Yet, for employees there will be uncertainty. Having worked in both companies over the years, it’s fair to say that bringing together two diverse cultures will be a significant task for the leadership team. For the merger to work, people will need to be at the heart of the discussion. 

Reducing duplication

That will bring about a debate on skills needed today and how it must bend as the new company goes through various transitions. What does the HR strategy look like for a new company of this size and nature, and what resource is needed to suit the future strategic direction? 

We’ll learn more about this as the broader strategy unfolds, but there can be no doubt that successful delivery will be underpinned by the mammoth network integration and rationalisation. After all, this was the prevailing case for a merger; if the UK wants to lead on connectivity then this must happen. 

Technical integrations of this scale take years. However, everything that hangs off the network must also be consolidated. There will be no luxury in having two of everything – two CRMs, two brand agencies, two BSS. The list is endless. Expect a scrap between the suppliers vying for strategic partner status. 

In the short-term, employees will welcome the job security that will come from managing the process of reducing everything by half. But – and it pains me every time I write this – jobs will go as the process kicks in. 

Three will fade

Getting back to the real basics of a brand, Vodafone’s  has much more equity than Three’s and ratings by the likes of Which? show how far behind Three is. It’s always been my hunch and it remains so now that I’ve seen the new logo, that the Three brand will eventually be dropped and making it easy to revert to a singular brand identity. I’m not a brand expert but I can’t see how a 51% stake in favour of Vodafone plays out any other way. VodafoneThree will be intent on making every ‘synergy’ it can for the ‘new normal’ and that includes the brand. (Buzzword bingo at its best.)  

Wholesale reviews

At a wholesale level, the remedies are now in full swing, so there will be some frenetic energy in the market. I suspect the wholesale team will be inundated with requests as every MVNO takes a look at what there is to gain. And, depending on the scale of the commercial requests, commercial aggregators like Gamma, eSIM Go and Gigs will be asked to step in. Good news for that side of the market. 

But what of the customer? 

Isn’t this all about them? Customers won’t care about any of the above so long as they get good value and service. 

They might start to care more about the impact of the merger when store closures are announced as the retail estate is thinned, or the inevitable network outages happen as a consequence of the integration projects. There’s just no way of avoiding interruptions to service that the aspects of bringing together large organisations will cause. 

There could be a bit of immediate friction too. Higher value Vodafone customers might balk when they realise former Three customers get ‘all you can eat unlimited deals’ for a fraction of the price. It will be interesting to observe how they handle this. 

What’s the right course of action for MVNOs?

1. Request reference commercials – This requires a written request, signing an NDA and, if you are a new company, a convincing pitch to VodafoneThree that you will deliver scale.
2. Review propositions – Can you do something new to target customers who question the validity of staying a VodafoneThree customer? Should your plan be to anticipate outages and seize on the chance to swoop in? 
3. Review your three year strategy – I would expect VodafoneThree to have very specific remedy and post remedy strategies so be warned. Discuss your options now, not when there’s a surprise change. 
4. Use your clout – If you are an MVNO on either Vodafone or Three building and protecting a base you have commercial clout post remedies. Turn this to your advantage and do the analysis to determine if your current wholesale offer is better than taking the remedy offer.
5. Think about your talent pipeline – There will be some great people, with huge experience and knowledge coming into the jobs market. Think about how you can scale with them onboard. 

If you want help running analysis of your commercial terms and how making adjustments could help you grow your business more quickly, then get in touch. We’re here to help. 

The post MVNOs look out. VodafoneThree has landed. appeared first on Graystone Strategy.

It’s therefore the perfect venue for the MVNO meet up of the year. With almost 600 delegates expected today, the breadth of expertise and experience is evident. As chair, I will welcome visitors from USA to Australia spanning MVNO, MVNE and MVNA.

In 30 years of telco, I don’t think there has never been a time when the industry has been as dynamic. Projected growth for the MVNO market reflects a steep upward trajectory with estimations of total value topping $150 billion by 2031. That’s an incredible 7.7% CAGR—driven by technological innovation, the customers demand for flexibility, and new entrants redefining what virtual operators can do.

I’m particularly excited that the event will have a strong representation from South America, Africa, and Southeast Asia, where digital-first propositions and low infrastructure costs are creating fertile ground for growth. These territories show that when regulation opens a market, and the shackles of legacy systems are negligible, rapid growth is achievable. As we’ll hear at various talks, launching an all-digital low cost MVNO is entirely possible in weeks.

Likewise, European and North American counterparts will illustrate how they are quickly carving out new avenues for growth using Enterprise IoT, AI and eSIM to differentiate.

The focus of the conference won’t necessarily be on the ins and outs of the technology, although there are plenty of opportunities to learn from the GSMA. Instead, we’ll uncover how brands are using digital journeys to deliver value – critical for building that all important margin. Innovators like Pendula will explain how Australian MVNO brands are using AI to keep customers engaged, and there’ll also a session on ‘growth hacks’ from the applied use of technology.

But it’s the lived experience that is often cited as the most valuable aspect for anyone new to the sector. That’s why I’d encourage people to join as many of the case study presentations as they can.

It’s the best way to get real insight on how brands are innovating and learn what could be transposed to your business. A good place to start will be RedBull’s presentation, which will lift the lid on its strategy to create a highly engaged fan base.

This year’s agenda will also look at the realities of running an MVNO. The panel discussions on successful marketing strategies should be high on the list of sessions to attend. If there’s one industry that proves that the philosophy of ‘build it and they will come’ is flawed, then it’s MVNO. Too many feisty start-ups have failed to deliver on the promise because they didn’t understand their target segment or how to communicate with them.

