1.
ISSUES IN THAILAND
…AND HOW TO
SOLVE THEM
ยุคของการเปลี่ยนแปลงในธุรกิจโทรคมนาคม
งานวิศวกรรมแห่งชาติ 2560
UPDATE TO THE PRESENTATION AT
PRESENTATION BY
ALLAN RASMUSSEN

2.
THAILAND’S TELECOM MARKET – AN UNLEVEL PLAYING FIELD
www.yozzo.com
MOBILE OPERATORS PLAYING FIELD MVNO’S PLAYING FIELD
Without some form of regulatory measures and changes as described in this presentation, Thailand’s 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.

3.
MVNO’S IN THAILAND – WHY IT FAILED
In 2009 five MVNO’s where given a license by the telecom regulator NBTC to operate as MVNO’s on the state enterprise telecom operator TOT
AS OF JANUARY 2018 ONLY
2 MVNO ARE LEFT
i-Kool 3G (Loxley) & Buzzme (formerly IEC3G)
UNLEVEL PLAYING FIELD – (UNRESOLVED)
POOR PLANNING AND EXECUTION
LEGACY SYSTEMS AND RED-TAPE
INSUFFICIENT NETWORK CAPACITY AT LAUNCH
INSUFFICIENT MVNO EXPERIENCE AND QUALITY
POOR MVNO CONTRACTS AND REGULATION
www.yozzo.com
THE FIRST MVNO’S IN THAILAND FAILED BECAUSE OF THE FOLLOWING REASONS

4.
THAILAND’S “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.”

5.
WHAT HAS THE REGULATOR NBTC DONE ABOUT IT?
www.yozzo.com
Pronoun
not anything; no single thing.
Adjective
having no prospect of progress; of no value

6.
BUT CONTINUES TO SELL MVNO LICENSES
54COMPANIESHAVE OBTAINED A MVNO LICENSE IN THAILAND
ONLY 9 HAVE LAUNCHED – 6 ARE STILL ALIVE
www.yozzo.com
MVNO LICENSES ISSUED IN THAILAND AS OF APRIL 2018

7.
BEHIND THE NUMBERS
www.yozzo.com
1/3OFTHE COMPANIES
WHO HAVE OBTAINED A MVNO LICENSE IN THAILAND
HAVE FOREIGN INVESTMENT/SHAREHOLDERS
APPROXIMATELY

8.
SOME OF THE NAMES BEHIND THE MVNO LICENSES
www.yozzo.com
• SB Telecom (Thailand) Co., Ltd. - Softbank
• Mobile Innovation Co., Ltd. - NTT DoCoMo
• NTT Comm. (Thailand) Co., Ltd. - NTT
• VM Digital (Thailand) Co., Ltd. - Axiata
• BT Siam Co., Ltd. - British Telecom
• Tune Talk (Thailand) Co., Ltd.- Celcom
• Lyca Mobile (Thailand) Co., Ltd. - Lycamobile
• J-Communications Service Co., Ltd. - KCS Japan
• Tesco Mobile (Thailand) Co., Ltd. – Tesco Mobile
• Advanced Wireless Network Co., Ltd. - AWN (AIS)
• Advanced Info Service (AIS) PCL. - AIS
• UIH Co., Ltd. - DTAC founder/Chairman
• Acumen Co., Ltd. - JASMINE
• Real Move Co., Ltd. - TRUE
• Loxley PCL - LOXLEY

9.
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
• 1000+ INDEPENDENT MVNOS WORLDWIDE
• MVNOS INCREASED 70% BETWEEN 2010 AND 2015
• 73 COUNTRIES HAVE MVNOS IN OPERATION
• MVNOS ACCOUNT FOR 14% OF THE TOTAL EU MARKET
• EUROPE IS HOME TO: 600 MVNOS, APAC: 140, US: 111
• 1 OUT OF 10 PEOPLE IN AUSTRALIA IS A MVNO CUSTOMER
TODAY, MVNOS HAVE REACHED 214 MILLION USERS WORLDWIDE, AND IS ESTIMATED TO GROW TO 300 MILLION USERS AND A $70 BILLION VALUE IN 2020
Ovum predicts that nearly 24% of all new subscriber connections over the
next 5 years will come from MVNO subscribers. Although the current
market represents less than 10% of these connections, they expect it triple
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
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.
Source IDC Thailand
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 world’s fastest growing MVNO sector, even more than the
highly competitive MVNO markets of Europe and North America.
Grand View Research
www.yozzo.com

10.
…AND HAVE DELIVERED
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

11.
Meanwhile back in Thailand…
www.yozzo.com

12.
THAILAND’S TELECOM ECOSYSTEM – THE MOBILE NETWORK OPERATORS
THE MOBILE NETWORK OPERATORS
www.yozzo.com
STATE ENTERPRISE STATE ENTERPRISE
AIS, DTAC AND TRUE + THE TWO STATE ENTERPRISE OPERATORS: CAT TELECOM AND TOT

13.
THAILAND’S TELECOM ECOSYSTEM – THE TELECOM REGULATOR
THE NATIONAL BROADCAST AND TELECOM COMMISION (NBTC)
www.yozzo.com
STATE ENTERPRISE STATE ENTERPRISE
900MHz
1800MHz
2100MHz
900MHz
1800MHz
2100MHz
850MHz
1800MHz
2100MHz
850MHz
1800MHz
470MHz
1500MHz
2100MHz
2300MHz
IS IN CHARGE OF SPECTRUM, LICENSES AND REGULATION

