
President von der Leyen’s recent remarks about “easing” EU antitrust rules need to be understood in the context of markets that are genuinely integrated at European level. The underlying idea is that where a true single market already exists or is being built (for example in cloud, semiconductors, defence or certain digital segments), it may be necessary to allow more consolidation to create “European champions” capable of competing with large US and Chinese players in global markets.
In these settings, European firms face direct competition from non‑EU rivals operating at continental or global scale, and enjoying economies of scale and scope that fragmented, country‑by‑country operators in Europe cannot easily match. Softening some rigidities in competition enforcement is therefore presented as a way to close this competitive “scale gap”, not as a blanket green light for any form of concentration.
Why this logic does not (yet) fit telecoms
This logic sits uneasily with the reality of fixed and mobile telecommunications, which remain organised predominantly on a national basis. European telecom operators do not compete with US or Chinese operators on EU retail markets; they compete almost exclusively with one another within domestic markets, under a mix of EU and national regulation.
In other words, there is still no direct competition between, say, a European MNO and a US or Chinese MNO operating in their markets. The core competitive challenge for European telecoms is therefore not the absence of “European champions” able to beat AT&T or China Mobile, but the combination of regulatory fragmentation, sector‑specific obligations and demand patterns that makes it hard to fully capture economies of scale.
The “too many operators” narrative
Against this backdrop, it is misleading to invoke the “European champions” narrative to claim that EU antitrust rules have produced “too many telecom operators”. In telecoms, loosening enforcement would not create a pan‑European champion ready to win global battles; at best, it would tweak the market structure in a limited number of already‑oligopolistic national markets.
The narrative about “too many operators” in Europe rests on a basic misunderstanding: it looks at the aggregate EU operator count as if a fully integrated single market already existed, when the sector in fact remains split into 27 distinct national markets. In most countries, the structure is the standard one for advanced economies: roughly 3–4 fully‑fledged MNOs, plus a constellation of MVNOs that do not change the underlying number of physical networks.
If you simply multiply 3–4 MNOs by 27 Member States, you mechanically arrive at “almost 100 operators” – a figure often quoted in an impressionistic way in public debates. Comparisons with the United States or China ignore this arithmetic: in those jurisdictions, the market is genuinely national, regulatory barriers to operating across the territory are far lower, and it is therefore natural to see fewer operators, each serving a much larger customer base. [
What EU antitrust actually does
EU competition rules affect only a small subset of potential consolidation deals, and in practice only the most material ones – typically 4‑to‑3 mobile mergers or transactions combining significant fixed and mobile assets. Over the past decade or so, the number of mobile cases examined in depth that involved a reduction from four to three MNOs has been very limited, certainly not the “dozens” of systematically blocked mergers sometimes suggested in political rhetoric.
In several instances, the Commission has cleared mergers subject to conditions (structural remedies or wholesale access commitments), while in others it has prohibited them – always with reference to specific national markets, not in pursuit of an abstract goal of “keeping many operators in Europe”. For the vast majority of entry, exit and smaller‑scale consolidation decisions, outcomes are determined by business choices within the general framework of competition law, as in any other sector.
Policy conclusion
The claim that Europe has “too many operators” because of antitrust enforcement gets the causality backwards: the high number of operators is the product of regulatory and political fragmentation into 27 national markets, not of over‑zealous antitrust enforcement. The real policy question is not “how many operators do we want in Europe?”, but “what trajectory of market integration and regulatory convergence do we want, so that pan‑European operators can emerge without sacrificing local competition?”.
Contrary to the simplistic pro‑consolidation narrative, the European case law shows that:
– the truly controversial or blocked cases are few relative to the total number of national markets;
– there are examples of 4‑to‑3 mergers being prohibited, authorised with remedies, and authorised without remedies, confirming that there is no automatic rule about an “optimal” number of operators;
– EU antitrust intervention concerns individual large‑scale transactions, not the overall industry structure (multiplied by 27 markets), which remains largely the outcome of business decisions and persistent regulatory fragmentation.
10 years case-law in the mobile sector
Some illustrative 4‑to‑3 mobile merger cases in the EU over the past decade include:
Denmark – TeliaSonera / Telenor (2015, withdrawn). A proposed joint venture that would have reduced the number of Danish MNOs from four to three, creating the largest operator by customers and revenues. The Commission signalled the need for far‑reaching structural remedies (essentially enabling a new fourth MNO), which the parties considered disproportionate and chose to withdraw the deal.
United Kingdom: Hutchison / Telefónica O2 (2016, prohibited). A merger between Three and O2 that would have reduced the UK market from four to three MNOs, with the combined entity becoming the largest operator. The Commission blocked the deal due to concerns about higher prices and reduced quality, a decision later annulled by the General Court but substantially preserved by the Court of Justice, which raised the evidentiary bar for future prohibitions without turning 4‑to‑3 mergers into automatically acceptable transactions.
Italy: Hutchison / VimpelCom-Wind (2016, cleared with structural remedies and a new entrant). This joint venture formally reduced the number of Italian MNOs from four to three; it was cleared on the condition that spectrum and assets be divested to allow Iliad to enter as a new fourth MNO. The case shows that in‑country consolidation is possible, but at the price of remedies that effectively re‑establish a four‑operator structure.
Netherlands: T‑Mobile NL / Tele2 NL (2018, 4‑to‑3 cleared without structural remedies). T‑Mobile NL’s acquisition of Tele2 NL reduced the number of Dutch MNOs from four to three. After an in‑depth review, the Commission cleared the transaction without remedies, finding that Tele2’s presence was limited, that the merged entity would not have sufficient market power to cause a SIEC, and that there was no robust evidence of likely coordinated effects or significant deterioration in price and quality; this decision is often cited as proof that there is no “magic number” of operators.
Spain: Orange / MásMóvil (2024, 4‑to‑3 cleared with structural remedies and a strengthened rival). The Orange–MásMóvil joint venture temporarily reduces the number of Spanish MNOs from four to three, creating a large convergent operator able to sustain major 5G and fibre investments. The Commission cleared the deal in 2024 subject to a package of remedies in favour of DIGI, including spectrum divestitures and network access, to preserve strong competitive pressure in a market known for intense price competition and numerous low‑cost offers. The transaction has been completed, creating a new “national champion” within an oligopolistic structure.
Romania: Telekom Mobile exit and consolidation to three operators (2025, no structural remedies). In Romania, Deutsche Telekom’s exit from mobile and the sale of Telekom Romania Mobile’s activities to a Vodafone–Digi tandem (with a split of customers and assets) reduced the market from four to three infrastructure‑based operators (Orange, Vodafone, Digi). The Romanian Competition Council approved the deal with behavioural commitments, explicitly linking its decision to the need to support investment capacity while maintaining acceptable competitive conditions in a country long known for some of the lowest mobile prices in Europe.
Categories: Competition, European telecoms regulation