Summary

  • The CRTC is asking how regional carriers have used wholesale mobile access, which customers they serve and which radio sites they have added. Responses are due on 13 November 2026.
  • The access mandate ends on 9 May 2030 under the current framework. That deadline, rather than a CRTC investment quota, was intended to encourage carriers to build their own networks.

A mobile network can grow without a new tower appearing on the skyline. Put a regional carrier's radio equipment on a shared mast and, for the CRTC's latest information request, that addition counts. The distinction is a useful way into a policy whose progress is harder to see than a construction site.

Canada's facilities-based MVNO framework allows eligible regional carriers to use incumbent networks in new areas while developing their own. Customers can arrive before a local network is complete. That brings forward competition, at least in the policy's design. It also leaves a practical question: what will carry those customers' calls when the obligation to provide access expires?

The current date is 9 May 2030. It marks the end of mandated supply, not an instruction to switch off every commercial agreement or every customer's phone. Even so, it gives today's wholesale arrangements a different character from an indefinite entitlement.

What has happened since the agreement?

In its 13 October 2026 letter, CRTC staff asks Bell Mobility, Rogers, TELUS and SaskTel for their regional-carrier agreements, copies and start and expiry dates. These are four incumbent hosts, not four national carriers: the framework distinguishes SaskTel from the other three.

Cogeco, Eastlink, Iristel and Quebecor, acting for Videotron and Freedom, face the more revealing questions. In each Tier 4 spectrum area where they use wholesale access to sell retail services, they must identify their customers and the new radio access network sites deployed since that use began. Equipment installed on shared towers is expressly included.

The request then asks for total capital associated with expansion into the identified new areas—actual figures where readily available, otherwise the best estimate—and additional sites planned between the response and May 2030. It does not expressly require an audited investment figure for every area. Nor is a planned site a completed one.

These distinctions change the picture. A customer count shows commercial use of access. A new radio site shows a physical addition. A spending total supplies another part of the account, but it needs a period and an explanation of what was included. None is a substitute for the others.

A deadline instead of a building quota

The choice was deliberate. In its 2021 policy, paragraphs 383–388, the CRTC considered investment targets and declined to impose them. It worried about setting a target high enough to encourage construction without putting smaller carriers in financial difficulty. Spectrum-licence build-out obligations imposed by ISED were a separate consideration; they did not disappear.

Instead, the CRTC relied on a limited access period and annual progress updates. The final tariff order of 9 May 2023 supplies the starting point for the seven-year clock. The October letter seeks a consolidated view as that period approaches its halfway point.

So a small site count would raise a question about the policy's progress, not automatically establish a breach of a construction quota. Conversely, a large count would not prove that wholesale access caused every addition. A project might already have been planned. The new letter alone does not supply that counterfactual, and the regulator has other reporting channels beyond this request.

Fewer reports need not mean less information

That last point matters because another CRTC process is moving in parallel. The 6 October reporting consultation asks whether separate MVNO progress reports remain necessary. Its stated reason is duplication: paragraph 17 says information needed to follow the framework is already collected annually through the Data Collection System.

This is not an announced end to oversight. The consultation accepts interventions until 20 November 2026 and replies until 22 January 2027. The separate information request has an earlier deadline: responses must reach the CRTC by 13 November, not merely be sent that day.

Abridged filings are required for the public record, with reasons for confidentiality claims. That does not promise that every financial figure will be visible. It should, however, give the public a better chance of seeing how contracts, customers and construction fit together.

The test is not whether Canada can count more towers. It is whether a temporary way into a market is becoming a durable way to compete in it. The October letter asks for evidence; it does not yet provide the answer.

Updated 25 October 2026: this version corrects the description of the four host carriers and clarifies the investment figures requested, the absence of a CRTC investment quota and the reporting consultation's duplication rationale. The original URL and publication date are retained.