AND HOW TO

SOLVE THEM
ISSUES IN THAILAND

PRESENTED AT


PRESENTATION BY
ALLAN RASMUSSEN
2560
 THAILANDS TELECOM MARKET AN UNLEVEL PLAYING FIELD
www.yozzo.com

MOBILE OPERATORS PLAYING FIELD MVNOS PLAYING FIELD

Without some form of regulatory measures and changes as described in this presentation, Thailands telecoms market will remain an unleveled playing
field, where competition and innovation of mobile services, and thereby the digital economy, may not evolve as it should - or at all.

The government has provided the platform for private industries to participate and form the final stages of Thailand 4.0 however the current regulation
from NBTC - or lack off, has not been able to follow suit but only concentrated on the existing silos in the market instead of getting all the wheels to spin.

Luckily, most of the issues evolves around issues created by NBTC itself i.e. home made quick fix paragraphs, lack of action, or lack of knowhow by the time
MVNO was introduced, which demands less effort to solve.
 MVNOS IN THAILAND WHY IT FAILED
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In 2009 five MVNOs where given a license by the telecom regulator NBTC to operate as MVNOs on the state enterprise telecom operator TOT

AS OF NOVEMBER 2017
ONLY 1 MVNO IS LEFT
i-Kool 3G (Loxley)

MVNO IN THAILAND HAVE FAILED BECAUSE OF THE FOLLOWING REASONS

INSUFFICIENT NETWORK CAPACITY AT LAUNCH UNLEVEL PLAYING FIELD - UNRESOLVED

INSUFFICIENT MVNO EXPERIENCE AND QUALITY POOR PLANNING AND EXECUTION
POOR MVNO CONTRACTS AND REGULATION LEGACY SYSTEMS AND RED-TAPE
 THAILANDS SUPERBOARD FAULTS THE REGULATOR NBTC FOR MVNO FAILURE
www.yozzo.com

In 2016, The Inspection and Evaluations Commission (also known as the Superboard) of the National Broadcasting
and Telecommunications Commission (NBTC), failed the telecom regulator and concluded that:

NBTC should issues regulations for mobile

virtual operators to support more of them in
the Industry, which should benefit consumers.
 WHAT HAS THE REGULATOR NBTC DONE ABOUT IT?
www.yozzo.com

nothing
Pronoun
not anything; no single thing.

Adjective
having no prospect of progress; of no value
 BUT CONTINUES TO SELL MVNO LICENSES
www.yozzo.com

MVNO LICENSES ISSUED IN THAILAND

AS OF DECEMBER 2017

51 COMPANIES
HAVE OBTAINED A MVNO LICENSE IN THAILAND
ONLY 9 HAVE LAUNCHED 5 ARE STILL ALIVE
 MVNOS, ARE AN INTEGRAL PART OF THE GLOBAL MOBILE LANDSCAPE
Over the past 18 years, MVNOs have helped stimulate competition
in the mobile market, launching innovative tariffs and services and
attracting niche consumer segments at a lower cost than mobile
network operators (MNOs). In Europe virtually every cable and
fixed-line operator has a mobility strategy, largely based on MVNO
TODAY, MVNOS HAVE REACHED 214 MILLION USERS WORLDWIDE, AND IS ESTIMATED TO GROW TO 300 MILLION USERS AND A $70 BILLION VALUE IN 2020
Overall connection growth for mobile phone service around the world was
about 4.5% end of 2015. MVNO connections are growing at about 18% per
annum 4 times faster than the average rate for the mobile industry.
1000+ INDEPENDENT MVNOS WORLDWIDE
MVNOS INCREASED 70% BETWEEN 2010 AND 2015
72 COUNTRIES HAVE MVNOS IN OPERATION
MVNOS ACCOUNT FOR 14% OF THE TOTAL EU MARKET
EUROPE IS HOME TO: 595 MVNOS, APAC: 137, US: 111
1 OUT OF 10 PEOPLE IN AUSTRALIA IS A MVNO CUSTOMER
www.yozzo.com
With a predicted compound annual growth rate (CAGR) of over 10% in
the forecast period to year 2020, the Asia Pacific region is home to the
worlds fastest growing MVNO sector, even more than the highly
competitive MVNO markets of Europe and North America.
Grand View Research
Ovum predicts that nearly 24% of all new subscriber connections
over the next five years will come from MVNO subscribers.
Although the current enterprise market represents less than
10% of these connections now, they expect it triple to 30%
By 2020, IDC predicts that 30% of the top 500
companies in Thailand will see the majority of their
business depend on the ability to create digitally-
enhanced products, services and experiences
Source IDC Thailand
 AND HAVE DELIVERED
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THE RATIONALE FOR THE INTRODUCTION OF MVNO, INCLUDE - BUT ARE NOT LIMITED TO:
Stimulate competition,
Efficient utilization of network resources,
Introduce new or better services aligned to lifestyle propositions currently unserved/underserved,
Promote investment opportunities for local and international businesses in the telecom market.
Consequently, MVNOs are intended to support innovation, bridge digital divide, and contribute to the growth in the ICT sector to
ensure the achievement of the broader industry and DIGITAL ECONOMY OBJECTIVES.

