“Connected Continent” - Telecoms Single Market Regulation – An Overview
Views of BT Group plc
The further integration of the Telecoms Single Market can deliver an important boost to economic growth in
the EU. The principles underlying EU telecoms regulation are basically sound. However, the challenges of
consolidation, convergence and of cross-border business service provision, require adjustments to the
Electronic Communications Framework to deliver a more aligned, consistent regulatory treatment of
converging markets and sectors. This should be underpinned by non-discriminatory wholesale access, and
with focus on active rather than passive products.
Consolidation among operators can help drive better capitalization and efficiency gains. In mobile, network
economics would not naturally lead to multiple competing infrastructures, and there is a trend in the EU
towards consolidation around fewer national networks. At the same time mobile is increasingly converging
with fixed. The policy response should be to apply the same regulatory approach as with fixed networks –
focusing singular wholesale access obligations on enduring bottlenecks. Effective wholesale access across all
markets is the essence of the completion of the telecoms single market.
Convergence between telecoms and media gives rise to a similar need for policy consistency. Asymmetries
between telecoms operators and PayTV providers are distorting the market as bundling becomes ever more
important, and content the most compelling element for consumers. By extending the access principles of
the Electronic Communications Framework to content bottlenecks, the EU can help level the playing field
across sectors, achieve a better deal for consumers and in turn stimulate fibre demand.
Cross-border service provision should of course be a key focus of the Telecoms Single Market. BT is a
significant player in this market, providing service to businesses across the EU, but regulatory inconsistency
and non-availability of key wholesale access inputs mean large business customers are still missing out on
the full productivity benefits of ICT. There is much that can be done here, from providing more guidance to
NRAs, to strengthening non-discrimination obligations, and reducing some of the administrative burdens of
the Authorisation process.
BT views on the proposed Regulation
Authorisations – we support the idea of a Single Authorisation for pan-EU operators and the European
Parliament ITRE Committee’s amendments simplifying the original proposals (CA1). However, while a Single
Authorisation may reduce unnecessary administrative costs, the key to effective cross-border service
competition is the availability and consistent regulation of the necessary wholesale access inputs.
Spectrum – we agree with the main principles of the Commission proposal but it is important that the
objective of harmonisation does not result in a slowing down of spectrum allocation or undermining of best
practice. Competent national authorities should be required to impose regulated wholesale access
obligations where the available infrastructure based competition fails to deliver commercially negotiated
wholesale access arrangements on fair and reasonable terms.
Wholesale Access – we support the requirement for wholesale access products, including leased lines, to be
made available, with a greater emphasis on virtual access, and on a more consistent basis. Availability in
particular of wholesale Ethernet access (leased line) products is the absolute key to the enabling of crossborder business service provision and therefore to the creation of the genuine Telecoms Single Market. The
further development of harmonised standards may facilitate this but will need to be carefully assessed
against potential cost implications for existing products.

We support the amendments adopted in the European Parliament Plenary vote in relation to “wholesale
high-quality access products allowing the provision of business communications services”, though we
believe the provisions on reference offers must be strengthened to make this more effective.
The extension of the ‘Article 7’ veto may assist more effective enforcement. The veto over SMP remedies
should be clarified as relating to SMP obligations for new access products in a ‘home’ country, which would
be consumed by a “European electronic communications provider” from a different country.
Assured Service Quality Connectivity - BT supports the commercial freedom to provide such services but the
nature of reciprocity for granting access to such services requires clarifying and strengthening.
Net Neutrality – we agree with the principles of an open internet proposed by the Commission, preventing
anti-competitive blocking and providing transparency, but allowing reasonable traffic management and
allowing innovation.

We do not support the amendments adopted in the European Parliament Plenary vote, which are overly
restrictive and which raise legal uncertainty. The amendments previously voted in the European
Parliament ITRE and IMCO Committees offered a more pragmatic solution. We believe that national
authorities should in any case have greater flexibility to maintain self-regulatory mechanisms where
these already meet the policy objectives and to avoid overly prescriptive detail.
Bundling – we support the consistent approach to bundles, an area where the market has changed
fundamentally since the current Directives were agreed and which will ensure a better deal for consumers.
Consumer Protection – we support high levels of consumer protection but question how consumers will
benefit from the sweeping harmonisation of requirements which are mainly already enshrined in EU
legislation. Where new requirements are introduced (eg on contract termination, control of consumption)
there is a risk of extra costs without commensurate consumer benefit.

We welcome the vote in the European Parliament Plenary in favour of a Directive as the appropriate legal
instrument.
Roaming – we welcome the intention to further reduce excessive international roaming charges, which will
clearly benefit consumers. There is a risk however that the proposals, including the proposed “roaming
alliances” may harm the potential competitive position of MVNOs.

We welcome the vote in the European Parliament but wish to see the direct introduction of lower
wholesale price cap steps to allow all market players to offer competitive price offers.
7 April 2014
BT Group plc
BT is one of the world’s leading communications services companies, serving the needs of customers in the UK and in more than 170
countries worldwide.