230 Vodafone Group Plc Annual Report 2025
Strategic report
Governance
Financials
Other information
Regulation continued Unaudited information
On infrastructure deployment, the Gigabit Infrastructure Act (‘GIA’), revising the 2014 Broadband Cost Reduction Directive, was adopted by the co-legislators at the end of April 2024. As part of this, legislators agreed to prolong the current caps on retail surcharges until 2029. Full abolition of retail surcharges from 2029 onwards is conditional on (i) an EC review/impact assessment by 2027 and (ii) an EC implementing act on fair use provisions by 2028. Otherwise, the caps will expire in 2032. On roaming, in 2023, the EU-Ukraine Association Committee in Trade Configuration and the EU-Moldova Association Committee in Trade Configuration separately adopted decisions to apply EU ‘roam like at home’, intra-EU communication provisions and EU fixed termination rates (‘FTR’), and mobile termination rates (‘MTR’, only Ukraine) between the EU and Ukraine/the EU and Moldova. Ukraine has notified its transposition of EU telecom law to the Commission in December 2024. The Commission is now in the process of confirming Ukraine’s correct implementation and triggering a Council decision. As final step, the trade committee under the EU-Ukraine Association Agreement needs to sign off Ukraine’s internal market treatment. The timeline is uncertain due to the novelty of the procedure, but it is anticipated to conclude by July 2025 when the voluntary industry agreement on connectivity support of Ukraine expires. The timeframe for transposition by Moldova is one year for intra-EU communications and two years for roaming and MTR/FTR after implementation of the decision. On wholesale termination rates, in December 2024, the Commission published its mobile cost model study results, which will inform this year’s review of EU wholesale roaming and mobile termination rates. The study does not prejudge any future policy decisions by the Commission including on the regulated rates which will consider further inputs and market considerations.
The cost model study will feed into BEREC’s opinion on the roaming review (expected Q1 2025) and into the EC review of the roaming regulation (due mid-2025) and the MTR regulation (end- 2025). However, the Commission might decide to not proceed with an update of the Roaming Regulation before mid-2027. On network security, the final compromise text of the Cyber Resilience Act (‘CRA’) was published in the Official Journal of the European Union on 20 November 2024. The CRA introduces horizontal cybersecurity requirements for products with digital elements and associated services that are placed on the European single market. Products in scope will be subject to conformity assessment. Highly critical products will be subject to European cybersecurity certification schemes. Digital platform regulation The Digital Markets Act (‘DMA’) became fully enforceable in March 2024 and enforcement proceedings are now underway. Currently, seven companies are designated as Gatekeepers under the DMA, and are therefore required to take steps to comply with the regulation and evidencing this in the form of a report to be audited by the EC. Upon entry into force, the EC immediately launched investigations into three Gatekeepers for possible non-compliance with their obligations under the DMA: Apple, Alphabet/Google, and Meta. These investigations focus inter alia on conditions and charges for developers within the Apple and the Google platform environment. Within 12 months from the launch of the investigations, the companies under investigation will receive preliminary findings from the EC that they (and other stakeholders) can respond to. The EC will then make a final decision. Gatekeepers will have two months to appeal to the EU courts if they disagree with the findings of the final decision, otherwise they must comply.
The Digital Services Act (‘DSA’) became fully enforceable in February 2024. Since then, online platforms and other intermediaries have been subject to new and updated rules on content moderation and due diligence. The EC has also now designated 20 firms as Very Large Online Platforms (‘VLOPS’), with additional obligations and subject to its direct supervision. The EC has opened enforcement proceedings into a number of VLOPs including Meta, TikTok and X. The AI Act entered into force on 1 August 2024. Enforcement will take place over a two-year time scale, starting with the prohibited AI systems from 2 February 2025 and concluding with the rules for high-risk AI systems by August 2026. Vodafone has signed a voluntary AI Pact, which launched in September 2024, allowing companies to assess their compliance with the Act by adhering to several baseline commitments. Sustainability regulation The EC’s first two Omnibus were published on 26 February 2025: (1) Omnibus on Sustainable Reporting Obligations, and (2) Omnibus to simplify InvestEU. The first Omnibus aims to streamline and simplify corporate sustainability rules, by consolidating reporting obligations across the Corporate Sustainability Reporting Directive (‘CSRD’), the Corporate Sustainability Due Diligence Directive (‘CSDDD’), the Carbon Border Adjustment Mechanism (‘CBAM’) and the EU Taxonomy, thus reducing compliance burdens while addressing concerns over Europe’s economic competitiveness and regulatory complexity. The second Omnibus aims to enhance the InvestEU programme’s risk-bearing capacity, mobilising up to €50 billion in public and private investment, particularly in clean tech, clean mobility, and waste reduction. It also includes the creation of a new Industrial Decarbonisation Bank with €100 billion in funding, linked to the Clean Industrial Deal’s pillar for investment.
On 26 February 2025, the EC launched the Clean Industrial Deal (‘CID’), a proposed policy package aimed at supporting European industries in transitioning to a carbon-neutral economy while maintaining global competitiveness. This framework will include legislative and non- legislative initiatives, for example, the Decarbonisation Accelerator Act will address, inter alia, clean energy, funding and investment. On the same day, the EC launched Action Plan for Affordable Energy, which sits as a cornerstone in the CID. The Ecodesign for Sustainable Products Regulation (‘ESPR’) establishes ecodesign requirements for placing mobile phones, cordless phones and slate tablets on the market. The Regulation entered into force on 18 July 2024. Delegated acts will be set for different products and material groups – a timetable is delayed due to the new Commission mandate. The Green Claims Directive, which was proposed by the EC on 22 March 2023, aims at ensuring that claims on the ‘green’ nature of products are reliable, comparable and verifiable throughout the EU. This has still not been adopted, with trilogues between the EU Parliament and Council ongoing since Q3 2024. The proposed directive will require companies like Vodafone to substantiate the voluntary green claims made in business-to- consumer commercial practices.
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