GSMA Mobile Policy Handbook 2022

Mobile Policy
Handbook
An insider’s guide to the issues
About the GSMA
The GSMA is a global organisation unifying

the mobile ecosystem to discover, develop
and deliver innovation foundational to
positive business environments and societal
change. Our vision is to unlock the full
power of connectivity so that people,
industry and society thrive. Representing
mobile operators and organisations across
the mobile ecosystem and adjacent industries,
the GSMA delivers for its members across
three broad pillars: Connectivity for Good,
Industry Services and Solutions and
Outreach. This activity includes advancing
policy, tackling today’s biggest societal
challenges, underpinning the technology
and interoperability that make mobile work
and providing the world’s largest platform
to convene the mobile ecosystem at the
MWC and M360 series of events.
We invite you to find out more at

www.gsma.com
Follow the GSMA on Twitter: @GSMA
Do you have
the knowledge?
Can you take a position?
Will you lead the debate?
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About this handbook
Ever since the introduction of the first is a signpost for regulatory best practice.
digital cellular services for commercial As the global trade association of mobile
use in the 1990s, mobile networks have operators, the GSMA conducts and
spread, evolved and changed our world. commissions research on policy trends
Massive infrastructure investment and and challenges in the fast-moving mobile
competition among mobile operators, communications market. This handbook
supported by enabling policies and draws on the unique insight of the GSMA
regulation, have led to continual into the mobile sector and presents it in
improvements in network speed and a practical way for those who want to
quality and have extended the reach explore the issues and unleash the value
of mobile services to the most remote of mobile technology in their own market.
rural communities.
In this eighth edition of the Mobile Policy
The GSMA believes that a country’s citizens Handbook, new policy topics and industry
benefit most when the private and public positions have been introduced, covering
sectors work together in a spirit of openness areas such as 5G and spectrum sharing.
and trust, and that policymakers and Throughout the handbook, the content has
regulators create the conditions to attract been refreshed with up-to-date statistics,
telecoms investment, encourage innovation new resources and industry insights.
and strengthen digital trust. This is why we
are committed to supporting governments The online version of this resource
and regulators in their efforts to introduce – www.gsma.com/publicpolicy/
pro-investment telecommunications policies. mobilepolicyhandbook – offers an
always up-to-date catalogue of the
The Mobile Policy Handbook: An Insider’s policy positions of the mobile industry.
Guide to the Issues is an effort by the GSMA
to promote this collaboration. A unique We encourage you to contact the
resource that assembles a range of policy GSMA with any questions or requests
topics and mobile industry positions and for more information. Email us at
initiatives under one cover, the handbook handbook@gsma.com.
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World-changing trends
The world has pivoted towards digital 5G is appearing in cities first, where mobile
technologies to enable seamless data volumes are growing fastest and mobile
communication, connection, commerce operators can secure a return on investment.
and internet-enabled services and solutions. It is coexisting seamlessly with earlier mobile
These technologies have indelibly changed generations, and will connect citizens to the
the way businesses operate and people live, mobile internet for years to come.
work and play.
Many countries are now home to their first
Mobile networks are at the heart of this digital commercial 5G network deployments.
transformation. They are the primary channel This is important because the digital economy
through which people communicate and needs 5G to respond to booming demand
access online applications and the internet. for mobile data, enable a massive Internet
However, the industry itself is going through of Things (IoT) and support an array of
a transformation as it looks to a future services that require fast, dependable and
opened up by fifth-generation, or 5G, low-latency connectivity.
mobile networks.
Governments have embraced the vision of
5G as a catalyst for economic growth and
life-changing services. However, significant
new investment will be needed to fund
equipment costs, spectrum access licences
and regulatory expenses. Governments and
regulatory authorities will play a crucial role in
enabling efficient and timely deployment of
next-generation mobile networks while also
bringing down costs for mobile operators.
5G networks will be at the core of this next-

generation digital economy and society, and
supportive policy and regulations are needed
to make it a reality. We hope this handbook
will serve as a compass to navigate the policy
and regulatory challenges that lie ahead.
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Contents
Mobile for Development

#BetterFuture10
Mobile for Development 12
GSMA Capacity Building

Introduction12
Digital inclusion 14
Mobile for Humanitarian Innovation (M4H) 16
Mobile Money 18
GSMA Capacity Building 20
Mobile initiatives
Mobile initiatives 24
Future Networks 27
Introduction 27
5G: reaping the benefits 28
Business environment
IP communication services 30
Voice over LTE 32
Internet of Things (IoT) 33

Introduction33
Advanced air mobility 34
Connected vehicles 36
The evolution of spectrum
Privacy and data protection for IoT 38
Smart cities and IoT 40
Identity42
Introduction42
Mobile Connect 44
AI for Impact 46
Climate Action 46
Consumer protection
Business environment 48
Introduction48
Policies for progress 50
Community networks 52
Competition54
Deeper dive: Competition in digital markets 56
Deeper dive: Recommendations for resetting

competition policy frameworks 57
Efficient mobile market structures 58

Deeper dive: The dynamic benefits of mergers 60
Infrastructure sharing 62
Deeper dive: Types of infrastructure sharing 64
Intellectual property rights: patents 66
International mobile roaming 68
Mobile termination rates 70
Net neutrality 72

Deeper dive: Traffic management 74
Passive infrastructure providers 76
Quality of service 78
Deeper dive: A network of interconnections 80
Single wholesale networks 82

Deeper dive: The risks of SWNs 84
Taxation86
Deeper dive: Taxes and fees on mobile
consumers and operators 88
Universal service funds 90
Public-private partnerships 92
The evolution of spectrum: to 2030 and beyond 94

Introduction94
Spectrum needs 96
Planning spectrum: 2025–2030 98
Spectrum harmonisation 100

Deeper dive: World Radiocommunication
Conference 2023 (WRC-23) 102
Coexistence of technologies 104
Spectrum licensing 106
Spectrum licence renewal 108
Spectrum sharing, leasing and trading 110
Technology neutrality 112
Spectrum assignment 114
Spectrum pricing 118
Spectrum for industries 120
Wireless backhaul spectrum 124

#BetterFuture
Consumer protection 126
Introduction126
Cybersecurity128
Children and mobile technology 130

Deeper dive: Collaboration in action 132
Cross-border data flows 134

Deeper dive: National data privacy regimes 136
Deeper dive: Localisation rules 136
Data privacy 138

Deeper dive: Smart data privacy practices
and regulation 140

Deeper dive: GSMA Mobile Privacy Principles 141
Privacy and big data 142
Electromagnetic fields and health 144

Deeper dive: Health authorities on the science 146
Deeper dive: Advanced antenna technologies 147
Deeper dive: A global look at mobile network

exposure limits 148
Mobile initiatives
Illegal content 150
Deeper dive: Mobile Alliance Against Child
Sexual Abuse Content 152
Internet governance 154
Mandated government access 156
Deeper dive: Trending towards transparency 158
Case study: National regulatory approaches to

government access 160
Mandated service restriction orders 162
Mandatory registration of prepaid SIMs 164
Misinformation and disinformation 166

Mobile devices: counterfeit 168
Mobile devices: theft 170
Mobile network and device security 172
Number resource misuse and fraud 174
Signal inhibitors (jammers) 176

Consumer protection
Appendix178
#BetterFuture
The mobile industry is united behind a remain the only form

common purpose to intelligently connect of internet access for
everyone and everything to a better future. many. Mobile operators
in every region have been
Mobile connectivity is transforming the lives proactive during the pandemic,
of billions of people around the world and is reaching out to their customers and
at the heart of solutions that will tackle some working with public authorities and
of society’s greatest challenges. Innovative third parties to provide a range of essential
and emerging mobile solutions, big data, services and support the communities in
artificial intelligence (AI) and 5G can all be which they operate.
leveraged as a force for good.
Closing the digital divide is a priority for
Today, understanding and responding to the industry. When people are connected,
social, environmental and ethical issues equality, prosperity and well-being follow.
are widely understood as being good for Countries with high levels of mobile
business, and the mobile industry strives connectivity have made the most progress
to advance responsible, sustainable and in meeting their SDG commitments. Mobile
trusted leadership. operators are continuing to deploy, extend
and upgrade networks, and the number of
Underpinning this vision is the industry’s people with no 3G or 4G network coverage
commitment to the Sustainable Development has dropped to fewer than 450 million
Goals (SDGs). Every year, the sector reports worldwide. Still, 3.8 billion people have
its collective progress in the GSMA Mobile been left behind. Even if they have mobile
Industry SDG Impact Report and shares policy coverage, they are not reaping the benefits,
actions needed to achieve the 2030 Agenda. whether because of a lack of digital skills,
financial resources or locally adapted services.
Throughout the COVID-19 pandemic, digital
technologies have played a vital role in With more than 5.2 billion people using
enabling social and economic activities to a mobile phone in 2020, 13.1 billion IoT
continue. People around the world have relied connections1 and $900 billion in capital
on the internet to stay connected to friends expenditure for 2021–2025 (80 per cent
and family, access education and health of which will be for 5G), the mobile
services and work remotely. This underscores industry has shown it has the power
the importance of connectivity in our daily and the scale to make a meaningful
lives and the value of mobile networks, which difference to economies and societies.
Resources:
The GSMA 2021 Mobile Industry Impact Report: SDGs

The GSMA Sustainability Assessment Framework 2021
1. GSMA. (2021). The Mobile Economy 2021.
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#BetterFuture Mobile for Development GSMA Capacity Building Mobile initiatives Business environment The evolution of spectrum Consumer protection
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Mobile for
Development
Introduction
The transformative power of mobile is M4D has impacted more than 120 million
most apparent in low- and middle-income people in the past decade thanks to the
countries (LMICs), where it is typically the support of funding partners and stakeholders
most widespread technology and supported from the public and private sectors. It has
with far-reaching infrastructure. This puts supported the growth of the mobile money
the mobile industry in a unique position to industry from a concept to a transformational
connect people with essential services. financial inclusion tool boasting more than
1.2 billion registered accounts. Similarly, it has
Mobile for Development (M4D) is a dedicated supported the early stages and growth of the
global team within the GSMA that brings pay-as-you-go (PAYG) solar industry, which
together our mobile operator members, tech today provides clean energy to millions of
innovators, the development community and households. Digital skills campaigns based
governments. Singularly positioned at the on M4D content and gender strategies
intersection of the mobile ecosystem and the developed by mobile operators with M4D
development sector, the M4D team stimulates support have enabled tens of millions of
digital innovation to deliver both sustainable users to get online for the first time.
business and large-scale socio-economic and
climate impact for the underserved. In addition to the policy activities detailed in
this handbook, M4D publishes foundational
The team identifies opportunities and research, provides on-the-ground technical
provides support for innovations in digital assistance to projects, creates technology
inclusion, financial inclusion, gender assets to strengthen collaboration among
equality, agriculture, essential urban industry players and de-risks pioneering
services, humanitarian response and digital solutions through the GSMA
climate resilience and adaptation. Innovation Funds, which have already
provided capital to more than 100 ventures.
A key part of the M4D strategy is taking
advantage of the synergies between these Through these activities and more, M4D
areas to amplify their impact. For example, tests the feasibility of new ideas and
identifying ways to use mobile money business models, supports the growth
payments and machine-to-machine (M2M) of those with the most potential for impact
communication to improve access to and scale and, ultimately, helps digital
energy, clean water and sanitation while, solutions address the challenges faced by
at the same time, working in a variety of our societies, our economies and our planet.
contexts to make digital services accessible
and helpful for populations otherwise at risk
of being left behind, particularly women and
persons with disabilities.
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Digital inclusion
Background
The world is more connected than ever Through the Connected Women and
before, with more than four billion people Connected Society programmes, the
and countless organisations relying on GSMA works with the mobile industry,
mobile operators to access the internet. governments and other key stakeholders
Despite this achievement, 3.8 billion people on digital inclusion initiatives that help to
remain unconnected and excluded from expand mobile broadband coverage and
the benefits of mobile internet. The vast address the barriers to mobile internet
majority (89 per cent or 3.4 billion people) adoption and use, with particular emphasis
live in areas already covered by mobile on underserved groups, such as women
broadband (this is known as the “usage gap”). and persons with disabilities.
Another 450 million do not have access to
a network, mainly in Sub-Saharan Africa. Public policy considerations
Unsurprisingly, most unconnected people All stakeholders can and must do more
live in LMICs (93 per cent) and are more to measure, understand and address the
likely to be poorer, less educated, female challenges perpetuating the digital divide.
and rural. Although the gender gap in If no action is taken, based on current trends,
mobile internet use has narrowed, it is still almost 40 per cent of the world’s population
significant. Women in LMICs are 15 per cent will still be offline by 2025. The reasons for
less likely to use mobile internet than men, the mobile digital divide are complex and
which means there are 234 million fewer rooted in a variety of economic, social and
women using mobile internet. Expanding cultural factors. Accelerating mobile internet
mobile broadband connectivity and adoption and closing the digital gender gap
accelerating mobile adoption are critical to will require deliberate and strategic efforts
the growth of the digital economy, achieving by the mobile industry, policymakers and
the SDGs and ensuring no one is left behind. the international community.
Resources:
GSMA Connected Society Website

GSMA Connected Women Website
GSMA Report: State of Mobile Internet Connectivity 2021
GSMA Report: The Mobile Gender Gap Report 2021
GSMA Report: Enabling Rural Coverage: Regulatory and Policy Recommendations to Foster Mobile
Broadband Coverage in Developing Countries
GSMA Report: Accelerating Mobile Internet Adoption: Policies to Bridge the Digital Divide in Low- and
Middle-Income Countries
GSMA Report: Reaching 50 Million Women with Mobile
GSMA Mobile Connectivity Index
GSMA Mobile Coverage Maps Website
GSMA Capacity Building Course: Unlocking Mobile Rural Coverage
GSMA Capacity Building Course: Bridging the Mobile Gender Gap
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#BetterFuture
From a policy perspective, stakeholders other agencies. Successful policy strategies
should focus on the following key areas: recognise this and address these barriers
holistically through a whole-of-government
Enabling rural broadband expansion. approach and in collaboration with key

People without network coverage typically stakeholders, including with the private
have low incomes and live in sparsely sector. The usage gap will only be closed
populated, rural areas without enabling when all stakeholders share responsibility for
infrastructure, such as electricity. Such factors accelerating mobile internet adoption and use.
have an adverse impact on the business case
for mobile network expansion. Policymakers Closing the mobile gender gap. The mobile
should recognise that the mobile industry gender gap is not going to close on its own.
cannot fully close the coverage gap without Targeted intervention is needed from industry,
government support. Instead, they can policymakers, the development community
Mobile initiatives
create better incentives to invest in rural and other stakeholders to ensure that
infrastructure by aligning key policies around women are no longer left behind. To
best practices. For example, adopting address the gender gap, policymakers
coverage-driven spectrum allocation and and regulators should:
pricing, implementing investment-friendly
tax policies, facilitating access to public » Ensure there is a focus on gender equality
infrastructure, reducing red tape for deploying and reaching women at an organisational
mobile infrastructure and encouraging and policy level through senior leaders
voluntary infrastructure sharing. championing the issue and setting specific
gender equity targets.
Addressing barriers to mobile internet
adoption and use. 3.4 billion people live » Understand the mobile gender gap by
in areas covered by a mobile network but improving the quality and availability of
do not use mobile internet. Closing the gender-disaggregated data and understand
usage gap will require tackling five main women’s needs and the barriers they face
barriers: the affordability of handsets and to mobile ownership and use.

data bundles; knowledge of mobile internet
and digital skills; lack of relevant content » Explicitly address women’s needs,
and services; safety and security concerns; circumstances and challenges in the design
and access to key enablers, such as formal and implementation of interventions and
IDs or accessibility features. Policy policies. This includes addressing the
considerations include measures that help barriers women face related to mobile
lower the cost of handsets and data; improve access, affordability, safety and security,
literacy and digital skills focused on the life knowledge and skills and the availability of
goals and needs of targeted user groups; relevant content, products and services.
Consumer protection
create an environment for businesses and

organisations to digitally transform or for » Collaborate and create partnerships with
start-ups to grow; and address online safety different stakeholders to address the
and security concerns, such as harassment, mobile gender gap.
disinformation or handset theft. Responsibility
for these and other policy measures cuts
across various ministries, regulators and
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Mobile for Humanitarian Innovation (M4H)
Background
The GSMA Mobile for Humanitarian Innovation an inclusive and impactful digital
(M4H) programme was launched in 2018 humanitarian future. M4H works to
with support from the UK Foreign, achieve this aim by catalysing innovations,
Commonwealth & Development Office supporting partnerships, generating
(FCDO). The mission of M4H is to evidence and advocating for enabling
accelerate the delivery and impact of digital policy environments that accelerate
humanitarian assistance through improved the delivery and impact of digital
access to and use of life-enhancing mobile- humanitarian assistance. The
enabled services during humanitarian programme’s high-quality monitoring,
preparedness, response and recovery. evaluation and learning framework
allows it to assess the impact of its
The mobile industry continues to invest in work and drive adaptive programming.
partnerships and solutions that have the
potential to deliver impactful, safe and Public policy considerations
efficient digital humanitarian assistance.
Nearly 160 mobile operators in 111 countries The M4H programme has developed
have committed to the GSMA Humanitarian the following policy considerations for
Connectivity Charter, an initiative to improve multilateral agencies, governments,
the preparedness and response of mobile national regulatory authorities and mobile
networks during humanitarian crises. operators to accelerate the delivery and
The M4H programme has shown that a impact of digital humanitarian assistance:
well-developed digital ecosystem has
the potential to not only provide people Recognise the role of government in
affected by crisis with a suite of humanitarian preparedness, response and
life-enhancing mobile services, but also recovery. This includes the coordination
strengthen the business case for mobile of response to sudden-onset disasters,
operators, and across the private sector, protracted emergencies and situations of
by expanding the range of digital services forced displacement. This is a necessary
and platforms that can be tested, role that enables governments to work
implemented and scaled. with and empower the mobile industry
and humanitarian partners to manage
The GSMA is in a unique position to support the risks associated with humanitarian
system- and industry-wide transformation for crises and respond effectively.
Resources:
GSMA and UNHCR Report: Displaced and Disconnected

GSMA Report: Access to Mobile Services and Proof of ID
GSMA Report: Proportionate Regulation in Uganda
GSMA Report: National Emergency Telecommunications Plans: Enablers and Safeguards – A Brief
Evaluation Guide for Policy Practitioners
GSMA Report: Policy and Regulatory Recommendations to facilitate Mobile Humanitarian and Social
Assistance during COVID-19
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#BetterFuture
Encourage mobile operators to have Promote the acceptance of other forms
up-to-date business continuity plans of ID issued by humanitarian organisations
or disaster recovery plans to ensure to satisfy know-your-customer (KYC)
communications services are available, and to requirements in markets where these

minimise the impact on telecommunications are mandated.
services during emergencies.
Create a clear and conducive legal pathway
Promote the adoption of robust privacy for non-nationals, such as refugees, to access
and data protection principles when dealing mobile connectivity and mobile money
with personal data, particularly those of services in their own name. Harmonise ID-
marginalised persons, in the absence of related SIM registration rules with the lowest
relevant legal frameworks. tier of KYC requirements in countries and
markets that mandate SIM registration.
Mobile initiatives
Create an industry-conducive emergency
telecommunications plan to enable all Promote robust validation processes for
stakeholders to think through the life humanitarian ID while being sensitive to data
cycle of a potential emergency, determine protection and privacy rules, particularly for
the capacities required and establish marginalised groups and populations.
a governance framework using a Provide for relaxed rules or regulations
multi-stakeholder approach. during emergencies to ensure the provision
of mission-critical telecommunications
Create clear and consistent legal and services during any phase of a humanitarian
regulatory instruments for managing crisis, and to allow mobile operators to
humanitarian digital identity and break adjust to unforeseen circumstances.
down barriers that may inhibit the roll-out
of mobile enabled-identification (ID) Promote partnerships, collaboration and
services or create regulatory uncertainty. coordination within government, across
public and private sector agencies and within
Create an inclusive and comprehensive ID communities at risk to facilitate timely and

enrolment policy to provide formal identities effective responses.
for the millions who are unregistered. Ensure
persons of concern (PoC) have an acceptable Facilitate agreements among mobile
and recognisable form of ID to access mobile operators that give all mobile customers
and other identity-linked services. access to their networks during emergencies.
Establish a proportionate risk assessment

process that considers different types of PoC
when developing proof-of-identity policies,
Consumer protection
procedures and rules.
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Mobile Money
Background Public policy considerations
Mobile money has done more to extend Regulation has a major impact on the
the reach of financial services in the past uptake of mobile money services. Evidence
decade than bricks-and-mortar banking has from the Global Findex Survey and GSMA
in the past century. This has been due to research show that enabling regulatory
the ubiquity of mobile phones and mobile frameworks accelerate the development and
operators’ extensive networks and retail adoption of digital financial services. When
distribution channels, which together provide banks and non-bank providers, especially
customers a more secure and convenient way mobile operators, are allowed to deploy
to access, send, receive and store funds. mobile money services and establish sound
commercial partnerships, mobile money can
Mobile money has transformed the financial be a catalyst for financial sector development.
services landscape in many LMICs by It significantly expands financial inclusion
complementing and disrupting traditional through lower transaction costs, better rural
banking. Mobile money platforms now access and greater customer convenience.
process more than $2 billion a day through It can also provide the infrastructure to
more than 1.2 billion registered mobile money support a broad range of financial services,
accounts. More than $1 billion in international including insurance, savings and loans.
remittances is received into mobile money
accounts every month, and $500 million is Analysis of customer data provides a major
converted into e-money daily by 5.2 million opportunity to develop innovative mobile
unique mobile money agent outlets worldwide. money services and ensure the long-term
sustainability of the industry. Appropriate
The mobile money industry has proven to be data privacy frameworks will be critical to
both viable and sustainable: as of 2020, there safeguard consumers’ personal data and
were 310 services in 96 countries. The services promote trust. Enabling frameworks that
provided by mobile money providers (MMPs) support cross-border data flows while
are deepening, with the number of merchants also protecting personal data will become
accepting mobile money payments surging increasingly important to the growth of
29 per cent between December 2019 and the industry.
June 2020. In 2020, the volume, activity and
value of mobile money-enabled merchant Global players in the financial services
payments all grew. Payments increased by industry are adapting their business
43 per cent, up from 28 per cent in 2019, models to embrace the cloud and use
generating more than $2.3 billion in monthly new solutions provided by financial
transactions in 2020, on average. technology providers (fintechs) to
Resources:
GSMA Mobile Money Programme Website

GSMA Mobile Money Metrics Website (Mobile Money Regulatory Index)
GSMA Mobile Money Certification Website
GSMA Report: Demystifying Regulatory Concerns for the Use of Cloud Services in Mobile Money
GSMA Report: 2021 State of the Industry Report on Mobile Money
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#BetterFuture
improve services and lower investment building trust with regulators and encouraging
costs. The mobile money sector is gradually appropriate and proportional regulatory
adopting these technological changes to standards. Enhancing trust in mobile
scale up their services and increase financial money is in the collective interest of the

inclusion sustainably. However, regulatory private sector, governments, regulators
concerns about using the cloud for mobile and consumers.
money services, such as data privacy and
supervision and oversight by local regulators, For mobile money to succeed, non-bank
should be addressed without restricting use mobile money providers must be able to
for mobile money providers. enter the market on an equal footing. This
level playing field must be established via an
Mobile money can help governments enabling policy and regulatory framework.
achieve policy objectives for safe, secure Policymakers and regulators should:
Mobile initiatives
and efficient payment systems. It also
makes a country’s financial system less » Embrace reforms to enable mobile
vulnerable by lowering the risks created by operators to launch and scale mobile
the informal economy and the widespread money services.
use of cash. For example, mobile money
can usher more people from the informal to » Allow market-led solutions to be
the formal economy and this, in turn, helps implemented at the right time for
governments become more transparent consumers and providers, and ensure
and make more informed economic policy that government-led instant payment
decisions. Government agencies can also schemes have fair and inclusive governance
reap the benefits of mobile money. Sending principles and operating rules.
government-to-person (G2P) and person-
to-government (P2G) payments via mobile » Engage with mobile money providers
money reduces cash-handling costs, security and provide adequate guidance to
risks and theft of funds while improving ensure that regulatory uncertainty
transparency, speed and efficiency. on cross-border data flows is not a

barrier to the use of cloud services
Trust is key to the success of mobile money. in the mobile money industry.
Over the past decade, mobile money has
evolved from a niche product in a few markets » Ensure that fiscal policy (taxation) is
to an emerging market phenomenon, bringing broad-based and not sector-specific.
reliable financial services to unbanked Taxes that discriminate against players
populations. In many LMICs, mobile money and users in the financial services sector
has become the leading payment platform should be avoided, particularly given
for the digital economy. The GSMA Mobile the positive externalities of mobile
Consumer protection
Money Certification is a global initiative to money services.

bring safer, more transparent and resilient
financial services to millions of mobile money » Adopt risk-based approaches to risk
users around the world. Certification will management and encourage the
help take the industry to the next level by implementation of appropriate and
improving quality of services and customer proportional regulatory standards.
satisfaction, facilitating trusted partnerships,
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GSMA Capacity
Building
Background
The GSMA Capacity Building programme are accredited by the United Kingdom
offers free training courses for policymakers Telecommunications Academy.
and regulators. Since its launch in 2013, it
has become the world’s premier provider Courses are suitable for professionals at
of specialist telecoms regulatory training, any stage of their career and are offered in
delivering courses to more than 8,000 English and French. Available both face-to-
regulatory professionals from more than face and online, policymakers and regulators
170 countries. Through a combination of have maximum flexibility in how they study.
engaging and interactive courses, expert The in-person courses are between one
trainers and in-depth research and analysis, and three days, while the online courses
the programme helps policymakers and last between three and seven weeks.
regulators shape the development and reach
of mobile services in their country and ensure To learn more about the training or to register
they deliver the most benefit to citizens. for a course, visit: www.gsmatraining.com
The courses help students understand and Courses:

keep track of the latest policy and regulatory
developments around the globe. Using real- » 5G — The Path to the Next Generation
world examples of regulatory good practice » Big Data Analytics and Artificial
from different regions, the courses examine Intelligence for Impact
the impact of different approaches on the » Bridging the Mobile Gender Gap
delivery of mobile services. Core areas » Competition Policy in the Digital Age
covered include 5G, spectrum, competition » Digital Identity for the Underserved
policy, rural coverage and how to leverage » Internet of Things
mobile technology to achieve SDG targets. » Leveraging Mobile to Achieve SDG Targets
» Mobile Sector Taxation
The in-house policy experts who develop » Personal Data in the Context of Mobile
and teach the courses have backgrounds Networks
in telecommunications, law and financial » Principles of Mobile Privacy
services. Many also hold advanced academic » Radio Signals and Health
qualifications. Through their work with the » Spectrum Management for Mobile
GSMA, they are in constant contact with Telecommunications
governments and regulatory authorities » The Role of Mobile in Humanitarian Action
around the world, which gives them a » Unlocking Rural Mobile Coverage
unique understanding of the most pressing
issues facing regulatory authorities today.
The courses are packed with the latest

and most robust market statistics, analysis
and insights thanks to the support of a
global team of researchers, forecasters
and analysts from GSMA Intelligence, the
research arm of the GSMA. Training materials
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Meet our students
Student profile
Pamela Tan,
Deputy Director,
Access and Interconnection Department,
Market Regulation Division of the Malaysian Communications
and Multimedia Commission (MCMC)
Pamela Tan has been with the MCMC since interconnection policies and regulatory
2006 and has a range of experience in policy instruments. The course also taught
planning, implementation and compliance. her about emerging bottlenecks in
In her role as Deputy Director, Pamela assists telecommunications and helped her
in the development of policies and regulatory understand the market definition process.
instruments for access regulation, monitoring
licensee compliance, evaluating and ensuring Pamela felt that the knowledge she gained
access agreement registrations and access from both courses assisted her in the review
complaint resolution. She also works on of the Access List, which is currently at a
capacity building initiatives. preliminary stage in Malaysia. The Access List
ensures that all network facilities providers,
Pamela took the 5G – The Path to the network service providers and applications
Next Generation course. She found it service providers can gain access to the
useful because it provided a basic necessary facilities and services on reasonable
understanding of 5G and the need for terms and conditions. The aim is to encourage
regulation and policies to evolve to downstream activities to flourish and create a
encourage adoption and support the more robust market environment that offers
growth of the technology. While taking consumers more choice and value for money.
the course, Pamela was researching
how to regulate 5G, which is already “The courses helped me to progress further
being rolled out in Malaysia nationwide, with my work, research, policy development
and found the information on network and reviewing the relevant instruments.”
slicing particularly interesting. Pamela
also took the Competition Policy in the Were the courses useful for Pamela’s career?
Digital Age course. She appreciated the “Knowledge of 5G is surely useful for a
holistic view of competition policy the career in telecommunications, whether
course provided and found it useful in Malaysia or other countries, since this
for the development of access and is the next generation.”
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#BetterFuture
Student profile
Sumit Mishra,
Director of Compliance,
Department of Telecommunications (DoT),

Government of India
Sumit Mishra has more than 20 years of operators to conduct trials of various 5G
experience in telecoms management in the technologies and applications in different
Indian Department of Telecommunications areas of the country. For example, Vodafone
(DoT), as well as in telecom companies Ideal was conducting trials of 5G apps
Mobile initiatives
such as BSNL and RailTel Corporation and services in the Gujarat area, including
of India. In his role as Director of Compliance 360-degree virtual reality (VR) content
at the DoT, Sumit is responsible for the playback and fixed wireless access
coordination and monitoring of all service broadband services.
providers. This involves checking that the
services offered by licensees are compliant, The 5G course helped him better understand
not only with licence conditions, but also the role 5G technology can play in expanding
with any directions issued in the public broadband services in rural areas, which will
interest by the licensor. This includes the soon be a driving force of the rural economy
imposition of penalties, if they have been in India.
issued, in accordance with Government
of India guidelines for Gujarat state. “The 5G – The Path to the Next Generation
course explained 5G-related topics in a very
Sumit enrolled in the 5G – The Path to simple but effective manner and this will
the Next Generation course to ensure surely help when the actual field trials start.”
that he understood the basic concepts

of 5G and the challenges that lay ahead Sumit really enjoyed learning about the
for licensors and regulators. At the time experience of 5G in other countries and
he took the course, India was on the would welcome regular refreshers on 5G to
verge of rolling out 5G and the government stay abreast of rapid developments in this
was working with the major telecom emerging technology.
Consumer protection
23
Mobile initiatives
Innovation and investment by the mobile

industry continue to have an enormous
impact on the lives of billions around
the world. Mobile does not just provide
connectivity; it also empowers people with an
ever-growing range of life-enhancing services.
Today, there are more than five billion unique

mobile subscribers, which means that more
than two-thirds of the world’s population
are now connected to a mobile service.
By the end of the decade, almost three-
quarters of the world’s people will have
a mobile subscription, with around one
billion subscribers added over this period.
The GSMA leads programmes in areas that

offer significant benefits for consumers and
clear opportunities for mobile operators.
From supporting the development of mobile
identity solutions to helping operators
prepare for a 5G future, these initiatives are
laying the foundation for an increasingly
connected world.
Each of the initiatives discussed in the

following pages has its own public policy
considerations and is related to one or
more of the public policy topics covered
in this handbook.
24
25
26
#BetterFuture
Future Networks

