RESEARCH REPORT A National Telecom Wholesale Network

A NATIONAL TELECOM
RESEARCH
2024 Yozzo Co.,Ltd. All Rights Reserved.
REPORT
WHOLESALE NETWORK

© 2024 Allan Rasmussen. All Rights Reserved. PAGE 1
1 RESEARCH REPORT| A NATIONAL TELECOM WHOLESALE NETWORK IN THAILAND
TABLE OF CONTENTS
EXECUTIVE SUMMARY ....................................................................................................................................3
CURRENT LANDSCAPE AND CONCERNS IN THAILAND:............................................................................................3
PROPOSED SOLUTION: NATIONAL WHOLESALE NETWORK (NWN):...........................................................................3
BENEFITS:.....................................................................................................................................................3
CHALLENGES AND CONSIDERATIONS:.................................................................................................................4
CONCLUSION:................................................................................................................................................4
1. MOBILE VIRTUAL NETWORK OPERATOR (MVNO) ..........................................................................................5
1.1 DEFINITION OF MVNO ...............................................................................................................................5
1.2 MVNO TYPES & OPERATIONAL MODELS........................................................................................................6
1.3 THE MVNO MARKET..................................................................................................................................7
1.4 MVNO STRATEGY: MARKET DIFFERENTIATION AND SEGMENTATION ..................................................................9
1.5 MVNOS COMPETITIVE EDGE .....................................................................................................................10
1.6 MVNOS LEVERAGING ON EXISTING ASSETS ..................................................................................................12
2. MOBILE VIRTUAL NETWORK AGGREGATOR (MVNA)....................................................................................13
3. MOBILE VIRTUAL NETWORK ENABLER (MVNE)............................................................................................15
4. MVNO BENEFITS FOR MOBILE NETWORK OPERATORS.................................................................................17
4.1 FINANCIAL BENEFITS FROM MVNA/MVNE/MVNO COLLABORATION .................................................................17
4.2 FROM A SINGLE BRAND MNO TO A MVNO MULTI-BRAND/SEGMENTATION STRATEGY .........................................18
4.3 MNO/MVNA/MVNE/MVNO BENEFIT CONCLUSION.......................................................................................19
4.4 MNO/MVNA/MVNE/MVNO CASE STORIES ..................................................................................................19
5. THE ISSUES IN THAILAND..........................................................................................................................22
6. SUPPORT FOR MVNA/MVNE/MVNO IN THAILAND......................................................................................28
7. THE SOLUTION: A NATIONAL WHOLESALE NETWORK (NWN).......................................................................30
7.1 BENEFITS:.............................................................................................................................................31
7.2 BENEFITTING ALL STAKEHOLDERS ..............................................................................................................31
7.3 CHALLENGES AND CONSIDERATIONS ..........................................................................................................32
7.4 MODELED ON BEST PRACTICE ...................................................................................................................33
7.5 CASE STORY: MEXICO RED COMPARTIDA.....................................................................................................33
ANNEX: THREE EXAMPLES OF INNOVATIVE MVNOS ........................................................................................36

Version: 1.0a
Status: Final
Date: 15/02/2024
Prepared by: Allan Rasmussen Technology, Media, & Telecom Executive • MVNA/MVNE/MVNO Specialist
The report is also available online here

EXECUTIVE SUMMARY
Exploring the potential of National Telecom Public Company Limited (NT) partnering with a
MVNA/MVNE to launch a National Wholesale Network for Mobile Virtual Network Operators (MVNO)
The merger between True Corporation (TRUE) and Total Access Communication (DTAC) on March 1st
,
2023 in Thailand has significantly reduced competition in the Thai telecommunications market, and
raised concerns about price increases, service quality decline, and lack of consumer choice.
This report explores the benefits of strengthening the role of National Telecom Public Company Limited
(NT), as a neutral player by allowing it to retain its spectrum and partner with a Mobile Virtual Network
Aggregator (MVNA) and enabler (MVNE), to establish a National Wholesale Network (NWN), as a
solution to enable competition into the market via Mobile Virtual Network Operators (MVNO).
This approach can foster competition, drive innovation, utilize existing infrastructure and ultimately
benefit consumers and enterprises by providing them with more choices and innovative mobile services.
Current Landscape and Concerns in Thailand:
The TRUE-DTAC merger created a duopoly controlling approx. 97% and raising concerns about:
 Reduced competition: Less choice for consumers, higher prices and lower service quality.
 Limited innovation: Reduced incentive for the duopoly to invest in technologies and services.
 Stifling of MVNO growth: Difficulty for MVNOs to access network infrastructure at fair terms.
Proposed Solution: National Wholesale Network (NWN):
 Allow NT to retain its spectrum currently slated to be returned next year (2025).
 NT partners with an MVNA/MVNE to enable a National Wholesale Network accessible to MVNOs.
 MVNOs can then use the NWN and offer competitive and innovative mobile services.
Benefits:
 Increased competition through MVNOs providing greater choice and affordable services.
 Enhanced innovation: MVNOs are well-known for driving innovation in the telecom sector.
 Improved MVNO access: A neutral wholesale network would provide MVNOs with fair and
transparent access to network infrastructure, fostering their growth.
 Promotion of Digital Inclusion: MVNOs often target specific niche markets or rural areas with
tailored offers. A wholesale network could enable them to provide affordable mobile services to
underserved populations, contributing to digital inclusion and closing the digital divide.
 Utilization of unused spectrum: Leveraging NT's unused spectrum would improve spectrum
efficiency and contribute to Thailand's digital development goals.

Challenges and Considerations:
 Clear Regulatory Framework: ensuring fair competition and prevent anti-competitive practices.
 MVNA/MVNE: The right MVNA/MVNE partner is crucial. The ideal partner should be independent
and possess strong expertise in MVNO operations and technology, along with a deep understanding
of the Thai market. Effective collaboration and clear roles within the partnership is essential.
 Business Model Viability: Generating sufficient revenue from wholesale leasing to sustain the
network and attract MVNOs will be crucial. Carefully considering pricing models, independence and
trustworthiness and ensure sufficient demand from MVNOs are key factors for success.
 Network investment and operational costs: Maintaining a National Wholesale Network requires an
efficient operation. NT has most of the infrastructure and spectrum in place already.
 Impact: The potential disruption to existing market dynamics needs consideration.
Conclusion:
Allowing NT to retain its spectrum and partner with an MVNA/MVNE to create a National Wholesale
Network for MVNOs presents a strong solution to address the concerns arising from the duopoly.
This approach would foster a more competitive and innovative mobile market, benefiting consumers
and contributing to Thailand's digitalization goals. However, careful consideration of the
implementation of a well-defined framework are crucial for successful execution.
Further Research:
 Detailed analysis of the potential economic impact of the proposed solution.
 Benchmarking with similar initiatives in other countries.
 Development of a regulatory framework.
Disclaimer:
This report does not constitute a comprehensive analysis of all potential benefits and implications.

