The Three Criteria Test (3CT)

Presence of strong economies of scale, scope, and density benefits incumbent telephone network.

Entry into the market through the construction of one's own infrastructure entails substantial investment and incurs large sunk costs.

Limited availability of wholesale of fixed access products that could allow the entrance to new entrants.

Continuing decline in legacy calls and limited roll-out of infrastructure from relatively smaller SPs (e.g., Salam and Go).

Implementation of 2020 remedies has prevented DSPs from engaging in anti-competitive behavior. These measures, however, need more time to fully reach their potential.

Presence of strong economies of scale, scope, and density in retail fixed broadband.

Entry into the market through building one's own infrastructure requires significant levels of investment & large sunk costs.

Entry could take place through wholesale fixed broadband access products if in place and if effective.

Full implementation of the Open Access measures could reduce market entry barriers and fostering competition, though achieving its full potential will take more time.

Considering competition based on its own infrastructure, it is unlikely that alternative SPs will increase their market shares over the next few years to reach effective competition.

Implementation of 2020 remedies has prevented DSPs from engaging in anti-competitive behavior. These measures, however, need more time to fully reach their potential.

Large economies of scale, investment and sunk costs.

Entry into the market through building one's own infrastructure requires significant levels of investment & large sunk costs.

Entry could take place through wholesale fixed broadband access products, if in place and effective.

Full implementation of the Open Access measures is reducing market entry barriers and fostering competition, though achieving its full potential will take more time.

Considering competition based on its own FTTx network, it is unlikely that alternative SPs will increase their market shares over the next few years to reach effective competition.

Dealing with dominance practices after they occur can be more costly for the affected parties than taking preventive measures in advance. Additionally, ex post regulation may take time to implement corrective actions.

In the B2B segment, significant economies of scale, scope, and density in telephone networks present high entry barriers.

Constructing one's infrastructure for market entry demands substantial investment and results in large sunk costs.

In the B2B segment, entry is possible through wholesale leased lines products if available and effective, yet challenges remain in accessing and sharing these products despite sufficient supply.

In the B2G segment, market entry is not possible due to the fact that only six SPs have been selected for the Etimad Platform, exclusively allowing them to conduct sales to the government.

In the B2B segment, limited competition exists due to economies of scale, with little expectation for significant shifts in market shares among alternative SPs in the near future.

The B2G segment sees a potential shift towards competition with the introduction of the Etimad platform, marking a positive development towards competitive dynamics.

Despite the Etimad platform in B2G, the market remains in early stages of development, with the future impact and effectiveness of the platform still uncertain.

Presence of strong economies of scale, scope, and density in mobile telephone networks.

Entry into the market through building one's own infrastructure requires significant levels of investment & large sunk costs.

A new MNO entrant would require access to spectrum and to build a network.

Entry via wholesale MVNO is feasible with the introduction of 2 new MVNOs in the period 2021-2023, although their presence remains limited.

Indicators for market concentration, such as HHI, have remained stable during the period.

Presence of strong economies of scale, scope and density in establishing access networks.

Strong structural barriers to entry and expansion.

Service depends on ownership of an access network.

Entry into the market through building own infrastructure requires significant levels of investment & large sunk costs.

Availability of alternative networks through fiber optic delivery is increasing, but achieving full coverage is not expected at the time of writing this report.

Implementation of the Access to Physical infrastructure and Interconnection regulations has improved competition, but it needs more time to be materialized.

Implementation of 2020 remedies has prevented DSP from engaging in anti-competitive behavior.

In the absence of ex ante remedies, a dominant Service Provider could engage in refusal to supply or discriminatory pricing, that would have damaging consequences for access seekers.

Presence of strong economies of scale, scope and density in establishing access networks.

Service depends on ownership of an access network.

Entry into the market through building own infrastructure requires significant levels of investment & large sunk costs.

Fiber optic delivery regulations are increasing fiber rollouts from alternative SPs, although the impact is limited at the time of the report.

Competition likely to be from self-supply of new fiber networks.

Implementation of the Open Access measures and the Physical Access and Interconnection regulations is going to increase competition.

Implementation of 2020 remedies has prevented DSPs from engaging in anti-competitive behavior. These measures, however, need more time to fully reach their potential.

In the absence of ex ante remedies, a dominant Service Provider could engage in refusal to supply or discriminatory pricing, that would have damaging consequences for access seekers.

Presence of strong economies of scale, scope and density in establishing transit networks.

Service depends on ownership of an access network.

Entering the market by constructing one's own infrastructure demands substantial investment and incurs significant sunk costs.

Competition is likely to be from self-supply of transit services.

Fiber optic delivery regulations are increasing fiber rollouts from alternative SPs, although the impact is limited at the time of the report.

Unlikely to be new demand for wholesale transit for legacy switched calls due to the transition to all-IP technology, coupled with the increase in mobile and OTT calls.

Refusing to supply or implementing discriminatory pricing for wholesale transit services could have immediate detrimental effects for access seekers, who rely on it as a crucial upstream input for their retail operations.

Every fixed operator controls access to its subscribers via wholesale fixed voice call termination.

There are unavoidable technical barriers to entry

Strong structural barriers to entry and expansion

Ex post intervention is likely to be too slow to address these concerns effectively

Presence of strong economies of scale, scope and density in establishing access networks.

Entry into the market through building own infrastructure requires significant levels of investment & large sunk costs.

Competition likely to be from self-supply of new fiber networks.

While investment in alternative networks is increasing this is still limited.

Implementation of 2020 remedies has prevented DSPs from engaging in anti-competitive behavior. These measures, however, need more time to fully reach their potential.

As a key upstream input for competitors at the retail level, refusal to supply or discriminatory pricing could have immediate damaging consequences for access seekers.

Ex post intervention is likely to be too slow to address these concerns effectively.

Presence of strong economies of scale, scope and density in establishing access networks.

Entry into the market through building own infrastructure requires significant levels of investment & large sunk costs.

Competition likely to be from self-supply of new fiber networks.

While investment in alternative networks is increasing this is still limited.

Implementation of 2020 remedies has prevented DSPs from engaging in anti-competitive behavior. These measures, however, need more time to fully reach their potential.

As a key upstream input for competitors at the retail level, refusal to supply or discriminatory pricing could have immediate damaging consequences for access seekers.

Ex post intervention is likely to be too slow to address these concerns effectively.

Every mobile operator controls access to its subscribers via wholesale mobile termination.

Unavoidable technical barriers to entry.

MVNOs rely on agreements with MNOs, which can exert a nuanced influence on them.

Wholesale service prices are established in the agreements for a specified period and can rarely be adjusted for changes (e.g., seasonal promotions, etc.).