Connectivity under the hood
Launching a virtual operator as a B2B2C platform for retail, banks and travel — and an own app-first B2C brand.
Connectivity is almost never sold head-on
It rides on the partner's core — card, purchase, loyalty, ticket — as a retention and cross-sell tool. We become connectivity under the hood and, at the same time, an own eSIM-first brand for tourists and relocators.
We're not an operator — moving along the control ↔ investment axis
Light MVNO
Own BSS/OSS + billing; core and RAN from the host.
- capex ~$10K–$400K lower bound: to verify
- launch: weeks–months
Full MVNO
Own HLR/HSS + numbering; lease only the RAN.
- capex $2M–$10M+
- launch: 9–18 months
MVNE (option)
A platform on which partners spin up their own brands.
- brand in 2–6 weeks to verify
- backbone of scenario A
Model recommendation: start Light on all markets → Full as the pilot's (Georgia) target state once volume is proven → MVNE combined with the Light→Full transition.
Georgia leads, Serbia fast-follows, Russia is separate
| Parameter | Georgia · pilot | Serbia · fast-follow | Russia · separate |
|---|---|---|---|
| Population / SIM | 3.81M / 6.21M (163%) | ~6.6M / 7.91M lines ↓ | ~146M / ~270M to verify |
| Operators (MNO) | 3 — Magti 40.7% / Silknet / Cellfie | 3 — mts 41.4% / Yettel / A1 | 4 — MTS / MegaFon / Tele2 / Beeline |
| MVNO authorisation | general, no licence | general, no licence | Roskomnadzor licence (3–25 yrs) |
| Mandatory MVNO access | YES (ComCom, SMP; partial) | NO (commercial only) | de facto no (Tele2 commercial) |
| Active MVNOs | Hallo (on Silknet); Tele1 launching (VoIP) | none independent (Globaltel absorbed) | mature: ~25.5M SIM (+51%) |
| Inbound tourism | 5.52M overnight — Russia #1 | 2.38M (2024) | constrained by regulation |
| Sanctions / geopol. risk | low | medium (EU convergence) | high |
The only market with mandatory MVNO access
- Regulation on our side: the ComCom mandate (since 2019) obliges SMP operators to grant wholesale access; general authorisation, no licence.
- Model already validated: MVNO Hallo is live (on Silknet); Tele1 (on Cellfie / Beeline brand) is launching (VoIP).
- Ready demand: record tourism of 5.52M overnight, Russia #1 (1.58M / 23%), under liberal KYC — SIM on a passport same day.
16.25 · 13.97 · 10.58
Magti · Silknet · Cellfie
Mandate partially enforced
Silknet took a 5G lot without the MVNO obligation, Magti resisted. to verify
Bigger market — higher barrier to entry
Window of opportunity
- Larger market — notably bigger than Georgia
- EU Roam-Like-at-Home opening (target ~2028)
- Strong segments: relocators, youth, travel
Structural risk
- No access mandate — everything via commercial talks
- Largest MVNO Globaltel absorbed by the incumbent (Telekom Srbija, 2023) — no independent MVNO left
- Market is shrinking (7.91M lines ↓)
→ Entry is gated: only after closed wholesale terms and contractual protection against brand absorption.
A mature bank-MVNO model — valuable as a reference
Not comparable to GE/RS on risk profile. A separate legal entity and perimeter, a sanctions-clean structure, delegating SORM/LI to the host, a bank partner — the decision is taken independently. For now it is valuable as proof of the “bank-MVNO” model for scenario A.
Light → Full, with MVNE as a platform option
| Criterion | Reseller | Light MVNO | Full MVNO | MVNE (option) |
|---|---|---|---|---|
| What's owned | brand/sales only | BSS/OSS + billing | + core HLR/HSS, numbering | platform for brands |
| Capex (year 1) | opex model | ~$10K–$400K to verify | $2M–$10M+ | combined with Light→Full |
| Launch | days–weeks | weeks–months | 9–18 months | brand in 2–6 wks to verify |
| Control / margin | low | medium | high | platform rev-share |
| Host dependence | maximum | high | medium (RAN only) | — |
The biggest unknown multiplier is the host's wholesale rate (NDA everywhere). Until an offer lands, any P&L is conditional.
Two scenarios for “us”: A — headline, B — parallel track
Platform / B2B2C
- “Connectivity under the hood” of a partner (retail / bank / travel) + own B2C
- Demand from the partner's ready channel → CAC ≈ 0
- Margin: wholesale + platform + rev-share
- Proven: Lidl, Tinkoff/T-Mobile, Airalo
- Leans on the access mandate in Georgia
Business / IoT-M2M
- Direct sales: corporate connectivity, IoT/M2M + own B2C
- Margin shielded by the ~32% MVNO↔MNO price gap (IoT)
- Low churn (postpaid/M2M ~1.8%/mo)
- Start with verticals: POS terminals, logistics telematics
- Less exposed to the retail price war
Own B2C in both scenarios is not an end in itself, but a showcase of capability and an anchor volume for wholesale buying from the host.
Who we sell “connectivity under the hood” to
Retail with POS
SIM/eSIM at checkout and in-app, “data with your purchase”, tied to the loyalty programme.
- Precedent: Lidl × 1Global (up to 30 countries)
- We close: retention, cross-sell, new revenue
Banks
Connectivity in the bank app, eSIM at card issuance, a travel pack. Georgia's fintech-liberal regime (VASP since 2023).
- Precedent: Tinkoff/T-Mobile (~6M, profitable)
- Wave: Revolut · N26 · Nubank
Travel
eSIM bundled with a ticket / tour / insurance; a roaming-killer for inbound tourism.