14.
THAILAND’S TELECOM ECOSYSTEM - SPECTRUM CAPACITY TO MVNO’S
www.yozzo.com
MVNO
10% 10%10%
STATE ENTERPRISE STATE ENTERPRISE
900MHz, 1800MHz & 2100MHz SPECTRUM LICENSES
STATES 10% OF THE CAPACITY MUST GO TO MVNO’S
900MHz
1800MHz
2100MHz
900MHz
1800MHz
2100MHz
850MHz
1800MHz
2100MHz
850MHz
1800MHz
470MHz
1500MHz
2100MHz
2300MHz

15.
HOWEVER IT IS ONLY CAT TELECOM (850MHz) AND TOT (2100/2300MHz) WHO HOST MVNO’S
www.yozzo.com
MVNO
STATE ENTERPRISE STATE ENTERPRISE
900MHz
1800MHz
2100MHz
900MHz
1800MHz
2100MHz
850MHz
1800MHz
2100MHz
850MHz
1800MHz
470MHz
1500MHz
2100MHz
2300MHz
900MHz, 1800MHz & 2100MHz SPECTRUM LICENSES
STATES 10% OF THE CAPACITY MUST GO TO MVNO’S

16.
HOW MVNO’S CONNECT 1 OF 2
www.yozzo.com
MNO MVNA
MVNO
MNO
The MVNO enters into an agreement with the MNO to obtain access to airtime at
wholesale rates, and then sets its own retail price and service. The MVNO either has
to invest in its own telecom operational systems or employ the services of a MVNE.
A MVNA is an entity, who buys large bulk of airtime from the MNO, and then
wholesale it to several MVNOs (Economies of scale). The MVNOs buys the
airtime from the MVNA and sets its own retail price and service to end-users.
MVNO’S CAN CONNECT TO MNO’S DIRECTLY MVNO’S CAN CONNECT TO MNO’S THROUGH A MVNA
MVNO MVNO
MVNO

17.
HOW MVNO’S CONNECT 2 OF 2
www.yozzo.com
MVNE
The MVNE provides infrastructure and services to both the MNO and MVNOs,
which enables MVNOs to offer their services on the MNOs network. The MVNE
provides services, such as billing, product setup, service delivery, customer care,
fraud management, reporting, sale platforms, device and SIM management, etc.
MVNA/MVNE
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 guidance during launch and operation as well as value added services.
MVNO’S CAN CONNECT TO MNO’S THROUGH A MVNA/MVNEMVNO’S CAN CONNECT TO MNO’S THROUGH A MVNE
MNO MNO
MVNO
MVNO
MVNO
MVNO
MVNO

18.
PROBLEM #1 IN THAILAND
THE MNO WALL
www.yozzo.com

19.
THE MNO WALL OF THAILAND www.yozzo.com
Somehow, and for some reason, none of the three MNOs AIS, TRUE or DTAC has had any
MVNOs operating on their networks, since the introduction of MVNOs in Thailand in 2009
NO
MVNO’S

20.
DESPITE THE MVNO CRITERIA AND CAPACITY ON THE 2100MHz LICENSES
Prior to Thailand's 2100 MHz 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
www.yozzo.com
2100 MHz 2100 MHz 2100 MHz

21.
AND DESPITE THE MVNO CRITERIA AND CAPACITY ON THE 900MHz & 1800MHz LICENSES
As with the 2100 MHz spectrum, the NBTC also added a MVNO clause
in the terms for the 900 MHz and the 1800MHz licenses (2015/2016)
(1) The Licensee shall comply with the Commission’s Notification Regarding Mobile Virtual Network Operator Service 2013.
(2) The Licensee shall provide telecommunications network service at least 10 percent of its network’s capacity to MVNO(s)
that is/are not the connected person(s) with any licensee under this Notification, upon receiving such service request.
www.yozzo.com
900 MHz 1800 MHz 900 MHz 1800 MHz

22.
Yet, no MVNO’s
have launched on
AIS, DTAC or TRUE
www.yozzo.com

23.
HOWEVER, ALL THREE MNO’S HAVE LAUNCHED THEIR OWN MVNO’S ON CAT AND TOT
www.yozzo.com
TRUE subsidary
TrueMove is a MVNO
on CAT’s 850MHz
AIS subsidary
SBN is a MVNO
on TOT’s 2100MHz
DTAC subsidary
DTN is a MVNO
on TOT’s 2300MHz

24.
THE MNO WALL SOLUTION
www.yozzo.com

25.
www.yozzo.com
“THEN OPEN THIS GATE - TEAR DOWN THIS WALL”
Dear NBTC, if you seek (with the words from your own strategy statement) to manage spectrum allocation efficiently, Create equality
in communication infrastructure access and digital opportunity, develop competition, fairness and efficiency in communication
resource management toward Thailand's digital community and support and promote innovation and networking…
THE MNO WALL SOLUTION

26.
THE MNO WALL SOLUTION
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.
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.
www.yozzo.com

27.
NO MVNO = NO NEW LICENSE
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
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.
THE MNO WALL SOLUTION

