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ISSUES IN THAILAND
…AND HOW TO
SOLVE THEM
ยุคของการเปลี่ยนแปลงในธุรกิจโทรคมนาคม
งานวิศวกรรมแห่งชาติ 2560
PRESENTATED AT
PRESENTATION BY
ALLAN RASMUSSEN
THAILAND’S TELECOM MARKET – AN UNLEVEL PLAYING FIELD
www.yozzo.com
MOBILE OPERATORS PLAYING FIELD MVNO’S PLAYING FIELD
Without some form of regulatory measures and changes as described in this presentation, Thailand’s telecoms market will remain an unleveled playing
field, where competition and innovation of mobile services, and thereby the digital economy, may not evolve as it should - or at all.
The government has provided the platform for private industries to participate and form the final stages of Thailand 4.0 – however the current regulation
from NBTC - or lack off, has not been able to follow suit but only concentrated on the existing silos in the market instead of getting all the wheels to spin.
Luckily, most of the issues evolves around issues created by NBTC itself i.e. home made quick fix paragraphs, lack of action, or lack of knowhow by the time
MVNO was introduced, which demands less effort to solve.
MVNO’S IN THAILAND – WHY IT FAILED
In 2009 five MVNO’s where given a license by the telecom regulator NBTC to operate as MVNO’s on the state enterprise telecom operator TOT
AS OF NOVEMBER 2017
ONLY 1 MVNO IS LEFT
i-Kool 3G (Loxley)
UNLEVEL PLAYING FIELD - UNRESOLVED
POOR PLANNING AND EXECUTION
LEGACY SYSTEMS AND RED-TAPE
INSUFFICIENT NETWORK CAPACITY AT LAUNCH
INSUFFICIENT MVNO EXPERIENCE AND QUALITY
POOR MVNO CONTRACTS AND REGULATION
www.yozzo.com
MVNO IN THAILAND HAVE FAILED BECAUSE OF THE FOLLOWING REASONS
THAILAND’S “SUPERBOARD” FAULTS THE REGULATOR NBTC FOR MVNO FAILURE
www.yozzo.com
In 2016, The Inspection and Evaluations Commission (also known as the “Superboard”) of the National Broadcasting
and Telecommunications Commission (NBTC), failed the telecom regulator and concluded that:
…NBTC should issues regulations for mobile
virtual operators to support more of them in
the Industry, which should benefit consumers.
WHAT HAS THE REGULATOR NBTC DONE ABOUT IT?
www.yozzo.com
noth•ingPronoun
not anything; no single thing.
Adjective
having no prospect of progress; of no value
BUT CONTINUES TO SELL MVNO LICENSES
51COMPANIESHAVE OBTAINED A MVNO LICENSE IN THAILAND
ONLY 9 HAVE LAUNCHED – 5 ARE STILL ALIVE
www.yozzo.com
MVNO LICENSES ISSUED IN THAILAND
AS OF DECEMBER 2017
MVNOS, ARE AN INTEGRAL PART OF THE GLOBAL MOBILE LANDSCAPE
Over the past 18 years, MVNOs have helped stimulate competition
in the mobile market, launching innovative tariffs and services and
attracting niche consumer segments at a lower cost than mobile
network operators (MNOs). In Europe virtually every cable and
fixed-line operator has a mobility strategy, largely based on MVNO
• 1000+ INDEPENDENT MVNOS WORLDWIDE
• MVNOS INCREASED 70% BETWEEN 2010 AND 2015
• 72 COUNTRIES HAVE MVNOS IN OPERATION
• MVNOS ACCOUNT FOR 14% OF THE TOTAL EU MARKET
• EUROPE IS HOME TO: 595 MVNOS, APAC: 137, US: 111
• 1 OUT OF 10 PEOPLE IN AUSTRALIA IS A MVNO CUSTOMER
TODAY, MVNOS HAVE REACHED 214 MILLION USERS WORLDWIDE, AND IS ESTIMATED TO GROW TO 300 MILLION USERS AND A $70 BILLION VALUE IN 2020
Ovum predicts that nearly 24% of all new subscriber connections
over the next five years will come from MVNO subscribers.
Although the current enterprise market represents less than
10% of these connections now, they expect it triple to 30%
By 2020, IDC predicts that 30% of the top 500
companies in Thailand will see the majority of their
business depend on the ability to create digitally-
enhanced products, services and experiences
Overall connection growth for mobile phone service around the world was
about 4.5% end of 2015. MVNO connections are growing at about 18% per
annum 4 times faster than the average rate for the mobile industry.
Source IDC Thailand
With a predicted compound annual growth rate (CAGR) of over 10% in
the forecast period to year 2020, the Asia Pacific region is home to the
world’s fastest growing MVNO sector, even more than the highly
competitive MVNO markets of Europe and North America.
Grand View Research
www.yozzo.com
…AND HAVE DELIVERED
THE RATIONALE FOR THE INTRODUCTION OF MVNO, INCLUDE - BUT ARE NOT LIMITED TO:
 Stimulate competition,
 Efficient utilization of network resources,
 Introduce new or better services aligned to lifestyle propositions currently unserved/underserved,
 Promote investment opportunities for local and international businesses in the telecom market.
Consequently, MVNOs are intended to support innovation, bridge digital divide, and contribute to the growth in the ICT sector to
ensure the achievement of the broader industry and DIGITAL ECONOMY OBJECTIVES.
THE CLEAR INTERNATIONAL EVIDENCE IS THAT MVNOs HAVE DELIVERED:
 More consumer choice
 Innovative pricing plans
 Innovative products and services
 innovation in, and better customer service
www.yozzo.com
…meanwhile in Thailand
www.yozzo.com
THAILAND’S TELECOM ECOSYSTEM
MNO = MOBILE NETWORK OPERATOR
MNO Is a Mobile Network Operator who owns its own network infrastructure and has licensed allocated spectrum.
In Thailand the MNO’s are: AIS, CAT Telecom, DTAC, TOT and TRUE
www.yozzo.com
MOBILE NETWORK OPERATORS OWN THE INFRASTRUCTURE
www.yozzo.com
AND LICENSE THE SPECTRUM
www.yozzo.com
FROM THE NATIONAL TELECOM REGULATOR (NBTC)
NBTC
www.yozzo.com
THE 900/1800/2100MHz SPECTRUM LICENSES STATES 10% OF THE CAPACITY MUST GO TO MVNO’S
MVNO
10%
www.yozzo.com
HOWEVER IN THAILAND ONLY CAT TELECOM AND TOT HOST MVNO’S
MVNO
STATE ENTERPRISE STATE ENTERPRISE
www.yozzo.com
HOW MVNO’S CONNECT: MVNO’S CAN CONNECT TO MNO’S DIRECTLY
MNO MVNO
MVNO
A MVNO does not own spectrum, instead it enters into an agreement with either a MNO or MVNA to obtain
access to airtime at wholesale rates, and then sets its own retail price and service. An MVNO may invest in
its own operational components or employ the services of a Mobile Virtual Network Enabler (MVNE)
MVNO = MOBILE VIRTUAL NETWORK OPERATOR
www.yozzo.com
MVNO’S CAN CONNECT TO MNO’S THROUGH A MVNA
MNO MVNA MVNO
MVNO
A MVNA is an entity, who buys mobile airtime in bulk from the MNO, and then
wholesale the airtime to MVNOs. The MVNOs retails the airtime to its end-users
MVNA = MOBILE VIRTUAL NETWORK AGGREGATOR
www.yozzo.com
MVNO’S CAN CONNECT TO MNO’S THROUGH A MVNE
MNO MVNE MVNO
MVNO
Provides infrastructure and services to both the MNO and MVNOs, which enables MVNOs to offer their services on the MNOs
network, while leaving the “telecom” enablement to the MVNE. The MVNE provides services, such as billing, business workflow,
product setup, service delivery, customer care, fraud management, reporting, sale platforms, device management, etc.