1. MOBILE VIRTUAL NETWORK OPERATOR (MVNO)
1.1 Definition of MVNO
The industry and national regulatory authorities (NRA), have over the years adopted various local
definitions for Mobile Virtual Network Operators (MVNO)1
, but taking it word by word, provides a
clearer understanding of the MVNO concept.
MOBILE - transportable, transferable, or movable. Relating to mobile cellular phones, handheld devices,
and similar wireless technology.
VIRTUAL - almost, or nearly as described, but not completely.
NETWORK - connect as, or operate with a network.
OPERATOR - a person or company that engages in, or runs a business or enterprise.
Although there is no unified international standard on what precisely defines a MVNO, the International
Telecommunication Union (ITU), defined MVNO as2
:
“A Mobile Virtual Network Operator (MVNO) is an operator that offers mobile
services but does not own its own radio frequency. Usually, this operator has
its own network code and in many cases issues its own SIM card. The mobile
VNO can be a mobile service provider or a value-added service provider. It is
to be noted that there are differing views on how to define a mobile VNO.”
Based on a combination of the definitions from various national regulatory authorities and the ITU, an
updated MVNO definition, look like this:
MVNO DEFINITION
A Mobile Virtual Network Operator (MVNO), is an entity, that offers telecommunications services similar
to a mobile network operator (MNO). However, an MVNO does not own radio frequency spectrum nor
radio access network. Instead, the MVNO enters into a commercial agreement with a provider that has -
and then provide its own service to its customers, under its own brand, value proposition and pricing.
1 MVNO Definitions in various countries: https://www.yozzo.com/mvno-academy/mvno-definition/
2
ITU: Regulatory Treatment of Mobile VNOs | https://www.itu.int/osg/spu/ni/3G/resources/MVNO/index.html

1.2 MVNO Types & Operational Models
Beside the definition of Mobile Virtual Network Operator (MVNO) in itself, some national regulatory
authorities have also adapted a range of sub-categories, or ”MVNO Types & Operational Models”3
, to
further define and categorize the individual MVNOs.
These Types and Operational Models are largely defined by which of the operational components,
network elements or facilities the MVNO manages and which one the host network operator manages,
or the MVNE - indicating the depth of the individual MVNO’s market participation.
Based on this criterion, three main types of MVNO and operational models are observed: Thin, Medium
and Full MVNO.
Note that the Full MVNO model is not available in Thailand.
Table 1: Operational Mode: Thin, Medium, Full MVNO and MVNE Architecture
Functions
Thin
MVNO
Medium
MVNO
Full
MVNO
MVNE
Enabling
infrastructure
and provisioning
Radio Access Network MNO MNO MNO MNO
Network routing MNO MNO MVNO owns MVNE
Content and
Service
Applications
Value added services MNO
MVNO
may own
MVNO owns MVNE
Applications &
Services
MVNO
may own
MVNO
may own
MVNO owns MVNE
Operation
SIM card / Number
MVNO
may own
MVNO
may own
MVNO owns MVNO
Billing system
MVNO
may own
MVNO owns MVNO owns MVNE
CRM
MVNO
may own
MVNO owns MVNO owns MVNE
Marketing MVNO owns MVNO owns MVNO owns MVNE
Branding and
Sales
Sales & Distribution MVNO owns MVNO owns MVNO owns MVNO
Branding MVNO owns MVNO owns MVNO owns MVNO
3
MVNO Types & Operational Models: https://www.yozzo.com/mvno-academy/mvno-types-and-operational-models/

1.3 The MVNO Market
MVNOs are spreading across the globe, from the initial four MVNOs first launched in the UK and
Denmark in year 1999/2000 to more than 2.000 MVNOs - in more than 90 countries, as of year 2023.
Illustration: There are now more than 2.000 MVNOs in more than 90 countries.
Europe continues to lead in terms of most MVNOs in operation with an estimated 1.016 MVNOs,
representing half of the total global MVNO market. It is followed by:
 Americas with 386 MVNOs,
 Asia with 322,
 International: 132,
 Oceania: 86,
 Africa: 57,
 Middle East: 9.

In addition more countries are opening up for MVNOs. In example, Nigeria awarded 43 MVNO licenses
to companies in Nigeria in 2023. The MVNOs are expected to launch in 2024.
The global MVNO market is projected to grow from USD 84.36 billion in 2023 to USD 149 billion by 2030,
representing a compound annual growth rate (CAGR) of 8.5%.
APAC
The Asia pacific MVNO market was valued at USD 29.33 billion in 2021 and it is expected to reach a
value of USD 46.42 billion by 2027, registering 7.93% CAGR.
Competition in the APAC MVNO markets has shifted from pricing to service and product differentiation
while the telecom regulators across the region are leveraging MVNO growth to increase competition
and the digital economy.
THAILAND
In Thailand, only 10 MVNOs have launched out of 60+ MVNO licenses awarded since the introduction of
MVNOs in Thailand in 2013. Four of the ten MVNOs are active today with just about 30.000 active
subscribers combined.
They are:
 iKool3G (Loxley),
 Penguin SIM (Whitespace)
 Feels (Feels Telecom)
 RedONE (From Malaysia).
Chart: The Thai telecom service market as of Q3 2023.
Sources: GSMA Intelligence, NBTC, AIS, TRUE, Global Market Insights, Research & Markets, Yozzo

1.4 MVNO Strategy: Market Differentiation and Segmentation
As mobile connections increase and the mobile penetration reach the saturation point, traditional
mobile network operators (MNOs), find it increasingly challenging to compete and grow organically.
Competition shifts from being predominantly network based – where the MNOs compete on differences
in network quality and coverage – to services based, where competition depend on the ability and
flexibility to match service, price and features with specific consumer needs and wants.
A similar challenge happens when new generations of mobile network technologies are introduced into
a market (3G, 4G, 5G). The MNOs are then (once again), competing against each other on network roll-
out, while also trying to get their own existing subscribers to update to a new and more expensive
package that delivers the same – only with more speed.
“As smartphone makers have shown, communications services are
all about the experience - and experience goes far beyond simply
having network connectivity perform as expected.” - Ericsson
Mobile network operators suffer from the limitations of their traditional method of marketing – a “one-
size-fits-all” strategy, where they approach all consumers, as having similar lifestyle, needs and
demands, resulting in under-served and un-reached segments who does not feel they belong.
Market dissatisfaction comes from either poorly tailored products and services or intangibles, such as a
mismatch between consumers individual lifestyles, and what their operator’s brands stand for.
Some Examples:
 Prepaid mobile customers feel like 2nd class citizens compared to the service offered to postpaid.
 The CFO of an enterprise doesn’t see the value of six months Netflix on the companies SIM cards.
 SMEs does not see the value on unlimited data on the SIMs they use for their calling center.
 Visually impaired persons does not see the value in the added Virtual Reality (VR) service.
 Different consumers simply do not all have identical needs - or identical use habits, which utilize the
same operator value components all the time.

MOBILE OPERATORS are designed for distribution of mass market telecom connectivity services,
however in the digital economy this logic shifts from the current supply focus, into a demand driven
reality.
CONSUMERS in today’s digital economy require personalized, and innovative telecom services, but the
mobile operators continue to deliver one-size fits all connectivity service and offers.
ENTERPRISES are increasingly demanding complete lifecycle services to support their digital business
models and transformation, only to be met with standard offers of connectivity from the MNOs.
1.5 MVNOs Competitive Edge
Mobile Virtual Network Operators (MVNO) have utilized the above issues, achieved a competitive edge
and captured market shares – by capitalizing on market differentiation and segmentation rather than
merely competing on connectivity and price.
Instead of the view of customers as one large, indistinct segment – MVNOs embrace a targeted
approach, creating a unique brand positioning and value proposition to attract a defined niche segment,
such as specific groups or demographics and tailor their service, offer and products to the needs, value
and lifestyle of this customer segment.
“The goal for an MVNO is to make profit by fulfilling the
expectations of the chosen segment, so that the customers
experience the level of service that satisfies their needs.”
Deploying in this way ensures that customers’ needs are more accurately identified, and serviced. In
return, customers respond positively, with growth resulting from the niche segment approach.
MVNOs can target a range of verticals and market segments by offering:
 Connectivity options that can be differentiated according to preference and context (i.e.,
differentiated data tariffs and connectivity for various sites, apps, location etc.).
 Platforms allowing the verticals/industry to control their own connectivity and business (Platform as
a service, Software as a service, Connectivity as a service, Data Analytics, etc.)
 Differentiated non-network services such as customer care, bespoke services, brand and product
characteristics, which create a sense of belonging according to lifestyle.