THE CLEAR INTERNATIONAL EVIDENCE IS THAT MVNOs HAVE DELIVERED:

More consumer choice
Innovative pricing plans
Innovative products and services
innovation in, and better customer service
 www.yozzo.com

meanwhile in Thailand
 THAILANDS TELECOM ECOSYSTEM
www.yozzo.com

MNO = MOBILE NETWORK OPERATOR

MNO Is a Mobile Network Operator who owns its own network infrastructure and has licensed allocated spectrum.

In Thailand the MNOs are: AIS, CAT Telecom, DTAC, TOT and TRUE
MOBILE NETWORK OPERATORS OWN THE INFRASTRUCTURE
www.yozzo.com
AND LICENSE THE SPECTRUM
www.yozzo.com
FROM THE NATIONAL TELECOM REGULATOR (NBTC)
www.yozzo.com

NBTC
THE 900/1800/2100MHz SPECTRUM LICENSES STATES 10% OF THE CAPACITY MUST GO TO MVNOS
www.yozzo.com

10%

MVNO
 HOWEVER IN THAILAND ONLY CAT TELECOM AND TOT HOST MVNOS
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STATE ENTERPRISE STATE ENTERPRISE

MVNO
HOW MVNOS CONNECT: MVNOS CAN CONNECT TO MNOS DIRECTLY
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MVNO = MOBILE VIRTUAL NETWORK OPERATOR

A MVNO does not own spectrum, instead it enters into an agreement with either a MNO or MVNA to obtain
access to airtime at wholesale rates, and then sets its own retail price and service. An MVNO may invest in
its own operational components or employ the services of a Mobile Virtual Network Enabler (MVNE)

MNO MVNO

MVNO
 MVNOS CAN CONNECT TO MNOS THROUGH A MVNA
www.yozzo.com

MVNA = MOBILE VIRTUAL NETWORK AGGREGATOR

A MVNA is an entity, who buys mobile airtime in bulk from the MNO, and then
wholesale the airtime to MVNOs. The MVNOs retails the airtime to its end-users

MNO MVNA MVNO

MVNO
 MVNOS CAN CONNECT TO MNOS THROUGH A MVNE
www.yozzo.com

MVNE = MOBILE VIRTUAL NETWORK ENABLER

Provides infrastructure and services to both the MNO and MVNOs, which enables MVNOs to offer their services on the MNOs
network, while leaving the telecom enablement to the MVNE. The MVNE provides services, such as billing, business workflow,
product setup, service delivery, customer care, fraud management, reporting, sale platforms, device management, etc.

