• The European Commission proposed wholesale data roaming cap of €8.5/GB is higher than the domestic fully allocated retail price per GB charged in 90% (279 out of 310) of 4G data-only tariffs sold across EU28.
• The Commission proposed wholesale data roaming cap of €8.5/GB is higher than the domestic fully allocated retail price per GB charged in 66% (252 out of 380) of 4G unlimited minute & SMS smartphone tariffs sold across EU28.
• The Commission proposed wholesale data roaming cap of €8.5/GB is primarily based on the dubious methodology of an external study that derived a factitious (artificially high) cost per GB that has little to do with the actual underlying costs.
• The Commission justified the €8.5/GB wholesale cap by conveniently comparing it to the domestic retail price per GB of the least expensive bundles (i.e. €10/GB to €20/GB) while turning a blind-eye to the fact that the majority of smartphone (66%) and data-only (90%) tariffs have lower GB prices.
• During the consultation 50% of MNOs stated that wholesale roaming prices are much higher than costs and much higher than domestic retail prices. This is in line with our research findings.
• The Commission proposed wholesale data roaming cap of €8.5/GB appears to be carefully calibrated to protect the very high domestic retail prices charged by operators in tight oligopoly markets (e.g. Germany, Spain) while penalizing operators with competitive much lower domestic retail prices (e.g. Finland, Denmark, Poland).
• EU should disregard the Commission’s proposal and mandate instead a wholesale data roaming cap that does not exceed the average domestic retail price level in any of the 28 countries (i.e. lower than €1/GB).
• The likely knock-on effect if the EU were to adopt the Commission proposed wholesale data roaming cap of €8.5/GB will be the reintroduction of roaming surcharges and/or domestic retail price increases by operators in competitive markets where domestic retail prices are low.

NOTE: Premium DFMonitor subscribers have access to the full version of the research note that includes additional tariff info and the median (smartphone & data-only) fully allocated price per GB for each of the 96 EU MNOs present in EU28.