INTUG Responds to BEREC’s Medium Term Strategy

INTUG, representing the business users of digital services and content, has provided executive summary input to BEREC’s Medium Term Strategy 2018-2020.

1    Regulate the Big Picture

INTUG continues to believe, as previously communicated to BEREC, that the EU business market has now evolved to such an extent that the effectiveness of regulation must be judged with regard to the digital economy as a whole, including content and service providers.  A narrow focus on the communications element alone will lead to suboptimal policy decisions on regulation.  The aim should be to regulate to optimise the big picture, not just one component in isolation.  This means the Medium Term strategy may not be beneficial for one subsector alone, for example mobile operators, but will be profoundly positive for the overall economy.

2    Prevent Vendor Lock-in

INTUG notes that this changed emphasis is already reflected in the growth of “bundled”, or “vertically integrated”, products and services, incorporating transmission, applications and content.  Many of these services are very attractive to business and mass-market customers, but risk establishing new monopolies built on vendor lock-in, with loss of flexibility of choice for individual elements of bundles.  Unified Communications, cloud platforms and Internet of Things applications, as well as the widespread triple and quad-play offerings, all face this danger. The Medium Term strategy needs to include effective tools and ex-ante mechanisms to prevent such anti-competitive developments.  Business users in the corporate and public sector need sustainable competition in each component of service, allied to incentives for innovation.

3    Encourage Infrastructure Sharing

INTUG believes the Medium Term strategy must acknowledge the trend in fixed and mobile communications towards sharing and outsourcing of infrastructure provision, management and operation, and the increasing demand for seamless international services.  These two drivers of EU economic growth require mechanisms to harmonise spectrum licensing in terms of both frequency consistency and financial principles.   The European Communications Code recognises the need to leverage greater RSPG power.

In addition to Relevant Markets, which offer the prospect for analysis of business services, there remains a gap in the tool box for analysing any international mobile markets.

4    Drive for a Totally Connected Society

INTUG wishes to emphasise the need for ubiquitous connectivity as the only acceptable goal if the Digital Single Market is to realise its full potential.  The public sector in particular can only truly innovate in services to citizens at lower unit cost and greater value if every single citizen has guaranteed connection.  The Medium Term strategy should include close monitoring not just of coverage and reach of 4G/5G mobile and super-fast fibre-based broadband, but also actually take-up in terms of live connectivity.  Member States must be driven to eliminate the unconnected completely.

5    Ensure a Safe and Secure Digital Environment

The imminent implementation of the General Data Protection Regulation (GDPR) in May 2018 brings into sharp focus the need for the BEREC Medium Term Strategy to give adequate weight to the full range of security, privacy and protection measures needed to provide a trusted environment for the Digital Economy.  The opportunity for growth in on-line business for all sizes of company, nationally and internationally requires a balanced regime that minimises risk for both service providers and users, in an administratively efficient yet thorough set of processes.  Co-operation between Member States is essential to prevent further growth in on-line fraud, identity theft, cyber attacks and denial of service attacks on essential services, and terrorism.  This must be achieved whilst preventing abuses of network neutrality interpretation, which allow blocking and anti-competitive linked sales, such as those, which the recent FCC Business Services Order allows.

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