The MVNO Europe association has urged the European Commission to ensure that the upcoming Digital Networks Act (DNA) finally establishes a true Single Market for mobile connectivity, M2M/IoT, and Connected Vehicles. The organization — which groups virtual mobile operators (MVNOs) active in both B2C and B2B in various Member States — believes that the new framework should strengthen effective competition, guarantee non-discrimination in wholesale access, and eliminate the cross-border barriers that currently hinder pan-European services.
What MVNO Europe requests the DNA to include
The MVNOs’ proposal is based on three pillars of the European Electronic Communications Code (EECC) that, in their view, the DNA should preserve and strengthen:
- Significant Market Power (SMP) regime. Maintain the ability to apply SMP remedies to any market, including the mobile market, to prevent abuse of dominant position and ensure effective competition.
- Wholesale access linked to spectrum licenses. Preserve the authority of national regulators to impose wholesale access when issuing spectrum licenses, fostering diversity of offers and innovation while optimizing the use of a public resource.
- Pan-European non-discriminatory operation. Enable all MVNOs (B2B and B2C) to operate efficiently across the EU without facing discrimination in the wholesale market. In this context, the association requests strengthening of Article 52 of the EECC, so authorities can impose non-discriminatory access obligations during frequency allocations.
Clear Definitions and “Permanent Roaming” for Industrial IoT and Vehicles
Regarding the deployment of M2M, IoT, and connected vehicles, MVNO Europe advocates that the DNA:
- Introduce clear definitions for M2M, IoT, and Connected Vehicles to avoid regulatory ambiguities and ensure consistent application across the EU.
- Establish an explicit obligation for visited mobile operators to facilitate permanent roaming in industrial, IoT, M2M, and connected vehicle applications. The goal: enable a true pan-European operation, boost industrial competitiveness, and reinforce digital sovereignty.
- Guarantee connection to multiple radio access networks through dynamic switching (multi-RAN), promoting resilience, service continuity, and freedom of choice for industrial clients.
Why it matters: From Connected Workshops to Smart Vehicles
The European industry is deploying sensors, robots, connected production lines, logistics fleets, and telematic platforms that require seamless cross-border and predictable connectivity. Without clear permanent roaming and guaranteed multi-RAN, manufacturers of connected vehicles or industrial equipment are forced to fragment their services by country, renegotiate access agreements, and duplicate integrations. The result: less resilience, higher costs, and slower go-to-market times.
For B2B MVNOs—which already operate SIM/eSIM profiles, multi-IMSI arrangements, and management platforms across multiple countries—the DNA is an opportunity to standardize practices and harmonize wholesale rights that currently depend on each country’s regulator and host operator. For the end consumer, increased wholesale competition usually translates into more tariff options and more tailored services.
Competition and sovereignty: Two sides of the same coin
MVNO Europe emphasizes that competition among diverse providers (MNOs and MVNOs) is the driver of innovation and efficiency necessary for the EU to maintain its global competitiveness. Digital sovereignty is not only achieved through data centers or chips; it also requires access rules that allow pan-European actors to offer continuous services across the internal market and avoid country-by-country lock-in.
What can change with the Digital Networks Act
The DNA presents a legislative opportunity to adjust and complete the EECC framework where practical gaps have emerged. If the Commission adopts MVNO Europe’s proposals, the new framework could:
- Create legal certainty for permanent IoT and automotive roaming.
- Reinforce wholesale non-discrimination in spectrum allocations.
- Deploy multi-RAN dynamic switching mechanisms as standard practice for resilience.
- Enable MVNOs to act as true pan-European operators without regulatory frictions at the national level.
The challenge, as always, will be in implementation: ensuring national authorities apply the new principles consistently and that BEREC provides clear guidelines to prevent divergent interpretations.
Frequently Asked Questions
What is an MVNO, and how does it differ from an MNO?
A MVNO (virtual mobile network operator) offers mobile services without its own spectrum or radio network; it purchases wholesale access from one or multiple MNOs and competes in retail or B2B/IoT services.
What does “permanent roaming” in IoT mean?
It refers to the continuous use of a visited mobile network in another EU country for industrial/IoT devices, rather than sporadic connections like a traveler. It enables managing fleets or pan-European equipment without switching profiles or contracts country to country.
Why is multi-RAN dynamic switching relevant for IoT/vehicles?
Because it allows a device to switch networks automatically based on coverage, quality, or incidents, enhancing resilience and service continuity in critical environments.
What role does the SMP regime play in mobile?
It enables regulators to impose remedies (such as access obligations) when an operator holds significant market power, preventing
source: MVNO Europe