The impact on NRTRDE following the implementation of EU roaming regulation 111

14th March 2013 

Reliance on NRTRDE is likely to increase in European Union countries as a result of the new EU Roaming Regulation III initiative. This introduces an obligation for mobile operators to allow their customers an option, as of 1 July 2014, to purchase roaming within the EU as a separate service. This is aimed at enhancing competition in the EU roaming market, and driving down costs (which will be regulated within the EU community and likely to be between Eur 0,21 and 0,24c per minute for outgoing calls). This provides an opportunity for new players to enter the roaming industry, including existing operators such as MVNO’s, as Alternative Roaming Providers (ARP). ARP’s, who do not have their own networks, are to be offered easier access to the roaming market, requiring network operators in other member states to grant them access to their networks at regulated wholesale prices. ARP’s may also extend their roaming offer to include ‘unregulated’ destinations ouside the EU.

This initiative will introduce some fraud risk, such as IRSF, international call forwarding and bypassing hot ‘B’ number blocking to name a few. Certainly the impact of this initiative on IRSF terminating within the EU will be interesting. Analysis of the GSM Fraud Forum High Risk Range list reveals that 16.3% of PBX, IRS and Wangiri fraud numbers submitted relate to terminations in either EU or EU acceding or candidate countries. It also shows that almost 80% of these fraud reports were from a source country located within these EU, acceding or candidate countries.

It is noted that the draft EU Roaming Regulation 111 High Level Technical Specification document clearly states that a visited MNO must make NRTRDE data available to the Home MNO in line with the current GSMA rules or become liable for any fraud losses suffered outside that reporting period. The Home MNO must then make these NRTRDE records available to the ARP in line with the same GSMA rules, or they then become liable for roaming fraud losses outside the reporting period (with slight modifications such as timing and inclusion of the visited MNO). Fraud is the responsibility of the operator implementing the retail billing, so in the case of roaming unbundling, this will be the ARP, and the Domestic Provider if the customer elects to remain with their domestic provider to provide EU roaming services.

This creates an interesing situation, where the HPMN now has some responsibility towards the VPMN for roaming traffic generated by an ARP’s customer. NRTRDE files will be delivered from the VPMN to the HPMN, who must then identify records that relate to the ARP’s customers, and forward these records on. In this situation, the fraud risk increases significantly if either (or both) the HPMN and the ARP do not have systems or processes in place for 24/7 monitoring of inbound NRTRDE records.

It is understood that a current proposal for Fraud Management involves using an On-line Charging System (OCS) through CAMEL however this requires all Local Break-Out Operators (LBO’s) to support, and move Post-Pay services, to CAMEL.

While the OCS initiative would provide significant advantages for real time roaming fraud management, the value of NRTRDE as an effective fraud detection tool when monitored 24×7 should not be under-estimated, and depending on how the EU Roaming Initiative develops, could deliver increased value for European operators providing EU regulated roaming solutions. If the decision is taken that OCS will be required to support the EU Roaming Regulation initiative, this will require significant investment by European operators and it is likely that implementation could suffer similar delays to those experienced with NRTRDE implementation. With a mandatory date of 1 July 2014 for European operators to provide these new regulated roaming services, NRTRDE may remain a preferred alternative to some roaming access service providers.