MVNE = MOBILE VIRTUAL NETWORK ENABLER
www.yozzo.com
MVNO’S CAN CONNECT TO MNO’S THROUGH A MVNE/MVNA
MNO MVNA/MVNE MVNO
MVNO
The MVNA/MVNE purchases airtime in bulk from the MNO, adds the operational telecom components on
top, and then wholesales the airtime and service as a full turnkey solution to MVNOs. The MVNA/MVNE
also offers additional value add to the MNVOs in terms of guidance during setup, launch and operation.
MVNA + MVNE = MOBILE VIRTUAL NETWORK AGGREGATOR + ENABLER
www.yozzo.com
PROBLEM #1 IN THAILAND
THE MNO TRIANGLE
www.yozzo.com
MYSTERIOUS CIRCUMSTANCES - THE BERMUDA TRIANGLE
Florida
Bermuda
Puerto Rico
North Atlantic Ocean
THE NORTH ATLANTIC OCEAN HAS ITS BERMUDA TRIANGLE
Where ships and airplanes has mysteriously gone missing
www.yozzo.com
MYSTERIOUS CIRCUMSTANCES - THE MNO TRIANGLE IN THAILAND
LIKEWISE IN THAILAND WE HAVE THE MNO TRIANGLE
Where MVNOs for mysteriously reasons haven’t been able to launch for 5 years
www.yozzo.com
DESPITE THE MVNO CRITERIA AND CAPACITY ON THE 2100MHz LICENSES
Prior to Thailand’s 2100MHz 3G auction in 2012, the NBTC released the following Criteria and Procedure for the Spectrum.
16.5.1 The Licensee shall provide telecommunications network service with the minimum
capacity of 10 percent of its networks to the MVNO who is not the Connected Person in
the Shareholding Structure with any licensee when receiving such service request
AIS 90% DTAC 90% TRUE 90%
NBTC Notification | http://www.parliament.go.th/ewtcommittee/ewt/tele/ewt_dl_link.php?nid=144&filename=index
www.yozzo.com
DESPITE THE MVNO CRITERIA AND CAPACITY ON THE 900MHz & 1800MHz LICENSES
As with the 2100MHz spectrum, the NBTC has also added a MVNO clause in the terms for the 900MHz and 1800MHz licenses (2015/2016)
(1) The Licensee shall comply with the Commission’s Notification Regarding Mobile Virtual Network Operator Service 2013.
(2) The Licensee shall provide telecommunications network service at least 10 percent of its network’s capacity to MVNO(s) that
is/are not the connected person(s) with any licensee under this Notification, upon receiving such service request.
AIS 90% True 90% True 90% AWN (AIS) 90%
900MHz 900MHz 1800MHz 1800MHz
PDF | NBTC 900MHz Criteria (English) | http://auction.nbtc.go.th/getattachment/HOME/900MHz_Criteria_Eng.pdf.aspx
PDF | NBTC 1800MHz Criteria (English)| http://auction.nbtc.go.th/getattachment/HOME/1800MHz_Criteria_Eng.pdf.aspx
www.yozzo.com
No MVNO’s have been able to launch on AIS,
DTAC or TRUE despite the license terms saying
the operators of 900, 1800 and 2100MHz have
to provide at least 10% capacity to MVNO’s
www.yozzo.com
THE MNO TRIANGLE SOLUTION
www.yozzo.com
THE MNO TRIANGLE SOLUTION
1. The NBTC should publish a clear policy statement requiring the telecom network operators to provision MVNOs on their network.
2. The NBTC should exercise its regulatory mandate to monitor the market and the negotiations to ensure that mobile network operators conduct
negotiations fairly and in good faith - and that the policy objectives of the mobile market are fulfilled.
3. The detailed terms and conditions of MVNO provisioning should first be left to the parties to negotiate on a purely commercial basis
4. It would be in the public interest for the NBTC to intervene, and assist the parties - or if necessary, settle and resolve in case a mobile network
operator is acting in bad faith, engaging in any form of anticompetitive conduct, or if, after a reasonable period (1 months) of in-good-faith
negotiations, a commercial agreement cannot be reached between the parties.
5. The NBTC should follow up on a monthly basis to see if there is a progress in on-boarding MVNOs, and take measures if not.
In addition, and as a last resort only, if no progress is made - a regulatory mechanism allowing the NBTC to intervene, to:
 Ensure fair and reasonable terms for access
 Safeguard fair and non-discriminatory competitive behavior
 Bring parties to the negotiating table at the earliest opportunity
 Introduce and safeguard the principle of in-good-faith commercial negotiations.
i.e., the mobile network operator shall enter into a wholesale agreement with the MVNO, within a period of 1 months from the date of issuing a Letter
of Intent (LoI) or Memorandum of Understanding (MoU) and submit a copy of the same to the NBTC (licensor).
NBTC would have the power to intervene in the agreement if deemed necessary by one of the parties.
The Regulations/Directives/Orders of NBTC in this regard would be binding on the telecom network operators and the MVNO.
www.yozzo.com
NO MVNO – NO LICENSE
NBTC is planning an auction for one 850Mhz and
three 1800MHz spectrum licenses in 2018. It would
suit the regulator well to live up to its reason to
exist, by facing the issue of un-used MVNO capacity
among the three existing spectrum license holders.
One suggestion would be to add to the auction
terms and conditions, that in order to participate in
the upcoming spectrum auction, an existing license
holder, who has not yet lived up to the terms and
conditions in its previous spectrum license
regarding MVNO capacity, would have to launch at
least one MVNO, on their networks in order to
participate in the spectrum auctions. The mobile
network operators should be given a maximum
period of 60 days to present an MVNO proposal.
www.yozzo.com
The NBTC has been very active in making sure that terms and conditions, such as minimum roll out
coverage, license payments, maximum retail pricing, etc. has been followed by the 900/1800/2100MHz
auction winners, while zero attention - nor consequences has been given regarding the MVNO capacity.