- Precedent: Airalo (30M), Holafly (>$500M)
- Ideal for Georgia's tourism flow
What the partner gets: new revenue · retention · data · low risk (we run the telco). Brand names are reference partner types, not a list of those operating in GE.
Connectivity and IoT/M2M for the business's own operations
- Corporate connectivity: SIM fleets, closed user groups, a single account and management.
- IoT / M2M: logistics telematics, POS terminals, metering, data-only for devices.
- Short path to revenue: start with POS terminals and logistics — clear demand, fast contracts.
B's edge: margin shielded by the price gap, less exposed to retail-access regulation. Downside — a long B2B cycle and IoT integration complexity.
Light MVNO as a private APN: traffic under the company's control
Corporate SIMs are placed on a dedicated APN — all device egress goes not to the public internet but to the customer's own gateway. Hence two use cases:
Corporate security & audit perimeter
- All mobile traffic through the perimeter: DLP · DPI · IDS/IPS · NGFW, logs to SIEM
- Closes the device “blind spot” invisible to MDM/MTD
- Audit and leak prevention, forensics
Independent routing
- Controlled, resilient egress; choice of exit point
- Legal regime depends on jurisdiction
- In RU — a risk zone (RKN · SORM · TSPU) needs legal opinion
A Light MVNO without its own core resells the host's APN; full control (own IP pools and policies) needs Full MVNO or host cooperation to verify. → The expanded case for large players — module private-apn.html.
Mobile traffic out of the “blind spot” — into a managed perimeter
Blind spot closed
A public APN routes traffic past the security perimeter; MDM/UEM and MTD give no network inspection or DLP. Private APN restores visibility.
PT · Kaspersky
Positive Technologies (PT NAD, MaxPatrol SIEM, PT NGFW); Kaspersky (KUMA, KATA, Security for Mobile). to verify
InfoSec ₽244→299B
RU cybersecurity market +23% YoY (2023→24), forecast →₽681B by 2030; import substitution and critical-infrastructure (CII) protection (deadline 01.01.2028).
An app-first / eSIM-first brand for priority niches
Travel / tourists
eSIM and roaming bundles, instant activation at the border / airport.
Relocators / nomads
A local number without bureaucracy, long subscriptions, retention.
Home connection
Calls home, a second number; ~4.5–5M Serbians abroad.
Youth / 2nd SIM
Price-sensitive, community, data-heavy, app-native.
Headwinds accounted for: Serbia↔EU roaming convergence by ~2028 erodes the arbitrage; tightening KYC (RS passport+photo, RU biometrics). → a shift toward retention and youth rather than one-off travel arbitrage.
Ranges, not a budget — wholesale rates under NDA
Logic: Georgia gives an easy entry (Light + travel-eSIM, low CAC) but one-off revenue — offset by retention (relocators/youth) and partner segments with stickiness.
Three sales motions
Platform
ICP: retail with POS and travel first, banks second. Pilot offer, funnel, partnership wholesale economics, KPIs.
IoT / corporate
Direct sales into POS-terminal and logistics-telematics verticals. Short cycle to first revenue.
App / eSIM
Digital acquisition, distribution at airport/border/store/app, instant eSIM activation, referral mechanics.
Further sales: right after this deck — a partner long-list by ICP, outreach to first retail/travel partners, launch of Light pilots in Georgia.
Trajectory GE → RS → RU with transition triggers
Triggers: S1→S2 — proven B2C unit economics + anchor partner · Light→Full — sustained volume justifying $2M–$10M+ capex · GE→RS — closed wholesale terms · RU launch — sanctions-clean structure + SORM/LI delegation + bank partner.
Risks and mitigations
| Risk | Market | Level | Mitigation |
|---|---|---|---|
| Access mandate fails / access denied | GE · RS · RU | high | start on a host with a working MVNO deal (Silknet); anti-termination (RS); Tele2 host-MVNE (RU) |
| Dependence on a single host | all | high | price protection + SLA, backup host, Light lowers switching cost |
| MVNO absorbed by the incumbent | RS acute | high | “tech platform under the hood” role, partner diversification, change-of-control |
| Sanctions / compliance (SORM, Yarovaya) | RU | high | full isolation of the RU track, sanctions DD, SORM/LI delegated to the host |
| Churn / relocator outflow / roaming squeeze | GE · RS | medium | tie to partner's core, postpaid focus, shift to youth |
Context: the claim “Georgia has almost no open niches” is a lobbying argument by KPMG commissioned by Magti against the MVNO mandate, not a regulator's conclusion needs context. The bet is on B2B2C / partner niches, not on mass discount.
Approve a pilot in Georgia
Ask: a Light MVNO in Georgia (scenario A in its B2C dimension), a phased budget in ranges. Full capex and the MVNE-layer investment — as separate gates triggered by volume and an anchor partner.
- 0–30 d: wholesale contact with a Georgian host — Silknet (hosts Hallo), Cellfie as backup; an offer via competitive tender
- 0–30 d: a compliance legal opinion — who bears LI/SORM and data retention in the Light model
- 0–30 d: verify the actual status of the ComCom MVNO mandate after 30.06.2024
- 0–30 d: a partner long-list by ICP — retail with POS + travel first, banks second
Open to close: wholesale rates (NDA) · GE mandate status · LI/SORM allocation · unit economics (confirmed by the pilot) · relocator sizing · commercial access in Serbia.
Become connectivity,
not an operator
Georgia as the lead pilot · a B2B2C platform as the headline · own B2C as a showcase and anchor volume. A proven model, low entry capital, demand tested before heavy investment.