How much do legal frameworks determine the success or failure of MVNOs in Europe?

When Mobile Virtual Network Operators (MVNOs) are planning their European expansion, there’s a critical factor that’s often undervalued. While technology concerns are often front and centre, the importance of telecoms regulation is frequently overlooked or underestimated.

Driven by technological improvements, like the development of cloud functions and advanced new services like IMS, operators are launching into new markets. Yet, they quickly discover that no two European markets regulate telecoms in the same way. From the UK’s Investigatory Powers Act 2016 (covering data interception, retention, and acquisition) to the EU’s European Electronic Communications Code (EECC) and the broader ePrivacy framework, the landscape is complex, fragmented, dynamic, and increasingly strict. Compliance has become a genuine challenge.

For MVNOs, non-compliance is clearly not an option. Ignoring legal imperatives can lead to operational shutdowns, heavy fines, and significant reputational damage. Recent examples include Ofcom’s £17.5 million fine to a major UK operator for failures in handling emergency calls, and a £2.8 million fine for poor commercial practices regarding customer contracts. Additionally, Ofcom has banned the leasing of Global Titles to combat fraud and interception. This ban on new leases and sub-allocations took effect in April 2024, with existing ones to be phased out by April 2026.

Regarding privacy, the European Data Protection Board (EDPB), while not directly interpreting lawful interception (LI)—which falls under national laws and ePrivacy—has established strict criteria for international transfers and data breach notifications, which directly impact cross-border MVNOs. Examples include the EDPB’s Recommendations 01/2020 following the Schrems II ruling and Guidelines 9/2022 on data breach notification.

The Challenge for MVNOs

Consider an MVNO looking to launch in both Spain and the UK. They would need to comply with the following rules simultaneously:

1. In the UK, the Investigatory Powers Act 2016 and Ofcom’s regulations on security and resilience.
2. In Spain, the General Telecommunications Law 11/2022 and the related interception obligations.
3. In the EU, the EECC‘s requirements, such as number portability without service loss for more than one working day, and emergency communications and location obligations.

And this is just for voice services. When you add IoT, fixed-mobile convergence, or roaming, the regulatory burden multiplies.

Many MVNOs, operating as ‘light MVNOs,’ rely on their host operator (MNO/MVNE) for services like IMS/voice, giving them limited visibility into LI systems. BEREC even notes that some MVNOs maintain a dual infrastructure (light and full) to gain certain functionalities from their host. This means compliance with national interception laws is often managed indirectly, increasing regulatory risk.

In this context, the ultimate responsibility for compliance lies with whoever provides the service to the end-user in each country. Regulators like BEREC and national authorities (e.g., Ofcom) publish guidelines that MVNOs must follow.

The Importance of Making the Right Choice

For all these reasons, choosing the right partner to develop your Core Network and BSS platform becomes a strategic, not just a technical, decision.

Implementing an IMS platform isn’t only about enabling VoLTE. It’s about creating a secure, auditable, and interception-ready infrastructure that meets the legal requirements of every country you operate in, both today and in the future.

At JSC Ingenium, we have helped telecom operators in multiple jurisdictions, including the UK, Spain, and major European markets, to implement IMS solutions with full LI integration. Our experience in diverse regulatory environments has taught us a key lesson: a one-size-fits-all approach does not work.

• Provides convergent charging independent of payment methods, whether it is prepaid, postpaid, or hybrid.
• Shorter Time to Market since the creation of comprehensive policy plans would take just a few hours.
• Covers all subscriptions, all service, tariff and policy options, and balances schemes.
• Include innovative offering like bonuses shared between subscriptions, advanced hierarchical bundles, quota rollover, Turbo boosts, unlimited service packages immediate payment of content, and so on.

For example, in a recent deployment, JSC Ingenium developed an MVNO’s network for four European markets. Instead of creating separate systems, the operator leveraged a single, compliant IMS backbone that could be adapted for each jurisdiction. The result? Unified operations and full audit readiness.

Conclusion

In an environment where regulation not only defines the limits of growth but also of all operations, MVNOs cannot afford to choose technology partners lightly. The choice of an IMS platform—and the partner who implements it—is, in essence, a decision about regulatory and operational sustainability. In Europe, scaling doesn’t just mean reaching more markets; it means doing so with an architecture that complies, resists, and evolves with the legal frameworks. This is only possible with a partner who not only understands networks, but has proven, country after country, that they know the rules of the game. After all, in this game, multi-country experience isn’t just an advantage. It’s a necessity.