Summary

  • BEREC’s draft work programme treats the telecom single market as an unresolved economic question, not as a proven consumer demand or a settled regulatory destination.
  • The Board of Regulators is consulting on the 2027 agenda through 31 October; a possible call for evidence is still tentative, and the final programme is expected in December.

Europe has used “telecom single market” for years as both a destination and an argument. The phrase can mean easier cross-border service, rules that are more alike, larger operators, or simply a more integrated market. BEREC’s new draft Work Programme 2027 does something more useful than repeat the slogan: it asks what a single market in electronic communications should deliver in practice, whether there is evidence of unmet demand for pan-European products and what incentives or barriers shape operators’ ability to offer services across borders.

That is a research agenda, not a finding that consumers are asking for a particular product or that regulation is the obstacle. The distinction matters. If policy starts with the label and assumes the answer, evidence becomes decoration. If it starts with an outcome and tests the demand and supply sides separately, the result can show where coordination would help, where national differences matter, or where the premise needs revision.

The draft was adopted by BEREC’s Board of Regulators at its 68th ordinary meetings on 1–2 October. The consultation closes on 31 October. In the draft’s section on “the telecom single market: market and economic approach,” BEREC notes that EU law does not contain one definition of the digital single market and that views differ about what a functioning market should look like. It proposes several workshops and says it may consider a call for evidence. The call is marked “TBC”; a summary of the workshops is planned for Plenary 4 in 2027.

The three questions are not interchangeable. “What outcomes should a single market deliver?” asks policymakers to define success before selecting an instrument. “Is there unmet demand for pan-European products?” asks for evidence about users and firms, not simply a count of national rules. “What are operators’ incentives and barriers?” asks whether supply-side constraints, commercial choices, regulatory differences or other conditions explain the gap. BEREC does not prescribe the answers or name a particular product as the test case.

The proposal arrives as the European Commission’s Digital Networks Act (DNA), published in January 2026, frames fragmentation and the ability to operate across borders as policy concerns. The Commission’s proposal is not enacted law. BEREC’s draft says that if the legislative procedure is sufficiently advanced in 2027, it will begin early preparatory work for DNA implementation. That conditional wording sits alongside work that existing sector rules already require, including roaming and intra-EU communications benchmarks and opinions on general authorisation and end-user rights.

A draft agenda therefore contains different degrees of certainty: statutory tasks, continuing work, new research proposals and work that depends on events outside BEREC’s control.

The programme itself has a defined decision-maker. Under Article 21 of Regulation (EU) 2018/1971, the Board of Regulators adopts the outline by 31 January in the preceding year and the final annual programme by 31 December after consulting the European Parliament, Council, Commission and other interested parties. For 2027, an outline was published in January; an early call for input ran from 27 February to 15 April; the Stakeholder Forum met on 31 March; and the Board adopted this consultation draft on 1 October. BEREC expects the final programme in December.

That sequence gives stakeholders a route to supply expertise and identify consequences. It does not turn the set of people who respond into a vote on behalf of all operators, consumers or member states. Nor does that make consultation meaningless: evidence can change the questions, the scope or the planned work. It means the public record should show what BEREC received, how it evaluated the evidence and which trade-offs shaped the Board’s final choice.

Capacity is part of that choice. The draft says some additional proposals from the early call were interesting but could not be taken on given the expected workload; it carries them into future reflection, including a section on potential work for 2028 and beyond. The text does not identify every excluded proposal or its sponsor. Still, the placement of work in 2027, the conditional DNA work and the items deferred beyond it reveal the control surface: BEREC’s annual plan allocates scarce regulatory attention before it produces advice, workshops or data collection.

For anyone commenting before 31 October, the useful test is to make the draft’s questions answerable. What outcome would count as a cross-border market working better? Which users or firms face unmet demand, and what evidence would distinguish it from a general preference for harmonisation? What specific barrier changes an operator’s decision to offer a service in more than one country? BEREC asks contributors to refer to paragraphs and says contributions and a summary will be published, subject to clearly marked confidentiality requests.

The important signal is not that BEREC has endorsed a particular vision of market integration. It is that the draft makes the vision contestable. A stronger final programme would preserve the separation between political objectives and observed demand, specify how workshops or any evidence call will test the three questions, and make clear which conclusions fall within BEREC’s advisory role. The title “single market” can describe an aspiration; only defined outcomes and evidence can show whether the proposed work has answered it.

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