A €10,500 regulatory fine is not going to trouble a company the size of 1GLOBAL. The more interesting part of today’s ComReg notice is what sits behind the number.

Ireland’s Commission for Communications Regulation says 1GLOBAL has paid €10,500 and entered into an agreement following an investigation into suspected regulatory breaches connected with electronic communications services sold through Revolut. 1GLOBAL has also committed to refund customers who were charged for the service but could not activate it.
That makes this more than a small enforcement story. It is an early reminder that “embedded connectivity” may look like a neat feature inside a banking or travel app, but regulators still see a telecom service — with telecom obligations attached.

What ComReg found

ComReg’s investigation covered several areas. The regulator said it had concerns that 1GLOBAL failed to provide contractual information on a durable medium, including information about cooling-off rights or a cancellation form. It also questioned how customers were notified about contract changes and said 1GLOBAL’s complaints-handling code did not meet applicable requirements.

There were two particularly interesting points for the eSIM market.

First, ComReg raised concerns about zero-rating access to the Revolut app while an eSIM was active and about the information supplied on estimated maximum and advertised download and upload speeds. Second, it said customers were charged in cases where they could not activate the service because their handsets were locked.

READ MORE: Why Embedded Connectivity Threatens Telecom Distribution?

1GLOBAL has agreed to address the issues and refund customers who paid but did not or could not activate their eSIM. ComReg says it will continue monitoring compliance.

It is important to keep the scale of the case in perspective. The real significance lies less in the size of the penalty and more in what the investigation reveals about the regulatory expectations now catching up with embedded eSIM services. EU electronic communications rules require relevant contractual information to be clear, understandable and provided on a durable medium, alongside a concise contract summary.

The app is not the service

Revolut launched its eSIM offer in 2024, initially positioning it as a simple way for travellers to buy data in more than 100 countries without leaving the banking app. The attraction is obvious. The user already has the app, already has a payment method attached and can add connectivity in a few taps.

Behind that experience sits 1GLOBAL. Revolut’s current terms state that Revolut markets and facilitates the sale as an agent, while 1GLOBAL is the service provider. The terms also now highlight that the conditions can be downloaded and saved in a durable format.

That distinction matters.

READ MORE: Revolut’s eSIM Strategy Is Bigger Than Travel Data

Consumers may think they are buying “Revolut eSIM.” Technically and contractually, they are entering a telecom relationship involving another company. Once something fails — activation, refunds, speed disclosure, complaints or contract changes — the clean app experience suddenly has to explain who is responsible for what.

For embedded connectivity, this may become one of the market’s biggest growing pains.

Embedded eSIM is getting bigger

1GLOBAL is not backing away from this model. Quite the opposite. Its partnership portfolio now extends beyond travel data into deeper telecom integrations. It powers Revolut mobile services in markets including the Netherlands and Poland and has also announced an eSIM mobile offering with N26 in Germany. Its own annual reporting describes B2B2C connectivity through APIs as a major growth area.

Nor is 1GLOBAL alone. Gigs openly markets embedded travel eSIMs to banks, airlines, accommodation businesses and loyalty platforms. eSIM Go, another major B2B player, raised new funding in 2026 to expand its travel-eSIM and MVNO business.

So the direction of travel is clear: connectivity is moving away from the operator’s own storefront and into apps people already use.

That is commercially attractive. It also creates a less visible problem. The more invisible the telecom provider becomes, the more explicit the responsibilities around contracts, support, performance and refunds need to be.

The best embedded eSIM experience is supposed to make telecom disappear. Regulation makes sure accountability does not disappear with it.

Convenience has limits

For travellers, buying data inside a banking app can be extremely convenient, particularly for a short trip or an emergency top-up. But convenience is not automatically the same thing as best value, best network choice or best support.

A frequent traveller comparing several destinations may still be better served by checking specialist travel-eSIM offers before buying. Likewise, someone with a locked handset, an older device or unusual connectivity needs should verify compatibility before payment rather than assuming an in-app offer will simply work.

For banks, airlines and travel platforms considering an embedded eSIM, the lesson is even clearer. Choosing an API partner is not only a question of coverage, wholesale pricing and integration speed. Contract presentation, complaint handling, refunds, speed disclosures and the division of regulatory responsibilities belong in the procurement conversation too.

That is less exciting than “launch in weeks.” It is also where expensive problems tend to start.

Conclusion

The €10,500 payment is almost a footnote. The important part of the ComReg action is that it exposes a structural tension in embedded telecom: brands want connectivity to feel like just another button, while communications law treats it as a regulated service with obligations that survive the interface.

That matters as 1GLOBAL, Gigs, eSIM Go and other infrastructure players compete to put connectivity inside fintech, airline, hospitality and super-app ecosystems. The winners will not necessarily be those that make the eSIM most invisible. They may be the ones that make responsibility most visible when something goes wrong.

1GLOBAL’s continued expansion with Revolut and other partners suggests embedded telecom is not being slowed by this regulatory episode. But the market is maturing. “Frictionless” can no longer mean only fast installation and checkout. It also has to mean clear contracts, understandable support routes and refunds that work when activation does not.

For the next phase of travel eSIM, compliance is no longer back-office plumbing. It is part of the product.