Introduction
The mobile industry continues to roll out industry achieve its target of making 5G
fifth generation (5G) technology. Building available to a third of the world’s
on the achievements of 4G, 5G networks population by 2025.
help the mobile industry capture the huge

opportunity presented by the Internet of Governments and regulators also have
Things (IoT), usher in an era of even faster crucial roles to play. By adopting national
mobile broadband and pave the way for policy measures that encourage long-term,
ultra-reliable, ultra-low latency services heavy investment in 5G networks, and
that may include exciting technologies ensuring that sufficient harmonised
such as tactile internet, augmented reality spectrum is made available for 5G services,
and autonomous vehicles. future 5G infrastructure will deliver significant
benefits for citizens. Decisions made today
As mobile operators deploy 5G networks, will have lasting impacts, and the ultimate
Mobile initiatives
close collaboration between industry, success of the technology will depend on
policymakers and regulators will be governments and regulators making the
needed to deliver on the promise of roll-out of 5G a priority.
this next-generation technology and
provide the infrastructure to operate it. While they explore 5G technologies,
mobile operators are also upgrading their
The GSMA is playing its part, providing networks to transition to all IP-based services.
guidance on innovations such as network This is important, not just for consumers
slicing in 5G, while also working to boost and business to reap the benefits of today’s
population coverage of high-speed most advanced services, but also because
broadband and reduce the capital intensity IP-based networks and services will be the
required to roll out 5G technology. Work on launchpad for 5G services.
infrastructure sharing and improvements to
radio networks, for example, have already
helped identify a potential four per cent
reduction. This will be vital in helping the

Consumer protection
27
5G: reaping the benefits
Background
Mobile telecommunications have had capability of integrated access and backhaul

a phenomenal and transformational on cars and trains; and using smart repeaters
impact on society. From the earliest that amplify signal but not noise.
days of first-generation analogue phones,
every subsequent generational leap has 2021 marked the first large-scale
brought huge benefits to societies around commercial launches of 5G, a mixed
the world and propelled the digitisation deployment of optimised 4G networks
of more and more segments of the global (5G Non-Standalone or NSA) and
economy. The mobile industry is now new 5G networks (5G Standalone or
transitioning to 5G technology, building SA). By 2025, 5G could account for
on the achievements of 4G while also more than a billion connections and
creating new opportunities for innovation. 5G networks are likely to cover a third
of the world’s population. The impact
Industry, research, academic and on the mobile industry and its customers
government groups around the world will be profound. 5G is more than a new
are working to define the technology for generation of technologies. It will also
5G. 3GPP are completing their Release-17 usher in an era in which connectivity is
definition of 5G and starting to work on more fluid and flexible, with 5G networks
Release-18, 5G-Advanced. One of the key adapting to applications and performance
objectives is a more sustainable mobile tailored precisely to the needs of users.
and technology sector and, because 5G
will drive significant investments in energy, The key focus areas for 5G development
the mobile industry is moving to boost and innovation include:
network efficiency as part of Release-18.
This includes sleep modes for base stations Internet of Things: 5G is needed to capture
when they are not transmitting, power the huge opportunity presented by IoT.
amplifier improvements and the use of Conservative estimates suggest that, by
AI and machine learning to enhance data 2025, there will be twice as many IoT
collection and internode communication to devices as personal communication
optimise energy savings. Other Release-18 devices. As the ecosystem grows, the
goals include enhancing the performance and mobile industry will be expected to
efficiency of 5G Massive MIMO; improving support bespoke services across industry
mobility for devices operating in sub-7GHz verticals and develop next-generation
and mmWave frequencies; expanding the services not possible with 4G networks.
Resources:
GSMA 5G Website
GSMA Blog: Five Things You Wanted to Know about 5G, But Never Dared to Ask
GSMA Report: The 5G Era: Age of Boundless Connectivity and Intelligent Automation
GSMA Report: 5G in China: Outlook and Regional Perspectives
GSMA Report: Smart 5G Networks: Enabled by Network Slicing and Tailored to Customers’ Needs
28
#BetterFuture
Mobile broadband: With every generational services and support a variety of new
leap in mobile technology, there is a natural applications. The mobile industry, academic
progression to faster and higher capacity institutions and national governments are
broadband. Mobile broadband services all actively investigating what technologies

using 5G technology will need to meet could be used in 5G networks and the
and exceed customers’ expectations of types of applications these could and
faster and more reliable access. should support. The speed and reach of
5G services will depend heavily on access
Ultra-reliable, ultra-low latency services: to the right amount and type of spectrum.
Superior speed, high reliability and low
latency will allow 5G to nurture new Additional spectrum will be required for 5G
services that cannot be supported on services, especially in very high frequency
existing 4G networks. Some of the services bands, to support significantly faster data
Mobile initiatives
being considered include tactile internet, speeds and enhanced capabilities.
virtual/augmented reality, autonomous
vehicles and factory automation. However, progressive refarming of existing
mobile bands should also be encouraged
Private networks: Private 5G networks to support wider area 5G services.
allow private and public sector enterprises Governments and regulators can enable
to bring a bespoke experience to indoor refarming and encourage heavy investment
or outdoor facilities where high-speed, in 5G networks by supporting long-term,
high-capacity or low-latency connectivity technology-neutral mobile spectrum
is crucial. They also address the need for licences with clear renewal procedures.
dedicated bandwidth capacity and range,
specialised security policies, high-quality Three key frequency ranges are needed
connections and consistent, always-on for 5G to deliver widespread coverage
service to help reduce downtime. and support all use cases: sub-1 GHz, 1–6
GHz and above 6 GHz. Higher frequencies
The GSMA aims to play a significant role (mmWave), especially above 24 GHz, will
in shaping the strategic, commercial and be needed to support superfast speeds in
regulatory development of the 5G ecosystem, hotspots. Lower frequencies will be needed
including the identification and alignment to support wider area broadband access and
of suitable spectrum bands. Working closely IoT services. Exclusive licensing remains the
with the mobile operators pioneering 5G, principal and preferred regime for managing
the GSMA is also engaging with governments mobile broadband spectrum to guarantee
and vertical industries (such as the quality of service and network investment.
automotive, financial services, health care,
transport and utilities sectors) to develop However, the licensing regime in higher
Consumer protection
business cases for 5G. frequency bands, such as above 6 GHz,

could be more varied than in previous
Public policy considerations mobile technology generations to suit
more flexible sharing arrangements.
The GSMA views 5G as a set of requirements
for future mobile networks that could
dramatically improve the delivery of mobile
29
IP communication services
Background
IP communication is increasingly recognised » ViLTE: This enables operators to deploy

as a natural evolution of core mobile services a commercially viable, carrier-grade,
and, therefore, a basic requirement of doing person-to-person video calling service.
business in the future. The IP Multimedia Like VoLTE, it is based on IMS technology.
Subsystem (IMS) has become the preferred As of 2022, there were 16 ViLTE services
technical approach to transferring core mobile commercially available in 15 countries.
operator services to an all-IP environment
because of its flexibility, cost-effectiveness » VoWiFi: This allows operators to offer
and support for IP services over any access voice calling over Wi-Fi, providing many
medium. With 670 mobile operators having of the same benefits of VoLTE. As of
launched Long-Term Evolution (LTE) networks 2022, there were 95 VoWiFi services
and LTE coverage currently reaching nearly commercially available in 51 countries.
80 per cent of the world’s population, the
industry is now in a realistic position to make » RCS: RCS marks the transition from
a global, interconnected IP communications messaging with circuit-switched
network a reality. technology to an all-IP world, using
the same IMS capabilities as VoLTE
IP communications is comprised of Voice and ViLTE. It incorporates messaging,
over LTE (VoLTE), Video over LTE (ViLTE), video sharing and file sharing, enriching the
Voice over Wi-Fi (VoWiFi) and Rich communication experience of consumers.
Communication Services (RCS):
The GSMA is working with leading mobile
» VoLTE: This offers a path from circuit- operators and equipment vendors to
switched 2G and 3G voice services to all-IP accelerate the launch of IP-based
packet-switched voice and includes a range services around the world. This involves
of enhanced features for customers, such developing specifications, assisting
as high-definition audio quality and shorter operators with technical and commercial
call connection times. As of 2022, 233 preparations for service launches and
mobile operators offered VoLTE services resolving technical and logistical barriers
commercially in 106 countries. to interconnect.
Resources:
GSMA Report: Building the Case for an IP-Communications Future

GSMA All-IP Business Guide
Greenwich Consulting Report: The Value of Reach in an IP World
GSMA Report: AA.35: Procedures for the Development of Industry Specifications
30
#BetterFuture
Public policy considerations
To support the exponential growth in IP Interconnect. VoLTE, ViLTE, VoWiFi

traffic, large-scale investments in network and RCS support the interconnection
capacity will be necessary. Financing these of these services between customers
investments will depend on predictable on different mobile networks. With

and stable regulatory environments in voice, they also support interconnection
which operator-led communications with customers on fixed networks.
can be closely aligned with regulatory
requirements for mobile telecommunications, Lawful intercept. Mobile operators are
and mobile operators will have systems in subject to a range of laws and licence
place to ensure compliance. conditions that require them to intercept
customer communications (and sometimes
Open standards. The GSMA is responsible retain certain data, such as the time and
for the industry specifications that many content of the communication and the
Mobile initiatives
stakeholders use, including for eSIM, VoLTE, location, numbers or IP addresses of
ViLTE, VoWiFi and RCS. In November 2019, the participants) for disclosure to law
the GSMA revised their procedures for the enforcement agencies upon request.
development and maintenance of industry Specifications for IP communications
specifications to reflect industry best are being developed to support the
practice and incorporate stronger measures capabilities needed to meet these
for balance, openness and transparency in lawful interception obligations.
standard setting.

Consumer protection
31
Voice over LTE
Background
Consumers expect seamless, carrier-grade of VoLTE to Voice over New Radio (VoNR)
voice services from mobile operators, for 5G.
regardless of the technology. Since the
introduction of digital mobile technologies VoLTE has several characteristics that
in the early 1990s, carrier-grade public distinguish it from internet-based voice
mobile voice services have been delivered services. These include carrier-grade call
using the circuit-switched capabilities of quality and reliability, support for emergency
2G and 3G networks. calls and universal interconnection with
other carrier-operated voice services, which
To keep pace with growing demand, means customers can make calls to, or receive
mobile operators are upgrading their calls from, any phone number in the world. By
networks using a fourth-generation contrast, most internet-based voice services
IP-based technology called Long-Term are not managed for service quality and may
Evolution, or LTE. LTE networks support be restricted to closed user groups.
VoLTE, a new carrier-grade voice capability
that supports the transition from circuit- In some jurisdictions, interconnection
switched 2G and 3G voice services. VoLTE of carrier-grade mobile voice services is
includes a range of enhanced features for unregulated and carried out pursuant to
customers, such as high-definition audio various commercial agreements. In others,
quality and shorter call connection times. regulated mobile call termination rates
apply. These rates typically use a time-based
Some operators now have LTE networks that charging mechanism and levels are set using
offer full national coverage and use VoLTE for different cost-oriented methodologies.
voice calls while others still have only partial
LTE network coverage. In most markets, Public policy considerations
full LTE coverage will take several years,
requiring partial reliance on legacy voice Since VoLTE is an evolution of carrier-grade
services. For voice services, the transition is mobile voice services historically provided
facilitated by the fact that VoLTE has been by circuit-switched 2G and 3G networks,
designed to support the seamless handover regulators should not apply additional or
of calls to and from 2G and 3G networks. specific regulations to VoLTE services.
As the industry starts to roll out 5G, In markets where mobile voice call termination
communication services over 5G will become is subject to regulatory control, the same
critical. In 2021, the GSMA published new and approach should be adopted for VoLTE with
updated specifications to support 5G-based a single rate applied for 2G, 3G and 4G/LTE
communications services and the application voice call termination.
Resources:
GSMA Networks Group Website

EEWorld Online: VoLTE — What Makes Voice Over IP “Carrier-grade”?
32
#BetterFuture
Internet of Things (IoT)

Introduction
The Internet of Things is set to have a huge

impact on our daily lives, helping us to reduce
traffic congestion, improve care for the elderly,
create smarter homes and offices, increase

manufacturing efficiency and more.
IoT involves connecting devices to the internet

across multiple networks to allow them to
communicate with us, applications and each
other. It will add intelligence to devices we use
every day and, in turn, have positive impacts
on the economy and broader society.
Mobile initiatives
We are poised to see rapid growth in IoT.
According to GSMA Intelligence, the
number of licensed cellular IoT connections
is expected to exceed three billion by 2025.
However, this will still represent only a small
portion of the overall market, as the total
number of IoT devices will have grown to
25.2 billion by 2025.
The GSMA is encouraging the development

of the nascent IoT ecosystem by defining
industry standards, promoting interoperability
and encouraging governments to create a
supportive environment that will speed the
growth of IoT globally.
Consumer protection
33
Advanced air mobility
Background
The development of Unmanned Aerial The rapid development of this market means
Vehicles (UAVs), commonly known as drones, regulators are struggling to keep pace.
has advanced at a rapid pace in recent years. However, regulatory efforts are focused on
Military use was the early focus of these creating frameworks that will allow the sector
developments, but the potential for drones to to develop and innovate while also limiting
be used in a civilian context for innovative new risks related to safety, privacy and data
and existing services is now widely recognised. protection. The fact that drones fly across
borders adds another layer of complexity.
Use cases range from filming for news
reporting and entertainment to inspecting Mobile operators are a key enabler for drones
key infrastructure, such as power plants, and will help to unlock their potential. By
roads, buildings, cell towers and power providing the connection between drones
lines. In agriculture, drones are already and their control centres, operators ensure
being used to produce timely crop surveys reliable communication with the drone on its
to boost yields. flight path and support the transfer of data.
Resources:
GSMA Internet of Things – Advanced Air Mobility Website
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#BetterFuture
New regulatory frameworks for drones By providing secure, high-quality connectivity

should ensure that they can, where with control centres, mobile connectivity can
required, be equipped with SIM cards also help ensure that drones are controlled
and a communications modem to allow and operated safely. This has several potential

the drone ecosystem to benefit from benefits for the drone ecosystem:
mobile connectivity. This would have
many benefits for the drone industry: » Mobile connectivity could become part of
unmanned traffic management solutions
» Mobile networks provide a global, and enable no-fly zones.
interoperable and scalable platform that
allows the drone market to develop and » A mobile-based solution could be an
benefit from the existing mobile ecosystem. effective way to enable drone identification
and authorisation services since identity
Mobile initiatives
» Many mobile operators already run 4G LTE verification and management are already
networks, which meet extremely high- key components of mobile services.
bandwidth and low-latency requirements
while also offering huge scalability and » Mobile connectivity could assist law
exceptional quality of service. enforcement by enabling the identification
and tracking of drones.
» The mobile industry already works with
IoT partners throughout the value chain » The mobile industry has a strong track
to embed privacy and security in IoT record of implementing privacy and data
technologies. These collaborations allow protection measures.
the drone market to benefit from initiatives
such as the GSMA Security Guidelines and To ensure licensed mobile spectrum is
Privacy by Design Toolkit. available for drone connectivity, there
needs to be cooperation between the
regulatory authorities responsible for
spectrum and the regulators responsible

for drones. By working together, they
could remove barriers to the use of
existing licensed mobile spectrum for
drone connectivity.
Consumer protection
35
Connected vehicles
Background
The automotive world is about to undergo dialogue among all stakeholders in the
the single greatest revolution in its history. automotive and C-ITS ecosystem and
Autonomous vehicles and intelligent transport seeks innovative ways for these sectors
systems (ITS) are set to transform the to leverage mobile technology.
efficiency, comfort, safety and environmental
impact of road transport. One example is the GSMA Embedded
SIM Specification, which provides a
The first fully autonomous-capable cars have single mechanism for the remote
been launched and, according to data from provisioning and management of M2M
Machina Research, the number of factory-fit connections, allowing “over-the-air”
connected vehicles worldwide is expected provisioning of an initial operator
to reach 366 million by 2025. In Europe, subscription, as well as subscription
regulation requires that, as of March 2018, changes from one operator to another.
all new models must support eCall. In the
event of an accident, an eCall-equipped Mobile technology is also set to play a vital
vehicle automatically calls the nearest role in ITS by providing Cellular Vehicle-to-
emergency centre and sends the exact Everything (C-V2X) services. Standardised
location of the crash site, allowing rapid by 3GPP, C-V2X supports connectivity
response by emergency services. between devices (whether in vehicles,
roadside infrastructure or mobile devices)
The GSMA is actively engaging with vehicle as well as between devices and networks.
manufacturers, mobile operators, SIM vendors, C-V2X is being developed within the
module makers and the wider Cooperative traditional mobile ecosystem and offers
Intelligent Transport System (C-ITS) ecosystem all the advantages and capabilities of
to facilitate the development of current and traditional cellular networks: security, privacy,
future connected vehicle solutions. interoperability and an innovation-oriented,
future-proofed ecosystem (5G technology).
The primary platform for these activities is The 5G Automotive Association (5GAA),
the Connected Vehicle Forum. Established whose 60 members include the main
by the GSMA, the Forum promotes vehicle manufacturers, support C-V2X.
Resources:
GSMA Report: Safer and Smarter Driving: The Rollout of Cellular V2X Services in Europe
GSMA Report: Cellular Vehicle-To-Everything (C-V2X): Enabling Intelligent Transport
GSMA Report: Automotive IoT Security: Countering the Most Common Forms of Attack
GSMA Report: Mobilizing Intelligent Transportation Systems
GSMA Transforming the Connected Car Market Website
GSMA Case Study: EE Helps Bring Safer Driving to the UK’s Roads
36
#BetterFuture
Connected vehicle and intelligent transport Regulators should adopt a technology-

apps have the potential to bring substantial neutral approach to this spectrum rather
benefits to consumers, including making travel than mandating or favouring one approach.
safer, reducing congestion and providing real- It is equally important that technology-

time information to passengers. neutral spectrum licences are adopted,
as this will allow existing mobile bands
Connected vehicle apps and services have to be refarmed for 5G and enable lower
several distinct features: they need to latency connectivity and improved
operate globally, support long device life, emergency response times.
integrate with local intelligent transport
solutions and comply with local security, Spectrum in the 3.4–3.8 GHz range should
data protection, privacy and emergency not be set aside for safety-based vehicle-to-
regulations. Policymakers and regulators vehicle communications, as this spectrum is
Mobile initiatives
must appreciate and understand these critical for future commercial 5G services in
differences if they are to implement many countries. This highlights the need
policies that allow global business models for regulators to work with the mobile
to develop, and to ensure that rules industry to support connected vehicles
apply consistently to all players in the in future spectrum planning. For example,
value chain. it is essential that sufficient spectrum
below 6 GHz is made available as this
As more cars become connected, spectrum spectrum travels farther and is better
policy related to intelligent transport systems suited to the wide-area connectivity
will become increasingly important. In many required by connected cars.
countries, regulators have set aside a portion
of spectrum for ITS, typically in the 5.9 GHz
band. This generally includes a dedicated
portion for safety-related communications
between vehicles, infrastructure and people.
Consumer protection
37
Privacy and data protection for IoT
Background
The IoT offers significant opportunities appliance may use data about a person’s
and potential for data-driven innovation eating or exercise habits to draw inferences
to achieve economic, social and public about their health, or develop a profile
policy objectives and improve our daily based on their shopping habits to offer
lives. It enables new apps and services them personalised discounts.
that can empower consumers to monitor
their health, manage their energy These types of IoT services and devices could
consumption and benefit from smart have an impact on people’s privacy and may
home and city solutions. This can lead to be subject to general data protection and
many positive outcomes, such as lower privacy laws. Where IoT services are provided
pollution levels and healthier lifestyles. by mobile operators, they will also be subject
to telecommunications-specific privacy and
Many IoT services will be designed to create, security rules. Nevertheless, as consumer IoT
collect or share data, some of which will not services gain in popularity, more consumer
be considered personal, such as data about data will be created, analysed in real time
the physical state of machines or weather and shared between multiple parties across
conditions. However, some IoT services national borders. Therefore, companies
aimed at consumers are likely to involve throughout the IoT ecosystem have a
generating, distributing and using detailed responsibility to ensure personal privacy
personal data. For example, a smart home is respected and to build consumer trust.
Resources:
GSMA Report: The Impact of the Internet of Things

GSMA Report: Safety, Privacy and Security Across the Mobile Ecosystem
GSMA Report: Privacy Design Guidelines for Mobile Application Development
GSMA News: U.S. Senate Subcommittee: Respect for Privacy Vital for Growth of the IoT
38
#BetterFuture
To realise the opportunities that IoT offers, Most importantly, protections should
it is important for consumers to trust the be practical, proportionate and designed
companies that are delivering IoT services into IoT services (“Privacy by Design”)
and collecting the data generated by them. to encourage business practices that

The mobile industry’s view is that consumer provide transparency, choice and control
confidence and trust can only be fully for individuals.
achieved when users feel their privacy is
appropriately respected and protected. IoT services are typically global in nature
and a mobile operator is often only one of
There are already well-established data many parties in a delivery chain that may
protection and privacy laws around the include a host of others, such as device
world. Where these data protection manufacturers, search engines, online
regulations and principles exist, they can platforms and even the public sector.
Mobile initiatives
also be applied to address privacy needs Therefore, it is key that privacy and data
in the context of IoT services and protection regulations apply consistently
technologies. It is vital that governments across all IoT providers in a service- and
apply these frameworks in ways that technology-neutral manner. This will help
promote self-regulation and encourage ensure a level playing field for all industry
the adoption of risk management-based players so they can focus on building trust
approaches to privacy and data protection. and confidence for end users.
Consumer protection
39
Smart cities and IoT
Background
The world’s population is increasingly and the IoT to solve many of the challenges
concentrated in cities, with more than half cities face today. For example, smart city
now living in urban areas, according to data technology can tackle traffic congestion,
from the World Health Organization (WHO). improve public transport infrastructure,
This trend is set to continue, as the WHO create safer streets with better lighting
forecasts that the global urban population and add intelligence to utilities infrastructure
will grow approximately 1.63 per cent per year via smart meters and smart grid solutions.
between 2020 and 2025, and 1.44 per cent It also opens new commercial and investment
per year between 2025 and 2030. This will opportunities for cities.
put additional stress on city infrastructure
and services through increased congestion, Mobile operators are at the heart of this
pollution and higher costs of living. The change, offering solutions based on mobile
infrastructure of today’s cities is typically IoT networks designed specifically to
not designed to deal with increasingly dense meet these goals. By supporting low-cost,
populations, which makes it very difficult for connected devices with long battery life
cities in most parts of the world to cope. that can be rolled out on a massive scale,
mobile operators can serve the next
National and local governments are generation of cities with solutions that
increasingly interested in “smart cities” and make it easier to add connectivity and
using mobile communications technology control to critical infrastructure.
Resources:
GSMA Smart Cities Website

GSMA Report: Maximising the Smart Cities Opportunity: Recom
GSMA Report: Keys to the Smart City
GSMA Video Case Study: Smart City Tainan
40
#BetterFuture
Policymakers and regulators seeking to foster » Comply with best practices in privacy
an environment that encourages investment in and security rather than defining new
smart cities should: service-specific rules. To safeguard privacy
and security, smart cities need to draw on

» Adopt an agile institutional framework industry best practice and comply with
and governance mechanisms. A smart national laws. Local city managers should
city needs an institutional framework resist the temptation to define their own
that ensures coordination and support data privacy and security standards for
throughout the life of a project. The the services they launch and adopt.
smart city agency will need to be agile
and, ideally, independent from traditional » Make city data available to promote
city departments. It should, however, transparency and stimulate innovation.
be accountable to a governance body While protecting individual privacy, city
Mobile initiatives
represented by city institutions. managers should seek to make data
accessible to promote transparency
» Appoint a chief information officer (CIO) and stimulate the creation of innovative
or smart city director with a strategic services. Some cities already have
vision. A strong vision and strategy are key portals that make data available in
to the success of smart city projects. A CIO accessible formats.
or smart city director should be a project
leader with cross-functional skills and » Explore new funding models.
capable of defining a long-term strategy. Smart city projects require significant
initial investment. Smart city managers
» Communicate the objectives and should explore public-private partnerships
benefits of smart city projects effectively. or alternative finance mechanisms, such
Establishing dialogue with the local as municipal bonds, development banks
community is essential to the design or vendor finance. IoT technologies and
and functionality of smart city services. smart city apps can generate substantial
Digital media can help to involve citizens socio-economic benefits for citizens and
at each step and highlight the tangible businesses. Policymakers should make
benefits a smart city project will deliver. the most of this opportunity by designing
and implementing smart city projects
» Promote technological investment in with a long-term vision defined around
open and scalable systems. A smart citizens’ needs, and which are managed
city should avoid relying on proprietary through agile governance structures,
technologies tied to a single provider. based on open and scalable systems
Standards-based solutions are essential and promote a culture of openness,
to the long-term evolution of a smart city. innovation and transparency.
Consumer protection
41
Identity
Introduction
Digital content, services and interactions standardisation bodies, such as the Open
have become a part of daily life for billions ID Foundation, to ensure support and
of people, driven by growing access to interoperability for global standards.
broadband and increasingly affordable
mobile devices. The use of data and user Together, mobile operators are bringing
authentication are requisite elements of mobile identity solutions to market that
being online, making it increasingly important can reach tremendous scale. By using
that users have a digital identity to securely consistent, easy-to-access technologies
authenticate themselves and carry out across the digital identity ecosystem,
tasks, such as accessing their accounts and these solutions can provide a consumer
subscriptions or making purchases. experience that is scalable, safe and
secure, and puts users in control of their
The digital economy is predicated on data and personal information.
trust, and interactions, whether social,
commercial, financial or intellectual, require There are many advantages to mobile
a proportionate level of trust in the other operators providing a digital identity service:
party or parties involved. Today, consumers
are seeking easy access to digital services
that also protect their privacy. Online service
providers must therefore reduce friction
in digital transactions while maintaining
a seamless and secure user experience.
Increasingly, governments are regulating and
demanding that digital identity solutions use
global standards to ensure interoperability,
privacy, scale and cost-effectiveness.
To this end, the mobile industry is

developing a consistent and standardised
set of services for managing digital identity.
The unique advantages of mobile operators,
such as SIM cards, registration processes,
contextual network information and fraud
mitigation processes, give them the ability
to provide strong customer authentication
and interoperable, federated identity
management solutions to enable consumers,
businesses and governments to interact
in a private and secure environment.
The GSMA is working with mobile operators,

other mobile ecosystem players, as well
as governments, banks and retailers, to
help roll out mobile identity solutions.
The GSMA is also working with industry
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#BetterFuture
» Flexibility to innovate: flexibility to provide » Robust regulatory requirements:
multiple authentication factors and the established systems to handle
ability to add consumer functionality, such personal data safely.
as “add to bill” or “click to call”.

» Customer service: sophisticated
» The mobile device: ubiquitous, personal customer care processes and billing
and portable; sensitive to location; and relationships.
capable of being disabled and locked.
» The network: secure by design, a
» The SIM card: strong, real-time mobile network can disable a device’s
authentication; encryption for SIM card and flag the device as lost
storing certificates; and other or stolen in a global database.
secure information.
Mobile initiatives
» Business processes: ensures that the
» KYC standards: strong registration and user has a way to report events, such
fraud detection processes. as lost/stolen devices or an account
compromise/takeover.
» Verified subscriber data: ready-for-mobile
identity.
Consumer protection
43
Mobile Connect
Background
Mobile Connect is a secure digital identity » Privacy protection: the operator confirms
framework developed by the GSMA in the user’s credentials and the user gives
cooperation with leading mobile operators. consent to share this information.
Simply by matching the user to their
mobile subscription, Mobile Connect To date, 60 mobile operators have deployed
allows them to log in to websites and Mobile Connect in 30 countries, making it
apps quickly without the need to remember available to nearly three billion customers.
passwords and usernames. It is safe and
secure, and no personal information is In keeping with the priorities of many
shared without permission. governments, Mobile Connect solutions
focus on privacy and preserving citizens’
The key benefits of Mobile Connect include: trust. For example, in line with the EU
General Data Protection Regulation (GDPR),
» Ease of use: passwords are not required Mobile Connect adopts the principle of
since the mobile phone itself is used Privacy by Design, as it seeks to ensure
for authentication. that an individual’s identity attributes are
used by digital services in a secure way
» Secure and strong customer that respects and protects their privacy.
authentication: user experience
is improved as there are no passwords
to steal.
» Secure and trustworthy digital

transactions: security and trust are built
into the transaction since it confirms the
user’s location, identity and usage.
Resources:
GSMA Mobile Connect Website

GSMA Identity Website
GSMA Report: Mobile Connect for Cross-Border Digital Services: Lessons Learned from the eIDAS Pilot
Mobile Connect Privacy Principles
GSMA Report: Mobile Connect: Mobile High-Security Authentication
GSMA Report: Mobile Identity: A Regulatory Overview
GSMA, World Bank and SIA White Paper: Digital Identity: Towards Shared Principles for Public
and Private Sector Cooperation
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#BetterFuture
Mobile identity services inevitably involve Governments and regulators should create
multiple devices, platforms and organisations a digital identity plan that acknowledges the
that are subject to different technical, central role of mobile in the digital identity
privacy and security standards. Increasingly, ecosystem. The mobile industry is committed

governments are using mobile technology to to working with governments and other
deliver identity services in their digital plans, stakeholders to establish trust, security and
thereby accelerating inclusion and closing the convenience in the digital economy.
digital divide. However, for mobile identity
solutions such as Mobile Connect to achieve The mobile industry has a proven track
widespread adoption and have the greatest record of delivering secure networks and
impact on the economy, several public policy developing enhanced security mechanisms
issues must be addressed: to meet the needs of other industry and
market sectors. The implementation and
Mobile initiatives
» Identifying and assessing existing legal, evolution of these security mechanisms is a
regulatory and policy challenges and continuous process. The mobile industry is
barriers that affect the development of not complacent when it comes to security
mobile identity services. issues, and the GSMA works closely with
the standards development community to
» Applying best practices and advances enhance the security features used to protect
in technology to foster the deployment mobile networks and their customers.
of widescale mobile identity services
and transactions. Via Mobile Connect, the mobile industry
offers an identity and authentication
» Engaging with mobile operators and experience that is aligned with best
the wider digital identity ecosystem to practice in the private sector, but uses
facilitate greater collaboration between mobile technology to leapfrog legacy
the public and private sectors and infrastructure and economic barriers to
encourage interoperability and innovation. deliver secure digital transactions.
Consumer protection
45
AI for Impact Climate Action
Mobile big data analytics and artificial The mobile industry recognises the urgency
intelligence (AI) are emerging as powerful of tackling the global climate crisis, which
forces for change in business and society, is why we are taking action to mitigate our
and the potential of these technologies to impacts and combat climate change as part
unlock life-changing benefits is only beginning of the solution.
to be seen. When grounded in ethical
principles that protect privacy, these solutions The COVID-19 pandemic has shown us how
can truly change the world for the better. vital digital infrastructure and connectivity
has become to working, socialising, accessing
The mobile industry is harnessing big data to medical care, learning and many other
work with governments and global agencies aspects of our lives. The mobile sector
to tackle some of the greatest challenges stands ready to help societies transition to
of our time: humanitarian crises, infectious lower carbon ways of living and a net-zero
disease, natural disasters and climate change. carbon economy. This requires not only a
Protecting privacy is at the core of big data common vision, but also an understanding
developments, and the mobile industry is of diverse markets and the steps needed
committed to the responsible use of data to create the investment incentives,
and protection of privacy. By aggregating infrastructure and policy frameworks to
and anonymising the data collected by their create a net-zero carbon economy.
networks, mobile operators can provide
insights into human movement patterns In 2019, the GSMA, with the support of our
without compromising individuals’ privacy. board members, launched an industry-wide
When this data is enriched with third-party Climate Action initiative and made a milestone
data sources, it can enable the public sector commitment: to transform the mobile industry
to make evidence-based decisions on when, to reach net-zero carbon emissions by 2050,
where and how to deploy resources. at the latest. Progress is being made:
Resources:
GSMA AI Ethics Principles