I’m also pleased to see that we’ll continue the discussion on diversity – expanding on last year’s panel looking at how women join the industry and progress careers, but also how we make the workplace more inclusive for divergent thinkers, and those with a disability. It’s an urgent conversation for an industry that prides itself on delivering affordable communication tools to customers, and I encourage people to take the opportunity to reflect on their company values.

Sustainability continues to get more airtime, and rightly so. Negotiating regulatory frameworks and setting industry standards are topics that can elude a scaling MVNO. But as research shows, they can’t be ignored forever. The conference will give people time to consider their role in building sustainable futures.

I’m a big believer that the success of a congress like this can’t be measured by the quality of speakers alone. I think the quality of conversations we will have over coffee (or a beer) are also a sign of how important events like this are.

Already, I know of deals that have been signed, but most heartening I have heard stories of people reconnecting after years of not being in touch and having vibrant discussions. For an industry that deals in connection there can be no better endorsement of the power of the MVNO community.

This is more than a conference—it’s a global forum for collaboration. Whether you’re here to find partners, share best practices, or challenge the status quo, I encourage you to connect widely, ask boldly, and think big.

The post My message for MVNO World – connect widely, ask boldly, and think big. appeared first on Graystone Strategy.

But, in gathering reaction from leaders across the market, I can see that several clauses in Friday’s CMA announcement rattled a few cages.

For instance, if you take this paragraph at face value, you could conclude it’s game over:

“may be expected to result in a substantial lessening of competition (SLC) in two markets in the UK. These are the supply of retail mobile telecommunications services to end customers, including both consumers and business customers (the retail market), and the supply of wholesale mobile telecommunications services (the wholesale market). “

In truth, there is nothing new here – it’s the CMA’s remit to explore this aspect of a merger.

The same is true for this clause – it’s not a new concern.

“The Merger would reduce the number of MNOs from four to three, making it more difficult for independent MVNOs to secure competitive terms, restricting their ability to offer the best deals to retail customers. This is important because many MVNOs price aggressively, often focusing on value segments of the retail market.”

It’s true, MVNOs who are usually challengers and price leaders could experience wholesale price increases and hence be unable to drive competition. But if contracts have been drawn according to what I believe to be best practice, and would always recommend, there will be some price protection and the option to renegotiate periodically. If wholesale prices went up, then of course, over time we should expect retail prices to rise too. But there are ways to remedy both challenges, which I’ll get on to.

“Most consumers also told us that they would not be willing to pay more for better quality. We therefore have significant concerns about the impact of the Merger on the large number of consumers who might have to pay more for improvements in network quality they do not value.”

I’m sure if you were asked if you want to pay a premium for quality, you’d be reticent.

But let’s be pragmatic for a moment. If it was a wholly price-based decision, wouldn’t Three as the cheapest mobile operator have the most customers in the UK market? There is clearly a difference between what consumers say and what they do, and I think the JV will push back on that.

It’s this paragraph that reveals the nitty gritty of the debate and indicates that compromise and negotiation are options. The CMA is willing to consider remedies that the two parties want to put forward.

“We are also consulting on potential solutions to our competition concerns. These include legally binding investment commitments overseen by the sector regulator, Ofcom, and measures to protect both retail customers and customers in the wholesale market. We will retain the option to prohibit the Merger should we conclude that other remedy options will not address our competition concerns effectively. In our notice of possible remedies, published alongside our Provisional Findings, we have set out more detail on options to remedy the provisional SLCs.”

If it were me, MVNOs and wholesale remedies would be top of my list. I think they will feature strongly as the parties explore options. But to understand why, we need to look at what else is on the table.

So, what is on the list, and which have merit? 

1. Divestiture, for which there are two directions 

The first is getting one of the parties to divest an asset. The CMA has pretty much suggested that there isn’t a company that could be carved off and could still trade as a separate entity. If we were talking about O2 back when they had proposed a merger with Three, then the Tesco Mobile JV and gifgaff would have been a reasonable candidate for divestiture but there are not really any options between Three and Vodafone.

However, an extremely radical (and highly unlikely) proposal could be to package up all the various sub brands of Voxi, Talkmobile and SMARTY and sell them to a third party which operates them applying MVNO economics.

It’s not as crazy an idea as it might seem, were it not for the relatively low customer numbers involved (probably less than 3million). It’s that which makes it a) difficult to justify a rebalance in the market and b) hard to find a buyer.

The other divestiture available is spectrum assets. There has been lots of talk about this and it is an obvious target. The CMA seem unconvinced that this will significantly alter the competition in the market. The merging parties have been pre-emptive, and if the merger is granted, have agreed with VMO2 (which need spectrum) that it will bring Three into the existing VF/ VMO2 site share agreement.

2. The next remedy is an investment commitment.The CMA needs to be convinced that the parties will make the investments outlined in their plan. If this goes ahead then I think this is almost a given that the CMA will seek to have some sort of binding commitment for this.
3. Retail customer protections is the next.In effect, the merged entity will be expected to honour current offers and pricing in the market for a negotiated period. This was one of the concessions made in the Channel Islands merger that Graystone was involved with, and with that experience to hand, I suspect this is something that can be easily agreed.
4. It’s therefore highly likely there will be a reliance on wholesale and MVNO remedies, with numerous tried and tested options apparent in other markets.

