Broadband Internet Access from a Mobile Terminal

Transcription

1 Broadband Internet Access from a Mobile Terminal Market Assessment Version January 2014 Prepared for:

2 Version History Version Date Author Changes Distribution Approval /1/2015 Cartesian Final report incorporating UCC feedback UCC T Twinemanzi Confidentiality This document and the information contained herein are private and confidential, and are solely for the use of the Uganda Communications Commission. Copyright The contents of this document are copyright 2015 Cartesian Ltd. All rights reserved. The information contained herein is the property of Cartesian and is provided on condition that it will not be reproduced, copied, lent, or disclosed, directly or indirectly, nor used for any purpose other than that for which it was specifically furnished. Cartesian Ltd. Registered in England and Wales. Registered Number: Registered Office Address: Descartes House, 8 Gate Street, London WC2A 3HP United Kingdom Copyright 2014 Cartesian Ltd. All rights reserved. 1

3 Table of Contents 1. Executive Summary... 5 Overview of market performance... 5 Key findings regarding market structure... 6 SMP assessment conclusions Introduction Definition of the Mobile Broadband Market Assessment of market performance... 8 Service Penetration and Growth... 8 Mobile Broadband Usage Retail Prices Industry Revenue Service Quality Innovation Market Performance Assessment Conclusions Market Structure Assessment Market Concentration Barriers to entry Sunk Costs Economies of Scale Economies of Scope Extent of Vertical Integration Market Structure Assessment Conclusions Market Conduct Assessment Scale and Ability to Access Resources Control of Essential Upstream Inputs Access to Sales and Distribution Channels Transparency of Retail Consumer Information Ease of Consumer Switching Countervailing Buyer Power Evidence of Dynamic Competition Potential for Market Growth Market Conduct Assessment Conclusions Basic Market Conditions Technology Copyright 2014 Cartesian Ltd. All rights reserved. 2

4 Cost Conditions Basic Market Conditions Conclusions Overall Conclusion of SMP Assessment Copyright 2014 Cartesian Ltd. All rights reserved. 3

5 List of Figures Figure 1: Mobile Broadband Subscriptions and Market Share in Uganda by CSP, Figure 2: Mobile Internet Subscriptions in Uganda, Figure 3: Mobile Broadband Penetration in Uganda, Figure 4: Broadband Penetration in Selected African Countries, Figure 5: Forecast of Ugandan W-CDMA and LTE Subscriptions, Figure 6: Uganda Key Demographic data, Figure 7: Handset Average Selling Price (Worldwide in USD), Figure 8: Mobile Broadband Service Pricing in Uganda (in UGX/MB), Figure 9: Selected Voice, SMS and Data Bundles in Uganda, Figure 10: Average mobile broadband price in Selected African Countries (USD/MB), Figure 11: Mobile Revenues in Uganda, Figure 12: Mobile Broadband Market Share in Uganda by Subscriptions, Figure 13: Concentration Level in Uganda for Mobile Broadband (HHI) Figure 14: Financial Results from Multinational CSPs present in Uganda, Figure 15: Technology Framework for Mobile Broadband Figure 16: Spectrum Allocation Status in Uganda (GSM Bands), Q Figure 17: Annual Spectrum Fees in Uganda, Copyright 2014 Cartesian Ltd. All rights reserved. 4

6 1. Executive Summary This document sets out an assessment of whether or not there is effective competition in the market for Broadband Internet Access from a Mobile Terminal within Uganda, ("mobile broadband") particularly whether or not one or more firms hold significant market power (SMP). A firm or group of firms that has SMP has the potential to either increase price above and/or reduce output below a level where there is effective competition. In turn, this would be detrimental to the benefits that consumers could derive from the service compared with a market that has effective competition amongst operators. The mobile broadband market include Internet access from smartphones, tablets and USB modems. For the avoidance of doubt, the market excludes fixed-wireless networks and connections of less than 256kbps. Mobile broadband services are supplied in Uganda by the communications service providers (CSPs): Airtel, MTN, Orange, Sure Telecom, Afrimax and K2. Of these firms: Airtel, MTN, Orange, Sure Telecom and Afrimax are mobile network operators (MNOs); and K2 is a mobile virtual network operator (MVNO) with a wholesale supply agreement with Orange. Overview of market performance Mobile broadband is an important market for Uganda. The service has the potential of reaching the majority of the country s population and represents the primary means of broadband internet access. It has been found that regarding growth and market penetration: Currently, the penetration of mobile broadband is 11.7% of the population, where the penetration of total internet access (fixed and mobile) is 16%; There were 4.1M mobile broadband subscriptions, as measured by the number of active SIMs, at June 2014; and The number of mobile broadband subscriptions has grown by approximately 70% per annum between 2010 and Ovum forecasts that 3G and LTE subscriptions will grow by approximately 40% per annum from 4.1M subscriptions in 2014, reaching 25M subscriptions in The significant historic growth of 70% is encouraging as it suggests that customers are benefiting from internet access. However, these growth rates are off a relatively low base, when compared with the current penetration rates in other African countries. The proportion of the population in Uganda with internet access is 16%, compared with the average for Africa of 21.3%. This is an indicator that there is significant potential for further growth. Our findings regarding the pricing of mobile broadband services are: 1 Source: Ovum, 2014 Copyright 2014 Cartesian Ltd. All rights reserved. 5

7 Smartphones are considered to be prohibitively expensive for most Ugandans; the Average Selling Price of an entry level smartphone is UGX 330,00 (USD 119) which represents more than 20% of the 2013 GDP per capita in the country; Smartphones are falling in price; Airtel has introduced its own-brand smartphone at UGX 183,300 respectively; and, The current average price of mobile broadband usage in Uganda is UGX 28 per MB. This average is within a range of average per MB prices for a selection of countries where Tanzania and Kenya have data prices that are lower than Uganda, and Nigeria and Botswana have prices that are greater than Uganda. The introduction of own-branded smartphones by MTN and Airtel that are priced significantly less than the current average of UGX 330,000, suggests that there is downward pressure on handset prices. This is encouraging as it is expected to make mobile broadband affordable to a larger number of consumers and thus encourage uptake in mobile broadband. Furthermore, as noted above, the average prices for usage is UGX 28 (USD 0.010) per MB, which is within the price range of a benchmark of a selection of countries in Africa. However, we are unable to confirm how the average price has changed over time because of a lack of historical data. Key findings regarding market structure The market for mobile broadband is highly concentrated between Airtel and MTN. Figure 1 summarises the market shares, based on subscriptions in June 2014, of the communication service providers (CSPs) that offer mobile broadband services. Figure 1: Mobile Broadband Subscriptions and Market Share in Uganda by CSP, 2013 Mobile Operator Number of mobile broadband subscriptions Market Share Airtel 2.2M 51% MTN 1.8M 44% Orange 100k 2% Sure Telecom 100k 2% K2 4k <1% Source: UCC The above table highlights that Airtel and MTN have similar market shares, of 51% and 44% respectively. The combined market share of Airtel and MTN is therefore 95%, indicating that mobile broadband in Uganda is a highly concentrated market. The evidence presented in this report indicates that the level of market concentration, as measured by the Herfindahl-Hirschman Index, increased over the 18-month period prior to June Copyright 2014 Cartesian Ltd. All rights reserved. 6