The GSMA COVID-19 Privacy Guidelines
GSMA AI for Impact Toolkit
GSMA Report: GSMA Climate Policy
GSMA Report: Mobile Net Zero: State of the Industry on Climate Action 2021
GSMA Report: The Enablement Effect
GSMA Climate Action Website
COP26 – Climate Hub
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#BetterFuture
» The mobile sector has worked The GSMA is providing support and guidance
collaboratively to create an industry-wide for mobile operators to commit to and set
climate action roadmap to achieve net-zero targets aligned with the net-zero pathway.
greenhouse gas (GHG) emissions by 2050, While the mobile industry is taking major
in line with the Paris Agreement. steps to reduce emissions, it is having an
even greater impact by supporting other

» Eighty per cent of the global mobile sectors to reduce their emissions through
industry by revenue is now disclosing efficiencies created by smart-connected
their climate impacts, energy and M2M technologies and behaviour change.
GHG emissions via the internationally Research conducted by the GSMA with the
recognised CDP global disclosure system. Carbon Trust in 2019 found that while the
mobile industry is currently responsible for
» Sixty-five per cent of the global mobile around 0.4 per cent of carbon emissions
industry by revenue has committed to globally, it enables carbon reductions in
science-based targets to cut their carbon other sectors that are 10 times greater,
Mobile initiatives
emissions rapidly over the next decade. equivalent to approximately four per cent
of global emissions.
» The mobile sector has been recognised
by the UN Race to Zero as a breakthrough
industry.
Consumer protection
47
Business
environment
Introduction
All over the world, mobile operators are

providing the essential connectivity that
people and businesses expect. In recent
years, the industry has adapted to major
changes brought about by the convergence
of technologies and services, and by the
emergence of internet platforms and services.
Telecommunications markets have expanded
and competition has increased as a result.
In most countries, however, mobile operators

are still subject to regulations designed for the
voice era. These rules and obligations restrict
their ability to innovate, invest and compete
on equal terms in the digital ecosystem.
Policymakers should strive to create an

enabling business environment that fosters
competition and protects consumers without
impeding commercial activity or economic
progress. This will require a fresh look at
regulations and revisions that better reflect
today’s technologies and markets.
The following pages cover several policy

topics affecting mobile operators, laying
out the key points of debate and formally
agreed industry positions. As the mobile
industry continues to roll out 4G networks
and initiate 5G trials, the need for
pro-investment policies and modern
regulatory regimes has never been greater.
48
49
Policies for progress
Resetting policy and regulation

to drive the digital economy
Digital technologies have fundamentally become distorted in ways that harm

changed our daily lives, from shopping competition, slow innovation and,
and entertainment to managing household ultimately, deprive consumers of the
finances. When given the opportunity, benefits of technological progress.
consumers have been quick to embrace
digital tools. Many governments, recognising Figure 1 identifies four areas of policy action
the value of mobile to society, have related to network investment, regulation,
implemented bold policies to cultivate promoting the digital economy and
the digital economy while extending demonstrating digital leadership.2
connectivity to underserved communities.
Emerging technologies are driving new
A holistic policy framework that reflects the business models and blurring boundaries
changing digital landscape, while reducing between once-distinct markets. Yet,
costs and barriers to network deployment, regulatory systems developed during the
will deliver the best social and economic early years of mobile telecoms are still in
outcomes. If regulatory policies and place in many countries, and reforms have
institutions fail to adapt, markets can not kept pace with the converging and
Figure 1 Policy levers to promote an inclusive digital economy
Encourage network Modernise

investment regulation
Implement a broadband policy Adopt functionality-based,

with clear goals technology-neutral regulation
Favour ex-post approaches over

Support infrastructure deployment
ex-ante prescriptive regulation
Focus on spectrum allocation and use, Apply regulations consistently across

not auction revenues the digital ecosystem
2. GSMA. (February 2017). Embracing the Digital Revolution: Policies for Building the Digital Economy
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#BetterFuture
dynamic digital ecosystem. Tomorrow’s
technologies cannot be allowed to be stifled
by yesterday’s regulations, which need to be

reframed for the digital and mobile age.
The good news is that policymakers
recognise the need for change. In many
jurisdictions, such as the European Union,
reforms are underway that will protect
competition and consumers without
impeding social and economic progress.
By updating the regulatory framework,
policymakers can ensure that government
Mobile initiatives
and industry are aligned and working to
foster an inclusive digital society for all.
Promote the digital Demonstrate digital

economy leadership
Support data security and privacy Encourage the use of digital IDs
Push digital literacy and lifelong

Support digital financial infrastructure
learning
Encourage the digitalisation of

Introduce digital government services
companies
Consumer protection
51
Community networks
Background
Community networks are a “do-it-yourself” simplified infrastructure, renewable energy,

approach to connectivity: local, community- a variety of backhaul methods (including
owned (or community-managed) networks an ISP or Wi-Fi backbone, VSAT and
that address specific local connectivity WiMAX) and open connectivity standards.
needs. They are usually established in Community networks often use Wi-Fi
areas that are not commercially viable for technology in unlicensed spectrum,
mobile operators to cover and typically although very few countries have assigned
operate on a small scale, addressing spectrum specifically for their operation.
discrete market failures. They can therefore
be effective complements to connectivity Community networks are generally funded
efforts led by mobile operators. through mechanisms such as crowdfunding,
local financial contributions, the donation
Community networks have been made of connectivity expertise and equipment
possible by advances in technology that and sometimes customer usage fees.
have reduced barriers to network deployment Since they offer a specific solution to often
and management and enabled non-operators unique geographical, commercial and
to build and deploy mobile and internet logistical connectivity challenges, they
connectivity solutions. Largely technology- are often context-specific and difficult to
neutral, these solutions are tailored to the scale. Only a few community networks
needs of the community or local setting, have established a lasting and financially
and can include the use of modular and sustainable business model.
Debate:
» What role can community networks play in a national connectivity approach?
» How can mobile operators leverage community networks to support their
rural connectivity strategies?
» How should community networks be supported and regulated to ensure
high-quality, local connectivity while maintaining a level playing field with
mobile operators?
Resources:
The Internet Society: Community Networks

WNDW Report: Wireless Networking in the Developing World
52
#BetterFuture
Industry position
Community networks can complement Where Wi-Fi cannot provide a suitable

the efforts of mobile operators to expand solution, voluntary spectrum sharing can be
coverage since they are an opportunity an interesting opportunity to open access
to deliver the transformative benefits to new spectrum for community networks.

of connectivity to locations that are not However, careful planning is required, and
commercially viable. By doing so, they it is essential that the chosen approach
can drive ICT usage, increase digital skills, protects the needs of incumbents, supports
support local business development and the needs of new users and does not limit
increase uptake of digitally delivered public the evolution of the spectrum band.
services within the communities they serve.
Voluntary spectrum trading through
Community networks have limitations, secondary market transactions should be
however. They typically do not have the considered to enable spectrum access for
Mobile initiatives
resources or expertise to sustain investment community networks. Countries should
in new innovations or address cybersecurity have a regulatory framework that allows
risks as effectively as scaled commercial mobile operators to engage in voluntary
networks. Regulatory uncertainty or spectrum trading.
constraints can also limit the potential
of community networks and hamper the Spectrum that is set aside for community
roll-out of larger-scale commercial networks in mobile bands may be underused.
connectivity networks. As a result, it may not just waste a valuable
resource, but also threaten the success
A level playing field is essential, and of commercial networks through reduced
regulation should empower both coverage, slower roll outs and worse
community networks and mobile operators performance.
to drive connectivity and accelerate digital
inclusion. The regulation and policies applied
to community networks should not impair or
discourage the deployment of larger-scale

commercial network operations and put
mobile operators at a disadvantage.
Consumer protection
53
Competition
Background
Mobile phones are the most widely adopted law are applied to the sector. For example,
consumer technology in history. In large part, a regulator’s jurisdiction may be limited to
this success is due to competition in the the telecommunications sector and not
mobile industry that has driven innovation. extend to internet players. As a result,
regulators often fail to take wider market
The rise of the digital economy and explosive dynamics into account during the evaluation
growth in smartphone adoption have brought and decision-making process. Equally, a failure
innovation and disruption to traditional mobile to understand the complex value chain can
communications services. These changes affect how competition law is applied.
are also having an impact on existing policy
frameworks and challenging competition Current competition policy is also being
policy, which includes government policy, challenged by the competitive advantage
competition law and economic regulation. conferred on some companies through
their ability to collect and analyse large
Despite the influence of new market troves of data. Combined with powerful
dynamics on the mobile sector, the industry network effects and the tendency for
is still subject to the contradictions of a legacy markets to tip in favour of dominant
regulatory system. This has put services in platforms, this can harm consumers,
competition with each other, such as voice hinder competition and stifle innovation.
services offered by mobile operators and
internet players that are regulated differently. The ability of competition policy and
enforcement to deal with issues arising in digital
These differences can be seen in how markets is, therefore, key to the competitive
economic regulation and competition development of the entire digital economy.
Debate:
» How should markets be defined in the digital age?
» How can traditional competition tools be applied in the digital age?
» Are significant market power (SMP) access remedies still appropriate?
Resources:
GSMA Competition Policy Website

GSMA Handbook: Competition Policy in the Digital Age
GSMA Report: The Data Value Chain
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#BetterFuture
Industry position
The mobile industry supports competition Including these new types of competitors
as the best way to deliver economic in market assessment reviews could
growth, investment and innovation for reveal there is much more competition in
the benefit of consumers. Excessive communications services than regulatory

regulation stifles innovation, raises costs, and competition authorities currently
limits investment and harms consumer recognise. It could also demonstrate the
welfare through the inefficient allocation potential for regulatory policy goals to
of resources, particularly spectrum. be achieved through competition law.
A basic principle of economic regulation
To ensure that competition and innovation is that regulation should not be imposed
thrive, it is essential that policymakers if competition law is sufficient to deal with
create a level playing field across the the issues identified. Therefore, regulation
digital ecosystem. All competitors providing of licensed providers could be lessened or
Mobile initiatives
the same services should be subject to the may no longer be needed. Competition law
same regulatory obligations, or absence of itself could also be improved and updated
obligations. This should be achieved through to tackle the issues arising in digital markets
a combination of deregulation and increased more effectively.
use of horizontal legislation to replace
industry-, technology- or service-specific rules.
Regulators and competition authorities must
recognise the dynamic nature of competition
in the digital age. Internet players adopt
new and different business models to offer
services to customers, such as advertising-
supported services that rely on sophisticated
web analytics. Regulators and competition
authorities need to understand these models
and map their competitive impact before

imposing regulatory obligations or competition
law commitments. Otherwise, services that
are in competition with each other may end
up being regulated differently. For example,
players that adopt traditional business
models that are better understood may
find themselves subject to greater scrutiny.
Consumer protection
55
Deeper dive: Competition in digital markets
The global economy is undergoing a is changing the nature of products and services
major transformation. The rapid uptake and how people interact. This transformation
of technologies, including mobile disrupts existing business models and industries
communications, digital platforms, big while also offering significant potential to enrich
data, cloud computing and social media, lives and raise living standards.
Figure 2 Characteristics of the digital economy
Dynamic Network effects

Multi-sided
waves of investment, and economies of
markets and
innovation and scale for digital
platforms
technology services
Quality Big data Broader markets

more important to as a key and blurring of
consumers than price ompetitive factor
c traditional boundaries
Competition in digital markets has certain » Multi-sided markets and platforms with
features that distinguish it from competition distinct groups of users benefitting from
in traditional markets, including: the presence of the other; and
» Waves of investment and innovation and » Large-scale data gathering and analysis
rapid technological progress; with the potential for anti-competitive
effects, especially where it contributes
» Quality and product features that are often to service quality.
more important to consumers than price;
These differences in the digital ecosystem
» Winner-takes-all outcomes where new challenge existing policies and demand
entrants offering innovative products an update of the competition framework
or services may be able to leapfrog and a more nuanced approach to
established firms; competition policy.
» Economies of scale and strong network

effects in the supply of digital services;
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#BetterFuture
Deeper dive: Recommendations for resetting
competition policy frameworks

The GSMA advocates that governments remain relevant and can address issues of
adopt the following recommendations to abuse of market power and market failures
ensure their competition policy frameworks in the digital economy.
Figure 3 Resetting competition policy frameworks: recommendations

Market definition The total welfare Ex-ante andex-post
and market power standard regulation
» Adjust existing tools to account for » Adapt to a total welfare » Review the thresholds for
specific features of digital markets. standard to support ex-ante regulation to ensure
long-term productivity balance between regulation
growth and higher living and investment risks.
Mobile initiatives
standards.
» Focus on actual substitution patterns.
» Focus on dynamic
» Use alternative tools to capture the
effects when
main determinants of consumers’
assessing mergers » Focus ex-ante
switching behaviour.
and competition regulation on
in digital markets. enduring market
power.
» Ensure market definition is sufficiently

forward looking, and revise and adapt
policies to fully capture changes in the » Ensure regulation is
relevant market. » Use better tools to streamlined and consistent
assess efficiencies. with competition law.
» Focus on alleged anti-competitive

conduct and its likely effects rather
than inferring market power from
market structure.
Institutional arrangements
» Assess the extent to which big data » Adopt interim measures to accelerate ex-post enforcement
confers market power. and mitigate potential harm from anti-competitive conduct.
» Maintain a high threshold for intervention

based on collective dominance. » Reassess institutional arrangements.
Consumer protection
57
Efficient mobile market structures
Background
From the outset, mobile markets have ensure the right economic conditions
been characterised by a vibrant, are in place to support investments.
competitive market structure that In particular, they must recognise the
drives investment and innovation. competitive nature of today’s mobile
markets, avoid regulating prices and
Today, demand for robust, high-speed, steer clear of interventions aimed
high-quality mobile broadband continues at engineering market structures.
to grow. This drives mobile operators to Instead, they should allow market
make large, regular investments in network mechanisms to determine the optimal
infrastructure and services to provide mobile market structure.
consumers with improved offerings at lower
costs. For example, while operators continue Some regulators have used spectrum
to invest in their 4G networks, they are caps – limits on the amount of spectrum
also starting to invest in the spectrum and one entity can hold – to influence market
technology required to roll out 5G networks. structure. However, spectrum caps can
have unintended consequences, including
The high level of competition in the mobile inefficient allocations of spectrum
services market has caused the tariffs and/or reduced incentives to invest.
charged to mobile users to fall steadily Since this ultimately produces poor
and significantly over the past few years. outcomes for consumers, they must
At the same time, consumption of mobile be considered carefully.
services, particularly mobile data, has
grown steadily, with users typically At the same time, competition authorities
getting more for their money. tasked with assessing the impact of
proposed mobile mergers must take full
To preserve competition, foster innovation account of the dynamic efficiencies (and
and support the wider societal benefits of accompanying societal benefits) arising
mobile connectivity, policymakers must from mobile mergers.
Resources:
GSMA Report: Assessing the Case for In-country Mobile Consolidation

GSMA Report: Assessing the Case for In-country Mobile Consolidation in Emerging Markets
GSMA Report: Assessing the Impact of Mobile Consolidation on Innovation and Quality
GSMA Report: Assessing the Impact of Market Structure on Innovation and Quality in Central America
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#BetterFuture
Industry position
When assessing mobile mergers, Unit prices. There is no robust evidence

policymakers should consider the full range to suggest that four-player markets have
of benefits of mergers, including price produced lower prices than three-player
effects, innovation, investments and the use markets in the past decade, in Europe or

of spectrum over the short- and longer term. elsewhere. Mergers can accelerate the
transition between technology cycles in
Investment and quality of service. the mobile industry (which are responsible
Competition authorities should consider for significant reductions in unit prices),
placing greater emphasis on how mergers leading to improvements in quality and
may affect an operator’s ability to invest. innovation in services. As the market moves
Growing demand for data services requiring from voice to data, the global volume growth
ever-increasing bandwidth necessitates rate of mobile networks is accelerating.
continuous investment in new capacity This requires more concentrated market
Mobile initiatives
and technology. structures to meet the investment challenge,
drive mobile data unit prices down and
Positive spill-over effects in the wider fuel demand for mobile data services.
economy. Improvements to digital
infrastructure support economic growth by Effects of remedies on investments and
increasing productivity across the economy. use of spectrum. Mergers that compel
mobile operators to provide third parties
Greater benefits than network sharing. with access to their networks could reduce
Competition authorities have often argued incentives to invest and significantly diminish
that network sharing is a better alternative benefits for consumers. In three cases where
to mergers. While the pro-competitive the European Commission’s Directorate-
nature of network-sharing agreements can General for Competition made a network
only be assessed on a case-by-case basis, entry option available (Ireland, Germany
these agreements are not always feasible and Austria), nobody took the option, even
between merging parties because of an though it was arguably offered on favourable
asymmetry of assets (such as spectrum terms. Remedies that involve reallocating

holding) or different deployment strategies. network assets or reserving spectrum for
other operators could, in some cases, deter
investment and lead to the underuse or
misuse of resources.
Consumer protection
Debate:
» Can mergers between mobile operators bring significant consumer benefits in
mobile markets and wider society?
59
Deeper dive: The dynamic benefits of mergers
Recently, there has been heated debate respectively, and 3G download speeds
about the effects of consolidation on the increasing by 1.5 Mbps after 2014.
performance of mobile markets following
mergers in key European markets, including Since 2015, at least seven other studies4
Austria, Germany, Ireland and the UK. have examined the relationship between
While some argue that consolidation market structure, innovation and investment,
has a detrimental effect on competition as measured by mobile operators’ capital
and prices, others argue that, without expenditure (CapEx). None found that
consolidation, mobile markets will not greater market concentration resulted
achieve the necessary scale and fail to in lower investment per operator or lower
attract sufficient investment. total country investment.
In the past three years, multiple studies have Meanwhile, initial studies have found that
analysed how mergers affect investment. investment always increases with market
For example, a 2017 GSMA3 report analysed concentration, suggesting that the Hutchison/
the impact of the Hutchison/Orange merger Orange merger would have had a positive
in Austria in 2012 on coverage and quality effect on Austrian consumers.
of service. It was found that, within two
years, Hutchison expanded population CERRE (2015) found that, on average, a 10
coverage of its 4G network by 20 to per cent increase in the Herfindahl-Hirschman
30 percentage points as a result of the Index boosts the CapEx of mobile operators
merger. 4G download and upload speeds that have merged by 24 per cent. In 2016,
also increased by 7 Mbps and 3 Mbps, Houngbonon & Jeanjean and found that
respectively, within the same period. The markets with four players average 14 per cent
quality of mobile networks in Austria lower investment per operator than markets
improved overall, with 4G download and with three players, and that a higher number
upload speeds increasing by more than of operators tends to decrease investment.
13 Mbps and 4 Mbps in 2013 and 2014, DG Competition (2017) found that investment
3. GSMA. (2017). Assessing the Impact of Mobile Consolidation on Innovation and Quality:
An Evaluation of the Hutchison/Orange Merger in Austria.
4. CERRE (2015), Frontier (2015), Houngbonon and Jeanjean (2015), Houngbonon and Jeanjean (2016), HSBC
(2015), WIK (2015) and DG Competition (2017).
5. Although WIK (2015) found that market structures that provide higher profit margins and greater
economies of scale (both enhanced by market consolidation) boost total CapEx per country.
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#BetterFuture
per operator increased as a result of the
five-to-four merger in the UK in 2010,
although no statistically significant effect
was found when analysing investment
per subscriber.

A second set of studies (Houngbonon and
Jeanjean, 2016, and HSBC, 2015) suggests that
greater market concentration increases CapEx
per operator only when their profit margins
are less than 37 to 44 per cent. Operators
in most four-player markets are below this
threshold, including the Austrian operators
before the merger. These studies suggest
Mobile initiatives
that the introduction of competition initially
has a positive effect on investment, but that
as mobile markets become less concentrated
it has a negative effect. Other studies have
found that investment does not depend on
market structure (WIK, 2015 and Frontier,
2015), suggesting that a mobile merger would
have a neutral effect on outcomes such as
network quality and coverage.5
While many believe that consolidation is

likely to lead to less investment by operators,
there was evidence that concentration leads
to increased investment after a merger.
This is because larger operators enjoy
economies of scale that enable them to

extend coverage and undertake network
upgrades. They are also financially stronger
due to higher profit margins and better access
to complementary assets and commercial
partnerships, which can lead them to expect
higher returns from their investments.
Consumer protection
61
Infrastructure sharing
Background Industry position
Common in many countries, infrastructure Governments should have a regulatory

sharing can provide additional capacity in framework that allows voluntary
congested areas where space for sites and infrastructure sharing among
towers is limited and help to expand coverage mobile operators.
in underserved geographical areas.
While it may, at times, be advantageous
Infrastructure-sharing arrangements allow for mobile operators to share infrastructure,
mobile operators to jointly use masts, network deployment remains an important
buildings and even antennas, avoiding competitive advantage in mobile markets.
unnecessary duplication of infrastructure. Any sharing should therefore be the result
Infrastructure sharing has the potential of commercial negotiation, not mandated or
to strengthen competition and reduce subject to additional regulatory constraints
the carbon footprint of mobile networks or fees.
while also reducing costs for operators.
National regulatory frameworks should
As with spectrum trading arrangements, facilitate all types of infrastructure-sharing
mobile infrastructure sharing has arrangements. This can include sharing
traditionally involved voluntary various components of mobile networks,
cooperation between licensed operators including so-called passive and active
based on their commercial needs. sharing. In some cases, site sharing
(a type of passive sharing) increases
competition by giving operators access
to sites necessary to compete on quality
of service and coverage.
Infrastructure-sharing agreements
should be governed by commercial
law and, as such, subject to assessment
under general competition law.
Access to government-owned trunk

assets should be available on non-
discriminatory commercial terms at
a reasonable market rate.
Resources:
GSMA Report: Unlocking Rural Coverage: Enablers for Commercially Sustainable Mobile Network Expansion
ITU Mobile Infrastructure Sharing Website
ZDNet Article: Learning to Share: Could Tower-Sharing be the Solution to Rural Networks’ Problems?
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#BetterFuture
Mobile initiatives
Consumer protection
Debate:
» Should regulators oversee, approve or manage infrastructure-sharing arrangements?
» What role should governments play in the development and management of
core infrastructure?
63
Deeper dive: Types of infrastructure sharing
Infrastructure sharing can be passive or In active sharing, operators may share the
active. Passive sharing includes site sharing, radio access network (RAN) or the core
when operators use the same physical network. RAN sharing may create operational
components but have different site masts, and architectural challenges. With core
antennas, cabinets and backhaul. A common network sharing, operators also share the
example is shared rooftop installations. core functionality, demanding more effort
Practical challenges include availability and alignment, particularly the compatibility
of space and property rights. A second of the operators’ technology platforms.
type of passive sharing is mast sharing,
when the antennas of different operators Infrastructure sharing optimises the use of
are placed on the same mast or antenna assets, reduces costs and avoids duplication
frame, but the radio transmission equipment of infrastructure (in line with urban and
remains separate. national planning objectives).
Figure 4 Mast sharing Figure 5 Site sharing
Shared compound Shared compound
Antenna A Antenna B Mast A Mast B

Core Network A
Antenna A Antenna B Core Network A
Network A Network B
Network A Network B
BTS/Node B BTS/Node B
BTS/Node B BTS/Node B
Core Network B
Core Network B
Network A Network B Network A Network B

BSC/RNC BSC/RNC BSC/RNC BSC/RNC
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#BetterFuture
It may also: » Reduce the energy and carbon footprint of
mobile networks;
» Reduce site acquisition time;
» Reduce the environmental impact of mobile
» Accelerate the roll-out of coverage into infrastructure on the landscape; and

underserved geographical areas;
» Reduce costs for operators.
» Strengthen competition;
» Reduce the number of antenna sites;
Mobile initiatives
Figure 6 Full RAN sharing Figure 7 Shared core network elements and platforms
Shared compound
Network A
Core Network A
Network A HLR Network A

MSC SG SNGG SN
Access Shared VAS

Network A Platform
Core
Transmission
Access Ring
Network B Shared
OMC
Core Network B
Network B Network B
MSC Network B SG SNGG SN
HLR
Consumer protection
65
Intellectual property rights
Background
The mobile ecosystem has been a major However, in the past few years, there
driver of economic progress and welfare have been radical changes in the licensing
globally. Countries around the world continue of telecommunications technology
to benefit from improvements in productivity (i.e. the prime use of patent portfolios
and efficiency brought about by the uptake in telecommunications). Initially, patents
of mobile products and services. GSMA were used to preserve a company’s
Intelligence predicts mobile will generate “freedom to operate” (i.e. its ability to
five per cent of global GDP by 2022, or bring its products to market by seeking
$4.6 trillion in economic value. large portfolio cross-licences). Increasingly,
patents have become tradeable, income-
Without the immense efforts of the mobile generating assets (via the “secondary
operator community, many of the adopted patent market”) capable of being asserted
technologies in 2G, 3G and 4G would against start-ups, small and large
not have been successfully developed, companies, and, in certain cases,
implemented or adopted on a mass scale. used to stifle competition.
At no point in history has telecommunications

technology had a greater impact on people’s
lives than now. The public has become
heavily reliant on mobile telecommunications
technology and the ability of mobile
operators to deliver such services. Mobile
telecommunications services provided by
the operator community have become
fundamental to everyday existence.
Debate:
» Now that patents have become tradeable and an income-generating asset,
can they still be considered a tool to support and promote innovation?
» Are Patent Assertion Entities (PAEs) having a negative effect on competition?
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#BetterFuture
Industry position
The secondary patent market has greatly business, but also on innovation and
encouraged the rise of non-innovating, standardisation in mobile telecommunications.
non-practicing, patent monetisation and
licensing or enforcement entities, known Increasing PAE litigations and adversarial/

as PAEs. Usually, PAEs are purchasing litigious licensing negotiations highlight
patents (rather than developing and the need for greater clarity on the
licensing technology) to be asserted licensing of standard essential technology.
against manufacturers and operators
already using the technology. These efforts should focus on:
There are several reasons mobile operator » The reliance of the public on mobile
networks have become a premium target telecommunications technology and
for so-called “patent trolls” in Europe, the ability of mobile operators to
Mobile initiatives
America and Asia. These include: deliver such services;
» The complexity of mobile operator » The fact that disruption to these services,
networks; even somewhat, will have a severe negative
effect on people’s lives;
» The scale of investments needed
to build them; » The importance of maintaining the integrity
of mobile telecommunication services
» The level of revenues they generate; and and ensuring continuous investment
and adoption of new technologies in
» The reliance of these networks on the telecommunications market; and
standards-based technology.
» The need to incorporate appropriate
The multiple costs associated with PAE rules and regulations in frameworks
litigation and threats of injunction (as governing the seeking and granting
leverage in demands for disproportionately of injunctions in predatory patent

high licensing fees) have a detrimental assertion cases (to allow the judiciary
effect, not only on a mobile operator’s to consider the above points).
Consumer protection
67
International mobile roaming
Background
International mobile roaming (IMR) allows In the European Union, roaming regulation
people to continue to use their mobile device has been in place since 2007 and, in June
to make and receive voice calls, send text 2017, “roam-like-at-home” was introduced
messages and email and use the internet across the EU, with mobile operators
while abroad. Telecoms regulators and required to include it by default in contracts.
policymakers have raised concerns about Travellers can call, text and surf on their
IMR prices and the lack of price transparency, mobile devices in any EU country for
which can cause bill shock for consumers. no more than what they pay at home.
Operators can implement “fair use”
In December 2012, when the International policies to prevent the abuse of regulated
Telecommunication Union (ITU) was updating roaming services.
the International Telecommunications
Regulations (ITRs), several governments Bill shock and certain high roaming
requested that the revised treaty include prices have also attracted the attention
provisions on transparency and price of international institutions such as the
regulation for mobile roaming. However, Organisation for Economic Co-operation
on balance, ITU Member States concluded and Development (OECD) and the World
that roaming prices should be determined Trade Organization (WTO). Regional and
through competition rather than regulation, bilateral regulatory measures are also
and text was included in the treaty to either in place or being considered in
reflect this approach. many jurisdictions.
Resources:
GSMA Roaming Website

GSMA Information Paper: Overview of International Mobile Roaming
GSMA News: GSMA Launches Data Roaming Transparency Initiative
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#BetterFuture
Industry position
IMR is a valuable service delivered in a Price regulation: Governments and

competitive marketplace. Price regulation regulators should only consider
is not appropriate as the market is price regulation as a last resort after
delivering many new solutions. transparency measures and innovative

IMR pricing have failed to address
The mobile industry advocates a consumer complaints and structural
three-phased strategy to address barriers have been removed. The costs
concerns about mobile roaming prices: and benefits of regulation must be assessed
carefully and consider unique economic
» Transparency: In June 2012, the GSMA factors, such as national variations in
launched the Mobile Data Roaming income, GDP, inflation, exchange rates,
Transparency Scheme, a voluntary mobile penetration rates, the percentage of
commitment by mobile operators to the population that travels internationally
Mobile initiatives
give consumers greater visibility of and the incidence of international travel to
roaming charges and their mobile neighbouring countries, all of which have
data usage when abroad. an impact on IMR prices.
» Removal of structural barriers: The mobile industry is a highly competitive

Governments and regulators should and maturing industry, and one of the most
eliminate structural barriers that dynamic sectors globally. In the past decade,
increase costs and cause price competition between mobile operators has
differences between countries. yielded rapid innovation, lower prices and
These include double taxation, a wide choice of packages and services for
international gateway monopolies consumers. Imposing roaming regulation
and fraud, all of which should be on mobile operators not only reduces
removed before any form of IMR price revenue and increases costs, but also
regulation is considered. deters investment.
Debate:
Consumer protection
» Some policymakers believe IMR prices are too high. Is regulatory intervention
the right way to address this?
» What measures can be taken to address concerns about price transparency,
bill shock and price levels?
» What other factors affecting roaming prices do policymakers need to consider?
69
Mobile termination rates
Background
Mobile termination rates (MTRs) are the fees

charged by mobile operators to connect
a phone call originating from a different
network. Setting regulated MTRs continues
to be a focus of regulators in both high- and
low-income countries, and many different
approaches have been developed to calculate
appropriate termination charges.
Regulators have generally concluded that

the provision of call termination services
on an individual mobile network is, in effect,
a monopoly. Therefore, with each operator
enjoying significant market power, regulators
have developed various regulations, most
notably, the requirement to set cost-oriented
prices for call termination.
Debate:
» How should an appropriate regulated rate for call termination be calculated?
» Is the drive towards ever lower mobile termination rates, especially in Europe,
a productive and appropriate activity for regulators?
» Once termination rates have fallen below a certain threshold, is continued
regulation productive?
» What is the long-term role of regulated termination rates in an all-IP environment?
“Intervening in a competitive market is far more complex and challenging than

the traditional utility regulation of the kind normally applied to monopolies in gas,
electricity and fixed-line telecommunications. With mobile, every action is more finely
calibrated. The benefits of intervention are more ambiguous and the error costs larger.”
– Stewart White, former Group Public Policy Director, Vodafone
Resources:
Vodafone Report: The Impact of Recent Cuts in Mobile Termination Rates Across Europe
GSMA Report: The Setting of Mobile Termination Rates: Best Practice in Cost Modelling
GSMA Report: Comparison of Fixed and Mobile Cost Structures
70
#BetterFuture
Industry position
MTRs are wholesale rates, regulated in
Regulated mobile termination rates many countries, where a schedule of
should accurately reflect the costs annual rate changes has been established
of providing termination services. and factored into mobile operators’
business models. Unsignalled, unanticipated

Evidence suggests that reductions in alterations to these rates have a negative
MTRs are not beneficial after a certain impact on investor confidence.
point. The setting of regulated MTRs
is complex and requires a detailed The GSMA believes the setting of MTRs
cost analysis, as well as careful is best done at a national level where
consideration of its impact on local market differences can be properly
consumer prices and, more broadly, reflected in the cost analysis. Extraterritorial
on competition. intervention is, therefore, not appropriate.
Mobile initiatives
Consumer protection
71
Net neutrality
Background
While there is no single definition of net reliable internet access to their customers,
neutrality, it often refers to issues concerning due to the shared use of network resources
the optimisation of traffic over networks. and limited available spectrum. Unlike fixed
Advocates assert that all traffic carried over broadband networks where a known
a network should be treated equally, number of subscribers share capacity, the
but others contend that offering different capacity demand at any given cell site is
service levels for different applications much more variable, as the number and
enhances the user experience. mix of subscribers constantly changes,
often unpredictably. The available bandwidth
Where this flexibility exists, mobile operators can also fluctuate due to variations in radio
can offer a bespoke, managed service to frequency signal strength and quality, which
providers of new connected products, such can be affected by weather, traffic, speed
as autonomous cars. This could not exist and the presence of interfering devices,
without constant, high-integrity connectivity. such as wireless microphones.
Operators can also enter commercial
arrangements with content and application Not all traffic has equal demands on a
providers that want to attract users by network. Voice traffic is time-sensitive while
offering free access, for example, by zero- video streaming typically requires large
rating their content so mobile subscribers are amounts of bandwidth. Networks need to
not “charged” for data usage. These kinds of be managed in a way that accommodates
arrangements support product and service all types of traffic and supports innovations
innovation, deliver added value to consumers with 5G and IoT. The principle of the open
and generate new revenue for operators, internet and allowing operators to offer their
which face constant pressure to enhance, customers a variety of service options are
extend and upgrade their networks. not mutually exclusive. As the net neutrality
debate has evolved, policymakers have
Mobile operators face unique operational come to accept that network management
and technical challenges in providing fast, plays an important role in service quality.
Resources:
GSMA Net Neutrality Website
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#BetterFuture
Statement
Just as content providers offer differentiated services, such as standard and premium content
for different prices, mobile network operators will offer different bandwidth products to meet
different consumer needs. Customers are benefitting from these tailored solutions; only those
who want to use premium services will have to pay the associated costs.

