232 Vodafone Group Plc Annual Report 2025 Regulation continued Unaudited information Also in Greece, institutional procedures for harmonising EMF limits have started. A Committee of Experts was set up on 30 August 2024 and are due to issue a recommendation on harmonised EMF limits, however, this has been delayed. Final adoption of this recommendation by Joint Ministerial Decision is expected by mid-2025. It is possible, however, that Government reform scenarios delay these timelines. The Greek NRA (‘EETT’) set up a working group that will examine the spectrum allocation conditions for the Spectrum Rights of Use expiring by 2027 (900MHz and 1800MHz). The working group will explore the market interest on spectrum and after conducting the relevant public consultation will propose the spectrum allocation procedure. The NRA, following the public consultation, will propose to the Ministry the final proposed approach on the spectrum allocation conditions. Based on the timeline by the NRA, the proposal to the Ministry of Digital Governance must be completed by the end of November 2025. In July 2023, EETT informed operators, including Vodafone, of the findings from on-site audits conducted from October 2021 to March 2023 in relation to microwave link (MwL) emissions. The findings indicated possible breaches, with possibility of fines as a consequence. MNOs were given opportunity to comment on their findings. Vodafone Greece responded to EETT’s letter and sought to obtain the proper licensing from EETT to remedy the breaches. In January 2024, EETT called operators to a hearing on MwL emissions. Vodafone Greece contributed to this hearing process via a written memorandum and additional supporting documentation on 19 February 2024.
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On assessment, EETT issued a fine of €342,000 in December 2024, with the total payable amount reduced to €228,000 due to a 1/3 discount for early payment for use of the unlicensed MwL frequencies. Vodafone appealed on 25 February 2025 before the Administrative Court of Appeal for a further reduction of the fine. EETT continues to perform audits to prevent unlicensed use of MwL frequencies. In November and December 2024, EETT notified Vodafone Greece of new cases of perceived breaches. Internal risk mitigation planning is currently underway. Furthermore, after completing the licensing procedure for existing base stations (according to Law 4635/2019), the NRA EETT launched a series of hearings for 34 base stations where the licence applications had been rejected or withdrawn. Vodafone Greece submitted the relevant memoranda for each case on 15 July 2024. Decisions are expected by the end of Q4 FY25. In the Czech Republic, the NRA (‘CTU’) renewed 900 MHz and 1800 MHz licences of O2 Czech Republic and T-Mobile Czech Republic. The new licences are valid until end of 2044 and include an obligation to share passive infrastructure built in selected rural areas and railway corridors with other 900 MHz or 1800 MHz licence holders, including Vodafone. In September 2024, Vodafone submitted a formal request to the CTU to start the renewal process of Vodafone’s 900 MHz and 1800 MHz licence. In October 2024 the CTU launched a public consultation of Vodafone licence renewal and the CTU published the settlement of comments from the public consultation in February 2025. Vodafone is in the process of finalising the licence renewal, which will be valid until June 2049.
Universal Service Obligations (‘USO’) and Consumer Support Measures Vodafone Greece has four active appeals against EETT. These are in relation to charges of approximately €16.75 million. Of this, €9.0 million is in relation to the provision of universal services by operator Hellenic Telecommunications Organisation (‘OTE’) for the period of 2010 through to 2011. Vodafone Greece has appealed these costs. The hearings were held in April 2024 before the Administrative Court of Appeal in relation to the charges for 2010 and 2011, and the decision was issued in March 2025. The Council of State rejected the company’s appeals awaiting finalisation. Vodafone has exhausted procedural rights. Therefore, the decision is considered final and irrevocable. The remaining €7.75 million is related to USO net costs for the period of 2012 to 2016. Vodafone Greece also appealed these costs. The appeal has been referred to the Administrative Court of Appeal and the court’s decision is pending. In addition, the Universal Service Net Cost Allocation Decision for the years 2017 to 2019 was issued in October 2023, with the Vodafone share (including CYTA, an operator subsidiary that merged with Vodafone Greece in 2019) being calculated at €2.2 million. Vodafone Greece appealed these costs before the Administrative Court of Appeal in April 2024, with the hearing scheduled for 23 May 2025. Similarly, Vodafone Portugal continues to challenge payment notices totalling €34.8 million issued by ANACOM regarding 2012 to 2014 extraordinary compensation of USO costs. In Greece, a hearing for perceived breaches of consumer regulation regarding 22 retail customer cases was held by EETT on 20 May 2024. Vodafone Greece submitted its memorandum on 7 August 2024 and the decision is still pending.
In Ireland, Eircom challenged the ComReg’s 2019 findings on USO cost for the periods 2010–2015. For each year ComReg found the net cost of provision of universal service did not represent an unfair burden on Eircom for the years in question. In 2020 the Irish court referred a question to the Court of Justice of the EU (‘CJEU’) concerning the unfair burden assessment. In 2022 the CJEU delivered its judgment, and the Irish High Court consequently made orders for ComReg to review aspects of its decisions in accordance with the CJEU judgment. ComReg has reviewed the years 2010–2011 and in June 2024 again found no unfair burden. In January 2025, ComReg have also published their final decision on the year 2011– 2012 and again found no unfair burden. Access In Albania the national MTRs have been reduced from 1.11 Lek/minute to 1.02 Lek/minute effective from 1 October 2024 according to the relevant NRA decision following the market analysis finalised in February 2024. This is the first step of the two-year glidepath of national MTRs reduction at the end of which the MTR will reach 0.75 Lek/ minute in 2027. In Greece, after extensive discussions with the incumbent (OTE) and following approvals from the EC and EETT granted in July 2024, a wholesale volume discount agreement for OTE FTTH services was signed and entered into force on 8 August 2024. Respective agreements with United Fiber and Fiber2All entered into force in December 2024. EETT launched a public consultation on the main principles of the NGA BULRIC+ model update regarding the wholesale broadband access services in January 2024. A second consultation will follow on the model. Vodafone Greece will push for an updated version to support competition and fibre roll out targets. A final decision is expected during Q3 2025.
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