EU Roam Like Home – Data Limits

After being very happy in my previous post on EU Roam Like Home coming into effect this is the follow up to take a look at the fine print. Back in September last year I analyzed the suggestions made by network operators of how to ensure that a subscription (pre-paid and contract) bought in one country is not permanently used in another to circumvent different pricing structures due to business models and network build-outs. The suggestions made then would have been quite limiting for my usage scenarios. Fortunately, however, things have changed somewhat in the meantime.

Here’s the press announcement of the EU on the topic that says at the beginning in the first few paragraphs that roaming charges are a thing of the past and that customers pay the same price at home and while roaming. Having said that the majority of the article then goes into the conditions under which the “same price” applies. The rules laid out are so complicated it’s difficult to find a point to start explaining things. I’m afraid the ordinary person will soon find out the hard way that the promise of the first part of the article does not apply to them.

Limited Amount of Roaming Data

The first major limit that contradicts the “you don’t pay extra” is for post-paid subscriptions that include a large amount or even unlimited mobile data. A large amount is defined as an amount of data included in a monthly bundle where the price per GB is less than €3.85 (in 2017). That is the case, for example, for my French contract in which 20 GB of data are included for 20 euros a month. Roaming regulation says that in this case the network operator can introduce a roaming limit that must at least be ‘twice the volume obtained by dividing the price of your mobile bundle (excluding VAT) by the wholesale data roaming cap (€7.70 in 2017).’ Get it? In my case that would be 20 Euros (bundle price) – 4 Euros for VAT = 16 euros. 2*16 euros = 32 euros / € 7.70 euros would result in 4.15 GB of data that is included while roaming per month. After that, a notification can be sent and each GB can be billed at €7.70 + VAT. In my case, 5 GB is included so my French network operator sticks pretty close to the minimum allowed. 5 GB is something one can work with but it’s far from using the subscription while roaming the same way like at home.

Prepaid-SIMs and roaming data

This story for pre-paid SIMs is even more complicated and I’m not sure I have fully understood it despite the example given after the rule. The way I understand it is that the amount of data available while roaming depends on the amount of data included in the pre-paid bundle and, that’s the important part, on the amount of credit (in Euros) on the pre-paid account. The example says that if 12 euros of credit are on the pre-paid account the subscriber should at least get  12 € / 7.7€ = 1.5 GB while roaming which, as I interpret it, does not cost extra because it’s included in the bundle. I guess this confusing rule has been made to prevent people buying pre-paid SIMs with large amounts of data in one country and then using a month or so in another country with little credit remaining. Let’s see if network operators will be using this.

Fair Use Policy

This rule lays out what is considered occasional roaming for which ‘roam like home’ applies: more time abroad than at home and your roaming exceeds your domestic usage over a period of 4 months. This rule is going to be an interesting one for me because some of my SIM cards are more abroad than at home but only used very little while roaming. So let’s see if I get a notification in 4 months time to explain myself and if my network operator will charge me in addition to the limits limits already in place today. (e.g. 5 GB).

Cross-border Workers

There are many more rules and I leave you to the original article for those except for the rule concerning cross-border workers. These say that a subscriber that connects to the home network once a day is not considered as a roamer and is thus exempted from the rule that roaming shall be occasional and not permanent.

All of this is going to be so much fun for national regulators to sort out… But as the saying goes: ‘Rome was not built in a day‘.