The first is the solution of divesting some spectrum to an MVNO to allow them to become the new fourth market entrant. We have seen this solution applied in Spain recently after the merger between Orange and Mas Movil. In fact, it was only approved subject to MVNO Digi getting access to both spectrum and national roaming agreements so they could become a credible fourth network over time.

How could this work in the UK? It would have to be a full MVNO and not one owned in a JV. So, it couldn’t be Tesco, the most obvious candidate in terms of scale. This therefore limits the options to Sky (most likely) Lycamobile, Lebara or Gamma.

In theory, there’s nothing to stop a credible and financially sound new entrant being created. But not only would that take a significant investment, we also have to remember that the whole premise of the merger is that Three cannot function and make the network investments required to be profitable with 10m customers.

With that as a backdrop, it would be a very brave organisation that takes on the market from nothing. But who knows, maybe Elon Musk, or someone similarly driven and financially able, fancies an adventure in telecoms. Nothing surprises me at the moment…

5. The next MVNO / wholesale related option is capacity ringfencingto allocate spectrum specifically for MVNOs. In the past, there have been two approaches to this. The first, used in Ireland and Austria amongst others, was to ring fence capacity for MVNOs and implement a capacity-based charging model.

In those examples, it was also coupled with bringing in new market entrants to leverage this model. However, it should be noted that those markets did not have such a vibrant MVNO market as the UK. Whilst this model is interesting, it’s my opinion that it typically requires the MVNOs to be full MVNOs, which is capital intensive. Not only that, but there are relatively few in the UK, making it a less viable solution.

A more radical solution, which was deployed in Mexico, was building a network entirely for MVNOs. Wild as it may seem, the same could be achieved using allocated spectrum and a full MVNO infrastructure either owned by a third party or leveraging the merged entities infrastructure (as they will have two of everything!).

This would be like creating the equivalent of Openreach for mobile. So, not such a wild idea as it’s been done before. But I suspect it’s a bridge too far for Three and Vodafone.

6. That leaves us with regulated pricing.On balance, I think this is the more likely option, and fits with the CMA expectations of Wholesale access terms. This could involve pre-agreed non-discriminatory wholesale terms, including prices, being made available to MVNOs, subject to a reasonable limit (number of MVNOs or network capacity utilisation).

This is relatively tried and tested in markets globally. However, the challenge is always how you set those terms. There have been many methodologies deployed in the past and not all have helped MVNOs succeed.

We should also consider that historically in the UK, wholesale deals and pricing have been 100% confidential and, because of this, published wholesale rates could cause a correction in existing wholesale deals.

What would I do? 

No one remedy is the golden arrow, but there are certainly golden threads that the JV parties, and the CMA could look at together. I think that applying scrutiny to the MVNOs and wholesale market is more likely to benefit MVNOs commercially, and therefore consumers, whether it’s a new entrant, or via existing MVNOs.

That’s where I would focus attention initially and it’s why I still think there’s a good chance of this happening. The CMA is stating a position of openness and it’s now up to the parties to come to the table and negotiate.

If this has made you think your business needs a plan fast to react to what will be a significant market event whether it is a yes or a no, then speak to us at Graystone. This is our heartland and we’d only too pleased to work with you on a strategy for success. 

The post Vodafone / Three JV – is the CMA signalling game over? appeared first on Graystone Strategy.

It’s an unstoppable multi-billion-dollar industry and you’ve followed the developments of new licenses around the world. Your analysis shows you that you could make a name for yourself in a burgeoning market.

You’ve got the intel, and the spirit and drive to be successful, but how do you get your idea off the ground quickly?

Ordinarily you’d expect me to say that you should develop a proposition, one that will give a substantial cohort of consumers something different, and compelling, even unexpected. Do the business case and speak to the operators and become an MVNO. It’s a tested model – Deliver a killer go to market strategy and through all means possible drive awareness of your brand and ultimately achieve cut through and customer consideration.

That’s a considerable commitment in time, and cash, even before you’ve started trading. Is it really possible to follow your dream?

Yes, and it can be easier and less costly if you re-evaluate what a brand is. If you set aside the concept of creating a brand, and all the complexities that comes with, but instead focus on the other core elements of running a business then you have a chance.

But a brand is the business I hear you cry. And yes, it is. But you can be a brand without creating your own. Today more and more fledging mobile entrepreneurs are latching on to the merit of licencing a brand.

I bet it’s not something you’ve considered before. It’s an option that has been quietly ticking along in the wings for some time now but came into the spotlight at MVNO World Congress in June, thanks to David Clyde, Brand Director at Lebara.

Lebara is a fascinating MVNO story. It’s now a well-known global MVNO brand, and it stands out because it’s a mobile provider that has proven how it’s possible to adapt a core brand for different markets.

Wherever you travel, the Lebara brand will be recognisable. It’s distinctive logo and uncomplicated offer shine through. Its rapid growth around the world is testament to decisively sticking to its core proposition and knowing its audience.

However, Lebara recognised some time ago that there isn’t a ‘one size fits all’. Brands don’t survive unless they make adjustments for local market conditions, language, and culture.

It’s something that Vodafone have led the way on. The brand team there, understood that a globally recognised and highly valued brand which is usually unwavering in its brand guidelines, needs to flex to accommodate local market nuances without losing the brand essence.

More critically, Vodafone has been highly successful at monetising the brand and what it stood for, by establishing a ‘partner market’ network. With this model, Vodafone allows partner markets to leverage the brand, the propositions, and the insights without technically being an operating company owned by the Vodafone Group. It’s a winning formula – partner without the cost of a network roll out and establish a brand presence in new territories with ‘relative’ ease.

