TRC Clarifies 5G Fixed Wireless Access Licensing Conditions

In 2024 the Cambodian authorities issued clarifications relating to the licensing of fifth-generation (5G) fixed wireless access (FWA) services. The clarifications address the treatment of 5G-based FWA under existing telecommunications licences, the spectrum arrangements applicable to such services, coexistence with mobile 5G deployments and the customer-facing considerations that arise where FWA is used as a substitute for or complement to fixed broadband.

The clarifications are relevant to mobile network operators exploring FWA as an extension of their existing 5G plans, to fixed-line operators considering FWA as a means of extending coverage, to internet service providers evaluating partnerships or wholesale arrangements and to enterprise customers considering FWA for connectivity.

The clarifications confirm that 5G FWA services fall within the scope of existing telecommunications licensing frameworks, with specific considerations relating to spectrum, service quality and consumer protection. Operators that hold appropriate telecommunications licences and that have access to the necessary spectrum can, in principle, offer FWA services alongside their mobile offerings, subject to observance of the applicable conditions.

Where FWA is offered as a substitute for traditional fixed broadband, the clarifications indicate that customer-facing rules applicable to fixed services, including those relating to advertising, service level commitments and complaint handling, apply to FWA in a manner appropriate to the technology. Purely wireless implementation does not exempt the operator from expectations relating to service quality and consumer protection.

5G FWA depends on access to sufficient spectrum in the bands identified for 5G deployment. The clarifications describe how existing spectrum authorisations may be used for FWA, how coexistence with other 5G use cases is expected to be managed and how additional spectrum may be requested where existing holdings are insufficient. The authorities recognise that FWA may have specific technical characteristics, including higher sustained load per user, that influence spectrum planning.

Operators are expected to plan their 5G deployments so that FWA users and mobile users can coexist without unreasonable degradation of service, and to be able to demonstrate to the regulator that spectrum is being used efficiently across the range of intended use cases.

FWA services differ from fibre-based broadband in a number of respects, including susceptibility to environmental conditions, dependence on line-of-sight or near-line-of-sight, and shared capacity with mobile users on the same cells. The clarifications expect operators to describe these characteristics honestly to potential customers, to configure services to deliver predictable performance and to design service level commitments that are realistic for the technology.

Operators are also expected to invest in installation, in customer support and in ongoing monitoring, so that FWA delivers a positive customer experience over the lifetime of the subscription. Where performance falls short of what has been described to customers, appropriate remedial action should be taken.

Because FWA and mobile 5G share the same underlying network, careful capacity planning is required to ensure that neither category of use unreasonably crowds out the other. The clarifications encourage operators to be transparent about their capacity planning assumptions and about the arrangements in place to manage congestion. Where cells consistently reach capacity, further investment or targeted traffic management may be appropriate.

Traffic management practices should respect the principles that apply more generally to the operation of Cambodian networks, including reasonable and transparent treatment of different types of traffic and adherence to any specific rules relating to net neutrality where these are addressed by the regulator.

Consumers considering FWA as a substitute for fixed broadband are entitled to clear information about the service, including the expected performance in their location, the impact of environmental conditions, the differences between FWA and fibre-based alternatives and the terms of any speed commitments. Marketing materials should not use language that overstates the comparability of FWA with fibre where meaningful differences exist.

Operators are expected to provide effective complaint handling, to acknowledge legitimate concerns about performance and to offer proportionate remedies where the service does not meet the reasonable expectations that have been created.

FWA can be a valuable option for enterprise connectivity, particularly in locations where fibre is not economically available. The clarifications support the use of FWA for enterprise applications, subject to appropriate arrangements around service level commitments, security and cooperation with the customer's own IT and communications infrastructure.

For community and public sector connectivity, FWA may be used to extend broadband access to areas that have historically been under-served. The framework encourages such use, particularly where it forms part of coordinated efforts to improve digital inclusion.

For operators considering FWA, the clarifications call for careful planning of network architecture, of spectrum use, of commercial propositions and of customer communications. Coordination between mobile and fixed business units may be necessary where operators offer both categories of service. Legal, marketing and technical teams should work together to ensure that offers are compliant with the applicable rules and consistent with realistic expectations of performance.

For competing fixed-line operators, the clarifications suggest that FWA will develop as a meaningful alternative in some segments of the market. Competitive responses should focus on the strengths of fibre-based offerings and on transparent communication of the differences between technologies.

For enterprise and community customers, the clarifications support informed decisions about the role of FWA in their connectivity strategies, including where it should be used as a primary connection, as a resilience option or as a temporary solution.

Lex Civora advises operators, competing providers and enterprise customers on the interpretation and application of the 5G FWA clarifications, on the design of licensing and spectrum arrangements, on commercial and consumer-facing terms and on engagement with the regulator on issues arising from FWA deployment.