MNO MVNE MVNO

MVNO
 MVNOS CAN CONNECT TO MNOS THROUGH A MVNE/MVNA
www.yozzo.com

MVNA + MVNE = MOBILE VIRTUAL NETWORK AGGREGATOR + ENABLER

The MVNA/MVNE purchases airtime in bulk from the MNO, adds the operational telecom components on
top, and then wholesales the airtime and service as a full turnkey solution to MVNOs. The MVNA/MVNE
also offers additional value add to the MNVOs in terms of guidance during setup, launch and operation.

MNO MVNA/MVNE MVNO

MVNO
 www.yozzo.com

PROBLEM #1 IN THAILAND
THE MNO TRIANGLE
 MYSTERIOUS CIRCUMSTANCES - THE BERMUDA TRIANGLE www.yozzo.com

Bermuda

THE NORTH ATLANTIC OCEAN HAS ITS BERMUDA TRIANGLE

Where ships and airplanes has mysteriously gone missing

Florida North Atlantic Ocean

Puerto Rico
MYSTERIOUS CIRCUMSTANCES - THE MNO TRIANGLE IN THAILAND www.yozzo.com

LIKEWISE IN THAILAND WE HAVE THE MNO TRIANGLE

Where MVNOs for mysteriously reasons havent been able to launch for 5 years
 DESPITE THE MVNO CRITERIA AND CAPACITY ON THE 2100MHz LICENSES www.yozzo.com

Prior to Thailands 2100MHz 3G auction in 2012, the NBTC released the following Criteria and Procedure for the Spectrum.

16.5.1 The Licensee shall provide telecommunications network service with the minimum
capacity of 10 percent of its networks to the MVNO who is not the Connected Person in
the Shareholding Structure with any licensee when receiving such service request

AIS 90% DTAC 90% TRUE 90%

NBTC Notification | http://www.parliament.go.th/ewtcommittee/ewt/tele/ewt_dl_link.php?nid=144&filename=index

 DESPITE THE MVNO CRITERIA AND CAPACITY ON THE 900MHz & 1800MHz LICENSES www.yozzo.com

As with the 2100MHz spectrum, the NBTC has also added a MVNO clause in the terms for the 900MHz and 1800MHz licenses (2015/2016)

(1) The Licensee shall comply with the Commissions Notification Regarding Mobile Virtual Network Operator Service 2013.
(2) The Licensee shall provide telecommunications network service at least 10 percent of its networks capacity to MVNO(s) that
is/are not the connected person(s) with any licensee under this Notification, upon receiving such service request.

900MHz 900MHz 1800MHz 1800MHz

AIS 90% True 90% True 90% AWN (AIS) 90%

PDF | NBTC 900MHz Criteria (English) | http://auction.nbtc.go.th/getattachment/HOME/900MHz_Criteria_Eng.pdf.aspx

PDF | NBTC 1800MHz Criteria (English)| http://auction.nbtc.go.th/getattachment/HOME/1800MHz_Criteria_Eng.pdf.aspx
 www.yozzo.com

No MVNOs have been able to launch on AIS,

DTAC or TRUE despite the license terms saying
the operators of 900, 1800 and 2100MHz have
to provide at least 10% capacity to MVNOs
 www.yozzo.com

THE MNO TRIANGLE SOLUTION

 THE MNO TRIANGLE SOLUTION
www.yozzo.com

1. The NBTC should publish a clear policy statement requiring the telecom network operators to provision MVNOs on their network.
2. The NBTC should exercise its regulatory mandate to monitor the market and the negotiations to ensure that mobile network operators conduct
negotiations fairly and in good faith - and that the policy objectives of the mobile market are fulfilled.
3. The detailed terms and conditions of MVNO provisioning should first be left to the parties to negotiate on a purely commercial basis
4. It would be in the public interest for the NBTC to intervene, and assist the parties - or if necessary, settle and resolve in case a mobile network
operator is acting in bad faith, engaging in any form of anticompetitive conduct, or if, after a reasonable period (1 months) of in-good-faith
negotiations, a commercial agreement cannot be reached between the parties.