Fig: Mobile Network Operators(MNO) Marketing Strategy vs. MVNOs
MNO – ONE SIZE FITS ALL MVNO – NICHE SEGMENTATION
MNOs suffer from the limitations of their
traditional “one size fits all” marketing strategy.
Taking consumers as large averaged groups,
resulting in underserved/unreached segments.
MNOs have realized that they can’t be all things - to
everyone and see the value of MVNOs, as partners to
reach specific segments the MNO cannot reach.
MVNOs cater to segments that are underserved
or unreached by the MNOs. They create a unique
value proposition to attract target niche clusters
such as specific groups or demographics.
MVNOs serve those segments that the MNOs can’t
reach by offering services customized specifically to
the end-user lifestyles, needs and demand.
MNO MVNO
APPROACH APPROACH
Mass Marketing Analytics Marketing
TARGET SEGMENT TARGET SEGMENT
Any customer
is a good customer
Each customer cluster
has different addressable value
APPEAL APPEAL
Standard
“One-size-fits-all”
Cater to needs that are specific to
each customer, or each segment
VALUE PROPOSITION VALUE PROPOSITION
Broad value proposition
“Build it and they will come”
Value proposition
tailored to target customer’s needs
COMMUNICATION STYLE COMMUNICATION STYLE
Broadcasting to the market Listening to customers and respond to their ideas

1.6 MVNOs Leveraging on Existing Assets
Some MVNOs have made use of their existing assets including their existing customer base, brand
affinity and distribution channels. They use these assets to create a unique brand positioning and value
proposition in order to attract their target segment – using mobile service more as a transportation to
sell their existing services.
One of the key competitive advantages of MVNOs is that they have a thorough knowledge of their
segment, allowing them to cater to that segment in a far more personal, relevant way than MNOs can.
Table: MVNOs Leveraging on existing assets
CORE ASSETS DESCRIPTION MVNO EXAMPLES
CONTENT / SERVICES
Content or bundle offers across services
(i.e. Internet, TV, Energy, etc.)
Sky, Xfinity, Nova Energy
(ISPs, Cable Co’s, Media).
BRAND
VALUE
Having a renowned brand or high level of
value among the targeted customers.
Red Bull, AC Milan
(Lifestyle, Sports)
CUSTOMER
MANAGEMENT
Being able to offer excellence in the
customer experience/journey.
Lenovo, Panasonic, Sony
(Customer Journey)
DISTRIBUTION
Being in possession of an existing
distribution network. (Off/Online).
PosteMobile, Kookmin Bank
(Postal, FinTech, Logistics)
EXISTING
CUSTOMER BASE
Customer base on which to perform
cross-selling and loyalty programs.
Walmart, FPT Retail, Equitel
(Retailers, Banks)
OPERATIONAL
EFFICIENCY
Being cost-effective with a lean
operating structure.
Tele2, IIJ
(Discount)
TECHNOLOGY
DRIVEN
Being able to offer data analytics, device
and SIM card management.
Cubic Telecom
(IoT/M2M)
DEFINED
SEGMENT
Having a customer/member base with a
defined segment/community.
Lebara, Lycamobile, Uber
(Ethnic, Elderly, Employees)
MVNOs play a key role in penetrating key underserved segments, such as youth, elderly, expatriates,
low-income earners, SME’s, travellers, communities, etc. Segments that the MNOs struggle to
adequately serve because such segments are typically too small for the MNO to justify tailored products
and services.
The lean and agile business model of the MVNO, however, allows highly focused targeting resulting in
benefits to the whole ecosystem: The MNO, the MVNO and the end-users.

2. MOBILE VIRTUAL NETWORK AGGREGATOR (MVNA)
Aggregate, comes from the Latin verb, "aggregāre", which means, to add to - or collect into a mass or
whole. An MVNA aggregates, a mass amount of data capacity (voice, text, data) from mobile operators,
and resell it to MVNOs. In essence, an MVNA is a middleman, between the MNO and the MVNOs.
The entry of MVNAs to the ecosystem has help facilitate the entry of MVNOs by making the
commercialization more efficient for both the MNOs and the MVNOs. The MVNA, is able to provide
tailored offers that suit the needs and individual business models of each MVNO.
Even MVNOs that successfully combine internal resources and partnerships to navigate challenges and
risks will still be disadvantaged to existing players due to lack of economies of scale. MVNOs need scale
to negotiate favorable pricing terms on network leases with MNOs.
Buying on behalf of several MVNO clients, the MVNA obtains capacity access/data from the MNOs in
large bulks, which in return provides the MVNOs with economies of scale benefits, similar to any other,
manufacture-wholesale-retail ecosystem.
Another benefit for the MVNOs, is that the sharing of the business models and KPI’s are shared with the
MVNA and not the MNO. This adds a level of security to the MVNOs, that the MNO will not copy and
launch (before the MVNO) the services or promotion packages, that the MVNO intend to launch.
The MVNA itself, will have to harness the skills necessary to conceive and build customized offers for
multiple MVNOs. MVNAs will need to transform MVNO visions into marketable, functional offers,
featuring an attractive set of mobile products and services.
As eSIM spreads, there will be a growing demand for MVNA-type players who can negotiate agreements
between different operators that provide automatic remote service when users cross borders.

An MVNA needs to have MVNO experience, posses strong analytical skills and market knowledge, in
order to understand, support - but also question the MVNOs business models, subscriber and traffic
forecast, as well as maintain ongoing MNO and MVNO managements.
For example, but not limited to:
 Identify the niche and value proposition,
 Customer Segmentation and needs,
 Product Portfolio,
 Tariffs, Bundles, Voucher, Fraud,
 Advertising and Promotions,
 Subscriber Analysis,
 New Product and Application Specification.
 Legal compliance,
 Definition of sales & payment channels,
 SIM Cards,
 Channel, and Distribution Management.
 Business Intelligence Reporting,
 Bundle and promotion offer development,
 Customer acquisitions & retention campaigns,
 Improvement of operational processes,
 ARPU, Churn management,
 Best time to market (launch services),
 Flexible and enhanced life cycle configuration.
MVNAs will need to play the vitally important partner role, guiding MVNOs’ marketing acquisition and
channel development strategies. Many if not most potential MVNO candidates will not readily know
how to apply existing marketing or distribution knowledge to wireless.
In its relationship with the MNO and MVNO, the MVNA needs to be flexible, agile and share the vision. It
needs to make sure both parties achieve their goals, as the MVNA own success depends on this.
The MVNA will have to obtain flexible and competitive wholesale network agreements with the MNOs.
It may deploy certain elements, which allows it to execute functions for billing, monitoring and
reporting, management of numbering resources, business intelligence, and other services that it
requires to address the needs of multiple client MVNOs.
The MVNA can take these steps directly or enter into a partnership with a Mobile Virtual Network
Enablers or (MVNE).

