Roaming charges being banned by the EU will compound the already huge declines in mobile operator voice revenues – while providing an opportunity for an innovator to break out of the pack and steal a march on the slower, less hungry Operators.

To be meaningful and effective in the short term – the Operator’s strategic responses must allow for the set-up of partnering units that don’t have the ‘die on the vine’ procurement rules and cycles that see so many promising technology partnerships between big & small collaborators fail.

The investments needed are tiny but as the biggest technology successes of the past decade show, they all rely upon mobile infrastructure for their success. Opportunity knocks for those who are listening.

For sure, the biggest mobile operators need to find, fund, and fast track  innovative small companies. Old rules and unimaginative gatekeepers to the corporate cash & resources must be removed by the leaders of these massive companies. Buying-in innovation is – a dirt cheap, low-risk, strategic option.

There will be start ups that play a crucial role in the outcome of the the creative destruction brought about by the competitive and regulatory dynamics of a maturing industry and deep down the CEO’s of the Operators know that the best corporate strategy cannot be to eat your competitors without figuring out how to deploy new innovation.


At their best BYOD Programs increase mobile employee-productivity and job satisfaction while cutting the employer’s hardware costs and avoiding fines from Regulators. Employee reticence to take them up however is driven by dislike of using their own number to take business calls out of hours and the imposition of company controlled MDM features, such as remote-wipe.

Consequently BYOD uptake often falls short of its potential leaving the promise unfulfilled.

Split persona phone numbers are meant to help and on paper they would seem to but the technology is limited to either MVNO integrations or virtual SIMs that limit deployment to one or two carriers or countries or require mass SIM replacement; neither of which are a panacea or meet the test of a universally-applicable solution continuously applied as employees join and leave in a rolling BYOD provisioning cycle.

Even more difficult; BYOD telephony has to work across the infrastructure & device mix of the corporate & employee combined estate while being globally operable across all mobile networks.

Blackberry has made an effort to resolve these challenges by going on a partnering and acquisition spree,  but one wonders whether it understands the difficulty it faces in combining these proprietary & partner technologies into a combined solution offering the essential elements needed to meet customer needs, even within industries that aren’t highly regulated?

To be compelling an ideal BYOD-centric mobile solution would offer global split persona and billing (any country or carrier) with company-owned, city-prefixed numbers. Once provisioned the application should include automated smart LCR and Roaming cost-reduction technology to eliminate the $millions in wastage through reimbursing sky high employee consumer-rate tariff charges for their international calls and roaming.


Compliance Officers may breathe a sigh of relief at the likelihood of a delay to MiFID II compliance but our experience is that most banks won’t be able to comply even with an extra year, should they get it. In fact complying with MiFID II isn’t necessarily the entire point, as existing rules are already catching out banks at an alarming rate with massive fines ever more common.

Mobile Technology; The Law – and –  Human Behaviour

Where BYOD, SMS, and Mobile Calls are used in business we find numerous risks over-arched by a struggle to avoid fines even where nothing illegal has occurred.

In terms of MiFID II preparation; most major financial services organisation we meet presents as ill-informed on technical limitations of  capturing in & outbound mobile communications in compliance with  global regulatory requirements – while struggling to also grasp how to organise mobile call-data, to satisfy discovery demands of  Regulators in under 72 hours.  With BYOD now prevalent and growing, how could they ?

Compliance Officers’ general lack of  deep IT knowledge is the Achilles heel of many banks & financial services companies effort to align with the new requirements, and in our experience Consultants hired by banks to bridge the gap often also struggle, despite having IT backgrounds.

How likely therefore is compliance? To RFP, shortlist, pilot, procure, plan and deploy a globally compliant, cost effective mobile-policy / SaaS strategy, that satisfies MiFID II,  across a blended mobile estate of CYOD, BYOD or Company Mobiles in under two years is a big ask.

To recognise potential solutions requires an understanding of the sometimes complex elements of mobile infrastructure, OTT Applications, Mobile Call Recording and Secure Data Storage & Analytics technologies.

To qualify to offer a solution vendors must provide enterprise grade global telephony network access that sits OTT on all existing mobile contracts, handsets and MAM, MDM deployments such as the market leading Good Dynamics. The rest is down to robust and widely applicable policy rules that narrow down the technologies and communication mediums employees can use.