5. The NBTC should follow up on a monthly basis to see if there is a progress in on-boarding MVNOs, and take measures if not.

In addition, and as a last resort only, if no progress is made - a regulatory mechanism allowing the NBTC to intervene, to:
Ensure fair and reasonable terms for access
Safeguard fair and non-discriminatory competitive behavior
Bring parties to the negotiating table at the earliest opportunity
Introduce and safeguard the principle of in-good-faith commercial negotiations.

i.e., the mobile network operator shall enter into a wholesale agreement with the MVNO, within a period of 1 months from the date of issuing a Letter
of Intent (LoI) or Memorandum of Understanding (MoU) and submit a copy of the same to the NBTC (licensor).

NBTC would have the power to intervene in the agreement if deemed necessary by one of the parties.
The Regulations/Directives/Orders of NBTC in this regard would be binding on the telecom network operators and the MVNO.
 NO MVNO NO LICENSE
www.yozzo.com

The NBTC has been very active in making sure that terms and conditions, such as minimum roll out
coverage, license payments, maximum retail pricing, etc. has been followed by the 900/1800/2100MHz
auction winners, while zero attention - nor consequences has been given regarding the MVNO capacity.

NBTC is planning an auction for one 850Mhz and

three 1800MHz spectrum licenses in 2018. It would
suit the regulator well to live up to its reason to
exist, by facing the issue of un-used MVNO capacity
among the three existing spectrum license holders.

One suggestion would be to add to the auction

terms and conditions, that in order to participate in
the upcoming spectrum auction, an existing license
holder, who has not yet lived up to the terms and
conditions in its previous spectrum license
regarding MVNO capacity, would have to launch at
least one MVNO, on their networks in order to
participate in the spectrum auctions. The mobile
network operators should be given a maximum
period of 60 days to present an MVNO proposal.
 www.yozzo.com

PROBLEM #2 IN THAILAND
NO FULL MVNO
NO FULL MVNO IN THAILAND = NO CONTROL OF THEIR OWN BUSINESS
www.yozzo.com
 TYPES OF MVNOS AND OPERATING MODELS
www.yozzo.com

MVNO types, e.g. branded reseller, thin, medium, or full MVNOs, are defined by which of the
operational components the MVNO manages, and which one the network operator or MVNE manages.

MNO Functions Carried out by MNO MVNO Functions carried out by MVNO MVNE Functions carried out by MVNE

APP. CUSTOMER CUSTOMER CUSTOMER SIM & VOUCHER SALES & HANDSET
MNO NETWORK
& SERVICES ACTIVATION BILLING SERVICE
MARKETING
DISTRIBUTION MANAGEMENT
MANAGEMENT

BRANDED RESELLER MNO MNO MNO MNO MNO MVNO MNO MVNO MNO

SERVICE PROVIDER MNO MNO MNO MVNO MVNO MVNO MVNO MVNO MNO

ENHANCED MVNO MNO MNO MVNO MVNO MVNO MVNO MVNO MVNO MVNO

FULL MVNO MNO MVNO MVNO MVNO MVNO MVNO MVNO MVNO MVNO

MVNE MNO MVNE MVNE MVNE MVNE MVNE MVNE MVNE MVNE

MNO = Mobile Network Operator MVNO = Mobile Virtual Network Operator MVNE = Mobile Virtual Network Enabler
FULL MVNO = CONTROL OF OWN BUSINESS AND FLEXIBILITY TO PROVIDE INNOVATIVE SERVICES
www.yozzo.com

HLR/HSS

SMSC
A Full MVNO has complete control over its operation, data, SIMs, customers and services due
to certain core network elements such as:

GMSC (Gateway Mobile Switching Centre)

GMSC HLR (Home Location Register)
SMSC (Short Message Service Centre),
MMSC (Multimedia Messaging Service)
GGSN (Gateway GPRS Support Node)
VOICEMAIL
Full MVNOs can also have their own roaming and interconnect agreements with other MNOs.