3. MOBILE VIRTUAL NETWORK ENABLER (MVNE)
Within the value chain, there are intermediary ICT companies between the mobile network operators
and MVNOs, these are called Mobile Virtual Network Enablers or MVNE.
MVNE differs significantly from the other MVNx models. An MVNE does not provide public telecom
services. It has no contact to the end-users and is therefore not subject to telecom regulation.
In the event that an MVNE would become interested in providing services to end users as a MVNO, they
would be subject to regulation, as a MVNO.
MVNEs are intermediaries between the mobile network operator (or MVNA) and the MVNOs, they
provide a platform with technical solutions and business infrastructure services that help to execute the
launch and operation of MVNOs.
These services may include core network and infrastructure elements, billing, administration,
operations, business support systems, operations support systems, analytics and provision of
technological and network elements, among others - for the adequate provision of the service.
Prospective MVNOs often have little relevant experience to guide them through the different steps of
the wireless service delivery chain and need to overcome many challenges.
High peak funding, lack of telecom skills and expertise, lack of economies of scale, limited technological
and architectural knowledge of the MNO/MVNO ecosystem and operational complexity are among the
major barriers to entry faced by potential MVNOs.
While the challenges for the mobile operators include the workload of administering the heavy
processes associated with the launch and day-to-day operations of each individual MVNO.
The MVNE solves these issues.

MVNO KEY ENTRY BARRIERS
High Initial Investment
The procurement and integration of IT infrastructure requires a high initial the investment.
Lack of Telco Knowledge
Many companies, with a strong brand and a large customer base, qualify as MVNO candidates but are
not attracted to the business due to lack of Telco/MVNO knowledge
Operational Complexity
Starting an MVNO business is faced with significant operational challenges ranging from using a new
unfamiliar billing platform to customer service, managing SIMs, devices, analytics, etc.
The MVNE mitigates the barriers to entry for the MVNOs, and eliminate many of the integration issues
that could otherwise slow deployment, or even sink the MVNO/MNO business in a market altogether.
Table: MVNO and MNO pain points mitigated with MVNE
MVNO MNO
The MVNE becomes the MVNO partner - not the
MNO. Providing each MVNO access to create and
manage its own service
The MNO saves on infrastructure, subscriber
acquisition costs and workload with no risks, while
gaining network market share and revenue
The MVNE gives the MVNOs the opportunity to do
what they do best, concentrate on customer
acquisition and outsource the rest
The MNO receives revenue without having to deal
with the administrative processes of launch, and day-
to-day operations of each MVNO
As the MVNE will host multiple MVNOs, it is possible
to achieve economies of scale, and thereby lower
rates/greater margins
Sustainability: Utilize and profit from selling wasted
network and capacity resources.
MVNOs can get guidance from the MVNE’s dedicated
team of experts, experienced in the launch and
operation of MVNO services
Address specific/niche segments through the MVNE’s
mix of MVNO clients, and gain healthy and sustainable
MVNOs
The MVNE reduces the initial Capex and Opex
providing faster ROI because all agreements and the
requisite infrastructure is in place
The MVNE solution dramatically decrease the internal
skill sets and time needed to launch an MVNO
The MVNO retains customer ownership and compensates the MVNE for the management of all layers of
the wireless service delivery chain.

4. MVNO BENEFITS FOR MOBILE NETWORK OPERATORS
Onboarding MVNOs will allow the MNO to address specific market niches, which the MNO has not yet
tapped into – incurring lower Subscriber Acquisition Costs (SAC) and add efficiency to the value chain by
creating offers aligned to the needs of each of the existing segments.
Illustration: MNO Market Approach vs. Market Segment Approach with MVNOs.
4.1 Financial Benefits From MVNA/MVNE/MVNO Collaboration
Besides being a source of growth, MVNOs are creating a significant advantages for the MNOs in terms of
improving its business profitability.
 With an MVNA/MVNE/MVNO partner, the Subscriber Acquisition Cost (SAC) for an MNO is zero, as
the Subscriber Acquisition Cost is transferred to the MVNO.
 The Average Revenue per User (ARPU) for the MNO, is only slightly lower with MVNA/MVNO than
the retail ARPU for the MNO without MVNO.
 The EBITDA margin percentage of the wholesale business, is much higher than that of the retail one
for MNOs without MVNOs.
Illustration: MVNO creating advantages for the MNO in terms of business profitability.

For the MNO, the EBITDA margins for customers acquired by MVNOs is 3 times the margin from retail.
MVNOs help MNOs to drastically improve their EBITDA margins by reducing Subscriber Acquisition Cost
(SAC) costs with only a slight reduction in Average Revenue per User (ARPU).
Network operators are continuously investing heavily into spectrum licenses and infrastructure to keep
up with demand and new technology. These new investments are resulting in capacity which needs to
be fully utilized - as much - and as soon as possible.
A MVNO partner strategy can fill this gap and generate economies of scale for better network utilization.
In the very beginning, MNOs opposed the entry of MVNOs by refusing the network access or making the
market entry difficult by other means. In response MVNOs requested regulatory actions in order to open
MNOs’ network. Since then, the MNOs attitude has changed and MVNOs are considered entities, not
only to increase competition but also to increase benefits to the MNOs.
4.2 From a Single Brand MNO to a MVNO Multi-brand/Segmentation Strategy
The multi-segment, multi-brand approach is not new, but built on experience from other industries such
as the automotive industry.
Today, the automotive market is heavily segmented and most car manufacturers actually own multiple
automotive bands, each focused on a specific market segment with the product tailored for the unique
needs of that segment.
Illustration: Shifting from a single brand to a multi-brand, multi-segmentation strategy.

4.3 MNO/MVNA/MVNE/MVNO Benefit Conclusion
A MVNO partnership brings the following benefits and opportunities for the mobile operator.
 Financial Benefits: New revenue streams • Higher margins • Quicker return of investment •
Reducing costs (increasing the EBITDA).
 Strategic Benefits: Niche segment tapping • Use MVNOs in segments where the competitor is strong
• Obtain greater share of the total market traffic • New distribution channels, reach new consumers
in unserved/underserved market segments • Risk sharing.
 Operational Benefits: Network utilization • Share business processes to increase overall
performance.
 Marketing Benefits: Minimize churn • Grow market • Cross-sell • More value, innovation and choice
for the end-users • Saved retail costs can be used to increase customer retention.
4.4 MNO/MVNA/MVNE/MVNO Case Stories
Case 1: Tele2 Russia’s “MVNO Factory”
In May 2017, Russian Tele2 launched its
“MVNO factory” strategy.
The strategy enabled Tele2 to host a
range of MVNOs in various niches, and by
mid-2017, it had six MVNOs operating,
and contracts with eight more.
In 2018, MVNO subscribers in Russia
grew to 3.2M with Tele2´s MVNO
partners accounting for 1.75M of those.
At the end of 2019, Tele2 had 21
MVNOs on its “MVNO factory”, serving
3.75M subscribers out of 10M total
MVNO subscribers in the market -
increasing Tele2’s revenue from the
"MVNO factory" 133% year on year.
End of year 2020, the MVNO factory
had 4.8M subscribers - with a revenue
increase of 55% YoY.
The goal is to occupy 15% of the total
market in Russia by 2024.

Case 2: Internet Initiative Japan (IIJ)
Internet Initiative Japan (IIJ), runs a
MVNA and MVNE on the telecom
operator NTT, catering services to
MVNOs, IoT and M2M companies.
From 1Q 2017 to 3Q 2017, the MVNO subscribers going through IIJ´s MVNE was 744,000.
In the period 1Q 2018 - 3Q 2018, the number of subscribers grew by 254,560 to a total of 998,892
providing IIJ with a service revenue of USD 96.3 million up 37.8% YoY.
In 1Q 2Q19, the subscribers grew by 105,000 to reach a total of 1 million providing IIJ with a revenue of
USD 115.1 million up 16.7% YoY.
FY2020, subscriptions through the MVNOs on IIJ’s MVNE platform was 1.1 million with a service revenue
of USD 153 million.
Case 3: MVNA/MVNE Surf Telecom Brazil
In September 2015, EUTV S.A launched
the company ”Surf Telecom” via the
network of TIM Celular SA (TIM) to
provide services as a MVNA/MVNE.
In February 2021, Brazil had a total of 82 licensed MVNOs with 36 of them enabled by Surf Telecom.
Among the MVNOs are the Brazilian Post Office and several football teams.
As of March 2022, Surf Telecom and its 43 MVNO partners had a total of 937,190 subscribers.

