Why has the GSMA legitimised some Global Title Leasing Use Cases?
The GSMA’s Global Title Leasing Code of Conduct, “CoC”, PRD FS.52, has rightly set new expectations for acceptable Global Title (GT) leasing practices. From now on, any party engaged in this activity that wishes to claim compliance with the CoC must implement a range of mechanisms and controls to ensure that the risks of GT leasing are mitigated. This is something that Mobileum welcomes and is why Stephen Ornadel chaired the task force that delivered the CoC, so make no mistake, Mobileum is a huge supporter of this initiative.
The purpose of this blog is to explain two exemptions that are specified in the CoC as follows:
- “Hosted services, such as those offered by third parties or centrally within an MNO group. In this case it is reasonable for the host to use the GT of its customer, this is not considered GT leasing. If the client’s GT is used for any other purpose than hosted services, then that other activity is GT leasing and must comply with the requirements of this CoC.
- Use of GTs by roaming enabling services as defined in PRDs BA.21 [1] and BA.23 [2] ”
So, what is it about these services that requires a GT and why are they acceptable? To answer those questions, allow me to delve into some roaming history.
From Local to Global and Beyond
When international roaming first started, India was a complex market. With 23 circles (in effect Indian regions divided into separate licensing regimes) and over 100 operators, achieving total coverage and optimising inbound roaming was a complex business. In fact, Mobileum published a blog on this a while ago which might be of interest. The blog captures just how challenging this market was back then.
In most other geographies operators could achieve maximum roaming coverage with two to four roaming partners in average. Sure, there were exceptions but nowhere was as complex as India. Indian operators were aware of this problem and even those operators that had near national coverage still presented themselves as multiple disparate networks to the outside world. Several Indian operators were looking for a solution and Mobileum was able to partner with them.
Mobileum’s roaming replicator platform was able to fulfil their requirements of offering “roaming extensions” leveraging just one roaming agreement. So, in other words, if an operator launched roaming with just one Airtel network in say Mumbai, they could immediately gain coverage in all of the sister networks around India. Whilst this work started in India, it soon spread to other regions such as the Caribbean, Russia, USA and elsewhere. So how does this relate to GT leasing?
The complexities of routing signalling traffic meant that there was a common platform used to relay signalling messages between the roaming partner and the destination network in India but using a “borrowed” GT from the single network the roaming partner had launched roaming with. There is nothing illegitimate about this – it was an elegant way to avoid the commercial and technical headache of achieving full coverage in India.
Similarly, operators that entered the GSM roaming world late – for example they never had a 2G, 3G or 4G licence or they had previously used alternative technologies such as CDMA, had an urgent need to offer their customers international roaming. The challenge is that it can take many years to build up a comprehensive global footprint. The market rapidly responded, and several companies produced solutions based upon dual IMSIs or roaming hubs to meet evolving market needs. Depending upon exact details, a GT may be used that does not actually belong to the home network and therefore this could, in theory, breach the rules of the CoC.
There was never any intention for any of these solutions to be prohibited, hence the clear statement in the scope section of the CoC. The GT Leasing Task Force agreed that there was a need to ensure that the roaming market continues to operate efficiently with the best possible customer experience.
The final use case I will address is the first detailed in the extract above. It is almost self-explanatory but, for completeness, it is only proper that I outline the use case. Many multi-operator groups have pooled network assets for some years. Those assets relate to multiple services, including roaming. Depending on implementation and design decisions, there may be scenarios in which some of those multi-tenant assets use a GT belonging to a sister network within the operator group. There is nothing wrong with that. Hence, this use case is specified as an exception and not subject to the CoC requirements.
[1] GSMA PRD BA.21 “Network Extension Principles” (GSMA member confidential)
[2] GSMA PRD BA.23 “Outbound Roaming Solutions Handbook” (GSMA member confidential)