Regulating roaming: transparency and comparability for consumers
12 December 2013
A brief note about the recent BEREC Report on Transparency and Comparability of International Roaming Tariffs
Transparency and comparability are the two key aspects of regulating roaming for consumers when selecting tariffs for international roaming services.
Firstly, transparency means the availability of clear information about prices and conditions for each tariff, as well as simple procedures for customers to switch between tariffs. Secondly, comparability is the possibility for customers to compare different types of tariffs offered by operators and to select the one best suited to their needs and pattern of consumption.
BEREC will repeat this exercise each year to track developments and advances so as to increase the transparency and comparability of tariffs.
In order to investigate these issues, BEREC sent a questionnaire to national regulatory authorities (NRAs) and mobile services providers (‘providers’). The questionnaire for NRAs focused on the following information:
- complaints received by NRAs on transparency issues as well as on any information about tariff comparison tools that may be offered by different organisations such as consumer associations;
- recommendations available to customers on how to select the most appropriate tariff and any tools and hints for customers to estimate data traffic that may be facilitated by NRAs and any third-party (i.e. consumer) associations.
The questionnaire for providers asked about the range of tariff structures offered by them, information for customers on the use of the tariffs, how to switch between tariffs, and information and tools for comparing tariffs and estimating consumption.
About customer complaints related to transparency issues, the investigation revealed that just half of the NRAs received transparency complaints and there were very few of them per NRA. Therefore, in general, it can be said that transparency is not an issue of concern in this regard. The few complaints received mainly focused on the need for greater clarity on the application of the cut-off limit, the services included in the bundles and the lack of information about the application by default of specific tariffs (already addressed in the BEREC compliance report).
Most providers report that they have adequate information on the conditions and prices for each tariff in their websites. They also report that they inform customers about tariffs by sending out SMS (short message service) or USSD (Unstructured Supplementary Service Data) messages.
BEREC identified only a minority of providers which do not inform their customers on how services are charged when the conditions for specific tariffs apply.
This is clearly an area where improvements can be made to avoid bill-shock issues and help customers to have favourable experiences when using roaming services.
Regarding issues related toswitching from one tariff to another, most providers give information on their website and through call centres.
Information about consumption and charges for past use may help consumers make informed decisions on which tariff to select. In general, providers supply this kind of information in the bill. Some providers also provide e-bills and detailed information on their website and/or in specific applications.
Providing data on real-time consumption is more challenging for roaming services, as it is typically based on the collaboration between the home network and the visited network, and the home network does not always have information available on real-time consumption of all services. This is reflected in the responses BEREC received, in which some providers point out these limitations.
With regard to the comparability of tariffs, the responses received show that there is a large variety of different types of tariffs, ranging from linear tariffs (such as the Eurotariff) to daily/weekly or monthly bundles of different services and specific tariffs where domestic prices are combined with different kinds of additional fees. In general, it is not a surprise that most of them are restricted to the EEA area. However, there are few cases where the tariff is valid only in the geographical area where the provider has a footprint, either within the EEA area or also covering the rest of the world.
BEREC welcomes this diversity of tariffs, as it increases customers’ ability to adapt and select the most suitable tariff based on their pattern of consumption, even though the number of different tariffs available for a European customer varies by country. However, making choices from such a large range of different types of offer makes it more challenging and difficult for customers to make informed and optimal choices. In summary, the more different options consumers have, the more difficult will be the task of comparing them and making informed decisions. BEREC will continue to assess the evolution of the current diversity of tariffs.
Regarding the availability of tables and/or tools for comparing different tariffs, BEREC found that consumers in general do not have simple access to any information summarising the features of each set of roaming tariffs offered by operators. Given the high burden of updating information about changing tariffs and the focus of public interest on domestic tariffs, this information on international roaming tariffs is not provided in a comprehensive way by consumer associations. Thus the information is limited to certain recommendations and the analysis of only certain alternative tariffs. In general, there is also a shortage of simple tables comparing all tariffs offered by the provider. Currently, international roaming is contracted with the same provider that supplies domestic services, and it may help customers to make informed decisions and compare different tariffs if providers supply tables on their website and in their retail outlets. Accordingly, to increase transparency and comparability of tariffs, BEREC encourages operators to publish comprehensive information on all active offers in one place and keep it up to date.
BEREC has noted a steady trend of alternative roaming tariffs with average prices higher than the regulated caps of the standard roaming services (linear tariff scheme) in its benchmark reports on the monitoring of roaming tariffs.
The findings in this transparency and comparability report lead to the conclusion that this effect is at least partly caused by the consumers’ difficulties in comparing available tariff structures and in selecting the most adequate tariff for their personal usage patterns.
Estimation of traffic consumption
Customers must be able to select the most suitable tariff based on their own estimated pattern of consumption.
In this regard, BEREC also explored the availability of tools and information for customers to estimate their traffic based on the use of internet services such as sending/checking emails, web browsing, video streaming, etc.
For most customers, it is far from clear how to estimate the amount of traffic consumed when using internet services, and this is one of the potential issues that may result in bill shocks as well as in customers underestimating or overestimating traffic when they contract bundles, leading to non-optimal buying decisions. The availability of transparent, historic and real-time usage of data is also key to making optimal buying decisions.
In general, apart from some isolated cases, NRAs and consumer organisations do not provide tools to help customers to estimate data traffic, but some of them supply information and tips on how to estimate traffic consumption. In the case of providers, a minority of them provide such tools on their websites, allowing customers to report estimated use of different internet services for a certain period, and providing, in return, an estimate of the data traffic in question.
BEREC considers this to be good practice and encourages all stakeholders to provide customers with these tools (where possible by means of graphical interfaces that use icons). This can help customers make more informed decisions between different types of bundles and tariffs and to select tariff contracts that best suit their needs.
BoR (13) 185 Report on Transparency and Comparability of International Roaming Tariffs
 BEREC International Roaming Compliance Report (Regulation (EU) No 531/512 of the European Parliament and of the Council of 13 June 2012 on roaming), Chapter 7. Document available at