Hot Off The Press: Airtel Nigeria Offers 10 Reasons For Opposing  Proposed A2P SMS Traffic Through A Central Hub

By Clifford Agugoesi, Editor-in-Chief

Telecommunications sector umpire, the Nigerian Communications Commission(NCC), has released the Report Of The Stakeholders’ Forum On Draft Application To Person (A2P) Framework.  Cyber Era NG can authoritatively report the information is now on the Commission’s website.  It has been there since  January 17, 2025.

In keeping with its policy on participatory rule making, the Commission had invited the general public and all stakeholders for submission of comments with regards to the proposed A2P Licensing Framework which held on December 20, 2024.

With reference to the objectives for emplacing a framework for regulating the A2- space, the NCC states: “ Implement unified rules and protections to shield Nigerian subscribers  from SPAM and fraud attacks. This includes country level regulations to prevent unwanted SMS traffic and ensure compliance with SMS protection, storage, and  data protection laws. To ensure that all brands and OTT service providers route  their A2P SMS traffic through a central hub, thereby ensuring standardized  processing and monitoring.”

In the report, Airtel Nigeria came up with 10 reasons it is not in support of a centralized hub for A2P SMS traffic.  “The use of a central hub,” stated Airtel,” would occasion the Underlisted issues:

1. Loss of Direct Control: Using a central hub outside Airtel’s network gives the  third-party control over message routing and quality of service.

2. Data Privacy and Security Risks: International A2P messages, just like local  transactional A2P often contain sensitive information (e.g., OTPs, bank alerts).

Routing these through a centralized third-party platform increases exposure to data  breaches, non-compliance with GDPR and other data protection laws, and possible  exploitation of sensitive subscriber data.

3. Revenue Leakage / Additional cost to MNOs: Centralized platforms typically  charge service fees or take a percentage of international messaging revenue, and this  reduces Airtel’s margins.

4. Dependence on a Single Entity: Centralizing operations creates dependency on  one provider. Any technical failures, downtime, or disputes with the third party  could disrupt messaging services, damaging customer trust and Airtel’s reputation.

5. Market Monopoly Concerns: By routing international A2P messaging through a  single entity, the third party could monopolize the international A2P market, and  introduce restrictive practices on Airtel in the future.

6. Reduced Differentiation and Competitive Edge: Airtel loses the ability to  differentiate its International A2P messaging service, as the third-party platform  standardizes all offerings. This restricts innovation and diminishes the competitive  advantages of individual operators.

7. Increased Latency and Potential for Service Degradation: Routing through a  centralized platform may introduce additional latency, impacting time-sensitive  messages such as OTPs and transactional alerts. This could lead to poor user  experiences and dissatisfaction for Airtel’s customers.

8. Conflict of Interest: The third-party platform custodians might have ties to other  operators, this could lead to biased routing decisions, favouring certain MNOs over  Airtel, thereby creating an uneven competitive landscape.

9. Compliance and Audit Challenges: Airtel might face added complexity in ensuring compliance with regulatory requirements when we rely on a third party. Auditing  message delivery, reconciling billing, and resolving disputes could become  cumbersome.

10. Inhibits Direct Partnership Opportunities: By relying on a centralized entity,  Airtel will lose the ability to build direct partnerships with global enterprises, limiting  our ability to negotiate mutually beneficial terms and explore additional  opportunities with OTT players.

In replying Airtel, the Commission stated: “The Commission respectfully appreciates and notes these comments. The Commission will take into consideration the 10 concerns raised by Airtel in  finalizing the Framework and concluding on its approach on A2P messaging  services in Nigeria.”

As per the report, the regulator commented: “Current state of local international A2P messaging in Nigeria: Individual operators  set their tariffs, leading to distortions and inconsistencies in termination rates.

Revenue from international A2P traffic is currently collected by entities outside  Nigeria. Payments are made in foreign currencies, which do not flow into the  country nor are the companies taxed. There is no specific regulation on A2P SMS  leading to a lack of visibility in the SMS market, potential formation of cartels and  reduced competition.”

Commenting, Airtel stated that it “recognizes and captures all its revenues, irrespective of jurisdictions where such income is earned, in the computation of Annual Operating Levy obligations,  tax assessment and remittances to the Government. We reaffirm that Airtel is  already charging A2P international SMS in USD, hence bringing forex in country  and paying tax to Regulators on same. A2P international SMS segment is  competitive notwithstanding that the MNOs elected to create a single point of  connectivity to their respective networks to effectively manage spam and in turn minimize revenue leakages. The MNOs have deployed resilient and robust anti[1]spam solutions to curtail SPAM and illegal activities on their respective networks.

With the projected 50 per cent drop in international A2P SMS volumes, the return on  investment does not justify the introduction of the proposed Aggregator.

“Furthermore, there is no country where a Regulator has proposed such a central  platform in the international A2P SMS ecosystem. Airtel recommendation is that the NCC should hold an extensive consultation with the industry to collectively  address its concerns with respect to having greater visibility in the international A2P  SMS segment in place of the proposed central hub/centralized SMS firewall and  introduction of a third party.”

In responding to Airtel, NCC stated that “The Commission respectfully appreciates and notes these comments. The  Commission also accepts Airtel’s recommendation for extensive consultation with  the Industry,” signifying a point of convergence between the telco and the regulator, in a difficult, delicate balancing act that telecommunications sector regulation typifies. -With additional reporting by Angeline Mgbele, Bureau Chief, Northern Nigeria.

file:///C:/Users/user/Downloads/NCC%20Legal_Report_of_A2P_Framework%202025.pdf