28.
PROBLEM #2 IN THAILAND
NO FULL MVNO
www.yozzo.com

29.
NO FULL MVNO’S ALLOWED IN THAILAND = NO CONTROL OF THEIR OWN BUSINESS
www.yozzo.com
ELEMENTS / LICENSE TYPES FULL MVNO MEDIUM MVNO THIN MVNO MVNA
SPECTRUM N/A No No No
NETWORK ELEMENTS
SWITCHING AND DATA NETWORK
BTS/Node B N/A No No No
BSC/RNC N/A No No No
MSC/GMSC N/A No No No
SGSN N/A No No No
GGSN N/A No No No
SUBSCRIBER REGISTRATION, VAS,
INTERNET, APPLICATION PLATFORMS
HLR/AUC/EIR N/A No No No
Voice Mail N/A Yes No Yes
SMSC N/A Yes No Yes
VAS N/A Yes No Yes
IN N/A Yes No Yes
IP Router N/A Yes No Yes
RETAIL ELEMENT
Billing N/A Yes Yes Yes
Customer Care N/A Yes Yes Yes
Customer Ownership N/A Yes Yes Yes
Tariff & Product Development N/A Yes Yes Yes
Brand visibility to end user N/A Yes Yes Yes
Retail sale N/A Yes Yes Yes
SIM BRANDING N/A Yes Yes Yes
This table from the NBTC shows which elements are allowed and not in Thailand for MVNA’s and MVNO’s

30.
FULL MVNO = CONTROL AND FLEXIBILITY TO PROVIDE INNOVATIVE SERVICES
www.yozzo.com
ELEMENT FUNCTION ADVANTAGE TO FULL MVNO
Mobile Switching Centre
• Controls call routing
• Generates usage information
• Ability to have independent wholesale relationships
for voice / SMS routing
Serving GPRS Support Node
• Handles all packet switched data within the
network, i.e. the mobility management and
authentication of the users. Charging Functions
• Location information (current cell, current VLR) and
user profiles (IMSI, addresses)
• Session Management
• Authentication and Identity Check
Gateway GPRS Support Node • Manages subscriber access to Internet network
• Map and control internet gateways
• Monitor / control data usage
Home Location Register
• Registers SIM cards
• Stores subscriber information and privileges
• Maps internet access point to each subscriber
• Shares subscriber information when roaming
• Own dedicated IMSI series, Allocate special numbers,
activate / deactivate services like SMS, outgoing
calls, roaming, international calling etc.
Management of internet AP
MSC
SGSN
GGSN
HLR
A Full MVNO has complete control over its own business, SIMs, customers and services due to certain core network elements such as:
Full MVNO’s can:
• Have their own roaming and interconnect agreements with other MNOs.
• Gain insights into customer or machine (M2M/IoT) profile.
• Create ‘stickiness’ with customers, where the customer will be under greater control of the MVNO.
• Offer a fixed line convergence proposition, where technical integration may be important.

31.
AS WELL AS TACKLING DIVERSE, URGENT AND SIMULTANEOUS DEMANDS ON A HOURLY BASIS
 Travel & Leisure MVNO needs to urgently
resolve customer billing disputes before start
of Songkran holiday season tomorrow
 Ethnic MVNO wants to launch
mothers day promotions before
competitor launches its promotions
 OTT MVNO wants to launch zero rating service on videos from
its own portfolio to compete in the market against HBO, Netflix
 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
1
2
4
6
 Retail MVNO wants to provide extra
bonus points in loyalty program to drive
sales this weekend
 Retail MVNO wants to access its user usage
data) to better address the needs and wants
of its own customers
35
MVNO
MVNO
MVNO
MVNO
MVNO
MVNO
www.yozzo.com

32.
10 KEY DRIVERS FOR FULL MVNO
www.yozzo.com
❶ Ownership of the subscriber's mobile phone number
❷ Collection of inbound termination rates
❸ Deliver specific IoT/M2M Solutions
❹ Negotiation of own roaming rates
❺ Create stickiness – reduce churn
❻ Greater technical independence
❼ Access to network intelligence
❽ Ability to monitor data usage
❾ Increased negotiation power
❿ Easier to switch host MNO
INCREASING FOCUS
ON DIFFERENTIATION,
SEGMENTATION AND
CUSTOMER LOYALTY
A FULL MVNO DELIVER LONGER
TERM VALUE TO THE MNO

33.
MVNO POSITIONING
LOW HIGHPRICING
SERVICEOFFERING
”No frills”
MVNO’s
MVNO’s based
on convinience
Traditional
Mobile Operators
MVNO’s based on
value addition
INNOVATIVE
IoT/M2M
MVNO’s
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 service offerings in the market
www.yozzo.com

34.
NOT ALLOWING FULL MVNO KILLS INNOVATION AND CREATES AN UNLEVEL PLAYING FIELD
LOW HIGHPRICING
SERVICEOFFERING
INNOVATIVE
www.yozzo.com
The MVNOs will not be able to 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

35.
THAILAND vs. SINGAPORE
4 - 0
Let’s 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
EXAMPLE TODAY www.yozzo.com

36.
IN THAILAND TODAY
WEEK 1 WEEK 3 MONTH ? MONTH ?
Fax your request
to the MNO
Present your case at a
meeting with the MNO
Internal meeting at the
MNO to approve or not
Wait for result
This is how it ”works” today in Thailand if MVNO’s want to introduce new promotions, service - or tackle issues
www.yozzo.com

37.
…Meanwhile Thailand will have
lost to another country in both
football and innovation
www.yozzo.comEXAMPLE TODAY