Case 4: Cell C South Africa
In 2016, South African operator Cell C
announced it had launched a MVNA and
MVNE setup, which allowed them to
launch MVNOs efficiently.
In its FY 2017 report, Cell C's reported its MVNE/MVNO strategy had been a key contributor to the
revenue growth, with MVNO wholesale revenue increasing by 79% to USD 52.8M YoY and MVNO
customers reaching 1.5M.
In 2018 wholesale revenue was USD 47.12M and MVNO subscribers 1.68M.
In 2019 wholesale revenue reached USD 53.55M and MVNO subscribers 1.91M.
In its H1 2020 result Cell C announced an 18% increase in revenue to USD 22.6M from MVNE/MVNO, as
an important part of its turnaround strategy.
In first half of 2021, wholesale subscribers through MVNE/MVNO reached 2M.
2023: South Africa has seen a swell in mobile virtual network operators (MVNOs). In addition, Cell C, the
challenger mobile network operator (MNO) is no longer operating its own network and spectrum,
instead it has become a full MVNO itself in 2023 with a MVNE partner enabling MVNOs.
With roughly 12.8 million subscribers, Cell C has gone from South Africa’s fourth-biggest MNO to the
country’s largest MVNO.
Cell C was South Africa’s only MVNE for years and provided services to South Africa’s very first MVNO,
Virgin Mobile. Since then the other operators have launched MVNA/MVNE/MVNO platforms as well.

5. THE ISSUES IN THAILAND
Since the introduction of a MVNOs in Thailand more than 60 companies have obtained MVNO licenses.
Ten have launched but only four are operational and struggling due to the issues in the market.
TOT and CAT telecom (NT today) has been the only mobile network operators hosting MVNOs in
Thailand. Neither AIS, TRUE or DTAC has hosted any MVNOs on their networks, since the introduction of
MVNOs in Thailand, despite NBTC’s Mobile Virtual Network Mobile Phone Service Notification B.E. 2013,
the revised Announcement in 2020, as well as described in the terms and conditions in the operators
spectrum licenses since 2013, stating that minimum 10% of their spectrum capacity has to go to MVNOs.
The big three’s self-interest has caused a collective outcome of resisting MVNOs on their networks, If
not the result of a coordinated behavior between the operators, then by deciding individually that
MVNO access should be prevented.
 Local and international enterprises are interested
in investing and launching MVNO services but are
held back by the problems in the market.
 Enterprises are aware of the need to transform
digitally but several are not interested in having to
rely on – and having their business (data) going
through the eyes of AIS or TRUE/DTAC.
 NT’s survival depends on wholesale. It has
underutilized capacity but not the necessary
knowhow, flexibility and platforms needed to
attract and support MVNO partners.
 The merger of TRUE/DTAC has created a duopoly
in the market with consumers and enterprises
demanding more choices.

With the merger of CAT Telecom and TOT on January 2021, the option for mobile virtual network
aggregators (MVNA), mobile virtual network enablers (MVNE) and MVNOs to obtain wholesale network
access, went from two to one, impacting the ability of MVNOs to enter the market.
Opposite, AIS, TRUE/DTAC has themselves taken advantage of using MVNO licenses and models to
launch their own sub-brands into the market based on MVNO i.e. AIS with GOMO by Singtel and
Finnmobile (DTAC), as well as enter into network rental/barter agreements with CAT and TOT (now NT).
Illustration: TRUE’s network agreement on CAT Telecom’s (now NT) 850 MHz.

Illustration: AIS’ network agreement on TOT’s (now NT) 2100 MHz.
Illustration: DTAC’s (now TRUE) network agreement on TOT’s (now NT) 2300 MHz.

These wholesale network rental/barter agreements has placed the big three, not only in control of NT’s
network capacity but also the wholesale pricing NT is able to offer to MVNOs.
As such, AIS, TRUE/DTAC are de facto in full control, of who can enter the market, by raising artificial
barriers to entry, protecting their own retail business through high wholesale access fees, adversely
impacting the ability of MVNOs to compete effectively at the retail level.
In example, when a MVNA or MVNO contacts NT today to discuss a wholesale agreement, NT has to
inform AIS (2100 MHz) and TRUE/DTAC (850/2300 MHz) of this, and the two will provide a wholesale
price to NT. However, as NT also have to make a business on this, it has to add its margin on top of the
wholesale price they got from AIS/TRUE.
Furthermore, in order for AIS and TRUE to give NT a wholesale price to NT’s MVNO partners, AIS and
TRUE say they need information from NT on the MVNOs, i.e. expected subscriber growth, capacity
needs, type of plans, segment(s), etc. Hence AIS and TRUE are not only de facto controlling the
wholesale price NT can give to MVNOs – they are also fed with information about possible competition.
AIS and TRUE/DTAC are thereby in control of the market at all times, and the MVNOs will always end up
with a higher wholesale price, as they have to pay not only NT but also the two gatekeepers (AIS and
TRUE) and those costs can only be forwarded to the end-users = no competition.
The competitive pressure the MVNOs have been able to exercise in Thailand has been extremely limited
and was reduced to zero as a result of the TRUE/DTAC merger. Not only due to a further reduction in the
number of wholesale network access operators, but also the decreased bargaining power of MVNOs in
the negotiating process that follows. This applies both to prospective MVNA/MVNO entrants and to the
existing MVNOs, once they need to re-negotiate their wholesale agreement – or switch host.
When CAT Telecom (now part of the NT) and True renewed their network/barter agreement, it was
added in the agreement that only CAT Telecom’s own retail service (MyCAT), would be given access to
4G, thereby actively excluding MVNOs to use 4G on the network NT has access to on True.
Besides humans, and the rise of devices that needs connection and a tailored service and package with
it, are in the millions. The mobile network operators cannot handle this by themselves. As seen in other
markets, MVNOs are the perfect partner for such, as they are more agile.
The current MVNO setup in Thailand has zero chance to provide innovation and competition in the
market. The operators have built barriers to entry by not having any active MVNA/MVNOs on their
networks, opposite in other countries where MVNOs have accelerated in IoT/M2M, Ai, Blockchain,
Fintech, new pricing and promotion models to both end-users, enterprises and government projects.
Thailand’s investment, support and effort to get 5G up and running successfully, is hampered by the lack
of MVNOs being able to utilize it for the requested innovative services and support in getting various
verticals and projects transformed into the digital economy. All the eggs have been placed in only two
baskets or gatekeepers = AIS and TRUE/DTAC.