PROBLEM #2 IN THAILAND
NO FULL MVNO
www.yozzo.com
NO FULL MVNO IN THAILAND = NO CONTROL OF THEIR OWN BUSINESS
www.yozzo.com
TYPES OF MVNO’S AND OPERATING MODELS
NETWORK
APP.
& SERVICES
CUSTOMER
ACTIVATION
CUSTOMER
BILLING
CUSTOMER
SERVICE
MARKETING
SIM & VOUCHER
MANAGEMENT
SALES &
DISTRIBUTION
HANDSET
MANAGEMENT
BRANDED RESELLER
SERVICE PROVIDER
ENHANCED MVNO
FULL MVNO
Functions carried out by MVNOMVNOFunctions Carried out by MNO
MVNOMVNO
MVNO
MVNO
MVNO
MVNO
MVNO
MVNO
MVNO
MVNO
MVNO
MVNO
MVNOMVNO
MNO
MNO
MNO
MNO
MNO
MNO
MNO
MNO
MNO
MVNO
MNO
MNO
MVNO
MVNO
MNO MNO
MVNOMVNO MVNO
MVNO
MVNO
MNO = Mobile Network Operator
MNO
MNO
MVNE MVNE MVNEMVNEMVNEMVNEMNO MVNEMVNE MVNE
Functions carried out by MVNEMVNE
MVNO = Mobile Virtual Network Operator MVNE = Mobile Virtual Network Enabler
MNO
MVNO types, e.g. branded reseller, thin, medium, or full MVNO’s, are defined by which of the
operational components the MVNO manages, and which one the network operator – or MVNE manages.
www.yozzo.com
FULL MVNO = CONTROL OF OWN BUSINESS AND FLEXIBILITY TO PROVIDE INNOVATIVE SERVICES
A Full MVNO has complete control over its operation, data, SIMs, customers and services due
to certain core network elements such as:
• GMSC (Gateway Mobile Switching Centre)
• HLR (Home Location Register)
• SMSC (Short Message Service Centre),
• MMSC (Multimedia Messaging Service)
• GGSN (Gateway GPRS Support Node)
Full MVNO’s can also have their own roaming and interconnect agreements with other MNOs.
HLR/HSS
SMSC
GMSC
VOICEMAIL
MMSC
GGSN
www.yozzo.com
MVNO POSITIONING
LOW HIGHPRICING
SERVICEOFFERING
”No frills”
MVNO’s
MVNO’s based
on convinience
Traditional
Mobile Operators
MVNO’s based on
value addition
INNOVATIVE
IoT/M2M
MVNO’s
As a FULL MVNO the MVNO
can have control over services
they can offer in the market,
and thereby the flexibility to
innovate and compete on new
service offerings in the market
www.yozzo.com
AS WELL AS TACKLING DIVERSE, URGENT AND SIMULTANEOUS DEMANDS ON A HOURLY BASIS
 Travel & Leisure MVNO needs to urgently
resolve customer billing disputes before start
of Songkran holiday season tomorrow
 Ethnic MVNO wants to launch
mothers day promotions before
competitor launches its promotions
 OTT MVNO wants to launch zero rating service on videos from
its own portfolio to compete in the market against HBO, Netflix
 Bank MVNO wants to utilize bulk of sales-force
tomorrow to visit its premium customers to make a
one-day only offer for rate plan upgrades
1
2
4
6
 Retail MVNO wants to provide extra
bonus points in loyalty program to drive
sales this weekend
 Retail MVNO wants to access its user usage
data) to better address the needs and wants
of its own customers
35
MVNO
MVNO
MVNO
MVNO
MVNO
MVNO
www.yozzo.com
THAILAND vs. SINGAPORE
4 - 0
Let’s say Thailand wins 4-0 over
Singapore in football, and the whole
country is celebrating the victory on
social media. The MVNOs also
wants to join the celebrations by
providing the customers with a 20%
discount on all voice calls
EXAMPLE www.yozzo.com
IN THAILAND TODAY
WEEK 1 WEEK 3 MONTH ? MONTH ?
Fax your request
to the MNO
Present your case at a
meeting with the MNO
Internal meeting at the
MNO to approve or not
Wait for result
This is how it ”works” today in Thailand if MVNO’s want to introduce new promotions, service - or tackle issues
www.yozzo.com
…Meanwhile Thailand will have
lost to another country in both
football and innovation
www.yozzo.comEXAMPLE
NOT ALLOWING FULL MVNO KILLS INNOVATION AND CREATES AN UNLEVEL PLAYING FIELD
LOW HIGHPRICING
SERVICEOFFERING
Traditional
Mobile Operators
INNOVATIVE
www.yozzo.com
The MVNOs will not be able to
compete on neither services,
pricing - or introducing new
innovations to the market,
thereby giving the traditional
mobile network operators an
unfair advantage, severely
limiting innovation and
competition in the market
THE SOLUTION
www.yozzo.com
• Allow Full MVNO’s (like in other markets), to level the playing field,
foster innovation and competition for the benefit of the consumers
PROBLEM #3 IN THAILAND
DOUBLE / TRIPLE LICENSE FEE
www.yozzo.com
UNFAIR DOUBLE LICENSE FEE HURTING THE MVNO AND CONSUMERS
OPERATOR
MVNO
License Fee
Total 1.5%
1.50% License Fee
3.50% USO Fee
Total 5%
New Voice
Call Cost
THB 105
New Voice
Call Cost
THB 106,57
Voice Call
Cost
THB 100
The operator pays NBTC 1.50% of revenue in license
fee + 3.50% of annual revenue in USO fee - Total 5%
Example:
The operator sells THB 100 worth of voice calling to
the MVNO which is THB 100 + 5% fee = THB 105
The MVNO pays NBTC 1.5% of annual revenue
in license fee.
Example:
The MVNO sells the now THB 105 worth of voice
calling to customers. THB 105 + 1.5% fee = THB 106,57
❶ ❷
TOTAL = 6.50%
2 x 1.5% License Fees (MNO+MVNO = 3%
1 x 3.5% USO Fee (MNO) = 3.5%
REGULATOR
Un-level playing field as the
operator can sell directly to
customers for just THB 105
vs. the MVNOs THB 106,57
MVNO
As the host operator and MVNO each have to pay the
license fees of annual revenue, the same mobile
signal (voice/sms/data) ends up having double the
tax, when it ends up at the MVNO and its customers.
❸
www.yozzo.com
In 2009 the NBTC introduced Mobile Virtual Network Operator (MNVO) license along with a license fee scheme up to 1.5% of yearly revenue.
However, the setup of the license fees causes the burden to be pushed to the MVNOs and consumers, as the NBTC is charging double fees on one ”signal”.