— GSMA
Industry position
Mobile operators need to be able to Consumers should have the ability to

actively manage network traffic to choose between competing service
meet the different needs of consumers. providers by comparing performance
Mobile initiatives
differences in a transparent way.
It is important to maintain an open internet.
To ensure it remains open and functional, Mobile operators compete in many areas,
mobile operators need the flexibility to including pricing of service packages
differentiate between different types of traffic. and devices, different calling and data
plans, innovative applications and features
Regulation that affects operators’ handling and network quality and coverage.
of mobile traffic is not required. Any The high degree of competition in
regulation that limits their flexibility to the mobile market provides ample
manage quality of service from end to end incentives to ensure customers enjoy
and provide consumers with a satisfactory the benefits of an open internet.
experience is inherently counterproductive.
Regulators should recognise the

differences between fixed and
mobile networks, including technology

differences and the impact of radio
frequency characteristics.
Debate:
Consumer protection
» Should networks be able to manage traffic and prioritise one traffic type or
application over another?
» For mobile networks, which have finite capacity, should fixed-line rules apply?
» In some cases, net neutrality rules are being considered in anticipation of a problem
that has yet to materialise. Is this an appropriate approach to regulation?
73
Deeper dive: Traffic management
Traffic growth, the deployment of next- and business opportunities will emerge.
generation technologies and the emergence
of new types of services are presenting The current competitive market is delivering
mobile operators with a huge challenge: choice, innovation and value for money
how to manage different types of traffic for consumers, which means no further
over a shared network pipe while providing regulatory intervention in the provision of IP-
subscribers with a satisfactory quality of based services is necessary. The commercial,
service that meets different consumer needs operational and technological environment
and service attributes. in which these services are offered is
continuing to develop, and any intervention
The finite capacity of mobile networks is likely to impact the development of these
means they can experience congestion. services in a competitive context.
Mobile operators use traffic management
techniques to efficiently manage network Traffic management techniques are necessary
resources, including spectrum, and to and appropriate in a variety of operational
support multiple users and services on and commercial circumstances:
their networks. Congestion management
is essential to prevent the network from » Network integrity: Protecting the network
failing during traffic peaks and to ensure and customers from external threats, such
access to essential services. as malware and denial-of-service attacks.
Traffic management techniques are applied » Child protection: Applying content filters
at different layers of the network, including that limit access to age-inappropriate
admission control, packet scheduling and content.
load management. In addition, operators need
to cater to different consumer preferences so » Subscription-triggered services: Taking
that customers can access the services they appropriate action when a customer
demand. Traffic management is therefore an exceeds their contractual data usage
efficient and necessary tool for operators to allowance or offering charging models
manage the flow of traffic over their network that allow customers to choose the
and provide fair outcomes for all consumers. service or application they want.
Mobile operators need the flexibility to » Emergency calls: Routing emergency

experiment with and establish new business call services.
models that align investment incentives with
technological and market developments, and » Delivery requirements: Prioritising real-
to create additional value for their customers. time services, such as voice calls, and
As the operational and business models of considering the time sensitivities of
networks evolve, a host of innovative services services, such as remote alarm monitoring.
74
75
Passive infrastructure providers
Background
Many mobile operators share infrastructure Increasingly, independent tower companies

on commercial terms to reduce costs, avoid provide tower-sharing facilities to mobile
unnecessary duplication and expand coverage operators. Several countries have established
cost-effectively in rural areas. The most regulatory frameworks based on registration
commonly shared infrastructure is passive that encourage passive infrastructure-sharing
infrastructure, which may include land, arrangements and provide regulatory clarity
rights of way, ducts, trenches, towers, masts, for network operators and independent
dark fibre and power supplies, all of which passive infrastructure providers. While
support the active network components regulatory authorities in almost all countries
required for signal transmission and reception. support passive infrastructure-sharing
arrangements, there is a lack of regulatory
Infrastructure sharing is arranged through clarity in some countries, particularly in
bilateral agreements between mobile relation to independent tower companies.
operators to share specific towers,
through strategic sharing alliances,
through the formation of joint infrastructure
companies between mobile operators
or via independent companies providing
towers and other passive infrastructure.
Resources:
AT Kearney Report: The Rise of the Tower Business

Reuters News: Bharti Airtel to Sell 3,100 Telecom Towers
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#BetterFuture
Industry position
Licensed network operators should be Registered providers should be permitted

able to share passive infrastructure with to construct and acquire passive
other licensed network operators and infrastructure that is open to sharing
outsource passive infrastructure supply with mobile operators, provide (e.g. sell

to passive infrastructure providers or lease) passive infrastructure elements
without seeking regulatory approval. to licensed operators and supply ancillary
Sharing passive infrastructure on commercial services and facilities essential to the
terms enables operators to reduce capital provision of passive infrastructure.
and operating expenditure without affecting
investment incentives or their ability to Mobile operators should be permitted
differentiate and innovate. to use infrastructure from passive
infrastructure companies through
Infrastructure sharing provides a basis for commercial agreements without explicit
Mobile initiatives
industry to expand coverage cost-effectively regulatory approval. Infrastructure-sharing
and rapidly while retaining competitive agreements should be governed by
incentives. Regulation of passive infrastructure commercial law and, as such, be subject to
sharing should be permissive, but should assessment under general competition law.
not mandate such arrangements.
Public authorities should provide licensed
In markets with licensing frameworks operators and passive infrastructure
that do not already provide for the providers with access to public property
operation of independent tower companies, and rights of way on reasonable terms and
regulatory authorities (or the responsible conditions. Governments, seeking to support
government department) should either national infrastructure development, should
permit independent passive infrastructure ensure swift approval for building passive
companies to operate without sector- infrastructure, and environmental restrictions
specific authorisation or establish a should reflect globally accepted standards.
registration scheme for such companies.
The scheme should be a simple authorisation Taxation and fees imposed on independent
that provides for oversight of planning- tower or passive infrastructure companies
related matters while making a clear should not act as a barrier to the
distinction with the licensing framework development of this industry, which
applicable to electronic communications makes more efficient, lower-cost forms
network and service providers. of infrastructure supply possible.
Debate:
Consumer protection
» What benefits do independent tower companies offer to mobile operators?

» Should passive infrastructure sharing ever be mandated by a regulatory authority?
» What steps should regulators take to provide clarity for tower companies
and mobile operators?
77
Quality of service
Background
The quality of a mobile data service is

characterised by a few important parameters:
speed, packet loss, delay and jitter. It is also
affected by factors such as mobile signal
strength, network load and user device and
application design.
Mobile operators must manage changing

traffic patterns and congestion, as these
normal fluctuations result in customers
experiencing different qualities of service.
Connection throughput is viewed by some

regulatory authorities as an important
attribute of service quality. However, it
is also the most difficult to define and
communicate to mobile service users. Mobile
throughput can vary dramatically over time,
and throughput is not the only product
attribute that influences consumer choice.
Resources:
GSMA Reference Document: Definition of Quality of Service Parameters and their Computation
GSMA Latin America Brochure: The Quality of Mobile Services in Latin America
78
#BetterFuture
Industry position
Competitive markets with minimal The commercial, operational and

regulatory intervention are best able technological environment in which
to deliver the quality of mobile service mobile services are offered is continuing
customers expect. Regulation that to develop. Mobile operators must have

sets a minimum quality of service is the freedom to manage and prioritise
disproportionate and unnecessary. traffic on their networks. Regulation that
rigidly defines a particular service quality
The quality of service experienced by mobile level is unnecessary and likely to affect the
consumers is affected by many factors, development of these services.
some of which are beyond the control
of operators, such as the type of device, Competitive markets with different
application and propagation environment. commercial offerings and information
Defining specific quality targets is neither that allows consumers to make informed
Mobile initiatives
proportionate nor practical. choices deliver the best outcomes.
If regulatory authorities are concerned
Mobile networks are technically different about quality of service, they should
from fixed networks since they make use engage in dialogue with the industry to
of shared resources to a greater extent and find solutions that strike the right balance
are more traffic sensitive. on transparency of quality of service.
Mobile operators need to deal with continually
changing traffic patterns and congestion
within a finite network capacity, where one
user’s traffic can have a significant effect on
overall network performance. The evolution of spectrum
Debate:
» Is it necessary for regulators to set specific targets for network quality of service in
competitive markets?
Consumer protection
» Is it possible to guarantee minimum quality levels in mobile networks,

which vary over time according to the volume of traffic being carried and the specific,
local signal-propagation conditions?
» Which regulatory approach will protect the interests of mobile service customers
while not distorting the market?
79
Deeper dive: A network of interconnections
Offering a dependable quality of service is a » The movements and activities of mobile

priority for mobile operators as it allows them users, such as travel, events or accidents;
to differentiate their internet access service
from their competitors and meet customer » Obstacles and distance between the
expectations. However, mobile operators have terminal and antennas; and
little control over many of the parameters that
can affect their subscribers’ experience. » The weather, especially rain.
Factors beyond an operator’s control include: In addition, the quality of internet access
that users experience depends on the
» The type of device and application being quality provided by each of the data
used; paths followed. The internet service
provider (ISP) only has control over
» The changing usage patterns in a mobile the quality of service in their section
network cell at different times of day; of the network.
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#BetterFuture
Figure 8 Factors affecting quality of service
Mobile
device
Environmental factors

Physical obstacles
User location and movement
Weather
Mobile initiatives
y
ne
ur
Traffic spikes
jo
a
at
D
Mobile device type
Mobile network
Internet
Content
source
For these reasons, regulation on the workings of these services can

quality of mobile internet service can be be an obstacle to their development,
counterproductive. Regulation that does widening the digital divide and
not consider the nature of mobile promoting inefficient use of the
networks and the competitive capital invested in networks.
Consumer protection
81
Single wholesale networks
Background
Policymakers in some countries are In 2000, there were almost as many

considering establishing single wholesale countries served by a single mobile network
networks (SWNs) or wholesale open as there were countries served by multiple
access networks (WOAN) instead of competing networks. Today, however, only
relying on competing mobile networks about 30 markets are served by a single
to deliver mobile broadband services. mobile network.6 Many are small islands with
Most of these proposals specify at populations in the thousands and, in total,
least partial network ownership and represent less than two per cent of the world’s
financing by the government. population. During the same period, network
competition has produced unprecedented
While there are variations in the SWN growth and innovation in mobile services,
proposals discussed by different particularly in developing countries. The
governments, SWNs can generally be number of unique mobile subscribers has
defined as government-initiated network now surpassed five billion.7 This success has
monopolies that compel mobile operators fuelled innovation and helped increase speeds,
and others to rely on wholesale services improved network coverage and cut costs.
provided by the SWN to serve and compete
for retail customers. Supporters of SWNs argue they can address
some concerns better than the traditional
SWNs would represent a radical departure model of network competition in some
from the approach to mobile service markets. These concerns generally include
provision favoured by policymakers over the inadequate or lack of coverage in rural areas,
past 30 years – namely, to license a limited inefficient use of radio spectrum and fears
number of competing mobile operators, that the private sector may lack incentives
which are usually under private ownership. to maximise coverage or investment.
Resources:
GSMA and Frontier Economics Report: Assessing the Case for Single Wholesale Networks in
Mobile Communications
GSMA Report: The Risks Associated with Wholesale Open Access Networks
6. GSMA and Frontier Economics. (2014). Assessing the Case for Single Wholesale Networks in
Mobile Communications.
7. GSMAi
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#BetterFuture
Industry position
SWNs and WOANs are likely to lead to The benefits of network competition go
worse outcomes for consumers than beyond coverage. Innovation is a key driver
network competition. of consumer value at the national level, and
this occurs in networks as well as services

Although some supporters claim they and devices. While mobile technologies are
provide greater network coverage than typically developed at the international level,
network competition, this is often because the speed at which they become available to
there are public subsidies and other forms consumers depends on national policies and
of favourable support for SWNs that are market structures. In practice, government-
not available to competing mobile operators, mandated wholesale networks have been
making it an unfair comparison. Commercial much slower to expand coverage, perform
networks can deliver coverage even in upgrades and embrace new technologies.
areas where duplicate networks are not
Mobile initiatives
economical. This can be achieved in many Rather than use public funds to create a
ways, including through voluntary network separate network to deliver coverage in areas
sharing among operators. where commercial networks have not found it
viable to cover, an alternative approach is to
consider how public funds might be used to
subsidise a commercial network provider to
expand coverage to these areas.
Debate:
Consumer protection
» Are SWNs likely to increase the quality and reach of next-generation mobile
broadband, compared with the existing approach of network competition?
» What alternative policies should be considered before adopting a monopoly
wholesale network model?
83
Deeper dive:
Policies The risks of SWNs
for progress
Governments often have ambitious goals In 2016, the Altán consortium, as the sole
when they mandate the creation of an SWN remaining bidder, was granted access to
or WOAN instead of relying on the market, 90 MHz of valuable spectrum in the 700
especially competing mobile networks, to MHz band to build an LTE-based wholesale
deliver mobile broadband services in their network. In mid-2018, the network had
country. However, research shows that of reached its first coverage target of 32 per
the five countries seriously considering cent of the population.
this option, only Rwanda and Mexico have
rolled out a network (as of mid-2018). However, as with the project in Rwanda,
The lessons from all five countries highlight the cost structure is a major concern. The
the significant challenges associated with government is not receiving any revenue
SWNs and WOANs. from the licence for this valuable spectrum,
and Altán is paying much-reduced annual
For example, the public-private partnership spectrum fees. This is distorting the market
project in Rwanda set ambitious goals, but since existing operators must still pay for their
has encountered several difficulties in meeting spectrum licence and full annual spectrum
them. While an LTE network has been rolled fees while also finding funds to reinvest in
out, connectivity is generally not being their networks.
delivered in areas where operators are not
already providing 3G coverage. The network The Altán consortium has yet to prove their
is also competing directly with existing mobile service is a valuable offering for Mexican
operators rather than selling services to consumers and businesses, as the network
them on a wholesale basis. Pricing remains a is only available in areas that already have
concern because levels are so low that they coverage. Consequently, uptake among the
are undercutting existing mobile operators, large operators, which would help increase
leaving little room for reinvestment. the impact of the project, has been slow. This
makes the goal of reaching 92.2 per cent of
In the other four countries, efforts to roll the population by 2024 look very optimistic.
out networks have either been significantly
delayed or abandoned altogether. In other countries, projects have been
abandoned or made little progress. In
The roll-out in Mexico was marred by Kenya and Russia, the push stalled due
delays and the scope of the project has to complicated negotiations with key
been reduced. In May 2015, the government stakeholders. As of September 2018, a
announced the investment target had Ministerial Policy Directive in South Africa to
been reduced from $10 billion to $7 billion. assign high-demand spectrum to a WOAN
It also estimated that the number of cell and to other electronic communications
towers built for the network will be closer network service licensees simultaneously was
to 12,000 than 20,000. the subject of a public consultation process.
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#BetterFuture
Improving rural coverage is something the » Elimination of sector-specific taxation
mobile industry works on tirelessly. Instead on operators, vendors and consumers;
of going down the wholesale monopoly
route, the GSMA recommends governments » Non-discriminatory access to public
conduct a comprehensive consultation with infrastructure;

all stakeholders to address coverage gaps.
» Support for streamlined planning
While it is often a fiercely competitive and administrative processes;
industry, mobile operators are not shying
away from cooperation to expand coverage. » Relaxation of quality-of-service
The connectivity gap can only be overcome requirements;
through close collaboration between
the telecoms industry and governments. » Context-appropriate competition policy,
The basic building blocks are: especially concerning market structure; and
Mobile initiatives
» Cost-effective access to low-frequency » Support for multisided business models,
spectrum; such as zero-rated and sponsored data.
» Support for flexible spectrum use (e.g.

refarming and technology-neutral licences);
» Support for all forms of voluntary
infrastructure sharing;
» Better use of government Universal

Service Funds (USF)/subsidiaries
to incentivise extended coverage;
Consumer protection
85
Taxation
Background
Industry position
The mobile telecommunications sector has
a positive impact on economic and social Governments should reduce or remove
development, creating jobs, increasing mobile-specific taxes because the
productivity and improving the lives social impact and the long-term
of citizens. positive impact on GDP (and hence
tax revenues) will outweigh any
Sector-specific taxes are levied on mobile short-term reduction in contributions
consumers and operators in many countries. to government budgets.
These include special communication taxes,
such as excise duties on mobile handsets Taxes should align with internationally
and airtime usage, and revenue-share levies recognised principles of effective tax systems.
on mobile operators. These taxes have In particular:
created a tax burden on the mobile sector
that exceeds the burden on other sectors. » Taxes should be broad-based. Different
taxes have different economic properties
Some countries have applied a surcharge and, in general, broad-based consumption
on international inbound call termination taxes are less distortionary than taxes on
(SIIT), which can have the effect of increasing income or profits.
international call prices and acting as a tax
on other countries’ citizens. » Taxes should account for sector and
product externalities.
There is growing consensus around the
world that for tax systems to be effective, » The tax and regulatory system should
they should follow internationally be simple, easily understandable and
recognised best practice principles. enforceable.
Resources:
GSMA Mobile Taxation Research and Resources

GSMA Report: Taxing Mobile Connectivity in Sub-Saharan Africa
86
#BetterFuture
» Dynamic incentives for operators should spending and prevent the positive
not be affected – taxation should not spill overs of mobile throughout the
disincentivise efficient investment or economy, ultimately diminishing social

competition in the information and and economic welfare.
communication technology (ICT) sector.
Emerging economies need to align
» Taxes should be equitable and the their approach to taxing mobile
burden of taxation should not fall broadband with national ICT objectives.
disproportionately on lower income If broadband connectivity is a key social
members of society. and economic objective, taxes must
not create an obstacle to investment
Discriminatory, sector-specific taxes deter in broadband networks or consumer
Mobile initiatives
uptake of mobile services and can slow adoption and use of mobile broadband.
adoption of ICT. Lowering such taxes Lowering the taxation burden on the sector
benefits consumers and businesses and increases mobile uptake and use, creating
boosts socio-economic development. a multiplier effect in the wider economy.
Governments often levy special taxes Taxing international calls has a negative
to finance spending in sectors where impact on consumers, businesses
private investment is lacking. However, and citizens abroad, damaging a
this approach is inefficient. Fiscal country’s competitiveness.
policy that applies a special tax to the
telecommunications sector causes
distortions that discourage private The evolution of spectrum
Consumer protection
Debate:
» Do sector-specific taxes deliver short-term government income at the expense
of longer term additional revenues that could be accrued through increased
economic growth?
87
Deeper dive: Taxes and fees on mobile consumers and operators
Mobile operators have repeatedly raised Research conducted by Deloitte for the
concerns that their customers shoulder GSMA revealed that:
an undue tax burden compared to other
goods and services. The taxation and fees » Mobile operators paid $32 billion in 2015 in
burden on the mobile sector consists of a 27 nations surveyed. Sector-specific taxes
wide range of charges. On the consumer side, accounted for around $8 billion of this total.
this includes taxes on handset purchases Sector-specific excise duties were present
and connection activation, as well as calls, in 81 per cent of surveyed nations, as were
messages and data access. High taxation spectrum fees.
makes mobile services less affordable and
can also have wider negative effects on » A little less than a third (28 per cent) of
productivity and economic growth. operator revenues were spent on taxes,
excluding non-recurring payments, such
In addition to consumer-facing charges, as spectrum auction fees.
mobile operators also face a range of other
charges, including licensing fees, corporation » In eight countries, including Brazil, Chad
tax, revenue charges and many more. Taxes and the Democratic Republic of Congo
and fees that specifically target the mobile (DRC), taxes accounted for 40 per cent
sector affect the willingness of operators or more of sector revenue.
to invest in rolling out networks. The extent
to which these charges fall on operators or Of the countries surveyed, it was only in
consumers depends on individual market South Africa and Italy that the sector’s
conditions. Some taxes may be absorbed by tax contribution as a proportion of the
operators in the form of lower profits while total tax take closely matched its
others may be passed on to consumers as contribution to the entire economy.
higher prices, or a combination of both. In four countries the sector paid more than
double, in three others more than triple and
in three others more than four times.
Taxes and fees on mobile services affect the

affordability of mobile access and usage, and
may have a disproportionate impact on lower
income consumers since mobile services
account for a larger share of the annual
income of poorer households. In the DRC, the
most extreme case, these fees represented
21 per cent of gross national income (GNI) of
the bottom 20 per cent of income earners.
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Eight steps governments can take 5. Eliminating import duties for mobile
to rebalance taxation and promote network equipment and other local
digital inclusion: taxes levied directly on mobile sites
has the potential to boost investment
1. Phased reductions of sector-specific in networks.

taxes and fees can be an effective
way for governments to signal their 6. Governments should avoid
support for boosting connectivity. disproportionate taxation of services
such as mobile money, as it puts a wide
2. To enable more users to afford mobile range of positive externalities at risk.
services, governments should choose
to lower so-called “luxury” taxes on 7. Removal of surtaxes on international
devices and connections. incoming calls can ease barriers to
regional and international trade by
Mobile initiatives
3. Uncertainty over future taxation reduces lowering the cost of international
investment because the risk of tax hikes communication. It can also make it more
is priced into investment decisions. affordable, enabling more consumers to
Governments should seek to limit reap the benefits of mobile services.
unpredictable tax and fee changes and
streamline how taxes and fees are levied. 8. Governments should apply fees on
profits rather than revenues to prevent
4. The spectrum award approach needs to discouraging investment and innovation.
balance the relationship between ex-ante These fees require the same payment
and ex-post fees in a transparent way, from an operator regardless of whether
to ensure operators do not pay twice they retain their profit or use it to invest
for access to the same resource. in new infrastructure and services. The evolution of spectrum
Consumer protection
89
Universal service funds
Universal service, characterised by a USFs should only be considered once

telecommunications service that is all policy and regulatory measures to
available, accessible and affordable, maximise coverage through market-driven
is a policy goal of many governments. mechanisms have been exhausted and
after careful assessment of alternative
Several countries have established universal mechanisms, such as coverage obligations
service funds (USFs) to extend coverage in and reverse spectrum auctions.
areas that are not commercially viable for
the private sector. USFs are typically funded Reducing costs and regulatory
by levies on telecommunications sector barriers is critical to expand the
revenues and the funds are disbursed either reach of mobile connectivity. Importantly,
through direct subsidies or competitive governments can help by removing
bidding. USFs can also provide non-financial sector-specific taxes, stimulating
support to connectivity initiatives. demand and developing infrastructure.
Despite these goals, USFs often perform In markets where they already exist,
poorly, and countries with USFs have typically USFs should be targeted, time-bound
not experienced stronger internet growth.8 and managed transparently.
Studies by the GSMA and the ITU show that Alternative funding mechanisms should
disbursement rates remain very low across the be considered to ensure a broad base
world and that many funds have been unable of stakeholders contribute to USFs, not
to distribute any of the levies collected. just mobile operators. The allocation of
funds, in consultation with the industry,
When not administered effectively, USFs should be competitive, technology-neutral
can be counterproductive. By effectively and target projects with the greatest
taxing communications customers, services possible impact. USFs should adhere
become less affordable. to the following best practices:
Resources:
A4AI Report: Universal Service And Access Funds: An Untapped Resource to Close the
Gender Digital Divide
GSMA Report: Survey of Universal Service Funds, Key Findings
GSMA Connected Society: Are Universal Service Funds an Effective Way to Achieve Universal Access?
GSMA News: Press Release: GSMA, Vodafone and GIFEC Partner to Deliver Connectivity
to Rural Communities
ITU Report: Universal Service Fund and Digital Inclusion for All
UN ESCAP Working Paper: The Impact of Universal Service Funds on Fixed-Broadband Deployment
and Internet Adoption in Asia and the Pacific
8. UN ESCAP. (2017). The Impact of Universal Service Funds on Fixed-Broadband Deployment
and Internet Adoption in Asia and the Pacific.
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#BetterFuture
» Clear targets that ensure effective » Consideration of a pay-or-play model
and timely disbursement of funds; by which mobile operators can choose
to make a financial contribution to the
» Continuous evaluations, annual USF or implement projects that meet

reporting and regular independent the fund’s goals;
audits of government administration to
ensure transparency in fund financing, » Consultation with mobile operators
disbursements and operations; to ensure investments in coverage are
targeted efficiently, include operational
» Solid, clear and transparent underlying expenditure subsidies where necessary and
legal frameworks that support flexible avoid duplication of infrastructure; and
services and technology neutrality;
» If USFs cannot be managed efficiently
Mobile initiatives
» Based on an independent fund structure within a reasonable time frame, a plan
to avoid political interference; should be implemented to phase them out.
» Administered effectively to avoid

excessively bureaucratic structures
or insufficient oversight;
» A thorough analysis of investment
gaps and the impact of introducing
levies on affordability and adoption
to set appropriate USF levies;
Debate:
Consumer protection
» What policies and processes need to be in place to ensure USF financial resources are
transparent and used efficiently?
» What alternative strategies can governments take to enable the private sector to
expand connectivity?
» How relevant are USFs in mature markets?
91
Public-private partnerships
Background
A public-private partnership (PPP) is by the public partner. Large-scale PPPs

a legal arrangement between two or often attract the interest of multilateral
more private and public sector parties to organisations, which recognise the potential
deliver a service via mutual investment. economy-wide benefits of such projects and
PPPs are common in infrastructure sectors are willing to support private companies and
such as telecoms where upfront investments governments that lack the financial means to
are high and payback periods long. get these projects off the ground on their own.9
PPPs can be an interesting mechanism In the telecoms sector, PPPs are found across
to facilitate investment from different all network segments:
stakeholders and support the extension of
network coverage in areas that are otherwise » First mile: submarine cables, satellite hubs,
risky investments with limited commercial Internet Exchange Points (IXPs);
potential. Governments view PPPs as a way
to drive investment in uncovered areas and » Medium mile: fibre backbone and
leverage the expertise of the private sector. backhaul; and
In turn, private companies benefit from the
certainty of a viable business model thanks » Last mile: radio access networks and
to the investment and guarantees provided wired local loops.
Resources:
European Commission Guide: The Broadband State Aid Rules Explained: An eGuide for Decision
Makers: An eGuide for Decision Makers
9. An illustrative example is the ACE submarine cable along the coast of West Africa, one of
the largest PPP investments in the ICT sector. The ACE submarine cable began operating in
2012 and now connects 23 countries to international fibre infrastructure, some for the first
time. It is enabling faster speeds and lower prices for internet access. The World Bank
financed part of the ACE submarine cable. Sources: World Bank. (2018). Private Participation
in Infrastructure Database; World Bank (2018) Implementation Completion and Results Report.
10. “ Todo Chile Communicado” is a typical example of the first case, where a PPP was created
to bring mobile connectivity to 1,474 rural communities in Chile. Source: GSMA. (2016).
Closing the Coverage Gap.
11. The ACE submarine cable is a good example of infrastructure that enabled faster and
cheaper internet connectivity across 22 countries in Africa.
12. European Commission. (2013). The Broadband State Aid Rules Explained.
13. See GSMA. (2016). Unlocking Rural Coverage: Enablers for Commercially Sustainable
Mobile Expansion.
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#BetterFuture
Industry position
PPPs can be an effective way to deploy through market-driven mechanisms.

and operate network infrastructure in areas Creating an investment-friendly policy
that do not have the economic potential framework should be the first step in
to attract private investment. Public and a coverage expansion strategy.13 As a

private resources may support network second step, governments should
deployment to deliver communications consider giving mobile operators the
services directly to customers10 or provide same preferential conditions PPPs often
the infrastructure to deploy commercially enjoy, such as subsidies, no-cost access
viable networks.11 to public infrastructure or less stringent
quality-of-service obligations. This may
Governments should only consider PPPs in be sufficient to create a favourable business
the most remote areas. Engaging with mobile case in remote areas.
operators and considering their roll-out plans
Mobile initiatives
is an essential part of the scoping phase,12 as When implementing a PPP, governments
it prevents public investment from being should avoid the single wholesale network
wasted in areas where operators could have approach. SWNs are PPPs that do not
deployed networks on their own. Service observe the best practices outlined above.
delivery and customer engagement should SWNs have a geographic scope that
be left to the private sector, which can overlaps with commercial networks and
provide the full suite of products and monopolises important resources, such
services to support digital inclusion. as spectrum. They create an uneven
playing field, use valuable public resources
Governments should only consider PPPs inefficiently and have multiple implementation
after exhausting all other policy and challenges (see the ‘Single wholesale
regulatory measures to maximise coverage networks’ section for more details). The evolution of spectrum
Debate:
Consumer protection
» Are PPPs an effective way to accelerate the deployment of infrastructure and

drive digital inclusion?
» What alternatives do governments have to use their resources to catalyse investment?
» What are the characteristics of a PPP that maximises positive impacts while
minimising negative consequences?
93
The evolution of
spectrum: to 2030
and beyond
Introduction
To close the connectivity gap, accommodate

growth in data traffic, drive the Internet of
Things and realise the full potential of 5G,
mobile networks must evolve. To support
this evolution, mobile operators need access
to sufficient spectrum in low, mid and
high bands.
Long-term planning and effective spectrum

licensing play vital roles in providing operators
with access to this necessary resource.
To encourage investment in mobile services,
it is important to have transparent, long-
term national broadband plans that include
a strategy for making sufficient spectrum
available to the mobile industry. This creates
certainty and allows the industry to invest,
innovate and thrive.
How spectrum is priced also has a

significant impact. Governments that
seek to maximise state revenues from
spectrum pricing risk deterring investors
and undermining competition in
communications markets. Research shows
that high spectrum prices are linked to
slower network speeds and lower coverage.
The primary goal of pricing mechanisms
should instead be broadband development.
94
95
Spectrum needs
Background
Mobile networks today operate across an in average user data traffic, will be far higher
evolving range of technologies, from 2G to 5G. than previous generations of mobile.
Each of these technologies requires spectrum
relative to the role they play in society. Meeting demand requires spectrum
2G voice applications use small tranches capacity in low, mid and high bands.
of spectrum compared to the much wider Low-band spectrum has the best
channels required for dense, high-throughput propagation, but also the smallest
5G usage. Governments can support mobile capacity, while high-band spectrum has
growth by having a long-term vision of the huge capacity but the signals do not reach
spectrum access mobile operators will receive. as far. Mid-band spectrum balances coverage
and capacity for city-wide coverage.
In some regions, 2G and 3G networks are
starting to be switched off. These technology Although countries in different regions
sunsets allow spectrum to be refarmed for have adopted different combinations
more efficient technologies such as 4G and 5G. of those bands, regional and global
However, the capacity burden on 5G networks, harmonisation have created economies
due to the higher number of devices that of scale that, in turn, have made mobile
will need to be connected and the growth services and handsets more affordable.
Low bands: sub-1 GHz
Low bands support wide-area coverage and improved indoor connectivity across urban,
suburban and rural areas. Increased low-band capacity is required to create greater
equality between urban and rural broadband connectivity and address the digital divide.
Figure 9 Low-band overview
617 652 663 698 791 821 832 862