In terms of how you and I experience it, it’s really quite straightforward. When you travel to a Vodafone partner market you may see familiar proposition elements including retail formats that are identical. The brand you trust in the UK is instantly recognisable, and all it stands for comes to mind just being seeing the shop front.

In this case, Vodafone is taking all the best practice, insight and trading experience across retail, proposition, brand, CVM, roaming and so on, and giving partners a way to leverage it all so they can accelerate their own commercial success and what’s more, do it with a standout brand.

It’s with this context in mind, that Lebara’s brand licensing proposition for MVNOs is so interesting. As a budding MVNO you can access a globally recognised brand and customer proposition, with the help of a team who have driven growth for Lebara globally, vastly increasing your chances of success in your chosen market, and probably adding significant credibility for those all so important MNO wholesale discussions.

Is now the time to strike?

Quite possibly.

Lebara has moved quietly and confidently with its strategy, establishing partners in Australia, Switzerland, KSA and Spain. More recently, it announced a partnership in Nigeria with Vas 2 Net, one of the Tier 5 license holders. Vas 2 Net will benefit from an established brand, exec expertise across every discipline and function, and benefit from know-how built from years of hands-on experience. This level of help is undoubtedly invaluable for any new MVNO.

It makes good sense for a start-up MVNO to go this way. As I’ve said, building a brand can be an expensive business both in terms of time and hard financial cost. I know from experience of launching MVNOs in a number of markets. In all cases, we had a trusted brand (Sainsbury’s for instance) and we were simply leveraging the brand values and customer loyalty to move into the mobile space.

For an MVNO starting out with a blank piece of paper and absolutely zero brand awareness or customer consideration, it can’t be overstated how much of a big task it is to make a name for yourself. It takes hefty marketing budgets to gain cut through.

So, why not look at leasing? It’s not just any brand that Lebara is delivering. It’s a well-established and trusted MVNO brand with impeccable smart value credentials, exactly the type of brand that any start up MVNO would aspire to be.

On top of all of that there is the unparalleled knowledge, insight, and experience that MVNOs can tap into, all of which has enormous value.

Of course, it would be naive to think Lebara will work with anyone. Afterall, it has a brand to protect too. Expect it to be highly selective about who it will partner with and steadfast to ensuring every licensee delivers against brand expectations and promises.

Brand licensing won’t be for everyone, in fact start-ups may look at Lebara, Vodafone (and others) and think that they could monetise their efforts with their own licensing strategy. It definitely gives weight to the argument to invest in building brand equity as part of an investment in the future.

With that strategy comes other options too. For instance, you could sell the brand to the MNO to create a sub brand that’s promoted in markets they believe they can grow share in.

My point is, MVNOs have more options for growth than they perhaps realised before. Just as they have a range of choices about their technical strategy and their commercial strategy, they now have some interesting choices on brand and marketing strategy too.

The reception David received at the conference, highlighted the appetite for this diversification. And the questions I was asked subsequently, show how much head scratching is already going on. I’m sure this won’t be a strategy confined to a few markets for very long. Not only should we expect to see more Lebara brand licensees in the future, but I’m certain other big MVNO and/or MNO brands will follow suit in the coming years.

If your head is fizzing with ideas after reading this, then our expert team at Graystone Strategy can help you work through the best approach for you. With over 100 years collective telecoms and MVNO experience spanning technology, operations, commercial and marketing we can help you make the right choices for your MVNO.

The post Is the MVNO future all about brand licensing? Lebara certainly thinks so. appeared first on Graystone Strategy.

In total, the Graystone team ran three masterclasses, scoring on average 4.9/5 to 5/5 on likelihood to recommend the classes to others.

The distances attendees had traveled was quite astonishing. Every corner of the globe, and every life stage of MVNO, was represented.

It was a strong reminder that although the MVNO model is well established in Europe, there are still many markets that are at the start of their journey and need expert knowledge and experience to guide their strategy.

The standout class in terms of diversity, focused on building a partnership with your host MNO.

The binding operator agreement is the most important partnership agreement for any MVNO to sign, and experience tells me that it can define the success, and sometimes failure, of MVNOs.

During the course of the conference, in quiet corners and in hushed, and sometimes embarrassed, tones, I heard catastrophic tales of MVNOs that did not pay attention to their partnership and terms of their contract and who now find themselves in very dire straits. Consequently, there are now people knocking at our door asking for help to avoid being the next anecdote.

On the flip side, there are MVNOs that have built an incredibly positive relationship with their partner host operator. Strategic goals are aligned and there is a mutual, 100% commitment to joint success.

But I think the really interesting insight came from new markets. I had underestimated just how much help new entrants need from specialists. There is a lack of skill on the ground for them to turn to and often, because the concept is so new (in local terms) there’s not even knowledge within the operators themselves.

Every MVNO and MNO can learn from our discussions in the masterclasses. Many think MVNOs magically appear overnight. They don’t. There’s an extraordinary amount that must happen – there’s a real art to getting one to the point of signed contracts, let alone to market.

What I took away from the event was that there is little unified clarity on what ‘good’ looks like.

I’ll take Nigeria as a great example of this conclusion, but I hasten to add, it is by no means alone.

The market has licensed just under 50 MVNOs across a range of license classes and technical models. This approach has meant that there is at least some sort of blueprint for the technology build that everyone can align against.

But when it comes to the commercial constructs, the wholesale contracts and how wholesale and MVNO should work together it is almost a blank piece of paper.

On the one hand MVNOs have a lot to do, building their proposition, their tech, their brand and distribution models. But MNOs who have never done wholesale are in a similar boat.

