Summary

  • BEREC’s final telecom comparison and its consultation report expose a dispute about which indicators and jurisdictions make a fair comparison, not just about how to interpret the results.
  • BEREC records several changes and rejected requests, but neither the consultation’s response count nor the regulator’s defence proves that every comparison is equivalent or neutral.

BEREC has published the final version of its “Europe’s Telecom Reality Check” alongside a report on comments to its draft. The two documents, BoR (26) 137 and BoR (26) 138, are dated 1 October and were registered on 6 October 2026. The draft consultation ran from 17 March to 8 May. BEREC says it received eight distinct submissions from ten respondents, including a joint submission from Connect Europe and GSMA and two confidential contributions from individuals.

The record matters because the disagreement was about the construction of the comparison as well as its conclusions. As BEREC summarizes their submission, Connect Europe and GSMA argued that the draft understated investment scale and competitive challenges, gave too much weight to short-term consumer prices, and too little weight to investment capacity, network quality and long-term competitiveness. They also challenged the comparator selection and the way EU top performers were shown alongside the EU-wide average.

Those are the organizations’ positions as reported by BEREC; they do not establish that the report was designed to favour one result.

BEREC’s answer is that the report uses public, transparent sources that readers can verify. It says parts of the industry contribution rely on proprietary datasets and offer limited methodological explanation, and it disputes some of the comparator choices and inferences. That reply is also an institutional position, not an independent audit of either side. Public availability makes replication more possible; it does not by itself make definitions, collection methods or populations comparable.

The final report compares the EU-27 with Australia, Canada, China, Japan, South Korea, the United Kingdom and the United States. It draws on sources including EU and national regulators, the FCC, ITU, OECD, Ookla and industry bodies. BEREC warns that definitions, reporting practices, geographic conditions and data availability differ. It generally focuses on trends from 2019 to 2024, using the latest available data rather than a single synchronized observation date.

One example makes the denominator problem concrete. In a 5G coverage comparison, EU figures use household coverage while several other jurisdictions report population coverage. BEREC approximates population coverage from household coverage at area level and acknowledges the assumption. A chart can therefore be based on published, checkable data and still compare measures that are not identical. The necessary question is not only where a figure came from, but what population and unit it represents.

The response report also shows what BEREC changed and what it did not. After suggestions from ecta and MVNO Europe, BEREC says it checked newer indicators, found no material effect on the draft’s conclusions and chose not to update them; it notes that updated data were not available for every indicator. Following requests from AIIP and Mynet, it added an introductory paragraph on local and medium-sized operators and a footnote distinguishing formal regulated wholesale access from access that is effective in practice.

BEREC declined a quantitative test of effective access, citing the lack of uniform evidence and the resource-intensive monitoring role of national regulators.

These changes make the response trail more useful than a simple tally of supportive and critical submissions. They show that BEREC considered specific requests, accepted some framing, and explained why it did not adopt others. They do not show that respondents represent all operators, users or governments, or that the consultation created a mandate for the report’s policy conclusions. Nor does the fact-finding report decide whether consolidation is desirable or settle the EU’s wider telecom-policy debate.

The standard for the next benchmark should be inspectability: publish the indicator definition, unit and denominator; identify the comparator and source vintage; state where updated data were unavailable; and show, request by request, whether a submission changed the measure, wording or conclusion. That makes disagreement testable without treating either a stakeholder’s objection or a regulator’s confidence as proof.

Sources

  1. BEREC final report, BoR (26) 137
  2. BEREC consultation outcome, BoR (26) 138
  3. BEREC consultation page for the draft report
  4. BEREC public consultation procedure
  5. Regulation (EU) 2018/1971 establishing BEREC
  6. BEREC announcement of the final report, 6 October 2026
  7. Draft BEREC report BoR (26) 36
  8. Final report PDF, BoR (26) 137
  9. Consultation outcome PDF, BoR (26) 138