Research and analysis

Future of TV distribution - Assessing the value and alternative uses of DTT spectrum for the future of UK TV distribution

Published 23 June 2026

1 Executive summary

This is the final report of a project carried out by Analysys Mason and DotEcon on behalf of the Department for Culture, Media and Sport (DCMS) and Department for Science, Innovation and Technology (DSIT), to examine alternative uses and value of ultra-high-frequency (UHF) spectrum. The spectrum in question, from 470-694MHz, is currently used primarily for digital terrestrial television (DTT). The consideration of the value of alternative uses of this spectrum in future is part of a wider government review of the future of TV distribution in the UK.

In this project, we have used a literature review and interviews with a selection of industry and government stakeholders in the UK market to understand alternative uses of the UHF spectrum if it were to be released from DTT use in the 2030s/2040s. We have also used qualitative and quantitative analysis to estimate the potential value of this spectrum in one of the key alternative uses identified, which is mobile use. We have also considered the wider benefits to the UK economy of UHF spectrum and the implications of different scenarios for DTT spectrum release on the programme making and special events (PMSE) sector, which currently uses UHF spectrum on a shared basis with DTT.

1.1 Description of the frequencies under study

The spectrum under consideration is from 470MHz to 694MHz. This spectrum is currently allocated for TV broadcasting use and assigned for use by DTT transmitters in a multi-frequency network (MFN) configuration in 8MHz unpaired channels. Spectrum from 606MHz to 614MHz is reserved for use by PMSE radio microphones and in-ear monitors (‘channel 38’), on a national basis. Spectrum from 470MHz to 606MHz and 614MHz to 694MHz is also available for PMSE use. However, it is available on a geographically co-ordinated basis and is shared with the DTT transmitters.

If the government’s decision on the future of TV distribution is to close the DTT network, the full spectrum currently used by (470-694MHz, excluding 606-614MHz) will become available for other uses. If the government’s decision is to reduce the number of DTT Multiplexes, some of the spectrum from 470-694MHz could become available for other uses.

The mobile industry standards body (Third Generation Partnership Project, or 3GPP) has already standardised a band plan for mobile use of the upper part of the 470-694MHz spectrum, called the 600MHz band. The International Telecommunications Union (ITU) World Radiocommunications Conference 2023 (WRC-23) made provision for countries wishing to use the 600MHz band in Region 1 for mobile use to do so on a secondary basis to DTT. The matter will be considered again at WRC-31.

The 600MHz band is approximately 617-698MHz. Since this 600MHz band is standardised and used in some markets already (e.g. USA, and Saudi Arabia), a mobile equipment ecosystem is already developing. This means if the UK decided to use the 600MHz band in mobile networks, network equipment and devices could become available in the UK market in a relatively short timeframe. There are already discussions taking place with other European countries about creating harmonised conditions for mobile use of the 600MHz band in Europe.

The 500MHz band (i.e. the remaining part of the spectrum currently used for DTT from 470-617MHz) does not have this same level of certainty over equipment availability. This band is not available for mobile use in any market worldwide yet and there has been no discussion on European harmonisation, nor international discussion. International discussions may take place at a forthcoming WRC, since the WRC in 2031 (WRC-31) is due to discuss matters relating to future use of 470-694MHz. The WRC in 2027 (WRC-27) will decide on the scope of the discussions for WRC-31 and whether enabling mobile use of the 500MHz band, as well as the 600MHz band, is included as a key consideration or not.

This difference in status between the 500MHz and 600MHz portions of the 470-694MHz band is relevant to considerations throughout this study. Since the 600MHz band is more immediately useable for alternative uses such as mobile, whereas the 500MHz band is not, this has implications for the value of the spectrum. Our assumption – further discussed in the remainder of this study – is that the 600MHz band will be more valuable for mobile use in the short to mid-term, due to the more advanced state of standardisation and the associated device ecosystem. The value of the future use of the 500MHz band has a higher risk of uncertainty, due to lack of clarity over the European and international harmonisation process timing and outcome.

1.2 Scenarios for future UHF spectrum release

Our study is guided by the following indicative scenarios for UHF spectrum release amounts and timing.

Figure 1.1: UHF spectrum scenarios (Source: Analysys Mason 2026)

Spectrum scenario	Name	Timing options/ implications for new uses of UHF spectrum	Implications for current uses (PMSE)
0	No change	No spectrum released	No change to spectrum currently available for audio PMSE
1	DTT re-planning: 500MHz band retained for use by DTT (for example, three or four multiplexes (MUX)). 600MHz band available for mobile or other uses	1a Release 600MHz band for mobile or other uses in 2035 (followed by release of 500MHz band in 2045) 1b Release 600MHz band for mobile or other uses in 2035 (no further spectrum release)	1a Loss or reduction in bandwidth available in the 600MHz band for PMSE in 2035 followed by similar loss or reduction in 500MHz. Some use of the 600MHz and/or 500MHz bands by PMSE might still be possible, if shared use with mobile or other new uses is possible – see Section 4 – or if some of the spectrum is retained for PMSE use. 1b Loss or reduction in bandwidth available in the 600MHz band for PMSE in 2035; continued access to the 500MHz band
2	DTT reduced to carrying a minimum number of core channels (for example, one or two MUX). 600MHz and part of the 500MHz band available for mobile or other uses	2a Release 600MHz band and part of the 500MHz band not retained for DTT by 2035 (followed by release of remaining 500MHz spectrum in 2045) 2b Release 600MHz band and part of the 500MHz band not retained for DTT by 2035 (no further spectrum released)	2a Loss or reduction in bandwidth available in the 600MHz band and part of the 500MHz band for PMSE in 2035 followed by similar loss or reduction of the full 500MHz. Some use of the 600MHz and/or 500MHz bands by PMSE might still be possible, if shared use with mobile or other new uses is possible – see Section 4 – or if some of the spectrum is retained for PMSE use. 2b Loss or reduction in bandwidth available in the 600MHz band and part of the 500MHz band for PMSE in 2035; continued access to the 500MHz band
3	IPTV migration/ DTT closure; release of all DTT spectrum	3a Release of all DTT spectrum in 2035 3b Release all DTT spectrum in 2045[footnote 1]	3a Loss or reduction in all UHF spectrum available for PMSE in 2035. Some use of the 600MHz and/or 500MHz bands by PMSE might still be possible, if shared use with mobile or other new uses is possible – see Section 4 – or if some of the spectrum is retained for PMSE use. 3b Loss or reduction in all UHF spectrum available for PMSE in 2045

1.3 Alternative uses of UHF spectrum

We identify the following alternative uses of UHF spectrum.