11 MHz 11 MHz
600 MHz 800 MHz
703 733 758 788 824 849 869 894

25 MHz 25 MHz
700 MHz - Region 1* 850 MHz
703 748 758 803 880 915 925 960

10 MHz 10 MHz
700 MHz - APT 700* 900 MHz
*North America uses a more complex 700 MHz plan
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#BetterFuture
Mid-bands: 1–7 GHz
Mid bands offer a balance of coverage and capacity. Most commercial 5G launches so
far have relied on spectrum within the 3.3–3.8 GHz range. Other bands, which may be
assigned to or refarmed by operators for 5G include 1500 MHz, 1800 MHz, 2.1 GHz, 2.3
GHz and 2.6 GHz. More spectrum will be needed to maintain 5G-quality of service and

meet growing long-term demand (e.g. 3.3–4.2 GHz, 4.8 GHz and 6 GHz).
Figure 10 Mid-band overview
1427 1518 1920 1980 2110 2170

130 MHz
1500 MHz 2.1 GHz
Mobile initiatives
1710 1785 1805 1880 2500 2690
20 MHz TDD
1800 MHz 2.3 GHz
1710 1770 2110 2170 2500 2570 2620 2690

340 MHz TDD
AWS band 2.6 GHz2
1850 1910 1930 1990 3800 4200

20 MHz TDD
1900 MHz 3.5 GHz
High bands (including mmWave)

High-band spectrum, such as mmWave, supports the ultra-high broadband speeds

envisioned for 5G. These bands produce the highest throughput and lowest latency
and include bands such as 26 GHz, 28 GHz and 40 GHz.
Figure 11 High-band overview
24.25 27.5 37 43.5

Consumer protection
TDD TDD
26 GHz 40 GHz
26.5 29.5 66 71
TDD TDD
28 GHz 66 GHz
97
Planning spectrum: 2025–2030
Background
5G will support significantly faster mobile The success of 5G services will depend
broadband speeds and heavier data on national governments and regulators.
usage than previous generations of mobile The speed, reach and quality of services
technology while also enabling the full will require governments and regulators to
potential of the Internet of Things. From support timely access to the right amount and
connected cars and smart cities to the type of spectrum under the right conditions.
industrial internet and fibre-like FWA, 5G
will allow more devices to access more data Mobile operators need clarity on the access
than ever before. The efficiency of 5G will be they will have to spectrum before launching
essential to preserving today’s most popular new technologies, such as 5G, or upgrading
mobile applications, such as on-demand network capacity to support long-term
video, in an environment of high-user demand. investment. Where spectrum shortages exist,
It will help ensure that growing capacity mobile operators will need to create denser
demands can be sustained, but requires networks with more base stations, which will
access to low-, mid- and high-band spectrums. increase broadband costs for consumers as
well as energy consumption.
The following usage scenarios are the four
main pillars of 5G: The roadmap for spectrum access should
be made transparent by governments and
» Enhanced mobile broadband, including regulators to optimise network planning
multigigabit per second (Gbps) data rates. and reduce capital expenditure. By working
together with industry, governments can
» Ultra-reliable low-latency communications, help ensure connectivity is affordable.
including very low latency (sub-1
milliseconds), very high availability
and very high security.
» Massive machine-type communications,

including the ability to support a huge
number of low-cost IoT connections.
» Fixed wireless access, including the

ability to offer fibre-type speeds in
both high-income and low- and
middle-income markets.
Resources:
GSMA Report: Vision 2030: Insight for MId-Band Spectrum Needs

GSMA Public Policy Position: 5G Spectrum
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#BetterFuture
Industry position
5G needs a significant amount of new » Setting spectrum aside for local or

harmonised mobile spectrum. Governments vertical usage in harmonised 5G bands
should carefully consider 5G spectrum could jeopardise the success of public
demands when 5G usage reaches its 5G services and may waste spectrum.

peak, and advanced use cases will require Sharing approaches like leasing are
additional spectrum. typically better options.
The mobile industry believes that: » Governments and regulators should

avoid inflating 5G spectrum prices as this
» Regulators should plan to make, on is linked to slower broadband speeds and
average, 2 GHz of harmonised mid-band worse coverage. Excessive reserve prices,
spectrum available between 2025 and annual fees, limited spectrum supply (e.g.
2030 to support 5G. This includes making through set asides) and poor auction
Mobile initiatives
80–100 MHz of contiguous mid-band design should be avoided.
spectrum per operator available at launch.
Channels of around 1 GHz per operator in » Regulators should carefully consider
millimetre wave bands (i.e. above 24 GHz) 5G backhaul needs, including making
will be required. additional bands available and
supporting wider bandwidths in
» Governments and regulators should existing bands. Measures should
support new harmonised bands globally also be taken to ensure licences are
to help 5G services grow over time (e.g. affordable and designed effectively.
UHF, 3.3–4.2 GHz, 4.8 GHz and 6 GHz).
This includes engaging in the World » Regulators should carefully consider
Radiocommunication Conference (WRC) the right 5G spectrum licence terms,
process to ensure sufficient mid- and conditions and awards approach and
low-band spectrums are available. consult with industry to maximise the
benefits of 5G.
» Exclusively licensed spectrum over wide

geographic areas is vital to the success » Governments need to adopt national
of 5G, although spectrum sharing spectrum policy measures to encourage
and unlicensed spectrum can play a long-term heavy investment in 5G
complementary role. The speed and networks (e.g. long-term licences, clear
quality of 5G relies on guaranteed and transparent renewal processes and
spectrum access. spectrum road maps).
Consumer protection
Debate:
» The GSMA recognises an average total of 2 GHz of mid-band spectrum needs to
be made available to licensed mobile. Regulators need to decide how to meet
this demand for 5G capacity and which harmonised bands can be used.
99
Spectrum harmonisation
Background
Spectrum harmonisation is the uniform for example, agreement was reached on

allocation of radio frequency bands under the creation of three global spectrum bands
common technical and regulatory regimes, for mobile: 700 MHz, 1427–1518 MHz and
across entire regions. Adherence to 3.4–3.6 GHz. In 2019, mmWave bands
internationally identified spectrum bands were discussed and the harmonised use
has many advantages: of 26 GHz, 40 GHz and 66 GHz was agreed.
» Lower costs for consumers, as device However, countries develop their

manufacturers can mass produce devices communications systems at different rates,
that function in multiple countries and and negotiations at the ITU have struggled
realise economies of scale; to keep pace with the needs of the fastest-
moving markets. Over the past 10 years,
» A wider range of devices supported countries have been developing bands for
by a larger international market; mobile use on their own, either regionally
or unilaterally, to meet demand.
» Roaming or the ability to use a mobile
device abroad; and This has been clearest with activity around
the 3.5 GHz range. Only 200 MHz of spectrum
» Fewer cross-border interference issues. in the 3.3–4.2 GHz range was agreed by the
WRC-15 but, even before the 2015 conference,
Harmonised bands for mobile are listed in the demand in some parts of the world had
earlier part of this section. Work towards their already risen well above that figure. Today, as
harmonisation has taken different forms. much as 700 MHz is available in this spectrum
band in some countries, leaving WRCs to tidy
Historically, the first point towards up harmonisation rather than initiate it.
harmonisation was agreement through
the ITU at a World Radiocommunication Spectrum harmonisation through the WRC
Conference (WRC) treaty meeting. Past process remains an important goal and
WRCs were responsible for all the early helps enable lower cost mobile devices
mobile bands, including 900 MHz, 1800 through economies of scale. However, many
MHz and 2.6 GHz. Mobile allocation for a governments and regions, such as the EU
particular frequency band, and additional or ASMG, are charting their own path,
IMT identification, have always been sought making inter-regional harmonisation and
at past WRCs to harmonise mobile use. industry guidance on spectrum use vital
to the spectrum development process.
The WRC process is still a useful way to
support harmonisation. At the WRC in 2015,
Resources:
The GSMA at WRC-23 Website
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#BetterFuture
Industry position
Governments that align national spectrum for spectrum development, they need
use with internationally harmonised band to look at least 10 years ahead. Recent
plans will achieve the greatest benefits for conferences have not managed to do so.
consumers and avoid interference along

their borders. At a minimum, harmonisation of mobile
bands at the regional level is crucial. Even
The mobile industry has had concerns small variations in standard band plans can
about the pace of the WRC process for result in many devices not being usable,
the past 15 years. Rapid growth in consumer with costly consequences for consumers.
demand for mobile has prompted countries
and regions to look beyond WRCs to provide All markets should harmonise regionally
access to new mobile bands. where possible, as this benefits the entire
global mobile ecosystem. Sometimes
Mobile initiatives
Where this has been necessary, multiregional technology advances, such as carrier
harmonisation has been broadly achieved aggregation or dynamic spectrum access,
by loose consensus based on equipment are believed to supersede the need for
availability. However, this approach risks harmonisation. However, these are technical
leaving slower-moving nations without processes, requiring more complex handsets
input into which bands are best used, that need more power. While they are
as equipment will only be developed in a help, they do not replace harmonisation
bands used by early-adopter nations. For as the best means of assuring affordable
WRCs to once again be the starting point communications services.

Consumer protection
Debate:
» What planning tools, forecasts of spectrum needs and technology analysis are
required to support long-term development?
101
Deeper dive: W
orld Radiocommunication
Conference 2023 (WRC-23)
Figure 12 WRC-23 frequencies being considered

Spectrum harmonisation has created
economies of scale for mobile networks
that, in turn, have made mobile services and Band Agenda item
handsets more affordable. Widely harmonised
mobile spectrum is again needed at the next 470–694 MHz 1.5
WRC in 2023 to achieve these goals.
3.3–3.4 GHz 1.2
The 2023 conference will differ from earlier
WRCs in that many of the bands it is likely 3.6–3.8 GHz 1.2, 1.3
to harmonise – 600 MHz, 3.6–3.8 GHz and
4.8 GHz – have already been developed 4.8–4.99 GHz 1.1
for mobile and are in use today. Meanwhile,
development of the 6 GHz range is well 6.425–7.125 GHz 1.2
under development.
10–10.5 GHz 1.2
WRC-23 must therefore ensure that the
harmonisation of these bands is spread as
broadly as possible to achieve the greatest
economies of scale. This will ensure 5G,
and subsequent generations of mobile
networks, meet expectations and deliver
the full range of affordable services.
The work of any WRC is split into

different portions of the agenda,
with different subjects allotted
their own agenda item or workstream.
Mobile spectrum discussions cut across
several agenda items.
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470–694 MHz 4.8–4.99 GHz
As low-band signals propagate, they become The GSMA believes that the 4.8–4.99
more effective at covering wide areas. GHz band provides a good option for
The mobile industry requires additional supplementary mobile spectrum. Following

spectrum below 1 GHz to improve the the implementation of 5G in the 3300–3800
performance of 5G networks in areas MHz range, this band could expand the
where higher frequencies, which have high capacity of future networks and has already
capacity but do not propagate as far, are not been considered through new assignments
affordable to use. These areas include wide in China and Russia, nearby assignments in
rural and some suburban areas where dense Japan, new announcements in the United
networks would be too costly to provide States and the on-going activity of WRC-23.
efficient broadband. Low frequencies also
provide better penetration in buildings. 6.425–7.125 GHz
Mobile initiatives
For countries with large rural populations, The 6 GHz range is a high priority for the
the bands below 1 GHz will improve digital GSMA and our members in all three regions
inclusion and help meet targets for equal supporting 5G in this band. In a recent
digital opportunities, including health care member survey, this band was supported
and education. Additional spectrum for by 90 per cent of GSMA operator members
mobile in the UHF band can thus support globally. The mobile industry believes that
several common policy goals, such as assigning an average of 2 GHz of mid-band
greater digital inclusion, a smaller urban/rural spectrum for 5G will be very difficult in most
digital divide, better access to e-government cases without the use of this band.
and smart health care/education and lower
consumer broadband prices. 10–10.5 GHz
3.3–3.8 GHz The mobile industry believes that 10–10.5

GHz and 10–10.5 MHz would provide
The 3.5 GHz range is the 5G launch band in valuable additional capacity between
most countries and, as such, has the deepest mid-band and mmWave. This spectrum
ecosystem and most affordable devices. is being studied in the Americas as a
3.3–3.4 GHz and 3600–3800 MHz are both potential supplement to mid-band capacity.
being discussed at WRC-23 under Agenda
Item 1.2 and 1.3. These two bands are being
considered on either side of the 3.4–3.6 GHz
band harmonised at WRC-15. Development
of both sub-bands will help support the
mid-band capacity requirements of 5G.
Consumer protection
103
Coexistence of technologies
Background
Each of the WRC agenda items looks at adjacent frequency bands. Detailed technical
the frequency bands developed, or under coordination at the ITU and in standardisation
development, for 5G but also used by other bodies, such as 3GPP, helps advance spectral
services. Part of the work of WRCs is to efficiency and minimise guard bands.
consider the technical characteristics and
sharing conditions to ensure compatibility Each new generation of mobile technology
and that different services can coexist. is more efficient than the last and can use
This may include national guidelines on spectrum to provide greater connectivity,
coexistence or rules for cross-border but additional spectrum needs still exist,
coordination of services. driven by higher demand for connectivity
beyond efficiency gains. 5G also uses
Governments need to ensure compatibility active antenna systems (AAS), which
between a wide range of services. Particularly provide a leap in efficiency with their
in LMICs, consumers use radio equipment precise targeting of connections where
such as satellite dishes for long periods, which the user is located. This enhances
means some less efficient terminals may be compatibility with other services.
in circulation. To mitigate this, adherence to
modern standards for new equipment is vital To maximise efficiency and support optimal
even if older equipment is still in use. coexistence, it is important to look at the
receiver performances of legacy services.
Industry position Older systems, including some satellite
receivers, have historically been linked
The mobile industry benefits from with claims that their susceptibility to
WRC decisions that develop the use interference require huge guard bands
of harmonised bands for mobile and to ensure compatibility between services.
help to mitigate interference between In a modern communications environment,
services using radio spectrum. such guard bands are a barrier to economic
development and should be avoided.
Harmonised use of frequencies is one of the More efficient satellite receivers should
benefits of agreements at the ITU. Defining be used by service providers in this case,
radio transmitter and receiver parameters and filters used where necessary to ensure
helps to ensure compatibility between consumers get the best possible access
radio systems operating in the same or to connectivity.
Debate:
» How can governments ‘future-proof’ systems to ensure all new equipment meets
modern compatibility standards?
104
105
Spectrum licensing
Background
Spectrum licensing is central to the delivery » Provide predictability to support the

of high-quality mobile broadband services new network investment needed; and
and long-term investment in networks.
The amount of spectrum made available » Avoid costly restrictions on the use
and the terms on which it is licensed drive of spectrum beyond those needed
the cost and quality of mobile services. to manage interference.
Mobile is a capital-intensive industry Success depends on tailored approaches

requiring significant investment in that consider specific market circumstances.
infrastructure. Governments’ spectrum The best approach should consider policy
licensing policies, when supported by objectives as well as market conditions.
a stable, predictable and transparent The latter should include current spectrum
regulatory regime, can make markets use, the competitiveness of the market and
dramatically more attractive to investors. the risks to investment and service quality.
Spectrum management for mobile Long-term planning is vital to encourage

telecommunications must include the release investment in mobile services. Success
of new spectrum in harmonised mobile bands, depends on having a transparent, long-term
renewal of licences coming to the end of road map that includes a strategy for
their initial term and the assignment of making sufficient spectrum available to
new bands for mobile broadband services. the mobile industry.
Industry position Licence conditions, other than those relating

to coexistence, should be kept to a minimum
Effective spectrum licensing is critical to or removed entirely. Other objectives,
the future expansion of mobile services. including coverage requirements, can be
Licensing frameworks should encourage addressed effectively through direct policy.
the investments needed to expand mobile
access, meet increased demand and A licence duration of at least 20 years will
enhance the range of services offered. incentivise network investment. A 20-year
or longer licence period offers the certainty
At its core, a licensing framework should: mobile operators need to expand and
upgrade networks. The use of indefinite
» Ensure operators have access to licence terms can make operators even
sufficient spectrum; more willing to invest.
Resources:
GSMA Report: Best Practice in Mobile Spectrum Licensing
106
#BetterFuture
As mentioned previously, spectrum pricing
has a significant impact on investment and
the quality of mobile services. Governments
that seek to maximise state revenues from

spectrum pricing, for example, risk deterring
investors from upgrading their networks.
Research also shows strong links between
high spectrum prices, slower network speeds
and lower coverage.
Mobile initiatives
Consumer protection
Debate:
» Spectrum licensing is the heart of mobile services. What measures can policy-
makers implement to guarantee long-term investment and certainty?
107
Spectrum licence renewal
Managing spectrum renewals effectively The right approach to licence renewals

is a vital part of any country’s spectrum is an important part of a successful
management strategy. The prospect spectrum management strategy.
of licences expiring creates significant Uncertainty over future rights to
uncertainty for mobile operators. spectrum use may lead operators
A transparent, predictable and coherent to cease investment in their networks
approach to renewal is therefore important and compete less to grow their customer
as it enables operators to make rational, base until issues are resolved.
long-term investment decisions.
The presumption of licence renewal and
There is no standard approach to renewing clear and timely renewal decisions are
or relicensing spectrum, but a presumption crucial to mobile network development,
of renewal is generally widely suitable. as they provide mobile operators the
Each market needs to be considered certainty they need to make large,
independently, with industry stakeholders long-term investments in their network
involved at all stages of the decision and mobile services. A decision not to
process. Failure to effectively manage automatically renew a licence should
the process can delay investment in only be made in circumstances where
new services, potentially affecting the benefits of reassigning spectrum
mobile services for millions of consumers. would outweigh the costs.
Resources:
GSMA Report: Spectrum Leasing in the 5G Era
108
#BetterFuture
Recommendations on licensing and
renewal approaches:
» Where spectrum is to be assigned for

the first time, there is no single best
licensing approach and authorities

should make their decision based on
the specific market context.
» When selecting an assignment approach,

licensing authorities should prioritise
efficient spectrum use and network
investment while also ensuring
effective competition.
Mobile initiatives
» Whether an auction or administrative
assignment is adopted, the details of the
implementation should be transparent
and provide certainty for the future.
» The decision to not automatically renew

a spectrum licence should only be made
when there are clear potential benefits
from reassigning spectrum. This includes
more efficient spectrum use or longer
competition time that are likely to outweigh
the costs (e.g. disruption to services and
customers, the risk of deterring investment
and customer service degradation and any
required network reconfigurations).
» Licensing authorities should work in close

partnership with stakeholders to enable a
timely, fair and successful licensing process.
Consumer protection
Debate:
» There is growing competition for access to spectrum. How can regulators balance
the need for clarity on renewals with the spectrum needs of new stakeholders?
109
Spectrum sharing, leasing and trading
Ever-increasing data traffic means mobile Spectrum sharing reduces the spectrum
services must have access to ever-increasing shortages faced by some mobile operators
spectrum to meet demand. This creates the while also ensuring valuable spectrum
need for better spectrum management, to does not lie fallow. It enables more
improve the efficiency of spectrum use and intensive spectrum use and higher
ensure its viable use in less economically volumes of services, improves service
viable areas. Also, completely clearing new quality and lowers the costs of service
frequency bands for future mobile use has provision. All this supports greater
become increasingly difficult. capacity and more affordable services.
At the same time, there is a growing thirst for Spectrum leasing and trading enable the
spectrum from new parties, such as industry parties with the best information on the
verticals. Where regulations permit their use, value of spectrum to determine its price.
and if implemented correctly, tools such as To justify the sale, a buyer or lessee needs
spectrum sharing, trading and leasing can to create more value from the acquired
help make spectrum use more efficient. spectrum than the seller.
Voluntary leasing and trading also reduce

risks for operators since they can sell or
lease unused spectrum while having the
opportunity to acquire new capacity as
they grow. The ability to trade and lease
licences can ensure that spectrum is
used efficiently without additional charges
needing to be imposed by government.
Trading is more likely when there is

substantial available spectrum, when
future spectrum and the regulatory
framework are predictable and when
there is a need to support network
deployment by the lessee, such as
for verticals.
Resources:
GSMA Public Policy Position: Spectrum Sharing

GSMA Report: Spectrum Leasing in the 5G Era
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#BetterFuture
Recommendations on spectrum
sharing, leasing and trading:
» Licensing authorities should allow voluntary proposals for sharing, leasing and trading
spectrum sharing, leasing and trading subject to consultation and consider risks
among operators and facilitate these to competition or of interference.

mechanisms through clearly defined
spectrum rights, long licence terms » Transparent and well-timed licence renewal
and limited administrative costs. processes, and information on spectrum
availability, pricing and conditions, will
» Authorities should only be notified of facilitate sharing, leasing and trading.
the agreements taking place so that
it is clear who holds spectrum usage » Competition issues should be
rights. Notification enables authorities assessed based on the specific
to assess whether a proposed trade circumstances of each sharing,
Mobile initiatives
would create any risks to competition. leasing and trading agreement.
» Before a formal spectrum secondary » Long licence terms allow the buyer or
market framework is established, lessee of the rights to invest in using
authorities should be prepared to assess the spectrum.
Debate:
Consumer protection
» Spectrum sharing can make spectrum use more efficient and create more value for
consumers, but complex frameworks may hamper uptake. How can governments
create a simple sharing framework that still ensures the robust and transparent
definition of rights?
111
Technology neutrality
Background
Where technology neutrality is written Allowing technology-neutral spectrum

into the terms of licences, operators can licences is now regarded as best practice
upgrade their technology (e.g. from 2G all over the world. Countries that were
to 4G) in a particular frequency band to among the first to implement them have
meet market demand. been rewarded with better coverage
and higher mobile broadband speeds.
Restricting technology and service use For example, Finland was the first to
exacerbates spectrum scarcity and prevents allow the 900 MHz band to be technology-
customers from gaining access to new and neutral, which meant mobile users
better services. Removing technology-specific benefitted from far greater geographical
restrictions (beyond those needed to manage 3G coverage than other European
coexistence) enables a market to maximise countries. In Asia, technology-neutrality
the benefits of its spectrum resources on in Singapore has created one of the
an on-going basis. The ability of operators world’s most advanced mobile markets.
to introduce new, more spectrally efficient
mobile technologies is critical to meeting
growth in demand.
Resources:
GSMA Blog: The Benefits of Technology Neutral Spectrum Licences
112
#BetterFuture
Industry position
Governments should allow operators to additional revenue when including

deploy any mobile technology that can technology-neutrality in licences have
technically coexist within the international backfired and held back the introduction
band plan. of new mobile technologies.

Technology neutrality encourages While renewal processes provide an
innovation and promotes competition. opportunity to reissue spectrum licences
This allows markets to determine which as neutral, regulators should not delay the
technologies succeed and ultimately introduction while waiting for the expiry
benefits consumers and society. dates of existing licences. However,
when assigning new spectrum, regulators
Experience from technology-neutral should do so in a technology-neutral
spectrum licensing has raised certain manner and not restrict the introduction
Mobile initiatives
issues. In general, attempts to extract of next-generation technologies, such as 5G.
Debate:
Consumer protection
» New spectrum bands are needed to make the most of 5G, but reusing existing
bands will also be possible. What are the best ways for regulators to apply
technology neutrality and allow mobile operators to make the best use of
existing bands for 5G?
113
Spectrum assignment
Background Administrative assignments
Governments need to manage the renewal of Administrative assignments must be well

licences approaching the end of their initial planned to succeed. The selection criteria
term and release spectrum in both new and and process must be clear and the weight
existing bands for mobile broadband services. given to each objective should reflect its
At the same time, they should encourage importance to society. The use of subjective
important processes such as refarming. criteria, or a lack of transparency, increase
the risk of favouritism and corruption, as
Effective management of these processes well as the potential for the outcome to
is vital to encourage continued investment be challenged in the courts. It may be
and development in the mobile sector. necessary to make a trade-off between
policy objectives and the licence fee.
Auctions are widely considered the most Even where the objective is clear, estimating
effective means of ensuring spectrum is held the appropriate price can be challenging.
by those who can make the best use of it.
Administrative assignments (e.g. “beauty A particular problem of administrative
contests”) are also sometimes used when assignment is the risk that successful
licensing the rights to use a particular applicants will not fulfil their offers,
spectrum band. Sometimes, a hybrid particularly if market or technology
approach may also be used, where a forecasts prove inaccurate. Licensing
shortlist of bidders is selected before an authorities should set out in advance
auction based on administrative criteria. what penalties will be imposed if
commitments are not met.
Auctions work best when there is excess
demand for the spectrum and they help to
select the operators most likely to put it to the
best use and benefit society. Administrative
assignments, on the other hand, may be
suitable where there is less demand and may
allow authorities to compare the range of
policy objectives offered by the candidates.
Whichever approach is chosen, it must

be implemented with care. This includes
identifying issues through public consultation
and weighing the trade-offs in specific design
choices (noting the importance of efficient
spectrum use and safeguarding competition).
Sufficient time and transparency must be
provided to allow potential candidates to
make informed decisions.
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Spectrum assignment
Auctions
Auctions are an efficient way to allocate Auctions can lead to more efficient spectrum
spectrum when there is competition for use, but auction design and rules are
scarce spectrum and demand is expected important. Certain design choices raise
to exceed supply. However, to succeed, the risk of spectrum not being sold or
they need to be carefully planned. limiting network investments. For regulators,
Excessively high reserve prices may the main challenge is balancing the
result in spectrum going unsold. objectives of efficient spectrum
assignment and supporting competition
There are several different auction designs in communications markets. Again,
to choose between, each with its strengths seeking to maximise auction revenues
and limitations. While multiround auctions can have significant costs for society,
are often preferred, the best choice depends especially the digital economy, if competition
on market conditions and the objectives in communications markets is undermined
of the government and regulators. The and network investment is limited.
most common are simple clock auctions,
simultaneous multiple-round ascending Low participation should also be a concern,
auctions (SMRAs), sealed bids, combinatory especially in mature mobile markets. A wide
clock auctions (CCAs) or hybrid approaches. variety of tools are available for regulators
to address these issues, including the choice
» When assigning spectrum via an auction, of auction format, determination of spectrum
government objectives include: lots, spectrum caps and set-asides, bid
information disclosure and reserve prices.
» Maximum long-term value to the However, these tools are often conflicting,
economy and society; and their effectiveness will depend on local
market conditions.
» Efficient technical implementation
of services;
» Sufficient investment to roll out

networks and new services;
» Revenue generation for the government;
» Adequate market competition; and
» A fair and transparent allocation

process.
Resources:
GSMA Report: Best Practice in Mobile Spectrum Licensing

GSMA Public Policy Position: Auction Best Practice
116
#BetterFuture
Industry position
Efficient allocation of spectrum is necessary » Auctions can produce important social

to realise the full economic and societal benefits if they are properly designed;
value of mobile.
» High spectrum prices jeopardise the

Spectrum auctions must be designed to effective delivery of mobile services;
reflect market conditions and achieve
the government’s stated objectives. » Spectrum licences should be technology-
The choice of auction format (e.g. and service-neutral;
simultaneous auctions where multiple
bands are auctioned together or sequential » Licence conditions should be used
auctions where bands are auctioned one with caution;
after the other), like other decisions in the
spectrum assignment process, depends on » Licence duration should be at least 20
Mobile initiatives
specific market conditions. Having a clear years to incentivise network investment;
spectrum road map with well-defined rights
and conditions understood in advance is key. » Competition can be supported by licensing
as much spectrum as possible and limiting
Regulators should work with stakeholders to charges and other barriers to services; and
ensure the auction design is fair, transparent
and appropriate for the market. Auctions » Voluntary spectrum trading should be
should also be designed to maximise the encouraged to promote efficient
long-term economic and social benefits of spectrum use.
spectrum. The following key principles can
help guide licensing authorities:
Consumer protection
Debate:
» Auction design is a delicate balancing act, but there is little doubt that policy
decisions have an impact on the quality of mobile services. How should
governments decide which spectrum assignment method to use?
117
Spectrum pricing
Background
High spectrum prices are associated with The cause of extreme prices are typically
more expensive, lower quality mobile policy factors that prioritise maximising short-
broadband services. They can lead to term state revenues over long-term support
irrecoverable losses in consumer welfare for the digital economy. Examples include:
worth billions of dollars worldwide.
Research shows that when prices are » Setting excessive reserve prices;
too high, mobile operators are likely
to invest less in their networks which, » Making insufficient spectrum available
in turn, affects the quality and reach for auction; and
of their services.
» A lack of clarity on future spectrum
High spectrum prices are particularly harmful releases or the process for renewing
in LMICs where the cost of mobile ownership expiring licences.
accounts for a higher percentage of income
than in high-income countries. In some cases, Such factors can create uncertainty and
affordability has become a major roadblock encourage bidding far above operators’
to widespread mobile penetration. true valuations of the licences on offer.
Resources:
GSMA Website: Effective spectrum pricing helps boost mobile services
118
#BetterFuture
Industry position
Spectrum is a valuable asset, but a

long-term vision is needed to maximise » License spectrum as soon as it is
its value. The primary goal in all awards needed to avoid artificial scarcity;
should be to encourage the most efficient

use of spectrum through investment » Avoid measures that increase risks
in widespread, high-quality networks. for mobile operators and force them
Many countries around the world have to overbid for spectrum; and
successfully struck the right balance
between increasing revenues and » Publish long-term spectrum award
delivering efficient spectrum awards. plans that prioritise societal benefits
over state revenues.
To do this, the GSMA recommends that
governments and regulators:
Mobile initiatives
» Set modest reserve prices and annual fees
and rely on the market to set prices;
Debate:
Consumer protection
» More and more telecom regulators are recognising the negative impact of
high spectrum prices, but getting governments onboard is not always easy.
How can regulators and mobile operators work together to highlight the
benefits of affordable spectrum to all necessary levels of government?
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Spectrum for industries
Background
The development of new mobile technologies Vertical industry needs are often met
alongside the cloud, big data and machine through partnerships with telecoms
learning is transforming how vertical industries providers, including public mobile
can use connectivity. Verticals are companies, operators, using licensed spectrum.
industries and public sector organisations This allows them to benefit from the
operating in a specific sector. While they telecoms providers’ extensive networks,
have traditionally deployed private networks substantial spectrum assets, expertise
to support their connectivity needs, this is and, typically, lower cost base. However,
changing as their requirements have evolved some verticals may continue to operate
to include more advanced capabilities. private networks and thus may want
access to additional spectrum to support
The new technologies range from creating advanced broadband capabilities.
smart utility grids and automating
manufacturing, to delivering goods by drones This is a challenge for policymakers as
and supporting advanced public safety and widespread demand for additional
transport networks. Policymakers play a spectrum outweighs supply. It is also
vital role by managing the spectrum that difficult given that some verticals may
underpins these developments. However, want direct access to spectrum in priority
great care needs to be taken to ensure 4G and 5G mobile bands (e.g. 700 MHz
verticals are fully supported without harming and 3.5 GHz) so they can benefit from
other wireless users, especially the consumers the mobile equipment ecosystem and
and businesses that rely on 4G and 5G. lower their deployment costs.
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#BetterFuture
Spectrum for drones
Unmanned Aerial Vehicles (UAVs), Mobile services in licensed bands are well
or drones, have the potential to deliver established and can be used to support
profound socio-economic benefits. UAV connectivity where permitted by
These range from transforming how regulators. Mobile operators typically have

businesses deliver their products exclusive access to coverage spectrum
to supporting life-saving services to reliably cover very wide areas and
such as drug delivery in remote areas. capacity spectrum that supports faster
However, this is all contingent on data speeds. Taken together, this means
effective UAV authentication, operators can support safe, reliable,
monitoring and connectivity. wide-area broadband connectivity for UAVs.
These benefits can only be realised if Regulators should also adopt a service- and
regulators remove barriers to using technology-neutral framework to fully support
Mobile initiatives
mobile networks to support UAVs, UAVs. This will facilitate the development
most notably those associated with and growth of UAV connectivity. Spectrum
the use of licensed mobile spectrum. licences that are technology specific may
Licensed mobile spectrum enables limit the ability to provide high-speed data
widespread, high-quality connectivity connectivity for UAVs (e.g. 3G or 4G) or new
for UAVs with sufficient capacity to IoT-specific cellular technologies that could
support competitive services and rising provide simple narrow-band authentication
usage levels. and identification (e.g. NB-IoT or LTE-M).