8 Even though market concentration is high and has grown over the 18 months prior to June 2014, between December 2013 and June 2014 MTN lost 13 percentage points in market share, of which Airtel gained 11 percentage points and Sure Telecom gained 2 percentage points. This rapid change in market share, particularly MTN's loss and Airtel's gain suggests that there was competition between these operators during this period. SMP assessment conclusions Our initial finding is that CSPs in the mobile broadband market are neither individually nor collectively/jointly dominant at the present time. Demand for the mobile broadband services has grown rapidly, there appears to be downward pressure in handset price, and usage prices are consistent with international comparators. These factors coupled with the significant shift in market share from MTN to Airtel over the first six months of the 2014 suggest that CSPs did not have SMP during the recent past. The fact that Airtel's and MTN joint market share is 95% and approximately equally distributed between each operator is one indicator of potential joint dominance. However, this is not sufficient in itself to conclude joint dominance. Other structural characteristics that would need to be identified in order to conclude joint dominance include: whether there is an incentive to coordinate; the ability to coordinate; the ability to detect cheating; the ability to enforce compliance; and/or potential market constraints. Airtel s recent market share gains at the expense of MTN suggests that these CSPs have not addressed these structural characteristics required for joint dominance. 2. Introduction The purpose of this document is to set out an assessment of whether or not there is effective competition in the market for broadband Internet access from a mobile terminal within Uganda, ("mobile broadband") particularly whether or not one or more communication service providers (CSPs) have significant market power (SMP). CSPs with SMP have the potential to increase price above, or reduce output below, the competitive level. This implies that customers would not derive the same levels of benefits from mobile broadband as they would if there were effective competition. Therefore, it is important to identify whether or not firms have SMP. If one or more CSPs are found to have SMP, then it may be appropriate to introduce regulatory measures. Properly designed and implemented, regulatory measures can ameliorate SMP and thus enhance market performance and economic efficiency in the relevant market. This assessment commences with a description of the definition of the mobile broadband market. This is followed by an assessment of the market performance focusing on the number of subscriptions, mobile broadband usage, and pricing structure and levels, amongst other factors. Market structure is then examined, which addresses recent developments and the concentration of market shares amongst CSPs. This is followed by an assessment of the conduct of CSPs in the market, and in turn a description of the basic market conditions. Copyright 2014 Cartesian Ltd. All rights reserved. 7

9 This report concludes with our initial overall conclusions regarding this assessment of SMP in the market for mobile broadband with Uganda. 3. Definition of the Mobile Broadband Market The relevant market for mobile broadband is defined in the report prepared by Cartesian, for the Uganda Communications Commission (UCC), Review of Uganda Communications Markets: Relevant Markets Report, dated 29th October 2014 (Relevant Markets Report). The Relevant Markets Report identifies that the mobile broadband market as a priority for the SMP assessment. The key features of the mobile broadband market as defined in the Relevant Markets Report are: The mobile broadband market is a retail market; The product is broadband access to the internet by a mobile device that includes smartphones, tablets and USB modems; The mobile device is connected to a mobile network, which for the avoidance of doubt excludes fixed-wireless networks; The download speed of the internet connection is at least 256kbps; The retail market includes mobile broadband services offered to business and residential customers; and, The geographic scope of the market encompasses the whole of the geographic region of Uganda and does not differentiate between different regions within Uganda. Mobile broadband services are supplied in Uganda by Airtel, MTN, Orange, Sure Telecom, and K2. Of these firms: Airtel, MTN, Orange and Sure Telecom are mobile network operators (MNOs); and K2 is a mobile virtual network operator (MVNO) with a wholesale supply agreement with Orange. 4. Assessment of market performance Service Penetration and Growth Mobile broadband is an important market not only to the country s telecom sector but also to the wider Ugandan economy and society. The service has the potential of reaching the majority of the country s population and represents the primary means of internet access. As of June 2014, there were 4.1M mobile broadband subscriptions in Uganda, representing a penetration of 11.7% of the population. The market has grown from 3.6M in 2013 and 2.6M in 2012 (see Figure 2). These numbers represent a Compound Annual Growth Rate (CAGR ) of approximately 70%. Copyright 2014 Cartesian Ltd. All rights reserved. 8

10 Millions Cartesian: Broadband Internet Access from a Mobile Terminal Figure 2: Mobile Internet Subscriptions in Uganda, Q2010 4Q2011 4Q2012 4Q2013 2Q2014 Source: UCC Fixed broadband take-up is limited, with around 106,900 subscriptions nationwide (June 2014). This represents 3.75% of all internet broadband subscriptions. This due to a number of factors including restricted legacy copper infrastructure and limited last-mile fibre deployments. The penetration of mobile broadband services by population is 11.7%. This share has grown significantly from 7.7% in 2012 (see Figure 3). Figure 3: Mobile Broadband Penetration in Uganda, % 12.0% 10.0% 10.3% 11.7% 8.0% 7.7% 6.0% 4.0% 2.0% 1.8% 2.8% 0.0% Dec-10 Dec-11 Dec-12 Dec-13 Jun-14 Source: UCC, Cartesian Copyright 2014 Cartesian Ltd. All rights reserved. 9

11 With reference to the benchmarks in the table below, the current Ugandan rate in 2013 (10.6%) is higher than Ghana (8.4%) and Tanzania (2.8%), and indeed higher than the African average (7.4%), but it is lower than Kenya (38.7%), and South Africa (45.8%).Ugandan mobile broadband penetration is also lower than in other developing regions such as Latin America (26.4%) and the Middle East (31.5%). 2 This penetration rate is lower than the African average of 21.3%, and far from that of more developed African economies such as Kenya (38%), Nigeria (38%) and South Africa (48.9%). Figure 4: Broadband Penetration in Selected African Countries, Country Mobile Broadband Penetration (% pop) Fixed Broadband Penetration (% pop) Total Broadband Penetration (% pop) Botswana 13.9% 1.1% 15.0% Kenya 38.9% 0.1% 39.0% Nigeria 38.0% 0.0% 38.0% South Africa 45.8% 3.1% 48.9% Uganda 10.3% 0.3% 10.6% Source: ITU, Cartesian This suggests that there is potential for penetration of the service increase substantially. As previously noted, the number of W-CDMA and LTE subscriptions is forecast to represent 79% of total mobile subscriptions (LTE alone will represent 9%), offering a substantial addressable market to CSPs for mobile broadband adoption. 3G and LTE broadband technologies cover just 30% of Uganda s population. 4 There are still significant opportunities to expand coverage beyond Kampala and reach more rural areas and a huge untapped potential amounting to 87% of the country s total population. It is estimated that there will be 26M mobile broadband subscriptions in Uganda by 2019, representing a penetration of 49% of the total population. 5 Ovum forecasts that 3G and LTE subscriptions are predicted to grow annually at 40% ( ) to a total of 25M subscription in 2019 (80% of total mobile subscriptions). 1 Consequently, mobile broadband has the potential to be not only a greater source of revenue for CSPs, but also a significant enabler of the country s national strategy for digital inclusion. 2 Source: Ovum and ITU, Total broadband penetration refers to the sum of total mobile broadband subscriptions and fixed broadband subscriptions over the total population. 4 WiMAX in Uganda uses the d standard. This is considered to be a fixed-wireless technology and it is not included in this market. 5 Source: Ovum, Copyright 2014 Cartesian Ltd. All rights reserved. 10

12 Millions Cartesian: Broadband Internet Access from a Mobile Terminal Figure 5: Forecast of Ugandan W-CDMA and LTE Subscriptions, W-CDMA LTE Source: Ovum The market is growing due to increasing demand for internet access. Since fixed broadband reach is limited, mobile broadband is positioned to be the principal service for Ugandans to connect to the internet. However, there are still factors that may limit this growth: smartphones are still not affordable for most consumers; mobile data network coverage is limited; availability of spectrum is limited; and the electricity grid has limited coverage. Taking each of these factors in turn, smartphones are becoming more affordable. More models are being offered under UGX 277,000, compared with the current average price for a smartphone, which is approximately UGX 330,000. However, these prices need to decrease further for smartphones to become affordable to a larger proportion of the population. W-CDMA and LTE network coverage is still relatively low and focused on large urban centres. There is demand to extend to more rural areas, where the majority of the population lives and great potential for CSPs to grow their customer base. For example, MTN covers only 16% of the country s geography with W-CDMA (GSM network coverage is 71%), and Orange covers approximately 30% of the population. Uganda Telecom s network uses GSM data technologies (GPRS and EDGE) that are not capable of supporting mobile broadband services. Furthermore, it does not have the necessary spectrum to deploy W-CDMA or LTE. Airtel, on the other hand, has spectrum to offer W-CDMA, but not LTE. Another factor that may limit the growth in mobile broadband services is access to electricity. Currently, only 14% of the population is connected to the electricity grid in Uganda. Electricity supply is also unreliable, forcing a significant share of the population to use alternative sources such as diesel. 6 6 Source: World Bank, Copyright 2014 Cartesian Ltd. All rights reserved. 11

