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The new Role of Regulators - Example IoT Ecosystems Detecon International, Zagreb, 03.12. 2019 Funded by the European Union

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Page 1: The new Role of Regulators - Example IoT Ecosystems · IoT services and low security hardware may be a gateway for espionage and sabotage Security and privacy by design may be required

The new Role of

Regulators -

Example IoT

Ecosystems

Detecon International,

Zagreb, 03.12. 2019

Funded by the European Union

Page 2: The new Role of Regulators - Example IoT Ecosystems · IoT services and low security hardware may be a gateway for espionage and sabotage Security and privacy by design may be required

01 Future Telco

02 Telco NRAs role in IoT Ecosystems

03 Regulatory Challenges

04 Regulatory Approaches

Table of Content

Page 3: The new Role of Regulators - Example IoT Ecosystems · IoT services and low security hardware may be a gateway for espionage and sabotage Security and privacy by design may be required

3

Fundamental Changes

Four Forces drive the 2nd

wave of digitization:

Technology

Customer

Society

Politics & Regulation

Future Telco

2nd

Wave

Internet Platforms

under Pressure

(“BAADD”)

Connectedness and

ComputeSecurity, Individuality

& Convenience

Globalization,

Protectionism,

Regulation

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4

A 2nd wave of digitization competition builds new momentum.

Meta Level View

“Calm Water”

TelCos own control

points

Market barriers

Stable revenues

“WWW - Wild Wild West”

TelCos partially losing control of end-customer

Little regulatory boundaries for internet players

Internet giants tremendously successful on service layer, developing unprecedented worldwide reach

Softwarization further lowers traditional industry boundaries

“Regulated Race for Gigabit Societies”

Welfare of nations depends on Gigabit readiness

Security, public control, ethical aspects will gain relevance

Technologies and business models become subject of industrial politics

Internet and data driven business will be regulated (data protection, privacy, anti trust, tax, sector specific regulation)

1st Wave 2nd WaveiPhone

2007 2018

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5

Players and Directions

Players’ strategic directions determine the Telco framework.

Many OTTs will enter into

the traditional Telco carrier

business

Telcos without own

network will consolidate or

vanish

Corporates may become

own Telcos

Vendors change their role

Integrate connectivity

Concentrate on platform services

Concentrate on platform services

Consolidate with others,vanish

Build own connec-tivity & solutions

Rely on carriers

Offer connectivity & solutions directly

to customers

Rely on carriers

Bypass Carrier with own API based

Eco-Systems

Rely on carriers

Digital Infra Provider Network Centric Digital Service Provider

Eco-System OTT

Corporates

Single Purpose OTT Reseller/MVNO

Trad. Vendors New Vendors

Telcos

Page 6: The new Role of Regulators - Example IoT Ecosystems · IoT services and low security hardware may be a gateway for espionage and sabotage Security and privacy by design may be required

6

Telco Provider

Two main target pictures

exist:

• Digital Infrastructure

Provider

• Network Centric Digital

Service Provider

Portfolio structure follows

the providers position on

the value chain

From pure infrastructure

portfolio to digital service

portfolio

Digital

Infrastructure

Provider

Network Centric

Digital Service

Provider

Physical

Sites

Frequency

License

Data Centers/

IaaS

DevOps

CI/CD

Net-

work

API

Platform

IDM

& BI

Partner

Services

Own

Services

BSS

functions

Touch-

points

Core Telco PlusCore Telco

“Infrastructure”

portfolio

Connectivity Services

Services

Voice

Internet access

VPN

Leased Line

..

Bandwidth

“Digital Network”

portfolio

“Digital Service” portfolio -

example automotive

Quality Options

Reliability

Speed

Security Options

Network

monetization

Ecosystem

platforms

Page 7: The new Role of Regulators - Example IoT Ecosystems · IoT services and low security hardware may be a gateway for espionage and sabotage Security and privacy by design may be required

02Telco NRAs role in

IoT Ecosystems

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8Funded by the European Union

The role of NRAs is becoming complicated in an increasingly complex Telco sector where the boundaries between industries are blurring.

