Consumer ProtectionApril 2024In force

Quality of Service Benchmarking Introduced for Mobile Operators

TRC formalised a quality of service measurement framework covering coverage, call setup success, dropped call rate and mobile broadband performance indicators.

Development

The Telecommunication Regulator of Cambodia formalised a quality of service (QoS) measurement framework for mobile networks in April 2024. The framework identifies the key performance indicators (KPIs) that operators are expected to measure and report periodically, sets out how measurements should be conducted and provides for independent verification. It applies to all licensed mobile network operators and forms part of the regulator's broader approach to consumer protection and service transparency.

The framework consolidates and updates a range of earlier expectations relating to network performance, drawing on international benchmarks and on measurement practice already used by the regulator in ad hoc campaigns. It is intended both to give consumers a more reliable basis for comparing operators and to give operators a common set of definitions and methodologies against which their performance will be assessed.

Key performance indicators

The framework defines a core set of KPIs covering coverage, network availability, call setup success rate, dropped call rate, voice quality, SMS delivery success and latency, and a series of mobile broadband indicators including data throughput in downlink and uplink, latency, packet loss and connection setup times. Definitions and calculation methods for each indicator are provided, together with the target values or thresholds that the regulator considers acceptable in ordinary conditions.

The KPIs are expected to be measured across representative geographic areas, times of day and network layers, so that the results reflect the experience of typical users rather than only that of central business districts or off-peak periods. Some KPIs are measured on a network-wide basis, while others are reported by region or by specific urban and rural clusters.

Measurement methodology

Operators are expected to derive KPIs from their operational support systems (OSS) using well-defined counters and formulas, and to supplement these network-based measurements with drive-test and walk-test campaigns to verify coverage and service quality on the ground. The framework describes the drive-test methodology at a general level, including route selection, sample sizes, equipment specifications and the reporting of results.

For mobile broadband, the framework accepts that measurements may be conducted using standardised test servers and reference terminals. The regulator may also conduct or commission independent measurement campaigns, either directly or through accredited third parties. Operators are expected to cooperate with such campaigns by facilitating access to sites, providing calibration information where relevant and responding to queries about the interpretation of results.

The methodology recognises that certain conditions may temporarily degrade performance, such as major events, natural disasters or planned maintenance. Operators are expected to record such circumstances and to reflect them in the reporting so that observed variations can be interpreted properly.

Reporting and publication

Operators are required to submit periodic reports to the regulator in a defined format, at frequencies specified in the framework. Reports typically include per-indicator results at national and regional level, a comparison with the applicable thresholds, and commentary explaining any material variations or non-conformities. Supporting evidence should be retained for a specified period so that it can be produced during audits or investigations.

The regulator may publish selected results to inform consumers and to encourage improvement in areas where performance is weak. Publication is designed to provide a fair basis for comparison across operators, which requires consistent application of definitions, methodology and reporting formats. Where publication is contemplated, operators are typically given an opportunity to review and comment on the data before it is released.

Implications for operators

For mobile operators, the framework has practical implications for operations, engineering, marketing and legal functions. Engineering teams must ensure that OSS tooling captures the required counters accurately, that drive-test resources are available for the expected frequency of campaigns and that data pipelines produce KPI values that can withstand scrutiny. Where existing definitions or calculations differ from those in the framework, changes may be required to align internal measurement with regulator expectations.

Marketing teams need to align advertising and product claims with the results that are being submitted to the regulator. Statements about "best network" or "fastest speeds" that cannot be substantiated by the underlying measurements may attract regulatory attention, particularly if regulator-published data tells a different story. Legal teams should ensure that customer contracts, terms of service and service level agreements are consistent with the measured performance and with the framework's definitions.

The framework also creates opportunities. Operators that consistently outperform peers on published KPIs can use that evidence in their commercial communications, in enterprise sales and in negotiations with wholesale customers. Areas where performance is weaker can be prioritised for investment, with a clear metric against which improvement will be visible externally.

Implications for consumers and enterprise customers

For consumers, the framework is intended to make it easier to compare operators on a like-for-like basis. Published KPI data can inform decisions on which operator to subscribe to, particularly for customers who rely on their mobile service for work or education. It also provides a reference point for complaints, since customers who experience persistently poor service can compare their experience with the regulator's published data.

For enterprise customers, the framework provides a useful input into procurement and service level negotiations. Enterprises purchasing mobile connectivity for their workforce or for machine-to-machine deployments can use published KPIs to challenge operators to demonstrate that their networks meet the customer's specific requirements in the relevant geographic areas. It also provides context for negotiating service credits and remedies in the event of underperformance.

Practical steps and Lex Civora perspective

Operators should confirm that their internal measurement systems align with the KPI definitions and calculation methodologies in the framework, that reporting templates match the format required by the regulator and that supporting records are retained in a way that will withstand audit. Where the framework introduces new indicators or tighter thresholds, remediation plans should be prepared to address foreseeable gaps.

Marketing and product teams should review advertising materials, retail offers and website claims to ensure that they are supported by the measurements being reported. Enterprise sales teams should adjust their proposals to reflect what the regulator's data shows and to differentiate the operator's proposition on that basis. Complaints handling processes should be updated so that customer complaints about performance can be traced to the underlying measurements and responded to consistently.

Lex Civora advises operators, enterprise customers and consumer organisations on the interpretation and application of the QoS framework. This includes support in preparing periodic reports, responding to regulator queries and investigations, negotiating service level commitments in commercial contracts and framing complaints where measured performance falls short of expectations.

Last verified: 14 July 2026

This article is provided for general information only and does not constitute legal advice. Regulatory positions may change; readers should verify obligations against the current official publication or seek professional advice before acting.

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