13 Of the four factors identified above, service coverage and spectrum are possibly the most significant. Smartphone affordability is a transitory challenge since the scale of device production is increasing globally, and their prices are expected to reduce (see Retail Prices, below, for more detail). In summary, we consider mobile broadband to have significant growth potential over the next five years. The service will be the primary means of internet access in Uganda, since fixed-broadband access will remain limited. However, service coverage and spectrum availability represent two significant challenges to realising this mobile broadband growth potential. Mobile Broadband Usage As the penetration of mobile broadband grows, residential consumers are expected to use mobile broadband to access basic services and applications such as education, banking and healthcare. Mobile broadband will therefore become an increasingly important tool for digital inclusion since fixed internet access is not available to a large portion of the population. There are, however, consumer-related factors that could place a constraint on demand, including consumer income, literacy levels, and information about the potential benefits of internet access. Literacy levels have the potential to limit mobile broadband adoption. Uganda's literacy level, defined as the proportion of people aged who can read and write a short, simple statement on their everyday life, is 73%. This level is slightly higher than the Sub-Saharan average of 71%, but still far from other countries such as Botswana and South Africa (87% and 93%). 7 A lower literacy rate means that fewer people will be able to access internet content and applications, thereby limiting the demand for the service (see Figure 6). Based on the latest available data, business services currently represent less than 1% of total mobile broadband subscriptions. However this figure is likely to under-represent the number of businesses that use mobile broadband. This is because a large portion of businesses in the country have fewer than 10 employees (64% of all businesses), hence many subscribe to residential consumer services which are sufficient for their needs. Business customers use both fixed and mobile broadband. Most of the aforementioned 106,900 fixed broadband connections are for business customers. 8 With the popularization of mobile broadband, businesses will gain access to applications and content that are relevant to their business needs. For example, farmers could use a weather forecast application to start planning the best periods for harvesting. A perceived lack of relevance might also be a barrier to mobile broadband uptake. As with the farmer example above, consumers may need to be educated in services, content and applications that they can access via mobile broadband which are germane to their circumstances. Data access per se might not be appealing to consumers, but by demonstrating content and applications that have relevance to them, CSPs will be able to increase interest, and potentially uptake, of their mobile broadband services. 7 Source: World Bank, Source: Uganda Bureau of Statistics, 2006/2007. Copyright 2014 Cartesian Ltd. All rights reserved. 12

14 Figure 6: Uganda Key Demographic data, 2014 Source: The World Bank Metric Segment Value GDP per capita (in USD) All segments 571 Population All segments 35M Rural population share over total All segments 87% Percentage of population with W- CDMA coverage All Segments 30% 0-14 years 49% years 21% Population distribution years 26% years 2% 65 years and over 2% Literacy (age 15 and over, who can read and write) All segments 73% Retail Prices Despite the various challenges, the demand for mobile broadband services is increasing. As more affordable W-CDMA devices become available and coverage increases, we expect the growth of mobile broadband to continue as new customers are likely to migrate to the service, even if they originally intended to only use mobile for voice services. As noted above, smartphones are considered to be expensive by most Ugandans, with the average selling price of an entry-level smartphone being USD 119 (see Figure 7). This represents 20% of the 2013 GDP per capita. Copyright 2014 Cartesian Ltd. All rights reserved. 13

15 Figure 7: Handset Average Selling Price (Worldwide in USD), Featurephones Core Smartphone Entry Smartphone Super Smartphone Source: Ovum Feature phones will continue to represent the entry point for consumers. Some feature phones support internet access, although such devices have limited capabilities compared to smartphones. However, there are already entry-level smartphones on sale for under USD 100 (UGX 277,000). Airtel is offering its own-brand smartphones for as low as UGX 183,300. These initiatives considerably reduce the smartphone price barriers, offering consumers entry-level devices at very attractive prices. Customers wishing to buy a prepaid mobile broadband subscription currently have three main purchase options in Uganda: Pay As You Go (i.e. usage based with per-mb pricing); in a data bundle; or, in a package including voice, SMS and data. All CSPs have at least one offering of each type. The average price of mobile broadband on a Pay As You Go plan is UGX 663/MB. Sure Telecom has the most expensive price (UGX 1,024/MB) and K2 the cheapest (UGX 512/MB). MTN and Orange have the exact same price (UGX 819/MB), as shown in Figure 8. 9 Average Selling Price (ASP) refers to the average wholesale flow from the operator, distributor or retailer to the device vendor. Please note that ASP does not reflect the device price to the end user as it does not include distribution costs, profit made by different dealers and retailers, or subsidies by the mobile operator. Copyright 2014 Cartesian Ltd. All rights reserved. 14

16 Figure 8: Mobile Broadband Service Pricing in Uganda (in UGX/MB), 2014 Plan Type MTN Airtel Orange K2 Telecom Smile Telecom Sure Telecom Afrimax Pay As You Go , N/A Bundles valid for 24 hours Bundles valid for 1 week Bundles valid for 1 month Bundles valid for 2 months N/A Bundles valid for 3 months N/A Source: CSP websites Pay As You Go prices are significantly more expensive than those included in data bundles. We believe the demand for Pay As You Go data is relatively low, and this is used more by customers who have used up their data bundle allowance and wish to purchase additional usage. Data bundle prices vary according to the amount of data included and the validity period. These can vary from 10MB to be used in 24 hours to 100GB for a 12 month period. MTN and Orange have very similar price strategies for data bundles since both focus on including a large amount of data in the bundle and provide more options for long validity periods. In terms of voice, SMS and data packages, the difference is significant between MTN, Airtel and Orange. The price of MTN voice, SMS and data packages are significantly higher than those from other CSPs. However, MTN plans include considerably more minutes and data. For example, while MTN offers a plan including 350 on-net minutes, 25 off-net minutes, 100 SMS and 1GB of data for UGX 75,000, Orange offers 300 on-net minutes, 15 off-net minutes and 100MB for UGX 15,000 (see Figure 9). Copyright 2014 Cartesian Ltd. All rights reserved. 15

17 Figure 9: Selected Voice, SMS and Data Bundles in Uganda, 2014 Bundle 1 Bundle 2 Bundle 3 Source: CSP websites, Cartesian Services Units MTN Airtel Orange Voice - On-net Minutes Voice - Off-net Minutes SMS - On-net # SMS SMS - Off-net # SMS Internet MB Duration # days Price UGX 18, ,000 Voice - On-net Minutes Voice - Off-net Minutes SMS - On-net # SMS SMS - Off-net # SMS Internet MB 1, Duration # days Price UGX 75,000 1,500 15,000 Voice - On-net Minutes 950-1,000 Voice - Off-net Minutes SMS - On-net # SMS SMS - Off-net # SMS Internet MB 2, ,024 Duration # days Price UGX 150,000 2,500 50,000 Airtel has a different approach for its voice, SMS and data packages. The CSP does not offer on-net minutes, but does include some off-net minutes. Moreover, it does not offer more than 75MB of data in its plans, which is much lower than the MTN and Orange offerings. Airtel is targeting two main types of consumer: those with a low usage profile; and those who are more price-sensitive and prioritize total spending over the cost of each component in the plan. Compared with other African markets, Uganda s mobile broadband prices are lower than Nigeria and Botswana on a per-mb basis, but still higher than Kenya and Tanzania. Botswana is the most expensive in the group with an average price of around USD 0.06/MB (see figure 9). Copyright 2014 Cartesian Ltd. All rights reserved. 16

18 Figure 10: Average mobile broadband price in Selected African Countries 10 (USD/MB), 2014 Tanzania Kenya Uganda Nigeria Botswana Source: CSPs websites, Cartesian In summary, prices in Uganda appear to be competitive and in line with prices in other countries in Africa and internationally. MTN and Orange seem to follow each other s approach to pricing very closely. Whilst Airtel is offering similar Pay As You Go data prices as its peers, its bundles are cheaper as they include a lower data allowance. However, the overall offer and price structure is similar across all CSPs. Industry Revenue Industry revenue generated from mobile broadband by the end of 2014 is forecast to be USD 122M, growing from USD 94M in 2013, and USD 76M in This represents 15% of total mobile revenues (see Figure 11). Over the next five years, the share of revenue from mobile data is forecast to grow significantly as mobile voice revenues decline. 10 The values represent average price per MB of prepaid data bundle tariffs available in that market. Copyright 2014 Cartesian Ltd. All rights reserved. 17