+ += =
UNFAIR TRIPLE LICENSE FEE HURTING THE MVNO AND MVNA
OPERATOR MVNA MVNO
MVNA
License Fee
Total 1.5%
MVNO
License Fee
Total 1.5%
1.5% License Fee
3.5% USO Fee
Total 5%
New Voice
Call Cost
THB 105
New Voice
Call Cost
THB 106,57
New Voice
Call Cost
THB 108,17
Voice Call
Cost
THB 100
As the MNO, MVNA and MVNO each
have to pay the license fee, the same
mobile signal (voice/sms/data) ends
up having triple tax, when it arrives at
the MVNOs and the consumers
The operator pays NBTC 1.5% of revenue in license
fee + 3.5% of annual revenue in USO fee - Total 5%
Example:
The operator sells THB 100 worth of voice calling to
the MVNA i.e. THB 100 + 5% fee = THB 105
The MVNA pays NBTC 1.5% of
annual revenue in license fee
Example: The MVNA resells the now THB
105 worth of voice calling to the MVNO.
I.e. THB 1,05 + 1.5% fee = THB 106,57
The MVNO pays NBTC 1.5% of annual revenue in license fee
Example: The MVNO sells the now THB 106,57 worth of voice
calling to customers. I.e. THB 106,57 + 1.5% fee = THB 108,17
❶ ❷ ❸
TOTAL = 8%
3 x 1.5% License Fees (MNO, MVNA, MVNO) = 4.5%
1 x 3.5% USO Fee (MNO) = 3.5%
The operator can sell
directly to customers
for just THB 105 vs. the
MVNOs THB 108,17
❹
www.yozzo.com
In 2009 the NBTC introduced Mobile Virtual Network Operator (MNVO) license along with a license fee scheme up to 1.5% of yearly revenue.
However, the setup of the license fees causes the burden to be pushed to the MVNA, the MVNO and consumers, as the NBTC is charging triple fees on one ”signal”.
+ + += = =
REGULATOR
MVNO’S MAKES ITS BUSINESS ON MARGINS
MVNO
VS.
www.yozzo.com
MVNO’s makes its business on the
small margins between costs and sale
price. They operate a lean and flexible
setup where every satang counts.
The unfair double, and triple taxation changes the
timeline significantly for the MVNO to reach financial
breakeven – if ever - given that the current fee
structure setup not only adds costs, but also provides
the mobile operators with an unfair pricing advantage
THE SOLUTION
www.yozzo.com
Let the MNO and MVNO (MVNA) split
the 1.5% license fee like we do with VAT
i.e. MNO 0.75% and MVNO 0.75% = 1.5%
PROBLEM #4 IN THAILAND
BUREAU-CRACY KILLING INNOVATION
www.yozzo.com
MVNO LICENSE APPLICATION IS IN-CORRECT AND NOT UP-TO-DATE
TERMS AND APPLICATION FOR MVNO IN
THAILAND IS ABOUT 15-YEARS TO OLD
www.yozzo.com
The application seems to be a copy
and paste from old applications and
various countries in early 2000’s
In mid-2017 the NBTC added a MVNA license
to the market without request for consulting
or public hearing, ending up using the MVNO
application for MVNA license as well.
LICENSE APPLICATION BUREAU-CRAZY
NBTC OFFICER HAS TO UNDERSTAND & APPROVEFILL-OUT & HAND-IN THE APPLICATION
NBTC has added their own little notice to the act regarding license approval.
The NBTC officer can decline the application if he/she doesn't understand, either due to language, the service, network etc.
www.yozzo.com
LICENSE APPLICATION BUREAU-CRAZY
ONCE APPROVED, THE OFFICER
HANDS THE APPLICATION TO NBTC’S
SECRETARY-GENERAL TO SIGN
BECAUSE THE OFFICER IS RESPONSIBLE
www.yozzo.com
LICENSE APPLICATION BUREAU-CRAZY
THE MVNO LICENSE IS GIVEN BASED ON THE APPROVED INFORMATION
I.e. The information given and approved is part of the license – License valid for 5-years
www.yozzo.com
LICENSE APPLICATION BUREAU-CRAZY
HOWEVER…
?
The NBTC officer will not uderstand new innovative service from the MVNO and decline it
because he/she is responsible, and it does not fit the boxes. Therfore all MVNOs are the same
in Thailand - even MVNAs have to use the MVNO application form which makes no sense
www.yozzo.com
BUREAU-CRACY KILLS INNOVATION AND OPENS FOR CORRUPTION
The officer becomes a single gatekeeper, which opens for corruption
The setup opens a ”backdoor
virus” for further corruption.
Because…
The MVNO license is valid for 5-
years and consist of the
information provided in the
application. That information is
however outdated because it has
to fit the old standard and
knowhow from the officer.
Once the MVNO launch in the
real world with technology and
interfaces according to updated
standards the regulator can come
back at anytime and say the
MVNO is not operating accoding
to the license (information
provided in the license) and
demand they stop operation – or
solve it with a brown envelope.
www.yozzo.com
GETTING A LICENSE WITHOUT AN AGREEMENT
Thailand is among few, if not the only country in the world,
where you can get a MVNO license without some sort of
agreement (MoU) with a mobile operator (or MVNA/MVNE)
www.yozzo.com
GETTING A LICENSE WITHOUT AN AGREEMENT – HOW?
MVNO LICENSE IS GIVEN BASED ON
THE APPLICATION INFORMATION
FILL-OUT & HAND-IN THE APPLICATION
HOW?
www.yozzo.com
GETTING A LICENSE WITHOUT AN AGREEMENT – HOW?
Question: How does a MVNO without a host operator agreement fill out 9,10, 11, 12?
Answer: They fill in ALL operators as example and use a network diagram from the 90’s
Who would buy equipment BEFORE
having an MNO agreement AND a license?
www.yozzo.com
THE SOLUTION
www.yozzo.com
• Update the license application to the present and amend it from time to time.
• Drop the added clause that the officer has to understand, approve and be responsible.
• There is no reason to provide a license prior to an agreement with a MNO/MVNA/MVNE.
• Introduce a real MVNA license application = do not use the MVNO application it’s not the same.
BUT BETTER YET…
• Drop the need for MVNA/MVNO application/license altogether in-line with other countries who no longer issues MVNO licenses.
Doing so would make sense, as most of the issues releated to MVNO in Thailand, as discussed in this presentation would need an
update or be removed. We are aware that NBTC is very keen on licenses in order to collect fees, and we therefor suggest a solution,
where NBTC could maintain a very simple MVNO and MVNA license scheme, purely for the sake of collecting its license fees.
Presentation by Yozzo Co.,Ltd.  www.yozzo.com  March 2016
DISCLAIMER
Some statements made in this material are forward-looking statements with the relevant assumptions, which are subject to various risks and
uncertainties. These include statements with respect to corporate plans, strategies and beliefs and other statements that are not historical
facts. These statements can be identified by the use of forward-looking terminology such as “may”, “will”, “expect”, “anticipate”, “intend”,
“estimate”, “continue” “plan” or other similar words. The statements are based on our assumptions and beliefs in light of the information
currently available to us. These assumptions involve risks and uncertainties which may cause the actual results, performance or achievements to
be materially different from any future results, performance or achievements expressed or implied by such forward-looking statements. Please
note that the company and executives/staff do not control and cannot guarantee the relevance, timeliness, or accuracy of these statements.
