TRC Studies the Feasibility of Secondary Spectrum Trading

In 2025 the Cambodian authorities initiated a feasibility study into the introduction of secondary market mechanisms for spectrum, including trading and leasing of spectrum usage rights between authorised holders. The study responds to observations that spectrum is increasingly recognised as a scarce resource whose efficient use benefits from mechanisms that allow rights to move to the users who value them most, subject to appropriate safeguards.

The study is relevant to mobile network operators, satellite operators, fixed wireless providers, private radio users and any organisation with a strategic interest in access to spectrum in Cambodia.

Spectrum trading refers to arrangements in which the holder of a spectrum authorisation transfers, in whole or in part, the rights to use the spectrum to another party. Trading can involve permanent transfer of the authorisation, leasing of usage rights for defined periods, or partial transfer covering specific frequency ranges or geographic areas. In each case, the transactions occur within a framework established and supervised by the regulator.

Trading complements the primary allocation process by allowing subsequent adjustments to reflect changing business plans, market conditions and technological developments. It does not replace regulatory oversight of spectrum use.

Secondary market mechanisms can enhance efficient use of spectrum by allowing rights to move to users who value them most, by supporting entry of new participants and by providing flexibility as business needs change. They can also provide a mechanism for consolidation and for the exit of holders whose plans have changed materially since the original allocation.

For new services and innovative business models, secondary markets may reduce the cost and time of accessing spectrum by offering an alternative to waiting for a primary allocation process. This can support innovation and can contribute to the responsive development of the sector.

Secondary markets also raise concerns that must be addressed in the framework design. Anti-competitive behaviour, including accumulation of spectrum by dominant operators to exclude competitors, is a particular concern. Speculation, in which spectrum is acquired without genuine intent to use it, can also undermine the objectives of spectrum policy. Preservation of policy objectives such as coverage obligations, quality of service commitments and universal service considerations may require that these obligations transfer with the spectrum or be reflected in transaction conditions.

The framework must also address technical considerations, including compatibility of transferred rights with the acquiring party's existing operations and coordination with neighbouring users.

A robust framework for spectrum trading typically defines the categories of authorisation eligible for trading, the procedures for approving or notifying transactions, the criteria the regulator will apply and the transparency measures that allow the market to function effectively. Publication of information about transactions supports informed participation and supports oversight.

The framework may also address specific mechanisms such as leasing, sub-licensing and partial transfers, each with its own conditions. Coordination with competition policy is important, and the regulator may require consultation with competition authorities on significant transactions.

The feasibility study draws on international experience with spectrum trading in a range of jurisdictions. Experience suggests that trading can deliver benefits when combined with appropriate safeguards, but that framework design and supervision are important. Lessons include the value of clarity about eligible transactions, the importance of proportionate procedures and the need for regulatory capacity to handle applications efficiently.

Regional experience within Southeast Asia may be particularly relevant, given similarities in market structure, spectrum demand profiles and cross-border considerations.

The feasibility study is expected to include consultation with stakeholders, including operators, investors and civil-society organisations. Stakeholders are invited to share their perspectives on the potential benefits and concerns, on framework design options and on the practical arrangements that would support effective implementation.

Constructive engagement with the consultation supports a framework that reflects the specific circumstances of the Cambodian market and that avoids importing arrangements that may not translate well from other environments.

Spectrum trading is one of several tools available to support efficient use of spectrum. Other tools include primary allocation methodologies, coverage and quality obligations, spectrum caps to prevent excessive concentration and refarming of underutilised bands. The feasibility study is expected to consider the interaction between trading and these other tools and to identify a coherent overall approach.

Coordination with broader policy objectives, including support for connectivity, competition and innovation, is central to the design of an effective spectrum framework.

For operators, the potential introduction of spectrum trading offers opportunities to optimise their spectrum holdings, to acquire additional spectrum where needed and, in some cases, to release spectrum that is no longer central to their plans. Strategic planning should consider the implications for network development, product roadmaps and competitive positioning.

For potential new entrants and specialised users, the availability of secondary market mechanisms could provide alternative pathways to access spectrum and to develop innovative services. Engagement with the consultation and with the eventual framework will be important.

For all interested stakeholders, the feasibility study is an opportunity to shape the future of spectrum policy in Cambodia. Well-founded contributions to the consultation, supported by analysis of the local market and of international experience, are likely to influence outcomes.

Lex Civora advises operators, satellite providers, potential new entrants and other stakeholders on engagement with the spectrum trading feasibility study, on the assessment of potential implications for their businesses and on preparation for future participation in secondary spectrum markets in Cambodia.