eSIM – Potential, challenges and competition problems (No. 490) © Photo Credit: Robert Kneschke -

eSIM – Potential, challenges and competition problems (No. 490)

An analysis of the market relevance of eSIM, its implications for relevant stakeholders and the value chain as well as potential competition problems and remedies.


The use of eSIM in mobile end devices steadily increases in both the consumer and M2M sectors. This study examines the possible effects of the eSIM on competition in mobile communication markets with a focus on applications in the consumer sector. We concentrate on the use cases “mobile smartphone communication”, “smartwatches with embedded SIM” and “connected car". We discuss competition problems which have been observed in the market as well as potential future competition problems. We discuss the appropriateness of remedies which are available in the existing legal framework at European and national level to address these (potential) competition problems.

In the three selected use cases we observe only few indications of competition problems on the part of market participants. There are also few complaints from consumers. It remains to be seen whether this is due to the fact that the eSIM has (still) little market relevance. Difficulties arise primarily in connection with compatibility problems between services of smaller MVNOs and the software or operating systems on terminals. In the future, further problems could arise in connection with the implemented standards, the use of eSIM locks to restrict switching options and the parallel use of provider profiles, and a growing relevance of app stores for the provisioning of eSIM based solutions.

In principle, §§ 59 and 66 ( TKG) address consumer protection with regard to switching and bundled offers. However, these regulations in the TKG on customer protection do not address device and operating system manufacturers of smartphones and smartwatches. A possible solution could be to include terminal equipment manufacturers in § 59 (8) TKG, which addresses the establishment of profiles when switching providers over-the-air. If competition problems arise in connection with the smartphone/smartwatch operating systems and platform access conditions (when using the app stores in the context of service provisioning), it must be examined whether the provisions of the DMA or possibly § 19a GWB apply.