Author
Jan Yngvar Olsen
Date
7 May 2014
Pages
1 (65)
Report on mixed use of 2 and 3
digit MNC codes under Sweden’s
MCC 240
Cybercom reference: SIN-035-14006-01
7 May 2014
Prepared by: Jan Yngvar Olsen
Email: [email protected]
Cybercom Group
Lindhagensgatan 126
P.O. Box 30154
SE-104 25 Stockholm
Sweden
Tel +46 8 578 646 00
www.cybercomgroup.com
[email protected]
Page 2 (65)
Table of contents
1
Executive Summary ........................................................................................... 4
1.1
1.2
1.3
Background............................................................................................................. 4
Analysis .................................................................................................................. 4
Recommendations .................................................................................................. 5
1.3.1
1.3.2
1.3.3
1.3.4
2
3
Scope of study.................................................................................................... 7
Standardisation and evolution in the use of MNCs ......................................... 8
3.1
3.2
3.3
3.4
3.5
3.6
4
Mixed use of 2 and 3-digit MNCs under MCC 240 ............................................................................ 5
Shared use of MNCs under the Swedish geographic MCC 240 ........................................................ 5
MNCs under shared MCCs “90X”...................................................................................................... 6
General policies to further safeguard MNC resources ....................................................................... 6
Structure of IMSI, MNC and MCC ........................................................................... 8
Key provisions of the standards and specifications ................................................. 9
Use of the identification plan ................................................................................... 9
Use of the identification plan for routing of signalling ............................................. 10
Current use of 2 versus 3 digit MNCs.................................................................... 10
Possible change from 2 to 3 digit MNCs ............................................................... 11
Background and overview of possible MNC changes .................................. 12
4.1
New service providers ........................................................................................... 12
4.1.1
4.1.2
4.1.3
4.2
4.3
Machine-to-machine (M2M) applications ......................................................................................... 12
Unbundling/decoupling of services .................................................................................................. 13
Coverage solutions to increase capacity and improve service quality ............................................. 13
MNC assignment criteria ....................................................................................... 14
How to meet demand for MNC resources ............................................................. 14
4.3.1
4.3.2
4.3.3
4.3.4
5
Introducing 3 digit MNCs ................................................................................................................. 15
Use of shared MNCs ....................................................................................................................... 16
MNCs under new MCCs .................................................................................................................. 16
Embedded SIM solution .................................................................................................................. 17
New services/applications and their MNC requirements .............................. 18
5.1
Utilities and security .............................................................................................. 19
5.1.1
5.1.2
5.2
Characteristics of market and service requirements........................................................................ 19
Expected MNC requirements .......................................................................................................... 20
Automotive applications (eCall, etc) ...................................................................... 21
5.2.1
5.2.2
5.3
Characteristics of market and service requirements........................................................................ 21
Expected MNC requirements .......................................................................................................... 24
Independent providers of unbundled services ....................................................... 26
5.3.1
5.3.2
5.3.3
5.3.4
5.4
SMS service providers .................................................................................................................... 26
Roaming service providers .............................................................................................................. 26
Mobile OTT Service providers ......................................................................................................... 26
Expected MNC requirements .......................................................................................................... 27
Providers of small cell coverage solutions ............................................................. 27
5.4.1
5.4.2
5.4.3
5.5
Public networks ............................................................................................................................... 27
Private networks .............................................................................................................................. 28
Expected MNC requirements .......................................................................................................... 28
Summary .............................................................................................................. 29
5.5.1
5.5.2
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Transformed industry structure........................................................................................................ 29
MNC requirements .......................................................................................................................... 30
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6
Summary of discussions with Swedish market participants ....................... 31
6.1
Scope of the survey .............................................................................................. 31
6.2
Present use of assigned MNC resources .............................................................. 32
6.3
Need for MNC resources ...................................................................................... 32
6.4
Use of shared country codes ( MCC “90X”)........................................................... 33
6.5
Impact on existing operations from mixed use of 2- and 3-digit MNCs under
Sweden’s MCC ................................................................................................................ 34
6.5.1
6.5.2
6.5.3
6.5.4
6.5.5
7
Core and access network systems and implementations ................................................................ 35
Billing and mediation systems ......................................................................................................... 35
Roaming agreements and related arrangements ............................................................................ 36
Interconnection arrangements ......................................................................................................... 36
Summary of potential impact on existing operations ....................................................................... 36
Analysis of mixed use of 2- and 3-digit MNCs ............................................... 38
7.1
7.2
Required changes to standards and specifications ............................................... 39
Impact on the different areas of operation ............................................................. 39
7.2.1
7.2.2
7.2.3
7.2.4
7.3
8
Core & access network systems, Mobile terminal behaviour .......................................................... 39
Billing and mediation systems ......................................................................................................... 43
Roaming arrangements and agreements ........................................................................................ 43
Interconnection arrangements ......................................................................................................... 45
Potential scenarios................................................................................................ 45
Analysis of the use of shared MNCs under geographic MCC ...................... 47
8.1
Shared MNCs as alternative to unique MNC ......................................................... 47
8.1.1
8.1.2
8.1.3
8.2
9
Shared MNC as identifier of networks and subscribers ................................................................... 48
Shared MNC in the Radio Access Network (RAN) .......................................................................... 49
International roaming....................................................................................................................... 50
Implementation scenarios ..................................................................................... 51
International outlook ........................................................................................ 52
9.1
Netherlands .......................................................................................................... 52
9.1.1
9.1.2
9.2
9.3
9.4
10
Mixed use of 2 and 3-digit MNCs .................................................................................................... 53
Use of shared MNCs ....................................................................................................................... 53
Norway ................................................................................................................. 53
USA ...................................................................................................................... 54
India ...................................................................................................................... 54
Conclusions and recommendations ........................................................... 56
10.1
10.2
10.3
Reasons for change .............................................................................................. 56
Possible solutions and scenarios .......................................................................... 58
Recommendations ................................................................................................ 61
10.3.1
10.3.2
10.3.3
10.3.4
11
12
Mixed use of 2 and 3-digit MNCs under Swedish MCC 240 ....................................................... 61
Shared use of MNCs under the Swedish geographic MCC 240 ................................................. 62
MNCs under shared MCCs “90X” ............................................................................................... 62
General policies to safeguard MNC resources ........................................................................... 62
References .................................................................................................... 64
List of abbreviations / acronyms ................................................................ 65
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1 Executive Summary
The focus of this study is the expected shortage of MNC resources and possible solutions, in
particular the possible mixed use of 2 and 3 digit MNCs under Sweden’s mobile country
code (MCC) 240. The study has been carried out by Cybercom on behalf of the Swedish
Post and Telecom Authority (PTS). The study is based on comprehensive consultations with
a number of Swedish operators and other market participants. The results of these
discussions form the basis for the further analysis presented in this report.
1.1 Background
A shortage of MNC numbering resources is expected over the coming years. New services
and business models are assumed to result in continued fragmentation of the mobile
services value chain resulting in a steadily growing number of service providers requiring
appropriate MNC numbering resources.
A review of the principles for assignment of MNCs, which so far has been reserved for use
by public networks offering public telecommunication services, may also be required. There
are both commercial and technical reasons for such changes. New users may include: large
telematics customers, operators of private (non-public) networks, etc. A change in direction
of less restrictive assignment policies will result in further shortage of MNC resources.
The need for more MNC resources has been discussed for some time. The MNC may
consist of 2 or 3 digits, and most countries, including all European countries, currently use 2
digit MNCs. 3 digit MNCs are used in North America and a few other countries. The possible
introduction of 3 digit MNCs in Europe in order to obtain more addressing resources has
been brought up from time to time, most recently in a report prepared by CEPT ECC1.
Other solutions include use of shared MNCs and more extensive use of MNCs under shared
MCCs (“90X”). MCC 901 exists, and a new MCC 902 for international SMS service providers
has been proposed by Sweden. Additional 90X MCCs may be considered.
1.2 Analysis
Swedish operators and service providers did not expect any major problems with mixed use
of 2 and 3-digit MNCs if introduced in the way proposed, i.e. 3-digit MNCs in the so far
unused range 70 – 99, which would become the range 700 – 999. Any major impact on
roaming arrangements and billing systems were not expected. Particular problems with core
and access networks were not foreseen assuming mixed use of 2 and 3-digit MNCs was
introduced in a harmonised manner supported by amended 3GPP specifications and
updates to systems and networks available from equipment vendors.
Mixed use of 2 and 3-digit MNCs is currently not supported by 3GPP specifications, and
these specifications would therefore need to be changed. Any 3GPP compliant product can
in principle not be assumed to support mixed use of 2 and 3-digit MNCs until specifications
have been amended and products are updated and confirmed compliant with the new
specifications.
1
ECC Report 212, Evolution in the Use of E 212 Mobile Network Codes.
http://www.erodocdb.dk/doks/doccategoryECC.aspx?doccatid=4
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A specific and widely discussed problem exists with regard to 3GPP specification TS 23.122.
The issue related to home network matching and the implementation in mobile terminals is
potentially difficult as it would impact the entire terminal population. However, this should
mainly be a problem if a new 3-digit MNCs is used by an operator with radio network
broadcasting the MNC.
It may therefore be easier to assign 3-digit MNCs to operators without radio access networks
(typically MVNOs). This could solve a significant part of the problem with shortage of MNCs,
as most demand for MNC resources so far seems to come from operators without radio
access networks.
Finally, some experiences from other countries and regions (e.g. India) suggest that a
transition to mixed use of 2 and 3-digit MNCs is manageable and that the issues with current
3GPP specifications should be possible to resolve with reasonable efforts.
1.3 Recommendations
The Swedish Post and Telecom Authority (PTS) as a National Regulatory Authority (NRA)
will have to make sure that shortage of MNC resources will not artificially constrain service
innovation and competition. It is therefore recommended that the following actions are taken:
1.3.1 Mixed use of 2 and 3-digit MNCs under MCC 240
The following approach is recommended:



Announce target date(s) for introduction (i.e. when to start assignments) of 3-digit
MNCs, possibly as a two-stage process. In the first stage, 3-digit MNCs could be
assigned to service providers without own radio network. In the second stage, all new
MNC assignments would be 3-digit MNCs.
The time schedule should permit reasonable time for:
o System updates and testing of key scenarios
o Further clarify details on variations of existing mixed use of 2 and 3-digit
MNCs in some other regions (e.g. India)
Delayed (or partially delayed) introduction of 3-digit MNCs must be accepted if the
tests reveal problems that demonstrate need for more time.
1.3.2 Shared use of MNCs under the Swedish geographic MCC 240
Shared use of MNCs (different service providers or networks would be identified by leading
digits of MSIN) is most suitable for MVNO type M2M operations. The “HLR Proxy” solution
proposed and planned to be implemented in the Netherlands is a suitable solution to
manage shared use of MNCs.
It is recommended that the NRA leave further development in this area to the market
participants. If Swedish market participants should want to establish “HLR Proxy”-providers
(“HPPs”) to support for example particular industry sectors (utilities, etc.), the NRA should
support this with appropriate MNC numbering resources.
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1.3.3 MNCs under shared MCCs “90X”
In a Swedish contribution to ITU, an MCC 902 has been proposed for use by international
SMS service providers. Further shared MCCs for specific types of service providers may be
considered, e.g. international MVNOs, Independent Roaming providers, etc. This may
generally be an effective way to create new MNC resources for operations, business models
and services, which naturally transcend national borders and not necessarily belong to a
specific country.
1.3.4 General policies to further safeguard MNC resources
Different types of MNC resources (geographic and non-geographic) suit different types of
services and applications. The NRA could therefore create policies for assignment of various
MNC resources (2 vs 3-digit codes under geographic MCC, MNCs under shared MCCs
“90X”, etc.) depending on service and application types. Guidelines or recommendations
would need to be continually updated to reflect availability of various MNC resources and the
continuous evolution of services.
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2 Scope of study
This study, focusing on possible mixed use of 2 and 3 digit MNCs in Sweden, has
been carried out by Cybercom on behalf of the Swedish Post and Telecom Authority
(PTS).
The background for this study is an expected shortage of MNC numbering resources over
the coming years. New services and business models are assumed to result in continued
fragmentation of the mobile services value chain resulting in a steadily growing number of
service providers requiring appropriate numbering resources.
The study is based on comprehensive consultations with a number of Swedish operators
and other market participants. The results of the discussions form the basis for the further
analysis of the issues in this report.
The main focus of the study is the possible mixed use of 2 and 3 digit MNCs under existing
national MCC (MCC “240” for Sweden). The possible introduction of 3-digit MNCs has been
analysed and the report provides conclusions and recommendations in this regard.
The study also considers alternatives and aspects of using the initial digits of the MSIN part
of IMSI to designate operators under shared MNCs
As background, the study provides an overview of:



Evolution in the harmonisation and standardisation of the MNC concept (ITU-T,
CEPT, GSMA, 3GPP)
Expected demand for MNC resources from various new services and applications
Experiences from some other countries where similar discussions or changes are (or
have been) taking place.
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3 Standardisation and evolution in the use of MNCs
The MNC is part of the IMSI as specified by ITU-T Rec. E.212. As a global addressing
plan, the IMSI is essential for mobile networks in order to facilitate authentication,
roaming, routing and billing, nationally and internationally.
MNC may consist of 2 or 3 digits. The length of the MNC is a national matter. This is
normally regulated by the National Regulatory Authority (NRA), which also is
responsible for assigning MNC resources to network operators and service providers.
Most countries, including all European countries, currently use 2 digit MNCs. 3 digit
MNCs are used in North America and a few other countries. The possible change to 3
digit MNCs in Europe has been brought up from time to time in order to obtain more
addressing space, most recently in a report prepared by CEPT ECC2.
Mobile Network Codes (MNCs) are parts of the International Mobile Subscriber Identity
(IMSI) as defined in ITU-T Rec. E.212. The IMSI and its components provide globally unique
identification of mobile networks and subscribers.
3.1 Structure of IMSI, MNC and MCC
The International Mobile Subscriber Identity (IMSI) consists of max 15 digits and permits
identification at three levels:



Country level: Mobile Country Code (MCC), 3 digits.
Network level: Mobile Network Code (MNC), 2 or 3 digits.
User level: Mobile Subscription Identification Number (MSIN), max 10 digits.
Figure 1: Structure and format of the IMSI
MCCs are assigned by the Director of the Telecommunications Standardization Bureau
(Director of TSB). One or more “geographic” MCCs are assigned per country. MCCs in the
“90X” range are also assigned by the Director of TSB. “90X” MCCs are not tied to specific
countries and are referred to as “shared MCCs”.
MNCs are 2 or 3 digits in length and, in accordance with E.212, are administered by the
respective national numbering plan administrator, usually the National Regulatory Authority
(NRA). MNCs under shared MCCs (“90X”) are the responsibility of the Director of TSB.
2
http://www.erodocdb.dk/doks/doccategoryECC.aspx?doccatid=4
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3.2 Key provisions of the standards and specifications
ITU-T Rec. E.212 defines the structure of the IMSI, its components and usage as well as the
responsibility and principles for the awarding of numbering resources. 3GPP specifications
further refines the concept in the specifications for 3GPP compliant systems3. The following
provisions may be noted with regard to MNCs:



”The MNC consists of 2 or 3 digits and the length of the MNC is a national matter”
(E.212, section 5.c)
“MNCs are only to be assigned to, and used by, public networks offering public
telecommunication services” (E.212, Annex B, 2).
“MSINs are to be assigned by the MNC assignee to their subscribed users. A user
may have multiple IMSIs” (E.212, Annex B, 5)
The 3GPP specification TS 23.003 further specifies that:

“A mixture of 2 and 3 digit MNC codes within a single MCC area is not recommended
and is outside the scope of this specification” (TS 23.003, section 2.2) 4
3.3 Use of the identification plan
The IMSI identification plan is a global addressing plan and was originally devised for use by
mobile networks operators (MNOs). The main functions of the IMSI, with its components
MCC and MNC, is shown in Figure 2 below.
Figure 2: Main functions of IMSI and its components for identification
These basic functions and architecture enable a mobile subscriber to be properly recognised
by home network as well as by visited networks when roaming, as:
3
Mobile technology based on GSM and evolved GSM specifications within the scope of IMT-2000,
i.e. UMTS, LTE, etc.
4
ITU-T Rec. E.212 specifies for shared MCCs (Annex A, A.3.2) that “For a specific shared MCC for
networks, the length of all MNCs within that MCC shall be the same.” The same is not explicitly stated
in Annex B “Principles for the assignment of mobile network codes (MNCs) within geographic MCCs”,
but is made explicit by the 3GPP specification TS 23.003 applicable to MNCs under all MCCs, as
quoted here.
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

IMSI (MCC+MNC+MSIN) uniquely identifies a subscriber and:
o It is stored on the SIM inserted in the mobile terminal
o It is used as the key to the user profile in the HLR
LAI (MCC+MNC) uniquely identifies the network and is broadcast on the Broadcast
Control Channel (BCCH) by the network
This structure is essential for mobile networks in order to facilitate authentication, roaming,
routing and billing, nationally and internationally.
Although originally devised for mobile networks, the IMSI identification plan has been taken
into use also in other types of networks including fixed networks and satellite networks. The
gradual convergence of wireless and fixed networks (e.g. within a called “Next Generation
Networks” context) will also require uniform addressing structure across the entire range of
services. Finally, the unbundling of the mobile services value chain creates a number of new
players with need for identification resources.
3.4 Use of the identification plan for routing of signalling
Global Title addresses are used for routing signalling. There are three types of Global Titles
used in mobile networks, E.164 (MSISDN), E.212 and ITU-T Rec. E.214. E.214 defines the
Global Mobile Title (MGT) and how it is derived from the IMSI defined in E.212. The MCC
and MNC are translated to the MGT defined Country Code (CC) and Network Code (NC).
The MGT has a structure similar to addresses defined by ITU-T Rec. E.164, and enable
signalling over SS7 networks. Consequently, as there is a direct relationship between IMSI
and MGT, any changes to E.212 would in principle have a potential impact on E.214..
With the exception of North America, the MGT is used for routing signalling messages.
Because of North American standards and Number Plan, etc., the E.212 addresses are used
directly for routing signalling in North America (World Area 1).
3.5 Current use of 2 versus 3 digit MNCs
Most countries currently use only 2 digit MNCs. By various historic reasons, this includes the
original European GSM countries. Although an option in ITU-T Rec. E.212, the use of 3 digit
MNCs were first defined in 3GPP from R98 (early 1999).
MNCs of 3 digit length are used by the countries and territories in the North American
Numbering Plan and some other countries (in Central and South America and in India).
With the introduction of PCS1900 in North America, it was a regulatory mandate to allocate 3
digit MNCs. However, due to various technical constraints, a so-called 0 suffix rule was
adopted for a transition period. According to this rule, 3 digit MNCs were assigned with the
3rd digit as “0” (i.e. “XY0”). A 2 digit MNC (“XY”) may be broadcast by the network, whereas a
3 digit MNC (“XY0”) is stored on the SIM. 3GPP specifications have been amended
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accordingly, and North America is therefore the only region where mixed use of 2 and 3 digit
MNCs is explicitly defined by 3GPP specifications at present time.
3.6 Possible change from 2 to 3 digit MNCs
The possible change from 2 to 3 digit MNCs in Europe has been a subject of long
discussions. After an initiative taken by the CEPT European Committee for
Telecommunications Regulatory Affairs (ECTRA)5 in 2000, GSM Europe (now GSMA) made
an assessment of the possible mixed use of 2 and 3 digit MNCs under the same MCC. The
report6 delivered in July 2001 concluded that:


“…from a technical point of view, this introduction would cause serious problems to
the existing network operators, both those in the country where the 3 digits MNC is
introduced and in that of their roaming partners. Particularly, the impact on the
roaming agreement cannot be underestimated.”
“GSM Europe is of the opinion that the introduction of 3-digit MNC would in either
case require a technical effort which is not proportionate to the foreseen shortage of
MNC that this introduction would solve.”
The need for MNC resources was seen mainly in perspective of the requirements from
traditional full service MNOs with own radio access networks, and there were (and still are)
only a very limited number of such operators per country. GSM Europe mentioned in 2001
the upcoming introduction of UMTS, but concluded that existing GSM operators were
expected to reuse their existing MNCs for UMTS and that a maximum of 4 to 6 UMTS
operators were expected per country. Based on these requirements, no shortage of MNC
resources were expected.
The subsequent developments, in particular the unbundling of the mobile services value
chain, which have seen the emergence of Mobile Virtual Network Operators (MVNOs),
special services providers like SMS service providers, private networks (e.g. small cells), etc.
have changed the situation. Some NRAs are in the process of using up a very significant
part of their existing MNC numbering resources (e.g. Sweden with almost 40 MNCs
assigned, the Netherlands with almost 30 MNC assigned, etc.)
Following its March 2012 meeting, ITU-T Study Group 2 raised the issue of introducing 3
digit MNCs7 as member states experienced increasing demand for MNCs under their
respective MCCs as new services and business models emerge. CEPT ECC has also again
taken up the issue in its recent report “Evolution in the Use of E.212 Mobile Network
Codes”8.
5
Now CEPT Electronic Communications Committee (ECC).
http://www.gsma.com/gsmaeurope/wp-content/uploads/2012/03/gsmepositionmnc.pdf
7
ITU-T Liaison Statement COM2-LS129-E, “Assignment of 3 digit MNCs” and subsequent
communications.
8
http://www.erodocdb.dk/doks/doccategoryECC.aspx?doccatid=4
6
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4
Background and overview of possible MNC changes
New services and business models are expected to continue increasing the demand
for MNC resources.
A review of the principles for assignment of MNCs, which so far has been reserved for
use by public telecommunications operators, may also be required. New users may
include: large telematics customers, operators of private (non-public) networks, etc.
There are several ways to meet the demand for more MNC resources. Mixed use of 2
and 3 digit MNCs and more extensive use of shared MNC resources are in the focus of
this study, but other alternatives such as additional shared MCCs are also discussed.
4.1 New service providers
The need for more MNC numbering resources is driven by a number of new developments,
which create opportunities for new types of service providers. The key drivers are
summarised in Table 1 below:
Areas driving demand for MNCs
Services providers
M2M
Typically MVNO/MVNEs for:
• Utilities, automotive, security, healthcare, etc.
Unbundling/ decoupling of services
Independent service providers:
• SMS
• Roaming
• VoIP
etc.
Coverage solutions to increase capacity
and improve service quality
Operators of:
• In-house coverage
• Hotspot networks
etc.
typically using unlicensed or shared spectrum
Table 1: Developments driving demand for MNC resources
4.1.1 Machine-to-machine (M2M) applications
New telematics applications (Machine-to-Machine applications, M2M) are among the most
important market developments driving the new requirements. The need for customised
service offerings and support adapted to new business models create opportunities for
specialised service providers. An increasing number of niche oriented service providers are
therefore entering this market, typically as specialised MVNOs.
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Specialised MVNOs targeting this market are therefore often implemented as “full MVNOs”
with own core networks and issuing own SIM cards, providing maximum freedom to create
customised service offerings for their target segments.
Issuing own SIM cards also enable service providers to change access provider (host MNO)
more easily, thereby avoiding the so-called “operator lock-in” effect. (“Lock-in” refers to the
problem an M2M service provider would have changing host MNO if all SIM cards were to
be changed. The cost of changing the SIMs would in many cases make the change of MNO
economically unfeasible.)
Certain customers and applications may also require improved resiliency and coverage
through access to national roaming arrangements (e.g. power distributors, water utilities, car
manufacturers, etc.). This functionality is sometimes provided by using subscriptions from a
foreign MNO, but may also be provided by an MVNO connected to multiple host MNOs.
As a final aspect, telematics functions are often embedded in products at time of
manufacturing. Products are then distributed and sold in various countries and regions
requiring appropriate mobile subscription solutions for the telematics devices. Moreover,
products and devices may regularly cross borders as part of ordinary use and/or moved from
a country to another as part of change of ownership (all scenarios would be typical for cars,
etc.). Solutions addressing the SIM provisioning as well as the various roaming issues are
therefore required.
These market developments in combination with strong growth of the telematics market are
expected result in increasing demand for MNC numbering resources.
4.1.2 Unbundling/decoupling of services
Unbundling (or decoupling) of services are seen in various areas. Services previously seen
as just integrated parts of the mobile operator service offerings are increasingly being
offered as separate services by independent service providers. Examples of such services
are:



SMS service providers (SMS-SPs)
Alternative Roaming Providers (ARPs)
“Over the Top” (OTT) services e.g. Voice over IP (VoIP) service providers, typically
providing services “over-the-top” of data connections (e.g. Skype, Viber, etc.)
These independent service providers may generally require MNC resources for interconnect
and traffic termination. Some service implementations may also require MNCs to facilitate
billing and authentication.
4.1.3 Coverage solutions to increase capacity and improve service quality
Small cell implementations (i.e. “pico”/”nano”/”femto” cell solutions) typically for in-house or
“hotspot” coverage, is a third area expected to require MNC resources, in particular if
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provided by independent service providers. Development of small cell networks is generally
driven by the need for improved quality of in-house coverage, increased capacity for data
services in hotspots, etc.
Small cell networks may offer public services or they may be private (closed) networks.
Numbering resources for private networks need to be regulated and harmonised with public
networks when same technologies and frequency ranges are used, and to avoid creation of
technical barriers to future interconnection of the networks.
4.2 MNC assignment criteria
MNC numbering resources enable market participants to operate core networks with own
HLR and to issue own SIM cards with own operator profiles, thereby increasing their
technical and commercial independence of a mobile network operator (MNO) used for radio
access.
Switching of an entire subscriber base from one MNO radio access provider to another can
be done without change of SIM cards. An MVNO with own core may also in principle
connect to more than one MNO, thereby obtaining better network coverage and resiliency.
Operators of private small cell coverage solutions may also need MNC resources for
technical and operational reasons (ref. 4.1.3 above). In case of private networks, this may
require a change of general eligibility criteria for assignment of MNCs as defined by E.212.
MNCs are at present only allowed to be assigned to, and used by, public networks offering
public telecommunication services (ref. 3.2 above). Assignment of MNCs to entities other
than public telecommunication operators would need further consideration.
4.3 How to meet demand for MNC resources
There are various ways to expand the available MNC numbering resources and to utilise
existing MNC resources more efficiently, for example:




Expand numbering resources through the use of 3 digit MNCs
More efficient use MNC resources through use of shared MNCs, in particular HLR
Proxy Provider (HPP) solutions
Use of new MNCs assigned under new MCCs either under national/geographic
MCCs and/or international shared MCCs (e.g. the existing MCC “901” and possibly
under new MCCs “90X”)
“Over-the-air” (OTA) SIM provisioning (ref. the GSMA proposed standard for
“Embedded SIM”) will make it possible to initially load and change operator
credentials remotely, for example change of home operator without change of
physical SIM. This technology does not create more MNC resources directly, but it
addresses issues (e.g. “operator lock-in”) which otherwise would require MNC
resources.
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4.3.1 Introducing 3 digit MNCs
Unlike some previous proposals for a general transition to 3 digit MNCs, the solution
proposed by the recent CEPT report assumes, at least for an unspecified transitional period,
a partial transition to use of 2- and 3-digit MNCs under the same MCCs.
Partial transition means that 2-digit MNCs already assigned can be maintained as 2 digit
MNCs. Operators and service providers not able to switch to 3-digit MNCs can therefore
continue to use their existing 2-digit MNCs.
New 3-digit MNCs would be assigned only using combinations of the first two digits that are
different from already assigned 2-digit codes, i.e. the principle of “non-overlapping” codes.
For example:


“01” is an existing 2-digit MNC in Sweden, and all values “010” to “019” would
therefore not be available as new MNCs.
“70” is not currently used, and the MNC values “700” to “709” would therefore be
available as new 3-digit MNCs.
The plan in Sweden is to use the current MNC range 70 – 99 as 3-digit MNCs 700 – 999.
The resulting change of the Swedish MNC numbering plan is shown in Figure 3 below:
Figure 3: Proposed evolution of Swedish MNC numbering plan
Specifically, this plan means:


An existing assignment of MNC “XY” would mean that the combinations “XY0”,
“XY1”, …”XY9” would not be available as MNCs, but would continue to be available
for use by the operator or service provider with right to use “XY”.
It should also be noted that for technical reasons, it is recommended that for those 2
digit MNCs already assigned, “XY” should be the only number considered MNC. The
number combinations “XY0”, “XY1”, …”XY9” would remain available for the assignee
of “XY”, but the digit (“0” to “9”) following “XY” would continue to be the first digit of
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the MSIN. Only unused combinations of “XY” should be considered for assignment
of new 3 digit MNCs, “XYZ”.
This is the specific plan for 3-digit MNCs under Sweden’s MCC 240 that is discussed in
more detail in subsequent sections of this report.
4.3.2 Use of shared MNCs
Use of shared MNCs is a way to extend existing MNC resources. For some applications, for
example private ‘small cell’ networks, not even the introduction of 3 digit MNCs would create
enough MNC resources to satisfy the expected potential demand.
Shared MNCs may then be a feasible solution and the leading digits of the MSIN can be
used to identify different networks. Various alternatives for use of shared MNC are discussed
in more detail in subsequent sections of this report.
4.3.3 MNCs under new MCCs
MNC numbering resources may also be expanded through introduction of additional MCCs.
Two alternatives are possible:


Assigning new geographic MCCs to countries.
o The general rule is that additional MCCs may be assigned by the Director of
TSB when 80% of existing address space has been used, provided that the
national numbering plan administrator can demonstrate efficient use of
existing numbering resources.
o Another option having been discussed is to assign additional geographic
MCC to countries currently using 2 digit MNCs. The new MCCs would then be
dedicated for assignment of 3 digit MNCs. This would be an alternative to
mixed use 2 and 3 digit MNCs under same MCC and would also have various
advantages and disadvantages. Consideration of additional geographic
MCCs is outside the scope of this study, and is not further discussed here9.
Assigning new shared (non-geographic) MCCs in the series “901”, “902”, … “90X”.
o Shared MCCs would create additional MNC resources and be suitable for
services that are not country specific by nature. An example is the code “902”,
which has been proposed for SMS service providers in a recent Swedish
contribution to the ITU10.
o MNCs under new MCCs may be assigned as 3-digit codes in order to
preserve addressing resources.
9
Additional geographic MCCs were discussed in the GSM Europe assessment from 2001:
http://www.gsma.com/gsmaeurope/wp-content/uploads/2012/03/gsmepositionmnc.pdf
10
COM 2-C4-E ITU-T SG2 – Contribution 4, December 2012, “New Annex G for E.212 – MNCs under
new MCC for International mobile messaging services
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4.3.4 Embedded SIM solution
The possibility to initially load and change operator credentials using “over-the-air” (OTA)
interfaces, i.e. effective change of home operator without change of physical SIM. Remote
changes of large numbers of SIMs would be possible, and the issue with “operator lock-in”,
raised in connection with telematics implementations, should be resolved.
The GSMA has announced its specification enabling the remote “over the air” provisioning
and management of Embedded SIMs in machine-to-machine (M2M) devices. According to
this specification, a non-removable SIM is embedded into the M2M device at the point of
manufacture and can later be remotely provisioned with the subscription profile of the
operator providing the connectivity11. First deployments of the GSMA-compliant Embedded
SIM solution are expected to roll out in 2014.
Various solutions have previously been proposed for “over the air” SIM provisioning and
change of home operator. Except when otherwise explicitly stated, this report assumes use
of solutions based on the above mentioned GSMA specification for this type of functionality.
11
http://www.gsma.com/connectedliving/embedded-sim/
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5 New services/applications and their MNC requirements
Machine-to-machine (M2M) applications, new unbundled/decoupled services in the
mobile value chain and increased use of small cell coverage solutions to improve
capacity and service quality are the main forces driving demand for new MNC
resources. Within the M2M sector, utilities and automotive are the most important
sectors.
Utilities and small cell operations are expected to be main drivers of demand for
MNCs under country specific geographic MCCs.
Automotive applications as well as the various unbundled/decoupled services are
most often international by nature (in terms of product distribution, usage, etc.) and
may be best served by MNCs under shared MCCs that are not country specific.
As briefly discussed in the previous section, we expect that the emergence of a number of
new mobile services and business models will increase the demand for MNCs. This section
provides a more detailed review of some typical applications and business models and the
possible requirements and demand for MNCs, which might be expected as a result of the
developments in these areas.
As discussed in 4.1 above, the main forces driving demand for new MNC resources are:



Machine-to-machine (M2M) applications
New unbundled services and independent service providers
Small cell coverage solutions to increase capacity and improve service quality
The largest M2M segments are the utilities, security and the automotive & transport
segments. The utilities segment, driven primarily by smart metering solutions, is the largest
and fastest growing M2M segment. It is expected that this segment will represent around two
thirds of worldwide M2M device connections by around 202012. The security sector is
expected to represent around one quarter of the M2M market and the automotive & transport
sector another quarter of the worldwide M2M connectivity market by 2020. Regulatory
requirements for installation of eCall facilities in new car models from 2015 are expected to
have an important impact on the development of automotive M2M market in coming years.
12
World wide number of connections. Sources: Analysys Mason and Machina Research.
Web site published research abstracts and publicly distributed papers as listed below.
Analysys Mason: 2.1 bn by 2020
http://www.analysysmason.com/About-Us/News/Insight/M2M_forecast_Jan2011/
Machina Research: 2.6 bn by 2022
http://www.telecomengine.com/sites/default/files/temp/CEBIT_M2M_WhitePaper_2012_01_11.pdf
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We have therefore chosen the following sectors for further discussion in this section:




Utilities and security sector
Automotive sector (Automotive discussed here as a specific part of the automotive &
transport segment. Transport segment would also include e.g. fleet management,
etc.)
Independent providers of unbundled services
Providers of small cell coverage solutions
The focus of the discussion here is the type of MNC resources (or other solution), which
would be most appropriate for the various sectors and types of applications.
5.1 Utilities and security
Smart metering (e.g. for electricity) and security alarms are the main application in this area.
Other applications include solutions for water utilities, etc. Estimates (see above) indicate
that the utilities and security sectors together account for more than three of four M2M
devices currently installed worldwide and forecasts indicate that these sectors will continue
to dominate the market in coming years. Most M2M service providers consulted as part of
this study provided services to these sectors.
5.1.1 Characteristics of market and service requirements
The utilities sector, in particular, is characterised by very large customers in number of
connections. The market is served by several MVNO/MVNEs specialising in services
targeted at this segment. A main concern is the so-called “operator lock-in” effect.
Consequently, MVNO/MVNEs, and ultimately also large customers themselves, would prefer
own MNCs in order to issue SIM cards with own operator profiles not tied to any particular
mobile network operator (MNO).
The sectors are well suited for service providers setting up specialised MVNO operations
(typically “full MVNOs” with own core networks, issuing own SIMs):



Own core network provides maximum flexibility for creation of services tailored to the
specific customer requirements
As international mobility is not a particular concern due to the very nature of these
services and installations (equipment normally installed in a fixed location), roaming
arrangements will normally be a minor concern. (The problem of establishing a
network of roaming agreements could otherwise have been the main obstacle for
smaller niche oriented MVNO in these sectors.)
On the other hand, national roaming might be necessary in order to meet network
quality/coverage requirements as well as for network redundancy. National roaming
is currently provided by MNOs in form of subscriptions (SIM) with a foreign (affiliated)
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13
MNO , but may also be provided by an MVNO having agreements with multiple
MNOs.
Embedded SIM with ‘over-the-air’ provisioning of profile for the operator providing
connectivity (“home operator”) resolves the problem of operator “lock-in” for customers with
large numbers of subscriptions as typical for the utilities sector.
Network redundancy through national roaming arrangements may be provided by a fully
independent MVNO (with own core) with multi-MNO interconnections14. As a service from an
independent MVNO, this would appear as the feasible long term response to these customer
requirements.15
The combined flexibilities obtained through own SIM profiles (physical SIM cards or profiles
downloaded ‘over-the-air’ to embedded SIMs) and specialised MVNO with multi-MNO
interconnects for national roaming are illustrated in Figure 4 below.
Figure 4: Embedded SIM only vs. MVNO with national roaming + Embedded SIM
5.1.2 Expected MNC requirements
MVNOs (typically with own core networks) serving these sectors should be expected to
require more MNC resources as these market sectors develop, usually under country
13
Most Swedish MNOs in our survey provide national roaming functionality by use of SIMs issued by
foreign associated companies (i.e. operators within same sphere of ownership)..
14
Implementation of a fully functional multi-MNO MVNO model would generally require a fully access
agnostic evolved core.
15
An alternative solution provided by MNOs is based on SIMs issued by foreign operators in order to
obtain national roaming. Typically SIMs issued by a foreign operator under special commercial
agreements to control international roaming costs.
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specific geographic MCCs. As the largest M2M sectors, significant demand for MNC
resources may come from these sectors.
If assignment criteria would permit, large customers may also request right to use MNCs in
order to avoid “lock-in” with MVNOs. However, this “lock-in” problem may be resolved by use
of embedded SIM with OTA provisioning of operator profiles.
5.2 Automotive applications (eCall, etc)
Over the next few years, a number of new mobile services are being expected for the
connection of cars. Various connectivity options might be considered depending on the types
of services, applications and implementations.
5.2.1 Characteristics of market and service requirements
Telematics services for the automotive sector include a wide range of services16, for
example:
 Emergency services (e.g. the standardised Pan European eCall)
 Remote diagnostic services
 Breakdown services (“bCall”)
 Stolen vehicle tracking services
 Navigation support
 Infotainment
etc.
The various alternatives for In-Vehicle systems (IVS) include embedded solutions where
both connectivity and intelligence is built into the vehicle as well as various other options
where connectivity, and in some cases also the intelligence, remains in a separate mobile
terminal.
The main IVS options are shown in Table 2 below:
Components
Embedded
Tethered
Integrated
Communication module
Built-in
Built-in
Brought-in
SIM
Built-in
Brought-in
Brought-in
Intelligence
Built-in
Built-in
Built-in
Table 2: In-Vehicle System (IVS) connectivity options 16,17
16
An overview of such services is provided in a recent paper: “Connecting Cars: The Technology
Roadmap”, GSMA Connected Car Forum, February 2013. http://www.gsma.com/connectedliving/wpcontent/uploads/2013/02/GSMA_mAutomotive_TechnologyRoadmap_v2.pdf
17
Source GSMA: http://www.gsma.com/connectedliving/wpcontent/uploads/2012/03/embedded_sim_imv1v091213vFinal.pdf
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For the discussion in this document, we will focus on the requirements of “embedded” IVS
solutions, which will have typical telematics requirements with regard to subscription issues,
SIM provisioning, etc.18 “Embedded” solutions will be installed in the vehicle by the vehicle
manufacturer, in most cases the user of the vehicle might not even be aware of the
embedded IVS, and MNO can be assumed contracted by the vehicle manufacturer19. For
“tethered” and “integrated” solutions, where connectivity module (mobile terminal) and/or
SIM are “brought-in” by the user (owner/user of vehicle), the situation would be different. The
user should in that case be expected to be fully aware of the communication device, its
subscription, roaming aspects and other cost related issues as for a usual mobile
subscription. The basic subscription requirements should therefore in principle not differ
fundamentally from those of an ordinary mobile phone and its subscription.
Focusing on the embedded telematics services, the automotive applications raise some of
the most complex issues with regard to subscription management:





Devices installed in moving vehicles will experience variable network coverage
conditions and still require the highest reliability of connectivity service (sometimes
for emergency services, etc.)
Vehicles will move regularly across borders (international roaming)
Vehicles typically change owners during product lifetime
Vehicles may be sold/exported and change home country (i.e. country of registration
and country of most frequent use)
There would be a question whether ordinary users/owners of vehicles can be
generally expected to be aware of embedded communication devices and
subscription arrangements in a way similar to the owner of a mobile phone.
Of particular importance in Europe will be the EU requirement that all new models of
passenger cars and light duty vehicles sold and distributed in Europe from October 2015
should be equipped for the in-vehicle pan-European emergency service (eCall). Private
emergency call services already established and provided by various car manufacturers are
expected to continue to exist in parallel with eCall. The operating requirements between
private services (“Third Party Support”) and eCall is defined in European standards20
Furthermore, car manufacturers may provide a range of value added services in addition to
emergency call service (e.g. Breakdown services (bCall), remote diagnostics, stolen vehicle
tracking, etc.)
18
It should be noted that there are also several other issues which need to be addressed with regard
to embedded solutions. Of particular concern might be service availability over lifetime of a vehicle,
e.g. GSM services currently available may be switched off in some countries or regions over a
vehicle’s lifetime.
19
For eCall, MNO is assumed contracted by vehicle manufacturer, ref. HeERO presentation to CEPT
ECC, Numbering & Networks Working Group, 22 January 2014, page 13
20
CEN EN 16102:2011 “Intelligent transport systems - eCall - Operating requirements for Third Party
Support”, ref. http://www.cen.eu/cen/products/en/pages/default.aspx
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The introduction of eCall will certainly lead to a strong increase in the number of In-Vehicle
systems deployed. This is also likely to lead to a strong growth in private value added
services, as combined devices for eCall and private services (emergency and value added
services) should be expected. The value added services may enable the car manufacturer to
recover some of the cost of providing mandatory eCall units for all new car models
(estimated to 60-100 euro per unit21).
A typical Dual SIM In-Vehicle System is illustrated in Figure 5 below:
Figure 5: Dual function / Dual SIM In-Vehicle System
The subscription issues (choice of operator, SIM provisioning) will be fundamentally different
for eCall versus private (“Third Party Support”) services.


Pan European eCall (“eCall”) will use standard 112 emergency call service (TS12) +
in-band modem for data transfer22, and will therefore be functioning on a panEuropean basis without any local subscription or roaming arrangements.
Private emergency (Third Party Support, TPS) and value added services use
ordinary mobile voice/data services, and therefore require subscription arrangements
with national as well as international roaming.
However, the difference in requirements means that a subscription meeting the requirements
of private value added services also will meet requirements for eCall. It would therefore be
appropriate to focus on the subscription requirements of the private value added services.
These services will need national and international roaming arrangements which are
technically and commercially feasible.
In principle, either the owner/user of the vehicle or the car manufacturer may have the
contractual relationship with the mobile communications provider (MNO or MVNO). For
eCall, the plan is that the car manufacturer will be responsible for contracting with the mobile
communications provider23. For eCall, it is also assumed that subscription will be dependent
on country where contract is taken out. This may be a feasible soltion for eCall, as roaming
21
Indicative figure from industry sources.
Data is transferred using in-band modem over the 112 voice channel
23
Ref. HeERO presentation to CEPT ECC NaN meeting 22 January, 2014, page 13.
22
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is not really required for the “112” based service. For the other telematics services, however,
this may not be the best solution as international roaming would be required. The solutions
in this area will be up to the industry (market participants) to decide.
Based on our interviews market participants, we expect the main subscription requirements
to be:



National roaming may be required in order to avoid coverage problems with a
single operator
International roaming would be required in order to support vehicles moving
temporarily or permanently across borders. Unlike emergency services, private
value added services, as for example remote diagnostics, will often involve more
significant data volumes on regular basis. International roaming on commercially
feasible terms is therefore important.
The possibility to move vehicles with subscriptions (individual subscribers or
blocks of subscribers) from one home network operator to another, without
change of SIM cards, would be generally required.
Various implementations are possible in order to meet the different requirements, but the
ideal solution meeting all requirements may be difficult to find.
5.2.2 Expected MNC requirements
The remote ‘over-the-air’ management and provisioning of operator profiles on SIM modules
will play a key role in automotive telematics applications. The Embedded SIM specification
as developed by GSMA (see section 4.3.4 above) has been selected for eCall24, and can
therefore be assumed to be de facto standard in this sector. First deployments of the GSMAcompliant Embedded SIM solution are expected to roll out in 2014, in time for the mandatory
deployment of eCall from 2015.
Irrespective of the possibility to manage operator profiles remotely, there would be various
alternatives for choosing the home operator of subscriptions in order to meet the different
requirements listed above. These are shown in Table 3 below:
24
Ref: http://www.gsma.com/connectedliving/wpcontent/uploads/2012/03/embedded_sim_imv1v091213vFinal.pdf
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Subscription options for
automotive M2M
(1)
(2)
Use MNO in country
other than user’s
home country
(typically one of a few
contracted MNOs in
the region)
Use an MNO in user’s
home country
MNC
(assumed
requirements or
preferences)
National roaming
International
roaming
Change of home
network
 MNOs MNC
(foreign)
Yes, as
international
roaming
Yes
Embedded SIM /
Remote provisioning
 MNOs MNC (in
user’s home
country)
Questionable
Yes, but may require
negotiations with
each country/MNO
to get acceptable
roaming cost
Embedded SIM /
Remote provisioning
25
(3)
Use a national
(specialist)
MVNO/MVNE
 MVNOs or car
manufacturer’s
MNC (in user’s
home country)
Yes, assuming
MVNO/MVNE has
agreements with
multiple MNOs
(4)
Use of international
(specialist)
MVNO/MVNE
or
Independent roaming
provider
 MVNOs or car
manufacturer’s
MNC under
shared MCC
(90X)
Yes, assuming
MVNO/MVNE has
agreements with
multiple MNOs
levels
Possible, but
MVNO/MVNE will
need to establish
network of roaming
agreements
Possible, but
MVNO/MVNE will
need to establish
network of roaming
25
agreements
Embedded SIM /
Remote provisioning
Embedded SIM /
Remote provisioning
Table 3: Subscription options for embedded automotive devices
1. In order to get national roaming, a typical solution at present is to use a SIM from a
country other than the country where the vehicle is expected to be (mostly) used.
This is shown as case (1) in the table above. The fact that the device will be a
permanent international roamer in the country of most frequent use is an important
cost issue, but continuous deregulation of the market should be expected to continue
reducing roaming charges within Europe. The solution may therefore be increasingly
feasible in Europe.
2. Case (2) might be a less interesting alternative for the general telematics SIM
because of national roaming problems. However, it may work for the eCall SIM, as
eCall does not require roaming.
3. Case (3) is the only case among the above which would result in increased demand
for MNCs under national MCCs, but the case might appear less attractive as the
significant efforts required to establish all necessary international roaming
agreements might be uneconomical for an MVNO/MVE with only national focus.
4. Case (4) could be a solution in co-operation with a regional (e.g. pan-European)
MVNO/MVNE with extensive network of roaming agreements in the region. The
25
Within EU, roaming cost should be expected to fall significantly as various regulatory measures
such as unbundling of roaming services will result in increased competition and reduced prices. EU
roaming regulation now requires all mobile network operators to meet “all reasonable requests for
wholesale roaming access”. Direct regulatory interventions, such as price caps for certain services,
are already used and should be expected more whenever deregulation is not effective.
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MNC(s) could be registered under an international shared MCC (“90X”). A new MCC
in the “90X” series would probably be the best solution, as our consultation with
market participants shows that MVNOs and service providers have problems
obtaining acceptable interconnection agreement for operations using the existing
“901” MCC26. If assignments criteria under such MCC would allow, car manufacturers
may prefer their own MNCs, alternatively establish their own special purpose
MVNOs, which could request unique MNCs.
Consequently, automotive applications are expected to use either existing geographic
MNCs (case (1)) or require new MNCs under shared MCCs (“90X”). National MNOs
might be used for the eCall SIM, as roaming is not required. This sector is therefore
not expected to require more MNC resources under the country specific geographic
MCCs.
5.3 Independent providers of unbundled services
Technical and regulatory evolutions are increasingly opening up new opportunities for
services like SMS, Roaming, and voice/video to be offered by independent service
providers.
5.3.1 SMS service providers
SMS service providers typically provide services for sending and receiving SMSs from/to
connected devices, various solutions for enterprise to individual user communication over
SMS, premium SMS (payment) services, etc. Services can be used for information
distribution, alerts, various forms of two-way communications (e.g. voting, gaming, etc.),
integration with various applications on PC or smartphones, etc.
5.3.2 Roaming service providers
Under new EU regulations from 201227, decoupling (or “unbundling”) of roaming services
from domestic services should be possible from 1 July 2014. Under same regulations,
mobile network operators are obliged to meet “all reasonable requests for wholesale
roaming access” from July 2012. These regulatory changes are expected to create
interesting new opportunities for Independent Roaming providers, and many new providers
might enter this market over the coming months and year.
5.3.3 Mobile OTT Service providers
Multiple OTT Services providers typically offer voice, chat and video services over IP data
connections, accessible through apps on the customer’s mobile device (e.g. Skype, Viber).
26
As MCC “901” is seen as an international or “foreign” code, for example in use by satellite service
providers, MVNOs and service providers report problems obtaining local interconnection agreements
for operations using MNCs under this MCC.
27
http://ec.europa.eu/information_society/activities/roaming/docs/roaming_recast11.pdf
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5.3.4 Expected MNC requirements
All services might require MNCs for interconnection and billing purposes, and as all these
services are in principle international in nature, assignment of MNCs under international or
“country agnostic” MCCs appears to be the most natural solution. SMS, Roaming and VoIP
service providers are therefore not expected to result in increased demand for MNCs under
geographic MCCs.
As for automotive applications, a new MCC in the “90X” series would probably be the best
solution. However, our consultation with market participants shows that MVNOs and service
providers have problems obtaining acceptable interconnection agreement for operations
using the existing “901” MCC. This problem would need to be resolved for any new “90X”
MCC. It seems that some type of regulatory intervention, if possible, might be necessary.
5.4 Providers of small cell coverage solutions
Development of public small cell networks is driven by the need for improved quality of inhouse coverage, increased capacity for data services in hotspots, etc. Private networks
using spectrum and technology compatible with public mobile networks will also need to be
taken into account in this area.
The typical cases are shown in Figure 6 below:
Figure 6: Public small cell and private networks
5.4.1 Public networks
There is an increasing interest in small cell implementations for in-house and other “hot spot”
coverage:

MNOs or independent service providers may build in-house or “hot spot” networks
(pico/nano cells) to improve coverage and capacity. Reasons might be: high traffic
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
load from large number of users (e.g. in shopping malls, offices), need for increased
data capacity in such locations (high concentration of “nomadic” user of data
communication intensive devices as tablets, etc.), problems with macro network radio
coverage in various building structures (e.g. high rise buildings).
Independent service providers may also enter this market implementing networks
based on shared or unlicensed spectrum. Unlicensed spectrum in the 1800 MHz
band (previously used for DECT) is currently subject to particular interest.
Another area which eventually will need to be considered in Sweden is the 3.4 – 3.8 GHz
band. The spectrum is of potential longer term interest for provision of higher data capacity
in “hot spots” using LTE/LTE Advanced. As the frequency band is currently licenced on
local/regional basis, it will need to be considered in this category.
5.4.2 Private networks
Private networks would also need MNC resources as 3GPP technologies of same type as
used in public mobile networks are deployed. LTE might be expected to increasingly replace
WiMAX for many private network deployments. These networks will require MNC resources
for technical implementation, but MNC should be also assigned so that future
interconnection and roaming between various networks (public and private) would be
possible without fundamental changes of numbering.
5.4.3 Expected MNC requirements
Independent service providers offering public network services using small cell solutions
would require unique MNC resources.
MNOs may be assumed normally to use their existing MNC resources for small cell
solutions. However, it is conceivable that in some cases, additional MNCs might be
requested. An example could be for in-house (”hot spot”) coverage networks which should
also be open for roaming subscriber from other operators. Use of unique MNCs could be a
way to enable national roaming limited to such “hot spots”.
As deployment of these types of networks and coverage solutions gather pace, an
increasing demand should be expected for MNC resources for this purpose. MNCs
under country specific geographic MCCs would be the natural solution in most cases.
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5.5 Summary
The various services and business concepts discussed in this section shows that the mobile
telecommunications industry is moving towards a more fragmented structure.
The fragmentation of the industry, resulting in more specialised players in both service
provision and radio access, potentially opens for more service innovation, new business
models and investments. These are desirable developments for market and consumers, and
it is important to avoid artificial technical constraints in form of limited MNC resources and
restrictive assignment criteria.
5.5.1 Transformed industry structure
Service requirements and innovation are resulting in a proliferation of specialised service
providers. Specialized service providers access customers over common radio access
infrastructures: MNOs RAN, shared RANs, and specialized (supplementary) access
providers. Figure 7 shows and overview of the various players.
Figure 7: Fragmentation of the mobile telecommunications industry
The radio access network is no longer seen as the main differentiator in the competition. The
increasing interest in shared access infrastructure among traditional MNOs confirms this
trend.
In addition to the MNO operated RANs, we may see an increasing number of independent
providers of specialized access for in-house, “hot spot” coverage. Such access providers
may use various combinations of licensed, unlicensed and shared spectrum. 3GPP
technology, in particular LTE, is likely to be the technology of choice, but WiFi may also play
an important role in for example “WiFi data offload” solutions.
The increasing number of players, both in specialized service provision and radio access,
results in a growing demand for MNC resources.
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5.5.2 MNC requirements
Assumed preferences / requirements for various types of subscriber arrangements and the
resulting demand for MNC numbering resources are summarised in Table 4 below.
MNCs under geographic MCCs
Utilities and security
Automotive
Independent providers
of unbundled services

SMS

Roaming

VoIP
Providers of small cell
coverage solutions

Public
networks

Private
networks
Preferred as roaming normally not
required / significant demand
might be expected
IMSI range with local MNO may
be an alternative for eCall only
(but not for general telematics
with roaming requirements)
Alternative if interconnect
unattractive with “90X” MCC
MNCs under international
shared MCCs (“90X”)
Other alternatives
28
HPP ,
IMSI range with MNO
Preferred for internationally
distributed products
IMSI range with foreign MNO
Preferred for services which
by their nature would
naturally transcend borders
Possible for services which are
local or country specific by nature
Preferred assuming requirements
for inbound roaming only /
Significant demand might be
expected
Shared MNC with own IMSI
range.
The use need to be co-ordinated
by NRA
Table 4: Summary of MNC requirements and expected demand per service area
The overview shows that most demand for geographic MNC numbering resources may be
expected to come from the utilities and security sectors and from small cell coverage
deployments.
The automotive sector may be expected to request MNC resources under shared (“90X”
type non-country specific MCCs) if such MNC resources are made available. The alternative
is to continue use of subscriptions with (remotely located) foreign MNOs to enable a
combination of national and international roaming. For the eCall SIM, a subscription with a
local MNO may be a feasible alternative as roaming is not required for eCall (as it is based
on “112” functionality). A common or harmonised provisioning solution for eCall SIM and
general telematics SIM would probably be preferred for logistical reasons. This may be an
opportunity for new service providers.
Unbundled services of interest for independent providers are mostly services that by nature
transcend national borders. Consequently, if appropriate MNC resources can be made
available under shared non-geographical MCCs (“90X”), such MNC resources should be to
be preferred as the most efficient use of total MNC resources available.
28
“HLR Proxy” provider (HPP) solution, ref. section 8.
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6 Summary of discussions with Swedish market
participants
Comprehensive consultations with a number of Swedish operators and other market
participants were an integral part of the analysis.
Potential problems with mobile terminal behaviour (related to 3GPP specification TS
23.122) were the main problems seen in connection with introduction of 3-digit MNCs
that would co-exist with 2-digit MNCs under same MCC. Except for this problem,
market participant only expected minor problems assuming mixed use of 2 and 3-digit
MNCs was introduced in the way proposed.
Use of MNCs under shared MCCs (“90X”) was also discussed with service providers
offering services which naturally transcend national borders. However, participants in
the survey made little use of such codes because of problems to obtain interconnect
agreements on local terms, resulting in increased demand for geographic MNCs in
each of the countries they operate. From a general perspective, this can be seen as
less efficient use of numbering resources.
The study included a comprehensive survey among Swedish operators and other market
participants. The survey was based on interviews and meetings, and the participants were
also invited to provide written comments to the proposed changes.
6.1 Scope of the survey
Operators and market participants consulted as part of the study fall in the following
categories:








Infrastructure based mobile operators with own frequency spectrum (MNOs)
Shared infrastructure providers
MVNOs (Mobile Virtual Network Operators)
MVNOs/MVNEs for M2M (Intermediate Specialised Service Providers for M2M)
Operators of private small cell networks (typically for in-house coverage)
SMS Service providers (SMS-SP)
Telematics solutions/equipment developers/vendors
Mobile network equipment vendors
The participants in the survey were primarily invited to discuss and comment on the possible
introduction of mixed use of 2- and 3- digit MNCs under Sweden’s MCC 240 as described in
section 4.3.1 above. The discussions were focused on the following aspects:


Present use of currently assigned MNC resources
Need for MNC numbering resources. Possible advantages and disadvantages of
introducing 3 digit MNCs in perspective of existing and new services and solutions
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

“HLR Proxy” provider (“HPP”) solutions and use of international (“country agnostic”)
MCC codes were discussed with some market participants as considered
appropriate in perspective of their current service portfolios and configurations
Impact on existing operations of mixed use of 2- and 3-digit MNCs under Sweden’s
current MCC 240, with regard to:
o Core and access network systems and implementations
o Billing and mediation systems
o Roaming agreements and related arrangements
o Interconnection arrangements
The results of the discussions are summarised in the following sections.
6.2 Present use of assigned MNC resources
MNOs and shared infrastructure operators use assigned MNC resources for their networks
in the conventional manner.
Other service providers use assigned MNC resources mostly for services not requiring
international roaming. These are mainly M2M services where the assigned MNC numbers
enable service providers to set up specialised MVNOs. These MVNOs are typically so-called
“Full MVNOs”, i.e. MVNOs with own core networks, issuing own SIM cards. This model gives
them more flexibility in choice of network operator and more possibilities for customisation of
the services.
For general voice and data services requiring international roaming, service providers
normally use IMSI ranges under their MNO host operators’ MNCs. They can then use the
MNO’s already established international roaming networks. The effort required to establish
own network of roaming agreements is generally regarded as commercially unfeasible for
service providers which normally are niche oriented with a more limited number of users.
The “Full MVNO” model with core network and own SIM cards is therefore rarely used for
this type of services, and MNCs are not required.
Many service providers (“MVNOs”) offer general voice and data alongside M2M services.
The assigned MNCs are typically used for the M2M operations only.
6.3 Need for MNC resources
All operators and other market participants in the study had currently assigned MNC
resources. All assigned MNC resources were in actual use or were planned to be taken in
use for specific planned services in the near future.
Service providers typically use their MNCs for the M2M oriented MVNO operations, so
growing demand for MNCs should be expected as the M2M market is growing with new
specialised service providers likely to enter the market.
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The automotive sector (including eCall and other telematics applications appear to have the
most complex and urgent problems with existing arrangements. Current services typically
include private emergency/breakdown services, remote diagnostics, etc. These services use
ordinary mobile data connections29. The main issues of concern are therefore:



Access to national roaming in order to ensure network coverage in all locations
where a vehicle might be moving.
Access to international roaming on economically feasible terms, as vehicles regularly
cross borders
Communication devices (In-Vehicle System, IVS) not requiring physical access for
modifications (e.g. SIM changes) after time of manufacture. As the cost of changing
or refitting the communication device for a vehicle in the field (i.e. already sold and
distributed) is very high30, remote ‘over-the-air’ provisioning of operator profiles is a
strong requirement in this sector.
The embedded SIM design (ref. 4.3.4 above) removes the need for physical installation or
change of SIM card in connection with initial provisioning and subsequent changes.
However, it does not by itself resolve the roaming issues for services requiring ordinary
mobile data connections31. In order to resolve the national roaming issue, a typical solution
is to use SIM cards (or “SIM profile”) from a country other than the country where the vehicle
is mostly used. This might, however, have undesirable cost implications32.
It will be up to the market participants (mobile operators, service providers and car
manufacturers) to find suitable solutions. Depending on solutions, various entities may
require new MNCs, ranging from specialised MVNOs targeting the sector to car
manufacturers themselves (see previous discussion under section 5 above).
6.4 Use of shared country codes ( MCC “90X”)
Some of the market participants in the study had been awarded MNCs under the shared
country code MCC 901, or they were (or had been) considering applying for such code.
The typical service providers, who could potentially use MNC resources under a shared
international code, operate services which naturally transcend borders and meet the general
requirement in ITU-T Rec. E.212 Annex A, A.4.7, stipulating that “The applicant must
demonstrate that its international network infrastructure will contain connecting physical
29
Ordinary mobile data connection might be assumed as to be the usual connectivity option. The
notable exception will be eCall, which will use the “112” emergency call services.
30
Typically in the range of euro 400, according to various indications from industry sources.
31
eCall does not require ordinary mobile data connection, but the vehicle manufacturer’s private
services, which can be expected to reside in the same IVS, are likely to require ordinary mobile data
connections in most cases.
32
Some MNOs provide subscriptions (SIMs) for M2M use from a foreign associated MNO in order to
resolve the national roaming issue. For M2M applications with limited mobility, as for example in the
utilities sector, this may be a suitable solution. In the automotive sector, however, with vehicles
frequently crossing borders, the cost implications might be more difficult to manage.
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nodes in two or more countries. In the case of satellite terminals, serving mobile terminals in
two or more countries will satisfy this requirement.”
However, the MNCs under MCC 901 are currently considered less useful, as it is understood
that local MNOs generally demand international interconnection rates for interconnect with
operations under MCC 901, as if it was a different country. This is incompatible with the
business models of these service providers, who are therefore forced to apply for MNCs
under geographic MCCs. This may be regarded as less efficient use of numbering
resources.
A new suggested shared MCC “902”, as proposed in a recent Swedish contribution to the
ITU33, was described in discussions with service providers who could potentially use it. It
was seen as interesting, provided that interconnection could be agreed on feasible terms.
It appears therefore that in order for MNC resources under any new shared MCCs (“90X”) to
be useful, they must be seen as “country indifferent” global codes that would be seen as
“local” (rather than a “foreign”) code in all countries and markets where they are used. This
might have technical34, commercial and regulatory implications. Regulatory intervention may
be required to enforce desired treatment of “90X” codes.
6.5 Impact on existing operations from mixed use of 2- and 3-digit
MNCs under Sweden’s MCC
Potential impact on existing operations was raised in discussions with all market participants,
but was mainly a topic discussed with MNOs.
The alternative considered for mixed use of 2- and 3-digit MNCs is as described in section
4.3.1 above. This plan assumes that current 2-digit MNCs would remain unchanged and 3digit MNCs will be introduced in a separate range of the number plan, currently 70 – 99,
which would be replaced by 700 – 999. This way, 3-digit MNCs would be assigned in a
separate range not overlapping with 2-digit codes. Existing 2-digit MNCs will therefore
continue to unambiguously identify the operators and service providers to which they are
already assigned, and operators and service providers not able to switch to 3-digit MNCs
can therefore continue to use their existing 2-digit MNCs.
33
COM 2-C4-E ITU-T SG2 – Contribution 4, December 2012, “New Annex G for E.212 – MNCs under
new MCC for International mobile messaging services.
34
As 3GPP specifications generally assume an MCC code to represent a country, there may be some
issues which need to be addressed in this regard. These issues would generally be the same as
those that arise when multiple geographic MCCs are used by the same country. As this is already a
situation in several countries, it is assumed to be a fully manageable issue.
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6.5.1 Core and access network systems and implementations
In accordance with current specifications (ref. 3.2 above), systems and networks
components based on current 3GPP specification will in principle not support mixed use of
2- and 3-digit codes. In the event of changes, operators assume that required updates will
be available from equipment vendors in accordance with the evolution of specifications.
Operators expect some additional work with system updates and other administrative work if
3-digit MNCs were introduced. This includes both one-time work in connection with the
introduction of 3-digit MNCs as well as more continuous maintenance work due to increased
complexity.
One specific obstacle brought up in the discussions was the consequences of the
specification in 3GPP TS 23.122 Annex A “HPLMN Matching Criteria”. The problem
concerns the interactions between the network and mobile terminals, as the radio network
broadcasts the so-called Location Area Identity (LAI), which includes MCC and MNC. The
problem is complex as it concerns both network and the entire mobile terminal population35.
The problem is further discussed in the analysis section (section 7 below).
With the exception of the issues related to TS 23.122 above, operators did not envisage any
fundamental problems with mixed use of 2 and 3-digit MNCs, but generally emphasised the
need for more detailed studies in order to analyse the exact consequences of possible
changes.
6.5.2 Billing and mediation systems
Only minor impact is expected on billing and mediation systems:


For incoming roaming user, billing systems already supports both 2 and 3-digit
MNCs, although the case where a user comes from a country with a mix of 2 and 3digit MNCs under same MCC might need to be tested.
Some billing systems may only support 2-digit MNCs for domestic users. Other
MNCs would be classified as roaming. This may be an issue if it is the billing system
of an MNO hosting an MVNO with a 3-digit MNC. However, it would be a commercial
decision for such an MNO when and if to accept hosting an MVNO with a 3-digit
MNC. The MNO would be free to delay hosting of such MVNOs until it can support
the solution technically.
35
The issue is the same as brought up by 3GPP TSG CT WG1 in its “Reply LS on assignment of 3
digit MNC” (May 2012) in response to ITU-T SG2’s Liaison Statement “Assignment of 3 digit MNCs”
COM2 – LS129 – E (March 2012).
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6.5.3 Roaming agreements and related arrangements
Minor impact is expected on roaming agreements and involved systems, as the
implementations already support interaction with operators with both 2 and 3-digit MNCs.
However, in particular the MNOs (as well as some other service providers) emphasise two
critical assumptions:


Existing 2-digit MNCs already assigned will not be changed, and no overlapping 3digit MNCs will be assigned (i.e. if MNC “XY” is assigned, any 3-digit MNCs with
codes “XY0” to “XY9” would not be assigned).
Mixed use of 2 and 3-digit MNCs will be introduced in an internationally harmonised
and co-ordinated manner that will permit general specifications and network systems/
products to be upgraded in accordance with normal procedures.
6.5.4 Interconnection arrangements
Possible impact on interconnection arrangements was brought up in the discussions with
operators, but no potential impact could be identified.
6.5.5 Summary of potential impact on existing operations
The potential impact on systems and network elements are summarised in Table 5 below:
Areas of operation
Impact on MNOs
Impact om MVNOs and
service providers
Core and access network
systems
In principle minor impact,
except issue with terminals
(TS 23.122, etc).
Expect only minor impact.
Billing and mediation
systems
Roaming agreements and
related arrangements
Interconnection
arrangements
Amended specifications and
systems updates from
equipment vendors required.
Expect only minor impact as 2
and 3-digit MNCs already
supported for incoming
roamers.
Expect only minor impact as 2
and 3-digit MNCs already
supported for incoming
roamers.
Assume introduction of mixed
2 and 3-digit MNCs are
harmonised internationally.
Expect no impact
Expect only minor impact
Expect in principle no impact.
Should be noted that few
MVNOs with assigned MNCs
(if any) are providing services
requiring roaming.
Expect no impact
Table 5: Mixed use of 2 and 3-digit MNCs – Potential impact by areas of operation
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The following general comments from operators and other market participants were noted:



Introduction of mixed use of 2 and 3-digit MNCs need to be based on amendments to
general specifications so that they can expect support and updated systems from
equipment vendors.
The changes need to be introduced in an internationally harmonised manner when
system updates and support are available
With regard to the specific issues with 3GPP specification TS 23.122, a specific
technical solution or generally agreed arrangements for circumvention (or mitigation)
of the issue would will need to be found and agreed.
With these general assumptions, the general understanding of the responses is that the
expected changes and modifications from operator point of view would not be out of
proportion compared to normal workload for continuous system and network upgrades
necessary for new functions and services continually introduced in the network.
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7 Analysis of mixed use of 2- and 3-digit MNCs
Fundamentally, 3GPP specification TS 23.003 generally assumes that 2- and 3-digit
MNC codes will not co-exist under the same MCC. Any 3GPP compliant product
cannot be assumed to support mixed use of 2 and 3-digit MNCs until specifications
have been amended and products are updated and confirmed compliant with the new
specifications.
The main issues with mixed use of 2 and 3-digit MNCs will occur when a 3-digit MNC
is assigned to an operator with own radio access network.
Except for these aspects, the analysis and consultations with Swedish operators and
market participant do not indicate that introduction of mixed use of 2 and 3-digit
MNCs would be overly complex.
A possible intermediary solution could be to assign 3-digit MNCs to virtual operators
(MVNOs). According to previous analysis, a significant part of the demand for new
MNC resources is expected to come from MVNOs (in particular in the Utilities sector).
We have analysed the possibility to introduce mixed use of 2 and 3-digit MNCs under
Sweden’s MCC as described under 4.3.1 above.
In accordance with this plan, previously assigned MNCs can be maintained as 2-digit MNCs
for those operators and service providers that are unable to switch to 3-digit MNCs. These
MNCs would continue to be recognised on the first 2 digits. New 3-digit MNCs will be
allocated from a separate range, not overlapping the range of 2-digit MNCs.
Figure 8: Allocation of non-overlapping MNCs under same MCC
The possibility to maintain already assigned 2-digit MNCs for operators and service
providers unable to switch to 3-digit MNC, without considerable operations impact, is a key
element of the proposed plan36.
36
It may be noted that some earlier discussions may have been based on different assumptions.
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7.1 Required changes to standards and specifications
3GPP specification TS 23.003 generally assumes that 2- and 3-digit MNC codes will not coexist under the same MCC. This forms a general basis for all current 3GPP specifications. A
review of all specifications was outside the scope of this study, but is assumed that several
other specifications might be based on the general assumption in TS 23.003.
3GPP TSG CT WG1 also emphasise the specifications in 3GPP TS 23.003 in its response
(May 2012) to an ITU-T SG2 Liaison Statement requesting comments on how introduction of
3 digit MNC codes would impact existing networks.37 3GPP TSG CT WG1 further refers to
TS 23.122 and its Annex A to illustrate how the basic assumption is used in other
specifications and therefore deeply embedded in functionality and interworking of products.
Consequently, any 3GPP compliant product cannot be assumed to support mixed use of 2
and 3-digit MNCs until specifications have been amended and products are updated and
confirmed compliant with the new specifications.
The extent of specification changes and required product modifications may vary from one
product area to another. Some areas may require significant changes, for example products
impacted by TS 23.122. It is reasonable to assume that in some areas, required changes or
updates might be minimal, and there would only be a question of confirming or verifying
compliance with amended basic specifications.
The Swedish market participants responding to this survey generally emphasised the need
for internationally agreed standards and a common approach to implementation in order to
avoid disruptions and problems concerning for example roaming.
7.2 Impact on the different areas of operation
The following sections provide analysis of how mixed use of 2 and 3-digit MNCs might be
expected to impact on various areas of operation.
7.2.1 Core & access network systems, Mobile terminal behaviour
The impact on core and access network systems would generally be that:


3GPP specifications generally need to be amended and systems and network
elements need to be confirmed compliant with amended specifications.
The IMSI analysis would generally need to be modified. Given the fact that both 2
and 3-digit MNCs are already in use, and even in some mixed structures for a few
countries, the necessary changes do not appear overly complicated.
37
Stated by 3GPP TSG CT WG1 in its “Reply LS on assignment of 3 digit MNC” (May 2012) in
response to ITU-T SG2’s Liaison Statement “Assignment of 3 digit MNCs” COM2 – LS129 – E (March
2012).
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38
In communication protocols used between core network nodes , the MNC is usually coded
so that one of the three digits (four bits) is coded as Hex F (“1111”) in the case of 2-digit
MNCs. Otherwise; the MNC is interpreted as a 3-digit MNC. A 2 or 3-digit MNC should
therefore, in principle, always be easy to detect and properly processed independent of the
MCC.
However, the potential problem observed by participants in our survey and by 3GPP TSG
CT WG1 in its reply to ITU-T SG2 (see 7.1 above) is related to analysis and matching of the
SIM-MNC (part of IMSI on the SIM) and the MNC broadcast by the network over Broadcast
Control CHannel (BCCH). However, the exact nature of this problem may depend on how
the 3-digit MNC is used. Two scenarios are described below:
A. 3-digit MNC used by a new operator with radio access network (RAN), and
B. 3-digit MNC used by MVNO.
(A) 3-digit MNC used by an operator with own RAN
The matching algorithm as described in TS 23.122 Annex A is shown for an example
configuration in Figure 9 below:
Figure 9: Example of TS 23.122 matching of 2-digit MNC SIM on a 3-digit MNC network
The example in Figure 9 shows two aspects:


The scenario violates the basic assumption stated in TS 23.122: “Within a single
country (or area identified by a MCC) all networks shall broadcast a 2 digit MNC
code, or all networks shall broadcast a 3 digit MNC code. A mixture of broadcast 2
and 3 digit MNC codes is not permitted within a single country (or area identified by a
MCC).”
On the other hand, assuming a domestic terminal (SIM-MCC = BCCH-MNC):
38
E.g.: The GPRS Tunnelling Protocol (GTP), the S6a protocol between MME and HSS, as well as
MCC+MNC in the Location Area Identity (LAI) broadcast on the broadcast control channel (BCCH).
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o
o
Test (2) fails (=”No”) as the network MNC (BCCH-MNC) is a 3 digit MNC
(=“731”).
Test (3) fails (= “No”) as long as MNCs are not overlapping39, i.e.: BCCHMNC (“731”) not equal SIM-MNC (“07X”), for all values of “X”.
A failing test should mean that the terminal with MCC+MNC=”24007” should be recognised
as a roaming subscriber and would be able (or not able) to register on the network
depending on any (national) roaming agreements.
Given the fact that the scenario violates the basic assumption of TS 23.122, the behaviour is
in principle undefined, but might still work. It is therefore interesting to look at the situations
in some countries/regions where variations of 3-digit MNCs are currently used.
The current assignments of MNCs in India are particularly interesting. They seem to prove
that the scenario described above may work, at least under certain circumstances. India has
two MCCs, 404 and 405. Under MCC 405, MNCs are now assigned as 3-digit MNCs, but a
number of 2-digit MNCs have also been assigned. Mixed (‘non-overlapping’) use of 2 and 3digit MNCs therefore occur in some circles. Under MCC 404, there are only 2-digit MNC
assignments.
The situation looks as follows for the circle of Orissa, India:
Circle
Operator
MCC
MNC
Technology/spectrum
Orissa
Orissa
Orissa
Orissa
Orissa
Orissa
Orissa
TATA DOCOMO
AirTel
Vodafone IN
IDEA
AIRCEL
CellOne
Reliance
405
405
405
405
404
404
404
041
53
753
850
28
76
52
GSM 1800
GSM 900
GSM 1800
GSM 1800
GSM 900
GSM 900 / UMTS 2100
GSM 900
Table 6: MNC assignments for the circle of Orissa, India
A dual band 900/1800 terminal will “see” both 2-digit and 3-digit MNCs under MCC 405 in
this circle.
It might be noted though, in this and similar cases, that a dual 900/1800 terminal made
according to specifications prior to 3GPP R98 would “see” all networks and is therefore likely
to get problems with recognition of the 3-digit MNCs used for the GSM 1800 networks. On
the other hand, a GSM 900-only terminal (typically older than 1997) should not experience
problems in this case, as it would not “see” the 1800 networks with 3-digit MNCs. In any
event, such problems seem limited to generations of terminals which are now fairly old.
39
“07” does not “overlap” with “731”. “Overlap” means two first digits equal, e.g. “07” would overlap
with “077”, and test (3) would have wrongly succeeded.
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(B) 3-digit MNC used by MVNO
If a 3 digit MNC is used by an MVNO, the case would in principal be more similar to the case
where a subscriber with a 3 digit MNC is roaming in the network of an MNO with a 2-digit
MNC. This scenario is illustrated in Figure 10 below:
Figure 10: MVNO with 3 digit-MNC / MNO with 2-digit MNC
The MVNO scenario Figure 10 would be in conflict the assumptions in specification TS
23.122, but as for scenario (A), it could still provide correct result as shown in Figure 11:
Figure 11: MVNO subscriber logic flow
The MVNO subscriber should be recognised as a roaming subscriber (and eventually as an
MVNO subscriber) as test (4) would fail for any non-overlapping MNC combinations used for
the MVNO and MNO respectively.
However, compared to scenario (A) where the 3-digit MNC is broadcast over the RAN and
potentially will impact the entire terminal population, scenario (B) will only impact the MVNO
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subscribers, for example M2M devices. A new MVNO with a 3-digit MNC should in principle
be able to ensure that new subscriber terminals, such as M2M devices, are compliant with
amended specifications supporting mixed use of 2 and 3-digit MNCs under same MCC. This
scenario may also in many cases be handled as a “domestic case” as many M2M
applications served by MVNOs will not require international roaming.
The conclusions to be drawn from the analysis of both scenarios (A) and (B) are therefore:
 The issues related to home network matching and the specifications in TS 23.122 is
generally complex. If MCC+MNC are broadcast over a radio network, there will be a
potential impact on all mobile terminals roaming in the coverage area.
 In principle, changes of 3GPP specifications will be required
 However, some (or most) scenarios may work although not explicitly defined in
existing specifications. As long as 2 and 3-digit MNCs are non-overlapping, systems
and terminals may work as far as TS 23.122 is concerned, and this seems to be
confirmed by the example from India.
 Scenario (B), where 3-digit MNCs are used by MVNOs, could be feasible for early
implementations of 3-digit MNCs as implications can be limited to country of
deployment and in most cases even to the MNO and MVNO involved.
7.2.2 Billing and mediation systems
Billing and mediation systems generally support both 2- and 3-digit MNCs, but systems are
generally operator specific, and operators need to analyse their specific systems to identify
any potential issues.
It was noted that operators consulted as part of this study did not expect any major
challenges in this area, as both 2 and 3-digit MNCs are supported in connection with
roaming.
It is also reasonable to assume that because billing is an area in constant development in
order to support new services and technologies, the modifications and testing necessary to
support the introduction of mixed use of 2 and 3-digit MNCs may fall well within these
programmes without causing substantial extra workload.
7.2.3 Roaming arrangements and agreements
As the already assigned 2-digit MNCs can remain unchanged for operators and service
providers unable to change to 3-digit MNCs (in principle including operators with roaming
networks), there should be no impact on existing roaming agreements and implementations.
The impact of new 3-digit MNCs in international roaming relationships needs to consider the
following aspects:

Existing use of 3-digit MNCs
Some countries using 3-digit MNCs are using the first two digits to designate
operator, e.g. USA. India, however, assigns unique MNCs for each operator in each
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‘circle’ (licence area) and assignments are made in a manner that requires all three
digits of the MNC to be analysed in order to identify an operator. An example is
shown below:
MCC
MNC
Operator
Circle
Technology/spectrum
405
405
405
405
810
811
818
819
AIRCEL
AIRCEL
Uninor
Uninor
Uttar Pradesh (East)
Uttar Pradesh (West)
Uttar Pradesh (West)
Andhra Pradesh
GSM 1800
GSM
GSM
GSM
Table 7: Example of 3-digit MNC assignments, India
We can therefore assume that the ability to deal with 3-digit MNCs in international
roaming agreements is working at present.

Existing mixed use of 2 and 3-digit MNCs
There are ‘circles’ in India with both 2 and 3-digit MNCs under same MCC 405 and
these are used in international roaming relations (the MNCs shown in Table 6 above
are examples).
We can therefore assume that mixed use of 2 and 3-digit MNCs in international
roaming relations is working at present.

Exchange of accounting information
Possible impact on procedures for exchange of roaming accounting information, i.e.
related to Transferred Account Procedure (TAP) records, etc., has been discussed.
IMSI codes are transferred as part of the transactions serving their main purpose of
identifying roaming subscribers and their home operators, as basis for billing and
settlement, but the TADIG code naming convention is used for the information being
transferred among operators for accounting purposes. The different code naming
conventions should provide some level of “insulation” between roaming accounting
procedures and the structure of the IMSI (MCC+MNC)40.

Gradual introduction of new 3-digit MNCs
Under current plan, existing 2-digit MNCs will be maintained for operators and
service providers unable to change to 3-digit MNCs without unreasonable efforts. By
this reason, there will be no “cut over” requiring changes to existing agreements and
relations.
Consequently, 3-digit MNCs requiring analysis of all three digits to identify and operator as
well as mixed use of 2 and 3-digit MNCs under same MCC already seem to be working in
international roaming relationships as one significant country already uses it in its relations
40
For the bilateral roaming model, there is normally a one-to-one relationship between TADIG codes
and MCC/MNC pairs (e.g. FRAF1 is used for Orange France instead of the PLMN ID (MCC/MNC
pair) 20801), but variations may occur, in particular in connection with roaming hubbing.
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with the rest of the world. Furthermore, as introduction of 3-digit MNCs would be gradual,
there should be no disruptive implications on existing roaming relationships. New
agreements involving operators with 3-digit MNCs would be introduced and tested gradually
as they are taken into use.
This conclusion is consistent with the general responses from the Swedish operators
consulted for this study. The operators did not envisage any significant issues regard
roaming, which would differ from the ordinary operational processes.
7.2.4 Interconnection arrangements
Based on analysis and consultations with Swedish operators, no possible impact could be
seen with regard to interconnection and related arrangements.
7.3 Potential scenarios
In principle, 3GPP specifications will need to be updated in order to support mixed usage of
2 and 3-digit MNCs in existing 2-digit MNC areas.
However, the experience from India as well as the analysis of key specifications involved
show that mixed use of 2 and 3-digit MNCs might still be working (possibly requiring only
some minor modifications to some systems). The implications of introducing 3-digit MNCs
would nevertheless be more complex if a new 3-digit MNC is assigned to an operator using it
in a radio access network (using licensed or unlicensed spectrum).


As discussed in 7.2.1 above, assigning 3-digit MNCs to operators with own radio
access network raises more complex issues as MNCs are broadcast and possibly
impacts all terminals able to listen to the broadcast (depending on spectrum and type
of technology).
Assigning 3-digit MNCs to MVNOs seems to have less complex implications as
MNCs would not be broadcast. MVNOs are national roaming implementations, and
3-digit MNCs (also in mix with 2-digit MNCs under same MCC) are already seen
working in international roaming scenarios, which technically are essentially similar.
As many MVNO operations do not have international roaming agreement the
scenarios are further simplified with limited (or no) cross-border impact41.
41
The responses to our consultations with Swedish operators and other market participants indicate
that most MVNOs use own MNCs for services not requiring roaming.
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The two scenarios are summarised in Figure 12 below:
Figure 12: Scenarios for introduction of mixed use of 2 and 3-digit MNCs
Scenario A above may be a longer term solution, while alternative B for operators
without radio access networks could be an initial approach suitable for MVNOs,
specialised MVNO providing M2M services, SMS service provider, etc. This would
respond to the strong demand for additional MNC numbering resources to be expected
from virtual operators, in particular within the Utilities and Security sectors (see section 5
above).
With limited impact on systems and operations beyond those directly concerned (MVNO
and its subscribers + hosting MNO), it might be possible for operators and market
participants to introduce mixed use of 2 and 3-digit MNCs before full support is available
through official system releases, etc.
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8 Analysis of the use of shared MNCs under geographic
MCC
The normal role of the MNC, as a unique identifier, is to enable an operator to build
own network infrastructure and issue its own SIM cards (or profiles) to its
subscribers. Shared use of MNC resources in order to better utilise limited numbering
resources would require some particular considerations and solutions.
Use of an “HLR Proxy”, serving as a gateway for several operators using same MNC,
but different IMSI sub-ranges, may be a possible way to implement shared use of
MNCs. Other operators would only see the ordinarily assigned MNC. This solution
could work well for operators without radio networks (MVNOs, SMS service providers,
etc.).
For operators with radio networks, for example small cell operators, special
arrangements would be required to avoid potential conflicts caused by conflicting
MNC broadcasts.
Shared use of MNC resources is an alternative way to make more efficient use of limited
numbering resources. It may be a suitable alternative for certain services and applications
and may therefore be used as a complement to other approaches to more efficient use of
MNC resources.
To distinguish between mobile operators and service providers using the same MNC, the
leading digits of the MSIN can be used as shown in Figure 13 below:
Figure 13: Shared MNC – Use of leading digits of MSIN to identify operator or service
provider
8.1 Shared MNCs as alternative to unique MNC
The question is to what extent it would be possible to use a shared MNC (in combination
with an IMSI sub-range, “Sub-MNC”, identifying participating operators or service providers)
to provide functionality similar to that of a conventional MNC assignment.
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As the basic objective, an MNC enables an operator or service provider to create services
tailored to specific customer requirements through the ability to issue own SIM cards and
create and operate mobile network infrastructure (core and/or radio access networks).
Technically, the MNC serves three basic functions in a mobile network:



The MNC is the basic identifier of the operator’s or service provider’s network and
subscribers. It is required for:
o Issuing own SIMs (cards or profiles)
o Building and operating own core and radio access networks
o Creation of signalling addresses for use between networks (as derived from
IMSIs using E.214 translation).
The MNC is broadcast by the radio access network (as part of the Location Area
Identity, LAI) enabling mobile terminals to identify available radio networks.
The MNC is part of the E.212 global identification plan, forming the basis for
fundamental mobile services such as international roaming.
Sharing MNCs may not be a problem for private networks that are completely insulated from
interaction with other private and public networks42, but for networks which are either
interconnected with public networks or have some level of signalling interaction (typically
through the radio interfaces) with subscribers of other networks, a solution is needed.
8.1.1 Shared MNC as identifier of networks and subscribers
An operator identified by an IMSI sub-range (“sub MNC”) will not be recognised by other
networks, nor can an operator or service provider issue own SIMs (cards or profiles) without
a uniquely assigned MNC.
A possible solution is to assign the shared MNC to a central entity, which can facilitate
routing based on IMSI sub-ranges. A solution is proposed in a recent study commissioned
by the Dutch Ministry of Economic Affairs43. The solution may be referred to as an “HLR
Proxy” solution and is shown in Figure 14 below.
42
Typical example would be a network based on 3GPP technology therefore requiring standardised
numbering resources, but operating as a closed private network with no interaction with other
networks because of geographical, spectral or other technical separation.
43
Report on Ministry website: http://www.rijksoverheid.nl/ministeries/ez/documenten-enpublicaties/rapporten/2013/07/03/gedeeld-gebruik-mnc-s-voor-m2m-toepassingen.html
Presentation available on Stratix Consulting website: http://www.stratix.nl/projecten/37?view=project
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Figure 14: "HLR Proxy" solution for MVNOs sharing an MNC
This solution would work as follows:


MNOs interact with a “regular” MVNO/MVNE.
The “HLR Proxy” routes traffic to customers/MVNOs based on IMSI ranges.
The customer advantages are:


Avoiding “lock-in” with MNO
Enabling national roaming (for network redundancy purposes) through “multi-MNO”
connectivity
8.1.2 Shared MNC in the Radio Access Network (RAN)
Location Area Identity (LAI) broadcast is a particular problem with shared MNCs. In
response to a LAI broadcast, all terminals/devices in its coverage area would attempt to
connect. If the network cannot serve a terminal/device because its IMSI range is not
recognised, it will be rejected. Upon rejection, the terminal/device will not reconnect to that
MNC, causing problems for all networks sharing the same MNC. In principle all sharing
MNCs could eventually block each other’s users. The scenario is shown in Figure 15 below.
Figure 15: Problem with broadcast of shared MNC
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This means that a shared MNC should not be broadcast, but should be used for virtual
networks only. An alternative to the above configuration would therefore be to let the two
operators identified IMSI sub-ranges act as MVNOs connected to an “HLR Proxy” as shown
in Figure 16 below.
Figure 16: Shared MNC used instead for MVNOs connected through "HLR Proxy"
Figure 16 shows an example where the two MVNOs, A and B (MNC 55, IMSI sub-range 11
vs. 22), access their subscribers via private or public small cell access network and/or
through a wide area MNO access network. The private or public small cell access network
may (or may not) be part of the same commercial operations as the operators A and B, but
would need to be identified by a different MNC, in the example MNC 56. The same MNC
might be used for several small cell access networks connected to the “HLR Proxy” and the
MVNOs shown in the example, but it is important to observe that use of shared MNCs in
configurations other than pure MVNO operations would require additional MNC resources.
8.1.3 International roaming
International roaming for an operator identified by an IMSI sub-range instead of an MNC
would in principle not be impossible. However, a possible solution could be shared roaming
arrangements with the other operators and service providers sharing the common MNC, as
the top level assigned MNC can enter roaming agreements as any other operator with
assigned MNC.
On the other hand, it should be noted that the typical M2M customers (e.g. electricity
distributors and other utilities), which may use this type of configuration, may not require
international roaming.
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8.2 Implementation scenarios
It follows from the discussions above that there are several issues with shared MNCs, which
need to be considered:




Shared MNCs need co-ordination to avoid addressing conflicts. In principle, this may
be the responsibility of the NRA or it may be the responsibility of an entity (if any) to
which the shared MNC is assigned.
In the case of an “HLR Proxy”, there should in principle be entity responsible for the
shared MNC, who could assume coordination responsibility
The responsibility (governance) for an “HLR Proxy” would also need to be defined. In
principle, it could be an independent commercial player (e.g. an MVNE) or it could be
the common responsibility of the participating service providers (MVNOs)
Inappropriate use of shared MNCs in radio access networks could be harmful for
other operations and their subscribers. Specific restrictions will therefore be required,
and an NRA would need to take a coordinating responsibility if it assigns shared
MNCs.
As for mixed use of 2 and 3-digit MNCs, we may consider two main scenarios for
assignment of shared MNCs as shown in Figure 17 below:
Figure 17: Implementation scenarios - Shared MNCs
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9 International outlook
The Dutch regulator is keenly aware of the growing demand for additional MNC
resources and has just recently finalised a revised E.212 numbering plan. The plan
has specific codes allocated for introduction of shared MNCs based on an “HLR
Proxy” as described in the previous sections. The Dutch regulator is also considering
assignment of 3-digit MNCs under its revised numbering plan, although decisions
remain to be taken in that regard.
The Norwegian regulator also sees growing demand for MNC resources by new
operators and service providers outside the traditional types of users. An MNC has
been assigned on trial basis to an operator using 3GPP compliant technology (LTE)
for a closed private network. The assigned MNC for the trial is a 3-digit MNC for
shared use.
The North American experience may be interesting. Allocation of 3-digit MNCs was a
regulatory mandate, and 3GPP specifications were amended in connection with the
introduction of PCS1900.
The Indian regulator now assigns unique MNCs to operators in each licence area
(‘circle’). To get enough MNC resources, the regulator started to assign 3-digit MNCs
from around 2008-2009. As old 2-digit MNCs are still in use, the result is now a mix of
2 and 3-digit MNCs under one of the country’s MCCs (the “405”.)
We have looked at some related developments in a few other countries: Netherlands,
Norway, USA and India.
9.1 Netherlands
The Dutch regulator has just finalised a revised E.212 numbering plan. 2-digit MNCs are
currently used and approximately 30 codes are assigned at this time. The regulatory body
(Ministry of Economic Affairs) is keenly aware of the growing demand for MNC resources
coming from new mobile applications and service providers. To increase availability of MNC
resources, there have been several recent as well as ongoing studies concerning MNCs for
shared use and the possible use of 3-digit MNCs.
Substantial work has been done in order to find suitable solutions for the M2M sector, in
particular the Utilities sector, where the problem of MNO “lock-in” of larger M2M customers
has been seen as a particularly important problem to resolve.
The regulator is also experiencing growing demand for MNC resources for private networks
(typically GSM 1800 based networks using unlicensed frequency bands) and it is
considering ways to meet this demand.
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9.1.1 Mixed use of 2 and 3-digit MNCs
The decision to start assigning 3-digit MNCs is still to be taken, but the proposed numbering
plan opens for the assignment of 3-digit MNCs in certain sections of the numbering plan not
currently used. The plan is shown in Table 8 below:
MCC / MNC range
MNC / number of digits
204 / 0X – 2X
204 / 3XX – 5XX
204 / 6X
204 / 7XX – 8XX
204 / 90 – 91
204 / 92 – 99
2-digit
2 or 3-digit
2-digit
2 or 3-digit
2-digit shared use
Reserved
Table 8: Proposed MNC numbering plan for the Netherlands
If decision is taken to assign 3-digit MNCs in the number ranges as indicated in Table 8, we
assume it will be done in a non-overlapping manner as currently planned for Sweden and
described in previous sections of this report (i.e. any initial 2-digit combination used for 2digit code will not be used for 3-digit codes). We understand that the concerns regarding
assignment of 3-digit MNCs reflect the same issues as discussed in previous sections of this
study.
9.1.2 Use of shared MNCs
In order to increase the availability of MNC numbering resources, a specific concept has
been developed for shared use of MNCs under a so-called “HLR proxy”44. The concept is
discussed earlier in this study (see section 8.1.1 above). In the proposed revised E.212
numbering plan, specific codes have been dedicated for “HLR Proxy” providers.
9.2 Norway
Regular MNCs are assigned as 2-digit codes, and less than 20 codes are assigned at this
time.
The NRA is aware of growing demand for MNC resources from new applications and service
providers (e.g. M2M applications in the Utilities sector), and has continuous discussions with
market participants over these issues.
One MNC is currently assigned to a private network on a temporary trial basis. This network
uses 3GPP based technology (LTE) for a private network and needs MNC numbering
resources in order to properly configure the equipment. The network has its own radio
44
Concept developed by Stratix Consulting is described in report available on the website of the
Ministry of Economic Affairs: http://www.rijksoverheid.nl/ministeries/ez/documenten-enpublicaties/rapporten/2013/07/03/gedeeld-gebruik-mnc-s-voor-m2m-toepassingen.html
PowerPoint presentation of the concept is also available on Stratix Consulting website:
http://www.stratix.nl/projecten/37?view=project
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access network, but has no connections or interactions with public network as it operates in
a geographical area separated from other networks. The case illustrates the upcoming need
for MNC numbering resources for private networks using 3GPP compliant technology.
The MNC assigned temporarily to the private network is a 3-digit MNC for shared use. The
NRA has specified the leading MSIN digit (IMSI sub-range) to be used by the private
network operator.
9.3 USA
The USA uses the MCCs 310 to 316. 3-digit MNC codes are assigned using the so-called 0suffix rule (see section 3.5 above). The 0-suffix rule means that MNCs are assigned in the
format “XY0”, so that operators are recognizable by the 2 leading digits of the MNC.
With the introduction of PCS1900 in North America, it was a regulatory mandate to allocate 3
digit MNCs.
The 3-digit MNC was first defined in 3GPP specification release R98 (functionally freeze by
early 1999).
Following the mandate to allocate 3-digit MNCs for PCS1900 in North America, 3GPP
specifications were amended, for example including the current specifications in Annex A to
3GPP specification TS 23.122.
It should be noted that the use of 3-digit MNCs was a mandate already at introduction of
PCS1900, so that specifications could be amended at an early stage. However, the
experience from North America proves that the effectiveness of a regulatory mandate should
not be underestimated when imposed in a harmonised way for a larger market.
The 0-suffix rule mentioned above was a transition arrangement allowed because of
technical constraints, but is still in place. Nevertheless, it shows how special arrangements
can be made to work around practical problems.
9.4 India
India uses the two MCCs 404 and 405. 2-digit MNCs are assigned under MCC 404 and,
since around 2008-2009, 3-digit MNCs are assigned under MCC 405. India assigns a unique
MNC to each operator in each licence region (‘circle’) and use of 3-digit MNCs under MCC
405 was therefore necessary in order to create sufficient amount of MNC resources.
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3-digit MNCs under MCC 405 are assigned in a manner that requires all three digits to be
analysed in order to identify an operator. An example is shown in Table 9 below:
MCC
MNC
Operator
Circle
Technology/spectrum
405
405
405
405
405
405
405
405
809
810
811
818
819
820
821
822
AIRCEL
AIRCEL
AIRCEL
Uninor
Uninor
Uninor
Uninor
Uninor
Kerala
Uttar Pradesh (East)
Uttar Pradesh (West)
Uttar Pradesh (West)
Andhra Pradesh
Karnataka
Kerala
Kolkata
GSM 1800
GSM 1800
GSM
GSM
GSM
GSM 1800
GSM 1800
GSM
Table 9: India - Examples of MNC assignments
Considering the MNCs “81X” in the example above, all three digits of the MNCs need to be
analysed in order to distinguish AIRCEL (810, 811) from Uninor (818, 819).
There is a mix of 2 and 3-digit MNCs assigned under MCC 405. For example:



Airtel has 2-digit MNCs 51 – 56 assigned for various circles
Vodafone has 3-digit MNCs 750 – 756 assigned for various circles
IDEA Cellular has 3-digit MNCs 845 – 853 assigned for various circles
For a specific circle, these assignments result in a mix of 2 and 3-digit MNCs also at circle
level. An example from the circle of Orissa is shown in Table 10 below:
Circle
Operator
MCC
MNC
Technology/spectrum
Orissa
Orissa
Orissa
Orissa
TATA DOCOMO
AirTel
Vodafone IN
IDEA
405
405
405
405
041
53
753
850
GSM 1800
GSM 900
GSM 1800
GSM 1800
Table 10: MNC assignments under MCC 405 for the circle of Orissa
Consequently, a mix of 2 and 3-digit MNCs will be broadcast in the circle of Orissa.
Finally, as all three digits in 3-digit MNCs need to be analysed to identify an operator,
roaming agreements need to be (and effectively are) established at circle level.
Consequently, the experience from India indicates that the following cases are working at
national and international level:



Analysis of all three digits in 3-digit MNC (irrespective of whether there is mixed use
2 and 3-digit MNCs or not)
Mixed use of 2 and 3-digit MNCs in roaming agreements and relations.
Broadcast of 2 and 3-digit MNCs with same MCC in same region (‘circle’)
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10 Conclusions and recommendations
The commercial and technical developments described in this report are just
examples of how new services, business models and technological developments are
driving the demand for MNC resources. The E.212 numbering plan and eligibility
criteria for assignment of MNCs therefore need to adapt to changing market
requirements.
Demand for more MNC resources can be met by more efficient use of existing
resources and by creating new resources, i.e. use of shared MNCs, introducing mixed
use of 2 and 3-digit MNCs, and using MNCs under new shared MCCs (“90X”).
A transition to mixed use of 2 and 3-digit MNCs would generally require amendment
of 3GPP specifications, but experiences from some other countries and regions (e.g.
India) suggest that the issues involved might be more manageable than previously
expected. It also appears to be a less complex issue to introduce 3-digit MNCs for
operations without radio access network. A possible approach could therefore be:



Announce target date(s) for introduction (i.e. when to start assignments) of 3digit MNCs, possibly as a two-stage process starting with 3-digit MNC
assignments to service providers without own radio network. In the second
stage, all new MNC assignments would be 3-digit MNCs.
Give reasonable time for testing of key scenarios as well as for further
clarification of details on variations of existing mixed use of 2 and 3-digit MNCs
in some other regions
Accept delayed (or partially delayed) introduction of 3-digit MNCs if tests reveal
problems demonstrating need for more time.
Introducing 3-digit MNCs is one of several ways to create more MNC resources.
Different types of MNC resources (geographic, non-geographic) may suit different
types of services and applications. The Regulator could therefore adopt policies for
assignment of various MNC resources (2 vs 3-digit codes under geographic MCC,
MNCs under shared MCCs “90X”, etc.) depending on service and application types.
10.1 Reasons for change
As discussed in the first sections of this report, there are a number of new services,
applications and business models which may require MNC resources. Such new users of
MNC resources may include specialised MVNOs serving the M2M market, small cell
networks for in-house coverage operated by independent providers; independent roaming
and SMS service providers, etc.
In addition, the success and increasingly wide adoption of 3GPP compliant technology
means that such technology also will be deployed for private networks. Initially, these
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networks may be closed private networks, but this may be an undesirable and even
unacceptable longer term limitation in an even more interconnected world. Proper numbering
resources will also be required for correct system configurations and to avoid conflicts
among systems and terminals in the radio access domain.
The list of new potential users of MNC resources cannot be complete as service and
technology innovation are continuous processes. The commercial and technical
developments described in this report are just examples of how fragmentation of the mobile
services value chain, new services and technological developments are resulting in a
steadily growing number of operations requiring MNC numbering resources. Figure 18
shows an overview of various players in a fragmented mobile telecommunications industry.
Figure 18: Fragmentation of the mobile telecommunications industry
In addition to the above come the widely discussed issues of “operator lock-in” and SIM
provisioning for M2M devices usually embedded into various products at point of
manufacture. The SIM card was a solution for the traditional mobile phone, enabling the
individual mobile phone user to change subscriber by changing the SIM card in the phone.
An M2M customer, however, with very large numbers of devices deployed in the field would
need a different mechanism in order to change operator.
In response to these problems, the GSMA has developed the specification for the
Embedded SIM, which enable remote ‘over-the-air’ provisioning and management of
operator profiles. The Embedded SIM standard resolves the issue of remote in-the-field
provisioning of SIM profiles once products with M2M devices are sold or deployed in the
field. It also resolves the problem of “operator lock-in”. However, it will not eliminate the role
of specialised service providers (typically MVNO type operations) providing specialised
services to niche market segments at domestic as well as international levels. The
Embedded SIM will eventually help MVNOs as well as MNOs improving their service
offerings.
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The E.212 numbering plans and eligibility criteria for assignment of MNCs therefore need to
adapt to changing market requirements. It is important that innovation and market
development are not unnecessarily constrained by shortage of MNC resources and rigid
eligibility criteria for number assignment that might follow.
10.2 Possible solutions and scenarios
The demand for more MNC numbering resources can be met in two ways:
1. More efficient use of existing resources
Existing numbering resources may be used more effectively through use of shared
MNCs. This study has focused on the following solution:
o The leading digits of the MSIN (IMSI sub-range) may be used to identify an
operator or service provider. However, this may result in addressing conflicts
as the MNC is assumed to be a unique identifier of an operator or service
provider45. The “HLR Proxy” model developed in the Netherlands and
described in this report (see section 8 above) presents a solution to this
problem. For the further discussions in this study, we have therefore assumed
this model for MNC sharing46.
2. Creation of more numbering resources
More MNC numbering resources can be created in many different ways. In this
study, we have discussed the following two possibilities47:
o Mixed use of 2 and 3-digit MNCs under geographic (country specific) MNCs.
Already assigned 2-digit codes can be maintained for operators and service
providers unable to change without unreasonable efforts. New 3-digit codes
would be assigned in a separate address range not overlapping with existing
2-digit codes.
o MNCs under existing and new shared country codes, i.e. MCCs “901”, “902”,
…”90X”. Use of new non-geographic MCC codes as alternative to the country
specific codes, might be an important way to reduce pressure on geographic
MNC addressing resources.
The main focus of this study has been on the creation of more MNC resources through
mixed use of 2- and 3-digit MNCs and use of IMSI sub-ranges for sharing MNCs.
The shared MNC solution, using IMSI sub-ranges, is in principle not in conflict with existing
standards and specifications if implemented using an “HLR Proxy” as discussed in this
report. However, broadcasting a shared MNC could result in harmful addressing conflicts.
45
Standards and specifications (ITU-T E212, 3GPP) generally assume that the MNC uniquely
identifies a network and shared MNCs therefore introduces a risk of addressing conflicts
46
The alternative would be that networks are completely insulated from each other (with regard to for
example: geography, spectrum, technical standards, etc.)
47
Other ways of creating more MNC resources, but not further discussed in this study, includes e.g.:
additional geographic MCCs, more radical transition to 3-digit MNCs replacing all existing 2-digit
codes.
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Special solutions would therefore be required to support operators with own radio access
networks (see 8.1.2 above). “HLR Proxy” is primarily a suitable solution for MVNOs.
For mixed use of 2- and 3-digit MNC under same MCC, 3GPP specifications will generally
need to be amended. Table 11 below provides a summary of available MNC resources and
issues (if any) which need to be resolved in order to use these MNC resources.
Mixed use of 2 and 3digit MNCs
Standards and
specifications
(ITU-T E.212,
3GPP, etc.)
MVNOs and
other service
providers
without radio
access
network
Radio Access
Networks
 Generally require
amendment of 3GPP
standards and
specifications.
 Network equipment
and systems to be
updated according to
new specifications
 Scenario with MVNO
using 3-digit MNC
seems less complex
 However, amendment
of standards and
specifications still
required (verification
of functionality ref. TS
23.122 Annex A)
 RAN broadcast of 3digit MNC raise more
complex issues
 Issues regarding
3GPP TS 23.122
must be resolved.
Possible impact on
entier terminal
population
Sharing MNCs by use of
IMSI sub-ranges and
“HLR Proxy”
 In principle, no
violation of existing
standards
 “HLR Proxy” solution
most suitable for
MVNOs (i.e. no radio
access)
 Shared MNCs should
not be broadcast
(problems with
addressing conflicts)
 Special configuration
using separate MNC
would be required
(8.1.2 above)
MNCs under new
shared MCCs (“90X”)
 Compliant with
standards and
specifications
 MNCs may be
assigned as 3-digit for
new MCCs (i.e.
except for “901” that
exists already
 Should be no
particular issues if 2digit MNCs
 Verification of
functionality required
if 3-digit MNC, ref TS
23.122 Annex A
 Correct functionality
needs verification
(scenario would be
similar to operating
multiple geographic
MCCs per country)
Scenarios requiring further study regarding amendments of 3GPP standards and specifications,
updates of networks and systems for compliance etc.
Special configuration required (ref 8.1.2 above).
Table 11: Main points of analysis - Mixed used 2 & 3 digit MNCs / shared MNCs / “90X”
However, despite current status of specifications, actual experiences from some countries
and regions (in particular from India) suggest that there might be few real obstacles to
introduction of mixed use of 2 and 3-digit MNCs. Considering a gradual introduction of 3-digit
MNCs, using 3-digit MNCs for a network broadcasting MNCs over the radio network would
have more complex implications than in a network without radio network (MVNO, SMS
service provider, etc.). If used for broadcast over the radio network, use of a 3-digit MNC
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would in principle impact the entire mobile terminal population. This suggests that 3-digit
MNCs could be introduced in two phases starting with operators and service providers
without radio access networks. This would meet the demand for MNCs for MVNOs targeting
the growing MVNO market. Full transition to 3-digit assignments might follow at later date.
Table 12 below provides an overview of how different administrative and technical solutions
(3-digit MNCs, “HLR Proxy” solutions, new MCCs, and embedded SIMs) can be used in
various areas to effectively manage limited MNC resources.