1.3.1 Mobile use

Mobile services in the UK form an essential part of the UK’s economy. The UK market is served by three nationwide mobile network operators (MNOs) – BTEE, VodafoneThree (VF3), and Virgin Media O2. These three MNOs operate the UK’s national Fourth Generation (4G) and Fifth Generation (5G) mobile networks. Overall levels of mobile data consumption using 4G and 5G networks continue to be very high and data consumption is rising, albeit at lower rates currently than in previous years. User experience expectations are also very high. MNOs already use spectrum in other parts of the UHF range (specifically, 700MHz, 800MHz and 900MHz bands) and these bands are used particularly to provide wide-area coverage, and in-building coverage. All the frequency bands used by UK MNOs are harmonised at a European level, and also identified internationally for mobile use. The existing sub-1GHz bands used by the UK MNOs (700MHz, 800MHz and 900MHz) all form part of the ITU’s frequency plans for International Mobile Telecommunications (IMT), meaning that these bands are widely supported by equipment vendors in network equipment and mobile devices.

There are likely to be a number of benefits of further UHF spectrum bands becoming available for mobile use. These benefits include potential cost savings by deploying fewer new base stations as data volumes and customer experience expectations increase. Benefits also include potential improvements in mobile network performance, especially indoors and in rural locations, taking advantage of the physical properties of UHF spectrum that are especially suited to reaching wider geographies and penetrating walls. Additionally, there is the possibility for new technologies such as 6G to be introduced sooner over wider areas of the UK. This can happen once 6G technologies are standardised, by end of this decade.

1.3.2 PMSE

The UHF spectrum is used by various forms of wireless equipment in the audio PMSE sector. Audio PMSE refers to wireless equipment used for audio purposes in live broadcasts, theatrical events and live productions. This includes equipment such as in-ear monitors, wireless microphones and audio links.

The PMSE sector includes a variety of small and large users. Small operations for audio PMSE include churches, local event and conference venues and theatres. A smaller number of wireless microphones might be in use at these locations. Larger users include large theatre productions, large production studios, large live event venues and live broadcast events produced by the UK’s TV broadcasters, including BBC, ITV, Channel 4 and Sky. Broadcasters will use audio PMSE equipment across the UK, in studios, for outside broadcasts and at major national events.

The main benefit of wireless equipment for audio PMSE is that it allows people using in-ear monitors and wireless microphones to move around. Over recent years, stakeholder evidence provided to us for this study suggests the popularity of using wireless microphone and in-ear monitor devices at major entertainment and sports events is growing substantially.

The UHF spectrum used by DTT is extensively used for audio PMSE globally, and is regarded as the core spectrum resource for audio PMSE use in Europe in accordance with European Radiocommunications Committee (ERC) Recommendation 25–10. In the UK, audio PMSE uses UHF spectrum in two blocks on a geographically interleaved basis with DTT: 470MHz to 606MHz, and 614MHz to 694MHz. In addition, channel 38 (606MHz to 614MHz) provides exclusive, UK-wide, access to spectrum for audio PMSE. While channel 38 is a popular band for some uses in the UK (for example, outside broadcasting), it is limited in bandwidth and is more at risk from interference. Therefore, the geographically interleaved channels between 470 to 606MHz and 614 to 694MHz are often preferred by the audio PMSE industry for professional audio PMSE use.

There are several other frequency bands available for audio PMSE in the UK but there is a preference within the PMSE industry to use UHF spectrum, due to wide availability of equipment, large amount of bandwidth and the characteristics of UHF spectrum being well suited for body-worn audio equipment. Alternative bands include 694-703MHz, 960MHz to 1164MHz, 1880MHz to 1900MHz (which is audio PMSE via ‘DECT’ technology^{[footnote 2]}) and 1785MHz to 1800MHz.

There are multiple large events held annually in the UK requiring significant use of audio PMSE (e.g. Glastonbury). There are also various new multi-studio venues emerging in the UK and these are expected to attract production companies into the UK market that will require extensive audio PMSE capabilities. New users can use the available 960MHz to 1164MHz band where there is an existing device ecosystem.^{[footnote 3]} More users might adopt technologies that allow for transmission of multiple audio channels over a single radio channel at venues where it is feasible to use such solutions. These newer technologies are referred to as wireless multichannel audio systems (WMAS), and might be used to offset spectrum demand in locations where it is feasible to use them.

Stakeholder interviews indicate that using WMAS in locations with multiple productions and few suppliers has helped partially offset spectrum demand. This is feasible where broadband solutions can replace multiple narrowband channels. However, stakeholders also expressed to us that significant improvements in spectral efficiency from WMAS developments are yet to be proven. This is particularly true when equivalent latencies and audio quality are considered. WMAS may not be suitable for productions such as live broadcast media where audio must be of the highest quality. Stakeholders have also investigated the capability of 3GPP’s 5G new-radio (NR) technology to support audio PMSE. However, they have found that it cannot currently deliver the required latency.