They also need to build out their commercial approach, API access, commercial contracts, support teams etc for MVNOs, all with distinct information barriers between their wholesale and retail business.

I’ve seen this blank page scenario before, and generally it leads to an enormous amount of frustration from licensees, because it seems impossible to get a credible deal and contract from an MNO.

In Nigeria, I hear stories of an extraordinary situation playing out. To get things done, the MNOs are asking the MVNOs to tell them what to draft into wholesale contracts, simply because they don’t know where to start. MNOs are assuming that the breadth of conversations MVNOs are having with technology suppliers, gives them enough knowledge to shape the contract. But the truth is, MVNOs are none the wiser. The phrase, blind leading the blind, comes to mind.

The takeaway should not be about who is to blame for this situation, but instead, MVNOs cannot happen magically. The levels of negotiation that are involved really aren’t for the faint hearted. I know from doing it on behalf of MVNOs and MNOs that they are complex to arrange and therefore agree.

I’m not only referring to the commercials and structuring the contract. Agreeing how you will run your wholesale team is also complicated.

There are a lot of decisions that the MNOs need to make about strategy, everything from information barriers between teams, through how they will technically wholesale the network, to how they will resource the support that the MVNOs need, provide the wholesale billing technology and how they ensure that there is separation between their retail customers and their wholesale customers.

It took a lot of work to deliver this for Vodafone back in 2006, and even after it was delivered, we only took on maybe three to four MVNO projects a year maximum. Pace is not on your side when it comes to MVNO deals.

Imagine having to do all of that with no guidance, no instruction book and probably 50 organisations beating a path to your door asking you what the answer is and wanting to negotiate with you?

In the case of Nigeria, not unreasonably, the MVNOs are expecting the MNOs to lead this. They are the telecoms experts, they are selling a wholesale service for commercial gain in a competitive market, and they have a responsibility to the regulator to deliver.

So how to square the circle? It’s my firm opinion that MNOs need to have a cohesive wholesale strategy to support this regulated change. They need to invest in teams and technologies to facilitate that strategy and deliver against their regulatory requirements. And if they can’t source expertise and experience locally (difficult as no one has done it, or Globally if they are a group company) then they need to seek external expert help.

There is no shame in that. It’s the smart move and will give any MNO that does it, the first mover competitive advantage. They will avoid costly mistakes and benefit from global best practice.

Our masterclasses are just the tip of the iceberg when it comes to helping both MVNOs and MNOs unpick their options and progress strategically. If you’d like to know how we can help you specifically, then contact me.

The post New MVNOs markets can’t wave a magic wand for growth. It takes time, patience and knowledge to build the MVNO ecosystem. appeared first on Graystone Strategy.

However, there’s another interesting story MVNOs should follow. For the first time in its history, the archipelago of Channel Islands is close to launching its first MVNO in the shape of Coop Mobile. Again, all subject to regulatory approval, the launch would be a remedial action in the wake of the likely completion of Sure’s purchase of Airtel-Vodafone.

Why should we care?

It’s all about the development of an MVNO market and the innovation that could come from it.

 It’s worth a few facts at this point. The islands of Jersey and Guernsey are home to 170,000 residents spread across an area of 70 square miles. Each island is independently governed and has its own regulator for telecoms.

Unsurprisingly, the proposed merger of Sure and Airtel-Vodafone has attracted regulatory attention. Principally, the merger would leave the islands with just two operators, limiting consumer choice. If you’ve watched other mergers around the world play out (think Ireland and Austria) then you’ll know that’s a bug bear for regulators. Stands to reason, a merger will be scrutinised, and why there will be reviews on competition and choice. We know from other examples that this leads to interesting proposals. That’s why Sure has put forward the launch of an MVNO as part of its remedial plan. Maintaining a buoyant competitive market isn’t about sticking with the status quo. Innovation – in the form of new licences – can steady the helm. 

Let’s look at the context.

The reasons for the purchase of Airtel are not dissimilar to those proposed by Three / Vodafone in the UK. Airtel-Vodafone is unable to sustain operating costs especially those associated to updating the mobile networks across the two islands. Its decision to exit the island will bring home the reality that it was making a loss. (I can’t imagine it was an easy brand decision to make with the ‘heart’, but I’m certain the ‘head for numbers’ had the final say.)

 Nevertheless, the sale, if approved, leaves a gap in the market. It might be considered a small gap at this stage in the game but closing it with a keen MVNO should turn that assumption around.

Is this really going to happen?

I would say, yes. There’s a good line of retailers that have taken the opportunity to join the MVNO community, setting the precedent for linking a value offer with mobile and combining the wealth of customer insight with targeted propositions.  

Having consulted the Coop team on the negotiations, I’m very excited about the prospect. By applying for an MVNO licence in both islands, Coop can leverage its considerable retail estate as a distribution channel and talk to its 120,000 members using its credentials as a trusted brand. I’m confident it can offer a compelling alternative to the remaining incumbents.

It’s not a done deal, I admit. In Jersey, the Jersey Competition and Regulatory Authority (JCRA) have launched a public consultation process giving consumers a voice on the proposed sale and launch of an MVNO. But it’s a significant step and I would hope it lands favourably. The authorities on Guernsey are also reviewing the proposed remedies from Sure.

As industry experts, we know that MVNOs have proven to be successful at driving competition. Currently in the UK, around a third of all customer acquisitions go to MVNOs or challenger operator sub brands and, historically, retail MVNOs have proven successful. Retailers are trusted, have a cost-effective route to market and the ability to innovate the proposition by aligning it with their core activities.

