The Great Disappearing Act

Since 2009, MVNOs have – in one form or another – been a “thorn in the side” of telco operators.

In the battle for ‘wholesale access’ MVNOs are really heros for breaking the MNOs monopolistic grip on their own networks. Spending valuable time and money ‘fighting the good fight’ for consumers in underserved communities. Consumers not profitable enough to garner direct interest or investment from the MNOs themselves.

In fact, MVNO demands for wholesale access, both on the regulatory and commercial front, have ostensibly acted as an important catalyst for the adoption of IoT platforms and the carrier ‘openness’ to diverse offerings, like eSIM.

Let’s be clear, I am not saying MVNOs invented IoT or eSIM (although there is an argument to be made here). However, MVNOs are absolutely the pioneers of wholesale access. Further still, full-MVNOs and their relentless push for deeper network integration forced these giants (under duress) to dedicate network slices, deliver scalable platforms, and integrate eUICC capabilities that have become the essential technical scaffolding for IoT/eSIM innovation.

The presence of MVNOs in the market has pushed telecom incumbents beyond their traditional retail strategics and subscriber acquisition models. Without the continued persistence of MVNOs “storming the gate”, MNOs would have never prioritized these technical functionalities which have since become commercial necessities for MNOs today.

This is an impact so valuable that when the GSMA opened its doors to MVNOs in 2022, it should have been more than a gesture. It should have been an acknowledgment that MVNOs were instrumental not only to the growth of but the existence of the wholesale market but for its entire existence in the first place. This integral market role which was highlighted by a BEREC study less than a year later (2023) which found that specialist IoT MVNOs “have a strong record in patching together national networks, innovating on top and selling new use cases” in vertical industries like automotive and logistics.

Yet today, despite two decades of effort and investment the MVNO landscape is hollowing out. With regulators and investors mistaking sub-brands for competitive market vitality – genuine MVNO are not so slowly-dying – consumed by their carriers, starved of market share by unenforced regulation, and abandoned in spectrum allocations.

Across the world, regulation supporting MVNOs exist, but the challane is enforcement.

• UK/EU: Ofcom’s 2025 review of wholesale access lacks firm measures and deadlines. While the EU’s BEREC wholesale mobile connectivity report (2023) details best practices; the European Commission lacks binding authority to enforce them across member states.
• USA: The FCC is twiddling it fingers under a Trump administration with new guidelines to enforce MVNO access, but which also relies on voluntary compliance with. consolidation from the T-Mobile/Sprint merger further solidifying MNO dominance
• LatAm: In Brazil- Anatel blocked Plintron’s acquisition of Surf Telecom over vaguely defined “wrongdoings”, signaling to the markets deep and continuing reluctance to allow independent MVNOs.
• Asia: Most concerning (at the moment) is the egregious example in Thailand where the NBTC has granted 58 MVNO licenses but today only ~5 are active, Spectrum once reserved for independent operators is now being siphoned. Recent industry press accuses the Thai regulator of everything from “cultivating a duopoly” and “stifling competition” through inaction to outright “fraud and market manipulation.” Furthermore NT (the state-owned MNO) will completely and entirely stop allocating MVNO spectrum by August of this year.

In all these cases, regulations exist to protect MVNOs but regulators have been receding quietly into the background rather than roaring into action. Fundamentally allowing MNOs to reduce wholesale competition while providing the “illusion of competition”.

These ‘faux-MVNOs’ masquerading as competition are sub-brands like Telefonica’s Giffgaff in the UK and Virgin Mobile which both now exist under parent MNO umbrellas. In the US, TracFone, Metro, and Cricket operate as AT&T or Verizon wings.

This “trick of the trade” is used to confused both investors and regulators. When sub-brands are counted as MVNOs, market fragmentation appears robust but in reality, true MVNOS are rare and increasingly vulnerable.

This vulerability is a trait shared by more than 2.5 billion people who remain unconnected—many in regions MVNO-driven models could effectively serve. MVNOs, especially IoT-focused ones, are uniquely positioned to serve rural, agricultural, and health segments. But as the ‘great disappearing act of 2025 continues to drive long-standing MVNO to the grave, even those “gateway” solutions are vanishing from the map.

It’s a simple really; In 2025 regulatory failure + sub-brand substitution + spectrum abandonment = a near-total collapse of MVNO ecosystems across the globe.

So is it too late to save MVNOs from complete obsolescence?

Here are a few suggestions at this critical juncture that could put some bite back into market regulation. A Blueprint to Revive the MVNO Layer from the iMVNOx Association knowledge base:

• Differentiate true MVNOs from sub-brands. Require separate branding, accounting, and licensing. Regulators must refuse to count captive sub-brands as independent operators.
• Ring‑fence spectrum for independents.
Auction not just frequency, but enforceable access rights. Suspend MVNO spectrum access to MNOs if wholesale terms aren’t met.
• Mandate wholesale terms for IoT/eSIM. Commission caps for network slicing and eSIM-enabled access—built into licensing terms across UK, EU, US & Brazil.
• Enforce transparency.
Require annual disclosures of MVNO penetration and spectrum use. Unexplained MVNO contraction triggers investigations or penalties.
• Support underserved pilots. Public-private funds aimed at MVNO initiatives in remote regions, linking operations to digital inclusion goals.
• Empower MVNO advocacy at GSMA.
MVNOs need a strong voice within GSMA—a formal alliance or lobbying unit to balance MNO influence.

These aren’t vague ideals spoken from a vacuum. This is real advice- anchored in existing policy frameworks and back by the input of more than 150 MVNOs with more than 20 years experienc serving markets across the globe.

But regulators must act decisively and swiftly. It’s not enough for MNOs to create an illusion with sub-brands—real competition requires independent, accountable operators with access, spectrum, and visibility.

Without this the world risks entering an era defined not by growth and innovation—but by monopolies wrangling profits while billions stay offline, deepening the global inequality created by the digital divide.

My only hope – considering that historical influence of regulation and speed of change – is that it is not already too late to keep the true MVNO from disappearing altogether.