PMSE stakeholders have also stated clearly that identification of new pan-European options for audio PMSE use is needed to meet growing demands in the creative sector in the UK and ensure device availability, compatibility, and avoidance of harmful interference.

1.3.3 Other potential uses

Other possible uses of UHF spectrum identified in this report include: services associated with the UK’s Emergency Services Network (ESN); future telecommunications networks to support the UK energy networks (including the transition to a smart grid); and/or water industries and services used in the UK transport network, such as passenger connectivity and certain transport operational use cases (for example, remote inspection of assets using real-time video, or remote piloting of autonomous buses or coaches).

There may be other potential uses that we have not been able to identify though our research.

1.4 Value of UHF spectrum for mobile use

In order to assess the benefits of additional UHF spectrum for mobile use, this study models the mobile network cost savings that could be realised by UK MNOs. This is done by comparing forward-looking projections of mobile network costs that would be incurred with and without additional UHF spectrum, under assumptions of future mobile broadband (MBB) data traffic, market shares and network configuration parameters.

The network cost savings model builds a bottom-up estimate of total mobile network (downlink) traffic and distributes that traffic across the sites in the mobile network. It then provisions sufficient capacity to serve this traffic at the lowest possible cost. The cost will, in general, be lower where MNOs have access to additional UHF spectrum. This is because additional spectrum allows for greater capacity per existing site and fewer (expensive) new site build requirements.

We also model additional benefits that could arise from improvements in network performance (over and above additional capacity, which the network cost model assesses the costs of replicating) resulting from the new UHF spectrum.^{[footnote 4]} To assess these additional benefits, an ‘adjusted technical value’ approach is used, which we previously used in work for Ofcom on the cost–benefit analysis of 700MHz clearance. This approach calculates the additional network costs that operators would incur if they sought to provide the same quality of service that a new UHF spectrum assignment would enable, but without access to the new spectrum (i.e. using increased network density instead).

The model outputs are expressed in Net Present Value (NPV) terms. NPVs are calculated to a fixed end date of 31 December 2054. This means that network cost savings for spectrum release at the start of 2035 are modelled over 20 years, whilst network cost savings for spectrum release at the start of 2035 are modelled over 10 years.

Highest network cost-saving combinations

The analysis of the model outputs is a two-step process:

• network cost savings of individual operators are determined
• highest network cost-saving combinations of spectrum acquisition by the three operators, for each of the six overriding spectrum release scenarios.

The second part of the analysis combines network cost savings for different scenarios for each operator to form the overriding spectrum-release scenarios, resulting in multiple potential combinations of the operator scenarios with different network cost savings. The highest network cost-saving combination is selected for each spectrum-release scenario.

Figure 1.2 provides the highest network cost-saving combination for each of the six overriding spectrum-release scenarios in our main case.

Figure 1.2: Highest network cost-saving combinations of spectrum acquisition by the three MNOs: main case (Source: Analysys Mason, 2026)

The total benefits from additional UHF spectrum for mobile use ranges between GBP2.1 billion (Scenario 1b and 3b) and GBP3.6 billion (Scenario 3a). These values are higher or lower under our high and low traffic scenarios.

Comparison of the spectrum-release scenarios can also be informative. For example, comparison of the network cost savings between Scenario 1a and 1b shows that the incremental benefit of releasing 500MHz in 2045 (over and above releasing 600MHz in 2035) is ~GBP1.1 billion (relative to GBP2.1 billion for release of the 600MHz in 2035). Scenario 3a, which involves releasing the entirety of both the 600MHz and 500MHz bands in 2035 has (unsurprisingly) the greatest overall benefit (GBP3.6 billion). The lowest benefit arises in Scenario 3b, which is the only scenario in which no additional UHF spectrum is released before 2045.

An ecosystem in 600MHz is highly likely to develop in a manner consistent with our forecast (that is, fully developed by 2035). The outlook for 500MHz is, however, far less certain. We assume that an ecosystem begins to develop by 2035 and is fully developed by 2045. For this to be the case, a primary or co-primary allocation at WRC-31 may be required, as well as standardisation through 3GPP. We consider our assumption on the timeline for development of a 500MHz ecosystem to be reasonable. However, we acknowledge that there is more downside risk than upside risk associated with this assumption. In particular, a delay in the development of a 500MHz ecosystem could reduce the incremental benefits (of ~GBP400 million) associated with a 2035, rather than a 2045, release (although this is mitigated by a low proportion of the value arising in the first few years). If, however, a 500MHz ecosystem failed to develop at all, then there would be no value for mobile spectrum in this band. This appears an unlikely but possible scenario.

1.5 Wider benefits to the economy

We consider the potential benefits to the economy from deploying released spectrum in the 600MHz and 500MHz bands for the various use cases identified. The counterfactual is that no additional UHF spectrum would be forthcoming for these uses.

Many studies seek to identify the overall benefits from spectrum use in a particular application. However, this is often expressed as a total economic value from the entire activity. The counterfactual is that no spectrum would be available and the application cannot continue. Whilst this may result in dramatically large benefits, it is not the relevant question here. The relevant considerations are:

• For mobile use, we are concerned with the incremental benefit that might result from making additional UHF spectrum available to be used alongside existing 700MHz, 800MHz and 900MHz bands.

• For PMSE, we need to consider the loss that might occur if access to UHF were curtailed and alternative solutions needed to be found.

• For other uses, such as smart grid use, we are primarily interested in the costs of achieving similar functionality without access to the released UHF spectrum (and so which costs could be avoided if spectrum were made available).

Benefits from additional spectrum will typically increase as more spectrum is made available to applications. This relationship may be complex. Enough spectrum may be needed to make it worthwhile deploying services within a new band. Additional functionality may also require some minimum amount of spectrum (e.g. higher-bandwidth smart grid). However, whilst benefits may increase as available spectrum increases, there may be diminishing returns beyond some point.