Tesco Mobile, the UKs biggest MVNO, has been particularly successful in this regard leveraging the Clubcard scheme and its “Super Market Mobile” credentials, similarly Asda Mobile, iD mobile (by Currys) Superdrug Mobile and even Your Coop Mobile offer are all available in the UK.

In Germany, Aldi and Lidl also operate MVNOs and we are seeing retail MVNOs as one of the more successful early entrants to the MVNO market in places like South Africa with brands like PNP (Pick and Pay) and Shop Rite Knect rated as ‘favourite’ brands these days. 

You could say that the outcome of the application for a licence is in the hands of the public. And I think that’s good. In my experience, the public will want choice and will favour the underdog to give them something the other operators can’t. Of course, the regulators need to review other aspects alongside, but I suspect gauging the public opinion will help sway the vote.

As the year unfolds, I think we should expect an historic outcome for the Channel Islands, and I’d recommend MVNOs watch to see how the move is executed. There’s a lot to learn from other markets, especially so in fledging ones.

If you’re thinking about launching an MVNO in a new market or need to drive competition with a differentiated offer, then call me. My team can help you appraise the market, negotiate the deal, and build the winning business model.

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Now I’ve had time to pick over the judgement, alongside the news that the government has said the proposed merger passes the National Security and Investment Act (2021) tests, it’s time to consider what else could stand in the way.

My analysis leads me to think that there are some interesting observations for MVNOs to note, as they might be the next set of hurdles to derail the proposal.

Before I launch into them, it’s worth summarising the areas of concern for the CMA:

1. General reduction of competition and thus likelihood of increased pricing. This is particularly acute in terms of pricing. The regulator sees Three as the ‘price challenger’ so removing it from the market will drive up costs. In turn, the remaining operators will be incentivised to be less aggressive.

1. Wholesale competition. If MVNOs are the answer to the above scenarios, then this is negated by the fact that, in theory, wholesale competition is reduced. With fewer operators providing wholesale terms, and, knowing not all operators will bid for every MVNO out there, there’s less opportunity for MVNOs to provide the ‘competitive tension’ needed to drive down prices.

1. Access to commercial information. This one didn’t get much coverage in the press, but it’s not something to gloss over. The judgement infers that with a foot in both camps of Cornerstone and MBNL, the merged party will be able to see competitor network rollout plans.

At a high level, my expectation is that this will kill off network sharing as we know it today. One way or another, if the merger goes through, (or even to allow the merger to go through), BT and VMO2 will need to reconsider their options with regards to Network sharing.

There are a lot of options. One could be a new sharing agreement between BT and VMO2, with the merged entity managing on its own sites across its current footprint from previous agreements. It’s quite a complex challenge and potentially a big barrier that MNOs opposed to the merger might highlight as a significant risk to competition.

So, with all this in mind, will the merger bring imbalance to the MVNO market?

Let’s start with some facts. MVNOs are normally a driver of market competition. The UK has a very mature MVNO market, with roughly 15-20% of all subs (depending on how you do the segmentation). The UK launched the very first ever MVNO way back in the last century, so the wealth of heritage is strong.

Although MVNOs are still offering great value, the concern is that with just three host operators in the market, MVNO competition will diminish in the longer term. I think the crux of the regulator’s argument is that MVNOs may not benefit from the same levels of aggressive wholesale pricing as they do today.

What’s more, existing MVNOs may not have the competitive tension to drive either a move to another host or re-negotiate better deal terms when it’s time to re-sign wholesale contracts.

I think it is a legitimate concern. Although Vodafone has been a bit less consistent than Three in its execution of a wholesale strategy, both are active.

But there’s a flip side to the challenge.

The new entity will have a lot of network capacity to monetise. Certainly, they will want to compete hard, both at wholesale and retail, against BT/EE and VMO2. But the ultimate question is whether the three MNOs can continue to compete to grow share, or will they try to drive extra value by competing less and forcing the market up?

If they did decide on the latter strategy, then it could take some time to execute. Wholesale contracts (or at least those I have written or advised upon), tend to have clauses that reward growth with discounts and have specific protections against price rises. It’s going to be difficult to walk these back any time soon.

So, it’s not a case of whether this will happen or not, it’s more about what the CMA can do to legislate against that risk.

Around the world, MVNOs have been used to drive competition with varying degrees of success. In some markets, regulators have mandated that MNOs must offer wholesale deals. They have even defined the methodology, which is typically benchmarked against retail pricing using retail minus methodologies.

This ensures MVNOs can be competitive and make reasonable margins. However, consumer competition isn’t always commonplace simply because of the regulated approach to wholesale.

If we look at Georgia, a market which is only just starting its MVNO journey, the networks are mandated to put out reference offers, and, in some cases, there are regulatory requirements to do so linked to 5G spectrum.

But, in my opinion, it feels like the market operators are only really paying lip service to this. They have no real intention or motivation to bring in more competitors, and frankly mobile telecoms competition is the least of Georgia’s problems! So, unless the CMA and OFCOM ensure any legislation has real “teeth” the approach may not be effective here.

In other European markets like Austria and Ireland where there was a similar scenario of operators merging, the regulator mandated more MVNOs to create balance. They also mandated the technical set up (to give maximum growth potential) and stipulated capacity-based wholesale deals. Having launched MVNOs in Ireland that were born from this legislation, I can see the value of this.

Further afield in Mexico, a far more radical solution transpired – a network ONLY for MVNOs.

Where does this leave the UK? What are the CMA’s choices?

