Icasa’s move to regulate what it terms “out-of-bundle billing practices” and “expiry of data practices” is years overdue. The regulator wants to get rid of the typical 30-day expiry period for mobile data bundles, which has been a characteristic of the industry since 3G data products were launched.
Importantly, it does not want to get rid of expiry all together. It is accepted that at some point, bundles purchased ought to expire (as is the case globally). Rather, the regulator seeks to ensure that the expiry period is more generous, particularly on larger bundles.
In a Government Gazette notice, it proposes the following expiry periods for bundles:
Now, the size and pricing of bundles by all operators in the market is not random; it is (obviously) deliberate. There’s a reason why pricing of 1GB of prepaid/one-off data on three of the four networks, for example, is clustered around the R150 mark and lasts 30 days (on Telkom Mobile it is priced at R99 and valid until the end of the next calendar month (as much as 60 days).
Operators know what the typical ‘deferral’ rate is, i.e. how much data is likely to expire on each bundle, on average. They take this into account when pricing. Combine this with the other vector, time, and you can quickly understand why the ‘same’ 1GB of one-off data can cost R12 (if you use it between 11pm and 5am, when there is minimal usage on the network), R29 (if you use it on weekends only), R79 (if it expires in seven days), R99 (if it expires in 14 days), R149 (if it expires in 30 days) or R579 (if it expires after six months).
These are all real prices and illustrate ‘dynamic’ pricing in the extreme. But, it must be noted that this situation is not unique to South Africa. In most markets (from developed to developing), pricing strategies are similar.
Coupled with this are the actual sizes of bundles, and the price differences between them. You can buy 1GB, 2GB, 3GB or 5GB bundles, but not 4GB. And, the gap between 5GB and 10GB is enormous (and between 10GB and 20GB, even bigger)! Price psychology plays a huge role here. Look at the differences between these larger bundle prices:
Typical 500MB customers are ‘incentivised’ to rather buy 1GB (double the data, for ‘only’ R50 more). Similarly, typical 2GB users are ‘incentivised’ to rather buy 3GB. Over time, the typical customer will use more data (by design). And, if they deplete their allocation before the 30-day expiry, they’ll buy data bundles more frequently (say, every 25 days). That’s why operators can argue that the ‘average’ price per megabyte has fallen to the extent that it has: Morecustomers are using more in-bundle data.
It’s important to understand how these numbers and expiry periods relate to the market. Using Vodacom data for Q1 2018, the average monthly usage by each of its 16.6 million smartphone subscribers is 734MB (up 15%). On the high-end – think iPhones and Galaxy S-type devices – this average is 2GB (up 36%).
The proposed regulations also require that notifications are sent at various points (50%, 70%, 90%, 100%) during the depletion of bundles. This is not a huge ask. Most networks have implemented aggressive notification strategies to counteract the negative market perceptions created by the #DataMustFall hearings. Separately, requiring customers to specifically opt-in to out-of-bundle charges upon depletion – which is proposed – is also not unique to this market. Nigeria sanctioned operators for not doing this back in 2015.
How are the operators likely to react?
For a start, they will surely lobby hard to get shorter expiry periods than those proposed by the regulator. I’m not certain we’ll get to the more optimistic 12-month and 24-month periods. It is likely that the operators will launch entirely new propositions at new price points (to comply with the regulations), but this pricing will be ‘stickier’ (a euphemism meaning higher, for longer).
Critical to these proposed regulations being successful is how they deal with so-called ‘promotional’ bundles as well as dynamic/targeted ones (those unique to the particular subscriber’s usage and purchase history). The latter is already a reality on the Vodacom network (its highly successful Just4You proposition). Data ‘bonuses’ (free data on top of standard bundles) is also not taken into consideration (yet?).
Along with this is the question of how regulations deal with bundled propositions, where voice minutes, SMSes and data access are bundled together in a single price (this is particularly prevalent in developed markets).
Tiering of pricing based on access speed could become a reality. This is already the case in many European markets, as well as emerging markets such as India. Data bundles on 2G or 3G networks are cheaper than those offering 4G access.
Let me be clear: operators will find ways to work – and price – around whatever regulations are implemented (especially in their current, overly simplistic construction). This is what operators do the world over.
That said, regulation can be highly effective, as has been seen with aggressive cuts to mobile termination rates, which have driven down the price of voice calls far quicker than the ‘market’ would’ve. A year ago, Icasa published a surprise (and since-withdrawn) Invitation To Apply for mobile spectrum. At the time, I argued that the proposal would yield a positive result for both sides of the market it intended to manage (which is rare). Government then lurched to the other extreme, with a proposal in its White Paper that all spectrum be assigned to a national wholesale operator. Thankfully, sanity has prevailed and we look set for a hybrid approach. Government gets its wholesale operator, while the likes of Vodacom, MTN, Cell C and Telkom get access to their own spectrum too, via an auction.
These data bundle and expiry regulations are long-overdue. Let’s get them implemented already!
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