Lack of network access (or a MVNA partner) - and the lack of a suitable wholesale pricing regulation, are
two of the key obstacles for the successful launch and operations of MVNOs.
Businesses who are in the same verticals, as some of AIS or TRUE’s sister companies don’t want to see
their company or user data, having to pass through AIS or TRUE.
In example, Electric Vehicle (EV) companies, struggles to choose between an operator who’s
shareholder is active in fossil fuel (AIS and Gulf Group) - or a operator who’s shareholder owns a
competing EV brand (TRUE and MG4
). Similarly, Telehealth projects in Thailand should not use – and
have patients data running through the two mobile operators who is also active in selling insurances5
.
The only other option these businesses and projects have is to launch their own MVNO (or Private
Network) to be in control of the data and own business. However, as no MVNA or MVNE partners are
attached to any of the mobile network operators today, the MVNOs aren’t able to use the data they
generate and run their own business, thus being pushed to use the “competitors” (AIS/TRUE)
4
SAIC Motor Corp. Ltd.: https://asia.nikkei.com/Companies/SAIC-Motor-Corp.-Ltd
5
AIS Insurance Service: https://www.add-digital.co.th/

The four MVNOs that are operating in Thailand today are not even able to monitor and analyze their
own generated business data, to see what part of their business and service is working or not.
For MVNOs, the lack of wholesale network access (or a MVNA partner attached to a mobile operator) -
and the lack of a suitable MVNO enabler platform, are two of the key obstacles for the successful launch
and operations of MVNOs.
The availability of a MVNA/MVNE in Thailand would not only lower the upfront capital cost for MVNOs
by taking advantage of economies of scale (buying power) but also provide them with the necessary
platform to launch and operate their own business – like any other businesses in Thailand are able to do.
It would encourage the businesses, who have already applied, approved and paid for a MVNO license in
Thailand (but haven’t launched) – as well as the potential local and international MVNO candidates, who
so far have steered clear of investing in Thailand due to the issues mentioned.
National Telecom’s (NT) 700 MHz
NT hasn’t been able to come up with a sustainable business plan and roll out its 700MHz 4G and 5G
network, several years after it won the spectrum at the auctions in 2020. The only “solution” has been
for NT to be dependent on AIS again.
Additionally, NT has to give back its existing 850MHz, 2100MHz and 2300MHz spectrum to NBTC next
year (2025) and has already started to the existing MVNOs that they need to find other options.
"NT has no time to hesitate, needing to quickly complete its business turnaround as well as improve
operating efficiency" NT's board Chair Nattapon Nattasomboon told Bangkok Post.6
This, raises a serious question: What will happen to MVNA/MVNOs in Thailand?
Because why would any company consider investing into a MVNO/IoT/M2M/Private network with only
a few months horizon on their business plan/break-even/return of investment?
Although NT (or rather AIS) has started to roll-out a 4G/5G network on the 700 MHz, this is far from
enough to support the deal it NT with AIS, NT’s own retail service, MVNOs and Private Networks.
In the deal between AIS and NT, AIS bought half of the 2 x 10 MHz, In addition, AIS will be operating NT’s
capacity and NT will rent and pay rental fees to AIS’s network and related equipment that NT will use to
provide its own service on the remaining 10MHz of the spectrum, which will be both 4G and 5G.
NT has about 2 million customers itself, and with AIS and NT taking up the capacity there is only space
left for about 400,000 MVNO subscribers which is not even enough for one MVNO to reach financial
break-even on its investment in the Thai market.
The main problems in the Thai mobile market boils down to three major issues:
 Lack of network access,
 Lack of MVNA/MVNE/MVNO expertise,
 Lack of the necessary technology platform
6
NT slashes 2024 investment budget: https://www.bangkokpost.com/business/general/2742355/nt-slashes-2024-investment-budget-by-b1bn

6. SUPPORT FOR MVNA/MVNE/MVNO IN THAILAND
The Thai telecom sector has been far behind other markets in enabling policies and dealing with barriers
to entry for new entries to the market, since the National Broadcasting and Telecommunication
Commission (NBTC) was introduced in 2011, resulting in significant market power and control to the
three operators (now only two).
The former leadership at the NBTC passed the buck of dealing with TRUE’s takeover of DTAC to the new
(current) leadership, as its first job when they took office in 2022.
Since then, the NBTC board has been split into two groups with the NBTC office, as a third wheel with
major delays in decision making, regulation and administration of the market as a result, causing
frustration among end-users, consumer associations and politicians, who have/are actively and
increasingly voicing their opinions and frustrations.
The complaints and comments have not just targeted the two operators, AIS and TRUE but also the
NBTC for its failure, as a regulator to listen to, react and protect the consumers.
Disagreements but all united on boosting MVNO
Interestingly, although there is disagreement on how to tackle the issues of the merger, merger
conditions, pricing and declined network quality – one thing they all seem to be united on – is the entry
and promotion of MVNOs into the Thai market.
On October 20, 2023, NBTC Board Commissionaire regarding Telecom Business, Mr. Sompop
Phuriwikraiphong said the important issue and policy for the NBTC, is to promote the creation of
MVNOs. “But in the past, there has been problems from high cost of MVNOs purchasing access to
spectrum or not getting any access at all from the private network operators. The NBTC therefore has to
hasten to issue policies to encourage the launch of MVNOs, in order to create an alternative access to
telecommunications services”.
The Senate’s Committee on ICT & Telecommunications, appointed a sub-committee to investigate and
help solve the problems at the national telecom regulator (NBTC) in November and in the press release
that followed it revealed 7 agenda items7
, among them: Accelerate the push for mobile virtual network
operators (MVNO) to create more competition in the market.
On December 15, 2023, Thailand’s Consumer Council held the live online event “Talk 2 Action” where it
called for a handful of policies including the introduction and promotion of MVNOs into the market8
.
7 ICT Committee appoints sub-committee to investigate conflict in NBTC: https://siamrath.co.th/n/489939
8
Talk 2 Action: https://www.youtube.com/watch?v=wvoENXQd00g&t=1985s

Five days later, December 20, Sirikanya Tansakul, MP from the Move Forward Party, gave their take on
the need for MVNOs in Thailand in a interview on Channel 3’s “News Talk”9
.
The support for MVNOs culminated when Dr. Saran Boonbaichaiphruek, Chair of the NBTC, revealed 9
urgent policies that will be accelerated in 2024, to increase and help facilitate options and services for
the people in the country and break market dominance10
.
Among the 9 policies announced are:
 The creation and promotion of a easy-to-connect MVNA/MVNE platform to enable and support
MVNOs into the market.
 The acceleration and implementation of “One Region, One MVNO” with the goal of adding at least
seven regional MVNOs in the market to increase options and services for the people.
 Reduce rates of the regional MVNOs by at least 20% from the plans of the duopoly.
 Out-of-area rates and interregional fees that suits the cost of living in that region.
 Conditions that makes sure the two large mobile network operators cannot own more than 25% of
shares in a regional MVNO.
“The policy for the NBTC office in 2024, Everyone must be more
committed to working for the people. As a regulatory agency, I would like
to see serious consumer protection regarding telecommunications service
fees to reduce inequality in all groups, including facilitating various
services for the people with the NBTC office being more involved.”
Dr. Saran Boonbaichaiphruek, Chair of the NBTC.
9 News Talk on YouTube: https://www.youtube.com/watch?v=oNB6wGpV1Ow&t=173s
10
NBTC Press Release: https://www.nbtc.go.th/News/Information/64144.aspx?lang=th-TH

7. THE SOLUTION: A NATIONAL WHOLESALE NETWORK (NWN)
This report suggest taking advantage of the role of NT, as a neutral state-owned player, by allowing it to
keep its current spectrum and infrastructure, and then partner with a MVNA/MVNE, to establish a
National Wholesale Network (NWN) - a wholesale-only network offering 4G/5G access and telecom
support to large and small enterprises, communities, government projects, etc. as MVNOs.
A National Wholesale Network (NWN) will drive innovation, utilize existing infrastructure and spectrum,
benefit consumers and enterprises, providing them with choices and innovative services, establish
effective competition at the retail level boosting the digital transformation and economy.
Illustration: National Wholesale Network (NWN) Thailand - Ecosystem.
 NT is responsible for the spectrum and the matching network infrastructure for the nationwide
distribution of telecom services.
 A NBTC licensed MVNA buys wholesale access to the National Wholesale Network on behalf of
MVNOs, using economies of scale to achieve a discount, and then resell the access to each MVNO.
 A MVNE provides each MVNO with an instance access to a platform with the telecom technology
needed - such as data analyses, operations and business support systems - enabling the MVNOs to
operate and customize their own service 24/7. In addition the MVNA/MVNE support the MVNOs
through all aspects of the customer lifecycle, from launch to operation by adding, and fully
capitalizing on their MVNO, local market and retail expertise.
 The MVNOs provide their own tailored services to the wants and needs of their own specific
segments - be it people or machines - under their own control, brand and pricing.
Providing an all-in-one turnkey solution of expertise, connectivity and technology to enable a full range
of service offers. In addition the MVNA/MVNE market experts can co-operate with NT for NT’s own
retail service.