Copyright © 2017 Yozzo Co.,Ltd. All Rights Reserved.

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MVNO issues in Thailand - and how to solve them

  • 1. ISSUES IN THAILAND …AND HOW TO SOLVE THEM ยุคของการเปลี่ยนแปลงในธุรกิจโทรคมนาคม งานวิศวกรรมแห่งชาติ 2560 PRESENTATED AT PRESENTATION BY ALLAN RASMUSSEN
  • 2. THAILAND’S TELECOM MARKET – AN UNLEVEL PLAYING FIELD www.yozzo.com MOBILE OPERATORS PLAYING FIELD MVNO’S PLAYING FIELD Without some form of regulatory measures and changes as described in this presentation, Thailand’s telecoms market will remain an unleveled playing field, where competition and innovation of mobile services, and thereby the digital economy, may not evolve as it should - or at all. The government has provided the platform for private industries to participate and form the final stages of Thailand 4.0 – however the current regulation from NBTC - or lack off, has not been able to follow suit but only concentrated on the existing silos in the market instead of getting all the wheels to spin. Luckily, most of the issues evolves around issues created by NBTC itself i.e. home made quick fix paragraphs, lack of action, or lack of knowhow by the time MVNO was introduced, which demands less effort to solve.
  • 3. MVNO’S IN THAILAND – WHY IT FAILED In 2009 five MVNO’s where given a license by the telecom regulator NBTC to operate as MVNO’s on the state enterprise telecom operator TOT AS OF NOVEMBER 2017 ONLY 1 MVNO IS LEFT i-Kool 3G (Loxley) UNLEVEL PLAYING FIELD - UNRESOLVED POOR PLANNING AND EXECUTION LEGACY SYSTEMS AND RED-TAPE INSUFFICIENT NETWORK CAPACITY AT LAUNCH INSUFFICIENT MVNO EXPERIENCE AND QUALITY POOR MVNO CONTRACTS AND REGULATION www.yozzo.com MVNO IN THAILAND HAVE FAILED BECAUSE OF THE FOLLOWING REASONS
  • 4. THAILAND’S “SUPERBOARD” FAULTS THE REGULATOR NBTC FOR MVNO FAILURE www.yozzo.com In 2016, The Inspection and Evaluations Commission (also known as the “Superboard”) of the National Broadcasting and Telecommunications Commission (NBTC), failed the telecom regulator and concluded that: …NBTC should issues regulations for mobile virtual operators to support more of them in the Industry, which should benefit consumers.
  • 5. WHAT HAS THE REGULATOR NBTC DONE ABOUT IT? www.yozzo.com noth•ingPronoun not anything; no single thing. Adjective having no prospect of progress; of no value
  • 6. BUT CONTINUES TO SELL MVNO LICENSES 51COMPANIESHAVE OBTAINED A MVNO LICENSE IN THAILAND ONLY 9 HAVE LAUNCHED – 5 ARE STILL ALIVE www.yozzo.com MVNO LICENSES ISSUED IN THAILAND AS OF DECEMBER 2017
  • 7. MVNOS, ARE AN INTEGRAL PART OF THE GLOBAL MOBILE LANDSCAPE Over the past 18 years, MVNOs have helped stimulate competition in the mobile market, launching innovative tariffs and services and attracting niche consumer segments at a lower cost than mobile network operators (MNOs). In Europe virtually every cable and fixed-line operator has a mobility strategy, largely based on MVNO • 1000+ INDEPENDENT MVNOS WORLDWIDE • MVNOS INCREASED 70% BETWEEN 2010 AND 2015 • 72 COUNTRIES HAVE MVNOS IN OPERATION • MVNOS ACCOUNT FOR 14% OF THE TOTAL EU MARKET • EUROPE IS HOME TO: 595 MVNOS, APAC: 137, US: 111 • 1 OUT OF 10 PEOPLE IN AUSTRALIA IS A MVNO CUSTOMER TODAY, MVNOS HAVE REACHED 214 MILLION USERS WORLDWIDE, AND IS ESTIMATED TO GROW TO 300 MILLION USERS AND A $70 BILLION VALUE IN 2020 Ovum predicts that nearly 24% of all new subscriber connections over the next five years will come from MVNO subscribers. Although the current enterprise market represents less than 10% of these connections now, they expect it triple to 30% By 2020, IDC predicts that 30% of the top 500 companies in Thailand will see the majority of their business depend on the ability to create digitally- enhanced products, services and experiences Overall connection growth for mobile phone service around the world was about 4.5% end of 2015. MVNO connections are growing at about 18% per annum 4 times faster than the average rate for the mobile industry. Source IDC Thailand With a predicted compound annual growth rate (CAGR) of over 10% in the forecast period to year 2020, the Asia Pacific region is home to the world’s fastest growing MVNO sector, even more than the highly competitive MVNO markets of Europe and North America. Grand View Research www.yozzo.com
  • 8. …AND HAVE DELIVERED THE RATIONALE FOR THE INTRODUCTION OF MVNO, INCLUDE - BUT ARE NOT LIMITED TO:  Stimulate competition,  Efficient utilization of network resources,  Introduce new or better services aligned to lifestyle propositions currently unserved/underserved,  Promote investment opportunities for local and international businesses in the telecom market. Consequently, MVNOs are intended to support innovation, bridge digital divide, and contribute to the growth in the ICT sector to ensure the achievement of the broader industry and DIGITAL ECONOMY OBJECTIVES. THE CLEAR INTERNATIONAL EVIDENCE IS THAT MVNOs HAVE DELIVERED:  More consumer choice  Innovative pricing plans  Innovative products and services  innovation in, and better customer service www.yozzo.com
  • 10. THAILAND’S TELECOM ECOSYSTEM MNO = MOBILE NETWORK OPERATOR MNO Is a Mobile Network Operator who owns its own network infrastructure and has licensed allocated spectrum. In Thailand the MNO’s are: AIS, CAT Telecom, DTAC, TOT and TRUE www.yozzo.com
  • 11. MOBILE NETWORK OPERATORS OWN THE INFRASTRUCTURE www.yozzo.com
  • 12. AND LICENSE THE SPECTRUM www.yozzo.com
  • 13. FROM THE NATIONAL TELECOM REGULATOR (NBTC) NBTC www.yozzo.com
  • 14. THE 900/1800/2100MHz SPECTRUM LICENSES STATES 10% OF THE CAPACITY MUST GO TO MVNO’S MVNO 10% www.yozzo.com
  • 15. HOWEVER IN THAILAND ONLY CAT TELECOM AND TOT HOST MVNO’S MVNO STATE ENTERPRISE STATE ENTERPRISE www.yozzo.com
  • 16. HOW MVNO’S CONNECT: MVNO’S CAN CONNECT TO MNO’S DIRECTLY MNO MVNO MVNO A MVNO does not own spectrum, instead it enters into an agreement with either a MNO or MVNA to obtain access to airtime at wholesale rates, and then sets its own retail price and service. An MVNO may invest in its own operational components or employ the services of a Mobile Virtual Network Enabler (MVNE) MVNO = MOBILE VIRTUAL NETWORK OPERATOR www.yozzo.com