38.
HOW COME OPERATOR’S MVNO SUBSIDIARIES ARE ALLOWED TO OPERATE AS FULL MVNO’S?
www.yozzo.com
TRUE subsidary TrueMove
operates as a FULL MVNO
on CAT’s 850MHz
AIS subsidary SBN
operates as a FULL MVNO
on TOT’s 2100MHz
DTAC subsidary DTN
operates as a FULL MVNO
on TOT’s 2300MHz
LINE MOBILE operates
as a FULL MVNO

39.
TRUE SUBSIDARY REALMOVE MVNO SETUP ON CAT TELECOM 850MHz
www.yozzo.com
BFKT MVNO REALMOVE
BFKT builds and
operates the network
infrastructure
❷
CAT Telecom leases the
equipment from BFKT
15,000 base stations
❸
TRUE
subsidiary
TRUE
subsidiary
CAT resells 80% of the
network capacity to
MVNO RealMove,
leaving 20% to CAT
itself and its MVNOs
❹
CAT Telecom’s own
retail service MY CAT
1,9 mio subscribers
Total remaining network capacity to
MVNOs ~2.3 mio subscribers
❺
❻
A new 4G roaming deal between CAT/True Move, will see True pay a
rental fee of THB 4.1 bn in cash to CAT within 8 years for the use of CAT’s
850MHz spectrum, and a barter deal (valued at THB 5.2 bn) giving CAT
access to some of True’s 4G network on 1800/2100MHz within 10 years.
According to True’s conditions, the 4G roaming agreement is exclusively
for CAT, i.e. none the MVNOs will be able to use it.
❼
CAT outsource network
operations and network
management to BFKT
❶

40.
AIS SUBSIDARY SBN MVNO SETUP ON TOT 2100MHz
www.yozzo.com
TOT outsource
network build and
management to SBN
❶
SBN builds and
operates the network
infrastructure
TOT will be able to use an
additional 15,000 base station
bringing the total to 20,520
❸
AIS
SUBSIDIARY
TOT resells 80%
network capacity from
the 20,320 base station
to the MVNO SBN
3G/4G Base stations
❺
15,000
❹
❷
In September 2016, TOT and AWN, a
subsidiary of AIS, signed a 6 month trial
contract where AWN would roam on TOT’s
2100MHz network.
Now a permanent deal, agreed and
approved by relevant agencies, AWN has
added 15,000 base stations to TOT’s
existing 5,520 bringing the total to 20.520.
AWN purchase 80% on a wholesale/resale
basis, of the total bandwidth capacity to
serve its own subscribers, and pay TOT an
annual fee of THB 3.9 billion. In June 2017
AWN was switched to be Super Broadband
Network (SBN) another subsidiary of AIS.
TOT will use parts of the remaining 20% capacity
for TOT and wholesale the rest to MVNOs.
20,520
Total 3G/G base stations
10% network
capacity to TOT
10% 3G/4G network capacity
to MVNOs on TOT ❻
SBN

41.
DTAC AND SUBSIDARY TELEASSET AND DTN MVNO SETUP ON TOT 2300MHz
www.yozzo.com
TeleAssets builds but
may not operates the
network infrastructure
❷
TOT leases the
equipment from
TeleAssets
❸
DTAC
SUBSIDIARY
DTAC SUBSIDIARY
DTAC TriNet Network (DTN)
Year 1: 1,769
Year 2: 8,455
Year 3: 14,994
Year 4: 20,367
Year 5: 21,217
Base stations
TOT Pcl is the 3rd largest shareholder in DTAC with 5.58% shares
TOT selected DTAC, as its partner to deploy 4G LTE
services using the 64MHz TOT was given by NBTC on
the 2300MHz band. The proposal is a copy of the
TRUE/CAT 850MHz setup, and involves DTAC’s wholly
owned subsidiary TriNet purchasing 60% of TOT’s
capacity for a fixed annual payment of THB 4.5 billion.
TOT outsource
network build to
TeleAssets
❶
❹
TeleAsset
20% network
capacity to TOT
20% network capacity to
MVNOs on TOT ❻
❺
TOT resells 60% of the
network capacity to
MVNO DTN, leaving
40% to TOT itself
and its MVNOs
MVNO DTN

42.
THE SOLUTION
www.yozzo.com
Allow Full MVNO’s to level the playing field, foster innovation and
competition - for the benefit of the consumers and Thailand 4.0

43.
PROBLEM #3 IN THAILAND
DOUBLE / TRIPLE LICENSE FEE
www.yozzo.com

44.
UNFAIR DOUBLE LICENSE FEE HURTING THE MVNO AND CONSUMERS
MNO
MVNO License
Fee 1.5%
Voice Call
Incl Fee
THB 106,57
The operator pays NBTC 1.50% of revenue in license
fee + 3.50% of annual revenue in USO fee - Total 5%
Example:
The operator sells THB 100 worth of voice calling to
the MVNO which is THB 100 + 5% total fee = THB 105
The MVNO also pays NBTC 1.5% of annual revenue in license
fee. It does not pay USO fee, as it dosen’t have spectrum.
Example:
The MVNO sells the now THB 105 worth of voice calling
to customers THB 105 + 1.5% fee = THB 106,57
❶ ❷
1 x 1.5% License Fees (MNO) = 1.5%
1 x 1.5% License Fees (MVNO) = 1.5%
1 x 3.5% USO Fee (MNO) = 3.5%
REGULATOR
Unlevel playing field as the MNO can
sell directly to its customers for just
THB 105 vs. the MVNOs THB 106,57
As the mobile operator and MVNO each have to pay
the license fees of annual revenue, the same mobile
signal (voice/sms/data) ends up having double the
tax, when it ends up at the MVNO and its customers.
❸
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”.
MVNO
1.50% License Fee
3.50% USO Fee
Voice call
incl. Fees
THB 105
Voice call
THB 100
TOTAL
6.5%