The benefit of additional spectrum for mobile services is primarily achieved through avoiding costs of network densification to provide additional capacity in rural areas, and for better indoor coverage. These cost savings would be split amongst:

• receipts for the state from spectrum auction revenue
• benefits to customers through lower prices and better service quality than would have been the case without the additional spectrum
• returns to shareholders.

Provided competition in downstream mobile markets is effective, returns to shareholders should be limited to the cost of capital and any excess profits would give way to normal profits due to high competition in the UK mobile market. On this assumption of effective competition in mobile service markets, the value that each operator faces on winning spectrum will be equal to its network cost saving.

1.5.1 Coverage obligations

Regulators can impose obligations, such as ones for coverage, as part of spectrum awards. This would be an option that Ofcom could pursue in any spectrum award. The auction price would be reduced by the expected cost of meeting the obligation.

Ofcom already has an agreement with the mobile operators to extend coverage to 89.2% of the UK’s landmass by 31 January 2027.^{[footnote 5]} It is unclear what the balance of costs and benefits might be for further intervention. Any case for imposing further obligations would need to be considered closer to the award of any spectrum in the light of prevailing competitive conditions. There might be a case for further intervention if there were concerns about market failure, such as competition failing to deliver an optimal level of coverage, or if significant positive external benefits for coverage were not reflected in consumers’ willingness to pay for services.

We note that if Ofcom subsequently assessed the situation and found reason to impose coverage obligations, this would increase economic welfare relative to the simple assessment above. This is because such an obligation would divert auction receipts to pay for the costs of delivering additional coverage. If intervention were warranted, then the benefits from additional coverage should exceed the costs of delivering it.

1.5.2 Competition benefits

It is possible that award of further sub-1GHz spectrum could be used as a market-shaping tool by Ofcom to bring about a more symmetrical distribution of spectrum (and especially sub-1GHz spectrum) amongst the three UK mobile operators. This would be with the intention of sharpening competition in mobile services.

This is a complex issue and would be a contentious matter for design of any auction. It would likely involve some capping of spectrum portfolios held, and so by implication the amount of spectrum that different operators might acquire.

Whether such an intervention might be justified would need to be considered by Ofcom in light of competitive conditions in mobile service markets at the time of designing a spectrum award. Therefore, we cannot reach any firm views at present.

Spectrum portfolios affect competitive positions as they affect the marginal cost to operators of additional network capacity. If there is less spectrum, more sites are needed to achieve similar capacity. Therefore, there may be variation in the effective marginal costs facing operators if they win customers or grow traffic through offering new or improved services. Those with more spectrum can handle the additional traffic more cheaply at the margin. This does not mean that all operators need identical spectrum portfolios for competition to be effective, but it does mean that they should not be too asymmetric.

It is not the case that a precisely symmetric spectrum allocation is needed to allow effective competition in mobile services. However, a more symmetric distribution might lead to slightly more intense competition through giving operators more similar costs of adding traffic (and customers) at the margin. This is only likely to be a modest effect.

As a regulator setting spectrum policy, Ofcom would not be enforcing competition law when making decisions about spectrum assignment, but rather working to its remit and legal duties for efficient assignment and use of that spectrum to the benefit of end users. Therefore, changes in competition conditions that are material, but below the level of changes that would typically trigger presumptions of concerns in merger control, would still be a relevant consideration for design of an award process.

1.5.3 External benefits

Because UHF spectrum release helps mobile networks deal with hard-to-serve traffic, there would likely be some external benefits to consumers. By definition, these are benefits that cannot be monetised by network operators.

Improvements in rural coverage, and the reliability of existing rural services, potentially bring benefits through improved public safety. These benefits are difficult to quantify and are unlikely to add significantly to our overall estimates of benefit given the uncertainties involved. Nevertheless, improved rural services may assist in meeting various societal goals, including digital inclusion, as discussed in the literature review below.

Rolling out services in additional bands may create some small improvement in the reliability of radio access networks. However, this is unlikely to be a significant benefit as much of the equipment at mobile sites would still be common to radio access networks in different bands. Therefore, failure risks would not be significantly reduced and additional benefits small.

2 Introduction

2.1 Background and context

This is the final report of an Analysys Mason and DotEcon study, on behalf of the Department for Culture, Media and Sport (DCMS) and Department for Science, Innovation and Technology (DSIT). It is a report on understanding the value of spectrum currently used primarily for digital terrestrial television (DTT) in the UK. The study is being carried out over a period from October 2025 to February 2026.

To frame the study, we will outline the context. After nearly 30 years of operation in the UK market, the future of the national DTT network is under consideration. This consideration is part of a wider government review of the future of TV distribution in the UK. This review is prompted by significant changes in the TV viewing landscape. The changes include the increasing use of internet delivery for TV distribution as well as an increasing use of hybrid forms of distribution. The hybrid forms of distribution include combining DTT with broadband-enabled internet delivery. These shifts in viewing trends brings into question whether it is still relevant and necessary to continue to invest in the UK’s DTT platform. The platform still operates using older technology (digital video broadcasting – terrestrial, or DVB-T), alongside a newer version, DVB-T2, used for high-definition channels.

DTT in its current form uses ultra-high-frequency (UHF) spectrum from 470MHz to 694MHz. DTT is not the only user of this spectrum, and the spectrum is shared with programme making and special events (PMSE). It is shared under a long-standing sharing arrangement. In this arrangement, time-limited and location-specific audio PMSE channels are accommodated within the multi-frequency regional re-use plan used in the UK’s DTT architecture. In light of television (TV) audience shifts towards viewing via Internet Protocol TV (IPTV), the government is considering the future of television distribution in the UK, including various options that might include reducing the DTT platform to carry a reduced Freeview service or switching the DTT platform off entirely. These changes could result in the release of some frequencies currently used by DTT for other purposes.