7.1 Benefits:
 Increased competition through MVNOs providing greater choice and affordable services.
 Enhanced innovation: MVNOs are well-known for driving innovation in the telecom sector.
 Improved MVNO access: A neutral wholesale network would provide MVNOs with fair and
transparent access to network infrastructure, fostering their growth.
 Promotion of Digital Inclusion: MVNOs often target specific niche markets or rural areas with
tailored offers. A wholesale network could enable them to provide affordable mobile services to
underserved populations, contributing to digital inclusion and closing the digital divide.
 Utilization of unused spectrum: Leveraging NT's spectrum would improve spectrum efficiency and
contribute to Thailand's digital development goals.
 A neutral wholesale network and MVNA/MVNE: With no other commercial interest. Providing a
safe haven for enterprise business and end-user data i.e. for Telehealth projects.
7.2 Benefitting all Stakeholders
A ecosystem build on a sustainable model generating value and therefore motivation to all stakeholders.
NT will be able to fully utilize existing infrastructure and
wasted spectrum capacity while adding a new
wholesale revenue stream to its books.
MVNOs benefits from getting network access and
having a MVNA/MVNE partner, who is supporting the
MVNOs in becoming successful, as the MVNA/MVNEs
business depends on the success of the MVNOs.
ENTERPRISES will have access to build and operate their
own mobile services as MVNOs and use the data it
produces to support their digital transformation and
business models.
CONSUMERS benefits from competition on innovative services and cost effective prices customized to
their lifestyle, as competition will now be focused on services rather than network technology.
THAILAND benefits from the increase in users/usage in the digital economy - stimulating economic
growth. New revenue stream from a state-enterprise. Sustainable usage of infrastructure and spectrum,
as well as new jobs and skills development in the digital economy.
THE MVNA/MVNE benefits from being a part of the digital economy and revenue the more successful
the MVNOs are.

7.3 Challenges and Considerations
Spectrum Allocation - Stare decisis
Although Section 45 of the Frequency Allocation Act stipulates that spectra must be allocated only
through auctions and that after expiry of concessions, spectra must be returned to the NBTC for
reallocation, there is precedent, as the NBTC gave TOT permission in 2015 to operate 4G on 60 MHz of
the 2300-MHz band spectrum until 2025.
In addition, a set of amendments was added to the National Broadcasting and Telecommunications
Commission Act, in late 2021. A royal decree that ”supports convergence of technologies for the benefit
of the country,” was formulated based on Section 30 of the amended Act.
NBTC received recommendations from the House of Representatives and the Senate to add the
definition of “technology convergence” stipulated in the legislation, as the infusion of technologies for
the benefit of the country, people and economy.
Along with it, the NBTC also drafted four new regulations:
 Criteria for spectrum license transfer,
 Criteria for allocating spectrum ranges other than from auctions,
 Criteria for applying for business licenses,
 An amendment to the Spectrum Management Master Plan.
Spectrum Auction
AIS and TRUE will probably challenge a decision to let NT keep its spectrum, with the help from GSMA
(the lobby organization of mobile network operators), citing the need for the spectrum to be auctioned
instead for “economical benefits” and the “digital economy”.
However, the following needs to be considered:
1. There are only two operators in the market = only two bidders.
2. The two operators have already shown signs of collusion i.e. on pricing and packages, as well anti-
competitive behaviors towards MVNOs access.
3. AIS and TRUE sent similar worded letters to the NBTC about the need for a reprieve on their 900 MHz
licensing payment, which was granted by adding another five-year instalment period and an interest
rate of only 1.5% for the extension period. The controversial extension meant that around THB 19 billion
– supposed to benefit the public went to the benefits of the telecom operators.
As such, an auction would be unable to perform to the best advantage.

7.4 Modeled on Best Practice
The suggestion of a National Wholesale Network (NWN) in Thailand, is largely modeled on best practice
from MVNA/MVNEs and the Single Wholesale Networks (SWN) in:
• Mexico: Red Compartida (Shared network), is a national, independent wholesale 4G-LTE network
and the result of the Mexican Government's effort to overhaul its telecommunications industry by
introducing competition into the marketplace.
• Malaysia: Digital Nasional Berhad (DNB), is a Malaysian special-purpose vehicle company owned by
the Ministry of Finance Malaysia. DNB was established in March 2021 to promote service-based
competition in Malaysia and drive the development of 5G.
• Brunei: Unified National Networks (UNN), an organization 100% wholly owned the government of
Brunei Darussalam. UNN’s purpose is serving Brunei’s digital telecommunication, offering 3G, 4G, 5G
wholesale telecommunication services to both national and international clients.
However, opposite these Single Wholesale Networks (SWN) projects, Thailand’s National Wholesale
Network (NWN), has the advantage of less investment in spectrum and infrastructure, as NT has existing
infrastructure and spectrum. In addition, NT is already used to other operators renting access.
7.5 Case Story: Mexico Red Compartida
More than just another mobile phone network — Red Compartida it is seen as a part of national
infrastructure that is vital to the nation’s economic and social development.
América Móvil, the company owned by Carlos Slim, the world's richest person between 2010 and 2013
had long held a monopoly in the telecom sector in Mexico with consumers complaining on “high costs
and spotty service”.
Faced with a non-competitive telecommunications sector, Mexico's telecommunications sector
underwent a major reform to address the lack of competition and encourage investment and in 2015,
the government announced the “Red Compartida” initiative.
To ensure true independent competition, a national, independent wholesale network named “Red
Compartida” (Shared Network in English) was to be rolled-out with the aim of creating a nationwide 4G-
LTE network as a vehicle for MVNOs to enter the market, increase innovation and consumer choice,
improving quality of service and, ultimately, overcome the digital divide between urban and rural areas.
Initially, the project was setup as a Public Private Partnership (PPP) with the company Altán Redes that
won the domestic and international public tender process.
The Red Compartida network is “wholesale only”, meaning that Altán Redes the company who build and
operates the network would not be providing mobile service to end-users. Instead, the operator
provides access to the network to MVNOs, who use the network to provide their mobile services.
In 2017 the government handed over the 90 MHz bandwidth on the 700 MHz spectrum frequency to the
Red Compartida project and Altán Redes began the roll-out of the network in 2018.

However, rolling out a entirely new network infrastructure, especially to sparsely populated rural areas
comes at a high cost and returns on investment takes longer, and in July 2021 Altán Redes filed for
bankruptcy aiming to use protection to renegotiate its debts.
In June 2022 the government signed an agreement to become the majority stakeholder in Altán Redes
and the company emerged from bankruptcy. At the time, Red Compartida had achieved a roll-out
coverage of 70% of the population.
As with similar projects, GSMA, the lobby organization of mobile network operators was not late to
criticize and call the project a failure – however the results speak for itself.
As of January 2024, the network coverage is 92.2% (103,5 million of the population).
At least 53 MVNOs launched and began operations in 2021 and 2022, and at the end of 2022 a total of
111 MVNOs were operating in Mexico.
Chart: MVNOs launched in Mexico in the period 2014 – 2022.
The mobile subscribers and connections served by the MVNO in Mexico quadrupled from 2020 to 2022,
going from 2.55 million to 10.52 million representing a market share growth from 2.5% to 8.6% of total
mobile connection in the country.

