Summary

  • The regulator says 29.5 million subscriptions and 135.5% penetration at end-2025 largely reflect multiple SIMs, while missing number portability, bundled offers and number-linked services make switching harder.
  • TRCSL’s paired draft reports propose retail controls for Dialog and new wholesale access remedies. They are still under consultation; their success should be measured in actual provider changes and entry, not in the publication of obligations.

A mobile market can look crowded in a spreadsheet and still leave customers with little practical freedom to leave. Sri Lanka’s headline ratio—about 135.5 subscriptions per 100 residents at the end of December 2025—counts active connections against population. It does not count unique people, nor show how many have moved their primary service from one operator to another. The retail mobile market draft makes this distinction itself: high penetration is driven by extensive multi-SIM use, not evidence that competition is unconstrained.

The difference is economic. A customer who keeps a primary number for banking, authentication and family contacts may add a second SIM for coverage, a promotional bundle or cheaper data. The second connection raises the subscription count without forcing either provider to win the customer’s full account. TRCSL says Sri Lanka has no mobile number portability; changing operator usually means changing the number. Its draft also identifies bundles and customer inertia as frictions. It reports that 95.3% of individual subscribers were prepaid at end-September 2025, but prepaid status does not remove these practical costs.

Nor does every disconnection mean a rival has won a customer. The retail report says reconnections and new subscriptions can make churn look larger than effective switching: a customer may stop using one SIM, reactivate another, or retain several connections. That is why a churn rate needs a denominator and a definition. Gross disconnections, net subscriber growth and a verified transfer of a customer’s primary usage answer different questions.

The proposed market diagnosis is consequential. At end-September 2025, TRCSL’s draft attributes 62.1% of mobile voice subscribers and 66.7% of voice revenue to Dialog Axiata; in mobile broadband it gives Dialog 62.7% of subscribers and 67.6% of revenue. The report proposes finding Dialog to have significant market power in both retail markets. These are regulator estimates for specified markets and dates, not final designations.

TRCSL has paired that retail review with an upstream wholesale analysis. The wholesale mobile access draft says no operator commercially supplies the defined mobile access products to third parties, no MVNO has entered, and national roaming has not become a practical entry route. It proposes cost-oriented, transparent and non-discriminatory wholesale access from Dialog, with separate accounts and margin-squeeze monitoring; it also proposes national-roaming and active RAN-sharing provisions. The retail report, meanwhile, proposes prior tariff approval and cost accounting for Dialog while allowing non-SMP operators greater tariff freedom, plus accounting separation and transparency measures.

The two layers address different obstacles. Wholesale access could give another service provider a route to customers without building a complete radio network. Retail tariff oversight could constrain conduct by an operator the draft considers powerful. But neither changes a customer’s number-linked switching cost by itself. TRCSL identifies number portability as a barrier; its listed remedy package does not set out a portability measure. That leaves a legitimate consultation question: can wholesale entry discipline offers if customers still face friction when they leave?

The evidence is not complete enough to answer that question in advance. The retail draft’s tenure discussion leaves some comparative percentage values unspecified, and the reports are proposals rather than observed outcomes. The consultation notice confirms that publication does not yet designate an SMP operator or impose these new obligations; the public announcement lists the four reports. Responses are due on 4 November 2026 at 17:00 Sri Lanka time.

The scorecard should therefore separate subscriptions from unique customers, SIM inactivity from provider switching, and wholesale access offers from executed agreements. The decisive outcomes are customers who actually consolidate or transfer service, access seekers that sign and use wholesale contracts, and changes in price and quality. A market with many SIMs can still be sticky. Only those outcomes show whether rivalry has become easier to use.