Since RLAH came into force on 15 June 2017, roaming providers must inform subscribers about the fair use policies implemented in their tariffs and about the conditions for any alternative tariff chosen by end-users. International Roaming tariffs

Such an awareness, together with policies and instruments which allow customers to estimate their consumption and compare international roaming tariffs, will allow customers to make better informed decisions.

In July 2019, BEREC sent a questionnaire to operators and National Regulatory Authorities (NRAs) in order to gather information for the period July 2018 to August 2019 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, the comparability of tariffs.

Transparency is key to enabling customers to make informed decisions. According to the Regulation (EU) No 531/2012 on roaming on public mobile communications networks within the Union as amended by the TSM Regulation, (hereafter “Roaming Regulation”), customers should have easy access to understandable information on prices and conditions for each existing roaming tariff including its fair use policy if applicable. According to the Roaming Regulation, it should also be possible to switch between roaming tariffs quickly and conveniently.

With regard to the different types of roaming tariffs that are offered by operators, the report shows
that 45 % of the responding operators include non-EEA destinations in some of their RLAH offers, which is beneficial for the customers as they can use mobile services in more countries under the same conditions as at home.
The survey shows that Switzerland, Monaco, Andorra and Faroe Islands are the non-EEA destinations most frequently being included into RLAH offers. Around 30 percent of the responding operators offer alternative roaming tariffs and this is most common in the business segment.

Regarding availability of 4G data roaming services, 46 % of the operators stated that they offer 3G roaming services in the EU/EEA even where 4G would be available and 61 % of those operators that only offer 3G services despite 4G being available are not planning to provide 4G roaming services by the end of 2019 or don’t have any plans at all.
Half of the roaming providers offer tariffs without roaming and 2 % of operators answered that they withdrew roaming services from at least one tariff plan after 1 July 2018. However, according to the results of the BEREC IR Benchmarking Report, those tariffs are not obtained by a significant number of subscribers.

General structure of international roaming tariffs

Some operators included a wide range of non-EU/EEA countries in their RLAH offers, however, most of the operators focus on a few neighbouring countries. The most frequently mentioned country was Switzerland, followed by Monaco, Andorra and Faroe Islands.

Compared to last year’s report, the number of operators that included non-EU/EEA destinations in their offers is nearly unchanged. Some operators also included the United States of America, Canada and Turkey in their RLAH tariffs. Only a few operators advertise RLAH tariffs with countries like Australia, China and Russia.

BEREC has collected information on the type of packages offered as alternative roaming tariffs (whether they are daily, weekly, monthly or other tariffs).

Of all responding operators which offer alternative roaming tariffs, 23 % of operators offer such a tariff in the form of daily packages, 16 % in the form of weekly packages and 34 % in the form of monthly packages. Compared to last year’s report, the proportions of the alternative roaming packages are nearly unchanged.

25 % of the operators offer other alternative packages. In detail, operators for example provide special pay-as-you-go tariffs, customized price plans for large customers, pooling tariffs or day-passes. Two operators stated that 3-day and 40-day passes for data roaming services were offered to roaming  customers.

Among the operators that offer alternative tariffs, such tariffs were most commonly offered in both customer segments (52 %). Regarding segment-exclusive offers, 12 % of the responding operators offered alternative roaming tariffs only in the consumer segment and 37 % only in the business segment. In total this means that 89 % of operators that offer alternative tariffs offer such tariffs in the business segment, and 64 % offer such tariffs in the consumer segment.

BEREC asked the operators whether they include in alternative tariffs non-EU/EEA destinations at a reduced rate (or without levying a surcharge) while applying a roaming surcharge in the EU/EEA.

41 % of the operators that offer alternative tariffs pursuant to Article 6e (3) answered that they do include services in non EU/EEA destinations at a reduced rate in such tariffs.
Switzerland and USA were the most frequently included countries in alternative tariffs at a reduced rate. Some operators also mentioned reduced fares for roaming-services in Eastern European non-EU/EEA states, e.g. Albania, Bosnia, Serbia and Belarus.