We are conducting this study as an input to the UK government’s review of the future of TV distribution. DCMS is working closely with DSIT on the spectrum aspects of the future of TV review, given DSIT’s role as spectrum policy lead across government. Specifically, DCMS and DSIT asked us to consider the potential alternative uses of UHF spectrum and the associated value of these uses. DCMS and DSIT also asked us to consider the implications of any changes in spectrum use for DTT on the spectrum available for PMSE.

2.2 Scope of the study

The scope of the study is as follows:

• Understand the alternative uses of UHF spectrum that might be released from DTT use. This is in terms of spectrum demand, timing of demand and characteristics (for example, amounts of spectrum, configuration and geographic nature), under several scenarios of spectrum release provided to us by DCMS and DSIT. This is further described in Section 3.

• Estimate the potential value of the spectrum that could be made available for other uses, as input to a cost–benefit analysis that the UK government is undertaking into the different options for future of TV.

• Consider the wider benefits to the UK economy of UHF spectrum.

• Assess implications of different scenarios for DTT spectrum release on the PMSE sector.

2.3 Summary of study approach

Our study uses a mixture of qualitative and quantitative approaches, as follows:

• Qualitative analysis of alternative use: we used a series of one-to-one interviews with stakeholders from across the communications market in the UK to inform us on the current and potential future uses of UHF spectrum. This includes mobile network operators (MNOs), mobile equipment suppliers, PMSE industry representatives, infrastructure companies and various public-sector spectrum users.

• Quantitative analysis: we developed a mobile network cost model to compare the net present value (NPV) of future network costs for MNOs in the UK market. We analysed this under different future mobile broadband (MBB) data traffic scenarios with, and without, additional UHF spectrum available in the network deployment.

• Consideration of wider benefits to the UK economy: our considerations were based on a review of economic literature on benefits of the various sectors of spectrum use under consideration in the study.

2.4 Structure of this report

The remainder of this document is laid out as follows:

• Section 3 describes the scenarios for UHF spectrum release brought about by different possible options for the future of the DTT platform shared with us by DCMS and DSIT
• Section 4 discusses demand for UHF spectrum for audio PMSE
• Section 5 describes demand for spectrum for mobile use
• Section 6 provides a summary of other use cases identified in the study
• Section 7 presents our analysis of the value of spectrum in mobile use
• Section 8 discusses benefits of UHF spectrum to the UK economy.

3 Uses of UHF spectrum

This section discusses the spectrum under consideration in this project. It also looks at the possible scenarios for spectrum release and the possible alternative uses of this spectrum. These topics have guided our research in the remainder of this report.

3.1 Spectrum under consideration

The spectrum under consideration is from 470MHz to 694MHz as shown in Figure 3.1. This spectrum is currently allocated for TV broadcasting use and assigned for use by DTT transmitters in a multi-frequency network (MFN) configuration in 8MHz unpaired channels. Spectrum from 606MHz to 614MHz is reserved for use by PMSE radio microphones and in-ear monitors (‘channel 38’), on a national basis. Spectrum from 470MHz to 606MHz and 614MHz to 694MHz is also available for PMSE use. However, it is available on a geographically co-ordinated basis and is shared with the DTT transmitters.

There are alternative 600MHz band plans standardised by the mobile industry’s standardisation body and Third Generation Partnership Project (3GPP). These have been standardised for mobile (4G/5G) use in other regions of the world. There are currently two prominent 600MHz options for mobile use:

• 3GPP band n71: uses 617MHz to 698MHz and was first used in the USA. It is now also used in Saudi Arabia, the first market in ITU Region 1^{[footnote 6]} to have assigned a 600MHz band for mobile use.

• 3GPP band n105: uses 612MHz to 703MHz and has been developed for use in ITU Region 3 (Asia–Pacific).

The two 600MHz band plan options above provide different amounts of spectrum. Band n105 potentially provides 2x40MHz of spectrum in a mobile configuration whereas band n71 provides 2x35MHz. The n105 option may be less attractive in Europe due to its overlap with spectrum used for radio astronomy in some European markets. However, this consideration does not apply in the UK. Assuming that the UK chooses a band plan that aligns with its European neighbours, it seems that n71 may be the most likely option. Figure 3.1 shows the current configuration of the UHF spectrum used by the DTT platform and by PMSE, alongside illustrations of alternative band plan options for mobile use.

Figure 3.1: Summary of spectrum under consideration: 470MHz to 694MHz (Source: Analysys Mason, 2026)

Our scope of work also includes the consideration of alternative uses of the 500MHz band. The 500MHz band is shown in the figure above as the lower part of the UHF spectrum from 470MHz to 606MHz.

For the 500MHz band, the only band plan option within 3GPP’s specifications currently is one referred to as ‘standalone downlink only’ (SDO). This covers the entire range 470-698MHz, intended to be suited to any market where an LTE or 5G-based terrestrial broadcasting network is proposed.^{[footnote 7]}

Under the preliminary scenarios for future of TV distribution, there are alternative possible uses of the 500MHz band in the 2030s, and beyond. Some or all of the 500MHz band could be retained for DTT use or could be available for other uses. Alternatively, the 500MHz band could be used for PMSE whilst the 600MHz band is changed to another use.

The envisaged scenarios for DTT spectrum release in the UK are described in the next section. At the time of producing this report, there is no suitable 500MHz band plan on the horizon in 3GPP standards for mobile broadband (MBB) use. Hence, use of the 500MHz band in public mobile networks would be subject to further mobile ecosystem developments once/if a suitable band plan for mobile equipment and devices is agreed. A potential future shift in use of UHF allocations may result from discussions to take place at the WRC in 2031 (WRC-31), since there is an agenda item confirmed for that conference on future use of the UHF spectrum. However, even if WRC-31 decided to implement a mobile allocation in the 500MHz band, there would be further harmonisation work needed after this to align timing for release of this spectrum at a European level. It seems unlikely this will occur before 2035.