  • 17. MVNO’S CAN CONNECT TO MNO’S THROUGH A MVNA MNO MVNA MVNO MVNO A MVNA is an entity, who buys mobile airtime in bulk from the MNO, and then wholesale the airtime to MVNOs. The MVNOs retails the airtime to its end-users MVNA = MOBILE VIRTUAL NETWORK AGGREGATOR www.yozzo.com
  • 18. MVNO’S CAN CONNECT TO MNO’S THROUGH A MVNE MNO MVNE MVNO MVNO Provides infrastructure and services to both the MNO and MVNOs, which enables MVNOs to offer their services on the MNOs network, while leaving the “telecom” enablement to the MVNE. The MVNE provides services, such as billing, business workflow, product setup, service delivery, customer care, fraud management, reporting, sale platforms, device management, etc. MVNE = MOBILE VIRTUAL NETWORK ENABLER www.yozzo.com
  • 19. MVNO’S CAN CONNECT TO MNO’S THROUGH A MVNE/MVNA MNO MVNA/MVNE MVNO MVNO The MVNA/MVNE purchases airtime in bulk from the MNO, adds the operational telecom components on top, and then wholesales the airtime and service as a full turnkey solution to MVNOs. The MVNA/MVNE also offers additional value add to the MNVOs in terms of guidance during setup, launch and operation. MVNA + MVNE = MOBILE VIRTUAL NETWORK AGGREGATOR + ENABLER www.yozzo.com
  • 20. PROBLEM #1 IN THAILAND THE MNO TRIANGLE www.yozzo.com
  • 21. MYSTERIOUS CIRCUMSTANCES - THE BERMUDA TRIANGLE Florida Bermuda Puerto Rico North Atlantic Ocean THE NORTH ATLANTIC OCEAN HAS ITS BERMUDA TRIANGLE Where ships and airplanes has mysteriously gone missing www.yozzo.com
  • 22. MYSTERIOUS CIRCUMSTANCES - THE MNO TRIANGLE IN THAILAND LIKEWISE IN THAILAND WE HAVE THE MNO TRIANGLE Where MVNOs for mysteriously reasons haven’t been able to launch for 5 years www.yozzo.com
  • 23. DESPITE THE MVNO CRITERIA AND CAPACITY ON THE 2100MHz LICENSES Prior to Thailand’s 2100MHz 3G auction in 2012, the NBTC released the following Criteria and Procedure for the Spectrum. 16.5.1 The Licensee shall provide telecommunications network service with the minimum capacity of 10 percent of its networks to the MVNO who is not the Connected Person in the Shareholding Structure with any licensee when receiving such service request AIS 90% DTAC 90% TRUE 90% NBTC Notification | http://www.parliament.go.th/ewtcommittee/ewt/tele/ewt_dl_link.php?nid=144&filename=index www.yozzo.com
  • 24. DESPITE THE MVNO CRITERIA AND CAPACITY ON THE 900MHz & 1800MHz LICENSES As with the 2100MHz spectrum, the NBTC has also added a MVNO clause in the terms for the 900MHz and 1800MHz licenses (2015/2016) (1) The Licensee shall comply with the Commission’s Notification Regarding Mobile Virtual Network Operator Service 2013. (2) The Licensee shall provide telecommunications network service at least 10 percent of its network’s capacity to MVNO(s) that is/are not the connected person(s) with any licensee under this Notification, upon receiving such service request. AIS 90% True 90% True 90% AWN (AIS) 90% 900MHz 900MHz 1800MHz 1800MHz PDF | NBTC 900MHz Criteria (English) | http://auction.nbtc.go.th/getattachment/HOME/900MHz_Criteria_Eng.pdf.aspx PDF | NBTC 1800MHz Criteria (English)| http://auction.nbtc.go.th/getattachment/HOME/1800MHz_Criteria_Eng.pdf.aspx www.yozzo.com
  • 25. No MVNO’s have been able to launch on AIS, DTAC or TRUE despite the license terms saying the operators of 900, 1800 and 2100MHz have to provide at least 10% capacity to MVNO’s www.yozzo.com
  • 26. THE MNO TRIANGLE SOLUTION www.yozzo.com
  • 27. THE MNO TRIANGLE SOLUTION 1. The NBTC should publish a clear policy statement requiring the telecom network operators to provision MVNOs on their network. 2. The NBTC should exercise its regulatory mandate to monitor the market and the negotiations to ensure that mobile network operators conduct negotiations fairly and in good faith - and that the policy objectives of the mobile market are fulfilled. 3. The detailed terms and conditions of MVNO provisioning should first be left to the parties to negotiate on a purely commercial basis 4. It would be in the public interest for the NBTC to intervene, and assist the parties - or if necessary, settle and resolve in case a mobile network operator is acting in bad faith, engaging in any form of anticompetitive conduct, or if, after a reasonable period (1 months) of in-good-faith negotiations, a commercial agreement cannot be reached between the parties. 5. The NBTC should follow up on a monthly basis to see if there is a progress in on-boarding MVNOs, and take measures if not. In addition, and as a last resort only, if no progress is made - a regulatory mechanism allowing the NBTC to intervene, to:  Ensure fair and reasonable terms for access  Safeguard fair and non-discriminatory competitive behavior  Bring parties to the negotiating table at the earliest opportunity  Introduce and safeguard the principle of in-good-faith commercial negotiations. i.e., the mobile network operator shall enter into a wholesale agreement with the MVNO, within a period of 1 months from the date of issuing a Letter of Intent (LoI) or Memorandum of Understanding (MoU) and submit a copy of the same to the NBTC (licensor). NBTC would have the power to intervene in the agreement if deemed necessary by one of the parties. The Regulations/Directives/Orders of NBTC in this regard would be binding on the telecom network operators and the MVNO. www.yozzo.com
  • 28. NO MVNO – NO LICENSE NBTC is planning an auction for one 850Mhz and three 1800MHz spectrum licenses in 2018. It would suit the regulator well to live up to its reason to exist, by facing the issue of un-used MVNO capacity among the three existing spectrum license holders. One suggestion would be to add to the auction terms and conditions, that in order to participate in the upcoming spectrum auction, an existing license holder, who has not yet lived up to the terms and conditions in its previous spectrum license regarding MVNO capacity, would have to launch at least one MVNO, on their networks in order to participate in the spectrum auctions. The mobile network operators should be given a maximum period of 60 days to present an MVNO proposal. www.yozzo.com The NBTC has been very active in making sure that terms and conditions, such as minimum roll out coverage, license payments, maximum retail pricing, etc. has been followed by the 900/1800/2100MHz auction winners, while zero attention - nor consequences has been given regarding the MVNO capacity.