MMSC

GGSN
 MVNO POSITIONING
www.yozzo.com

INNOVATIVE

IoT/M2M
MVNOs
MVNOs based on
value addition
SERVICE OFFERING
As a FULL MVNO the MVNO
can have control over services
they can offer in the market,
and thereby the flexibility to
innovate and compete on new MVNOs based
service offerings in the market on convinience

Traditional
No frills Mobile Operators
MVNOs

LOW PRICING HIGH

 AS WELL AS TACKLING DIVERSE, URGENT AND SIMULTANEOUS DEMANDS ON A HOURLY BASIS
www.yozzo.com

1 OTT MVNO wants to launch zero rating service on videos from

its own portfolio to compete in the market against HBO, Netflix

MVNO
6 Ethnic MVNO wants to launch 2 Travel & Leisure MVNO needs to urgently
mothers day promotions before MVNO MVNO resolve customer billing disputes before start
competitor launches its promotions of Songkran holiday season tomorrow

5 Retail MVNO wants to provide extra 3 Retail MVNO wants to access its user usage
bonus points in loyalty program to drive data) to better address the needs and wants
sales this weekend MVNO MVNO of its own customers

MVNO

4 Bank MVNO wants to utilize bulk of sales-force

tomorrow to visit its premium customers to make a
one-day only offer for rate plan upgrades
 EXAMPLE www.yozzo.com

Lets say Thailand wins 4-0 over

Singapore in football, and the whole
country is celebrating the victory on
social media. The MVNOs also
wants to join the celebrations by
providing the customers with a 20%
discount on all voice calls

THAILAND vs. SINGAPORE

4-0
 IN THAILAND TODAY
www.yozzo.com

This is how it works today in Thailand if MVNOs want to introduce new promotions, service - or tackle issues

WEEK 1 WEEK 3 MONTH ? MONTH ?

Fax your request Present your case at a Internal meeting at the

Wait for result
to the MNO meeting with the MNO MNO to approve or not
 EXAMPLE www.yozzo.com

Meanwhile Thailand will have

lost to another country in both
football and innovation
NOT ALLOWING FULL MVNO KILLS INNOVATION AND CREATES AN UNLEVEL PLAYING FIELD
www.yozzo.com

INNOVATIVE

The MVNOs will not be able to

SERVICE OFFERING compete on neither services,
pricing - or introducing new
innovations to the market,
thereby giving the traditional
mobile network operators an
unfair advantage, severely
limiting innovation and
competition in the market

Traditional
Mobile Operators

LOW PRICING HIGH

 www.yozzo.com

THE SOLUTION
Allow Full MVNOs (like in other markets), to level the playing field,
foster innovation and competition for the benefit of the consumers
 www.yozzo.com

PROBLEM #3 IN THAILAND
DOUBLE / TRIPLE LICENSE FEE
 UNFAIR DOUBLE LICENSE FEE HURTING THE MVNO AND CONSUMERS
www.yozzo.com

In 2009 the NBTC introduced Mobile Virtual Network Operator (MNVO) license along with a license fee scheme up to 1.5% of yearly revenue.
However, the setup of the license fees causes the burden to be pushed to the MVNOs and consumers, as the NBTC is charging double fees on one signal.

The operator pays NBTC 1.50% of revenue in license

fee + 3.50% of annual revenue in USO fee - Total 5%
The MVNO pays NBTC 1.5% of annual revenue
in license fee.

Example: Example:
The operator sells THB 100 worth of voice calling to The MVNO sells the now THB 105 worth of voice
the MVNO which is THB 100 + 5% fee = THB 105 calling to customers. THB 105 + 1.5% fee = THB 106,57

OPERATOR MVNO

Un-level playing field as the As the host operator and MVNO each have to pay the
operator can sell directly to license fees of annual revenue, the same mobile
customers for just THB 105 signal (voice/sms/data) ends up having double the
vs. the MVNOs THB 106,57 tax, when it ends up at the MVNO and its customers.

