Which? Response to DSIT Mobile Market Review Call for Evidence Consultation

Which? welcomes this opportunity to respond to the DSIT Mobile Market Review Consultation. A summary of key themes and the related questions can be found below. 

1. Driving Investment and 5G Ambition 

• Support for 5G Ambition: We support the government's ambition for all populated areas to have access to higher-quality standalone 5G by 2030.
• Sector-Wide Target Risk: At present, the target applies sector-wide, which may reduce the incentive for multiple Mobile Network Operators (MNOs) to provide high-quality coverage in the same area. The government should ensure customers on all networks have access to high-quality 5G.

2. The value of the Mobile Virtual Operator Network (MVNO) and eSIM Markets to consumers 

• MVNOs and Affordability: The growth of Mobile Virtual Network Operators (MVNOs) and eSIMs is highly beneficial for consumers, promoting good value and choice. MVNOs consistently outperform MNOs in Which? customer satisfaction surveys (e.g.,Which? Best and Worst of Mobile 2026 survey). MVNOs play a key role in reaching niche consumer segments and providing responsive customer service. 
• eSIMs and Roaming: eSIMs are growing in popularity among consumers by offering an alternative to expensive MNO roaming passes. The government should seek a sector-wide roaming scheme to extend the benefits of "Roam Like at Home" to UK consumers travelling in the EU.

3. Defining and Measuring 'Good' Mobile Coverage 

• Beyond Signal Availability: 'Good' mobile coverage must move beyond coverage availability to include accurate performance information, such as, download and upload speeds. 
• Transparency and Ofcom: MNOs should be required to provide live performance data to Ofcom. Ofcom's 'Map Your Mobile' tool needs to evolve to capture "real-world performance" data alongside mobile coverage predictions. 

4. Strengthening Consumer Protection 

• Ofcom’s powers: The government should consider whether Ofcom should be given the power to directly enforce consumer law, similarly to the CMA.  
• Prohibit Unexpected Price Hikes: The government should work with Ofcom to strengthen protections against unexpected, discretionary price increases during a contract's minimum term. It is recommended that Ofcom update General Conditions to allow price increases only for changes imposed by law (like VAT).
• Mobile Service Code of Practice: The government and Ofcom should consider introducing a mobile service "code of practice," similar to the broadband speeds code, allowing customers to leave a contract penalty-free due to persistent issues with poor signal reliability for voice, text, or data.

5. Net Neutrality and potential consumer benefits and risks 

• Zero-Rating Support: The existing net neutrality framework works well, particularly in allowing zero-rating of websites that deliver a public benefit or provide access to essential services.
• Network Slicing Benefits: The ability of MNOs to use network slicing for effective traffic management (e.g., at large events) is supported, as it ensures consumers can access services during periods of high congestion.
• Risk of Two-Tier Networks: Concerns exist regarding future retail trends (e.g., high-speed boost add-ons) potentially leading to a "two-tier network" where baseline reliability is deprioritised, especially if net neutrality protections are weakened.