  • 29. PROBLEM #2 IN THAILAND NO FULL MVNO www.yozzo.com
  • 30. NO FULL MVNO IN THAILAND = NO CONTROL OF THEIR OWN BUSINESS www.yozzo.com
  • 31. TYPES OF MVNO’S AND OPERATING MODELS NETWORK APP. & SERVICES CUSTOMER ACTIVATION CUSTOMER BILLING CUSTOMER SERVICE MARKETING SIM & VOUCHER MANAGEMENT SALES & DISTRIBUTION HANDSET MANAGEMENT BRANDED RESELLER SERVICE PROVIDER ENHANCED MVNO FULL MVNO Functions carried out by MVNOMVNOFunctions Carried out by MNO MVNOMVNO MVNO MVNO MVNO MVNO MVNO MVNO MVNO MVNO MVNO MVNO MVNOMVNO MNO MNO MNO MNO MNO MNO MNO MNO MNO MVNO MNO MNO MVNO MVNO MNO MNO MVNOMVNO MVNO MVNO MVNO MNO = Mobile Network Operator MNO MNO MVNE MVNE MVNEMVNEMVNEMVNEMNO MVNEMVNE MVNE Functions carried out by MVNEMVNE MVNO = Mobile Virtual Network Operator MVNE = Mobile Virtual Network Enabler MNO MVNO types, e.g. branded reseller, thin, medium, or full MVNO’s, are defined by which of the operational components the MVNO manages, and which one the network operator – or MVNE manages. www.yozzo.com
  • 32. FULL MVNO = CONTROL OF OWN BUSINESS AND FLEXIBILITY TO PROVIDE INNOVATIVE SERVICES A Full MVNO has complete control over its operation, data, SIMs, customers and services due to certain core network elements such as: • GMSC (Gateway Mobile Switching Centre) • HLR (Home Location Register) • SMSC (Short Message Service Centre), • MMSC (Multimedia Messaging Service) • GGSN (Gateway GPRS Support Node) Full MVNO’s can also have their own roaming and interconnect agreements with other MNOs. HLR/HSS SMSC GMSC VOICEMAIL MMSC GGSN www.yozzo.com
  • 33. MVNO POSITIONING LOW HIGHPRICING SERVICEOFFERING ”No frills” MVNO’s MVNO’s based on convinience Traditional Mobile Operators MVNO’s based on value addition INNOVATIVE IoT/M2M MVNO’s As a FULL MVNO the MVNO can have control over services they can offer in the market, and thereby the flexibility to innovate and compete on new service offerings in the market www.yozzo.com
  • 34. AS WELL AS TACKLING DIVERSE, URGENT AND SIMULTANEOUS DEMANDS ON A HOURLY BASIS  Travel & Leisure MVNO needs to urgently resolve customer billing disputes before start of Songkran holiday season tomorrow  Ethnic MVNO wants to launch mothers day promotions before competitor launches its promotions  OTT MVNO wants to launch zero rating service on videos from its own portfolio to compete in the market against HBO, Netflix  Bank MVNO wants to utilize bulk of sales-force tomorrow to visit its premium customers to make a one-day only offer for rate plan upgrades 1 2 4 6  Retail MVNO wants to provide extra bonus points in loyalty program to drive sales this weekend  Retail MVNO wants to access its user usage data) to better address the needs and wants of its own customers 35 MVNO MVNO MVNO MVNO MVNO MVNO www.yozzo.com
  • 35. THAILAND vs. SINGAPORE 4 - 0 Let’s say Thailand wins 4-0 over Singapore in football, and the whole country is celebrating the victory on social media. The MVNOs also wants to join the celebrations by providing the customers with a 20% discount on all voice calls EXAMPLE www.yozzo.com
  • 36. IN THAILAND TODAY WEEK 1 WEEK 3 MONTH ? MONTH ? Fax your request to the MNO Present your case at a meeting with the MNO Internal meeting at the MNO to approve or not Wait for result This is how it ”works” today in Thailand if MVNO’s want to introduce new promotions, service - or tackle issues www.yozzo.com
  • 37. …Meanwhile Thailand will have lost to another country in both football and innovation www.yozzo.comEXAMPLE
  • 38. NOT ALLOWING FULL MVNO KILLS INNOVATION AND CREATES AN UNLEVEL PLAYING FIELD LOW HIGHPRICING SERVICEOFFERING Traditional Mobile Operators INNOVATIVE www.yozzo.com The MVNOs will not be able to compete on neither services, pricing - or introducing new innovations to the market, thereby giving the traditional mobile network operators an unfair advantage, severely limiting innovation and competition in the market
  • 39. THE SOLUTION www.yozzo.com • Allow Full MVNO’s (like in other markets), to level the playing field, foster innovation and competition for the benefit of the consumers
  • 40. PROBLEM #3 IN THAILAND DOUBLE / TRIPLE LICENSE FEE www.yozzo.com
  • 41. UNFAIR DOUBLE LICENSE FEE HURTING THE MVNO AND CONSUMERS OPERATOR MVNO License Fee Total 1.5% 1.50% License Fee 3.50% USO Fee Total 5% New Voice Call Cost THB 105 New Voice Call Cost THB 106,57 Voice Call Cost THB 100 The operator pays NBTC 1.50% of revenue in license fee + 3.50% of annual revenue in USO fee - Total 5% Example: The operator sells THB 100 worth of voice calling to the MVNO which is THB 100 + 5% fee = THB 105 The MVNO pays NBTC 1.5% of annual revenue in license fee. Example: The MVNO sells the now THB 105 worth of voice calling to customers. THB 105 + 1.5% fee = THB 106,57 ❶ ❷ TOTAL = 6.50% 2 x 1.5% License Fees (MNO+MVNO = 3% 1 x 3.5% USO Fee (MNO) = 3.5% REGULATOR Un-level playing field as the operator can sell directly to customers for just THB 105 vs. the MVNOs THB 106,57 MVNO As the host operator and MVNO each have to pay the license fees of annual revenue, the same mobile signal (voice/sms/data) ends up having double the tax, when it ends up at the MVNO and its customers. ❸ www.yozzo.com In 2009 the NBTC introduced Mobile Virtual Network Operator (MNVO) license along with a license fee scheme up to 1.5% of yearly revenue. However, the setup of the license fees causes the burden to be pushed to the MVNOs and consumers, as the NBTC is charging double fees on one ”signal”. + += =
  • 42. UNFAIR TRIPLE LICENSE FEE HURTING THE MVNO AND MVNA OPERATOR MVNA MVNO MVNA License Fee Total 1.5% MVNO License Fee Total 1.5% 1.5% License Fee 3.5% USO Fee Total 5% New Voice Call Cost THB 105 New Voice Call Cost THB 106,57 New Voice Call Cost THB 108,17 Voice Call Cost THB 100 As the MNO, MVNA and MVNO each have to pay the license fee, the same mobile signal (voice/sms/data) ends up having triple tax, when it arrives at the MVNOs and the consumers The operator pays NBTC 1.5% of revenue in license fee + 3.5% of annual revenue in USO fee - Total 5% Example: The operator sells THB 100 worth of voice calling to the MVNA i.e. THB 100 + 5% fee = THB 105 The MVNA pays NBTC 1.5% of annual revenue in license fee Example: The MVNA resells the now THB 105 worth of voice calling to the MVNO. I.e. THB 1,05 + 1.5% fee = THB 106,57 The MVNO pays NBTC 1.5% of annual revenue in license fee Example: The MVNO sells the now THB 106,57 worth of voice calling to customers. I.e. THB 106,57 + 1.5% fee = THB 108,17 ❶ ❷ ❸ TOTAL = 8% 3 x 1.5% License Fees (MNO, MVNA, MVNO) = 4.5% 1 x 3.5% USO Fee (MNO) = 3.5% The operator can sell directly to customers for just THB 105 vs. the MVNOs THB 108,17 ❹ www.yozzo.com In 2009 the NBTC introduced Mobile Virtual Network Operator (MNVO) license along with a license fee scheme up to 1.5% of yearly revenue. However, the setup of the license fees causes the burden to be pushed to the MVNA, the MVNO and consumers, as the NBTC is charging triple fees on one ”signal”. + + += = = REGULATOR
