Ukraine joining the EU roaming area - “Roam-Like-at-Home”
The practical implementation of the Joint Statement was also important in the context of the dialogue on Ukraine’s joining the EU roaming area - “Roam Like at Home” (RLAH).
To implement the agreement on this matter reached between the Parties, the Association Agreement was updated with Ukraine’s commitment to implement the EU acquis on roaming (Decision No 1/2023 of the EU-Ukraine Association Committee in Trade configuration of 24 April 2023 modifying Appendix XVII-3 (Rules applicable to telecommunication services) of Annex XVII to the Association Agreement).
For the purpose of practical implementation of the above-mentioned ACTC decision, the NCEC established a Working group on Ukraine’s joining to the EU “Roam-Like-At-Home” policy, chaired by the NCEC and with the participation of representatives of the Ministry of Digital Transformation of Ukraine, mobile operators, the Association of Telecom Operators “Telas”, as well as experts from the project “Digital Policy Support to Ukraine” (DPS2UA).
During 2023-2024, the Working group drafted comprehensive proposals for amendments to the legislation of Ukraine implementing the relevant EU acquis, necessary for Ukraine’s joining RLAH by obtaining an internal market regime with the EU for roaming services for Ukraine. The relevant package of documents, among other things, includes:
2) NCEC Resolutions on the approval/establishment of:
- Rules for providing regulated retail roaming services;
- Single maximum termination rates for voice traffic on mobile and fixed communication networks originating from European Union numbers or Ukrainian numbers roaming in the European Union, charged by wholesale service providers for the provision of voice traffic termination services;
- Conditions and rules for providing wholesale access (including wholesale charges for regulated roaming services) to public mobile electronic communications networks for providing regulated roaming services;
- Rules for applying the fair use policy to the consumption of regulated retail roaming services provided at the applicable domestic retail prices in order to prevent abusive or anomalous use of regulated retail roaming services by roaming customers in the Ukraine – EU roaming zone and the imposition of surcharges for the consumption of retail regulated roaming services in excess of any limits under any fair use policy;
- Procedure and methodology for assessing the sustainability of the provision of retail regulated roaming services at domestic prices;
At the end of 2024, the Ukrainian side, in accordance with the provisions of Article 4 of Annex XVII to the Association Agreement, notified the European Commission of the transposition of the EU acquis on roaming, necessary for granting the internal market treatment for roaming in public mobile communications networks. At the same time, within the framework of the European Commission’s preliminary assessment of the notified legislation, to avoid the possibility of postponing the adoption of the eventual ACTC decision to grant internal market treatment in the roaming sector, given the need for additional time necessary for the full implementation of certain provisions of the EU law due to Russia’s ongoing war of aggression against Ukraine, the Parties amended Part “A” of Appendix XVII-3 of Annex XVII to the Association Agreement with additional relevant clarifications (ACTC Decision No. 1/2025 of 13.03.2025).
Based on the results of the work carried out by the NCEC on the implementation of EU roaming legislation, following its assessment, the European Commission determined that Ukraine meets the necessary requirements for implementing the EU roaming rules.
Consequently, in mid-July, the European Union and Ukraine granted each other internal market treatment with respect to the sector of roaming on public mobile communications networks (ACTC Decision No. 2/2025 of 16.07.2025). The market treatment for roaming applies starting 1 January 2026. This is the first time that the EU has extended its internal policy to a country that is not a Member State or a member of the European Economic Area (EEA), Ukraine being the example of the full integration of one of the sectors of the economy into the Digital Single Market.
In order to ensure the necessary level of coordination, exchange of information and developing common approaches to the proper practical implementation of the ACTC decision regarding the internal market treatment for roaming, the NCEC established the Working group on the implementation and ensuring the functioning of “Roam Like at Home” (RLAH) in Ukraine (NCEC Decision of 30.07.2025 No. 468).