Regulation (EU) 2022/612 — Roaming on public mobile communi

Are we charging our roaming customers correctly under the recast Roaming Regulation — and what happens if our wholesale agreements or retail transparency fall short?

Since 1 July 2022, every EU mobile operator must offer roam-like-at-home at domestic prices, respect declining wholesale caps that reach EUR 1.00/GB by 2027 [Art. 11], and meet strict quality-of-service and transparency rules — with Member States required to impose effective, proportionate and dissuasive penalties for non-compliance [Art. 19].

Short Answer

Regulation (EU) 2022/612 recasts the EU Roaming Regulation until 30 June 2032. Roaming providers may not levy any surcharge on top of domestic retail prices for voice, SMS, or data used while travelling in the Union [Art. 4(1)], unless a fair use policy or sustainability derogation applies [Art. 5, Art. 6]. Mobile network operators must meet all reasonable requests for wholesale roaming access, including access to all available network technologies and generations [Art. 3(1), Art. 3(3)]. The Regulation introduces new obligations on quality of service equivalence [Art. 4(2)], transparency on value-added services and non-terrestrial networks [Art. 13, Art. 14], and free access to emergency services while roaming [Art. 12, Art. 15].

Who is affected

All mobile network operators, MVNOs, and resellers providing roaming services within the EU/EEA. The wholesale access obligation covers any undertaking requesting access for the purpose of providing regulated roaming services [Art. 3(1)]. Machine-to-machine and IoT communications are not excluded from the scope [Art. 1(1), Recital 21].

Deadline

The Regulation is fully applicable since 1 July 2022 and expires on 30 June 2032. The latest wholesale data cap reduction to EUR 1.00/GB applies from 1 January 2027 [Art. 11(1)]. The Commission was required to submit its first review report by 30 June 2025 and its second by 30 June 2029 [Art. 21(1)]. An interim report based on BEREC data was due by 30 June 2027 [Art. 21(2)].

Risk

The Regulation does not specify fixed Union-wide fines. Instead, Member States must lay down penalties that are 'effective, proportionate and dissuasive' [Art. 19]. National regulatory authorities may require immediate cessation of any breach [Art. 17(7)]. Commercial non-compliance risks enforcement action, contract disputes, and reputational damage, particularly where consumers experience bill shock or degraded quality of service while roaming.

Proof

Legal status

• In force
• as of 2026-04-19
• Original version

Primary sources

• EUR-Lex — Full text
• European Commission — Roaming — EU roaming policy

What to do now

Legal / DPO

•Review and update all wholesale roaming agreements to ensure compliance with the current wholesale price caps: EUR 0.019/min for voice [Art. 9(1)], EUR 0.003/SMS [Art. 10(1)], and EUR 1.00/GB for data from 1 January 2027 [Art. 11(1)].
•Verify that the reference offer published under [Art. 3(5)] is sufficiently detailed, covers all network technologies and generations [Art. 3(3)], and includes emergency service access information [Art. 3(6)].
•Assess whether any sustainability derogation under [Art. 6] is or will become necessary, and ensure the application to the national regulatory authority meets the requirements of [Art. 6(2)].

Compliance

•Audit retail contracts for all required roaming disclosures: tariff plans, fair use policy details, quality of service conditions, value-added service risk warnings, and complaints procedures [Art. 8(3), Art. 8(4)].
•Confirm that fair use policies comply with the implementing acts adopted under [Art. 7] and do not act as a barrier to genuine roam-like-at-home for periodically travelling customers [Art. 5(1)].
•Ensure the financial/volume cut-off mechanism for data roaming is operational with a default limit not exceeding EUR 50/month and that 80 % and 100 % notifications are sent to customers [Art. 14(4)].

IT / Security

•Implement automated transparency messaging systems that send SMS/push notifications with personalised pricing, fair use status, value-added service warnings, and emergency access information upon network registration in each visited Member State [Art. 13(1), Art. 14(2), Art. 15].
•Ensure billing systems charge roaming voice calls on a per-second basis with a maximum initial charging period of 30 seconds, and data on a per-kilobyte basis [Art. 8(1)].
•Deploy safeguards against inadvertent connection to non-terrestrial networks (vessels, aircraft), including opt-out mechanisms and real-time notifications [Art. 13(6), Art. 14(7)].