This risk around development of a mobile ecosystem for the 500MHz band further discussed in Section 5 and also in Section 7.

3.2 Scenarios for DTT spectrum release

Our study is guided by the indicative UHF spectrum-release scenarios that were shared with us at project inception by DCMS and DSIT, as summarised in Figure 3.2.

Figure 3.2: UHF spectrum scenarios (Source: Analysys Mason 2026)

Spectrum scenario	Name	Timing options/ implications for new uses of UHF spectrum	Implications for current uses (PMSE)
0	No change	No spectrum released	No change to spectrum currently available for audio PMSE
1	DTT re-planning: 500MHz band retained for use by DTT (for example, three or four multiplexes (MUX)). 600MHz band available for mobile or other uses	1a Release 600MHz band for mobile or other uses in 2035 (followed by release of 500MHz band in 2045) 1b Release 600MHz band for mobile or other uses in 2035 (no further spectrum release)	1a Loss or reduction in bandwidth available in the 600MHz band for PMSE in 2035 followed by similar loss or reduction in 500MHz. Some use of the 600MHz and/or 500MHz bands by PMSE might still be possible, if shared use with mobile or other new uses is possible – see Section 4 – or if some of the spectrum is retained for PMSE use. 1b Loss or reduction in bandwidth available in the 600MHz band for PMSE in 2035; continued access to the 500MHz band
2	DTT reduced to carrying a minimum number of core channels (for example, one or two MUX). 600MHz and part of the 500MHz band available for mobile or other uses	2a Release 600MHz band and part of the 500MHz band not retained for DTT by 2035 (followed by release of remaining 500MHz spectrum in 2045) 2b Release 600MHz band and part of the 500MHz band not retained for DTT by 2035 (no further spectrum released)	2a Loss or reduction in bandwidth available in the 600MHz band and part of the 500MHz band for PMSE in 2035 followed by similar loss or reduction of the full 500MHz. Some use of the 600MHz and/or 500MHz bands by PMSE might still be possible, if shared use with mobile or other new uses is possible – see Section 4 – or if some of the spectrum is retained for PMSE use. 2b Loss or reduction in bandwidth available in the 600MHz band and part of the 500MHz band for PMSE in 2035; continued access to the 500MHz band
3	IPTV migration/ DTT closure; release of all DTT spectrum	3a Release of all DTT spectrum in 2035 3b Release all DTT spectrum in 2045[footnote 8]	3a Loss or reduction in all UHF spectrum available for PMSE in 2035. Some use of the 600MHz and/or 500MHz bands by PMSE might still be possible, if shared use with mobile or other new uses is possible – see Section 4 – or if some of the spectrum is retained for PMSE use. 3b Loss or reduction in all UHF spectrum available for PMSE in 2045

3.3 Use of UHF spectrum by audio PMSE

The UHF spectrum is used by various forms of wireless equipment in the audio PMSE sector. Audio PMSE refers to wireless equipment used for audio purposes in live broadcasts, theatrical events and live productions. This includes equipment such as in-ear monitors, wireless microphones and audio links.

Audio PMSE is part of a broader range of PMSE applications, which use different frequency bands. Audio-only applications tend to have lower bit rate requirements. However, these applications have stringent requirements for latency and audio quality. Lower frequency bands such as Very-High-Frequency (VHF) and UHF have been most widely used for audio PMSE. Higher bit rate PMSE includes HD and ultra-high definition (UHD) video cameras, and these use higher frequency bands. In recent years, some video PMSE applications have been delivered by the BBC using private 5G networks to upload live video from events. It was used for onward distribution to broadcasters around the world.^{[footnote 9]}

The audio PMSE sector accesses UHF spectrum on a shared basis with DTT. Demand for audio PMSE – especially in-ear monitors – is growing. Demand for audio PMSE use is growing in specific locations as large events and productions held in the UK become more complex and elaborate. To meet this growth, the PMSE sector is seeking to supplement the bands that are currently available with additional spectrum. Hence, any change of use in the UHF band will impact the audio PMSE sector.

The sector itself includes a variety of smaller and larger users. Smaller operations for audio PMSE include churches, local event or conference venues and small theatres. A smaller number of wireless microphones might be in use at these locations. Larger users include large theatre productions, large studios, large event groups and the UK’s broadcasters, including BBC, ITV, Channel 4 and Sky. Broadcasters will use audio PMSE equipment across the UK, in studios, for outside broadcasts and at major national events. The main benefit of wireless equipment for audio PMSE is that it allows presenters and performers to move around with wireless microphones or in-ear monitors, rather than being confined to fixed locations where a wired connection is available. Over recent years, the popularity of wireless devices at major entertainment and sports events has grown substantially.

3.4 Possible new uses of 470MHz to 694MHz

The following section summarises alternative uses of the UHF spectrum we identified at the start of the project as being relevant for consideration in the UK market. This applies in the event that spectrum is released from DTT use and becomes available for other uses.

3.4.1 Public mobile networks

Mobile services in the UK continue to form an essential part of the UK’s economy. Growth in mobile data traffic in the UK has slowed in recent years. However, overall levels of mobile data consumption continue to be very high and growing. User experience expectations are also very high. The use of UHF spectrum is an important part of the strategy that MNOs use to ensure network performance keeps pace with both technology development and user expectations.

Sub-1GHz signals propagate further than higher frequency mobile bands. Rural areas of rely on existing sub-1GHz mobile bands. Ofcom’s coverage figures state that some outdoor 4G coverage from at least one MNO is available to 96% of the UK landmass. For 5G, 83% of areas outside of premises in the UK can receive 5G-standalone or 5G-SA. Ofcom refers to this 96% coverage as ‘variable’ and expresses that 88% of the UK landmass has ‘good’ 4G coverage from at least one MNO.^{[footnote 10]} However, there are disparities across regions and rural areas, in particular, suffer from mobile not-spots.

