For some time, the debate on Europe’s Telecommunications Single Market has been marked by ambitious rhetoric and renewed political emphasis, yet it has often failed to address the sector’s underlying structural problem: the persistent tendency of European telecom operators to operate, consolidate and defend their positions primarily within national markets. While calling for regulatory harmonisation and greater scale, many operators have an incentive to preserve the separation of those markets, since national segmentation enables them to protect established customer bases, sustain differentiated pricing strategies and limit exposure to cross-border competition.

This defensive approach is ultimately self-defeating. It prevents European operators from fully capturing continental-scale economies in services, platforms, procurement and customer reach, while leaving them fragmented and comparatively small in global terms. It is also difficult to reconcile with the recurring claim that Europe has “too many operators”: if cross-border competition and genuine pan-European service provision remain constrained, the persistence of a large number of nationally confined operators is an unsurprising outcome.

The Digital Networks Act (DNA) appears similarly inconsistent in this respect. Although it is presented as a major step towards a stronger Single Market for connectivity – principally through maximum harmonisation and a single-passport authorisation framework – it largely confines market integration to the regulatory and administrative sphere. The proposal does not address one of the structural barriers to a genuine European market for mobile connectivity services: the roaming framework. By leaving the reform of roaming, including the conditions that prevent sustainable permanent roaming and pan-European mobile offers, outside the scope of the DNA, the Commission risks delivering a largely formal Single Market: one in which operators face more uniform rules, but citizens, businesses and service providers remain unable to benefit from truly cross-border and contestable retail connectivity markets.

Connect Europe’s paper fits within this broader narrative: it calls for a more integrated operational and regulatory environment, but stops short of supporting the measures that could make the market for connectivity services genuinely European and contestable across borders.

The paper

A Single Market for Telecoms (September 2026) argues that the European telecommunications Single Market must be strengthened in order to support more robust investment, greater innovation and resilient digital infrastructure. It identifies three main priorities:

1. Greater regulatory predictability through harmonisation and simplification;
2. The removal of barriers to the cross-border management of infrastructure and back-end systems;
3. Greater operator scale in order to support investment in advanced networks.

The first part of this agenda is broadly persuasive. The sector remains affected by national differences in the implementation of the European Electronic Communications Code, authorisation procedures, spectrum-assignment conditions, and rules relating to cybersecurity, data retention, lawful interception and the localisation of critical functions. According to Connect Europe, these divergences generate compliance costs, uncertainty and operational duplication, preventing groups operating across several Member States from organising themselves efficiently. The paper also highlights the growing role of network virtualisation and cloudification: while fixed and mobile access networks remain local, core networks, platforms, data centres, network operations centres, security operations centres, procurement, software and specialist functions can be organised in a more integrated manner at European level.

The emphasis on economies of scale also has a sound basis. Telecommunications combine economies of scale, density and scope. Economies of density are particularly significant for access networks: once the fixed costs of covering a given area have been incurred, the incremental cost of serving additional users tends to decline. Cross-border economies of scale, by contrast, chiefly concern elements such as software, procurement, cybersecurity, virtualised network functions, compliance and the centralised management of platforms. From this perspective, reducing barriers to the centralisation of operational functions and harmonising national requirements can genuinely unlock efficiencies and support investment.

A selective conception of the Single Market

The paper’s central limitation, however, lies in its understanding of the “Single Market”. Connect Europe advocates a Single Market primarily in relation to rules, back-end infrastructure and the internal organisation of large European telecom groups. By contrast, it takes a strongly cautious view of a Single Market for connectivity services – that is, the ability of an operator to provide mobile services on a stable basis and to acquire customers across several Member States without having to replicate a fully-fledged national infrastructure in each of them.

The paper argues that assessing the Single Market through the availability of cross-border retail offers would be “short-sighted”. It further maintains that additional measures concerning permanent roaming and harmonised mobile wholesale access could hamper investment in 5G standalone and 6G, by distorting mobile markets that it regards as already highly competitive.

This position creates an asymmetry. The paper calls for a more integrated Europe for the operator – enabling it to centralise functions, standardise processes and reduce costs – yet it does not support corresponding instruments that would make the market European from the perspective of users and services. Put differently, the document promotes the Europeanisation of the multinational incumbent’s internal structures, but not the full Europeanisation of competition for the end customer.

It is correct to observe that access networks are territorial. Fibre is deployed in specific locations, while mobile networks require sites, spectrum, permits, backhaul, energy and coverage obligations connected to a defined geographical area. However, this technical and economic reality does not necessarily mean that the retail service must also remain national. A local network can perfectly well be used to provide a cross-border commercial service, provided that wholesale access conditions are compatible with a stable and sustainable retail offer.

Permanent roaming and the market for services

Permanent roaming is an emblematic example. The European Roam Like at Home regime has eliminated most retail surcharges for travellers using their phones in another Member State. But it does not establish a general right to retain indefinitely a SIM card and mobile contract from one Member State while living permanently in another. Fair-use policies allow operators to take action where use occurs predominantly or permanently abroad.

The issue is structural: an operator serving one of its customers in another Member State must purchase wholesale roaming from the visited network. European caps have reduced maximum wholesale prices – data caps stand at €1.10/GB in 2026 and will fall to €1/GB from 2027 – but these levels are designed to ensure the sustainability of occasional roaming, not to create an ordinary European market for permanent mobile services.

Where domestic retail prices are particularly low, the implicit unit revenue per GB may be substantially below the wholesale roaming cost. An operator allowing its customers to reside permanently abroad may therefore end up selling below cost, even without imposing any surcharge on the customer. In such circumstances, permanent roaming is not a commercially viable option, and customers remain, in practice, tied to the national market in which they reside.

The criticism of Connect Europe is therefore that the paper treats permanent roaming and harmonised mobile wholesale access only as potentially distortive instruments, without addressing their possible pro-competitive and integrative role. The objective should not be to impose a single European network, nor to permit indiscriminate arbitrage whereby users living in high-price countries systematically buy offers from low-price countries. Rather, it should be to design sustainable wholesale conditions, accompanied by proportionate safeguards against fraud, abusive resale, congestion and structural imbalances in traffic flows.

Conclusion

A telecommunications Single Market should not be limited to making already multinational operators more efficient. It should also make effective cross-border competition possible in the retail market. This requires a conceptual distinction between the local nature of the access network and the territoriality of the commercial service. The former will inevitably continue to depend on local conditions; the latter could develop on a European scale, benefiting citizens, multinational businesses, IoT services and new entrants.

In other words, the integration of rules and back-end functions is necessary, but not sufficient. Without roaming and wholesale-access conditions that permit the stable provision of mobile services across national borders, Europe risks creating operators that are more European in their internal organisation, while users and businesses remain captive to national retail markets.