It could set wholesale pricing caps across the market to keep MVNO costs lower and to ensure MVNOs can compete on price. Or it could insist upon the JV launching extra MVNOs and the wholesale pricing methodology it uses.

But we shouldn’t forget the UK market isn’t full of MVNOs that are exclusively driven by providing the lowest price. There are others that differentiate on offering other forms of value to consumers e.g. calls abroad and family bundling, better service, different member benefits and so on.

And, even with fewer MNOs, consumers will still get a good deal. Our MVNO market is vibrant and diverse enough to ensure it.

For what it’s worth, based on my 30+years’ experience in telecoms, the overwhelming trend has always been that pricing and ARPUs have reduced in real terms and the value included (whether that’s minutes, texts or more recently data) has grown, not to mention your download speeds.

The recent inflation-linked price grab by the major operators has slowed this, but you still get far more minutes, texts, and data for your pound now than you did a few years back.

Let’s not forget that we have already seen several mergers in our history – BT/EE, Virgin Media and O2, Vodafone and Cable and Wireless, and, for the real veterans, Orange and T Mobile – and MVNOs continued to spring up.

You can see why it’s a difficult conundrum for the CMA, and why it’s prudent that it seeks evidence from all parties to reassure it that competition will be maintained both in wholesale and retail.

The next few months will ensure this analysis is done in detail. Every rock will be up turned. Though, I still hold my view, MVNOs can steady the market and, if we look at this factor alone, the merger has merit.

The trick will be to have a strategy regardless of which way it falls. There will be change. MVNOs need to be thinking about what they would want from an opportunity to renegotiate terms, what proposition development they’d want to do, and how they could turn the saga into an opportunity for growth.

If you’re running an MVNO and reading this thinking ‘we need to do this’, then drop me a line and we can set up a consultation and game-plan the options.

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My bets are a decision will come, and it will be to let it go through to phase 2. It’s a long process, probably running until the Autumn, and will be run by a second independent team, but it’s wholly worthwhile. I see no reason not to do the due diligence.

Phase 2 will get into the nitty gritty. Fundamentally, it will look at the market, the consumer interests and wider national infrastructure issues. Economic prospects will form part of it – jobs are always a thorny issue. I see that as an inevitable part and parcel of the market, and of course this deal, but I don’t think the CMA will say it’s a deal breaker.

Chinese ownership has also been cited as a barrier to merger, and parliament debated this on 14^th December 2023 (you can watch it here). It’s important to note that aspect is out of the hands of the CMA. Its remit is to look at competitive telecoms. The NPSA will have its say, I’m sure and it’s best we await their judgement.

I guess the big question is why now?

If like me, in your early working life you watched Vodafone emerge from above a curry house in Newbury, you’ll find this a fascinating tale of fortunes. How can the trailblazer be in a position to consider merging with the minnow?

Speaking on the record to both parties, the proposed deal is about scale. I have to agree that it is a necessity in the UK. The last few years have given birth to some hefty players. BT/EE and VMO2 are making returns, and Vodafone and Three will feel like they’ve been left in the cold.

For Three, the options are limited since the failed merger with O2. It needs this to work. Vodafone will argue it needs it too. But for different reasons – a merger is a steppingstone to acquisition (let’s not forget the 51.9% share it would have), and the share price needs revival.

A merger would stabilise market dynamics. But most importantly it will give the UK’s 5G infrastructure the capital boost it needs. £11bn is on the table and I’m doubtful consumers will be sold on the 5G dream until they experience it everywhere, every day. They certainly won’t pay any more for it until they realise more of the benefits the government wants for its UK ‘power-house’ credentials.

The real advantages for consumers and businesses will come from continuity of service and connectivity – promises associated to Digital Britain. With combined capital, RAN and spectrum sharing that a merger like this facilitates will give consumers better, faster mobile. That can and will drive market competition and challenges the network leadership of BT/EE. It all adds up to an enticing prospect for the government, which so desperately needs to prove UK ‘power-house’ credentials.

But for the CMA, it’s a case of weighing up whether stabilising the market today would eventually create a market imbalance tomorrow. Currently, VMO2 and BT/EE are benefitting from mobile and fibre bundling. A sticky proposition in a market that needs to retain customers to survive. Of course, these brands achieve it with their own infrastructure.

Sky, on the other hand, is performing extremely well in the market without the network overhead. Many forget this. But not Vodafone. It says Sky’s impressive customer base and market power is a cause for concern.

I’m not sold on this as an argument, but I do agree that Sky has logged some very impressive growth in a relatively short time.

There’s also the buoyant MVNO market, ready to snap at the heels of change. If phase 2 concludes in favour of a merger, then the publicity alone could prompt consumers to rethink their provider and look at the smaller more innovative brands. Add to this the teething problems all brands inevitably go through when they merge and consumers could be persuaded to leave either brand for a better deal, and better service, elsewhere.

That said, there’s also opportunity – I can see the likelihood that a merger would encourage more MVNOs to spring up. Largely, because there will be capacity to fill, and Vodafone will want to put the wounds of losing Virgin behind it and build credibility again. There could be some exciting deals to be done for any MVNO that wants to renegotiate terms or has intentions to start up. That’s another reason for the merger, as it could give rise to more equable MNVO shares across the market.

Overall, I’d say there’s more to rule in favour of the merger than against it. But of course, this is all pie in the sky until phase 2 concludes. And there will be firm warnings to anyone counting their chickens before they hatch. The CMA will follow a strict process and woe betide any party getting ahead of it.

