Questions to the Thai telecom regulator NBTC regarding MVNO in Thailand

Questions to the Thai telecom regulator NBTC on 10 topics regarding MVNA and MVNO in Thailand.

Thailand’s telecom regulator recently announced that its leadership had meet with some of the representatives from the mobile network operators to exchange information. There has however not been any similar meetings with the MVNOs in the country…yet!

1. As a follow up on the last public hearing, comments and suggestions regarding MVNA/MVNOs, four years ago (July/August 2019).

• Has any of the suggestions been implemented?
• If so, which – and has these suggestions delivered results?
• What has the NBTC done to monitor and follow up (actions points)?

2. As a follow up on the revision to the Mobile Virtual Network Mobile Phone Service Notification B.E. 2556 (2013) – added to the Government Gazette: Book Number: 137, Section: 172 on July 20, 2020.

The revision was said to be “in order to be consistent with the current situation, support free and fair competition and promote fair entry for smaller entrepreneurs, to increases the level of competition in the Thai mobile market and give users an opportunity to access more service”.

• Did the revision result in promoting fair entry?
• Did the revision result in the level of competition increasing in the market?
• Did the revision result in more MVNOs and give users access to more services?
• Has the NBTC done workshops and events with MVNO as subject – similar to its promotions on 5G?

3. Since the first spectrum licenses rewarded in Thailand (2012), there has been a clause in the license terms where the license holder must provide at least 10% of its capacity to MVNA/MVNOs. However, no MVNA/MVNO has ever managed to get access to any of the spectrum license holders capacity.

• The issues has been raised over the last decade but with no results. What other measures does the NBTC have in their toolbox to make this happen?
• At the public hearing in 2019, the NBTC showed a dated retail minus example from Poland. Has the NBTC updated the already dated example to reflect the current usage pattern (data more than voice) and does the NBTC have plans to introduce any measures regarding wholesale pricing?
• How does the NBTC monitor and measure the current wholesale pricing, connections, active subscribers, capacity usages, retail pricing of MVNOs and their host operator in Thailand?
• Has the NBTC ever done any test on wholesale margin squeeze?

4. Given that National Telecommunications (NT), the only mobile network operator to give access to MVNA/MVNOs in Thailand, has to return their 850MHz, 2100MHz and 2300MHz spectrum to the NBTC by 2025 – How will the NBTC secure the current and coming MVNA/MVNOs access?

• How much MVNA/MVNO capacity is available today and after NT’s return of spectrum?
• How will the NBTC secure enough capacity to MVNA/MVNOs on NT/AIS’ 700MHz deal?
• How will the NBTC secure that MVNA/MVNOs can offer 5G services to their clients/end-users?

5. As part of the TRUE/DTAC merger, the NBTC set forth a couple of conditions involving MVNO and wholesale.

• What is the status of these conditions?
• Is there a timeline/progress report on each of these conditions?
• How does the NBTC monitor these conditions?
• Given the 12% reduction in retail pricing has the NBTC used this for the calculation on retail minus wholesale pricing as well?
• How much MVNA/MVNO capacity is available at the separate MVNO business setup on the merger?
• Are their any conditions attached to TRUE/DTAC’s sub-brand “Finnmobile”?
• Is TRUE/DTAC’s sub-brand “Finn Mobile” paying license fees like everyone else?
• When calculating the average retail price has the NBTC included the price of “Finn Mobile”?

6. It has been more than a decade with limits on which type of model and network elements a MVNA/MVNO can have in Thailand, i.e. it is only possible to be a “Thin MVNO” or “Medium MVNO”. The limitations has proven to be a barrier to entry and resulted in only a few MVNOs launching with no – to low innovation on services or promotions.

• When will the NBTC allow “Full MVNO” in Thailand and allow the MVNA/MVNO to invest in more network elements to be able to control their own business and provide innovative services?

7. The NBTC introduced a maximum retail pricing cap in the market with lower prices on 4G services than 3G, and also changed from charging voice calls per minute to seconds. The construction of a new unified tariff regulation scheme has been underway for a long time. This transition should result in a regulation policy that corresponds to the current economic state and the convergence of technologies.

• What is the status of the unified tariff regulation scheme?
• What is the maximum retail pricing on 5G?
• Which measures has the NBTC introduced on those who have not adhered to the maximum pricing cap, i.e. some MVNOs are pricing the services above the maximum price cap?
• Which measures has the NBTC introduce to deal with charging voice per seconds instead of minutes?
• Why are the operators still allowed to charge per minute?

8. In line with Thailand’s entry in to the Association of Southeast Asian Nations (ASEAN), it was announced that acts, regulations and notification should be made available in English language as well. In addition to the interest from foreign companies interested in investing in a possible setup in Thailand.

• When will the NBTC be ready with the English versions of regulation, applications, notification, acts, etc. on MVNO and related regulation i.e. Interconnection fees, mobile number portability, roaming, IoT/M2M, IMSI range fees, etc.?

9. The mobile number portability (MNP) setup in Thailand includes AIS, DTAC, TRUE and NT.

• How can the MVNOs be better included in the MNP instead of having to go through NT?
• When will the NBTC numbering bureau start to report quarterly mobile number port-ins and out like in other markets?

10. NBTC’s numbering bureau stopped reporting active SIMs per operator and MVNOs prior to the merger of TRUE/DTAC.

• When can the public expect to get this data and information again?