45.
UNFAIR TRIPLE LICENSE FEE HURTING THE MVNO, THE MVNA AND CONSUMERS
MNO
MVNO License
Fee 1.5%
Voice Call
Incl Fee
THB 108,17
The operator pays NBTC 1.50% of revenue in license
fee + 3.50% of annual revenue in USO fee - Total 5%
Example:
The operator sells THB 100 worth of voice calling to
the MVNO which is THB 100 + 5% total fee = THB 105
The MVNO also pays NBTC 1.5%
of annual revenue in license fee.
Example:
The MVNO sells the now THB 105 worth of voice calling
to customers THB 105 + 1.5% fee = THB 106,57
❶
TOTAL
8%
1 x 1.5% License Fees (MNO) = 1.5%
1 x 1.5% License Fees (MVNA) = 1.5%
1 x 1.5% License Fees (MVNO) = 1.5%
1 x 3.5% USO Fee (MNO) = 3.5%
REGULATOR
As the MNO, MVNA and MVNO each have
to pay the license fee, the same mobile
signal ends up having triple tax, when it
arrives at the MVNOs and the consumers
❸
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”.
MVNO
1.50% License Fee
3.50% USO Fee
Voice call
incl. Fees
THB 106,57
Voice call
THB 100
MVNA
Voice call
incl. Fees
THB 105
MVNO License
Fee 1.5%
Unlevel playing field as the
MNO can sell directly to its
customers for just THB 105
vs. the MVNOs THB 108,17
The MVNA also pays the NBTC 1.5%
of annual revenue in license fee
Example:
The MVNA resells the now THB 105 voice calling to
the MVNO. I.e. THB 1,05 + 1.5% fee = THB 106,57
❷ ❸

46.
MVNO’S MAKES ITS BUSINESS ON MARGINS
MVNO
VERSUS
www.yozzo.com
MVNO’s makes its profit on the small margins between the
costs of purchasing airtime in wholesale from the MNO (or
MVNA) and the retail price. They need to operate a lean
and flexible setup, with low operation costs (small staff,
low office rentals, cheap distribution) as every baht counts.
The unfair double, and triple taxation changes the
timeline significantly for the MVNO to reach financial
breakeven – if ever - given that the current fee structure
setup not only adds additional costs, but also provides
the mobile operators with an unfair pricing advantage

47.
THE SOLUTION
www.yozzo.com
Let the MNO and MVNO (and MVNA) split
the 1.5% license fee like we do with VAT
i.e. MNO 0.75% and MVNO 0.75% = 1.5%

48.
PROBLEM #4 IN THAILAND
UNFAIR ADVANTAGE RESULTING IN ONE
PLAYER BEING ABLE TO PROVIDE LOWER PRICES
www.yozzo.com

49.
MVNO OR NOT
www.yozzo.com
850MHz
1800MHz
2100MHz
DTAC
SUBSCRIBERS
LINE
MOBILE
In June 2017, DTAC launched the sub-brand MVNO LINE
MOBILE, and made it available across the 850MHz and
1800MHz network, which is under concession with CAT
Telecom - and DTAC’s own licensed 2100MHz network.
The sub-brand MVNO was launched without a MVNO license.
DTAC claims it is not a MVNO - but that LINE MOBILE (which is
a MVNO in Japan), is a service of DTAC's subsidiary DTN, who
has entered into a brand licensing deal for the rights to use
LINE MOBILE in Thailand, against a nondisclosed royalty fee.
NBTC invited DTAC and LINE to provide information regarding
the setup. NBTC pointed out amendments needed regarding
online SIM registration, marketing and customer support but
allowed LINE MOBILE to continue without a MVNO license.
DTAC and LINE MOBILE insist, that despite LINE MOBILE not
having a MVNO license, there is no unfair advantage and the
country is still receiving full licensing fees from this setup.

50.
IN-HOUSE SUB-BRAND = NO NEED FOR MVNO LICENSE
www.yozzo.com
In 2014, AIS launched a prepaid sub-brand called YOU!
The setup was build from scratch by AIS but with its own YOU!
SIM, branding, design, promotion packages, marketing, etc.
This is a sub-brand build, owned and maintained by AIS under
existing license and as such, it does not need a MVNO license.

51.
BRAND LICENSING AGREEMENT = MVNO LICENSE
www.yozzo.com
Plenty of mobile operators have entered into joint ventures or
brand licensing agreements, where the operator buys access to
use the brand value of an existing brand i.e. brand recognition,
distribution, users/followers etc.
Examples are:
• Australia: MNO Optus and Virgin Mobile
• America: MNO Sprint and Virgin Mobile
Virgin Mobile, is/has been a sub-brand MVNO in Australia,
Canada, Qatar, India, UAE and the US.
Energy drink Red Bull is/has been a sub-brand MVNO in Austria,
Belgium, Hungary, Poland, South Africa and Switzerland.
This is a sub-brand MVNO and as such, it needs a MVNO license.
MNO

52.
MNO/MVNA/MVNO – WHOLESALE AGREEMENTS
www.yozzo.com
MVNO
Agreements
Brand
Licensing
Capacity
based pricing
Retail
Minus
Cost
Plus
Revenue
Share
Commision
based
MVNO MVNO MVNO MVNO MVNO MVNO
Own
Subscribers
Retail
Subscribers Subscribers Subscribers Subscribers Subscribers Subscribers
MNO
LINE MOBILE