Telco NRAs role in IoT Ecosystems

Traditional Role of NRAs in old Market Structure New Role of NRAs in current Market Structure

Telco sector a national monopoly with one dominant fixed line

carrier and few service providers

Clearly defined separate network specialized on one dominant

service (voice telephony), basically a consumer product

High public share in the sector, stable growth, low innovation rate

Communications traffic and assets concentrated on one country

Telco sector consisting of many global fixed, mobile, satellite,

virtual, private networks with shifted market boundaries and

millions of service providers

Networks/platforms clearly separated from service level, voice a

special case of data, telecom a necessary input to all industries

Small public share in the sector, volatile growth, strong innovation

Traffic routed globally, many stakeholders multinationals

Regulatory focusasymmetric (monopoly), ex ante, national, retail markets

Regulatory focussymmetric (horizontal), ex post, international, wholesale

markets

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9Funded by the European Union

Global SIM and HW-manufacturers

Delivery of IoT Services

Hardware &

Data sourcingConnectivity Interoperability

Security /

Privacy

Data

Management

Computing

resourcesAnalytics

Gather / Generate data for the applications and services

Transport the data through various connectivity media through to aggregation

Manage connectivity, aggregate data streams

Manage security of application and users, manage privacy

Enable vertical and horizontal application development and operations

Create value from the data that the IoT provides

Store, protect and process data while guaranteeing its accuracy, accessibility, reliability and timeliness

Sensors, camera, user phones, cars, positioning device...

WiFi, 2G, 3G, 4G, 5G, ADSL, ...

Mediation devices and platforms

Firewalls, policies Cloud platform BI and Big Data tools and platforms

Enterprise bus, identity management

Local MNO/ MVNOs MNO, MVNO, CSP, OEM

CSP CSP, OTT players Platform providers, OTT players

Specialized ICT

Example

Role

Players

The IoT value chain is an example where partnering between industries is key for successful delivery. Depth and content of regulation is challenged.

Telco NRAs role in IoT Ecosystems

TRA Regulatory Tasks

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10Funded by the European Union

Communications services are becoming a core product of many non-Telco industries and thus the regulatory area of responsibility becomes unclear.

Telco NRAs role in IoT Ecosystems

Examples of Digital Services with a Telco component in end-to-end delivery

Modern ICT services are forcing NRAs to co-operate with other national and international public Regulatory Authorities.

Smart metering

Autonomous cars

Mobile payments

Remote health monitoring

Remote steered Drones

Utilities Regulators

Regulators for Traffic Safety

Financial Serv. Regulators

National Health Regulator

Air Security Regulators

Telco Regulatory Authority

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11Funded by the European Union

In a future Industry 4.0 environment NRAs increasingly have to co-operate, partner, network and take initiative for evolutionary regulation.

Telco NRAs role in IoT Ecosystems

Other Vertical Regulatory Authorities Telecom National Regulatory Authority “Horizontal” National Legislation

Data privacy and security

Cybersecurity

Consumer protection (B2C and B2B),

including e-commerce and audiovisual

media

Contract law (e.g. M2M contracts, digital

signature, liabilities of intermediaries)

Competition law

Taxation (double taxation, tax avoidance)

Intellectual Property Rights / Copyrights

Education and inclusion in ICT

….

ICT Ecosystems

InitiativesCo-operation

Telecom Sectorenables

Spectrum, Numbering, Licensing

Standardization, Type approval

….

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12Funded by the European Union

The structure of an NRA should be adapted by creating a horizontal “Digital Transformation Unit” and vertically responsible “Sector Units”.

Telco NRAs role in IoT Ecosystems

Organizational Improvements to adapt to Digital Transformation

Ministry for Digital

Transformation

Other Ministries

Parliament, Councils

etc. with the right to

introduce draft laws

Finance Sector

Regulator

Energy Sector

Regulator

...

ICT Sector

Expert Units

Digital

Transformation

Unit

Telecom

Regulatory

Authority

Other TRA

Units

ICT related Laws

Other Sector

Regulators

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13Funded by the European Union

The autonomous car ecosystem is an example how the future co-operation between TRA, Traffic Regulation and Government Legislation has to work.

Regulatory Challenges

Example: Traffic Sectors Example: BNetzA (German NRA) Example: Government

Traffic Sector regulation in Germany

(2017) Traffic Infrastructure

Regulation:

Several roads opened for testing

autonomous driving, in particular

motorways in Bavaria and a city route in

Berlin. Further to come in other Federal

States

(2017) Automotive Sector: >52% of world

wide patents about autonomous driving

handed in by German Industry

Telco regulation in Germany

Spectrum: (2019) 300MHz of spectrum

3.4-3.7GHz bands have been auctioned

with strong coverage, latency and

throughput obligations (all roads).

Identifiers: (2016) permanent

extraterritorial use of national numbers for

M2M use allowed.

