understand how mobile will add value, and encourage customer stickiness then get in touch here.

Further reading 

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Dig a little deeper and lack of focus on the bottom line or failure to understand the dynamics of a marginal business are often the root cause.

Why margins are under pressure

Average revenue per user (ARPU) has been declining for some time, but today’s economic environment has made the impact much more significant. 

Many network operators have responded by introducing annual inflation-linked price increases. Although this helps offset rising costs, it often damages customer relations and can lead to increased churn, something MVNOs have benefitted from.

Few MVNOs have this luxury. They may win customers from MVNOs who price hike, but there’s little point in the long-term if they can’t make sufficient margin to cover the acquisition cost.

There’s also the backdrop of wholesale arrangements, which can restrict the choices MVNOs have when it comes to making price adjustments.  

For instance, for MVNOs offering large data bundles or even unlimited, and relying on customers to use than they buy, (known as breakage), will find relatively few heavy users will break the model and erode all the margin. Edge cases really do matter in the breakage model.  have this model broken and all the margin eroded by a relatively small number of very heavy users.

Edge cases matter in the breakage model because in effect, the MVNO is paying more for wholesale data, yet unable to raise prices to compensate. The breakage that once contributed to healthy margins gradually disappears and the result is a steady erosion of profitability.

Even MVNOs that purchase fixed data bundles from their host network shouldn’t assume they are immune. While these arrangements may currently shield MVNOs from some of the risk, wholesale providers continually monitor usage trends. As customer behaviour changes, wholesale pricing is likely to evolve too, reducing today’s advantages over time.

There is no single solution

Margin recovery rarely comes from one dramatic change. Instead, the strongest results usually come from improving several areas of the business at the same time.

Small commercial improvements, operational efficiencies and product enhancements can combine to create a meaningful improvement in profitability. The trick is to do it without fundamentally changing the customer proposition. 

So, what are the four things we recommend?

1. Start with the wholesale agreement

For most MVNOs, wholesale costs represent the largest single expense, making them the obvious place to begin.

A contract review may uncover opportunities to negotiate improved commercial terms, marketing support, growth incentives or revised pricing structures.

However, successful negotiations require realistic expectations. Any concession from an MNO will almost certainly come with commitments in return, whether that’s longer contract terms, customer growth targets or other commercial obligations.

It’s also worth recognising that host networks are experiencing many of the same financial pressures. Their infrastructure costs are increasing, while their own retail businesses face similar margin challenges. Negotiations are therefore most effective when both parties can identify mutual long-term value rather than simply seeking short-term price reductions.

2. Understand your negotiating position

Before entering any wholesale discussions, it’s essential to understand the balance of power within the relationship. Read our negotiations blog here.

Suggesting a move to another network can be an effective negotiating tactic—but only if it’s genuinely viable and you are prepared to do it. Migrating customers between host networks carries significant operational risk. 

The risk mainly lies in customer disruption which can increase churn, increase customer support costs and reduce lifetime value. Host networks understand these risks and will challenge an MVNO’s willingness to switch. 

For that reason, any negotiation strategy should be based on careful commercial planning rather than tactical brinkmanship.

3. Focus on acquisition quality, not just volume

Another opportunity to steady margin lies in customer acquisition, or rather, attracting a better quality customer.

Of course, reducing acquisition costs is valuable, but winning higher-quality customers often delivers greater long-term returns.

It’s therefore vital MVNOs understand which customer segments generate the greatest lifetime value. Bear in mind, it’s not always the customers on the biggest bundles. I’ve seen MVNOs be very successful with a good mix of medium to low users who are happy to spend a relatively small amount, use little data and stay forever.  

With this knowledge, they can invest in the most effective acquisition channels while reducing spend on lower-performing ones. Since channel performance changes over time, it’s crucial to do regular reviews of commission structures, incentives and marketing effectiveness.

If you take this path, then be aware that the objective isn’t necessarily to acquire the largest number of customers. A smaller base of loyal, profitable subscribers will often create more value than a large pool of price-sensitive, high-data users.

4. Create additional sources of value

Be warned that cost management alone won’t solve the margin challenge. Sustainable profitability also depends on increasing customer value.

Many MVNOs have opportunities to strengthen their proposition through complementary products and services. There are examples all over the world to take inspiration from. Everything from device insurance and cyber security services to family safety features, handset financing, entertainment bundles and broader multi-play offerings.These services can generate incremental revenue while also strengthening customer relationships. We’ve proven numerous times with our clients that value-added services improve retention, increase customer lifetime value and create additional differentiation in highly competitive markets.

Building healthier margins

Margin pressure isn’t going to go away. In fact, it will probably get tougher. Rising data usage, changing customer expectations and increasing operating costs mean MVNOs will need to continually adapt.

The brands that succeed will be those that treat margin management as an ongoing discipline rather than a one-off exercise. They will also understand that combining stronger wholesale agreements, employing better acquisition strategies, developing smarter customer segmentation and introducing enhanced propositions, will build more resilient, profitable businesses that are well positioned for long-term growth.

If you need help negotiating better wholesale arrangements to drive margin improvement, then talk to us. We’ve helped MVNOs all around the world adopt strategies for continuous margin management and grow their business as a result. 

For further reading, see our ‘The art of the wholesale deal:5 things Every MVNO must do‘ blog.

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