The telecom regulatory authority, Instituto Federal de Telecomunicaciones (IFT) estimated that the
figure has risen to 13.3 million at the end of 2023, equal to a market share of 9.7% of total connections
and equivalent to an increase of 2.5 million mobile subscribers/connections in one year.
Chart: MVNO connection/subscriber development in Mexico 2014 – 2023.
Source: IFT with data from the Telecommunications Information Bank, provided by operators as of the fourth quarter of 2022
Of the 111 MVNOs operating in Mexico 61% of them were doing so only via Red Compartida. 22% via
one of the traditional operators (Telefónica, Telcel, AT&T), and the remaining 17% using both a
traditional operator and Red Compartida.
From 2020 to 2023, the MVNOs solely using the Red Compartida increased from 43% to 61%, which
confirms that Red Compartida is important for the commercialization and development of the MVNO
market.
In its annual report on the market (2023)11
, the IFT conducted a survey among the MVNOs regarding
their perception and use of Red Compartida with 83% of the respondents pointing out positive impacts,
among which the following stand out:
 increase in user experience, and the expansion of markets, especially in highly marginalized areas;
 increase in coverage and quality of service,
 less dependence on roaming from traditional operators.
 17% of the respondents said it had no usage of the Red Compartida because it is not a 5G network.
11
IFT MVNO Market 2023: https://www.ift.org.mx/sites/default/files/contenidogeneral/estadisticas/omvs2023.pdf

ANNEX: THREE EXAMPLES OF INNOVATIVE MVNOs
Case 1: Audacious a MVNO for people with hearing loss
Targets people with hearing loss who need assistance in hearing mobile calls. The service lets you take a
hearing test, then broadcasts calls at the optimum frequency.
Audacious provide mobile services tailored to the needs of a
disabled community, and the value-added aspect lies not in plan
features or pricing but in signal transmission.
Manx Telecom has developed it in partnership with Goshawk
Communications and debuted it in 2018. However, the new
company envisioned a wider distribution for it, and the SIM-only,
MVNO model has been a good way to achieve that at low cost
Brian Moore, a professor at Cambridge University and one of the
world’s top authorities on auditory perception, worked with
Goshawk and Manx Telecom and developed algorithms that
measure hearing loss via a mobile phone signal. With these
measurements in hand, the operator can then compensate for the
losses, on its own end, without needing to make any adjustments to
the user’s device. The fact that it is apparently device-agnostic
vastly increases the potential reach of this solution.
How it works
You take the company’s hearing test – it’s all done online, so you can do it from the comfort of your own
home. It should only take about 5 minutes, and you can re-take the test at any time.
Then you order your SIM card. It works just like any other network, with deals offering bundles of calls,
texts and data, but the SIM is especially tailored to your individual hearing profile.
When you make or take a call, the SIM will use the company’s unique technology to adjust the audio to
the frequency you can hear best. That means clearer calls with less distortion.
You don’t need a new phone, and you can use it with or without a hearing aid.
It’s not just aimed at the hearing impaired. It’s also ideal for anyone struggling to make out calls in noisy,
crowded places.

Case 2: MVNO Greatcall for Seniors
In April, 2006 the husband-and-wife team of Arlene Harris and Martin
Cooper launched the MVNO “GreatCall” offering a simplified wireless service
for seniors. The service was launched with phones designed for seniors
featuring a simple design, oversize buttons and graphics.
In 2009 the company launched Live Nurse providing customers access to
registered nurses 24/7.
In 2011, GreatCall added the app MedCoach, which provides daily
medication management. It also introduced a mobile Personal Emergency
Response System device, along with a Medical Alert System, which uses GPS
to connect users with emergency certified Agents.
The MVNO also provide a feature phone as well as wearables for safety.
Services include:
5Star Urgent Response - Just press the button to speak to an IAED Certified 5Star Agent. They will assess
your situation and get you any kind of help you need.
Urgent Care - Speak with a nurse or doctor for medical advice and common prescription medications
24/7 without an appointment.
GreatCall Link - If you’re a caregiver, the Link app will send you updates about the well-being of a person
using a GreatCall phone or device.
Brain Games - Just like the jigsaw puzzles you know and love, these innovative games from Posit Science
keep your mind sharp and active.
“GreatCall services provide safety and independence. Whether you
need emergency help, have a medical question, need a locksmith,
or are concerned about having a fall, GreatCall offers these services
and many more, accessible right on your phone or device.”
John Walsh, Safety Advocate and Vice Chairman of GreatCall

Case 3: Equity Bank MVNO in Kenya
Transform Equity Bank from a physical place that customers
come to, to something you do (Lifestyle).
With 2.8 million MVNO subscribers, or about 4.2% of the
mobile-money subscriber base in Kenya, Equitel processes
21.7% of the total value of Kenya’s mobile-money
transactions.
89% of all successfully processed loans are now originated via
mobile channels, while 96% of all transactions are happening
outside the branch
All Equity Bank account holders will receive a sim card without
any KYC since it is already done at the time account was
opened.
All Kenyans who do not have account with Equity can open
their accounts "Equity Hapo Hapo" by dialing *247# from any
network to ensure the bank will be ready with their sim cards.
Services:
 Remove or eliminate cost of depositing money and eliminate 50% of cost of money transfer.
 Mobile banking as a banking channel accessing a convergence suit of financial products, loans,
savings, brokerage, custodial, investment, insurance services and other social corporate offerings
such as health, education, entrepreneurship and financial literacy
o Offer special mobile loans based on:
o Psychometric scoring
o Statistical financial scoring
o Mobile payments and airtime use scoring
o Existing credit score & rating
o Liquid security based limits
o Interest rate 1% - 2% / month against market offer of 7.5%.
Social Programs:
 1,555,476 Kenyan Women & Youth completed Financial Literacy Education
 600,000 peasant framer transferred to Agri-business and 2,616 medium-sized farmers supported.
 1 million trees planted 40,000 clean energy products distributed.
 Loans to empower women.
 37,785 entrepreneurs trainers
 Mobile & Digital learning tools.
 Mama" program for mothers

Disclaimer
The reader acknowledges that Yozzo Co., Ltd, its partners and employees do not accept any duty or responsibility to
it and shall not be liable in respect of any loss, damage or expense of whatsoever nature which is caused by any use
the reader may choose to make of this Report. Neither we nor any individual who participated in the making of the
Report shall be required to give testimony, or be involved in legal proceedings in relation to this Report.
We have no responsibility to update this Report for events or circumstances. We reserves the right to withdraw or
make revisions to this report should we receive additional data or be made aware of facts existing at the date of the
report that were not known to us when we prepared this Report. The reader agrees that Yozzo Co., Ltd., its partners,
principals, employees and agents neither owe nor accept any duty or responsibility to it, whether in contract or in
tort (including without limitation, negligence and breach of statutory duty), and shall not be liable in respect of any
loss, damage or expense of whatsoever nature which is caused by any use the reader may choose to make of this
report, or which is otherwise consequent upon the gaining of access to the report by the reader.
Further, the reader agrees that this report is not to be referred to or quoted, in whole or in part, in any prospectus,
registration statement, offering circular, public filling, loan, other agreement or document and not to distribute the
report without prior written consent.
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

RESEARCH REPORT A National Telecom Wholesale Network

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