As an outsider looking on, I’m prepared to sit on the fence for now. But if you really pressed me for an outcome, it will be that at the end of phase 2 the CMA waves the merger through.

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eSIM has been a huge talking point at MVNO conferences that I’ve chaired. Usually, the discussion has been related to predictions, and technology developments and adoption. But today’s move by Revolut makes it a leader of a trend we’ll see repeated.

Revolut is one of many brands who have seen the potential of eSIM and how it can be used to disrupt not just telecoms but its sector. Other recent brands targeting the traveller market include Easyjet and Uber. They are logical. Buy a ticket, buy an eSIM.

New MVNOs like Airalo (founded in Singapore but operating globally), Holafly (set up in Spain also operating globally) and Global Yo (headquartered in Mexico and combining entertainment too) are also in on the act.

But to see a bank take a slice of the action holds real power in terms of consumer value, and it is a true development in the market.

What’s happening, and why now?

Ultimately, these brands offer a cheaper and credible alternative to roaming with your existing mobile operator.

The idea of MVNOs providing roaming substitution is not new. The relatively high cost of roaming in 2012 meant that the GSMA singled it out as a key segment in its MVNO analysis.

A lot has changed since then, not least Brexit. When Roam like Home was introduced into Europe, into was to deal with bill shock and, as a result, the demand competitive roaming options all but disappeared.

Back then companies like truphone (now Global One and the company supplying the service to Revolut) invested significant sums, largely because it was a technically complex undertaking.

But now that technical challenge has gone. Firstly, voice and SMS for roaming are less of a ‘thing’, it’s all about the data and with the advent of OTT apps like WhatsApp and Facetime there really is no need to use your existing mobile number while roaming – people can contact you using data.

The second change is that eSIM is becoming far more prevalent.

That makes it much easier to add a data only eSIM (from one of the providers mentioned above) before you leave or when you land, or even while you’re in your Uber from the airport.

It’s simple, very cost effective and you can easily shop around for the best deal depending on which country you’re visiting.

Travel money with benefits

But what I find really interesting, is that Revolut is positioning this a benefit for its customers. And it is. It’s the killer combination of low cost and high value to the customer, making the decision to use Revolut for travel money a ‘no brainer’.

For a long time, I have theorised that industries like banking should put in place a discounted or free MVNO depending on how many banking products a customer has. It’s a useful and sticky benefit, not to mention it gives banks a route directly to the customer and probably helps with KYC and one-time passwords.

We have seen banking MVNOs spring up in Africa, a continent that boasts real leadership in ‘M money’. But not so much in Europe, and those that have launched, have always used it as a distribution-led offer, generally because they have an estate of banks.

However, today’s news shows the trend in eSIM is blowing this wide open for the digital innovators.

No surprises, but I am very excited about what we will see next. I predict a bow wave of partnerships and launches. What’s more, all this talk of eSIMs, almost makes me want to go on holiday!

If you need help bringing eSIM to market, developing your strategy and understanding how telecoms could help you monetise your existing customers, get in contact or send me a WhatsApp to +447799244962.

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For instance, the prospect of market consolidation in the UK mobile market, represents a seismic shift. MVNOs are already using this as a chance to review their strategy and seek out new opportunities and advantages.

Similarly, in markets issuing new licenses, there’s a chance for the application providers delivering billing or customer service platforms to grow their brand and assert their capability by becoming integral to the go-to-market strategy.

Of course, some brands have cause for concern in times of change. Digital start-ups are eating up market share and

leaving legacy providers in their dust. It’s a case of transform or die.

Yet, for all of these companies, it’s hard to communicate their value in a new world. It’s often not a skill-set they boast, and, as we’ve discovered, not something they have done for a long time. And why would it be if their brand has not experienced the urgency of competing in more dynamic economies, or at such high levels?

Prior to working with us, many have tried to identify the message they need to take to market. But it never gels. Usually because the proposed messaging has come from an internal view of the world. It’s clouded by what people believe to be true, and a mix of opinions that are not always consistent.

It can lead to a short sighted approach with little longevity in terms of how it will support the goals set out in the company strategy. And that’s if there is a strategy that reflects the changing dynamics.

It’s generally at this point that leaders have to accept they won’t arrive at messaging that will cut through, because the strategy is no longer fit for purpose. You can’t lead a company into change if the message you want to convey does not align with what you do and how you do it.

Messaging needs to come from insight. You must know your customers and prospects inside out, and ensure the messaging not only reflects what’s happening today but the direction the market is going. How will you serve those needs? What’s the gap? Can you do it alone? Do you need partners? What will you be famous for?

This makes messaging a cultural exercise as much as anything else. Amazon is clear that if you want to be the largest e-commerce platform in the world, you need people who are willing to take risks, fail, learn and thrive.

Are your people up to the job? Are they capable of meeting the demands of the company’s new strategy? Are they measured on objectives that achieve the strategic goal? Are they supported to become visionary? Are their behaviours a reflection of the company values?

As we start to work with leaders, it becomes clear to them that unless they understand the fabric of their company and how it translates to the market, they can’t address the company message.

That’s a brilliant outcome, albeit for some, unexpected. Having the bravery to accept strategy and messaging are intertwined, allows leaders to take great strides towards realising the ambition.

They can get the right team and skills in place. Focus on partnerships that drive the strategy. Adopt processes that underpin the company ethos and values. Build products and services that meet the customers’ needs and deliver marketing that drives the market demand.

We know, because we’ve got the clients to prove it.

If you find yourself leading a company through crossroads of change, then speak to us about how we can help you devise and deliver your plan.

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