PTA Invites Public Feedback on Draft Framework For Mobile Virtual Network Operator Services

Pakistan Telecommunication Authority (PTA) has officially invited comments/ feedback on the draft framework for Mobile Virtual Network Operator (MVNO) services.

The regulator has invited stakeholder comments on the draft MNVO Framework to analyze the market dynamic for MVNO licensing in Pakistan.

The draft consultation framework is available on the PTA website. The deadline for providing feedback/ comments is 8th February 2024.

Mobile Virtual Network Operator (MVNO) is an operator that does not own any spectrum; instead, MVNOs have commercial arrangements with conventional Mobile Network Operators (MNOs) for the provision of Mobile Communication Services and Next Generation Mobile Services to their own customers.

This framework allows MVNO services in Pakistan in the light of clause 9.11.1 of Telecommunications Policy 2015.

An MNO shall be allowed to make commercial agreements with single/ multiple MVNOs. Further an MVNO shall also be allowed to make commercial agreements with single/multiple MNOs. The agreement between MNO and MVNO will define the scope of operations of MVNO, however, the scope of operations shall remain in line with MVNO models.

A brief description of the MVNO models is as under:

1. Reseller: The MVNO will be allowed to use its own brand name, marketing strategies, and sales however will only be allowed to market the services being offered/provided by the parent MNO and will not be allowed to install any radio or core network equipment
2. Service Provider: The MVNO will be allowed to use its own brand name, marketing strategies, customer care, and billing however will only be allowed to market the services being offered/provided by the parent MNO and will not be allowed to install any radio or core network equipment.
3. Enhanced Service Provider: This category of MVNO may provide its customized services in addition to the services provided by parent MNO and will use its own brand name and marketing strategy. This category may install telecom network elements restricted to its model.
4. Full MVNO: A full MVNO will be allowed to provide all types of services as provided by MNO which include branding, marketing, and install its core network elements except access network elements.

MNO and MVNO shall jointly submit to the Authority, a technical and business plan along with a draft commercial agreement between MNO and MVNO as per the checklist. The applicant shall be granted an MVNO license after fulfillment of all codal formalities.

MVNOs shall be allowed to install their network elements depending upon the scope of operations agreed upon as per the agreement with parent MNOs duly approved by the Authority. Further, the agreement once approved by PTA shall not be changed by any party without prior approval of PTA.

Quality of Service shall be the sole responsibility of MVNO. Since MVNO shall hold its brand name, and consumer ownership and market its SIMs, it must ensure that its users receive good quality of service as per benchmarks set by PTA. MVNO while agreeing with MNO(s) shall look into this aspect and individual responsibilities in this regard should be pronounced in the document.

MVNO shall be responsible for fulfilling the National Security requirements. Appropriate clauses will be included in the agreement to ensure efficient resolution of issues related to security, Lawful Interception (LI), data records, etc., and terms and conditions for activation/ de-activation of SIMs as set by PTA and its amendments thereto, before commencement of its commercial services.

Once an MVNO commences its services, the MNO shall provide service to the MVNO without interruption. Also, the parent MNOs shall not degrade, suspend, discontinue, or terminate any service provided to MVNO or take any measures that affect the delivery of service to MVNO without prior approval of PTA. Similarly, MVNO shall not stop the provision of services to its customers without at least three (3) months’ notice and prior approval from PTA.

As MVNO will hold the ownership of its customers, it will be responsible for making necessary arrangements to facilitate them. The MVNO shall address the complaints of its users and for this purpose shall establish at least one customer care center in each city of its operation and a 24/7 nationwide helpline.

MVNO shall be required to take action against its customers related to its services as required under the prevailing law. MVNO shall be responsible for the resolution of billing or other disputes with its customers as per its scope. The MVNO shall submit its Code of Commercial Practice and Standard Contract of Service to PTA for approval and shall follow the same in true letter and spirit. MVNO shall ensure necessary safeguards are in place to abide by PTA’s DIRBS and loss/stolen device requirements.

MVNO shall be allowed to use only parent MNO’s roaming and interconnect agreements with other operators.

MVNO shall pay regulatory fees and contributions including USF and R&D in the same way as applicable on MNOs, however, MVNO will pay USF and R&D contributions through their parent MNOs. Detailed mechanisms for payments will be provided.

The MVNO license shall be issued for an initial period of xx years which can be renewed, subject to the provision of mutual agreement between the parties. If the agreement between MVNO and parent MNO is terminated for any reason before the license term of xx years and MVNO has no other valid agreement with any other or same MNO the MVNO license will be suspended for one year if the MVNO provides a valid agreement with another or same MNO the license will be restored otherwise the MVNO license will be terminated. In case of termination, MVNO has to ensure and complete all legal and codal formalities.