Pressure to deliver guidance is suppressing commercial activity which in turn is making guidance more challenging to reach. Although the dividend is well covered for now, the deteriorating cashflow outlook is unhelpful.

The change in strategy to give autonomy to country markets and to be more customer-centric has its merits but is not consistent with many Group initiatives and will take a long time to bear fruit.

Vodafone reiterated its intention to merge with H3G in the UK. Recent setbacks to approval prospects may not be as detrimental as they appear, and there is much to be gained with the potential to increase cashflow four-fold.

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Cross-party support for an 11th hour amendment to the Online Safety Bill’s Commons report stage has forced the Government to agree that a new criminal liability for tech executives will be added in the Bill’s passage through the Lords.

The proposed amendment cites faulty precedents, including in financial services, and a new, not yet established Irish online safety regime that is lengthy in procedural steps before criminal sanction.

The introduction of criminal liability will not strengthen the safety objectives of the bill. It is at odds with the approach of the wider regulation, and is practically unworkable.

The amended Online Safety Bill contains sensibly scaled back provisions for “legal but harmful” content for adults, retaining the objectives of removing harms to children and giving users more choice. However, this comes at the expense of enhanced transparency from platforms.

News publishers have won further protections: their content will have a temporary ‘must-carry’ requirement pending review when flagged under the Bill’s content rules. Ofcom must keep track of how regulation affects the distribution of news.

The Bill could be further strengthened: private communications should be protected. Regulators will need to keep up with children’s changing habits, as they are spending more time on live, interactive social gaming.

Telcos are pressing the EU to force big tech to make a ‘fair contribution’ to their network costs, although this has drawn opposition from telecoms regulators, who rightly fear risks to the wider ecosystem

There are valid concerns to address however, with content providers not currently incentivised to deliver traffic efficiently, and telcos constrained by net neutrality rules from doing anything about it, resulting in unnecessary costs and service degradation

However, there may be better ways to address these, through reforming the implementation of existing rules to encourage more efficient content delivery, and allowing the telcos to provide enhanced delivery routes of their own, with Ofcom’s approach in the UK a step in this direction, but perhaps not a step far enough

The BBC announced that it should be active in planning for broadcast switch-off, but that the UK should be fully connected with universal affordable access to content.

World Radiocommunications Congress (WRC-23) takes place next year and the long-term future of DTT across EMEA will be debated. If WRC agrees coprimary access to existing DTT spectrum for mobile, this likely spells the end for DTT in the early 2030s.

By 2034, at the current migration rate, nearly 20 billion hours of TV will be viewed in DTT homes—just 20% less than today—with over 80% of that being to adults over 55.

As more viewing is delivered on-demand and online, the jeopardy and immediacy of sport make it one of the few genres which will remain overwhelmingly live.

Shared national experiences that allow as wide an audience as possible to follow simultaneously are increasingly rare in a fragmented media landscape, and public service broadcasters are still the only media capable of providing them.

The listed events regime should not just be protected but at least extended to include live digital rights: although the vast majority can presently access these events via DTT, changing viewing habits, eventual DTT switch-off and a shift in how rights are packaged means that action should be taken now to guarantee continual full, free availability.

Openreach has simultaneously announced that it is applying a full 11% inflationary price increase across all its key products, and effectively removing this price increase (and a bit more) for full fibre products through an update to its ‘Equinox’ special offer pricing.

Equinox 2's purpose is described as to encourage migration of existing connections to full fibre, but this is hard to see, and it looks more like a defence against migration to altnets and/or VMO2’s emerging wholesale proposition, albeit one that seems like it will not fall foul of regulatory rules.

Openreach will still benefit from the 11% price increase across most of its revenue base in 2022/23, and the shift to FTTP will remain accretive. Openreach’s customers will suffer from the price rise, but with a stronger outlook as they move to FTTP, while the altnet/VMO2 wholesale economics are as-you-were.

BT Consumer’s move to the EE brand is a gradual one, with an EE re-launch due next year set to accelerate this, although the BT and Plusnet brands will not be withdrawn in a hurry.

The company is hoping that the new converged EE will drive new revenue streams, a challenging task, but one that it is approaching with realism, and building on previous success.

BT confirmed that the inflation-plus price rise will be applied next year, along with a hope-to-be-sustained increase in front book pricing too. The cost-of-living crisis is putting pressure on ARPU, with FTTP likely to only partially compensate.

Market revenue growth of 2% in Q3 was slightly lower than the previous quarter, but remained firmly positive at least.

The dual impacts of slowing broadband volume growth and consumer price sensitivity will likely hit volumes and ARPU even harder over the tough winter to come.

Inflation-linked price increases will give some operators a boost next year, but their very high levels (c.15%) will be hard to manage during a cost-of-living squeeze.

Vodafone’s downgraded guidance is due to its woes in Germany rather than the economy. There is some limited reassurance that this will turnaround soon.

It remains challenging for Vodafone to achieve its revised FY guidance with a 7ppt improvement in underlying EBITDA growth required to get there.

Leverage and cash-calls are much improved, and the dividend looks assured, but the Vantage and German deals mean escalating pressures on EBITDA.