The roaming reform finally entering into force on June 15, 2017 is right and due, because European citizens deserve, although within the limits of simple traveling, the end of roaming surcharges which, beyond the economic burden, have been an unbearable discontinuity in the European integration process.

However, the reform is also incomplete because it eliminates roaming surcharges for users (Roaming Like At Home: RLAH) while keeping such surcharges amongst operators under the form of high wholesale roaming caps (the cost that a mobile operator must pay to a foreign network to use it and provide roaming service sto its customers). Such wholesale caps have been fixed by way of regulation at a level which is totally inconsistent with the market practice. To make an example, the starting wholesale cap for data will be 7.7 Euro for Gigabyte (6.0 euro from January 2018 up to 2.5 euro in 2022) awhile current retail tariffs are already much below and cheaper (between 1 and 2 Euro per Giga).

As a result, many mobile operators, especially small innovative and MVNOs, will have to provide RLAH services below costs. In order to recover such costs, various options may be available (which may come as unexpected surprises for consumers):

– limiting the RLAH data with the so-called fair usage clauses (for unlimited or low cost data bundles)

– asking national regulators for a derogation and continue to apply roaming surcharges;

– increasing domestic tariffs, in order to be able to replicate them abroad as RLAH;

– issuing “domestic” SIM cards without roaming ;

– quitting the market.

The above will not happen tomorrow, it will depend on market conditions and on the evolution of usage patterns. Until now European citizens were not consuming data abroad because were scared about high or uncertain roaming tariffs. This situation will change, also due to new features available in the market, like the portability of content abroad.

However, some signals are already in the market. Finnish operators Elisa and DNA are already asking for derogation, as well as all the operators in Lithuania and Estonia, O2 Slovakia and Voo in Belgium. Up to now, it seem that almost 40 derogation requests have been filed in the EU and 24 of these have been granted by national regulators. In addition, domestic tariffs increases are happening in Denmark and Sweden. Moreover, operators are increasing a variety of other charges to try and offset the end to roaming surcharges: in Italy, for instance, mobile network operators have been rescheduling the monthly subscription from 30 days to 4 weeks.

The next months will tell us whether this is just a normal market adjustment or the beginning of a general trend that may frustrate the consumers’ expectation for the end of roaming.

Of course, the above problems may be mitigated should the European institutions decide to lower roaming wholesale caps to level more aligned with the market practice.