19 U$ Millions Cartesian: Broadband Internet Access from a Mobile Terminal Figure 11: Mobile Revenues in Uganda, ,200 1, Mobile Voice Revenues Mobile Data Revenues Source: Ovum, 2014 Service Quality Innovation The quality of mobile broadband services is normally measured by bandwidth and download speeds, number of disconnections, service coverage and customer complaint rates (e.g. billing issues). In Uganda, mobile broadband quality key performance indicators (KPIs) are not yet included in the regulator s quality report. The report currently focuses on the quality of voice services; however, mobile broadband KPIs are expected to be introduced in the near term. In fact, KPIs on mobile broadband only cover the number of complaints received by each CSP. In the first half of 2014, there were just 12 complaints a remarkably low figure given there are 4.1 million mobile broadband subscriptions. Most complaints were about lower-than-stated download speeds and disconnections prior to the end of their validity period. However, the number of complaints may not give the full picture of service quality in the country. That is, we do not know the number of customers who experienced problems with their services but did not raise a complaint. Consequently, there is a need for greater transparency in terms of the quality of services provided to end customers. To this end, we recommend the UCC start monitoring specific KPIs in its quality report in order to determine where CSPs are not meeting their customers expectations, or whether quality is being affected by abuse of market power. Mobile broadband is a relatively nascent market in Uganda. CSPs are investing in increasing their network coverage, and innovation is focused on have the most advanced technology in the market. For instance Airtel is advertising 3.75G, while Orange and MTN are promoting LTE. For all CSPs, a strong competitive differentiator is to launch services using the most advanced technologies. Copyright 2014 Cartesian Ltd. All rights reserved. 18

20 Market Performance Assessment Conclusions The mobile broadband market shows signs that it is growing rapidly. Evidence indicates that CSPs are competing by investing in technology and that prices are currently in line with international benchmarks. However, there are factors that may limit the future growth in mobile broadband penetration. W- CDMA networks cover only 30% of the population, with most coverage concentrated in large urban centres. In addition, the prices of smartphones are still not affordable for most consumers, preventing broader adoption of mobile broadband services. Furthermore, indicators of mobile broadband service quality are yet to be introduced. Currently the UCC tracks complaints and it is expected other metrics will be added in the near term. 5. Market Structure Assessment Market Concentration Mobile broadband services are supplied in Uganda by Airtel, MTN, Orange, Sure Telecom, Afrimax and K2. Airtel, MTN, Orange and Sure Telecom are mobile network operators (MNOs). K2 is a mobile virtual network operator (MVNO) with a wholesale supply agreement with Orange. The market shares of CSPs in the mobile broadband market as a percentage of subscriptions, measured by active SIMs, is presented in Figure 12. Figure 12: Mobile Broadband Market Share in Uganda by Subscriptions, Source: UCC Copyright 2014 Cartesian Ltd. All rights reserved. 19

21 Airtel is part of Bharti Airtel group with operations in Africa and Asia. In 2014, Airtel had the largest share (51%) of the market. Airtel s acquisition of Warid in 2013 increased its market share from 23% to 40%. Airtel increased its market share by a further 11 percentage points through competition. It appears based on the aggregate data that Airtel s share gains were at the expense of the MTN. MTN is the largest CSP in the market. It is part of the international MTN group, with operations in 22 countries. MTN held a market share of 44% in This represents a decrease of 13 percentage points from In 2014, Orange Uganda was acquired by Africell, an African group with presence also in the Gambia and Sierra Leone. Previously, Orange Uganda had been part of the international Orange S.A. group (formerly known as France Telecom). Orange Uganda s market share decreased by 1 percentage point between 2013 and 2014, and is currently 2%. Sure Telecom Uganda Limited entered the market in early 2014 under the brand name Smart. Sure Telecom is owned by the Aga Khan Fund for Economic Development. Sure Telecom's current market share is 2%. Sure Telecom was able to attract 100,000 subscriptions within approximately six months of operation. Finally, K2 Telecom launched its services in 2013 as the first MVNO in the country, based on wholesale arrangements with Orange. K2 Telecom ended June 2014 with 4,666 subscriptions compared to 3,409 in December The level of market concentration, as measured by the Herfindahl-Hirschman Index (HHI), has been increasing in recent years. The market's HHI is currently 4,561. It has increased from its December 2013 value of 4,104, which indicates that the mobile broadband market has become more concentrated. Although MTN's market share fell from 57% to 44% between 2013 and 2014, the market as a whole has become more concentrated. Airtel s acquisition of Warid is the main the reason for this increase in market concentration. This has resulted in two firms MTN and Airtel holding a combined market share of approximately 95%. 11 Source: UCC and CSPs websites Copyright 2014 Cartesian Ltd. All rights reserved. 20

22 Figure 13: Concentration Level in Uganda for Mobile Broadband (HHI) 12 Current Mobile Broadband HHI HHI in Markets with Moderate Concentration 5,000 4,500 4,000 3,500 3,502 4,104 4,561 3,000 2,500 2,500 2,500 2,500 2,000 1,500 1,000 Dec-12 Dec-13 Jun-14 Source: UCC, Cartesian Orange is deploying its data networks across a large portion of the country s population. In addition, it has quickly started to offer LTE services, giving it a technological advantage over its competitors. Despite this, Orange has experienced a relatively small increase in terms of subscriptions, from around 90,000 in June 2012 to just over 99,000 in June Uganda Telecom, the third largest mobile CSP in the country is significantly behind its competitors as it has not launched a mobile broadband services. Currently, Uganda Telecom is unable to offer 3G (W-CDMA). Its data users therefore rely on older technologies such as GPRS and EDGE. The weakness of its mobile broadband offering reduces Uganda Telecom's ability to compete with the other CSPs. Barriers to entry A key barrier to entry in the mobile broadband market is access to spectrum. For MNOs, spectrum represents a substantial entry barrier in the market. There is limited spectrum available in the market and any possible new CSP entering the market will have to wait until new spectrum ranges become available. In the near-term, spectrum suitable for mobile broadband will be released by the digital switchover of TV broadcasting (expected to be completed by June 2015). Additional spectrum may become released following Airtel s acquisition of Warid. The spectrum available is likely to be in popular ranges such as 900MHz, 1800MHz, 1900MHz and 2.5GHz. In addition, CSPs need access to significant funding and financial resources to be able to cover the significant investment in both RAN and core networks. Moreover, the investment in network is 12 HHI in markets with moderate concentration considers a scenario with four players with equal market shares (25% each). Copyright 2014 Cartesian Ltd. All rights reserved. 21

23 Sunk Costs independent from the consumer demand, which means that CSPs will have these initial high costs even if the usage take up on their network is significantly low. UTL is an example of how network investment and spectrum availability represent significant market entry barrier. UTL offers voice services and low speed data services (i.e. EDGE and GPRS), but it has been unable to launch services using W-CDMA and LTE due to limitations in terms of spectrum and investment capacity. In order to reach their target audience, CSPs will have to build their retail presence by either opening their own channels or partnering with an established retailer. In Uganda, independent retailers have exclusive franchising agreements with established CSPs, which represents a significant barrier to new CSPs to build their retail footprint. Finally, the market requires significant investment in marketing in order to build a new brand and attract customers to buy services. Telecom companies are the biggest spenders in terms of advertising in Uganda, which represent a considerable challenge to small or new CSPs to compete against large marketing budgets. Market entry barriers for MVNOs are different from those of MNOs. Since MVNOs don t require spectrum and network to operate, these CSPs are not required to have a significant upfront cost without starting to grow its customer base. The most significant barrier for MVNO entry is securing a wholesale agreement with a host network. MNOs are often reluctant to provide wholesale access to MVNOs as they view the MVNO as an additional competitor in the retail market. Because of this, even when access is granted, the financial terms may make it difficult for the MVNO to build a viable business. Other costs for an MVNO entrant include the need to invest significantly in marketing to build a new brand and be able to compete against established CSPs, which have already well-known brands. The provision of mobile broadband is characterized by significant sunk costs. Network represents the greatest costs for mobile market entry. In some cases, spectrum can represent a significant sunk costs, but in Uganda prices are fixed and are not considerably high. Network establishment and setup can be divided into access and core networks. The first requires the installation of base stations in different locations to provide service coverage to customers. The second relates to the switching elements of a CSP s network which provide functions such as location identification and authentication. The access portion of the network requires greatest up-front investment. In order for the service to be relevant to customers, the network has to have coverage across important and popular locations. Dues to the mobility characteristics of mobile services, access needs to be available not only where customers reside, but also in areas where customers would normally travel. The recent entry of tower companies into the Ugandan market has allowed CSPs to divest mobile towers, which would previously have been viewed as sunk costs. Base station electronic costs are still considered sunk. CSPs must also invest in backhaul connections in the access network to link the base stations to the core. CSPs may choose to lease backhaul connectivity or build their own using either microwave of Copyright 2014 Cartesian Ltd. All rights reserved. 22