Consumer protection
121
Spectrum for IoT
The Internet of Things (IoT) is an enormously As a result, licensed mobile IoT may be
important and rapidly growing market the only choice for services that require
with the potential to transform the digital concrete assurance levels, such as security
economy. Mobile services play an important and medical applications.
role in the wide-area IoT market and are
evolving to meet an array of requirements. The viability of mobile IoT is contingent
For example, the key markets for mobile on governments adopting a positive
IoT solutions include the utility, medical, regulatory and spectrum framework.
automotive and retail sectors. This is in This must not impose service or
addition to current consumer electronics technological restrictions that hold
devices, including e-book readers, GPS back innovation. Instead, it should
navigation aids and digital cameras. be designed to nurture evolution in
the capabilities of mobile networks
According to data from GSMA Intelligence, and allow the market to decide which
the total number of IoT connections is solutions will thrive.
predicted to grow from just over nine billion
(9.1 billion) in 2018 to 25.2 billion by 2025, International spectrum harmonisation
with the total IoT revenue opportunity is vital for the development of a global,
worth $1.1 trillion by 2025. affordable mobile IoT market. It enables
the development of mass-market,
The requirements of wide-area IoT services low-cost mobile IoT devices through
vary much more than those for traditional the creation of an addressable market
mobile services. This has meant that mobile that is large enough to support manufacturing
technology standards are being continuously economies of scale.
updated to support these use cases, which is
driving innovation and ensuring that mobile Harmonised mobile spectrum is needed
IoT is well placed to compete effectively with to support all wide-area IoT use cases,
other IoT solutions. including coverage bands for Low-Power
Wide-Area (LPWA) use cases and capacity
Licensed spectrum is vital to deliver the bands for high-bandwidth applications
most reliable IoT services and has a like video streaming.
unique ability to support quality of service
guarantees over wide areas. Networks Regulators should work with the mobile
using licensed spectrum are not at risk industry to support IoT in 5G spectrum
of interference and operators can control planning, as 5G is expected to play an
usage levels on their networks. important role in the evolution of mobile IoT.
Resources:
GSMA Public Policy Position: Mobile Networks for Industry Verticals: Spectrum Best Practice
GSMA Public Policy Position: Mobile spectrum for Unmanned Aerial Vehicles
GSMA Public Policy Position: Internet of Things
122
#BetterFuture
Industry position
Policymakers should ensure that verticals can Spectrum leasing or, when carefully
get the connectivity they need to support planned, other types of spectrum
their use cases without undermining other sharing can be viable options for
spectrum users while also upholding fair and supporting verticals that want to

efficient assignment of mobile bands. build private networks.
A core concern is the use of dedicated set- » Spectrum that is set aside exclusively
asides for verticals since these pose significant for verticals in core mobile bands risks
risks to wider mobile services, most notably being underused and can undermine
slower 5G networks and reduced coverage. fair spectrum awards.
There are other options to support verticals
and other ways to provide access to spectrum » Spectrum that is set aside for mobile
for these networks. networks for verticals in core mobile
Mobile initiatives
bands can also threaten the wider success
Spectrum set-asides can lead to insufficient of 5G, including slower roll-outs, worse
spectrum available for mobile operators to performance and reduced coverage.
use and prevent them from meeting all 5G
requirements and capabilities. Scarcity also » Policymakers should consider the
encourages higher prices to be paid for coexistence challenges when different
spectrum, which is strongly linked to less use cases need to be supported in the
network investment, slower roll-outs, limited same mobile band.
coverage and reduced data speeds.
» Unlicensed spectrum is likely to play an
Where industries require access to specific important role for numerous verticals.
licensed bands, they can do so via sharing and
leasing agreements with mobile operators, » Policymakers should carefully consider
for example. their options and consult stakeholders
to ensure they most efficiently support
The mobile industry believes: the needs of verticals without undermining

other spectrum users.
» Commercial mobile operators already
support the needs of a wide variety of
vertical sectors and will have added
capabilities with 5G.
Debate:
Consumer protection
» As governments turn their attention to supporting high-speed network roll-outs,

regulators face the daunting challenge of deciding who gets access to spectrum.
How can governments and regulators develop spectrum policies that support
mobile networks for verticals without negatively affecting commercial 5G services?
123
Wireless backhaul spectrum
Background
The evolution of advanced 4G and the This is in large part due to the flexibility it
emergence of 5G have created challenges for offers, from high-frequency wireless backhaul
mobile backhaul – the connection between bands that support the fastest 5G speeds, to
base stations and the mobile core. 4G and lower microwave frequencies that support
5G access networks rely on high-quality long-link distances for rural base stations.
backhaul networks. Therefore, backhaul
must evolve to support significantly higher Terrestrial wireless backhaul continues
data speeds, greater resiliency and a wider to evolve with new, extremely wide
variety of network deployments, as well as frequency bands, which will be essential
extend coverage further into rural areas. for the fastest 5G speeds, and by
supporting denser small cell networks
While fibre remains the standard for in urban areas. New technologies can
backhaul due to its significant data capacity, also support significantly more data
wireless backhaul plays a vital role as fibre on a given amount of bandwidth and
is not accessible or affordable at all sites. enable bands to be aggregated to create
Terrestrial wireless backhaul is the most wider bandwidths. Access spectrum is
common backhaul method worldwide and also sometimes used for backhaul in certain
will continue to be for the foreseeable future. situations, known as ‘in-band backhaul’.
Resources:
GSMA Backhaul Position Paper
124
#BetterFuture
Industry position Recommendations:
The combination of new bands and » New backhaul bands are needed to
technologies can have a major impact support evolving network requirements and
on the performance of mobile networks increasing traffic (E, V, W and D bands).
and the kinds of services they can enable.

Governments and national regulators » Current backhaul bands will still play
have a role in opening new terrestrial an important role, but need support
backhaul bands vital for 5G while also to maintain relevance in the 5G era,
evaluating how existing bands can evolve especially through wider channel sizes.
to be suitable for the 5G era and beyond.
» Regulators need to carefully consider
This includes looking at widening channel the most effective backhaul licensing
sizes for key bands and, importantly, weighing terms approaches, terms and conditions.
the pros and cons of other users gaining
Mobile initiatives
access to backhaul bands. In the near term, » High backhaul spectrum prices are a
the E-band (70–80 GHz) will be important, barrier to the evolution of mobile networks,
especially to support initial 5G growth, improved coverage and more spectrum-
but the W-band (92–114 GHz) and D-band efficient backhaul technologies.
(130–175 GHz) will also be vital to powering
5G networks in years to come. V-band (66–71 » Regulators should, in consultation with
GHz) is also likely to be used for backhaul the industry, ensure the timely availability
and portions will be used for 5G access, as of a sufficient amount of affordable
well. The E-band, D-band and W-band can backhaul spectrum under reasonable
handle 15 to 50 times more traffic than typical licensing approaches, terms and conditions.
popular mid-microwave backhaul bands
(e.g. 14–25 GHz). The evolution of spectrum
Consumer protection
Debate:
» How can governments balance the need for new spectrum for 5G in currently
used wireless backhaul bands and the future wireless backhaul needs of 5G?
125
Consumer
protection
Introduction
As mobile services become more » Defining, sharing and promoting

economically and socially important, global best practice;
particularly the mobile internet, there
is a corresponding need to ensure that » Building and participating in
the more than five billion people currently cross-sector coalitions;
connected via these services can continue
to enjoy them safely and securely. The » Educating consumers and businesses
challenge is providing this protection in the safe use of mobile technologies
while also ensuring users have control and applications; and
over their privacy and personal data.
» Commissioning research that offers
It is therefore essential for the mobile real-world insight and evidence.
industry to deliver safe and secure
technologies, services and apps that The following pages illustrate the work
inspire trust and confidence. At the undertaken by the mobile industry to
same time, consumers need to be ensure consumers are appropriately
educated about potential risks and protected and informed as they enjoy
be aware of the steps they can take the full range of benefits made possible
to avoid those risks. by mobile technology.
The mobile industry takes consumer

protection seriously. The GSMA and
its members play a leading role in
developing and implementing appropriate
safety and security solutions, technical
standards and protocols. They also
work with governments, multilateral
organisations and non-governmental
organisations (NGOs) to address concerns
related to consumer protection by:
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Cybersecurity
Background
The internet and mobile connectivity have The mobile industry has a long history of
become pervasive, making it vital to ensure providing secure products and services
that people can use essential services safely to its customers:15
and securely.
» Protecting network infrastructure
Cyberattacks are not only harmful and and devices
criminal, but also undermine trust in Operators test for vulnerabilities and
digital services. The mobile industry detect and deter malicious attacks on
is continually working to educate current generation and future networks.
consumers while incorporating new The GSMA and its members support
features and enhancing existing security the principles of ‘security-by-design’
capabilities, such as encryption, integrity to be applied across the value chain.
checking and user identity validation, The GSMA plays a central role in
to minimise the potential for fraud, coordinating activity and leads industry-
identity theft and other possible threats. wide initiatives and programmes, such
Governments and policymakers have as the Fraud and Security Group (FASG),
put measures in place to prevent the Security Accreditation Scheme (SAS)
cyberattacks, and national and regional and the Network Equipment Security
strategies have been adopted in many Assurance Scheme (NESAS), which
countries to strengthen resilience, build provides a security assurance framework
capacity and fight cybercrime. to facilitate improvements in security
levels across the mobile industry.16
‘Cybersecurity’ covers several areas,14
but generally refers to the protection » Protecting public safety
of network-related systems and Mobile networks are considered to
devices and the software and data constitute critical national infrastructure
they contain. It typically comprises in many jurisdictions, and the services
the protection of technical infrastructure, they support play a key role in protecting
procedures and workflows, physical the public. Operators have a legal
assets, national security, as well as obligation to assist law enforcement
the confidentiality, integrity and agencies, which they do while
availability (CIA triad) of information. supporting human rights concerns.
Resources:
GSMA IoT Security

GSMA Report: The 5G Era: Age of Boundless Connectivity and Intelligent Automation
GSMA Report: Mobile Telecommunications Security Landscape 2021
GSMA Report: Cybersecurity: A Governance Framework for Mobile Money Providers
GSMA Blog Post: Cybersecurity and Mobile Money: Prioritising Consumer Trust and Awareness
14. ENISA. (2016). Definition of Cybersecurity: Gaps and Overlaps in Standardisation.

15. GSMA. (2017). Safety, Privacy and Security Across the Mobile Ecosystem for All: Key Issues and Policy Implications.
16. Network Equipment Security Assurance Scheme (NESAS).
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» Protecting consumers from fraud Given that cybersecurity risks are dynamic and
Fraudulent attacks take many forms, not confined to national borders, sustained
such as identity theft, financial fraud, international multistakeholder cooperation
phishing, smishing or vishing, where in all areas of security is key to managing

victims are tricked into revealing risks. Robust security measures must also be
sensitive personal information and adopted by the entire digital value chain.
service access credentials. Operators
implement and offer solutions to Mobile operators continue to invest in the
prevent the use of networks to security of their own networks, devices
commit fraud and the use of devices and services, building solutions and capabilities
to harm consumers. to detect and deter malicious attacks. They
are improving preparedness and incidence
» Protecting consumer privacy response and contributing to the development
Mobile initiatives
Information security implies that of globally recognised, industry-led, voluntary
information, including personal data, consensus security standards, assurance
is not accessible or disclosed to programmes and conformity assessment
unauthorised individuals, entities or schemes. They also continue to participate in
processes, and that it is maintained, capacity building, engage with experts in the
complete and available, throughout field of cybersecurity and share best practices
its life. The GSMA has undertaken with other stakeholders.
extensive work on data protection
and data privacy. Governments and law enforcement agencies
should ensure there are appropriate legal
Industry position frameworks, resources and processes in
place to deter, identify, investigate and
Cybersecurity is the shared prosecute criminal behaviour. This requires
responsibility of industry, government global cooperation between governments
and regulators. Every actor in the and the wider ecosystem. Future-proofing
digital value chain, across all sectors across jurisdictions will ensure regulation
of the digital economy, needs to and network security obligations are
ensure the appropriate protection of consistent and clear for all players involved
infrastructure, products and services. in this complex and rapidly evolving area.
Debate:
Consumer protection
» In the context of 5G implementation and the expanding web of IoT devices and
services, how can policymakers ensure that cybersecurity is the responsibility of
everyone in the mobile ecosystem?
» What is needed to facilitate a more holistic response to cybersecurity?
129
Children and mobile technology
Background
Young children and teenagers are enthusiastic » Improved social and civic engagement; and
users of mobile technology. Young people’s
knowledge of mobile apps and platforms » Opportunities to play and be creative.
often surpasses that of parents, guardians
and teachers, and children now use social Mobile devices increasingly play a role in
networking services more than their parents. formal education and informal learning.
For people in LMICs and rural areas, as
For growing numbers of young people, mobile well as places where certain people –
technology is an increasingly important tool girls in particular – are excluded from
for communicating, accessing information, formal education, mobile connectivity
enjoying entertainment, learning, playing offers new opportunities to learn.
and being creative. As mobile technology
becomes increasingly embedded in everyday Like any tool, a mobile device can be used
life, mobile operators have an important in ways that cause harm, so young people
role to play in protecting and promoting require guidance in order to benefit from
children’s rights. mobile technologies safely and securely.
For children and youth, mobile devices can The mobile industry has taken active steps
be key to accessing: to help with the safe and responsible use of
mobile services by children. The GSMA plays
» Employment skills; a leading role in self-regulatory initiatives on
issues such as parental controls, education
» Enhanced formal and informal and awareness.
education and learning;
» Information and services to aid

in health and well-being;
Resources:
UNICEF Guidelines for Industry on Child Online Protection Website

UNICEF Tools for Companies in the ICT Sector Website
ICT Coalition Website
GSMA mPower Youth: Enhancing Children’s Lives through Mobile Website
GSMA and Child Helpline International: Internet Safety Guides
Global Kids Online: Research Results
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#BetterFuture
Industry position
Mobile devices and services enhance the The GSMA takes part in international
lives of young people. This perspective initiatives related to safeguarding children
needs to be embraced, encouraged and online, including contributing to the ITU’s
better understood by all stakeholders to Child Online Protection programme, and

ensure young people reap the full benefits actively engages with governments and
of mobile technology. regulators looking to address this issue.
Through its Capacity Building programme,
Addressing safe and responsible use of for example, the GSMA helps policymakers
mobile by children and young people is best better understand children’s use of
approached through multistakeholder efforts. technology and discusses strategies for
encouraging young people to become
Working closely with UNICEF, the GSMA positive, engaged, responsible and
and its mobile operator members and a resilient users of digital technology.
Mobile initiatives
range of other organisations, including the
the International Centre for Missing and Young people are critical to the evolution
Exploited Children (ICMEC) and INHOPE, of the mobile sector as they represent
hold national and regional multistakeholder the first generation to have grown up
workshops on the issue. These workshops in a connected, always-on world. They
bring together policymakers, NGOs, law are future consumers and innovators
enforcement and industry, to facilitate the who will deliver the next wave of innovation
development of collaborative approaches in mobile.
to safe and responsible use of the internet.
Through its mPower Youth programme,

the GSMA also works closely with Child
Helpline International to foster collaboration
between mobile operators and child
helplines in promoting children’s rights
– in particular their right to be heard –

and to work together on areas of mutual
concern, such as a safer internet.
Consumer protection
Debate:
» What potential harm are children exposed to in the online environment?
» How can all stakeholders navigate the tensions between differing child rights
in the digital world?
131
Deeper dive: Collaboration in action
As more young people are leading digital with input from a range of experts who
lives, they reach out to child helplines for also reviewed and approved the content.
support and guidance when they encounter The guides are purposely high level to
problems online. accommodate different local contexts,
with each guide providing a definition
While many child helplines already have and examples of the issue, discussion
experience in this area, globally there are ideas with children, parents/caregivers,
still many that would benefit from guidance practical and technical advice, as well as
on these issues. The GSMA and Child ‘red flags’ that counsellors should watch for.
Helpline International wanted to extend their
support to child helplines by harnessing The 30th anniversary of the UN
the experience of experts from a range Convention on the Rights of the Child
of stakeholder groups. In May 2016, they
co-hosted an intensive one-day workshop 1989 was a milestone year, as it marked
that brought together the child helpline both the agreement of the UN Convention
community, the Child Helpline International on the Rights of the Child (UNCRC) and
youth panel, mobile operators and other the birth of the World Wide Web.
industry players, NGOs, child online safety
experts, including a specialist child and The UNCRC sets out child-specific needs
adolescent psychiatrist and law enforcement. and rights that children everywhere are
entitled to in order to survive and thrive,
The workshop kick-started the development to learn and grow and to reach their full
of a series of high-level guides for child potential. It outlines children’s rights to
helpline counsellors and volunteers on education, information, privacy and the
nine common or challenging digital issues highest attainable standard of health.
that lead young people to seek advice It also outlines their rights to leisure and play,
from helplines. The nine guides were launched to be heard, as well as to protection from
in November 2016 and cover cyberbullying, violence, sexual exploitation and abuse.
discrimination and hate speech, grooming,
illegal content, inappropriate content, privacy, The provisions in the UNCRC were set out
sexual extortion, sexual harassment and and agreed without knowledge of the
unsolicited contact. technology revolution that would shortly
follow. The UNCRC remains as important
The guides were created with child helplines and relevant in today’s connected world
and their counsellors and volunteers in as it was for children at the time of its
mind, especially those for whom internet creation more than 30 years ago.
safety issues were relatively new or where
counsellor guidance and training was still The GSMA supports its members as they seek
under development. Each guide was created to enable children to safely and positively
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realise the many opportunities afforded
through connectivity, while also taking
steps to mitigate potential risks.
As the UNICEF State of the World’s Children

2017 report notes, the internet “...reflects
and amplifies the best and worst of human
nature. It is a tool that will always be used
for good and for ill. Our job is to mitigate
the harms and expand the opportunities
digital technology makes possible.”
Mobile initiatives
Consumer protection
133
Cross-border data flows
Background
The global digital economy depends on They contain accountability mechanisms

cross-border flows of data to deliver crucial and are based on internationally accepted
social and economic benefits to individuals, data protection principles.
businesses and governments.
However, their successful adoption is
When data is allowed to flow freely across undermined by governments implementing
borders, it enables organisations to adopt data localisation rules (also known as ‘data
data-driven digital transformation strategies sovereignty’) that impose local storage
that benefit individuals and society. Policies that requirements or use of local technology.18
inhibit the free flow of data through unjustified Such localisation requirements can be
restrictions or local data storage requirements found in a variety of sector- and subject-
can have an adverse impact on consumers, specific rules. They are sometimes
businesses and the economy in general.17 imposed by countries based on the belief
that supervisory authorities can more
Cross-border flows of personal data are easily scrutinise data that is stored locally.19
currently regulated by several international,
regional and national instruments and laws Today, bilateral and multilateral trade
intended to protect the privacy of individuals, agreements are incorporating more
the local economy or national security. modern trading arrangements that recognise
the potential of digital trade powered by
While many of these instruments and laws open, cross-border data flows. These can
adopt common privacy principles, they act as a catalyst for continued growth that
do not create an interoperable regulatory facilitates trade and improves productivity
framework that reflects the realities, and economic well-being. Examples are
challenges and potential of a globally the Comprehensive and Progressive
connected world. Emerging frameworks, Agreement for Trans-Pacific Partnership
such as APEC Cross-Border Privacy (CPTPP), the ASEAN Regional Comprehensive
Rules and the EU Binding Corporate Economic Partnership (RCEP), the African
Rules, allow organisations to transfer Continental Free Trade Area (AfCFTA) and
personal data under certain conditions. the EU Binding Corporate Rules.
Resources:
GSMA Mobile and Privacy Website

GSMA Report: Mobile Privacy Principles
GSMA Report: Smart Data Privacy Laws
GSMA Report: 5G and Data Privacy
GSMA Report: Protecting Privacy and Data in the Internet of Things
17. International Chamber of Commerce. (2016). Trade in the Digital Economy; ECIPE (2014)
The Cost of Data Localisation.
18. Chander, A. and Le, U. (2015). “Data Nationalism”. Emory Law Journal, 64(3); Hill, J.F. (2014).
“The Growth of Data Localization Post-Snowden”. The Hague Institute for Global Justice,
Conference on the Future of Cyber Governance, 2014.
19. E uropean Commission Report. (2017). Building a European Data Economy Communication.
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Industry position
Cross-border flows of data play a key role administrative requirements while also
in innovation, competition and economic helping to realise potential social and
and social development. Governments economic benefits. Such frameworks
can facilitate data flows in a way that is should be made interoperable across

consistent with consumer privacy and countries and regions to the greatest
local laws by supporting industry best extent possible. This would stimulate
practices and frameworks for the convergence between different approaches
movement of data, and by working to to privacy, while promoting appropriate
make these frameworks interoperable. standards of data protection and allow
accountable companies to build scalable
Governments can also ensure these and consistent data privacy programmes.
frameworks have strong accountability
mechanisms and authorities have a Requirements for companies to use local
Mobile initiatives
role in overseeing and monitoring their data storage or technology create
implementation. Governments should unnecessary duplication and costs.
only impose measures that restrict There is little evidence that the policies
cross-border data flows if they are produce tangible benefits for local
essential to achieving a legitimate economies or improved privacy
public policy objective. The application protections for individuals.
of these measures should be proportionate
and not arbitrary or discriminatory against To the extent that governments need
foreign suppliers or services. to scrutinise data for official purposes,
mobile operators would encourage them
Mobile operators welcome frameworks to achieve this through existing lawful
such as the APEC Cross-Border Privacy means and appropriate intergovernmental
Rules or the EU Binding Corporate Rules, mechanisms that do not restrict the flow
which allow accountable organisations of data.
to transfer data globally provided they
meet certain criteria. Such mechanisms The GSMA and its members believe that
are based on commonly recognised cross-border data flows can be managed
data privacy principles and require in ways that safeguard the personal data
organisations to adopt a comprehensive and privacy of individuals. We remain
approach to data privacy. committed to working with stakeholders
to ensure that restrictions are only
The frameworks encourage more effective implemented if they are necessary to
protection for individuals than formal achieve a legitimate public policy objective.
Consumer protection
Debate:
» How can industry, legislators, regulators and civil society engage effectively
to develop policy that supports cross-border flows of data?
» How can data protection safeguards adequately address the legitimate
concerns of governments that seek to impose localisation requirements?
135
Deeper dive: National data privacy regimes
The challenge of regulating data privacy, companies to treat data consistently across
including cross-border flows of data, is their operations, innovate more rapidly,
putting measures in place that consistently achieve greater scale and reduce costs.
provide consumers with confidence in Consumers will benefit from wider choice,
existing and new services without limiting improved quality and lower prices of services.
service adoption or imposing significant
additional costs on service providers. The 2009 Madrid Resolution on International
Standards for the Protection of Personal
To achieve this, it is crucial for privacy Data and Privacy, for example, encourages
regulation to be based on shared core consistent international protection of personal
principles, which, according to United data and embraces privacy approaches from
Nations Conference on Trade and all five continents. As well as being designed
Development (UNCTAD), are “at the “to ease the international flow of personal
heart of most national [privacy] laws data, essential in a globalised world”20 the
and international regimes”, as well as resolution advocates six privacy principles
industry initiatives. This would allow to be adopted by policymakers.
Figure 13
Lawful and fair Purpose Proportionate
Personal data must Processing should be Processing should

be lawfully and limited to specified be proportionate
fairly processed purposes. and not excessive.
Quality Openness Accountable
Data held should The processor should The processor should

be accurate. be open regarding be accountable for
their activities. their activities.
Similar principles are reflected repeatedly in Principles and the APEC Privacy Framework.
laws and policy initiatives around the world, The mobile industry has also adopted the
such as the Council of Europe Convention GSMA Mobile Privacy Principles to give
108, the OECD Guidelines, the EU General consumers confidence that their personal
Data Protection Regulation, the US Federal data is being protected, irrespective of
Trade Commission Fair Information Practice service, device or country.
20. International Standards on the Protection of Personal Data and Privacy: The Madrid Resolution 2009.
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Deeper dive: Localisation rules

There are several reasons why countries stored securely abroad. Requiring localisation
seek to justify imposing data localisation on the grounds of a perceived economic
rules, including concerns about foreign benefit are equally flawed. Restricting data
surveillance and national security, as well processing activities to a national rather than
as a desire to stimulate a national digital global scale, is likely to lead to significant

economy through in-country data analysis. operational costs per customer served and
prevent citizens from accessing emerging
The range of localisation restrictions can innovative global digital services.
include subjecting the data flows to certain
restrictions to protect citizens’ privacy To address legitimate concerns about privacy,
and requiring organisations to keep data governments have adopted a patchwork of
in-country but allowing the data to flow international, regional and national rules. In
thereafter. It may also include requiring addition to the APEC Privacy Framework and
the data to be kept in-country or imposing the EU General Data Protection Regulation
Mobile initiatives
requirements that have the indirect effect (GDPR), regional frameworks have emerged in
of keeping the data in-country, such as the ASEAN region, Latin America and Africa.
mandating the use of local infrastructure. These frameworks are commendable in that
they aim to align regional economies around
However, these restrictions do not necessarily a common understanding of data privacy.
lead to better protection of personal data However, they need to be interoperable across
and, in fact, can undermine it. For example, regions to the greatest extent possible, to
a fragmented approach results in inconsistent reflect the realities of a globally connected
protection (e.g. differences across jurisdictions world. This would allow companies to build
and sectors in what can be stored and for scalable and accountable data protection
how long) and causes confusion, which and privacy platforms.
ultimately has a negative impact on the
secure management of personal data. Flows of data across borders are important
for societal and economic reasons. Without
The risks identified by governments can them, economic growth and the potential
be mitigated by various solutions and benefits to society of digital transformation

principles without restricting data flows. can be hampered. It is therefore incumbent
For example, internet platform companies on governments, regulators, industry and civil
and cloud computing providers are society groups to reject localisation measures
increasingly establishing regional hubs so and find other ways to enable the flow of data
that governments concerned about the while also protecting individual privacy.
surveillance activities of foreign countries
can avoid data being held in particular
jurisdictions. Encryption techniques also
allow data to be protected from access and
Consumer protection
137
Data privacy
Background
Research shows that mobile customers are

concerned about their privacy and want simple
and clear choices for controlling how their private
information is used. They also want to know
they can trust companies with their data.
A lack of trust can act as a barrier to growth
in economies that are increasingly data-driven.
One of the major challenges created by the

growth of the mobile internet is that the
security and privacy of personal information
is regulated by a patchwork of geographically
bound privacy regulations while the mobile
internet is, by definition, international. In many
jurisdictions, the regulations governing how
customer data is collected, processed and
stored vary considerably between market
participants. For example, the rules governing
how personal data is treated by mobile operators
may be different to those governing how it can
be used by internet players.
This misalignment between national privacy

laws and global standard practices makes it
difficult for operators to provide customers
with a consistent user experience. It may also
cause legal uncertainty for operators, which can
deter investment and innovation. Inconsistent
levels of protection also create risks that
consumers might unwittingly provide easy
access to their personal information, leaving
them exposed to unwanted or undesirable
outcomes, such as identity theft and fraud.
Resources:
GSMA Mobile and Privacy Website

GSMA Report: Smart Data Privacy Laws
GSMA Report: 5G and Data Privacy
GSMA Report: Protecting Privacy and Data in the Internet of Things
138
#BetterFuture
Industry position
Currently, the wide range of services Because of the high level of innovation in
available through mobile devices offers mobile services, legislation should focus on
varying degrees of privacy protection. the overall risk to an individual’s privacy,
To give customers confidence that rather than attempting to legislate for specific

their personal data is being properly types of data. For example, legislation must
protected – irrespective of service or deal with the risk to an individual arising from
device – a consistent level of protection a range of different data types and contexts,
must be provided. rather than focusing on individual data types.
Mobile operators believe that customer The mobile industry should ensure privacy
confidence and trust can only be fully risks are considered when designing new
achieved when users feel their privacy apps and services and develop solutions
is appropriately protected. that provide consumers with simple ways
Mobile initiatives
to understand their privacy choices and
The necessary safeguards should derive control their data.
from a combination of internationally
agreed approaches, national legislation The GSMA is committed to working
and industry action. Governments should with stakeholders from across the mobile
ensure legislation is technology neutral industry to develop a consistent approach
and that its rules are applied consistently to privacy protection and promote trust
to all players in the internet ecosystem. in mobile services.
Debate:
» How can policymakers help create a privacy framework that supports innovation
in data use while balancing the need for privacy across borders, regardless of the
Consumer protection
technology involved?
» How is responsibility for ensuring privacy across borders best distributed across
the mobile internet value chain?
» What role does self-regulation play in a continually evolving technology environment?
» What should be done to allow data to be used to support the social good and
meet pressing public policy needs?
139
Deeper dive: Smart data privacy practices and regulation
A combination of smart data privacy practices Policymakers around the world have been
and regulation is required to sustain consumer studying the EU’s GDPR and other regional
trust in the digital ecosystem rapidly evolving and national frameworks or laws to inform their
around them. own legislative proposals. Among the lessons
learned are that smart data privacy rules are:
The GSMA has developed eight Mobile Privacy
Principles, as well as a range of resources » Horizontal, meaning they apply to all
to promote good practice. These resources processing of personal data rather than
include the GSMA’s Privacy Design Guidelines focusing on just one technology or sector.
for Mobile Application Development, which This reduces the need for sectoral rules
are considerations that should be taken into or operating licences that subject mobile
account when engaging in big data analytics operators to an additional set of competing
and a Privacy by Design decision tree for privacy obligations.
use in developing IoT products and services.
These guidelines seek to strike a balance » Principles-based, allowing innovation
between protecting privacy and enabling to thrive without having to reinvent
organisations to achieve commercial, public the rules every time new technologies
policy and societal goals. or business methods are introduced.
If organisations adopt comprehensive policies, » Risk-based, encouraging companies to

processes and practices to protect the privacy focus on preventing harm (for example,
of individuals, and can easily demonstrate by setting a threshold for reporting
that these safeguards are effective, they data breaches rather than mandating
will strengthen trust of consumers and that all breaches are reported), or
regulators. Equally, if governments adopt encouraging organisations to implement
smart data privacy rules, they can establish Privacy by Design and privacy impact
a regulatory environment that stimulates assessment processes.
the digital economy while also unleashing
its benefits for consumers and citizens. » Based on the idea of accountability,
holding companies to account, while
While governments must ensure smart allowing them to innovate and comply
data privacy laws take account of citizens’ in a way that makes sense for their
privacy concerns, they must also recognise business and rewarding those that embed
that these rules can have important a culture of privacy in their organisations.
consequences beyond the protection
of privacy. As a result, when drafting » Open to data flows, allowing data to cross
these rules, governments must take borders provided there are sufficient
into consideration how these laws sit safeguards to protect an individual’s privacy
within an economic and societal context. (see the Cross-border data flows section).
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Deeper dive: GSMA Mobile Privacy Principles

The GSMA has published a set of universal » Respect user rights
Mobile Privacy Principles that describe Users should be provided with
how mobile consumers’ privacy should information about, and an easy
be respected and protected: means to exercise, their rights over
the use of their personal information.

