In its response to the BEREC consultation on its draft report on the Internet of Things (IoT), the GSMA called for the establishment of a predictable and consistent spectrum policy environment to enable this nascent industry to grow in Europe. International spectrum harmonisation is essential for IoT services as it enables providers to gain economies of scale and offer cost-effective propositions. The availability of suitable spectrum, particularly in bands below 1GHz, will be required to provide broad coverage, while the use of licensed spectrum will be essential to guarantee the quality of service for IoT applications.
It is important that BEREC recognises the global nature of many IoT services. Users often require global distribution coverage and managed platforms both to keep costs down and ensure the provision of consistent global services. The GSMA believes regulatory action should not mandate or promote a specific provisioning model, so that all parties have the flexibility to select a model that best suits their needs.
- For numbering, flexibility is essential as different services or M2M users may have different requirements. Both extra territorial and international global numbers are being used to deploy IoT connected services. European regulators should refrain from introducing any undue restriction or administrative barriers related to the assignment and use of numbering resources, which would act as a barrier to the development of a pan-European IoT market.
- Connectivity also needs a flexible approach. Although permanent roaming is one of the viable connectivity models to facilitate the creation of the IoT market in Europe, the optimum deployment model will depend on a number of factors, such as the needs of the mobile network operator, the IoT service provider and the end-user, the scale and geographical footprint of the deployment, the type of IoT application, the device lifetime, its accessibility and the bandwidth requirements.
- For switching providers, any relaxation of the current mobile network codes policies should be carefully assessed in light of its costs, and its technical and logistical complexities. The GSMA believes that its specification for remote provisioning of Embedded SIMs is both efficient and cost-effective to implement.
- On privacy, the GSMA believes the current framework needs to be updated to achieve legal certainty for European consumers and a level playing field for all IoT players irrespective of sector and geographic location. The European Privacy Directive needs to be reviewed to ensure that the same protection applies to the same services in a technology-neutral way.
The full response can be found here.