Tariffs without roaming

BEREC has collected information on tariffs without any roaming option as well as on tariffs from which roaming was withdrawn. As far as tariffs without a roaming option are concerned, 51 % of the responding operators offered such tariffs. This is an increase of 17 percentage points compared to previous year’s report. 10 However, according to the results of the BEREC IR Benchmarking Report, those tariffs are not obtained by a significant number of subscribers.

32 % of the operators offer prepaid tariffs without roaming and 41 % offer post-paid tariffs
without roaming.

The majority of the operators stated that tariffs without roaming are mostly dedicated dataonly plans or fixed wireless access (FWA) products that can only be used on a specific location. Some operators also mentioned that low-end tariffs and other inexpensive offers like welfare tariffs were restricted to national use. Other tariffs without roaming included IoT tariffs, dedicated business tariffs, and special tariffs for minors.
According to the responding operators, there were several reasons for not providing roaming services. Some operators stated that roaming was not possible for some offers because there was no commercial sustainability in the RLAH context, especially in regard to low-end tariffs and data-only offers. Another reason for domestic-only offers are tariffs that are designed for tourists and other foreign users that do not need any roaming. Operators also mentioned that some tariffs for business customers were created for national use only based on customer request.


2 % of the operators stated that they withdrew roaming from at least one tariff after 1 July 2018. This is a decrease of 15 percentage points compared to last year’s report. Reasons stated by operators for withdrawing roaming are customers asking for a domestic solution and launch of a new tariff portfolio.

Complaints about roaming services International Roaming

Roaming on board of planes and ships, as well as the issue of inadvertent roaming, were the cause of complaints amongst 65 % of the NRAs. These two categories also subsumed the most frequently cited reasons for complaints in the previous reporting period. The total number of complaints in each country regarding transparency issues when end-users are roaming on ships or planes are low in most countries, i.e. less than 10. However, 5 countries had more than 10. The same situation applies to complaints regarding inadvertent roaming; however, 3 countries received more than 60 complaints each in this category.

More than half of the responding countries have received complaints regarding the activation of cut-off limits for data services while roaming. The cut-off did not happen the way users expected. 5 countries received more than 30 complaints each on this issue.
Billing of roaming is also a category where more than half of the responding NRAs received complaints. One NRA received around 200 complaints, 3 NRAs received between 40-70 complaints and the remaining NRAs received less than 10.
Since the previous reporting period, BEREC observed an increase in the number of countries that received complaints regarding quality of service and data speeds while roaming. However, the number of complaints in each country is relatively low (from 1-9 complaints), except for one country, where approximately 30 complaints were received.


On the other hand, a slightly positive downwards trend for several categories of complaints was noted. Improvements in the following categories were registered: awareness of international calls not covered by the regulation, RLAH not applying automatically, awareness of charges applying outside EEA, information about non-roaming enabled tariffs, charging when calling free numbers while roaming, awareness of alternative tariffs, information about prices for calling premium-rate  services and information about domestic discounts. These issues caused complaints in fewer countries than during the previousreport period. However, one NRA received around 200 complaints from end-users that did not know that international calls were not covered by the regulation. In the same country, around 40 complaints stemmed from end-users that were not clearly informed about tariff plans that were not roaming enabled, and an equivalent number from end-users that were not aware of having subscribed to an alternative tariff. Another NRA received many complaints from end users that were charged for calling free phone numbers while roaming.
Apart from these cases, the number of complaints corresponding to these categories was
very low. A lack of Welcome SMS is a problem in some countries. 4 NRAs received over 20
complaints on this topic.

Quality of service in roaming

BEREC was also interested in the network technology that was used for providing roaming services. 46 % of the operators stated13 that they offer 3G roaming services in the EU/EEA even where 4G would be available14. The issue about quality of service while roaming was also analysed in the BEREC Opinion and identified as an issue to be addressed in any potential update of the Roaming Regulation.

61 % of the operators that only offer 3G services despite 4G being available are not planning to provide 4G roaming services by the end of 2019 or did not specify any plans at all to improve their quality.

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