3-digit MNCs may initially be most suitable for operators without radio access
network, but may eventually be used for all categories.
MNCs under “90X” MCCs would be suitable for services that typically transcend
borders or serving M2M devices crossing borders in ordinary use (e.g. in automotive
applications).
Embedded SIM is an effective solution for remote management of SIMs for M2M
customers with large numbers of devices in the field, but should not be seen as a
substitute for specialised MVNOs requiring MNC resources.
Examples of
applications /
services
Utilities/security –
Specialised MVNOs
Automotive –
Specialised MVNOs
Public small cell
networks
Private small cell
networks
SMS Service
Providers
Roaming Service
Providers
OTT VoIP Service
Providers



(1)
(2)
(3)
(4)
(5)
2 digit MNCs
under
geographic
MCC
3 digit MNCs
under
geographic
MCC




2
( )
2
( )
5
( )
5
( )
5
( )
( )
( )
( )
( )
( )
Shared
MNCs
(“HLR
Proxy”)
MNCs under
nongeographic
shared
MCCs/“90X”

Embedded
SIM solution



2
2
3
( )
4

4

4

Suitable for the service/application and efficient use of MNC numbering resources.
Possible/suitable for the service/application, but not the most efficient use of MNC numbering resources.
Possible alternative, but not assumed to be the best option for service/application.
SIMs issued by foreign MNO are currently used for automotive applications in order to obtain national
roaming (also used in other sectors, e.g. Utilities, but seems more widely used in the automotive sector).
Use of 3-digit MNCs for small cell networks should be introduced in a phase 2 after introduction for
operators and service providers without radio networks.
Shared MNCs and “HLR Proxy” solution may be possible, but require special technical arrangements
(see section Error! Reference source not found.)
Alternative if MNCs under suitable shared MCC (“90X”) not possible to obtain (see 6.4 above).
Alternative if neither 3-digit MNC nor MNC under shared MCC (“90X”) possible to obtain.
Table 12: Suitable use of various methods for creation of new MNC numbering resources
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10.3 Recommendations
The study has confirmed the need for more MNC resources to meet demand from an
increased number of players in the mobile telecommunications industry. This is the result of
new services, applications and business models, and the Swedish Post and Telecom
Authority (PTS) as National Regulatory Authority (NRA) has to make sure that shortage of
MNC resources will not artificially constrain service innovation and competition. We therefore
make the following recommendations covering four areas:




Mixed use of 2 and 3-digit MNCs under the Swedish geographic MCC 240
Shared use of MNCs under the Swedish geographic MCC 240
MNCs under shared MCCs “90X”.
General policies to further safeguard MNC resources
10.3.1 Mixed use of 2 and 3-digit MNCs under Swedish MCC 240
ITU-T Recommendation E.212 states that the length of the MNC, 2 or 3 digits, is a national
matter. Considering the introduction of mixed use of 2 and 3-digit MNCs under same MCC,
harmonisation among European countries would be natural and is already in process within
CEPT ECC/NaN. However, some countries may take the lead in introducing mixed use
based on their specific national situation and requirements.
The following approach should be considered by the NRA:



Announce target date(s) for introduction (i.e. when to start assignments) of 3-digit
MNCs.
o A possible two-stage process could be considered, starting with 3-digit MNC
assignments to service providers without own radio network.
o In the second stage, all new MNC assignments would be 3-digit MNCs.
The time schedule should permit reasonable time for:
o System updates and testing of key scenarios. The NRA could make available
resources for testing such as numbers, spectrum, etc. as might be required.
The NRA may also assist in organisation of test programmes (e.g. organise
technical forums, etc.).
o Further clarify details on variations of existing mixed use of 2 and 3-digit
MNCs in some other regions (e.g. India). This would include details on
regulatory decisions and specific implementation experiences from operators
and equipment vendors.
Delayed (or partially delayed) introduction of 3-digit MNCs might be considered if
tests reveal problems that cannot reasonably be resolved before original target
date(s).
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10.3.2 Shared use of MNCs under the Swedish geographic MCC 240
Shared use of MNCs (different service providers or networks identified by leading digits of
MSIN) is most suitable for MVNO type M2M operations. The “HLR Proxy” solution proposed
and planned to be implemented in the Netherlands is a suitable solution to administer shared
MNC use.
The NRA may leave further development in this area to the market participants. If Swedish
market participant should want to establish “HLR Proxy”-providers (“HPPs”) to support for
example particular industry sectors (utilities, etc.), the NRA should support this with
appropriate MNC numbering resources. 2-digit MNCs would be required as shared MNCs
might serve as intermediary solutions until 3-digit MNCs can be assigned.
The use of shared MNCs could also be a solution for private networks (typically small cell
networks). However, the use of MNC resources assigned for this purpose would need to be
controlled by the Regulator. This means:


To permit future interconnection and roaming among such networks as well as
between such private networks and public networks, the leading MSIN digits should
be coordinated and assigned by the NRA48.
Coordination will also be needed as these networks would broadcast MCC and MNC
as part of the Local Area Identity (LAI). NRA would need to make sure that there is
geographical or spectral separation between networks sharing MNCs.
10.3.3 MNCs under shared MCCs “90X”
In a Swedish contribution to ITU, an MCC 902 has been proposed for use by international
SMS service providers.
Further shared MCCs for specific types of service providers may be considered, e.g.
international MVNOs, Independent Roaming providers, etc.
In order to utilise all new number resources as efficiently as possible, it is recommended to
specify that all MNCs under new shared MCCs should be 3-digit. (It may be noted that to
permit mixed use of 2 and 3-digit MNCs under shared MCCs, a formal update of ITU-T
E.212, Annex A would be required.)
10.3.4 General policies to safeguard MNC resources
As the demand for MNC resources can be met in various ways for different services and
applications as shown in Table 12, the NRA may use this as a basis for policies to safeguard
MNC resources. Assignment of different types of MNC resources could be based on service
and application types.
48
For an existing private network trial operation in Norway, the Norwegian NRA has assigned the
leading MSIN digit in this manner (see section 9.2)
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Such policies need to consider the MNC resources available at any given time. The situation
will vary over time because of e.g.:




Time required to agree new MCC/MNC resources, e.g. new shared MCCs (“90X”)
Time required if change of specifications are required
Time required to test compliance of networks and systems
MNC demand from new services and applications
For some services and applications, existing 2-digit MNCs under geographic MCC may
remain the only possible option. It is important therefore to reserve these remaining 2-digit
MNC resources for services and applications which are not able to use other MNC resource
alternatives as shown in Figure 19 below:
Figure 19: Creation of policies to safeguard all available MNC resources
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11 References
1. ECC Report 212, Evolution in the Use of E 212 Mobile Network Codes.
http://www.erodocdb.dk/doks/doccategoryECC.aspx?doccatid=4
2. ITU-T Specification E.212 : http://www.itu.int/rec/T-REC-E.212/en
3. ITU-T Specification E.214 : http://www.itu.int/rec/T-REC-E.214/en
4. ITU-T Specification E.164 : http://www.itu.int/rec/T-REC-E.164/en
5. 3GPP TS 23.003 : http://www.3gpp.org/DynaReport/23003.htm
6. 3GPP TS 23.122 : http://www.3gpp.org/DynaReport/23122.htm
7. http://www.gsma.com/gsmaeurope/wp-content/uploads/2012/03/gsmepositionmnc.pdf
8. ITU-T Liaison Statement COM2-LS129-E, “Assignment of 3 digit MNCs” and subsequent
communications.
9. http://www.gsma.com/gsmaeurope/wp-content/uploads/2012/03/gsmepositionmnc.pdf
10. COM 2-C4-E ITU-T SG2 – Contribution 4, December 2012, “New Annex G for E.212 – MNCs
under new MCC for International mobile messaging services
11. http://www.gsma.com/connectedliving/embedded-sim/
12. http://www.analysysmason.com/About-Us/News/Insight/M2M_forecast_Jan2011/
13. http://www.telecomengine.com/sites/default/files/temp/CEBIT_M2M_WhitePaper_2012_01_1
1.pdf
14. “Connecting Cars: The Technology Roadmap”, GSMA Connected Car Forum, February 2013.
http://www.gsma.com/connectedliving/wpcontent/uploads/2013/02/GSMA_mAutomotive_TechnologyRoadmap_v2.pdf
15. http://www.gsma.com/connectedliving/wpcontent/uploads/2012/03/embedded_sim_imv1v091213vFinal.pdf
16. HeERO presentation to CEPT ECC, Numbering & Networks Working Group, 22 January 2014
17. CEN EN 16102:2011 “Intelligent transport systems - eCall - Operating requirements for Third
Party Support”, ref. http://www.cen.eu/cen/products/en/pages/default.aspx
18. http://ec.europa.eu/information_society/activities/roaming/docs/roaming_recast11.pdf
19. COM 2-C4-E ITU-T SG2 – Contribution 4, December 2012, “New Annex G for E.212 –
20. 3GPP TSG CT WG1 in its “Reply LS on assignment of 3 digit MNC” (May 2012) in response
to ITU-T SG2’s Liaison Statement “Assignment of 3 digit MNCs” COM2 – LS129 – E (March
2012).
21. Dutch Ministry on Economic Affairs: http://www.rijksoverheid.nl/ministeries/ez/documentenen-publicaties/rapporten/2013/07/03/gedeeld-gebruik-mnc-s-voor-m2m-toepassingen.html
22. Stratix Consulting: http://www.stratix.nl/projecten/37?view=project
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12 List of abbreviations / acronyms
3GPP
ARP
bCall
BCCH
CEPT
CEPT ECC
DECT
eCall
ECTRA
GSM
GSMA
HLR
HPP
IMSI
IMT-2000
IVS
LAI
LTE
M2M
MCC
MGT
MNC
MNO
MSIN
MVNE
MVNO
NRA
OTA
PCS 1900
PLMN
RAN
SIM
SMS
SMS-SP
SS7
UMTS
VoIP
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3G Partnership Programme
Alternative Roaming Providers
Breakdown Call
Broadcast Control CHannel
Conférence européenne des administrations des postes et des
télécommunications / European Conference of Postal and
Telecommunications Administrations
CEPT Electronic Communications Committee
Digital Enhanced Cordless Telecommunications
Pan-European emergency Call
European Committee for Telecommunications Regulatory Affairs (now part of
CEPT ECC)
Global System for Mobile Communications (originally Groupe Spécial Mobile)
GSM Association
Home Location Register
HLR Proxy Provider
International mobile subscriber identity
International Mobile Telecommunications-2000 (ITU specification)
In-Vehicle System (for telematics, eCall, etc.)
Local Area Identity
Long-Term Evolution (also 4G or 4G LTE)
Machine to machine (communications)
Mobile Country Code
Mobile Global Title
Mobile Network Code
Mobile Network Operator with own RAN (used with same meaning as PLMN)
Mobile Subscription Identification Number
Mobile Virtual Network Enabler
Mobile Virtual Network Operator
National Regulatory Authority
Over-The-Air (communications or interface)
Personal Communications Service 1900
Public Land Mobile Network (same as MNO)
Radio Access Network
Subscriber Identity Module / Subscriber Identification Module
Short Message Service
Short Message Service – Service Provider
Signalling System No. 7
Universal Mobile Telecommunications System (also 3G)
Voice over IP