Setting up a MVNO in Cyprus

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RedLightbulb

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Mar 3, 2025
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Hey all!

TL/DR: is there a EU country that offers Mobile Virtual Network Operator (MVNO) licenses with the lest amount of bureaucracy? I'm thinking what Lithuania was for EMIs a few years back.

Apparently, this business is not very popular on this forum (i.e. zero posts on this topic despite trying a few keywords). But I'll give it a shot.

I recently spoke to a former client of mine, and he offered me to become his sales director for a new startup he'd like to incorporate.

Here's the deal: he operates in a niche sector in Italy, and since a couple of years he started selling SIM cards for a specific IOT service. It's been a success, because it's good margins, but insane cash flow. The key is the prepaid service: he sells the SIM and guarantees the traffic for the next 5 years, kind of a "set it and forget it" thing, the customer pays him NOW the 5 years, and he pays to his provider monthly. Genius.

He has a minimal infrastructure, as he's basically acting as a commercial middleman and customer service agent for a big company, let's say Vodafone.

In the lingo, he's a light Mobile Virtual Network Operator (MVNO)

Now he wants to expand, in order to:
  • Create himself an alternative outside Italy
  • Reduce the tax burden (but pay some taxes somewhere)
  • Diversify suppliers and get more leverage
Suppliers will be MVNE (Enablers) or MVNA (Aggregators) who will act as intermediary between us and, say, Vodafone. We'd go to them and say: "we already sell thousands of SIMs, and the old company started as a hobby. Now we're getting serious, this is the new startup with a dedicated commercial structure, let's negotiate terms and conditions".

We still aim to stay as lean as possible: everything except sales and customer support is managed by our supplier, or our supplier's supplier.

I guess that's enough on the business model.

To move on, my immediate advice to my prospective partner was Cyprus. I reside there, and we can easily appoint myself as director and create true and defendable substance on the island. Anyway, my question here is NOT about substance or the like. I got that covered.

It's the licensing / bureaucratic / authorization system that worries me.

In Cyprus it seems straightforward: I'd only need a notification to the relevant authority. But I hate the fact of not being able to navigate the regulations myself (it's all in Greek, which I don't speak, and it's never translated. Plus, reformed laws seldom get consolidated in updated texts, making the job even more challenging). And despite being more than happy to delegate the task to a competent consultant, I hate to be fully reliable on somebody whose work I'll never be able to audit, as I lack the basic knowledge nor the understanding of the documents he's producing.

I was wondering is if there's some alternative countries where getting a MVNO license is easypeasy, and the bureaucracy is more english friendly. What Lithuania and Bulgaria were for EMI a few years back, but for a guy who wants to sell third party SIMs.

Any ideas either on the country, or on how to reduce my anxiety on working without ever being able to audit the Cypriot process?
 
Cyprus is not a place you go to if you want to avoid bureaucracy or‌ seek efficient bureaucracy. Cyprus is good for a few well established things. This is not‍ one of them.

I could be wrong, though. But I'd look at the European mainland⁠ instead.
 
Good point, Sols!

That thought crossed my mind when I started to look into Estonia,‌ as it's a jurisdiction I used in past ventures.

Now, the problem I have with‍ Estonia is exactly the opposite: they're too efficient, and may be willing to scrutinize the⁠ company operations and compliance way too zealously, especially once we're above a certain threshold.

That's why I mentioned something similar to Lithuania and Bulgaria for EMI. It wasn't efficiency what⁤ brought people to those countries, nor lack of rules, but rather lack of controls.

In reality, I don't need the bureaucracy to be efficient. I just need them not to⁣ bother me once I get my licence, and spare me audits and requests that slow⁢ me down.
 
Having some telco experience myself, do not forget the UK. Maybe not the best country‌ tax wise, their regulation system is top notch and respected all over the world.
From thereon its also not too complicated to lower the tax burden.
 
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