Turkey is a very important market for car manufacturers. 2019 motor vehicle production in Turkey was in the range of 1.5 million, while sales of new vehicles on the market have fluctuated sharply in the last 10 years between 1 M and 500,000.
Car connectivity usage in Turkey are closely related to the EU’s usage; for example Turkey has implemented the eCall (emergency call system with in car embedded cellular modem) regulation too.
For telematics and infotainment services, cars sold in Turkey require cellular connectivity the same way they would in EU countries.
Turkey has adopted its own data protection law (called DPL) comparable to EU’s GDPR, even if it is slightly harsher.
However the main impact on car connectivity is the very strict implementation of the telecommunication regulation in Turkey. Indeed the Turkish authorities are particularly strict regarding permanent roaming. They proscribe fully permanent roaming- using a foreign cellular provider for data services after 120 days in Turkey. It means that cars sold to Turks should be equipped with a Turkish cellular provider’s IMSI, and no international roaming solution can be used.
World’s car manufacturers therefore needs to obtain IMSIs from Turkish cellular operators. However the choice is restricted: there are 3 licensed MNOs in Turkey. There is a regulation for allowing in MVNOs. However the insurmountable tax obligations have refrained MVNOs to enter the Turkish market. Only licensed resellers such as football clubs reselling their partners MNOs services under their own brand are active in Turkey.
The conditions imposed on the entry of MVNOs may change over time, in view of economical, technological and political evolution, and the full MVNO model (MVNO with own core network) may become accepted.
Indeed local regulations across the world do vary over time: the MVNO model status has evolved over time in the EU countries, from partially allowed with strong limitations to favored by local regulators in recent spectrum auctions.
However regulation on permanent roaming vary over time too, but latest evolutions show a pattern towards limiting or forbidding permanent roaming across the world’s countries. Regions or countries forbidding permanent roaming includes EU, Singapore, Brazil, India. Other territories such as United Arab Emirates currently tolerate permanent roaming even if formally forbidden, but this may change.
As sold cars have a life duration of about 20 years in the street, car manufacturers should make sure their connectivity solution remains of quality, not too costly over a very long period of time. Only a flexible solution able to switch models can allow car manufacturers to control and make their connectivity services evolve. By being a full MVNO in a country A, they would be able to have a wholesale agreement with a country B MNO to get IMSIs and airtime. The MVNO A could then inject the IMSI of the MNO B to car sold in country B, therefore complying with local regulation (however OTA functions may be subcontracted to a local entity to comply with the regulation, like in Turkey). If country B ‘ s regulation evolve, allowing MVNOs, then the car manufacturer can duplicate its MVNO to build a new MVNO in country B. Then it could switch the MNO B’s IMSI of the sold car to MVNO B’s local IMSI: this would mean cheaper costs and controlled services for the car manufacturer.
The own MVNO approach provide the full flexibility of local connectivity solutions for car manufacturers, so to cope quickly with regulation evolutions, and always choosing the best and most cost effective solution.
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