  • 43. MVNO’S MAKES ITS BUSINESS ON MARGINS MVNO VS. www.yozzo.com MVNO’s makes its business on the small margins between costs and sale price. They operate a lean and flexible setup where every satang counts. The unfair double, and triple taxation changes the timeline significantly for the MVNO to reach financial breakeven – if ever - given that the current fee structure setup not only adds costs, but also provides the mobile operators with an unfair pricing advantage
  • 44. THE SOLUTION www.yozzo.com Let the MNO and MVNO (MVNA) split the 1.5% license fee like we do with VAT i.e. MNO 0.75% and MVNO 0.75% = 1.5%
  • 45. PROBLEM #4 IN THAILAND BUREAU-CRACY KILLING INNOVATION www.yozzo.com
  • 46. MVNO LICENSE APPLICATION IS IN-CORRECT AND NOT UP-TO-DATE TERMS AND APPLICATION FOR MVNO IN THAILAND IS ABOUT 15-YEARS TO OLD www.yozzo.com The application seems to be a copy and paste from old applications and various countries in early 2000’s In mid-2017 the NBTC added a MVNA license to the market without request for consulting or public hearing, ending up using the MVNO application for MVNA license as well.
  • 47. LICENSE APPLICATION BUREAU-CRAZY NBTC OFFICER HAS TO UNDERSTAND & APPROVEFILL-OUT & HAND-IN THE APPLICATION NBTC has added their own little notice to the act regarding license approval. The NBTC officer can decline the application if he/she doesn't understand, either due to language, the service, network etc. www.yozzo.com
  • 48. LICENSE APPLICATION BUREAU-CRAZY ONCE APPROVED, THE OFFICER HANDS THE APPLICATION TO NBTC’S SECRETARY-GENERAL TO SIGN BECAUSE THE OFFICER IS RESPONSIBLE www.yozzo.com
  • 49. LICENSE APPLICATION BUREAU-CRAZY THE MVNO LICENSE IS GIVEN BASED ON THE APPROVED INFORMATION I.e. The information given and approved is part of the license – License valid for 5-years www.yozzo.com
  • 50. LICENSE APPLICATION BUREAU-CRAZY HOWEVER… ? The NBTC officer will not uderstand new innovative service from the MVNO and decline it because he/she is responsible, and it does not fit the boxes. Therfore all MVNOs are the same in Thailand - even MVNAs have to use the MVNO application form which makes no sense www.yozzo.com
  • 51. BUREAU-CRACY KILLS INNOVATION AND OPENS FOR CORRUPTION The officer becomes a single gatekeeper, which opens for corruption The setup opens a ”backdoor virus” for further corruption. Because… The MVNO license is valid for 5- years and consist of the information provided in the application. That information is however outdated because it has to fit the old standard and knowhow from the officer. Once the MVNO launch in the real world with technology and interfaces according to updated standards the regulator can come back at anytime and say the MVNO is not operating accoding to the license (information provided in the license) and demand they stop operation – or solve it with a brown envelope. www.yozzo.com
  • 52. GETTING A LICENSE WITHOUT AN AGREEMENT Thailand is among few, if not the only country in the world, where you can get a MVNO license without some sort of agreement (MoU) with a mobile operator (or MVNA/MVNE) www.yozzo.com
  • 53. GETTING A LICENSE WITHOUT AN AGREEMENT – HOW? MVNO LICENSE IS GIVEN BASED ON THE APPLICATION INFORMATION FILL-OUT & HAND-IN THE APPLICATION HOW? www.yozzo.com
  • 54. GETTING A LICENSE WITHOUT AN AGREEMENT – HOW? Question: How does a MVNO without a host operator agreement fill out 9,10, 11, 12? Answer: They fill in ALL operators as example and use a network diagram from the 90’s Who would buy equipment BEFORE having an MNO agreement AND a license? www.yozzo.com
  • 55. THE SOLUTION www.yozzo.com • Update the license application to the present and amend it from time to time. • Drop the added clause that the officer has to understand, approve and be responsible. • There is no reason to provide a license prior to an agreement with a MNO/MVNA/MVNE. • Introduce a real MVNA license application = do not use the MVNO application it’s not the same. BUT BETTER YET… • Drop the need for MVNA/MVNO application/license altogether in-line with other countries who no longer issues MVNO licenses. Doing so would make sense, as most of the issues releated to MVNO in Thailand, as discussed in this presentation would need an update or be removed. We are aware that NBTC is very keen on licenses in order to collect fees, and we therefor suggest a solution, where NBTC could maintain a very simple MVNO and MVNA license scheme, purely for the sake of collecting its license fees.
  • 56. Presentation by Yozzo Co.,Ltd.  www.yozzo.com  March 2016 DISCLAIMER Some statements made in this material are forward-looking statements with the relevant assumptions, which are subject to various risks and uncertainties. These include statements with respect to corporate plans, strategies and beliefs and other statements that are not historical facts. These statements can be identified by the use of forward-looking terminology such as “may”, “will”, “expect”, “anticipate”, “intend”, “estimate”, “continue” “plan” or other similar words. The statements are based on our assumptions and beliefs in light of the information currently available to us. These assumptions involve risks and uncertainties which may cause the actual results, performance or achievements to be materially different from any future results, performance or achievements expressed or implied by such forward-looking statements. Please note that the company and executives/staff do not control and cannot guarantee the relevance, timeliness, or accuracy of these statements. Copyright © 2017 Yozzo Co.,Ltd. All Rights Reserved.