Roaming: (2017) EC decision to abolish

international roaming fees within EU

Legal development in Germany

2017: Ethical Commission releasing a

report with 20 recommendations on

guidelines for autonomous driving

including rules, if an accident cannot be

avoided.

2017: Minister for Traffic and Transport

introduced a change of the general

traffic law including possibility for

automated / autonomous driving

Many liability issues still unsolved, in

particular for artificial intelligence software

producers.

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03 Regulatory

Challenges

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15Funded by the European Union

The worldwide revenue generated from IoT is expected to increase by 67 percent by 2022. However only a small part will use regulated spectrum.

Growth in revenue from IoT, worldwide (in USD million) Growth in revenue from IoT, by vertical (in USD million)

3,500,000

0

1,000,000

2,500,000

500,000

1,500,000

2,000,000

3,000,000

2,119,391

3,025,049

2018 2019 2020 2021 2022

2,726,245

1,816,343

2,426,539

+67%

1,500,000

500,000

3,000,000

1,000,000

2,000,000

2,500,000

3,500,000

0

211,852

20192018 2020 2021

633,088

204,086

454,796

2022

527,603

431,954

411,312

150,358

+14%

Connected Business

Connected Consumer Electronics

Connected Energy

Connected Health

Connected Home

Connected CitiesConnected Industry

Connected Car

Source: Machina Research, 2017

Regultory Challenges

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16Funded by the European Union

Spectrum falls clearly under jurisdiction of Telecom NRAs. However, for

different IoT use cases different unregulated access technologies coexist.

Regulatory Challenges

RFIDNFC

DECT

IEEE802.15.46LoWPAN

Low

Ban

dwid

thLo

w P

ower

/C

ost

Hig

h B

andw

idth

/D

ecen

t Ene

rgy

Wide Area Local Area

QR

Wide Area / Cellular Local Concentrator

Wide Area Low Power Local Use (Low/No Power)

NB-IoT

Regulated

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17Funded by the European Union

There are at least 12 different areas where regulation might play a significant role in developing the IoT markets.

Areas of regulatory focus in IoT markets

While some areas are

clearly in the responsibility

of the TRAs, others have to

be aligned with other

stakeholders and regulators

Regulatory Challenges

Coverage

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04 Regulatory

Approaches

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19

Regulatory Approaches

The general trend is to shift the regulation focus from infrastructure to cloud, OTTs and Artificial Intelligence.

Telco Infrastructure –

increase

consolidation options

Fixed

Further regulate only SMP wholesale

markets

Accept commercial arguments to push

fixed wholesale partnerships to lower

redundancy and increase RoI in fiber

Mobile

Set strong area coverage targets as a

shared industry target

push 5G network sharing / wholesale

mobile providers setup

Allow for corporate mobile networks

Bill&Keep principle

IT / Services –

increasing pressure

on OTTs

Cloud computing Other trends

EU Digital Single market “Supporting

cloud in Europe”

Data ownership

Liability

Standards, interoperability &

portability

OTT taxation (ASEAN)

First regulation idea on AI in EU

(EIT/JRC workshop)

GDPR enforcement

Increased attention on OTTs M&As

(after FB acquired Whatsapp)

Further commit to Open Internet in EU

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20Funded by the European Union

There are three general regulatory principles that should be followed when regulating IoT services.

Regulatory Approaches

No compromise in

security and

privacy

No overregulation

Evolutionary

approaches

IoT services are a nascent industry that needs freedom to develop

Ex ante regulation only in exceptional cases, in particular specific telecom services license requirements

Unless specific challenges are appearing a policy of forbearance of new services may be recommended

Ex post regulation is a tool to correct unwanted developments

IoT services and low security hardware may be a gateway for espionage and sabotage

Security and privacy by design may be required for all imported and produced IoT devices (type approval)

Security development guidelines for software may be required

EU best practice GDPR requirements for all services including IoT

No overregulation does not necessarily mean to wait and do nothing for a TRA

New vertical services may be observed and followed up with an evolutionary approach to regulation along

use cases

For this the NRAs have to organize themselves in project groups together with other stakeholders (other

regulators, Ministries, industry,…)

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21Funded by the European Union

Connectivity services in an IoT partnering network is typically provided by MNOs or MVNOs, if wide area mobile connectivity is required.

Regulatory Approaches

SIM card type / form factor

Data-, SMS-, Voice-services

Data volume (pooling), # of SMS, Voice

minutes

Roaming capabilities (countries, areas)

Local breakouts

Connectivity / Service portal required?