» Openness, transparency and notice
Responsible persons (e.g. application » Security
or service providers) shall be open Personal information must be protected,
and honest with users and will ensure using reasonable safeguards appropriate
users are provided with clear, prominent to the sensitivity of the information.
and timely information regarding their
identity and data privacy practices. » Education
Users should be provided with information
» Purpose and use about privacy and security issues and ways
Mobile initiatives
The access, collection, sharing, disclosure to manage and protect their privacy.
and further use of personal information
shall be limited to legitimate business » Children and adolescents
purposes, such as providing applications An application or service that is directed
or services as requested by users, or at children and adolescents should ensure
to otherwise meet legal obligations. that the collection, access and use of
personal information is appropriate in
» User choice and control all given circumstances and is compatible
Users shall be given opportunities to with national law.
exercise meaningful choice and control
over their personal information.
» Data minimisation and retention

Only the minimum personal information
necessary to meet legitimate business
purposes should be collected and

otherwise accessed and used.
Personal information must not be
kept for longer than is necessary for
those legitimate business purposes or
to meet legal retention obligations.
Consumer protection
141
Privacy and big data
Background
Increases in computing power and falling Together, these capabilities represent a

prices of information technology systems sea change in society’s ability to create new
make it possible to process huge volumes products and services and solve some of
of data from a variety of sources, in a the most pressing public policy needs of our
range of formats, at greater speed than ever time, from road management in congested
before. It is now possible to analyse all data and polluted urban areas to understanding
from one or more large data sets, rather and preventing the spread of diseases.
than relying on smaller samples of data.
This allows meaningful insights to be Mobile operators will increasingly use
drawn, where appropriate, from mere the information they collect for big data
correlations in the data rather than initiatives. They have an important role to
having to identify causal connections. play as responsible stewards of that data
These capabilities are often referred to and potentially as facilitators in a future
as ‘big data analytics’ techniques. marketplace for access to this type of data.
At the same time, the Internet of Things However, big data capabilities also give
(IoT) is equipping an ever-increasing rise to questions about security and
number of devices with sensors that privacy and how these important
collect and communicate data. concerns can be addressed.
Resources:
GSMA Report: Mobile Privacy and Big Data Analytics

GSMA Report: Privacy Design Guidelines for Mobile Applications
OECD Report: Data-driven Innovation for Growth and Well-being
Federal Trade Commission Report: Big Data: A Tool for Inclusion or Exclusion?
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Industry position
The mobile industry recognises the societal » Thinking carefully about the impact on
benefits that can result from big data and wants individuals (and groups) of insights derived
to unlock the huge potential of big data analytics from big data and the actions or decisions
in a way that respects well-established privacy that may be taken based on those insights.

principles and fosters an environment of trust.
» Reducing the risk of re-identification of
New laws are not necessary to address individuals after data has been processed
big data analytics and IoT. Rather, mobile where this may raise privacy concerns.
operators recognise that existing privacy
principles apply in these areas. Rules that » Establishing clarity on responsibilities
restrict the legitimate use of data or metadata between parties when collaborating on
should be qualified and proportional to the risk big data analytics projects.
of privacy harm that consumers might suffer
Mobile initiatives
if their data is misused. These rules should » Incorporating ethical decision-making
also be applied consistently across different into governance models.
industry sectors and types of technology.
Equally, governments can ensure their
Operators are well placed to understand country and citizens gain the most benefit
the potential risks to individuals and groups from the potential of big data by:
from big data analytics and can implement
measures to avoid or mitigate those risks. » Understanding how big data analytics works
and the context in which it takes place.
New insights derived from the data will often
give rise to new uses or ‘purposes of processing’ » Accommodating innovative approaches
that had not been considered or identified when to transparency and consent.
the data was initially collected. Accordingly,
privacy frameworks must recognise this » Developing and adopting practical industry
potential and make such uses possible. guidelines and self-regulatory measures
that seek to harness, rather than hinder,

Mobile operators can address these types big data analytics.
of challenges and increase trust between
industry stakeholders and consumers by:
» Building on existing privacy initiatives, such Debate:

as the GSMA Mobile Privacy Principles and
the Privacy Design Guidelines for Mobile » How can mobile operators and
Application Development. policymakers help society realise
the benefits of big data analytics in
Consumer protection
» Finding innovative ways to provide a privacy-protective manner and in

individuals with meaningful choice, control compliance with applicable laws?
and transparency to individuals on what data » How can the GSMA strengthen the
is collected and how it is used. For example, trust of stakeholders involved in
this could be addressed through user-friendly collecting and analysing data?
dashboards or signals from IoT devices easily
discoverable by smartphones.
143
Electromagnetic fields and health
Background
Research into the safety of radio signals However, research has suggested a possible
has been conducted for several decades increased risk of brain tumours among long-
and underpins human exposure limits term users of mobile phones. As a result,
that provide protection to all people in May 2011, the International Agency for
(including children) against all established Research on Cancer classified radio signals
health risks. as a possible human carcinogen. Health
authorities advise that given the scientific
The WHO and ITU encourage governments uncertainty and lack of supporting evidence
to adopt the radio frequency electromagnetic from cancer trend data, this classification
field (RF-EMF) exposure limits developed by should be understood to mean that more
the International Commission on Non-Ionizing research is needed. They also remind mobile
Radiation Protection (ICNIRP). These were phone users of practical measures for
reviewed and updated in 2020. individuals to reduce exposure, such as
using a hands-free kit or text messaging.
New applications, such as 5G, wireless
IoT and wearable devices, are designed Mobile phones are tested for compliance
to comply with relevant exposure limits. with exposure limits when operating at
The international exposure guidelines maximum power. In use a mobile phone
are not technology-specific and apply to operates at a much lower power level.
all mobile technologies, including 5G.
For mobile networks, whether 2G, 3G, 4G or
The strong consensus of expert groups 5G, the typical levels in publicly accessible
and public health agencies, such as the areas are a small fraction of the exposure
WHO, is that no health risks have been limits and similar to broadcast services.
established from exposure to the radio
signals of mobile devices and mobile A comprehensive health-risk assessment of
network antennas that comply with radio signals is being conducted by the WHO.
international safety recommendations. The conclusions are expected in late 2022.
Resources:
WHO International EMF Project Website

GSMA Report: EMF Exposure Compliance Policies for Mobile Network Sites
GSMA Report: International EMF Exposure Guidelines
GSMA Website: Safety of 5G Networks
GSMA Interactive Map: 5G EMF Surveys
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Industry position
National authorities should implement phones. The current WHO position is that
EMF-related policies based on established international safety guidelines protect
science, in line with international everyone in the population with a large safety
recommendations and technical standards. factor, and that there is no scientific basis

to restrict children’s use of phones or the
Significant differences between national locations of base stations. We encourage
limits and international guidelines can cause governments to provide information and
confusion and increase public anxiety. voluntary practical guidance to consumers and
Consistency is vital, and governments should: parents based on the position of the WHO.
» Base EMF-related policy on reliable Concerned individuals can choose to limit

information sources, including the WHO, their exposure by making shorter calls,
trusted international health authorities using text messaging or hands-free devices
Mobile initiatives
and expert scientists. that can be kept away from the head and
body. Bluetooth earpieces use very low
» Set a national policy covering the siting of radio power and reduce exposure.
masts, balancing effective network roll-out
with consideration of public concerns. The mobile industry works with national and
local governments to help address public
» Accept mobile operators’ declarations of concerns about mobile communications.
compliance with international or national Adoption of evidence-based national policies
radio frequency levels using technical for exposure limits and siting of antennas,
standards from organisations such as public consultations and information can
the International Electrotechnical help to reassure the public.
Commission (IEC) and the ITU.
On-going, high-quality independent research is
» Actively communicate with the public necessary to support health-risk assessments,
and address their concerns based on develop safety standards and provide
the positions of the WHO. information to inform policy development.

Studies should follow good laboratory
Parents should have access to accurate practice for EMF research and be governed by
information so they can decide when and contracts that encourage open publication of
whether their children should use mobile findings in peer-reviewed scientific literature.
Debate:
» Does using a mobile phone regularly or living near a base station have any
Consumer protection
health implications?
» Are there benefits to adopting the updated international EMF limits for
mobile networks or devices?
» Should there be specific restrictions to protect children, pregnant women
or other potentially vulnerable groups?
145
dive: Health
Deeper Dive: title authorities on the science
To date, and after much research performed, no adverse health effect has been causally
linked with exposure to wireless technologies. Health-related conclusions are drawn from
studies performed across the entire radio spectrum but, so far, only a few studies have
been carried out at the frequencies to be used by 5G.
Tissue heating is the main mechanism of interaction between radiofrequency fields and
the human body. Radiofrequency exposure levels from current technologies result in
negligible temperature rise in the human body.
As the frequency increases, there is less penetration into the body tissues and absorption of
the energy becomes more confined to the surface of the body (skin and eye). Provided that
the overall exposure remains below international guidelines, no consequences for public
health are anticipated.
– WHO Question and Answer, February 2020
Most of the epidemiological research does not support an association between mobile phone
use and tumours occurring in the head, which is the body part with the highest exposure to
radio frequency electromagnetic fields. In studies reporting positive associations, it is difficult
to exclude various forms of bias, such as recall bias in retrospective exposure assessment.
– International Agency for Research on Cancer, IARC, 2020
A large number of studies have been undertaken on both acute and long-term effects from
RF EMF exposure typical of base stations. Research at these levels of exposure has provided
no conclusive evidence of any related adverse health effects.
– International Commission on Non-Ionizing Radiation Protection (ICNIRP),

accessed January 2022
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Deeper dive: Advanced antenna technologies

Many of the antennas used for 5G are similar
to those in use today. Advanced antenna
technologies, such as beamforming, require
the use of arrays of small antenna elements
to optimise the delivery of radio signals to

connected mobile devices. At high-band 5G
frequencies these antennas can be small.
Figure 14 Conventional and beamforming antennas
Conventional antenna Beamforming antenna Mobile initiatives

As shown in Figure 14, a conventional base

station antenna transmits a radio signal to

a wide area regardless of how many users
are connected while advanced beamforming
antennas transmit radio signals to connected
users, reducing unwanted signals.
Consumer protection
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dive: A
Deeper Dive: global look at mobile network exposure limits
title
The WHO endorses the guidelines of the

ICNIRP and encourages countries to adopt
them. While many countries have adopted
this recommendation, some have chosen to
adopt other limits or additional measures on
the siting of base stations.
A map on the GSMA website shows the

approach to radio frequency (RF) exposure
limits that countries have adopted for
mobile communication antenna sites.
Much of the world follows the ICNIRP
guidelines or the similar US Federal
Communications Commission (FCC) rules.
In some cases (e.g. China and Russia) RF

limits have not been updated to reflect more
recent scientific knowledge. In other cases,
limits applicable to mobile networks may
be the result of arbitrary reductions made
as a political response to public concern.
Excluding countries or territories with

unknown RF limits, 137 apply ICNIRP
(1998 or 2020 limits), 10 follow the FCC
limits from 1996 and 37 have other limits.
For the ‘Other’ category, there are many
differences between these countries in
their limit values and application.
Resources:
GSMA EMF Policy Website
148
149
Illegal content
Background
Today, mobile networks not only offer Communications service providers, including
traditional voice and messaging services, but mobile operators and ISPs, are not usually
also provide access to virtually all forms of liable for illegal content on their networks
digital content via the internet. In this respect, and services, provided they are not aware
mobile operators offer the same service as of its presence and follow certain rules
any other internet service provider (ISP). (e.g. ‘notice and take-down’ processes
This means mobile networks are inevitably to remove or disable access to the illegal
used to access illegal content, ranging from content as soon as they are notified of its
pirated material that infringes intellectual existence by the appropriate legal authority).
property rights (IPR) to racist content or child
sexual abuse material (child pornography). Mobile operators are typically alerted to illegal
content by national hotline organisations or
Laws regarding illegal content vary law enforcement agencies. When content
considerably. Some content, such as is reported, operators follow procedures
child sexual abuse material, is considered based on relevant data protection, privacy
illegal around the world, while other and disclosure legislation. In the case of child
content, such as dialogue that calls for sexual abuse content, mobile operators use
political reform, is illegal in some countries terms and conditions, notice and takedown
while in others they are protected by processes and reporting mechanisms to
rights to freedom of expression. keep their services free of this material.
Resources:
GSMA Reference Document: Mobile Alliance Against Child Sexual Abuse Content Interpol Crimes
Against Children
GSMA and UNICEF Report: Notice and Takedown: Company Policies and Practices to Remove
Online Child Sexual Abuse Material
GSMA Guide: Hotlines: Responding to Reports of Illegal Online Content
GSMA and Child Helpline International Guides: Internet Safety Guides
International Centre for Missing and Exploited Children Report: Model Legislation and Global Review
INHOPE
WePROTECT Global Alliance Guidance Document: The Model National Response
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Industry position
The mobile industry is committed to which content is illegal before placing

working with law enforcement agencies and responsibility for enforcement on hotlines,
appropriate authorities and having robust law enforcement agencies and industry.
processes in place that enable the swift

removal or disabling of confirmed instances The mobile industry condemns the misuse
of illegal content hosted on their services. of its services for sharing child sexual abuse
content. The GSMA Mobile Alliance Against
ISPs, including mobile operators, are not Child Sexual Abuse Content provides
qualified to decide what constitutes illegal leadership in this area and works proactively
content, the scope of which is broad and to combat the misuse of mobile networks
varies between countries. As such, they and services by criminals seeking to access
should not be expected to monitor and judge or share child sexual abuse content.
third-party material, whether it is hosted on,
Mobile initiatives
or accessed through, their own network. Regarding copyright infringement and
piracy, the mobile industry recognises
National governments decide what the importance of proper compensation
constitutes illegal content in their country. for rights holders and the prevention of
They should be open and transparent about unauthorised distribution.
Debate:
Consumer protection
» Should all types of illegal content, from IPR infringements to child sexual
abuse content, be subject to the same reporting and removal processes?
» What responsibilities should governments, law enforcement or industry
have in the policing and removal of illegal content?
» Should access to illegal content on the internet be blocked by ISPs and
mobile operators?
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dive: M
Deeper Dive: title
obile Alliance Against
Child Sexual Abuse Content
The Mobile Alliance Against Child Sexual of the mobile environment by individuals
Abuse Content was founded by an or organisations wishing to consume or
international group of mobile operators profit from child sexual abuse content.
within the GSMA to obstruct the use
Figure 15 Mobile Alliance procedures to stop child sexual abuse content
A report of suspected illegal child sexual abuse content is made by an internet user,
directly or through their internet service provider (ISP) or mobile operator
National hotline or law enforcement agency (LEA) assesses the content
Illegal Not illegal
Traced to host country No further action
If the content is hosted in a d ifferent

country, the report is passed on to
If the content is hosted
INHOPE or the relevant LEA
in the same country
as the hotline or
LEA, notice and
take-down processes
are instigated and the
Some countries also add the U RL
content is removed
to a ‘block list’ that allows ISPs and
mobile operators to prevent access
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Alliance members have made the
commitment to:
» Implement technical mechanisms to In the 10 years since the Mobile Alliance was
restrict access to websites or URLs founded, changes to the digital ecosystem,

identified by an appropriate, including the increase in online interactivity
internationally recognised agency and user-generated content, have altered
as hosting child sexual abuse content. the nature of online child sexual exploitation
and abuse. For example, hotlines are
» Implement notice and take-down increasingly seeing self-generated content
processes to enable the removal (also known as ‘sexting’) being shared online.
of any child sexual abuse content Child helplines are receiving calls from
posted on their own services. young people reporting ‘sexual extortion’
or being blackmailed by an offender using
Mobile initiatives
» Support and promote hotlines or other self-produced sexual images or videos to
mechanisms for customers to report child make sexual or financial demands.
sexual abuse content discovered on the
internet or on mobile content services. GSMA and Mobile Alliance members
continue to work with their external partners
Through a combination of technical measures, to monitor emerging issues such as these
cooperation and information sharing, the and find additional ways to contribute to
Mobile Alliance is working to stem, and wider efforts to address them. For example,
ultimately reverse, the growth of online child they are collaboratively developing guidance
sexual abuse content around the world. for child helpline counsellors on internet
safety issues (including illegal content and
The Mobile Alliance also contributes to sexual extortion) and members lead internet
wider efforts to eradicate online child safety consumer education and awareness
sexual abuse content by publishing campaigns on an on-going basis.
guidance and toolkits for the benefit of
the entire mobile industry. For example,

it has produced a guide to establishing
and managing a hotline in collaboration
with INHOPE, the umbrella organisation for
hotlines, and a guide to implementing notice
and take-down processes with UNICEF.
Consumer protection
153
Internet governance
Background
Internet governance involves an array

of activities related to the policy and
procedures of the management of the
internet. It encompasses legal and
regulatory issues, such as privacy,
cybercrime, intellectual property
rights and spam. It is also concerned
with technical issues related to network
management and standards, and
economic issues such as taxation and
internet interconnection arrangements.
Because the growth of the mobile industry

is tied to the evolution of internet-enabled
services and devices, decisions about the use,
management and regulation of the internet
affect mobile service providers and other
industry players and their customers.
Internet governance requires input and

collaboration from diverse stakeholders
relating to their interests and expertise in
technical engineering, resource management,
standards and policy issues, among
others. Relevant stakeholder groups will
vary depending on the specific internet
governance issues that are being addressed.
Resources:
Internet Governance Forum Website

Internet Society Internet Governance Website
UNESCO Internet Governance Website
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“Only a concerted joint global effort by governments, businesses, the technical community
and civil society will produce a governance architecture that is as generic, scalable and
transnational as the internet itself. No single actor or group of actors can solve this alone.”

– Vint Cerf, Chief Internet Evangelist at Google and
Co-inventor of the Internet Protocol suite, February 2018
Industry position
The internet should be secure, stable, Some internet governance issues warrant
trustworthy and interoperable, and no a different approach at the local, national,
single institution or organisation can regional or global level. An effective and
Mobile initiatives
or should manage it. The existing efficient multistakeholder model ensures
multistakeholder model for internet that stakeholders, within their respective
governance and decision-making should roles, can participate in building consensus
be preserved and allowed to evolve. on such issues.
Given the ubiquity of the internet in today’s Technical aspects related to the management
world, any architecture designed to govern its and development of internet networks
use should be capable of addressing a range and architecture should be addressed
of issues and challenges relevant to different collaboratively by different stakeholder
stakeholders in a manner that is more agile groups through relevant standards bodies,
and flexible than traditional government the Internet Engineering Task Force (IETF),
and intergovernmental mechanisms. the Internet Architecture Board (IAB) and
other forums.
Collaborative, diverse and inclusive decision-
making models are required for stakeholders Economic and transactional issues, such as
to participate in internet governance. internet interconnection charges, are best left

to commercial negotiation, consistent with
The decentralised development of the commercial law and regulatory regimes.
internet should continue, without the
control of a particular business model
or regulatory approach.
Debate:
Consumer protection
» Who ‘owns’ the internet?

» Should certain countries or organisations be allowed to have greater
decision-making powers than others about the management of the internet?
» How should a multistakeholder model be applied to internet governance?
155
Mandated government access
Background
Mobile operators are often subject to a This creates challenges for the industry in
range of laws and/or licence conditions that protecting the privacy of its customers’
require them to support law enforcement information and their communications.
and security activities in countries where
they operate. These requirements vary Legislation often lags behind technological
from country to country and have an developments. For example, obligations may
impact on the privacy of mobile customers. apply only to established telecommunications
operators but not to more recent market
Where they exist, such laws and licence entrants, such as those providing internet-
conditions typically require operators to based services, including Voice over IP
retain data about their customers’ mobile (VoIP), video or instant messaging.
service use and disclose it, including their
personal data, to law enforcement and In response to public debate concerning
national security agencies on lawful the extent of government access to
demand. They may also require operators mobile subscriber data, a number of major
to have the ability to intercept customer telecommunications providers (such as
communications following lawful demand. AT&T, Deutsche Telekom, Orange, Rogers,
SaskTel, Sprint, T-Mobile, TekSavvy,
Such laws provide a framework for the TeliaSonera, Telstra, Telus, Verizon, Vodafone
operation of law enforcement and security and Wind Mobile), as well as internet
service surveillance and guide mobile companies (such as Apple, Amazon, Dropbox,
operators in their mandatory liaison with Facebook, Google, LinkedIn, Microsoft,
these services. However, in some countries, Pinterest, Snapchat, Tumblr, Twitter and
there is a lack of clarity in the legal framework Yahoo!) publish ‘transparency reports’ that
to regulate the disclosure of data or lawful provide statistics relating to government
interception of customer communications. requests for disclosure of such data.
Resources:
United Nations General Assembly Report: Guiding Principles on Business and Human Rights –
Implementing the United Nations ‘Protect, Respect and Remedy’ Framework Sixth Form Law –
Malone v. The United Kingdom Website
High Court Judgement: Data Retention and Investigatory Powers Act 2014 (DRIPA)
156
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Industry position
Governments should ensure they International Convention on Civil and

have a proportionate legal framework Political Rights. Given the expanding
that clearly specifies the surveillance range of communications services,
powers available to national law the legal framework should be

enforcement and security agencies. technology-neutral.
Any interference with the right to privacy Governments should provide appropriate
of telecommunications customers must be limitations of liability or indemnify
in accordance with the law. telecommunications providers against
legal claims brought in respect of
The retention and disclosure of data and compliance with requests and obligations
the interception of communications for for the retention, disclosure and interception
law enforcement or security purposes of communications and data.
Mobile initiatives
should take place only under a clear
legal framework and using the proper The costs of complying with all laws
process and authorisation specified by covering the interception of communications
that framework. and the retention and disclosure of data
should be borne by governments. Such
There should be a legal process available costs and the basis for their calculation
to telecommunications providers to should be agreed in advance.
challenge requests which they believe to
be outside the scope of the relevant laws. The GSMA and its members are supportive
of initiatives that seek to increase government
The framework should be transparent, transparency and the publication by
proportionate, justified and compatible government of statistics related to
with human rights principles, including requests for access to customer data.
obligations under applicable international
human rights conventions, such as the
Debate:
» What is the correct legal framework to achieve a balance between a government’s
obligation to ensure its law enforcement and security agencies can protect citizens
and the rights of those citizens to privacy?
Consumer protection
» Should all providers of communications services be subject to the same interception,

retention and disclosure laws on a technology-neutral basis?
» Would greater transparency about the number and nature of requests governments
make assist the debate, improve government accountability and bolster consumer
confidence?
157
dive: Trending
Deeper Dive: title towards transparency
There is an important global debate on the communications. Intercepting standard

scope, necessity and legitimacy of the legal phone calls or SMS messages to and
powers government authorities use to access from specific users is technically possible,
the communications of private individuals. and lawful interception requirements
ICT firms are increasingly reporting the and capabilities have been described in
demands of governments for communications global mobile standards for decades.
data where it is legal to do so. These
reports have revealed the degree to which However, communications between users
government intelligence and law enforcement on an internet-based platform, known as
agencies rely on such information. an over-the-top (OTT) service, is generally
beyond the reach of mobile operators. OTT
Many of the largest communications and messaging applications are usually encrypted
internet content providers (including AT&T, and messages are not stored by operators,
Deutsche Telekom, Telenor, Verizon, Vodafone, nor are decryption keys made available to
Apple, Dropbox, Facebook, Google, LinkedIn, them. This leaves operators unable to access
Microsoft, Twitter and Yahoo!) publish or provide the content of messages, even
periodic transparency reports. by lawful request. Both internet companies
and mobile operators may find themselves
Typically, these reports include how many in a difficult position, bound to meet their
of these requests resulted in the disclosure obligations to provide lawful access while
of customer information. They reveal the also assuring their customers that they
frequency of such requests, as well as protect their personal information.
some detail about the kind of information
accessed. This can include customer To further support their commitment to
account information, the interception of transparency, some operators have joined
communications and metadata, which can forces with internet companies and other
reveal an individual’s location, interests or stakeholders in initiatives such as the Global
relationships. Mobile operators often have Network Initiative (GNI). The GNI brings
no option but to comply with such requests, together telecommunications operators,
but they are increasingly pressing for greater major internet companies, leading academics,
transparency about the nature and scale of civil society organisations and investors
government access. to advance privacy and freedom of
expression in the ICT sector. In March 2017,
Questions have also arisen about the role seven operators – Millicom, Nokia, Orange,
of telecommunications network and service Telefónica, Telenor Group, Telia Company
providers in relation to such access. For and Vodafone – joined an expanded GNI
example, misunderstandings can arise after having promoted transparency through
about the extent to which mobile operators the Telecommunications Industry Dialogue.
have the technical capacity to intercept These companies committed to the GNI
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Principles on Freedom of Expression and and publish their own transparency reports
Privacy, which provide direction and guidance to make it clear what information they
to the ICT industry and its stakeholders in demanded from companies and why.
protecting and advancing the enjoyment
of these human rights globally. The debate can be heated between those

who argue that law enforcement agencies
Civil society organisations have contributed require broad access to fight crime and
to the advancement of these issues by those who challenge the level of government
trying to provide trustworthy measures of inquiry into private lives and strive to maintain
transparency. Ranking Digital Rights (RDR) citizens’ rights to privacy in the digital age.
publishes an annual report on telecoms’ and GSMA members maintain that transparency
internet companies’ disclosed commitments, reporting brings valid information to
policies and practices that affect users’ the public and policymakers, raising key
privacy and freedom of expression. The RDR questions about the balance between
Mobile initiatives
calls for governments to allow encryption government access and privacy.
Figure 16 Government access – encouraging transparency
Governments sometimes request access
to mobile operators’ subscriber data
To provide more transparency to users, These requests should be based

mobile operators, as well as some internet on a proportionate legal framework
companies, publish transparency reports that clearly specifies the surveillance
providing statistics relating to government powers available to national law
requests for disclosure of such data enforcement and s ecurity agencies
Consumer protection
159
Case study: N
ational regulatory approaches
to government access
Increasingly, as witnessed in the UK, France, Germany and Australia, laws are being proposed
that would require service providers to capture and retain communications data and grant the
government systematic access to this information.
In the UK, communications service providers are required to separately retain a range
of account and communications data and must ensure the data can be disclosed in a
timely manner to UK law enforcement agencies, the security services and a number of
prescribed public authorities under the UK Regulation of Investigatory Powers Act (RIPA).
Prescribed authorities can also seek a warrant from the Secretary of State to intercept
communications. The two main objectives of RIPA are to regulate the investigatory
powers of the state and to set the legitimate expectations for citizens’ privacy. As RIPA is
subject to oversight by the Surveillance Commissioner and the Interception Commissioner,
citizens can seek redress for alleged unlawful access to their data or communications, and
service providers operating in the UK can raise concerns about the validity of requests.
In April 2014, the European Court of Justice ruled that the EU Data Retention Directive is
‘invalid’ because it violated two basic rights: respect for private life and protection of personal
data. The European Commission has emphasised that the decision of whether to introduce
national data-retention laws is a national decision and consequently, the UK and several other
EU countries are reviewing their data-retention laws, which required communications service
providers to store communications data for up to two years.
Meanwhile, in May 2015, the German Government outlined plans for a new data-retention law
that would require telecoms companies to retain ‘traffic data’ relevant to communications
and hand them over (under certain conditions) to Germany’s law enforcement and security
agencies. Germany’s privacy campaigners questioned whether the plans were constitutional,
adding that, in their opinion, the German Government had not sufficiently outlined why the
retention of the data is necessary.
In July 2015, the French Parliament approved a bill that allows intelligence agencies to
tap phones and emails without seeking permission from a judge. The new law requires
communications providers and internet service providers to hand over customers’ data
upon request, if the relevant customers are linked to a ‘terrorist’ inquiry. Protesters from
civil liberties groups claimed the bill would legalise intrusive surveillance methods without
guarantees for individual freedom and privacy.
Australia’s new Telecommunications (Interception and Access) Amendment (Data Retention)

Act 2015 requires telecommunication service providers to retain for two years certain
telecommunications metadata prescribed by regulations. This two-year retention period
equals the maximum allowed under the earlier EU Data Retention Directive that the EU
Court of Justice ruled as invalid.
160
161
Mandated service restriction orders
Background
From time to time, mobile operators receive another. Freedom of expression, freedom of
orders from government authorities to assembly, freedom to conduct business and
restrict services on their networks. These other human rights can also be affected.
service restriction orders (SROs) require
operators to shut down or restrict access Individuals and businesses can also be
to their mobile network, network service or affected by an SRO, unable to pay friends,
Over The Top (OTT) service. Orders include suppliers or salaries. This can have a knock-
blocking particular apps or content, restricting on effect on credit and investment plans,
data bandwidth and degrading the quality ultimately damaging a country’s reputation
of SMS or voice services. In some cases, for managing the economy and foreign
operators would risk criminal sanctions investment and discouraging donor countries
or the loss of their licence if they disclosed from providing funds or other resources.
that they had been issued with an SRO.
MNOs also suffer. Not only do they sustain
SROs can have serious consequences. For financial losses from the suspension of
example, national security can be undermined services and damage to their reputation,
if powers are misused, and public safety can but their local staff can also face pressure
be endangered if emergency services and from authorities and possibly even
citizens are unable to communicate with one public retaliation.
Resources:
Australian Government Draft Guidelines on Website Blocking

Global Network Initiative and the Telecommunications Industry Dialogue Joint Statement:
Service Restrictions
Telia Company Form for Assessment and Escalation of SROs
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Industry position
The GSMA discourages the use of SROs. For example, rather than block an entire
Governments should only resort to SROs network or social media platform, it
in exceptional and pre-defined may be possible for the SRO to target
circumstances, and only if absolutely particular content or users. In any event,

necessary and proportionate to achieve the SRO should always specify an end
a specified and legitimate aim that is date. Independent oversight mechanisms
consistent with internationally recognised should be established to ensure these
human rights and relevant laws. principles are observed.
To aid transparency, governments should Operators can play an important role by

only issue SROs to operators in writing, citing raising awareness among government
the legal basis and with a clear audit trail to officials of the potential impact of SROs.
the person authorising the order. They should They can also be prepared to work swiftly
Mobile initiatives
inform citizens that the service restriction and efficiently to determine the legitimacy
has been ordered by the government and of the SRO once it has been received.
has been approved by a judicial or other This will help establish whether it has
authority in accordance with administrative been approved by a judicial authority,
procedures laid down in law. They should whether it is valid and binding and whether
allow operators to investigate the impacts there is opportunity for appeal, working
on their networks and customers and to with the government to limit the scope
communicate freely with their customers and impact of the order. Procedures
about the order. If it would undermine national can include guidance on how local
security to do so at the time when the service personnel are to deal with SROs and
is restricted, citizens should be informed as the use of standardised forms to quickly
soon as possible after the event. assess and escalate SROs to senior
company representatives.
Governments should seek to avoid or
mitigate the potentially harmful effects All decisions should first and foremost
of SROs by minimising the number of be made with the safety and security
demands, the geographic scope, the of the operators’ customers, networks
number of potentially affected individuals and staff in mind, and with the aim of
and businesses, the functional scope and being able to restore services as quickly
the duration of the restriction. as possible.
Consumer protection
Debate:
» What factors and alternatives should governments consider before planning an SRO?
» What tools and methods can be used to avoid the need for an SRO or to avoid
negative impacts if an SRO is the only option?
163
Mandatory registration of prepaid SIMs
Background
In a number of countries, customers of mobile and digital services that would

prepaid or pay-as-you-go (PAYG) services can not otherwise be available to them as
anonymously activate their subscriber identity unregistered users, including identity-linked
module (SIM) card simply by purchasing services such as mobile money, e-health
credit, as formal user registration is not and e-government services.
required. Some 150 governments around
the world21 have mandated prepaid SIM For a SIM registration policy to create
registration, citing a perceived but unproven positive outcomes for consumers, it must be
link between the introduction of such policies implemented in a pragmatic way that takes
and the reduction of criminal and anti-social local market conditions into account, such
behaviour. Mandated prepaid SIM registration as the ability of mobile operators to verify
is most prevalent in Africa, where 90 per cent customer IDs. If registration requirements
of UN-recognised states have such laws. are too onerous for a customer to meet,
mandating a SIM registration policy may
Some governments, including the Czech lead to implementation challenges and
Republic, UK and US, have decided unforeseen consequences. For example, it
against mandating registration of prepaid could unintentionally exclude vulnerable and
SIM users, concluding that the potential socially disadvantaged consumers or refugees
loopholes and implementation challenges who lack the required IDs. It might also lead
outweigh the merits. to the emergence of an underground market
for fraudulently registered or stolen SIM cards,
SIM registration can, however, allow driven by the desire of some mobile users,
many consumers to access value-added including criminals, to remain anonymous.
Resources:
GSMA Mandatory Registration of Prepaid SIMs website

GSMA Report: Access to Mobile Services and Proof of Identity
GSMA Policy Note: Enabling Access to Mobile Services for the Forcibly Displaced
GSMA Report: Mandatory Registration of Prepaid SIM Cards: Addressing Challenges through Best Practice
GSMA Report: Regulatory and Policy Trends Impacting Digital Identity and the Role of Mobile
21. GSMA. (2021). Access to Mobile Services and Proof of Identity.
164
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Industry position
While registration of prepaid SIM card users » Consult, collaborate and communicate
can deliver valuable benefits to citizens, with mobile operators before, during
governments should not mandate it. and after the implementation exercise.