24 fibre links. This will especially be the case in areas where there is no wholesale alternative, or where it is more strategically advantageous to self-supply rather than acquiring wholesale capacity (e.g. large urban centres with high population density). Backhaul is considered a sunk cost where a CSP has to invest in its own infrastructure. This investment can vary depending on which technologies are employed. Microwave will be a cheaper option than fibre, but it suffers significant quality and reach limitations. On the other hand, fibre offers good capacity and quality, but it requires higher investment. In conclusion, there are significant sunk costs related to the provision of mobile broadband services. We believe sunk costs create a considerable investment risk to prospect CSPs entering the market, since it will be more difficult for these companies to find funding and thus increases their cost of capital. Economies of Scale Economies of scale play a significant role in the provision of mobile broadband services. As previously mentioned, CSPs face significant upfront investments and sunk costs that require substantial scale and time to be amortized. Mobile broadband services are characterized by significant fixed costs and relatively low variable costs. Therefore, CSPs with large customer bases will be able to generate better margins than their smaller competitors. In mobile, the cost of the radio access network is driven by two major factors: coverage and capacity. The costs of providing coverage are fixed costs (i.e. there is a fixed cost for a cell site with minimum capacity which cannot be avoided). These costs are therefore subject to scale economics: they can be amortized more widely as demand grows. Once the capacity of the fixed-cost, coverage network is exhausted, CSPs must invest in further capacity. The costs of providing capacity are variable costs (i.e. the cost of capacity upgrades increase with customer demand). The scale economies available in capacity-driven costs are less significant. CSPs that efficiently utilize their network will have a distinct cost advantage over those who have underutilized network capacity. This allows CSPs to compete more effectively on retail prices or to benefit from greater margins. Since network coverage is an important factor in mobile competition, large CSPs will have significant advantage compared to smaller CSPs simply by virtue of the fact that they cover a large portion of the population, making their services available to more potential customers. Significant recurrent fixed costs include personnel expenses, site lease or maintenance, and customer care infrastructure (IT, customer care platform, and personnel). Economies of scale allow a CSP to absorb these overheads with greater facility and improve their margins. MTN and Airtel have clear advantages compared to other smaller CSPs in this regard. Since their subscription base accounts for 4.1M subscriptions (95% of the mobile data market), they can benefit from significantly more economies of scale than the likes of Orange or Sure Telecom. We consider economies of scale to have significant bearing on market power. MTN and Airtel have clear advantages from the size of their customer base and operations. Copyright 2014 Cartesian Ltd. All rights reserved. 23

25 Economies of Scope Economies of scope can provide a CSP with reduced unit costs by combining the provision of two or more services. In the case of mobile broadband, there are a number scenarios which deliver these types of benefits. CSPs offering mobile voice, SMS, mobile broadband, and fixed services can leverage these to reduce upfront investment, decrease recurrent fixed costs, provide service bundles, and apply cross-subsidies. Cost items with significant economies of scope potential include: Radio access network; Core network; Backhaul circuits; Network operations; General and administrative costs; and, Marketing costs. All CSPs in Uganda that provide mobile broadband also offer voice and SMS services. Where the mobile broadband service is offered over W-CDMA networks, all three services are delivered using the same technology. As such, the costs are shared across different business lines (voice and SMS and mobile broadband), thereby reducing the unit cost. In cases which CSPs offer services over different technologies (i.e. GSM, W-CDMA and LTE), there are still costs that can be shared across the diverse services, thus reducing the unit cost to provide mobile broadband services. The same RAN and core network technologies can be used by a CSP to offer both voice and broadband services to allow it to benefit from economies of scope. Modern RANs allow GSM and W-CDMA on the same equipment, and there are newer models that also support LTE. W-CDMA core networks are able to support GSM RAN. It is therefore feasible for CSPs to migrate existing GSM RANs to new W-CDMA and LTE cores. As such, CSPs are able to leverage the investment in new core technologies and benefit from backwards compatibility in order to support GSM, W-CDMA and LTE RANs. A single passive infrastructure deployment can support GSM, W-CDMA and LTE technologies. A single backhaul infrastructure (microwave or leased lines) can support GSM, W-CDMA and LTE RAN technologies for both voice and mobile broadband services. In addition to the economies of scope advantages of network infrastructure, there are also considerable synergies within the CSPs business that can be had. For example, CSPs offering voice and mobile broadband services have shared customer care, marketing and sales functions. If offering fixed and mobile services, CSPs can provide both over the same network. In Uganda, the majority of fixed services are implemented employing fixed-wireless technologies. In most cases, GSM or W-CDMA is used for both fixed and mobile voice. Therefore, CSPs offering W-CDMA can potentially leverage the same technology to offer fixed and mobile broadband services. Copyright 2014 Cartesian Ltd. All rights reserved. 24

26 In terms of fixed and mobile services, CSPs offering both services can benefit in at least two ways. The first one is to offer both fixed and mobile services over the same radio access network (i.e. most fixed lines in Uganda are delivered over fixed-wireless technologies). The second is to use the fixed network to provide connectivity in the mobile backhaul and core network. MTN and UTL are able to benefit from economy of scope since both CSPs have mobile and fixed operations. The two CSPs also offer fixed services using both fibre infrastructure and fixed-wireless networks (i.e. GSM and W-CDMA). Other costs such as backhaul, network operations, some general administrative costs and some marketing costs can also be diluted across fixed and mobile since both services require common infrastructure and organization structure. In some cases a fixed and mobile CSP has invested in fibre infrastructure to offer both direct fixed connectivity (i.e. retail leased lines) or to support its fixed broadband services by offering backhaul infrastructure. This reduces the concerned CSPs reliance on the wholesale market and thus reduce the overall cost to deliver mobile broadband services. In this case, MTN, UTL and Orange have significant benefits due to their fibre infrastructure in several areas within Uganda. These operators are able to leverage their fibre infrastructure in Uganda to provide backhaul for mobile voice and broadband. Extent of Vertical Integration Vertical integration can offer significant benefits for CSPs with operations in more than one market. Integrated CSPs are able to use their own infrastructure to provide essential upstream inputs to their mobile broadband services and reduce the dependency of acquiring these via wholesale. Self-supply is beneficial in situations where a wholesale alternative is either more expensive than sourcing the input internally, or not readily available at all. Integrated CSPs are able to leverage assets from their other operations to reduce costs or simply to have access to specific upstream resources. For example, CSPs require backhaul in several different locations to support their countrywide network. In some regions wholesale leased line is not available, requiring CSPs to either use microwave or deploy fibre infrastructure for backhaul. The ability to manage the quality of upstream inputs is another significant benefit for vertically integrated CSPs. CSPs that already have fibre infrastructure will benefit from not needing to find the additional CapEx to build the network. By the same token, the cost of this fibre network is shared across different services. Self-supply enables CSPs to internalise economies of scale and scope, and to achieve a lower unit cost. However, this is only an efficient alternative if CSPs have sufficient volume, otherwise wholesale would be a less expensive option. In order to provide mobile broadband services, CSPs require a number of essential upstream inputs. Backhaul, international transmission and internet transit are essential resources. All CSPs is Uganda will have a mix of self-supply and wholesale acquisition for backhaul capacity. The decision to use self-supply relies on the wholesale infrastructure available and its capacity in different locations. For example, in regions where there is no fibre infrastructure, CSPs would Copyright 2014 Cartesian Ltd. All rights reserved. 25