53.
TO BE - OR NOT TO BE A MVNO – IT NOT A QUESTION
www.yozzo.com
“Mr Norling intimated that the contract was not exclusive, which suggests
that Line can partner with AIS and TrueMove to provide similar services”.
This remark clearly shows that LINE is a partner and not part of DTAC or
DTN and therefore need a MVNO license to operator on DTAC’s network
https://www.bangkokpost.com/tech/local-news/1331395/dtac-deflects-line-mobile-licence-criticism
In this article published in the Bangkok Post on 26 September 2017, CEO of DTAC,
Lars Norling states why he thinks LINE Mobile does not need a MVNO license
DTAC DEFLECTS LINE MOBILE LICENSE CRITICISM

54.
LINE MOBILE UNFAIR ADVANTAGE
www.yozzo.com
Line Mobile is given the unfair advantage of being able to provide lower prices than rest of the players in the market, as it doesn't have
to shoulder the extra cost of a MVNO licensing fee, and the country is also not benefitting, as it won't receive MVNO licensing fees.
MVNO License
Fee 1.5%
Voice Call
Incl Fee
THB 106,57
DTAC pays NBTC 1.50% of revenue in license fee
+ 3.50% of annual revenue in USO fee - Total 5%
Example:
The operator sells THB 100 worth of voice calling to the
MVNO which is THB 100 + 5% total fee = THB 105
The MVNO also pays NBTC 1.5% of annual revenue in license
fee. It does not pay USO fee, as it dosen’t have spectrum.
Example:
The MVNO sells the now THB 105 worth of voice calling
to customers THB 105 + 1.5% fee = THB 106,57
❶ ❷
1 x 1.5% License Fees (MNO) = 1.5%
1 x 1.5% License Fees (MVNO) = 1.5%
1 x 3.5% USO Fee (MNO) = 3.5%
REGULATOR
Unlevel playing field as LINE Mobilecan
sell directly to its customers for just
THB 105 vs. the MVNOs THB 106,57
As the mobile operator and MVNO each have to pay
the license fees of annual revenue, the same mobile
signal (voice/sms/data) ends up having double the
tax, when it ends up at the MVNO and its customers.
❸
MVNO
1.50% License Fee
3.50% USO Fee
Voice call
incl. Fees
THB 105
Voice call
THB 100
TOTAL
6.5%
LINE
MOBILE
NOW
5%

55.
DTAC AND SUBSIDARY TELEASSET AND DTN MVNO SETUP ON TOT 2300MHz
www.yozzo.com
LINE
MOBILE
If LINE MOBILE connects to DTN, which is a MVNO on TOT’s 2300MHz spectrum
then it must obtain a MVNO license, as the 2300MHz isn't’ DTN’s network but TOT’s

56.
LINE MOBILE WHAT WILL HAPPEN ON 2300MHz
www.yozzo.com
If DTAC allows the LINE Mobile customers to use its new setup on TOT’s 2300MHz, questions is how does the NTBC plan to bill the license
fee. The 2300MHz is the spectrum of TOT and DTN is a MVNO – Will the NBTC allow the MVNO DTN to provide access to LINE Mobile
TOT
MVNO License
Fee 1.5%
Voice Call
Incl Fee
THB 108,17
TOT pays NBTC 1.50% of revenue in license fee + 3.50%
of annual revenue in USO fee - Total 5%
Example:
TOT resell THB 100 worth of voice calling to the
MVNO DTN which is THB 100 + 5% total fee = THB 105
The MVNO also pays NBTC 1.5%
of annual revenue in license fee.
Example:
The MVNO sells the now THB 105 worth of voice calling
to customers THB 105 + 1.5% fee = THB 106,57
❶
TOTAL
8%
1 x 1.5% License Fees (MNO) = 1.5%
1 x 1.5% License Fees (DTN) = 1.5%
1 x 1.5% License Fees (MVNO) = 1.5%
1 x 3.5% USO Fee (MNO) = 3.5%
REGULATOR
As the MNO, MVNA and MVNO each have
to pay the license fee, the same mobile
signal ends up having triple tax, when it
arrives at the MVNOs and the consumers
❸
MVNO
1.50% License Fee
3.50% USO Fee
Voice call
incl. Fees
THB 106,57
Voice call
THB 100
Voice call
incl. Fees
THB 105
MVNO License
Fee 1.5%
Unlevel playing field as the
MVNO can sell directly to its
customers for just THB 106.57
vs. the MVNOs THB 108,17
As a MVNO DTN also pays the NBTC 1.5% of annual
revenue in license fee. LINE Mobile pays nothing
Example:
DTN and LINE Mobile sells the now THB 105 worth of voice
calling to customers I.e. THB 1,05 + 1.5% fee = THB 106,57
❷ ❸
LINE
MOBILE
NOW
6.5%
MVNO DTN

57.
THE SOLUTION
www.yozzo.com
LINE Mobile is a MVNO and must obtain a
MVNO license, pay fees and compete on
the same terms as the rest of the market