To date, there has been no empirical evidence » Balance national security demands
that mandatory SIM registration directly leads against the protection of citizens’
to a reduction in crime. Where a decision rights, particularly where governments
to mandate the registration of prepaid SIM mandate SIM registration for security
users has been made, we recommend that reasons.
governments take into account global best
practices and allow registration mechanisms » Set realistic timescales for designing,
that are flexible, proportionate and relevant testing and implementing registration
to the specific market, including the level of processes.
Mobile initiatives
official ID penetration in that market and the
timing of any national identity roll-out plans. » Provide certainty and clarity on registration
requirements before any implementation.
If these conditions are met, the SIM
registration exercise is more likely to be » Allow and/or encourage the storage of
effective and lead to more accurate customer electronic records and design registration
databases. Furthermore, a robust customer processes that are administratively ‘light’.
verification and authentication system
can enable mobile operators to facilitate » Allow and/or encourage the SIM-registered
the creation of digital identity solutions, customer to access other value-added
empowering customers to access a variety mobile and digital services.
of mobile and non-mobile services.
» Support mobile operators in the
We urge governments considering the implementation of SIM-registration
introduction or revision of mandatory programmes by contributing to joint
SIM-registration to take the following communication activities and to their

steps prior to finalising their plans: operational costs.
Consumer protection
Debate:
» To what extent do the benefits of mandatory prepaid SIM registration outweigh
the costs and risks?
» What factors should governments consider before mandating such a policy?
165
Misinformation and disinformation
Background
It is important to distinguish between Through its work with the mobile industry,
misinformation and disinformation. the GSMA provides access to factual
Misinformation is information that is false but information, including independent
not created with the intent to cause harm. expert reports on EMF and health.
Disinformation is information that is false
and deliberately created to harm a person, In some countries, governments have used
social group, organisation or country. service restriction orders (SROs) to require
operators to shut down or restrict access
Mobile operators do not typically host to their mobile network or service or an
content, but they can nevertheless be Over The Top (OTT) service. Orders can
affected by false information. In particular, include blocking particular apps or content,
misinformation linking 5G and the COVID-19 restricting data bandwidth and degrading
pandemic has had direct consequences the quality of SMS or voice services. This
for the industry, such as attacks on can have consequences for customers and
telecommunications equipment and staff. society in general.
Resources:

GSMA EMF and Health Website
GSMA Report: Exploring Online Misinformation and Disinformation in Asia Pacific
GSMA Report: Safety, Privacy and Security across the Mobile Ecosystem
EU Code of Practice on Disinformation
WHO FAQ: Radiation: 5G Mobile Networks and Health
WHO Mythbusters: 5G Mobile Networks DO NOT Spread COVID-19
166
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Industry position
False information can have a harmful Awareness campaigns can also be used
impact on society. It can erode public to point citizens to trustworthy sources
confidence and distort perceptions of of information, equip them with tools
independently verifiable facts, leading to use technology safely and provide

to a lack of public trust in democratic a mechanism to report websites
processes and in institutions. It can containing false or harmful information.
also create or deepen tensions in
society by exploiting individual or Mobile operators continue to communicate
collective vulnerabilities. accurate information on their networks and
services to their customers.
Governments and policymakers should
explore appropriate countermeasures While governments and law enforcement
to false online information. The EU agencies have a legitimate mandate to
Mobile initiatives
Code of Practice on Disinformation, protect citizens, this sometimes leads
signed by online platforms, is an them to use powers that require mobile
example of organisations collaborating operators to block or restrict communication
to create an accountability mechanism services. Internet shutdowns should be
and opportunities to share information avoided or used only in very exceptional
and best practice. and predefined circumstances.
Consumer protection
Debate:
» Who determines whether information is true or false?
» What are the most effective mechanisms to deal with misinformation
and disinformation?
167
Mobile devices: counterfeit
Background
A counterfeit mobile device explicitly is now common for counterfeiters to hijack

infringes the trademark or design of IMEI number ranges allocated to legitimate
an original or authentic branded product, device manufacturers for use in their products,
even where there are slight variations which makes it more difficult to differentiate
to the established brand name. between authentic and counterfeit products.
Due to their illicit nature, these mobile Industry position

devices are typically shipped and sold on
shadow or underground markets globally by The mobile industry supports the need for
organised criminal networks. It is estimated legal and product integrity in the device
that almost one in five mobile devices may be market and is increasingly concerned about
counterfeit22. This has far-reaching negative the negative impact of counterfeit devices
impacts. Consumers risk lower quality, safety, on consumer welfare and society in general.
security, environmental health and privacy
assurances. Governments forego taxes and Although mobile operators and legitimate
duties and must contend with increased vendors cannot stop the production
crime. Industry players are also affected, as it and distribution of counterfeit devices,
can harm their trademarks and brands. multistakeholder collaboration can help
combat the issue at the source. National law
Some countries are considering introducing enforcement and customs agencies should
national lists of homologated (i.e. approved) take measures to stop the production and
devices to combat counterfeiting, smuggling exportation of counterfeit devices in their
and tax evasion. The purpose of homologated jurisdictions. Information on crime patterns
lists is to indicate which devices are permitted and specific criminal activity relating to
access to mobile networks. Operators add counterfeit devices must be provided by
device-blocking capabilities to their local national agencies to appropriate international
networks and connect with the national bodies, such as Interpol and the World
homologated list to ensure only permitted Customs Organization, to facilitate action
devices are allowed network access. by relevant agencies in other jurisdictions.
However, counterfeit mobile devices are not The GSMA has made its device information and
easy to identify and block, given that many device status services available for customs
have International Mobile Equipment Identity agencies and other industry stakeholders
(IMEI) numbers that appear legitimate. It to verify the authenticity of mobile device
Resources:
GSMA IMEI Services: The Global Source of IMEI Data

GSMA Device Check Platform
EUIPO-ITU Report: The Economic Cost of IPR Infringement in the Smartphones Sector
Spot a Fake Phone Website
22: According to figures from OECD, 2017
168
#BetterFuture
identities online. National customs agencies they are unnecessary – the subscriber
are advised to use these services as part of identities associated with each device can
a rigorous set of measures to monitor the be established by operators themselves.
importation of mobile devices.

Where national authorities are considering
The GSMA encourages operators to deploy introducing a system to block non-
systems like Equipment Identity Registers homologated devices, they should consider
(EIRs) and to connect to GSMA systems offering amnesty to consumers who already
like EIR with access to the GSMA Device own non-compliant devices. Blocking huge
Database. Using the GSMA global Type quantities of devices would not only be a
Allocation Code (TAC) list of all legitimate major loss for consumers, but would also
device identity number ranges, operators have significant social, economic and security
can block devices with invalid IMEIs. impacts. It is recommended that the funding
Mobile initiatives
model for such systems should not place a
National authorities should study which burden on consumers and mobile operators,
factors, such as import duties and taxation since they are not the cause of the underlying
levels, contribute to local demand for issue. National systems should also not be
counterfeit devices. The potential of reducing applied to roamers who might be denied
tax levels on devices to narrow the price service without cause.
gap between counterfeit/smuggled and
legitimate devices should be carefully
considered, as it could make the underground
market a less lucrative place to trade.
Implementing national lists of homologated

devices can be successful if they are linked
to the GSMA TAC list. National import
verification systems and national device
homologation systems should also be

linked to national lists of approved devices.
Some implementations propose that
customers register their details and devices
centrally. The GSMA does not support
central customer registrations because
Consumer protection
Debate:
» How can governments and other stakeholders best address the issue of
counterfeit mobile devices?
169
Mobile devices: theft
Policymakers in many countries are The mobile industry has led numerous
concerned about the incidence of mobile initiatives and made great strides in the
device theft, particularly when organised global fight against mobile device theft.
crime becomes involved in the bulk export
of stolen devices to other markets. Although the problem of device theft is not
of the industry’s creation, the industry is part
The GSMA has been leading industry of the solution. When lost or stolen mobile
initiatives to block stolen mobile devices devices are rendered useless they have
based on a shared database of the unique significantly reduced value, removing the
identifiers of devices reported lost or stolen. incentive for thieves to target them.
Using the IMEI of mobile devices, the GSMA
Device Registry maintains a central list, The GSMA encourages operators to
known as the GSMA Block List, of devices participate in its Device Registry Programme
reported lost or stolen by mobile customers. to report and block the IMEIs of devices
The GSMA Device Registry is available to flagged as stolen on the global Block List.
mobile operators around the world to Typically, operators deploy EIRs on their
ensure stolen devices transported to other networks to deny connectivity to flagged
countries are also denied network access. devices and share identifiers of devices from
their own local network’s block list to ensure
The effectiveness of blocking stolen devices devices stolen from their customers can be
on individual network EIRs depends on blocked on the networks of other participants.
the secure implementation of the IMEI These block list solutions have been in place
in all mobile devices. Leading device on some networks for many years.
manufacturers are encouraged to
support a range of measures to strengthen To enable a wider range of stakeholders to
IMEI security in accordance with combat device crime, the GSMA provides
GSMA-defined security requirements. services that allow eligible parties, such
as law enforcement, device traders and
insurers, to check the status of devices
against the GSMA Block List and, in
some cases, to also flag stolen devices.
Resources:
GSMA IMEI Services: The Global Source of IMEI Data

GSMA Device Registry
GSMA IMEI Security Technical Design Principles
GSMA Report: IMEI Security Weakness Reporting and Correction Process
GSMA Reference Document: Anti-Theft Device Feature Requirements GSMA Mobile Phone Theft:
Consumer Advice
170
#BetterFuture
IMEI blocking, when combined with other National authorities have a significant
multistakeholder measures, can be the role to play in combating criminal
cornerstone of a highly effective anti-theft activity. It is critical that they engage
campaign. constructively with the industry to

ensure the distribution of mobile devices
Consumers that have had their devices stolen through unauthorised channels is
are particularly vulnerable to their personal monitored and that action is taken
data being used to commit a range of against those involved in the theft or
additional crimes. Industry, law enforcement illegal distribution of stolen devices.
agencies and regulators are recommended
to provide anti-theft consumer education A coherent cross-border information-sharing
material on their websites with advice and approach involving all relevant stakeholders
measures appropriate to their market. makes national measures more effective.
Mobile initiatives
The GSMA advocates the sharing of stolen
The concept of a ‘kill switch’ – a mechanism device data internationally for blocking and
that disables a stolen phone remotely – status-checking purposes, which can be
has been developed for a range of devices. facilitated by the GSMA Device Registry and
The GSMA supports device-based anti-theft Device Check services. Only if regulation
features and has defined feature requirements allows stolen device information to be shared
for a globally applicable solution. These across all countries will this deterrent have
high-level requirements have set a benchmark a global impact.
for anti-theft functionality while allowing the
industry to innovate. In markets with a national homologated
list, lost and stolen device information can
The deployment of persistent endpoint be exchanged between mobile operators
security solutions on mobile devices can through the GSMA Device Registry.
also help render devices useless and Alternatively, if a national device block
unattractive to criminals by preventing list system is already in place, and complies
those devices from working on non-mobile with GSMA requirements, it may be

networks such as Wi-Fi where EIR blocking approved to use the GSMA Device Registry
would otherwise be ineffective. to exchange block list information.
Consumer protection
Debate:
» What can industry do to prevent mobile phone theft?
» What are the policy implications of this rising trend?
171
Mobile network and device security
Security attacks can impact all technology, The protection and privacy of customer
including mobile devices. Mobile operators communications are at the forefront of
use encryption technologies to deter criminals operators’ concerns. The mobile industry
from eavesdropping and intercepting traffic. makes every reasonable effort to protect
the privacy and integrity of customer and
The barriers to compromising mobile network communications.
security are high and research into
possible vulnerabilities has generally The GSMA leads a range of industry initiatives
been technically quite complex. While to make operators aware of the risks and
no security technology is guaranteed mitigation options available to protect their
to be unbreakable, practical attacks on networks and customers and its work is
mobile services are rare, as they tend to acknowledged by regulators around the
require considerable resources, including world as being sufficient to eliminate the
specialised equipment, computer processing need to formally regulate.
power and a high level of technical expertise
beyond the capability of most people. » The GSMA works with a wide group
of experts to facilitate an appropriate
Reports of eavesdropping are not uncommon, response to threats. We play a key role
but such attacks have not taken place on in coordinating the industry response to
a wide scale, and LTE and 5G networks security vulnerability research through its
are considerably better protected against Coordinated Vulnerability Disclosure
eavesdropping risks than GSM networks. (CVD) programme.
Moreover, 5G technology boasts a host
of new security capabilities that further » The GSMA’s Telecommunication Information
enhance protection levels. Sharing and Analysis Centre (T-ISAC)
collects and disseminates information
and advice on security incidents within
the mobile community in a trusted and
anonymised way. The GSMA has also
conducted a comprehensive threat
Resources:
GSMA Security Accreditation Scheme Website

GSMA Network Equipment Security Assurance Scheme
GSMA Security Advice for Mobile Device Users Website
GSMA Coordinated Vulnerability Disclosure Website
GSMA T-ISAC Website
172
#BetterFuture
analysis involving industry experts from » The GSMA supports global security
across the ecosystem, regulators as well standards for emerging services and
as public sources such as 3GPP, the acknowledges the role that SIM-based
European Union Agency for Cybersecurity secure elements have played in protecting

(ENISA) and the National Institute of customers and mobile services because
Standards and Technology (NIST) and the SIM card has proven itself to be
mapped these threats to appropriate and resilient to attack. The Embedded
effective security controls. This analysis Universal Integrated Circuit Card (eUICC)
has been collated into a 5G Cybersecurity approach used in eSIM solutions that
Knowledge Base providing useful guidance has been defined by the GSMA and
on a range of 5G security risks and has been rolled out by industry inherits
mitigation measures. the best security properties from the
SIM and is designed to build on the
Mobile initiatives
» The GSMA’s Fraud and Security Group protection levels achieved in the past.
acts as a centre of expertise to drive
the industry’s management of fraud » The GSMA constantly monitors the
and security matters. The group seeks activities of hacker groups, as well as
to maintain or increase the protection researchers, innovators and a range of
of mobile operator technology and industry stakeholders, to improve the
infrastructure, and customer identity, security of communications networks.
security and privacy, so that the industry’s Our ability to learn and adapt can be
reputation stays strong and mobile seen in the security improvements
operators remain trusted partners in implemented from one generation
the ecosystem. of mobile technology to the next.
» The GSMA’s 5G Cybersecurity Knowledge

Base makes available the combined
knowledge of the 5G ecosystem to
increase trust in 5G networks and make the

interconnected world as secure as possible.
Debate:
Consumer protection
» How secure are mobile voice and data technologies and what is being done
to mitigate the risks?
» Do emerging technologies and services create new opportunities for criminals?
» What will the 5G security landscape look like?
173
Number resource misuse and fraud
Background
Many countries have serious concerns main focus is to drive industry management of
about number resource misuse or calls mobile fraud and security matters to protect
that never reach the destination indicated operators and consumers and safeguard the
by the international country code. These mobile industry’s trusted reputation.
calls are instead terminated prematurely,
through carrier and/or content provider The Fraud and Security Group supports EU
collusion, to revenue-generating content guidelines under which national regulators can
services without the knowledge of the instruct communications providers to withhold
ITU-T assigned number-range holder. payment to downstream traffic partners in
cases of suspected fraud and misuse.
This abuse puts such calls outside any
national regulatory controls on premium-rate The group believes that national regulators
and revenue-share call arrangements and can help communications providers
is a key contributing factor to International reduce the risk of number resource
Revenue Share Fraud (IRSF) perpetrated misuse by enforcing stricter management
against telephone networks and their of national numbering resources.
customers. Perpetrators of IRSF are Specifically, regulators can:
motivated to generate incoming traffic to
their own services with no intention of » Ensure national numbering plans are easily
paying the originating network for the calls. available, accurate and comprehensive.
They then receive payment quickly, long
before other parties, within the settlement » Implement stricter controls over the
process. Misuse also affects legitimate assignment of national number ranges
telephony traffic, as high-risk number to applicants and ensure the ranges
ranges can be blocked as a side effect. are used for the purpose for which
they have been assigned.
Industry position
» Implement stricter controls over leasing
Number resource misuse has a significant of number ranges by number-range
economic impact on many countries, so assignees to third parties.
multistakeholder collaboration is key.
The Fraud and Security Group shares abused
The telecommunications fraud carried out as number ranges among its members and with
a consequence of number resource misuse other fraud management industry bodies.
is one of the topics being addressed by the It has also worked with leading international
GSMA Fraud and Security Group, a global transit carriers to reduce the risk of fraud that
conduit for best practice with respect to arises as a result of number resource misuse,
fraud and security management for mobile and with law enforcement agencies to support
operators. The Fraud and Security Group’s criminal investigations in this area.
Resources:
ITU-T Notification of Possible Misuse of E.164 Resources Website
174
#BetterFuture
Best practice
Recommended operator controls to reduce exposure to fraud from number resource misuse
» Implement controls at the point of subscriber acquisition and controls to prevent

account takeover.
» Remove the conference or multi-call facility from a mobile connection unless specifically
requested, as fraudsters can use this feature to establish up to six simultaneous calls.
» Remove the ability to call forward to international destinations, particularly to countries

whose numbering plans are commonly misused.
» Use the High-Risk Number List available from the GSMA Fraud Intelligence Service, so that
Mobile initiatives
unusual call patterns to known fraudulent destinations can raise alarms or be blocked.
» Ensure roaming usage reports received from other networks are monitored 24x7,
preferably through an automated system.
» Ensure that up-to-date tariffs, particularly for premium numbers, are applied within
roaming agreements.
» Implement the Barring of International Calls Except to Home Country (BOIC-exHC)
function for new or high-risk subscriptions.

Consumer protection
Debate:
» How can regulators, number-range holders and other industry players collaborate
to address this type of misuse and fraud?
175
Signal inhibitors (jammers)
Background
Signal inhibitors, also known as jammers, Moreover, signal inhibitors do not prevent
are devices that generate interference mobile devices from connecting to Wi-Fi
or otherwise intentionally disrupt networks because they do not affect the
communications services. In the case frequency bands used by Wi-Fi routers.
of mobile services, they interfere with As a result, signal inhibitors do not block
communication between the mobile people from using Over The Top (OTT) voice
terminal and the base station. Their applications to make calls to phone networks.
use by private individuals is banned in
countries such as Australia, the UK and US. Mobile operators provide coverage
and capacity by investing heavily in
In some regions, such as Latin America, the installation of radio base stations.
signal inhibitors are used to prevent the However, the indiscriminate use of
illegal use of mobile phones in specific signal inhibitors compromises these
locations, such as prisons. However, investments by causing extensive
blocking the signal does not address the disruption to the operation of mobile
root cause of the problem: wireless devices networks, reducing coverage and
illegally ending up in the hands of inmates leading to the deterioration of service
who then use them for illegal purposes. for consumers.
Resources:
GSMA Common Position Proposal on Signal Inhibitors (Jammers) in Latin America

GSMA Report: Signal-Blocking Solutions: Use of Jammers in Prisons
176
#BetterFuture
Industry position
In some Latin American countries, such via numbers such as 999, 911 or 112, and they
as Colombia, El Salvador, Guatemala and can interfere with the operation of mobile-
Honduras, governments are promoting connected alarms or personal health devices.
the deployment of signal inhibitors to

limit the use of mobile services in prisons. The industry’s position is that signal inhibitors
The GSMA and its members are committed should only be used as a last resort and only
to working with governments to use deployed in coordination with operators.
technology to help keep mobile phones This coordination must continue for the
out of sensitive areas, and to cooperating total duration of the deployment of the
on efforts to detect, track and prevent devices, from installation through to
the use of smuggled devices. deactivation, to ensure that interference is
minimised in adjacent areas and legitimate
It is vital that a long-term, practical mobile phone users are not affected.
Mobile initiatives
solution is found that does not have
a negative impact on legitimate users, Furthermore, to protect the public interest
nor affect the substantial investments and safeguard the delivery of mobile services,
that mobile operators have made to regulatory authorities should ban the use
improve their coverage. of signal inhibitors by private entities and
establish sanctions for private entities that use
The nature of radio signals makes it virtually or commercialise them without permission
impossible to ensure that the interference from relevant authorities. The import and sale
generated by inhibitors is confined, for of inhibitors or jammers must be restricted to
example, within the walls of a building. those considered qualified and authorised to
Consequently, the interference caused by do so and their operation must be authorised
signal inhibitors affects citizens, services by the national telecommunications regulator.
and public safety. It restricts network
coverage and has a negative effect on Nevertheless, strengthening security to
the quality of services delivered to mobile prevent wireless devices being smuggled
users. Inhibitors also cause problems for into sensitive areas such as prisons is the
other critical services that rely on mobile most effective measure against the illegal
communications. For example, during an use of mobile devices in these areas, as it
emergency they could limit the ability of would not affect the rights of legitimate
mobile users to contact emergency services users of mobile services.
Debate:
Consumer protection
» Should governments or private organisations be allowed to use signal inhibitors

that interfere with the provision of mobile voice and data services to consumers?
» Should the marketing and sale of signal inhibitors to private individuals and
organisations be prohibited?
177
Appendix
GSMA Intelligence Powerful data tools
GSMA Intelligence is an extensive and Information in GSMA Intelligence is made
growing resource for GSMA members, easy to use by a range of data selection
associate members and other organisations tools: multifaceted search, rankings, filters,
interested in understanding the mobile dashboards, a real-time data and news feed,
industry. Through industry data collection as well as the ability to export data into Excel
and aggregation, market research and and add graphs and charts to presentations.
analysis, GSMA Intelligence provides a
valuable view of the mobile industry, and the The global unique subscriber base grew by
wider mobile ecosystem, around the globe. 1.7 per cent in the previous 12 months. This
growth is forecast to continue at a similar
Global coverage rate until 2025. Growth is far from uniform
GSMA Intelligence publishes data and around the world and is largely driven by
insights spanning 240 markets and 900 LMICs, which are forecast to add 360 million
mobile network operators. Comprising subscribers over the next six years, compared
more than 30 million individual data points, to only 28 million new additions in high-
GSMA Intelligence combines historical income markets over the same period.
and forecast data from the beginnings
of the industry in 1979 with forecasts out Unique subscriber penetration rates vary
to 2030. New data is added every day. significantly across regions. Europe has
the highest penetration rate on average,
Numerous data types followed by North America and the
The data includes metrics on mobile Commonwealth of Independent States
subscribers and connections, operational and (CIS). Sub-Saharan Africa had the lowest
financial data, and socio-economic measures penetration rate in 2021 at 46 per cent of
that complement the core data sets. Primary the population, despite having the fastest
research conducted by the GSMA adds insight subscriber growth of any region over the
to more than 7,000 network deployments to past decade.
date. White papers and reports from across
the GSMA and weekly bulletins are also https://gsmaintelligence.com
available as part of the service. info@gsmaintelligence.com
178
Figure 17 Unique subscriber penetration by region
A Unique subscriber penetration by region B Smartphone adoption by region

70% 74%
73% 80%
Latin America Latin America
68% 74%
70% 85%
Asia-Pacific Asia-Pacific
67% 72%
69% 82%
World World
47% 52%
50% 63%
Sub-Saharan Africa Sub-Saharan Africa
85% 70%
86% 73%
North America North America
81% 74%
82% 85%
Commonwealth of Independent States Commonwealth of Independent States
64% 68%
67% 79%
Middle East and North Africa Middle East and North Africa
86% 80%
87% 84%
Europe Europe
2021 2025
179
Figure 18 Global connection trends
9bn
8bn
7bn
6bn
5bn
4bn
3bn
2bn
1bn
2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025
Total mobile connections Unique mobile subscribers Mobile broadband connections
GSMA Intelligence forecasts that between will continue as operators expand the
2022 and 2025, mobile operators will grow coverage and capacity of their networks.
annual revenues by 1.1 per cent CAGR to GSMA Intelligence forecasts that the total
reach $1.14 trillion. Slowing subscriber number of IoT connections (cellular and
growth, coupled with declining levels of non-cellular) globally will reach 23.4 billion
ARPU, are the main factors driving this trend. in 2025, and rise to 37.5 billion by 2030.
Between 2022 and 2025, mobile operators While IoT is rapidly becoming a
around the world will spend $745 billion on mainstream technology in consumer
CapEx, compared to $788 billion over the markets (for consumer electronics
preceding four years. While 5G is already and smart home devices), enterprise
available across most of the world’s largest IoT will be the largest source of
economies, spending on the technology connections growth in the future.
180
Figure 19 Total IoT connections, 2010 – 2025
40bn
35bn
30bn
25bn
20bn
15bn
10bn
5bn
0bn
10
12
13
23
14
15
16
17
18
19
20
21
22
23
24
23
24
25
23
24
25
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
The Internet of Things defined require mobility, lower latency and ultra-
GSMA Intelligence defines IoT devices reliability will primarily be connected by
as those capable of two-way data cellular networks using licensed spectrum.
transmission (excluding passive sensors Cellular networks address the need for more
and radio frequency identification, secure, managed connectivity, allowing
or RFID tags). It includes connections devices to connect directly to the cloud
using multiple communication methods, (as opposed to a gateway). Managed
such as cellular and short-range connectivity. connectivity will be one of the key drivers
It excludes PCs, laptops, tablets, e-readers, of growth. Licenced LPWA networks enable
data terminals and smartphones. a slew of IoT devices that require longer
battery life and lower data throughputs
Most IoT devices, typically in indoor to be connected. Currently, there are nearly
environments, will be connected by 150 licensed LPWA networks around the
unlicensed radio technologies designed world. GSMA Intelligence forecasts that by
for short-range connectivity. These 2025, licensed cellular networks will serve
include technologies such as Wi-Fi, 4.1 billion IoT connections globally or 17 per
Z-Wave and ZigBee. IoT devices that cent of all IoT connections.
181
Mobile Policy
Handbook
GSMA
2nd Floor
The Walbrook Building
25 Walbrook
London
EC4N 8AF
Tel: +44 (0)20 7356 0600
Fax: +44 (0)20 7356 0601
Copyright © 2022 GSM Association

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Mobile Policy

The GSMA is a global organisation unifying

We invite you to find out more at

Follow the GSMA on Twitter: @GSMA

Can you take a position?

Will you lead the debate?

5G networks will be at the core of this next-

Mobile for Development

Mobile for Development 12

GSMA Capacity Building

Mobile for Humanitarian Innovation (M4H) 16

GSMA Capacity Building 20

5G: reaping the benefits 28

Voice over LTE 32

Internet of Things (IoT) 33

Advanced air mobility 34

Privacy and data protection for IoT 38

Smart cities and IoT 40

Policies for progress 50

Deeper dive: Recommendations for resetting

Efficient mobile market structures 58

Intellectual property rights: patents 66

International mobile roaming 68

Mobile termination rates 70

Passive infrastructure providers 76

Single wholesale networks 82

Universal service funds 90

The evolution of spectrum: to 2030 and beyond 94

Planning spectrum: 2025–2030 98

Spectrum harmonisation 100

Coexistence of technologies 104

Spectrum licensing 106

Spectrum licence renewal 108

Spectrum sharing, leasing and trading 110

Technology neutrality 112

Spectrum assignment 114

Spectrum pricing 118

Spectrum for industries 120

Wireless backhaul spectrum 124

Children and mobile technology 130

Mobile for Development

Cross-border data flows 134

Deeper dive: Localisation rules 136

Data privacy 138

GSMA Capacity Building

Privacy and big data 142

Electromagnetic fields and health 144

Deeper dive: Advanced antenna technologies 147

Deeper dive: A global look at mobile network

Internet governance 154

Mandated government access 156

Case study: National regulatory approaches to

Mandated service restriction orders 162

Mandatory registration of prepaid SIMs 164

Misinformation and disinformation 166

Mobile devices: counterfeit 168

Mobile devices: theft 170

Mobile network and device security 172

Number resource misuse and fraud 174

Signal inhibitors (jammers) 176

The mobile industry is united behind a remain the only form

The GSMA 2021 Mobile Industry Impact Report: SDGs

1. GSMA. (2021). The Mobile Economy 2021.

GSMA Connected Society Website

Mobile for Development 12

Mobile for Humanitarian Innovation (M4H) 16

GSMA Capacity Building 20

Voice over LTE 32

Internet of Things (IoT) 33

Advanced air mobility 34

Privacy and data protection for IoT 38

Smart cities and IoT 40

Policies for progress 50

Deeper dive: Recommendations for resetting

Efficient mobile market structures 58

Intellectual property rights: patents 66

International mobile roaming 68

Mobile termination rates 70

Passive infrastructure providers 76

Single wholesale networks 82

Universal service funds 90

The evolution of spectrum: to 2030 and beyond 94

Planning spectrum: 2025–2030 98

Spectrum harmonisation 100

Coexistence of technologies 104

Spectrum licensing 106

Spectrum licence renewal 108

Spectrum sharing, leasing and trading 110

Technology neutrality 112

Spectrum assignment 114

Spectrum pricing 118

Spectrum for industries 120

Wireless backhaul spectrum 124

Children and mobile technology 130

Cross-border data flows 134

Deeper dive: Localisation rules 136

Data privacy 138

Privacy and big data 142

Electromagnetic fields and health 144

Deeper dive: Advanced antenna technologies 147

Deeper dive: A global look at mobile network

Internet governance 154

Mandated government access 156

Case study: National regulatory approaches to

Mandated service restriction orders 162

Mandatory registration of prepaid SIMs 164

Misinformation and disinformation 166

Mobile devices: counterfeit 168

Mobile devices: theft 170

Mobile network and device security 172

Number resource misuse and fraud 174

Signal inhibitors (jammers) 176