27 consider deploying microwave infrastructure for short distance, or fibre infrastructure in case of long-distance or regions with significant demand. MTN, UTL and Orange are currently able to leverage its fibre infrastructure in several locations in the country to serve its backhaul demand. Since these CSPs already has fibre deployments in several regions in the countries, it has the considerable benefit of being able to use this network and avoid extra wholesale costs. MTN also has an extensive network in several countries in Africa and the Middle East, so it is able to leverage its international footprint for international connectivity. As a large, multi-national telecoms group, MTN is likely to have peering agreements with many international ISPs. Although it may still need to purchase internet transit for specific destinations, one would expect that MTN has pre-existing agreements in place. Similarly to MTN, Orange has some fibre infrastructure in the country. It is also a member of an international group, although Africell, the new owner of Orange Uganda has global footprint that is considerably smaller than that of the MTN Group. As such, Orange Uganda is likely to have greater dependence on Internet transit providers in Uganda. UTL has the potential to leverage its fixed assets (including leased lines) when launching mobile broadband services over W-CDMA or LTE. However, the local CSP relies on wholesale inputs for international transmission and internet transit. Airtel does not have a significant fibre deployment in Uganda since it has no presence in the fixedline segment. However, it can leverage its wide operations in Africa, Asia and the Middle East for international transmission and internet transit. Sure Telecom will rely on wholesale for most of its backhaul demand, international transmission and internet transit. Since Orange hosts K2 operations, the MVNO will use Orange infrastructure and agreements for all the wholesale inputs for mobile broadband. Therefore, vertical integration may provide greatest cost advantages to MTN, UTL and Orange. Vertical integration can also pose a competitive threat, as CSPs could potentially use their wholesale operations to impact competitors retail offers through actions such as raising prices or discriminating access to wholesale services. MTN is the largest CSP in the country and it controls several essential inputs to mobile broadband services. This enables MTN to not only internalise the costs for these inputs and benefit from economy of scope, but also to potentially create constraints in wholesale prices since all other CSPs buy wholesale capacity from MTN. As an alternative, CSPs are using either UETCL, NITA or Google dark fibre infrastructure to meet some of their backhaul connectivity demand. This is a viable option for locations where these companies provide infrastructure (UETCL for long trunk routes, and NITA and Google for metropolitan trunk and terminating segments). So we see that vertical integration is a significant factor in the power of firms operating in this market. There is a risk that CSPs could exploit vertical integration to gain competitive advantages in the mobile broadband market. Copyright 2014 Cartesian Ltd. All rights reserved. 26

28 Market Structure Assessment Conclusions The mobile broadband market is highly concentrated, with MTN and Airtel holding more than 95% of total subscriptions. The market has become even more concentrated after Airtel acquired Warid in However, Airtel s recent 11 percentage point gain in market share at the expense of MTN indicates that Airtel is competing aggressively. The extent to which the smaller CSPs are able to compete will depend on their ability to overcome barriers to entry. The fact that Sure Telecom has been able to enter the market and gain 100,000 customers within a year is an encouraging indicator that it at least has addressed these barriers over this period. However, a barrier to entry and expansion that has been identify relates to the limited ability of spectrum, particular for bands required for mobile broadband services. 6. Market Conduct Assessment Scale and Ability to Access Resources Multinational CSPs are able to leverage their scale at group level to support local operations. Benefits to the local operations may include greater purchasing power, easier and lower cost access to capital, access to knowledge and experience from other group companies and greater brand recognition. In some cases group companies may also provide shared services to the local operations, for example a central procurement department or a central team responsible for negotiating roaming agreements with international CSPs. Uganda s mobile broadband market includes three multinational CSPs (MTN, Airtel and Africell - operating under the brand name Orange ). The three multinational CSPs have operations in several markets (including significant presence in Africa), that generate substantial revenues (Figure 14). Figure 14: Financial Results from Multinational CSPs present in Uganda, 2013 CSP Global subscriptions Number of global operations Operations in Africa Global revenues EBTIDA margin Profits after tax MTN 200M USD 11B 43% USD 2.7B Airtel 221M USD 14.7B 31% USD 418M Africell ~12M 4 ~USD 305M Source: CSP financial statements USD 305M (2012) 41% (2012) N/A Africell acquired its operations in Uganda from the Orange Group, towards the end of (Orange Group was formerly known as France Telecom.) In addition to Uganda, Africell has operations in Gambia, Sierra Leone and the Democratic Republic of the Congo. Copyright 2014 Cartesian Ltd. All rights reserved. 27

29 Africell is a much smaller corporation than Orange Group, which may reduce the benefits of vertical integration that Orange previously enjoyed. Arguably, Africell will also have different credit conditions than those of Orange currently has. The market therefore now has two strong international groups: MTN and Airtel, each with significant presence in the African continent. International scale provides some advantage in terms of buyer power, ability to invest and access to human resources compared to the other mobile CSPs. In terms of buyer power, large international groups are able to leverage their global procurement power to benefit from better discounts when acquiring network equipment, IT infrastructure and mobile handsets. Scale allows CSPs to access better mobile devices at lower price than smaller CSPs. International scale can be important in this case since handset purchases are done on a global level rather than on a country basis. For example, MTN offers its own branded devices at very low price. An MTN phone costs as low as UGX 33,300 and UGX 183,300 for a smartphone. These models are among the cheapest devices available in the market. Only MTN, Airtel and Orange (Africell) offer own-brand handsets in the market since they are the only CSPs with significant global scale to negotiate with handset manufacturers. Large CSPs will also benefit when negotiating with wholesale providers. Since wholesale prices vary significantly based on volumes, CSPs with significant demand for wholesale services may have access to lower prices than those with less demand. The global scale of MTN and Airtel can also be expected to provide them with better access to capital than their local counterparts. This can reflect in more investment power or less capital cost when borrowing money. This allow these CSPs to invest in network and coverage at lower cost. Finally, the two multinational CSPs can potentially leverage their knowledge and experience acquired in other operations. This allows MTN and Airtel to quickly bring innovation into its operation in Uganda. Considering whether new entrants have the ability to access the necessary resources, we note that two of the licensees have changed ownership in the last two years: Africell acquired Orange s operations and Sure Telecom was acquired by the Aga Khan Fund for Economic Development. This indicates that there is interest from investors in the sector and that there are international groups with sufficient resources to fund the acquisition of network operators. We also note that market entry is also possible as a MVNO, which avoids the high investments required to deploy a network. In conclusion, we consider scale and ability to access resources to be contributing factors to market power. Moreover, we identified that MTN and Airtel have some advantages compared to other CSPs due to their international scale and network footprint in Africa, the Middle East and Asia. Control of Essential Upstream Inputs The main upstream inputs to mobile broadband are: Passive infrastructure (towers); Copyright 2014 Cartesian Ltd. All rights reserved. 28

30 Wholesale leased lines and dark fibre (backhaul); Internet transit; International transmission. In general, new investment to enable self-supply of these inputs is not economically viable due to the substantial funding requirement and the need to enter and compete in other markets to recover these costs. CSPs that do not already own the facilities to self-provide these inputs must therefore source them on a wholesale basis. The control of these essential inputs is therefore an important consideration in assessing the conduct of firms in the market, particularly where a CSP both controls an input and competes in the retail market. For passive infrastructure, the majority of CSPs in Uganda have divested their towers to the two tower companies in the market, ATC and Eaton Towers. The passive infrastructure market is being reviewed separately for evidence of SMP. Within the mobile calling and SMS market, passive infrastructure would be of interest if access to leased towers was controlled by any of the mobile operators. In 2011, American Tower Corporation ( American Tower ) and MTN Group Limited ( MTN Group ) announced a new joint venture ( ATC Uganda ) to acquire the tower assets of MTN in Uganda. According to the press release, ATC Uganda is to be managed by American Tower and controlled by a holding company of which American Tower will hold a 51% stake and MTN group holds a 49% stake. MTN s investment in ATC Uganda is relevant should MTN have influence over the activities of ATC Uganda. However, we found no evidence that ATC Uganda is acting to foreclose or distort competition in the mobile broadband market. Backhaul from cell sites to the core network is a necessary input to mobile voice and SMS services. CSPs use a mix of microwave and fixed network for backhaul, depending on the location of the cell site, distance and availability of fixed network infrastructure. Microwave links are provided through self-supply. In regions where CSPs need fixed infrastructure, they can build their own fibre or copper network or they can buy wholesale leased line capacity. The investment in fibre infrastructure only makes sense for CSPs using the network for additional purposes to backhaul (i.e. fixed broadband offers), since backhaul alone does not justify the considerable investment cost of fibre. MTN, Orange and UTL have their own fixed infrastructure and the three CSPs offer wholesale leased line capacity. These operators are therefore vertically integrated. At the time of writing, the leased line market has not been formally assessed for SMP. However, we found no evidence that MTN, UTL and Orange are denying access to their wholesale inputs to other CSPs. There are also alternative providers in Uganda offering dark fibre. UETCL, NITA and Google offer dark fibre infrastructure in the wholesale market for long distances (i.e. UETCL and NITA) or reach in metropolitan areas (i.e. Google through C-Squared). CSPs are able to use dark fibre network to serve their demand for backhaul capacity. Internet transit and international transmission is a more competitive market including a number of global carriers and submarine cable companies. Therefore, the market does not rely on MTN and Orange, not representing any competitive constrain to retail mobile broadband offer. Copyright 2014 Cartesian Ltd. All rights reserved. 29

