Kingdom of Saudi Arabia

Key Facts

Zain KSA needed to respond to the Communications & Information Technology Commission of the Kingdom of Saudi Arabia public consultation on licensing mobile virtual network operators.



Strategic advisory, Regulatory advisory, Market insight, Commercial modelling, Business strategy


In 2012 the Communications & Information Technology Commission (CITC) National Regulatory Authority publicly consulted on their desire to introduce new competition in the mobile market through licensing three Mobile Virtual Network Operators (MVNOs). Whilst recognising the benefits arising from new competition, our client Zain was nevertheless concerned about the impact on their nascent business such new entrants could have.

Having launched in 2008, into a market dominated by STC and Mobily, Zain had made rapid progress taking 14% market share. However, structurally they were facing headwinds relating to wider mobile telecommunication market competition issues such as the implementation of a ‘Long Running Incremental Cost’ model to set equitable inter-operator mobile termination rates, coupled with clear and transparent controls on cross-subsidy and bundling.


Our client needed to respond to CITC’s consultation clearly setting out Zain’s concerns and commercial position, whilst also ensuring that Zain would be able to support a new MVNO commercially, operationally, and technically should the CITC introduce new MVNO licensees – as consequently happened.

Piran Partners, working closely with Zain’s senior executives and legal team, drafted the formal response addressing the consultation questions relating to the competitive impact, potential licensing approaches, timings and key principles.
As an essential input into this process, we developed Zain’s first ever wholesale strategy providing:

  1. an internal ‘playbook’ addressing the strategic and tactical measures required to mitigate the competitive pressures that would naturally arise from new MVNOs entering the market using STC’s and Mobily’s networks, and
  2. the commercial and operational ‘blueprint’ setting out how Zain would need to support an MVNO – in the likely event of the commercial and operational ‘blueprint’ setting out how Zain would need to support an MVNO – in the likely event of the Regulator approving the licensing of MVNOs – whilst minimising the impact to Zain’s existing retail operations and business.


With the introduction of new MVNO licensees in 2012, we were pleased to see that many of Zain’s recommendations were adopted by CITC, and Zain was able to move quickly into its market engagement with prospective MVNOs and its foreign partners stipulated as a licence condition.

In our work we were guided by our experience advising and launching many MVNOs in the United Kingdom and Europe, and supporting mobile network operators in their engagements with MVNOs and regulators alike. As an independent advisory we craft strategies reflective of local market conditions and our client’s position in these markets.