This report provides an overview of the transparency and comparability of retail roaming tariffs. In July 2020, BEREC sent a questionnaire to operators and National Regulatory Authorities (NRAs) in order to gather information for the period September 2019 to July 2020 on two aspects that are key issues for customers when selecting tariffs for international roaming services: Firstly, transparency, meaning the availability of clear information about prices and conditions for each tariff, as well as simple procedures for customers to switch between tariffs; and secondly, comparability of tariffs. International Roaming Tariffs

By comparability, BEREC means the ability for customers to compare different types of tariffs offered by operators and to select the one best suited to their needs and patterns of consumption.
Transparency is key to enabling customers to make informed decisions.

Switch between roaming tariffs quickly and conveniently International Roaming Tariffs

According to Regulation (EU) No 531/2012 on roaming on public mobile communications networks within the Union as amended by the TSM Regulation 2015/2120 and Regulation 2017/920, (hereafter “Roaming Regulation”) and the Commission Implementing Regulation 2016/2286 (hereafter “CIR”) customers should have easy access to understandable information on prices and conditions for each existing roaming tariff including its Fair Use Policy (FUP) if applicable. According to the Roaming Regulation, it should also be possible to switch between roaming tariffs quickly and conveniently. BEREC has collected information on the structure of international roaming tariffs.
In view of the application of FUPs, BEREC found that roaming providers make use of all kinds of FUP laid down in the CIR. It is worth noting, that limiting roaming data volumes according to the provisions for open data bundles is the most used policy.
With regard to alternative tariffs in addition to regulated roaming tariffs, around 30 % of the responding operators said that they offer alternative roaming tariffs. According to the answers received, BEREC has also noted that roaming providers in addition to the EEA also include non-EEA destinations in their RLAH tariff plans. BEREC intends to analyze under which conditions non-EEA countries are included in RLAH tariff plans in further transparency and comparability reports.
Finally, on the structure of roaming tariffs, this year’s evaluation confirmed the findings of previous years concerning tariffs without roaming. Mainly data only and fixed mobile convergence plans do not include roaming options due to the fact that in general a high domestic data volume is granted in those tariffs.

Regarding the availability of 4G data roaming services, 41 % of the operators stated that they offer 3G roaming services in the EU/EEA even where 4G would be available and 13 % of those operators are not planning to provide 4G roaming services by the end of 2020 or don’t have any plans at all. International Roaming Tariffs

With regard to 5G, BEREC observes that operators start implementing 5G across Europe, however the speed of implementation varies between Member States and operators. Yet, there is no nation-wide 5G coverage in any of the Member States. Therefore, it is too early to draw any conclusions about 5G and roaming.
When BEREC asked whether NRAs had received consumer complaints about roaming, 81 % of the responding NRAs said that they had received complaints on roaming issues. This is almost the same compared to the previous reporting period. However, there has been a decrease in the total number of registered complaints of around 45 %. The categories of complaints that are most frequent are still end-users that inadvertently roam on a non-EU network while remaining on EU territory and about roaming when being on board of planes and ships, which is not covered by the Roaming Regulation. However, the number of NRAs that have received such complaints has decreased since the previous report.
In specific and exceptional circumstances in order to ensure the sustainability of its domestic charging model, roaming providers may apply for authorisation to apply a surcharge in the case that they are not able to recover their overall actual and projected costs of providing regulated roaming services in accordance with the Roaming Regulation.
According to the answers received by BEREC, a total amount of 21 applications for sustainability surcharges have been received for the period 1 September 2019 to 31 July 2020. Out of these 21 applications, 16 were granted. In this year’s survey, a small share of roaming providers (6 %) said that they charge surcharges based on the derogation
mechanism. It seems that after a certain acclimatization phase of the RLAH principle with large numbers of applications, RLAH is no longer a threat to the domestic charging models of most of the mobile providers.
BEREC asked operators if they informed customers about the FUP applied in its “Welcome SMS”. 82 % of the operators that apply a FUP provide information about it in the “Welcome SMS”.
Regarding the opportunity to switch between tariffs, providers reported that they mainly informed their customers via call centres or through information on their website or in the contract.

Another question dealt with the information provided by operators to end-users about the FUP. 75 % of the roaming providers who implemented a FUP inform their customers about how the fair use limit is calculated. 98 % of the roaming providers state that they provide information about the actual roaming limit. This is about the same level as in the previous period.
The most commonly requested means of proof by roaming providers who have implemented stable link criteria are: A presentation of any valid document which proves that the person falls into one of the categories of stable links (68 %), details of the customer’s address and/or details showing the provision of any other services to them at the given address (e.g. a utility bill) (52 %) and a declaration by the customer (51 %).
The data collected for this report shows that a few NRAs or consumer associations provide tariff comparisons. 24 % of the responding NRAs reported that they featured information on their website comparing domestic tariffs including intra-EEA roaming provided by different operators.

Guidance for customers to estimate data traffic and tools to select a tariff

The major factor determining the price of tariffs offered to customers is the volume of data included in the package. Therefore, it is important that customers can estimate their capacity needs in order to be able to make an informed choice. Any tool estimating future data usage is supposed to help customers choose the most suited tariff.
In order to review the availability of any resources which aids informed decisions making BEREC asked whether consumer associations and operators offer information, applications or other tools to estimate the consumption of data services and to decide which kind of tariff to select based on given estimated consumption.
34 % of the responding operators confirmed that they provided end-users with information on how to estimate data services consumption based on the use of Internet services such as web browsing, e-mails, and specific applications such as Google Maps or WhatsApp. International Roaming Tariffs

15 % of the responding operators confirmed that they provided applications to help consumers to select the most adequate tariff, including intra-EU roaming based on their estimation of consumption.
As the above numbers show only a minority of providers actually have interactive tools where the customers’ consumption patterns are the starting point for selecting the most adequate tariff. Most likely, the demand for this type of service is not sufficient to attract operators to introduce them due to the wide availability of consumption history for the customers and also a range of external comparison engines throughout the internet.