31 Control of essential upstream inputs generates three main competitive issues in the retail market: Access discrimination; Quality control (different quality between services upstream used internally and those offered as a wholesale input); and, Margin squeeze. Vertically integrated CSPs are able to deny or restrict access to other CSPs in a way to impact the competition at the retail level. Without access to essential upstream inputs, CSPs are not able to offer the retail services or will have to invest significantly in building infrastructure to be able to self-supply. However, there is no evidence that MTN, UTL and Orange are denying access to their wholesale inputs to other CSPs. Another potential issue is when integrated CSPs offer upstream inputs with lower quality than those used internally. This will impact the quality of the competition retail mobile access, voice and SMS services offering integrated CSPs a superior position in the retail market. Nevertheless, there is no evidence of quality issues or differences in the upstream inputs offered in the market. Finally, an integrated CSP may set the price of an essential wholesale input at a level which does not permit competitors in a downstream retail market to profitably meet the integrated CSP s retail pricing. This situation is termed margin squeeze. Again, there is no evidence of this behaviour in the mobile broadband market. Access to Sales and Distribution Channels The telecom retail structure in Uganda is mostly based on exclusive franchising agreements with CSPs, and independent agents who work either with those independent retailers or directly with the CSPs. In addition, some CSPs have also their own retail presence. Mobile broadband, mobile access, calls, SMS and handsets are usually all offered by the sales channels since these products and services can be bundled. Independent sales agents partner with retail dealers to sell the products and services in the various districts in Uganda. For example, Nilecom has over 5,000 agents. Retail outlets are normally established in large urban centres. Most telecoms sales are made either via these independent agents or directly using a mobile phone (i.e. to top up credits using cash or mobile money). All CSPs offer direct sales through their website, but due to the low internet penetration in the country, this channel will not generate significant sales. In order to attract more dealers and independent agents, CSPs need to present a good commission policy and scale. Independent agents will be attracted by CSPs that are not only able to offer better remuneration, but also can provide a product that is relatively easy to sell. Arguably, large CSPs with well-known brands will attract more independent dealers. Copyright 2014 Cartesian Ltd. All rights reserved. 30

32 Some CSPs also offer ongoing dealership programs with a focus on developing the dealer relationship. For example, MTN offers a dealership program that awards the top dealers and agents each year. Since MTN is the largest CSP in the market, it is able to provide substantial scale to attract more dealers to sell its products. The two biggest telecom retailer chains, Simba Telecom (30 shops in the country) and Nilecom (20 shops in the country) only offer MTN products. Nilecom was acquired in 2008 by South African Cellcom, which is MTN s biggest dealer in that country. In 2010, Simba claimed it was accountable for approximately 21% of MTN s prepaid turnover. This gives an idea of how representative sales from dealers and their agents are compared to total CSPs sales. Orange has approximately 30 dealers listed on its website, and it doubtless has a significant number of agents working with these dealers. Airtel operates two of its own stores, located in Kampala. Additionally, there are approximately 30 dealers operating Airtel-branded stores in addition to the independent agents. With the relatively sizable financial capacity available to large CSPs, they are able to offer a good number of promotions and large commissions (for the market), which in turn help to attract and retain a substantial network of retailers and distributers. Establishing a retail distribution network in Uganda can be significantly challenging to new players entering into the market, however, due to the scale and appealing commission packages needed to attract dealer and independent agent partnerships. Since internet penetration is very low, it would not be effective for a CSP to enter into the market via low-cost online channels. It must therefore invest in building its own network of retailers and independent agents in the country, which can be a prohibitively expensive barrier to market entry. The telecoms retail market structure in Uganda clearly favours CSPs that are already established in the market, limiting the growth potential of new CSPs. MTN is in a particularly advantageous position as it has established exclusive deals with the largest telecom retailers and independent agents in the country. Transparency of Retail Consumer Information The large prepaid penetration in Uganda is driving mobile broadband services offering in Uganda. As discussed above, there are three common offers across all CSPs: Pay per MB; Pay per MB allowance and period validity (bundle); Pay per packaged voice, SMS, mobile broadband services, and period validity. There is little variation in the plans structures across all CSPs. With the exception of Sure Telecom, all CSPs offer the three types of plan listed above. Sure Telecom does not offer voice, SMS and mobile broadband bundles. Variation between CSP plans is more based on the service allowance and plan validity period (see Section 4 for further details). Copyright 2014 Cartesian Ltd. All rights reserved. 31

33 Service offering and pricing are relatively clear on all CSPs websites. It is easy to find all the available options for prepaid and post-paid. Information about prices and plans are transparent and it is easy to compare the different options without a great effort. Post-paid plans do not appear to include a bundled option of voice, SMS and data. The only options available are by MB and by MB allowance. Since there are no (or very limited) handset subsidies in the market, tariffs and plans do not include any handset price which makes the offers easier to understand (i.e. consumers know exactly what they are paying for). That said, consumers may not have a good understanding of what a MB of usage represents. This uncertainty may be a contributing factor to the low penetration. There are no reported complaints regarding misleading material for mobile broadband internet. In general, broadband internet complaints (both fixed and mobile) represented only 7% of total complains during the 2013 and 2014 (February to June). 13 As such, we do not consider transparency of retail consumer information to be an issue in the mobile broadband market. Prices and plans are relatively easy to find and understand. All CSPs tend to follow the same offer structure, and there is no evidence of any CSPs having an advantageous position here. Ease of Consumer Switching Mobile broadband customers in Uganda face few barriers to switching their provider. Since the market is predominantly composed of prepaid customers, there are no contract obligations and customers can freely and frequently change their CSP. Generally, consumers own more than one SIM card in the mobile access and voice market as this will allow them to take advantage of on-net call discounts (rather than pay for more expensive offnet calls). There are fewer benefits to have more than one SIM card for mobile broadband services, but consumers have the ability to top-up mobile broadband credit on different SIM cards on any day, week or month. The only limitation to switching CSP would be cost. Where a consumer has a voice, SMS and mobile broadband bundle and benefits from a promotional discount, it will be more costly to the consumer to buy the same services separately from different CSPs. However, even in the case above, customers using a bundle are free and able to buy the services from different CSPs if they prefer to do so. As previously mentioned, there are limited handset subsidies in the market. Therefore, most handsets are unlocked and accept SIM cards from all CSPs in the market. This is not perceived to be an impediment to switching. Therefore, we believe that there are no significant switching barriers in the mobile broadband market. 13 Source: UCC, Copyright 2014 Cartesian Ltd. All rights reserved. 32

