The Association of Comms & Technology (ACT), which represents South Africa’s biggest telecommunications operators, wants a five-year exemption from parts of the Competition Act so they can coordinate parts of their rural infrastructure roll-out.
The pitch is simple – stop duplicating infrastructure, lower the cost of deployment and reach places that remain underserved.
This is a very bad idea.
Nobody can argue with the need. After all, rural connectivity is expensive; Roads are poor; power is unreliable; backhaul is difficult; and there may be very few paying customers around a site. Those constraints are real.
But a real problem does not automatically make this the right solution, except for the major players themselves. The rural underserved require affordability as well as availability and competition guarantees this.
To be clear, the application, set out in Government Gazette 55257, goes beyond sharing a tower that has already been built or pooling existing resources. ACT proposes that operators supply forward-looking planning information to an independent third party, which would identify gaps and opportunities for coordinated investment.
Even though the application says this would not extend to retail pricing or market allocation, that does not absolve the commercial effect we should worry about.
In a thin rural market, the first operator to build a site may become the only operator with a rational reason to be there. Once the large operators have coordinated where and when infrastructure is built, who is going to duplicate that investment to compete for a small pool of customers?
Customer choice
Nobody needs to sign an exclusivity agreement. The economics can create exclusivity all by themselves. That leaves the person living in that area with one practical choice. And choice is the one thing that keeps a network honest.
Customers switch when a service is unreliable, when pricing is poor or when a competitor offers something better. That threat of churn forces operators to maintain sites, improve capacity and sharpen their prices.
Remove it and the pressure goes with it. What looks like wasteful duplication on an operator’s balance sheet can be the only leverage a customer has.
We have seen exactly the opposite happen with fixed broadband. As more fibre network operators and ISPs entered, customers gained options and prices fell sharply. Competition did that, which is why we should be very careful before designing rural markets in the other direction.
There is also another hole in the proposal: it speaks at length about coverage, but says nothing meaningful about affordability.
In many underserved communities, mobile coverage already exists. It may be patchy, but the bigger obstacle is often that people cannot afford to use it properly. In fact, the Competition Commission’s own data services market inquiry found mobile data pricing to be structurally “anti-poor”, with low-volume customers paying more per megabyte and relying on inferior short-validity bundles.
One recent price comparison put a 5GB monthly prepaid bundle at R89 on the cheapest broadly available option assessed, while a R49 Telkom bundle was restricted to its own network footprint.
Smaller providers have shown that a different model can work. Daily access at around R5 makes heavy internet use possible without a contract or a large upfront bundle purchase. This is why you still find video shops in communities with mobile signal: a 3GB film is not useful if the data needed to download it costs many times the price of the film.
Coverage that people cannot afford is not inclusion. It is a signal on a phone that people dare not use.
The proposal also asks us to place a great deal of faith in promises of future delivery. Let’s look at the record: Icasa’s2026 State of the ICT Sector report found that only 4 377 of 21 878 government facilities identified under spectrum licensing obligations had been connected by October 2025 – about 20%.
These are schools, health facilities, libraries and traditional authorities. If existing public interest obligations remain 80% incomplete, why should the commission believe that another broad permission, granted now and policed later, will produce a different result?
ACT argues that the arrangement will promote participation by small businesses and historically disadvantaged firms. Yet smaller wireless ISPs, ISPs and independent infrastructure providers are not inside the proposed planning circle. Many have spent years making marginal markets work through lean networks and local knowledge.
Shut it down
A process dominated by six major operators could therefore crowd out precisely the businesses the exemption claims it will help.
This is not an argument against infrastructure sharing. Co-location, facilities leasing, roaming and open-access infrastructure all have a place. Sharing what has been built can reduce waste while preserving independent decisions about where to compete.
Jointly aligning future plans among competitors is a different proposition, especially where the likely outcome is one entrenched provider in each marginal market.
The Competition Commission should refuse the exemption as it stands.
If it is minded to consider any form of approval, the conditions must come first, not as an afterthought: open and non-discriminatory wholesale access, measurable rural build targets, affordable retail options, enforceable service levels, transparent reporting and real penalties for missed commitments. Smaller operators must have a fair route into the infrastructure and the market.
The Competition Act exists because cooperation between competitors can be convenient for the companies involved and costly for everyone else.
Rural South Africans should not be asked to surrender competition in return for an unpriced promise of coverage. They deserve the same things every other customer expects: a service they can afford, a network that works and somewhere else to go when it does not.
- The author, Paul Colmer, is executive member of the Wireless Access Providers’ Association, a non-profit trade association acting as a collective voice for the wireless industry
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