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5January2026 About the GSMA The GSMA is a global organisation unifying the mobile ecosystem to discover, developand deliver innovation foundational to positive business environments and societalchange. Our vision is to unlock the full power of connectivity so that people, industry,andsociety thrive. Representing mobile operators and organisations across the mobileecosystem and adjacent industries, the GSMA delivers for its members across threebroad pillars: Connectivity for Good, Industry Services and Solutions, and Outreach. Thisactivityincludes advancing policy,tackling today’s biggest societal challenges,underpinning the technology and interoperability that make mobile work, and providingthe world’s largest platform to convene the mobile ecosystem at the MWC and M360series of events. We invite you to find out more atgsma.com. Follow the GSMA on Twitter:@GSMAand@GSMAEurope About Connect Europe Connect Europe is the voice of the leading providers of connectivity networks andservices in Europe. Our members are at the forefront of innovation in the telecom andtechnology ecosystems, connecting over 270 million Europeans with cutting-edgemobile and fixed networks, such as fibre and 5G. They also deliver advanced services,ranging from first-class IT, AI and cybersecurity solutions, to entertainment and content.As the main investors in the industry, our members drive the digital transformation of theContinent , accounting for more than 70% of total telecom sector investment in Europe.Formerly known as ETNO, we stand for an improved policy and regulatory environmentthat enables citizens and businesses to benefit from digital connectivity and services.Weinvite you to find out more atconnecteurope.org. Follow Connect Europe on X:@Connecteuropex. Introduction The GSMAand Connect Europe, representing the European mobile communicationsindustry, welcome the opportunity to comment on the DraftRSPGWork Programme 2026and beyond. Weappreciate RSPG’s commitment to transparency and stakeholder inputs. At the sametime, we would welcome further opportunities to contribute as the programme develops.For example, by actively participating or providing input in the Peer Review activities sodiscussions can reflect the practical experience of those delivering connectivity acrossEurope. This work programme comes at a very important moment for the sector. Europe isreassessing how it supports digital networks, services and investments–and thedecisions taken now will set the tone for the coming years. Through the Digital NetworksAct and otherlegislativeproposals, the bloc has an opportunity to tackle fragmentedregulation and long-standing underinvestment. Given that spectrum is a core enabler of digital growth, innovation and advancedconnectivity, it is important that the RSPG’s expertise is fully reflected in the wider policyprocess. By drawing on RSPG’s insight, the EU can ensure that the spectrumpoliciesnowunder development support a harmonised, pro-investment and future-proof frameworktosecure and resilientconnectivity across the Union. On the specific work items detailed in the draft work programme, the GSMA and ConnectEurope would like to provide the following comments. Peer review and Member States cooperation Mobile networks are critical infrastructureserving European society.They requirecontinuous investments forremaining capable ofserving current and future connectivitydemands.As GSMA and Connect Europe stressed during the RSPG’s stakeholderworkshop in October 2025, it is essential that spectrum licensing in every Member Statecreates the right conditions for the investment needed to deliver high-quality mobileservices acrossthe EU. Thus, RSPG’s Peer Review group can make a meaningfulcontribution by supporting consistent, well-designed approaches to awards. To that end,we outlined a set of measures that the group, together with each Member State, shouldconsider. For competitive and comparative award procedures it is important that key informationis shared in a clear and timely manner, assessed openly, and discussed with all relevantparties. The group should continue to invite input from stakeholders directly involved in awards, as this helps ensure that practical experience is reflected and that lessons fromeach award are carried forward. We believe,however, it would be helpful for the group to compile comparablemetricsonkey features of national licensing frameworks, such as award types (competitive,prolongation), spectrum fees, reserve and final prices, and any set-asides or relatedjustifications. A shared evidence base of this kind would support more consistentpractices across the EU and help inform future policy decisions. There are ongoing discussions at EU level regarding a review or replacement of article 35of the EECC, to strengthen consistency and promote best practices in Member States'approaches to spectrum authorisations and awards. GSMAand Connect Europeadvocate for clearer EU guidelines on key aspec