58.
PROBLEM #5 IN THAILAND
NBTC ISSUES A LICENSE THAT IS
BOTH AN MVNA AND AN MVNO
www.yozzo.com

59.
NBTC ISSUES A LICENSE THAT IS BOTH AN MVNA AND AN MVNO
www.yozzo.com
MVNO
MVNO
MVNA
OK!
Hello handsome MVNO,
Welcome! I will make
special price just for you!
NBTC wants the MVNO part on the MVNA license to take over
customers, in case the MVNO client goes out of business!!!
NBTC ISSUES A LICENSE THAT IS BOTH AN MVNA AND AN MVNO

60.
COMBINED MVNA/MVNO LICENSE = CONFLICT ON INTEREST
www.yozzo.com
MVNO
MVNA
Three down, five
more to go, and the
world is my oyster
How can you, as a MVNO client, who want to use the service of the MVNA be
sure that it will take care your interest when it is also a competing MVNO?
NBTC ISSUES A LICENSE THAT IS BOTH AN MVNA AND AN MVNO
This will further manifest itself in negotiations of packages, fees, terms and
conditions, as the MVNA will always have more power in any outcome and
be able to control the competition (MVNO clients) = non level playing field.

61.
COMBINED MVNA/MVNO LICENSE
www.yozzo.com
MVNA
This also means that when a MVNA is applying for a license, the NBTC wants the
MVNA to provide written information on call center, customer support, distribution
and marketing plans towards end-users, which the MVNA will never use…
YOU MUST FILL OUT ALL THE BOXES

62.
THE SOLUTION
www.yozzo.com
If the NBTC absolutely have to issue licenses, then there should be one
license for MVNA and another for MVNO. It is two different setups.

63.
PROBLEM #6 IN THAILAND
NO PLANS FOR MVNO’S
GOING OUT OF BUSINESS
www.yozzo.com

64.
THE NUMBER YOU HAVE DIALED IS NO LONGER IN SERVICE
www.yozzo.com
OUT OF BUSINESS
AND THEN WHAT?

65.
NO PLANS FOR MVNO’S GOING OUT OF BUSINESS
IN REAL LIFE X 3
www.yozzo.com
Section 20 of the Telecommunications Act of 2001 stipulates that:
The licensee shall not suspend or terminate the service, in whole or
in part, unless permitted by the Commission under the criteria and
procedures prescribed by the Commission.
And Section 22: The licensee shall, without delay, inform the
Secretary General of the following events: (5) any case that affects,
or may affect, the business operation or the supply of service of the
licensee as prescribed in notification of the Commission.
In case of (5), the licensee shall inform the Secretary General
immediately when the events occur. The Secretary-General shall,
without delay, submit the matter to the Commission after having
been informed. In this regard, the Commission shall have the power
to prescribe certain conditions for the licensee to perform for the
prevention of damages to public interest.
At a meeting on January 17, 2017, at the NBTC commission, TOT
requested guidelines from the NBTC, to suspend the service with
MVNO Mojo3G on grounds that the MVNO had defaulted on
payments to TOT since 2015 but TOT had continued the service.
Despite Section 20 on notifying the NBTC in advanced, the MVNO,
had not submitted such a plan to the NBTC at the time of the
meeting taking place. Instead it was suggested that customers, could
voluntarily transfer to TOT, and that the MVNO must inform the
customers on the suspension of service in order for the customers
to cancel the service, and get remaining funds back.
This is not the first time, and it will not be the last that a MVNO goes
out of business. Prior to Mojo3G, it was MVNO 365 communication,
and in June 2017 the MVNO i-mobile followed suit, but did however
inform the NBTC first. Before approving the exit request, NBTC, TOT
and i-mobile had to figure out how to handle the remaining users.
THE INTENTION

66.
MVNO’S IN THAILAND ARE ALLOWED TO CONNECT TO SEVERAL MNO’S
www.yozzo.com
This provides a dilemma in case the MVNO ends its service.
Which MNO has to take over the MVNO subscribers, CAT or TOT?
MVNO’S IN THAILAND CAN CONNECT TO SEVERAL MNO’S
MVNO
?

67.
MVNO’S IN THAILAND CAN CONNECT TO SEVERAL MNO’S THROUGH SEVERAL MVNA’S
www.yozzo.com
This provides a dilemma in case the MVNO ends its service.
Which MNO has to take over the MVNO subscribers, CAT or TOT?
MVNO’S IN THAILAND CAN CONNECT TO SEVERAL MNO’S THROUGH MVNA’S
MVNO
?
MVNA MVNA

68.
ALL-IN-ONE
www.yozzo.com
• Who owns the numbers – the MVNO or the companies?
• Which MNO has to take over the MVNO subscribers if it closes?
• If a MVNO can wholesale then why do we need a MVNA license?
• Who are the subscribers – The two companies or the companies subscribers?
ONE MVNO, WHO HAS AGREEMENT WITH TWO MNO’S, IS SELLING WHOLESALE TO NON-MVNO’S, WITHOUT A MVNA LICENSE
MVNO
COMPANY COMPANY
The MVNO is selling SIMs and airtime to unlicensed outlets, as well as acting as a MVNA to MVNOs by selling airtime and SIM packages.