Voice Call 1.50% License Fee New Voice MVNO New Voice
Cost + 3.50% USO Fee
Total 5%
= Call Cost + License Fee = Call Cost
Total 1.5%
THB 100 THB 105 THB 106,57

REGULATOR
2 x 1.5% License Fees (MNO+MVNO = 3%
1 x 3.5% USO Fee (MNO) = 3.5% TOTAL = 6.50%
 UNFAIR TRIPLE LICENSE FEE HURTING THE MVNO AND MVNA
www.yozzo.com

In 2009 the NBTC introduced Mobile Virtual Network Operator (MNVO) license along with a license fee scheme up to 1.5% of yearly revenue.
However, the setup of the license fees causes the burden to be pushed to the MVNA, the MVNO and consumers, as the NBTC is charging triple fees on one signal.

The operator pays NBTC 1.5% of revenue in license

fee + 3.5% of annual revenue in USO fee - Total 5%
The MVNA pays NBTC 1.5% of
annual revenue in license fee
The MVNO pays NBTC 1.5% of annual revenue in license fee
Example: Example: The MVNA resells the now THB Example: The MVNO sells the now THB 106,57 worth of voice
The operator sells THB 100 worth of voice calling to 105 worth of voice calling to the MVNO. calling to customers. I.e. THB 106,57 + 1.5% fee = THB 108,17
the MVNA i.e. THB 100 + 5% fee = THB 105 I.e. THB 1,05 + 1.5% fee = THB 106,57

OPERATOR MVNA MVNO

As the MNO, MVNA and MVNO each
have to pay the license fee, the same
mobile signal (voice/sms/data) ends
up having triple tax, when it arrives at
the MVNOs and the consumers

The operator can sell Voice Call 1.5% License Fee New Voice MVNA New Voice MVNO New Voice
directly to customers Cost + 3.5% USO Fee = Call Cost + License Fee
Total 1.5%
= Call Cost + License Fee
Total 1.5%
= Call Cost
for just THB 105 vs. the THB 100 Total 5% THB 105 THB 106,57 THB 108,17
MVNOs THB 108,17

REGULATOR
3 x 1.5% License Fees (MNO, MVNA, MVNO) = 4.5%
1 x 3.5% USO Fee (MNO) = 3.5% TOTAL = 8%
 MVNOS MAKES ITS BUSINESS ON MARGINS
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MVNO
The unfair double, and triple taxation changes the
MVNOs makes its business on the
timeline significantly for the MVNO to reach financial
small margins between costs and sale
breakeven if ever - given that the current fee
price. They operate a lean and flexible
structure setup not only adds costs, but also provides
setup where every satang counts.
the mobile operators with an unfair pricing advantage
VS.
 www.yozzo.com

THE SOLUTION
Let the MNO and MVNO (MVNA) split
the 1.5% license fee like we do with VAT
i.e. MNO 0.75% and MVNO 0.75% = 1.5%
 www.yozzo.com

PROBLEM #4 IN THAILAND
BUREAU-CRACY KILLING INNOVATION
 MVNO LICENSE APPLICATION IS IN-CORRECT AND NOT UP-TO-DATE
www.yozzo.com

TERMS AND APPLICATION FOR MVNO IN

THAILAND IS ABOUT 15-YEARS TO OLD

The application seems to be a copy

and paste from old applications and
various countries in early 2000s

In mid-2017 the NBTC added a MVNA license

to the market without request for consulting
or public hearing, ending up using the MVNO
application for MVNA license as well.
 LICENSE APPLICATION BUREAU-CRAZY
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FILL-OUT & HAND-IN THE APPLICATION NBTC OFFICER HAS TO UNDERSTAND & APPROVE

NBTC has added their own little notice to the act regarding license approval.
The NBTC officer can decline the application if he/she doesn't understand, either due to language, the service, network etc.
 LICENSE APPLICATION BUREAU-CRAZY
www.yozzo.com