34 Countervailing Buyer Power There is no clear evidence of countervailing buying power in the market. The mobile broadband market is characterized as a mass-market service, so CSPs are not dependent on a small number of large customers. Large business customers could potentially have some countervailing buying power since they demand large volumes of services. There is some evidence of this in the fixed voice and business connectivity markets, where large corporate customers are able to exert pressure on price and conditions. However, businesses represent only a small percentage of the mobile broadband market (e.g. business users represent only 18% of MTN s mobile internet revenue). The majority of customers are individual consumers. 14 It is possible that a small number of specific corporations might wield some bargaining power when negotiating with mobile broadband CSPs, but such cases are very limited and do not influence the overall market. Evidence of Dynamic Competition Mobile broadband was first launched in Uganda in 2008, and it still represents a relative new service in the market. CSPs are focusing on evolving their RANs and core networks to more advanced technologies such as HSPA+ and LTE. Bandwidth is a strong competitive factor for all CSPs and they tend to promote one technology over another (i.e. Airtel promotes its W-CDMA services as 3.75G and Orange highlights its LTE services). MTN and Orange are using their recent investment in LTE to promote their services. Since LTE is only available in limited areas in the country, CSPs are using the technology as a way to endorse the quality of their overall broadband services. Therefore, customers would be inspired to use services from a CSP promoting LTE even if they subscribe to 3G services on the assumption that all services from that provider use the most advanced technology. MTN and Orange are both investing in LTE and W-CDMA. Since Airtel does not have enough spectrum for LTE, it is investing in improving and expanding its W-CDMA network. UTL is limited to GSM data technologies and extremely dependent on next spectrum allocation to be able to invest in new networks to become competitive in the market. Investment priorities seem to be in line with other countries in Africa. Most initiatives are targeted on taking W-CDMA coverage beyond urban centres into more rural areas, while the slow start in deploying LTE is focussed on areas where the demand justify the investment. Particularly, CSPs are investing in increasing coverage of W-CDMA, HSPA+ and LTE. MTN, Airtel and Orange have at least 30% of the population covered by their W-CDMA or HSPA+ networks. UTL s coverage is limited to EDGE and GPRS with insignificant W-CDMA coverage. CSPs are also working on alternatives to enable them to reduce their costs. Since network coverage is one of the main priorities for the provision of mobile broadband, CSPs are outsourcing their 14 Source: UCC, Copyright 2014 Cartesian Ltd. All rights reserved. 33

35 passive infrastructure to other independent companies. For example, MTN and Airtel have sold their towers to ATC Uganda and Eaton Towers respectively. This decision allowed the two CSPs to turn CapEx into OpEx and free up finances to allow them to expand their coverage. Other CSPs have also benefited from this decision, since passive infrastructure capacity is now available wholesale to all CSPs in the market. In terms of service quality, CSPs do not supply detailed KPIs for their mobile broadband services. The main metric is the number of complaints. Even this for their mobile broadband services is significantly small. Therefore, there is insufficient evidence to assess how the service quality has been evolving over the last few years. Pricing of offerings and promotion structures is similar among all CSPs. MTN s and Orange s prices are very similar, whilst Airtel is trying the alternative approach of including fewer services in its bundles, but offering a significantly lower overall price than its competitors. We discussed pricing in more detail earlier in this assessment. In summary, there is evidence that the market is relatively competitive in terms of price. There is no evidence of any significant innovation in how CSPs are offering mobile broadband services. The main propositions are focused on network technology and bundled offers (data, voice and SMS). As such, there is evidence that the mobile broadband competition in the country is significantly driven by technology and coverage advantages. Whilst Airtel and UTL have some restrictions in terms of spectrum availability, MTN and Orange are using their investment to expand their W- CDMA networks. In addition, there are initiatives to reduce costs in a way that will improve margins, given that retail price competition in the market is significant. The recent passive infrastructure deals are one example of CSPs cost reduction initiatives. Potential for Market Growth It is estimated that mobile broadband services will generate approximately USD 122M by the end of 2014, representing 15% of all mobile revenues in Uganda. These revenues are predicted to grow in the next five years to more than USD 500M, or more than 45% of all mobile revenues (see figure 3). As previously mentioned, since the market for fixed broadband is limited, mobile broadband will be the main means of internet access in the country. The low number of fixed broadband users is largely due to the lack of legacy copper network, limited fibre access network deployments, and emphasis on business customers. Mobile broadband subscriptions are growing significantly in the country. Currently, there is a total of 4.1M subscriptions, growing from 3.6M in 2013, 2.6M in 2012 and 977,000 in This represents an annual growth of approximately 70% (see figure 2). W-CDMA and LTE subscriptions are predicted to represent around 22% of all mobile subscriptions in the country by the end of This share is predicted to grow to almost 80% by 2019 or a total of 26M subscriptions (see figure 2). Copyright 2014 Cartesian Ltd. All rights reserved. 34

36 Not all W-CDMA subscriptions will take advantage of data services, however; the number above includes a significant number of customers using their W-CDMA SIM card only for voice and SMS services. However, the more W-CDMA subscriptions there are in the market, the bigger the opportunity is to upgrade these customers onto a tariff that includes mobile broadband. Therefore, the potential for the service is considerably high. The mobile broadband market has seen two new players since 2013: the MVNO K2 and Sure Telecom (operating under the brand Smart ). Although Smile telecom is offering LTE services in the country, it is only offering fixed-wireless services, so is not included in this market. Given the above, we consider the market to grow significantly over the next five years, representing a considerable opportunity to CSPs in the mobile broadband market. Market Conduct Assessment Conclusions Multinational CSPs such as MTN, Airtel and Orange have access to more capital at lower prices than national groups. These groups are able to leverage their scale and global credibility to source more funding to help them with the significant investments in their operations in the country. After Orange s sale to Africell, MTN and Airtel are left the remaining two strong multinational CSPs in the country. Retail and distribution represent potential constraints to market competition. Since the existing telecoms retail structure is based on exclusive franchising deals with independent retailers and agents, there are potential barriers for new CSPs to establish a meaningful retail footprint. MTN has agreements with the largest independent retailers, with significant reach via independent agents. This represents a significant advantage to the CSP since it offers it a wider retail network to distribute its services compared its competitors in the market. Since spectrum availability is limited, some CSPs are facing challenges to cope with demand, or to migrate to more evolved technologies (i.e. W-CDMA and LTE). Airtel has restrictions on deploying LTE, limiting its offerings to HSPA+, while UTL is only providing data over GSM networks. This favours both MTN and Orange, which already offer W-CDMA, HSPA+ and LTE. Finally, market conditions could promote possible joint dominance between MTN and Airtel. At the current stage, Airtel is acting more as a strong competitor to MTN than being a candidate for any possible joint dominance, but with a market that is considerably concentrated with two comparable CSPs sharing the market leadership position, it is possible for MTN and Airtel to exert joint dominance in the future. 7. Basic Market Conditions Technology Mobile broadband services allow consumers to access the internet from a smartphone connected to a mobile network. In order to provide the service, CSPs need to acquire spectrum, invest in network equipment in addition to other upstream wholesale inputs such as passive infrastructure, leased lines and termination (see Figure 15). Copyright 2014 Cartesian Ltd. All rights reserved. 35

37 Figure 15: Technology Framework for Mobile Broadband Source: Cartesian CSPs build their Radio Access Network (RAN) and core networks using equipment based on international standards acquired from global suppliers. These standards ensure CSPs maintain interoperability with handsets and other CSPs. RAN and core network technologies have evolved since the creation of GPRS and EDGE. In the past ten years, CSPs globally have been investing in migrating to GSM standards by deploying W-CDMA and LTE networks. More modern technologies enable a better use of the spectrum. The cost of deploying a new mobile technology, however, can be considerable obliging CSPs to upgrade their RAN and core network and in some cases, acquire new spectrum to be able to offer mobile services. The most popular network technology is GSM, which connects 78% of all mobile subscriptions in the country. Other technologies such as WiMAX and CDMA are present in the market supporting both voice and broadband. However, although both technologies are mobile ones, they are only used to offer fixed-wireless services and thus are not included in this market. Moreover, CSPs are investing in new technologies (i.e. WCDMA and LTE) to be able to offer mobile broadband services in the country. It is expected that W-CDMA subscriptions will represent 22% of total subscriptions in the country by the end of Since W-CDMA is also capable of supporting voice services, CSPs are gradually migrating customers to W-CDMA as their coverage increases. It is highly likely that CSPs in Uganda will keep the two technologies since they are able to use GSM technology to support voice services in areas where there is no W-CDMA coverage. This will allow CSPs more time to grow their W-CDMA presence without providing any interruption to the provision of mobile voice and SMS services. Copyright 2014 Cartesian Ltd. All rights reserved. 36