69.
www.yozzo.com
1. A protection plan should be part of the MVNO Agreement between the host operator and the MVNO. I.e. The Agreement
shall include provisions covering the expiration, termination or suspension of the Agreement and shall contain an adequate
protection plan for MVNO customers and their payments, including processes and information to subscribers on refund
process, number porting options, and the continuation of uninterrupted services (taken over by the host operator), if the
customer chose not to de-activate, or port out three months after the announcement of service termination.
2. The NBTC should issue a mandatory Code of Practice notification to all new and existing MVNOs and host operators, to
include the amendment to its MVNO agreements mentioned above, as well that both the host operators and the MVNOs
from the date of the notification, are required to, provide mobile number portability services for at least three months after
the date of service stop to allow affected customers to port out their mobile numbers to other service providers.
Ensure subscribers are automatically absorbed by the Host Operator (no end-user action or consent required) if they choose
not to port out, three months after the announcement of service termination.
3. To minimize the impact on various stakeholders, the NBTC should publish a Service Cessation Alert Notice standard sample
format to be used for host operators to notify the NBTC, and one Service Cessation Alert standard sample to be used by
MVNOs to inform the NBTC, affected customers and the public.
THE SOLUTION

70.
SOLUTION: IF A MVNO GOES OUT OF BUSINESS
www.yozzo.com
MVNA
MVNO MVNO MVNO MVNO MVNO
CUSTOMERS

71.
THE HOST MNO HAS TO TAKE OVER THE REMAINING CUSTOMERS
www.yozzo.com
MVNA
MVNO MVNO MVNO MVNO

72.
IF A MVNA GOES OUT OF BUSINESS
www.yozzo.com
MVNA
MVNO MVNO MVNO MVNO MVNO

73.
THE HOST MNO TAKES OVER AND MAKE SURE THE MVNO’S ON THEIR NETWORK CAN CONTINUE
www.yozzo.com
MVNO MVNO MVNO MVNO MVNO

74.
EXAMPLE: SCOPES OF 3 MONTHS TERMINATION PLAN
www.yozzo.com
STAGE 1 STAGE 2 STAGE 3
SERVICE TERMINATION REFUND CONTINUITY OF SERVICE
MVNO issue a notice 3 months
before termination to:
• NBTC
• Host operator (or MVNA)
• Subscribers
Notice shall include:
• Date of termination.
• Refund period for prepaid
customers.
• Service continuity options.
• Contact information.
• MNP process.
MVNO to provide:
• The subscribers with the choice
to port or terminate.
• Refund of unused prepaid
deposit.
• Unused credit transfer to new
service provider.
• Information on MNP.
• Weekly report to NBTC during
the 3 month termination
process.
Refund process to be completed 3
month after service termination
notice.
Main concern for subscribers:
• Continue to have access.
• Able to obtain refund.
Subscribers Service Continuity Plan
• Subscribers who have not yet
ported will automatically
continue to have access.
• MVNO handover HLR and
customer database to host
operator.
• Host operator takes over the
remaining customers.
• Utilization of remaining /
transferred prepaid value.
• Submit final report to NBTC.
PRE-LAUNCH
MVNO provides the NBTC
before service launch with a
notice which include:
• Details and terms regarding
termination of service plan
from the contract with host
operator (or MVNA).

75.
PROBLEM #7 IN THAILAND
BUREAU-CRACY AT NBTC
KILLING INNOVATION
www.yozzo.com

76.
MVNO LICENSE APPLICATION IS IN-CORRECT AND NOT UP-TO-DATE
TERMS AND APPLICATION FOR MVNO IN
THAILAND IS ABOUT 15-YEARS TO OLD
www.yozzo.com
The application seems to be a copy and paste from old
applications and various countries in early 2000’s
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.

77.
LICENSE APPLICATION BUREAU-CRAZY
NBTC OFFICER HAS TO UNDERSTAND & APPROVEFILL-OUT & HAND-IN THE APPLICATION
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.
www.yozzo.com

78.
LICENSE APPLICATION BUREAU-CRAZY
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
www.yozzo.com

79.
LICENSE APPLICATION BUREAU-CRAZY
ONCE APPROVED, THE OFFICER HANDS THE APPLICATION TO A BOARD
WHO HANDS IT TO NBTC’S BOARD FOR APPROVAL AND SIGNATURE
www.yozzo.com

80.
LICENSE APPLICATION BUREAU-CRAZY
THE MVNO LICENSE IS GIVEN BASED ON THE APPROVED AND PROVIDED INFORMATION
I.e. The information given and approved is part of the license – License valid for 5-years
www.yozzo.com

81.
BUREAU-CRACY KILLS INNOVATION AND OPENS FOR CORRUPTION
THE OFFICER BECOMES A SINGLE GATEKEEPER, WHICH OPENS FOR CORRUPTION
There are people who are either
direct employees or have very
close ties with employees at the
NBTC, who provide a service in
which they guarantee you a
license for the price of THB
50,000-100,000.
We are aware of some who have
used the service and has been
awarded the mentioned license.
Question is how many have used
this ”service” and how is it even
possible that this can take place
considering the license approval
process involves several stages
and departments/boards?
The license approval process is
long, slow and non-transparent,
and NBTC will drive you in circles.
This further helps trigger the
interest in ”guaranteed license”
www.yozzo.com
The setup opens a ”backdoor 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 according
to the license (information
provided in the license) and
demand they stop operation – or
solve it with a brown envelope.
SAYNO!
TOCORRUPTION

82.
GETTING A LICENSE WITHOUT AN AGREEMENT
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)
www.yozzo.com

83.
GETTING A LICENSE WITHOUT AN AGREEMENT – HOW?
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 90’s
…and who would buy equipment BEFORE
having an MNO agreement AND a license?
www.yozzo.com

84.
THE SOLUTION
www.yozzo.com
• 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 it’s 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.

85.
Presentation by Yozzo Co.,Ltd.  www.yozzo.com  March 2016
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