Public hearing: Promotion of MVNOs and an urgent need for a clear spectrum action plan

Written by
Allan T. Rasmussen
Published on
April 23, 2024
Thailands Telecommunication Master Plan Promote competition via MVNOs

Public hearing on Thailand’s Telecommunication Master Plan: Promotion of MVNOs and an urgent need for a clear spectrum action plan

Thailand’s telecom regulator NBTC, held a public hearing (April 23), on the Telecommunications Master Plan No. 3 (2024-2028) draft, highlighting strategies to “promote competition via MVNOs, reduce digital inequality and protect consumers


The Telecommunications Master Plan draft consists of strategies for development in 5 areas:

Strategy 1: Amend the regulations to develop an environment that allows for increased competition, the creation and enablement of MVNOs.

Strategy 2: Reducing the digital divide and promote access to and utilization of a wide range of telecom services to cover both spatial and social dimensions.

Strategy 3: Effective management of telecommunications resources. Efficient frequency allocation Create a spectrum allocation plan (Spectrum Roadmap) for various businesses.

Develop criteria for granting permission to use frequencies in the public sector and frequency bands for general use, in order to be able to allocate spectrum in line with needs and value. Review guidelines for allocation and utilization of frequencies for efficient and cost-effective use.

Strategy 4: Develop the licensing and regulation to suit the digital industrial ecosystem.

Strategy 5: Improve consumer protection in the digital age. Focus on providing consumers with knowledge and understanding of consumer rights in telecommunications business. Strengthen consumer knowhow to be able to protect themselves from threats.The participants at the public hearing included member of the public, representatives from the private sector, and government agency representatives.

Although all five strategies, is on the agenda for the public hearing, most of the participants at the hearing wants the NBTC to make a clear spectrum management plan (Spectrum Roadmap), and urged the NBTC to improve the ecosystem and framework for mobile virtual network operators (MVNO) to bring much needed competition into the market.

Captain Ativat Asvasirayothin, Chair and founder of the MVNO A Telecom Company Limited, expressed the opinion that the MVNO license system should be updated - from only Thin and Medium MVNO - to also include Full MVNO. He also suggested that the NBTC should enforce the regulations and encourage the large operators to allow MVNOs on their networks with the NBTC setting the details on wholesale pricing. "This would keep MVNO costs low enough to be competitive".

Admiral Prasarn Sukkaset, Chair of the NBTC’s Performance Monitoring and Evaluation Committee said: "Last year, MVNOs declined significantly, as competition in the market was reduced by the True-Dtac merger. We also urge operators to return profits to society from their ability to reduce costs from reduced business competition, and asked for an increase in the market concentration index (HHI), which measures the level of competitiveness in the market”.

Representatives from the Office of the Trade Competition Commission (TCCT), joined in expressing their opinions regarding inequality, noting that inequality is not just in terms of access to telecommunications services. But there are also disparities between entrepreneurs.

The concern of the TCCT is on competitive pricing standards, because now the big operators can lower their prices but the smaller operators cannot, so the NBTC should create equality in competition.”

Public sector representatives who have worked in the telecommunications industry for more than 20 years also gave their opinion that spectrum frequency plans "need to be more detailed than they used to be, because there is a range of spectrum that is about to expire, and how many new ones will be auctioned?"

In relation to effective management of spectrum frequencies, MVNO representatives urged the NBTC to speed up, and make a clear Spectrum Roadmap, especially in the case of National Telecom’s (NT) spectrum that is about to expire

Since the introduction of telecom licenses and MVNOs in Thailand in 2013, the only operator to allow MVNOs onto its network has been TOT and CAT (Now NT), despite the license conditions of AIS and TRUE/DTAC, clearly stating that they must provide minimum 10% capacity to MVNOs, none of them have ever hosted a MVNO, despite several attempt from both mobile virtual aggregators (MVNA), enablers (MVNE) and operators (MVNO).

Atip Keeratipich, CEO of the MVNO Red One Network (Thailand) said: "We are dependent on NT who is gracious to us. But the 850 MHz, 2100 MHz and 2300 MHz bands held by NT will expire in September 2025. Therefore, we have an urgent need to see an Action Plan including the MVNO’s agenda, and additional time period from the NBTC, because we are not able to make a 5 year business plan. We hope the NBTC will accept and consider this".Stakeholders, organizations and the public can share opinions and suggestions to the Telecommunications Master Plan No. 3 (2024-2028) draft.

The comment form can be submitted from 2 April 2024 until 16 May 2024 via the following channels:

1) By e-mail: telecompolicy@nbtc.go.th

2) Delivered in person or by registered mail at the following address:

NBTC Office (Office of Academic Affairs and Telecommunications Resource Management)

No. 87 Phahon Yothin Road, Soi 8 (Sailom), Samsen Nai Subdistrict,

Phaya Thai District, Bangkok 10400.

Comment form and more information available at the NBTC's website

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In a formal letter submitted to the NBTC, the Consumer Council emphasized the necessity for a comprehensive stakeholder consultation before proceeding with the auction, which encompasses the 850 MHz, 1500 MHz, 1800 MHz, 2100 MHz, 2300 MHz, and 26 GHz frequency bands.

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Thailand’s Consumer Council (TCC) has issued a strong appeal to the National Broadcasting and Telecommunications Commission (NBTC), urging the postponement of the upcoming mobile spectrum auction.

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66.17M 99.41M 150% 72%
Population Mobile Connections Mobile Penetration Prepaid Market Share
As of 2021 EoY 2021 EoY 2021 EoY 2021
66.17M 99.41M 150% 72%
Population Mobile Connections Mobile Penetration Prepaid Market Share
As of 2021 EoY 2021 EoY 2021 EoY 2021

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66.17M 99.41M
Population Mobile Connections
As of 2021 EoY 2021

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19.67M
5G Package Subscriptions

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Market Year Acquirer Target Subs Deal Per/Sub
Denmark 2003 TDC Telmore 460K €53.7M €117
Germany 2003 Carphone Warehouse Hutchison 540K €52M €96
Norway 2004 TeliaSonera Chess/Sense 405K €185M €457
Sweden 2004 TeliaSonera Sense 1.8M €189M €104
Denmark 2004 Sonofon CBB 437K €17.5M €40
UK 2006 NTL Virgin UK 3.3M €1.06bn €318
Germany 2007 Vodafone AG Allmobility 404K €25M €62
Switzerland 2008 Sunrise Tele2 525K €33M €63
France 2009 Virgin Tele2 400K €56M €140

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MVNO/Service price VOICE (THB/minute)* DATA (THB/MB) SMS (THB/SMS) MMS (THB/MMS)
Penguin SIM (Prepaid) 0.9 0.45 2 No service
I-Kool 3G (Prepaid) 0.8 0.24 1.75 No service
Feels (Prepaid) 0.77 0.21 1.8 No service
Redone (Postpaid*) 0.62 0.05 No SMS promotion in main package No service
MVNOs blended 0.77 0.24 1.85 No service
MNOs (AIS, TRUE, NT) blended** 0.6 0.16 0.89 2.33

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MNO MVNO
APPROACH
Mass Marketing Analytics Marketing
TARGET SEGMENT
Any customer
is a good customer
Each customer cluster has
a different addressable value
APPEAL
Standard
“One-size-fits-all”
Cater to needs that are specific to
each customer, or each segment
VALUE PROPOSITION
Broad value proposition
“Build it and they will come”
Value proposition tailored
to each target customer’s needs
COMMUNICATION STYLE
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and respond to their ideas

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