Consumers must not be bound to use a specific electronic mobile communication network for more than six months after the contract comes into force, e.g. by using SIM lock. This means it must be possible to change the provider of internet access services in cars.
Internet access services in the car can be provided in different ways. One example is providing access to the internet via a Wi-Fi hotspot, allowing passengers access to browse the internet, download apps, stream video, etc., on smartphones and tablets.
Another example is so-called “infotainment services” that provide access to different third-party services via a touch screen built into the car. The services available via the touch screen may consist of various internet content and applications, ranging from traffic information and music streaming to all kinds of apps and web browsers. It is not the number of third-party services made available that defines a service as an internet access service, but the type of services and content made available and to what extent such services are typically made available via the internet.
It must be possible to switch internet access services provider in all the above-mentioned cases.
The requirement to be able to switch service provider does not include communications services used for eCall and machine-to-machine (M2M) services.
The requirement to be able to switch internet access provider could be met by:
- giving end-users access to a physical SIM slot in the car that enables them to use another SIM card,
- giving alternative providers access to one of the terminal equipment’s eSIMs or
- providing end-users with the necessary equipment that enables them to select provider for the internet access service in the car.
If the car uses a shared SIM for all connectivity to the car, it may not be feasible to switch provider on the existing terminal equipment. In that case, the car could be supplied with free-of-charge equipment that easily enables the user to use an alternative provider of internet access services, e.g. a dongle.
The requirement that it must be possible to switch provider is not met by directing the user to buy and install the necessary equipment or to use their personal equipment to enable switching. ADSI strongly supports that tethering is possible for the services provided in the car, but tethering does not meet the requirement that it must be possible to switch provider on the terminal equipment in the car.
When evaluating solutions to allow users to switch internet access provider in the car, ADSI will consider the specific solution on the basis that it should be easy for the user to switch provider and that the user will have access to the internet functions of the car on equivalent terms as the user had when using the original internet access service provider.
Find link to a Danish decision on internet in cars here
Find link to Section 7 (2) of the Danish Executive Order on End-user’s rights here