Sub-1GHz spectrum is also better at penetrating building walls than higher frequency spectrum. This can mean that in-building coverage is better when using UHF spectrum. The UK mobile market is evolving as a result of the Vodafone–Three merger. The merged entity has committed to an accelerated 5G roll-out involving an increased site footprint over the coming years. The other two national MNOs are responding in terms of their own increased site deployments. Ofcom’s estimate is that that number of sites using 5G technology has increased rapidly over the last year. MNOs upgrading technology deployments on existing macro sites, and site and network sharing is helping to push the increasing penetration of 5G. The building of new sites has included 99 government-funded mast upgrades delivered through the Shared Rural Network (SRN) programme.^{[footnote 11]}

There are likely to be a number of benefits of using parts of the UHF spectrum currently used for DTT, for mobile use. These benefits include potential cost savings by deploying fewer new base stations as data volumes and customer experience expectations increase. They also involve improvements in mobile network performance, especially indoors and in rural locations, which both benefit from the physical properties of UHF spectrum. Additionally, there is the possibility for new technologies such as 6G to be introduced sooner over wider areas of the UK. This can happen once 6G technologies are standardised, which is expected by the end of this decade. We discuss how MNOs might view demand for UHF spectrum in Section 5.

We discuss the evolution of mobile coverage in the UK and our analysis of network cost savings from having additional UHF spectrum available for mobile use in Section 7.

3.4.2 Wireless technologies used in the transport sector

Multiple wired and wireless connectivity solutions are used to support the operation of the UK’s transport networks. Use cases for telecoms connectivity across the transport network include the following:

• Monitoring of transport infrastructure: used to manage maintenance, predict maintenance and maintain overall visibility of transport infrastructure. Asset inspections might include use of real-time video either to display images of buses, ferries or trains in real time in control rooms. It could also include the use of drones for aerial asset inspections.

• Passenger connectivity: typically refers to use of public mobile networks by passengers while on the move via trains, buses and in cars.

• Movement of goods: this refers to various UK-wide logistics industries, using different transport modes to move and deliver goods and products either directly to customers or as part of a supply chain within the UK.

• Automation: this refers to the prospect of fully autonomous vehicles of different types, now and in the future. Examples of vehicles that might be operated autonomously includes buses and ferries, and, in the future, passenger vehicles on roads.

• Transport operations: this includes monitoring of traffic levels across transport infrastructure and the capture of data that can be used for future modelling. For example, of future capacity requirements in the transport network.

Where assets are fixed (for example, a bus stop), connectivity is possible via a wired connection such as fibre. Where movement is involved, mobile connectivity is possible either via a MNO’s network or via a dedicated form of wireless network can be used. A summary of the key spectrum bands used in different transport networks in the UK is shown in Figure 3.3 below.

Figure 3.3: Operational wireless networks used in transport networks in the UK (Source: Analysys Mason, 2026)

Transport mode	Current use cases	Future use cases	Relevant to UHF spectrum (yes/no)
Rail	Trains in the UK are fitted with 2G-based cab radios using spectrum in the 900MHz band harmonised for railways purposes at a Conference of European Postal and Telecommunications Administrations (CEPT)[footnote 12] level under GSM-R harmonisation decisions (covering frequencies 876MHz to 880MHz/921MHz to 925MHz). This band is adjacent to, the spectrum used by UK MNOs in the 900MHz band. This provides track-to-train communications and signalling. Additionally, passenger connectivity for people travelling on trains can either be provided by mobile networks (use of smartphones on trains), or by in-train wireless networks provided by train companies, usually via Wi-Fi.	The GSM-R network is to be replaced by the Future Railway Mobile Communications System (FRMCS), which will replace the 2G technology used in GSM-R with 5G. This will support greater use of data, as well as voice and video. Ofcom issued a statement in March 2025 proposing to assign a 10MHz block of spectrum in the 1900MHz to 1920MHz band for FRMCS use, in line with a harmonised decision of CEPT countries.[footnote 13] Like GSM-R, FRMCS is designed for use by operational communications for the railway and not for passenger connectivity. There is no change currently to the way passenger connectivity is provided in the rail network. A discussion with the Department for Transport (DfT) as part of this project indicated that having further UHF spectrum available for MNOs use may be beneficial for improved passenger connectivity, both for rail and for road.	Yes – for improved passenger connectivity via MNO networks
Road	Current use cases include operational use of short-range wireless (for example, sensors and Wi-Fi) and public mobile networks in a range of uses cases. These include as management of traffic signals, road monitoring and voice communications for field workers. Passenger connectivity for passengers in cars, taxis and buses is as per the rail network and delivered via MNO networks.	National Highway’s ‘Digital Roads’ vision[footnote 14] sets out objectives for leveraging large data sets to improve road operations and support road planning in the UK. The vision includes use of data and sensor technology, digital workforce applications for field workers, predicted asset management and greater use of automation. The DfT’s pilots of self-driving taxis and bus services have been announced for 2026.[footnote 15]	Yes – for improved passenger connectivity via MNO networks. We conducted an interview for this project with the DfT. Based on that, it is also noted that public mobile networks might be part of the connectivity solution for future connected vehicles. This will be via the vehicle-to-network component of V2X. The vehicle-to-vehicle connectivity envisaged as part of V2X would not use MNO networks. It would use dedicated short-range wireless connectivity (currently earmarked in the 5.9GHz band)
Ferries	Similar to roads above	Similar to roads above – self-driving ferries may be a future use case.	Similar to road above
Buses	Similar to roads above	Similar to roads above – self-driving ferries may be a future use case.	Similar to road above
Air	Various radiocommunications solutions are used for aeronautical connectivity such as voice and data connectivity with aircraft. These generally use spectrum assigned for aviation use in the UK Frequency Allocation Table. Passenger connectivity services in aircraft via satellite have emerged in recent years such as the European Aviation Network operated by Viasat and used by British Airways.	Satellite constellations closer to Earth (for example, low-Earth Orbit satellites, or LEOs) may increase passenger connectivity via aircraft or offer new services. Electric vehicle take-off and landing (eVTOL), or electric air taxis, are also being proposed and would use various forms of wireless connectivity.	Possibly, if eVTOL or passenger air-taxis use MNO networks as part of voice or data connectivity (for example, to provide passenger connectivity during the flight).