Setup of platform account

APN setup (public, private)

VPN setup

IP addresses

SIM Connectivity Management Network Operation Service

Network operation center (NOC) for

mobile & fixed line services

National / International WAN

Helpdesk services (2nd/3rd level)

Service assurance / incident

management

SLA monitoring

National application / licensing process

SIM card activation / deactivation

Data limit supervision

IP session monitoring

Roaming monitoring

SIM card ordering & shipping

SIM contract / tariff maintenance

SLA monitoring

Helpdesk services (1st level)

National service licenses, restrictive spectrum regulation, restrictions of permanent roaming and permanent use of foreign identifiers, retail price regulation as well as restrictive rules for data hosting are major regulatory bottlenecks for the

development of IoT solutions.

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22Funded by the European Union

IoT Privacy policies need to carefully consider the Thing/Person correlation, having due regards to protection of personal information.

Asset tracking

Public Interest

Digital maps

The may be public interest debates for tracking people, or informing the location of people which over-rides the

right to privacy:

• Law enforcement/ anti-terrorism Hospital patients

• Mentally disabled Emergency/ Disaster assurance

• The European GPRD doesn’t cover tracking of assets, only people.

• Europe is considering an ePrivacy Regulation, which deals with location risks.

• An “informed consent” approach is being adopted.

"Privacy has already been a consideration for our products and services for a long time. Therefore, the

concepts of privacy by design and privacy by default are not new. However, the formal aspects of data

protection impact assessments are new requirements that have to be integrated into the product

development process”Philip Fabinger, global privacy counsel for HERE Technologies (owned by Audi, Daimler and BMW)

Regulatory Approaches

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Regulatory Approaches

Communication SecurityWiFi, Bluetooth, NFC, Lora, ZigBee …

Physical Access SecurityDebug Interfaces (JTAG, IO, …)

OS SecuritySystem Level Software

Low-level Software SecurityFirmware, Drivers

Application & Data SecurityUser-Facing Software & Services

Regulators dealing with IoT Security (e.g. by certification) have to addressall attack surfaces of an IoT device.

Regulatory Bodies &Standard Development OrgsITU, National-level, ISO, ETSI …

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24Funded by the European Union

Regulatory Approaches

Mission Critical IoT Services or those implemented in vital infrastructures may need to be regulated differently than others.

Special regulations for Mission Critical IoT services

General regulations (best practice)

Key features of the device involved in collecting data, sensor inputs (camera, microphone,…) and location identifiers shall be indicated on the device, its packaging and in the user documentation.

Device must have the capability for users to reset to factory standard

“Security and Privacy by Design” shall be incorporated in the device to protect against unauthorized usage.

Special regulations for mission critical IoT (best practice)

Mandatory Over the Air / remote provisioning of eSIMs of IoTdevices used for mission critical services has to be possible.

IoT service providers offering mission critical IoT services have to register with the TRA and obtain an IoT Service Registration Certificate.

Such service providers may be obliged to maintain subscriber information that may be transmitted to the TRA upon request (name, address, ID, device model and registration number, etc. e.g. for owners of drones)

ENISA recommendations for NRAs

Clarify liability among IoT actors.

Harmonize efforts on IoT security standards

Establish an IoT baseline for security interoperability

Design security development guidelines for software

Definition

Mission Critical IoT services means an IoT service that if fails may result in an adverse impact on health of individuals, safety and/or national security.

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25Funded by the European Union

Pro-active role in formulationg “e-legislation”

Support vertical industries in the digital transformation process

Take a role in international harmonization and approximation of digital transformation

The future role of NRAs implies to extended pure Telco regulatory tasks to digital industries, improve human capital and introcuce new processes.

Summary

New Competences,

Responsibilities, Tasks and

Objectives for NRAs

Development of Human

Capital

Work Process

Cybersecurity, privacy, data security specialists

Vertical industry specialists as interface to other sector regulators

Technology specialists for pro-active impact assessment on regulation (AI, AR/VR, blockchain,

digital twins,…)

Project work organization with vertical end-to-end digital services stakeholders

Evolutionary approach to IoT regulation along use cases

Light touch regulation for emerging new technologies and services without compromise on security

Page 26: The new Role of Regulators - Example IoT Ecosystems · IoT services and low security hardware may be a gateway for espionage and sabotage Security and privacy by design may be required

Your contact!

Dr. Arnulf HeuermannDetecon International GmbHManaging Partner

Sternengasse 14-1650676 Cologne (Germany)Phone+49 221 9161 1550Mobile: +49 171 2254217

e-Mail: [email protected]