BECAUSE THE OFFICER IS RESPONSIBLE ONCE APPROVED, THE OFFICER

HANDS THE APPLICATION TO NBTCS
SECRETARY-GENERAL TO SIGN
 LICENSE APPLICATION BUREAU-CRAZY
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THE MVNO LICENSE IS GIVEN BASED ON THE APPROVED INFORMATION

I.e. The information given and approved is part of the license License valid for 5-years
 LICENSE APPLICATION BUREAU-CRAZY
www.yozzo.com

HOWEVER
The NBTC officer will not uderstand new innovative service from the MVNO and decline it
because he/she is responsible, and it does not fit the boxes. Therfore all MVNOs are the same
in Thailand - even MVNAs have to use the MVNO application form which makes no sense

?
 BUREAU-CRACY KILLS INNOVATION AND OPENS FOR CORRUPTION
www.yozzo.com

The officer becomes a single gatekeeper, which opens for corruption

The setup opens a backdoor

virus for further corruption.

Because

The MVNO license is valid for 5-

years and consist of the
information provided in the
application. That information is
however outdated because it has
to fit the old standard and
knowhow from the officer.

Once the MVNO launch in the

real world with technology and
interfaces according to updated
standards the regulator can come
back at anytime and say the
MVNO is not operating accoding
to the license (information
provided in the license) and
demand they stop operation or
solve it with a brown envelope.
 GETTING A LICENSE WITHOUT AN AGREEMENT
www.yozzo.com

Thailand is among few, if not the only country in the world,

where you can get a MVNO license without some sort of
agreement (MoU) with a mobile operator (or MVNA/MVNE)
 GETTING A LICENSE WITHOUT AN AGREEMENT HOW?
www.yozzo.com

FILL-OUT & HAND-IN THE APPLICATION MVNO LICENSE IS GIVEN BASED ON

THE APPLICATION INFORMATION

HOW?
 GETTING A LICENSE WITHOUT AN AGREEMENT HOW?
www.yozzo.com

Question: How does a MVNO without a host operator agreement fill out 9,10, 11, 12?
Answer: They fill in ALL operators as example and use a network diagram from the 90s

Who would buy equipment BEFORE

having an MNO agreement AND a license?
 www.yozzo.com

THE SOLUTION
Update the license application to the present and amend it from time to time.
Drop the added clause that the officer has to understand, approve and be responsible.
There is no reason to provide a license prior to an agreement with a MNO/MVNA/MVNE.
Introduce a real MVNA license application = do not use the MVNO application its not the same.

BUT BETTER YET

Drop the need for MVNA/MVNO application/license altogether in-line with other countries who no longer issues MVNO licenses.
Doing so would make sense, as most of the issues releated to MVNO in Thailand, as discussed in this presentation would need an
update or be removed. We are aware that NBTC is very keen on licenses in order to collect fees, and we therefor suggest a solution,
where NBTC could maintain a very simple MVNO and MVNA license scheme, purely for the sake of collecting its license fees.
 Copyright 2017 Yozzo Co.,Ltd. All Rights Reserved.

DISCLAIMER
Some statements made in this material are forward-looking statements with the relevant assumptions, which are subject to various risks and
uncertainties. These include statements with respect to corporate plans, strategies and beliefs and other statements that are not historical
facts. These statements can be identified by the use of forward-looking terminology such as may, will, expect, anticipate, intend,
estimate, continue plan or other similar words. The statements are based on our assumptions and beliefs in light of the information
currently available to us. These assumptions involve risks and uncertainties which may cause the actual results, performance or achievements to
be materially different from any future results, performance or achievements expressed or implied by such forward-looking statements. Please
note that the company and executives/staff do not control and cannot guarantee the relevance, timeliness, or accuracy of these statements.

Presentation by Yozzo Co.,Ltd. www.yozzo.com March 2016