Product / Engineering

•Ensure that regulated retail roaming services are not offered under conditions less advantageous than domestic services, particularly regarding data speed and network generation — if 5G is offered domestically and available on the visited network, it must be accessible while roaming [Art. 4(2)].
•Design the roaming customer journey so that switching to or from the RLAH tariff is free, completed within one working day, and does not impose restrictions beyond roaming elements [Art. 8(2)].
•Provide a dedicated, accessible webpage with up-to-date information on value-added service numbering ranges, emergency access means, and — where applicable — public warning mobile applications for each visited Member State [Art. 13(1), Art. 15].

Key Terms

Roam-like-at-home (RLAH): The principle that roaming customers pay no surcharge above their domestic retail price for regulated voice, SMS, and data services when travelling within the EU/EEA [Art. 4(1)].
Fair use policy: A policy applied by roaming providers to prevent abusive or anomalous use of regulated retail roaming services, such as permanent use in a Member State other than that of the domestic provider [Art. 5(1)].
Wholesale roaming access: Direct wholesale roaming access or wholesale roaming resale access provided by a mobile network operator to another undertaking for the provision of regulated roaming services [Art. 2(2)(k)].
Sustainability mechanism: An exceptional derogation allowing a roaming provider to apply a retail surcharge where it cannot recover its overall costs of providing regulated roaming services, subject to authorisation by the national regulatory authority [Art. 6].
Visited network: A terrestrial public mobile communications network in a Member State other than that of the roaming customer's domestic provider, which permits the customer to use mobile services via arrangements with the home network operator [Art. 2(2)(d)].
BEREC: Body of European Regulators for Electronic Communications — the EU body that collects market data, issues wholesale roaming access guidelines, and maintains Union-wide databases on value-added services numbering and emergency access means [Art. 16, Art. 21(2)].
Reference offer: A published offer by a mobile network operator containing the standard terms and conditions for direct wholesale roaming access and wholesale roaming resale access [Art. 3(5), Art. 3(6)].

Frequently Asked Questions

Does the Regulation apply to machine-to-machine (M2M) and IoT communications?

Yes. M2M communications are not excluded from the scope of the Regulation or the wholesale roaming access obligations, including fair use provisions. However, permanent roaming for M2M can be agreed bilaterally in a wholesale roaming agreement [Recital 21, Art. 5].

Can a roaming provider still charge surcharges to customers?

Only in two cases: (1) consumption exceeding a fair use policy allowance [Art. 5, Art. 8(1)], or (2) where the national regulatory authority has authorised a sustainability derogation because the provider cannot recover its overall costs [Art. 6]. In both cases, surcharges are capped at the applicable wholesale maximums.

What are the current wholesale price caps for data roaming?

The wholesale data cap follows a glide path: EUR 2.00/GB (2022), EUR 1.80 (2023), EUR 1.55 (2024), EUR 1.30 (2025), EUR 1.10 (2026), and EUR 1.00/GB from 1 January 2027 until expiry on 30 June 2032 [Art. 11(1)].

What quality of service must be provided while roaming?

Roaming providers must not offer regulated retail roaming services under conditions less advantageous than those offered domestically, in particular in terms of speed and network generation, where the same technology is available on the visited network [Art. 4(2)]. Commercial practices that reduce quality, such as bandwidth throttling to minimise roaming volumes, are prohibited.

How are emergency services handled for roaming customers?

Visited network operators may not charge any wholesale fees for emergency communications or caller location transmission [Art. 12]. Roaming providers must inform customers via SMS about access to 112 and provide a link to a dedicated webpage listing alternative emergency access means in the visited Member State [Art. 15].

When does this Regulation expire?

The Regulation expires on 30 June 2032 [Art. 24]. The Commission must submit review reports by 30 June 2025 and 30 June 2029, each potentially followed by a legislative proposal to amend the Regulation [Art. 21(1)].

What is the default financial limit for data roaming?

Roaming providers must offer a default financial or volume limit close to but not exceeding EUR 50 per monthly billing period (excl. VAT). Customers must be notified at 80 % consumption and again when the limit is reached. The service is cut off unless the customer explicitly requests continuation [Art. 14(4)].

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