International Benchmark

Main findings

Equivalence of treatment model

Of the countries researched, Iceland and New Zealand have an equivalence access model based on EoI for fixed access services. UK has an equivalence access model based mainly on EoI.

A mixture of EoI and EoO obligations, depending on the fixed access service requested, applies in Ireland, Italy and Sweden.

Australia, Denmark and Poland currently have an EoO regime. However, the regulatory authorities mandated these types of equivalence of access obligations:

for Denmark, before the NRA implemented legal separation in June 2019 (a new analysis on the wholesale broadband market after separation is in progress); and

for Australia, before the completion of the structural separation of the Australian incumbent (Telstra), which is due to take place in July 2020.

In the Czech Republic, the NRA removed the EoI and KPI remedies imposed in 2015, following its fourth round review of market 3a and market 3b in 2018, introducing a more general obligation of non-discrimination.


Models of separation

In the countries researched, nine out of ten adopted separation at the wholesale level.

Ireland, Italy, Poland and Australia implement functional separation. The Italian incumbent (Telecom Italia) also notified to the NRA its project of voluntary legal separation on 27 March 2018. This was taken into consideration under the last fixed market review of markets 3a and 3b, published on 6 August 2019. In Australia, the functionally separated incumbent Telstra committed to achieve structural separation by July 2020.

Czech Republic, Denmark, Iceland and UK implement legal separation. The Swedish incumbent, Telia, voluntarily implemented legal separation from 2007 to 2017 through its fully owned subsidiary Skanova Access AB before reintegrating it as a part of a larger wholesale unit (Telia Infra) on 1 January 2018.

To Cullen’s knowledge, at present the only country which has already implemented structural separation is New Zealand, where the vertically integrated incumbent decided to split itself into two separately listed companies under different ownership in 2011. As stated above, Australia should follow the example of New Zealand in July 2020.