The game may well be over for predatory roaming charges. A small digital tool is doing what regulators struggled to do for years.
Demand for travel eSIMs is on course to jump by around a third this year, and Brussels is already scrambling to work out what that means for the EU telecommunications package currently in the pipeline. Analysts at FDM CCS Insight estimate that around 134m travel eSIMs will have been used globally by the end of 2026, up from 101.8m in 2025. The five most popular eSIM apps have already been downloaded more than 26m times so far this year. For European mobile operators, the numbers spell trouble.
The market is growing fast. Researchers at STL Partners estimate it was worth £649m in 2025 and could reach £3.2bn by 2030. More than 326 handsets accepted eSIMs in 2025. This marks an increase of almost 50 per cent on the previous year, according to mobile industry body GSMA.
Charges under threat
Current EU’s rules obliges operators to offer the same quality of service abroad as at home, leaving eSIM sellers off the hook. This is a gap that the incoming telecoms package will have to close. Vykintas Maknickas, chief executive of Saily, an eSIM operator owned by NordVPN developer Nord Security, put it plainly. “The market’s moving from educating customers to converting them and that conversion is accelerating,” he said.
The economics are stark. A Revolut eSIM offers 1GB of data over seven days for £3.49. BT-owned EE can charge £8 for 500MB in a 24-hour period. That gap is wide enough to drive a regulatory lorry through. It is precisely what Brussels will now have to address.
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Roaming revenue matters to operators. It accounts for between three and five per cent of revenues, according to Joe Gardiner, analyst at FDM CCS. He notes that this income is typically higher margin. Juniper Research estimates that travel-eSIM take-up rose 85 per cent in 2025 and could drain up to $11bn in annual roaming revenue by 2028 if operators do nothing.
Wholesale data caps are falling at the same time, to €1.10 per GB in 2026 and €1 per GB in 2027. This is compressing margins further.
Detect and surcharge
Operators are not passive. Industry surveys show 45 per cent of them are already seeking to detect and potentially surcharge travel-eSIM traffic. Vodafone and Orange have launched white-label travel eSIM pilots of their own. The incumbent argument is consistent: pure-play eSIM brands free-ride on their networks, cherry-pick lucrative travellers, and contribute nothing to 5G roll-outs.
Hermann Frank, chief executive of Gigs—the connectivity start-up whose technology underpins the mobile offerings of Revolut and Klarna—rejected that framing. “The structural advantage that these players have is that they don’t have to pay for customer acquisition cost and have a better user experience as well; you just need to click a button on the app,” he said.
The structural advantage that these players have is that they don’t have to pay for customer acquisition cost and have a better user experience as well. — Hermann Frank, Gigs
Mr Gardiner, for his part, was measured. “How [operators] react to that challenge, whether that’s through innovation, pricing parity or better service, will determine how much of that revenue is at risk,” he said.
What Brussels must now decide
The EU’s 2022 Roaming Regulation requiring operators, unlike eSIM sellers, to offer the same quality of service across the EU, creates a gap. It is not a matter of theory. The Commission’s 2025 roaming-market review warns that divergent eSIM fair-use limits could confuse consumers and undermine the price-comparison clarity that EU law demands.
The same review, however, explicitly cites eSIM as “an important development that could facilitate competition and switching in mobile connectivity including roaming”. Brussels, in other words, wants the benefits without the disorder.
Three regulatory questions now dominate. First, whether remote SIM provisioning counts as a roaming service subject to retail-rate parity and consumer-protection clauses. This is a question BEREC is expected to address. Second, whether the Commission should mandate reference wholesale-access offers for eSIM traffic, mirroring the fixed-line local-loop unbundling rules of the early 2000s.
The level playing field that isn’t
Third, whether travel-eSIM sellers should be required to display an effective euro-per-GB price across all covered countries and issue usage alerts. This is what Regulation EU 2022/612 already guarantees for traditional roaming.
A fourth question is technical but consequential. ETSI is drafting eSIM profile-quality standards under the SGP.32 framework. The EU could accelerate their adoption to guarantee caller-location and lawful-intercept capability for any eSIM profile active in the bloc. Emergency-call mandates, currently absent for third-party eSIMs, would follow.
The market’s moving from educating customers to converting them, and that conversion is accelerating. — Vykintas Maknickas, Saily (Nord Security)
The eSIM boom also intersects with a broader competitive pressure on incumbents. Mobile virtual network operators (which use established networks to offer full mobile services without building infrastructure) already strain operator margins. The FT reported in May that the UK’s three mobile network operators experienced their worst year of customer losses on record in 2025. Travel eSIMs are an additional front in the same war.
Small, silent, effective
The Commission’s next regulatory cycle, expected in 2027–28, will need to reconcile three objectives that do not sit easily together. Affordability and choice for travellers, sustainable network investment for operators, and level-playing-field obligations for every party selling mobile connectivity in the single market — that would be precisely what regulators usually have in mind when dealing with complex business environments’ problems.
The eSIM, small, silent, and downloadable in seconds, has forced that reckoning earlier than anyone in Brussels anticipated.