3.4.3 The Emergency Services Network

The Home Office together with the other UK government emergency services departments set up the Emergency Services Mobile Communications Programme (ESMCP). It was set up to implement a replacement to the current dedicated critical communications network provided by Airwave. The Airwave network uses ‘TETRA’ technology whereas the new Emergency Services Network (ESN) will use 3GPP 4G mobile technology. ESN is a network service set up through contracts awarded by the Home Office. A selection process took place to find an ESN supplier, and the Home Office awarded the current ESN contract to BTEE. An initial contract ran to 2024 and a new contract was announced in 2024, indicating that the ESN is expected to be operational by 2029.^{[footnote 16]}

The Home Office has chosen to adopt a deployment model for the ESN whereby emergency services (ES) user devices for police, fire and ambulance users will be connected via BTEE’s radio access network (RAN) using BTEE’s existing licensed 800MHz and 1800MHz spectrum (the same spectrum used by BTEE to provide 4G services to consumers across the UK). A separate core network has been built and the ESN will operate using a multi-operator core network (MOCN) approach.

Although BTEE’s licensed 800MHz and 1800MHz spectrum will provide the majority of network-based voice and data connectivity for ES users, there are several bespoke elements of ES connectivity that will use dedicated spectrum. This includes air-to-ground connectivity (that is, connectivity for ES helicopters), and ESN ‘gateways’. These gateways are a means of provided extended coverage for ES users using equipment fitted to ES vehicles served by 10MHz of 1900MHz spectrum.

One aspect of the TETRA operation not yet provisioned via the ESN is device-to-device connection. This refers to ‘direct mode’ operation (DMO) that enables TETRA-based ES devices to communicate with each other, without using a network for communications. ES users have used this DMO capability in the past to form local area networks for voice communications at major incidents. ES users have also used it as a back-up to the network connectivity (for example, in coverage-limited situations). TETRA handsets provided both DMO and network connectivity via the same device.

A 3GPP technology referred to as ‘Sidelink’ for device-to-device connection is being standardised. The Home Office noted that Sidelink connectivity could be used for handset-to-handset calls by the emergency services. This would require additional spectrum, which could be provided via spectrum in the 500MHz or 600MHz band. However, this would depend on standardisation, harmonisation and implementation in ESN user devices. The Home Office suggested they think it will be at least 7 years before Sidelink standardisation is considered commercially stable and available. However, it is not clear whether this standardisation will happen (since 3GPP standards are contribution-driven and depend on commitment from 3GPP members to implement changes). If standardisation does happen, it is also not clear if this will include 500MHz or 600MHz spectrum, or whether standards might focus on other frequency bands.

One of the current plans is for ESN handsets to be dual-mode between LTE and TETRA and for TETRA to be used for the handset-to-handset communication. This would allow TETRA DMO to provide voice connectivity in situations where an alternative to ESN voice calls is required. These situations might include users being in places where network coverage is not available from the ESN. Situations may also include places where additional resiliency is required (for example, due to a network failure). Another alternative to provide voice connectivity outside the ESN might include direct to device (D2D) via satellite.

3.4.4 Wireless technologies to support the evolution of the energy smart grid

In the utilities sector, both energy and water industries may see evolving demands for wireless technologies. This is due to evolution of requirements in those sectors together with a need to replace legacy solutions as a result of some wired and wireless technologies traditionally used in these sectors being removed from the UK market (e.g. public switched telephone network (PSTN) and 2G/3G mobile).

Energy distribution network operators (DNOs) around the UK have used various forms of fixed and wireless telecoms infrastructure over many years to control and monitor the state of the electricity grid. This control and monitoring helps consumers as well as providing real-time network operations and control to manage the energy grid. For example, grid management helps to reduce the number of electricity interruptions and the length of time that customers are without supply in the event of a power failure. There are various spectrum bands in the UK that are currently used by DNOs to manage the energy grid. Fixed links bands are used for core network backhaul. DNOs also use the UHF band (450MHz to 470MHz) for low data rate monitoring, called ‘Supervisory Control and Data Acquisition’ (SCADA). The Joint Radio Company (JRC), a joint venture between the UK electricity and gas network operators, co-ordinates use of this spectrum nationally. This enables multiple DNOs to share channels without interference, maximising spectrum utilisation. The current SCADA network extends to thousands of connected assets on the high-voltage network across the UK. However, various published reports have suggested that the existing SCADA infrastructure and other legacy telecoms solutions used by DNOs are not sufficient to meet the additional demands driven by smart grids.

Arqiva uses its 412MHz spectrum for smart meter connectivity (Scotland and north of England) and for smart water metering (major regional contracts). These include long-term contracts (15-plus years). Expectation of water metering expansion means 412MHz is potentially fully committed to this use and Arqiva did not foresee additional, large-scale smart grid needs being accommodated using this spectrum. The water industry is understood to have used legacy telecom solutions extensively in the past – including PSTN and 2G mobile. With these solutions being removed from the UK market, there will be a need for replacement solutions to be found.

Requirements for smart grid and digitisation of energy systems derive from a move towards decentralised power generation. The objective is to accommodate new clean-energy generation and facilitate the move to clean power by 2030. This is per the government’s commitment in the Clean Power 2030 Action Plan. The government is also working on enhancing the UK’s energy security and resilience. This has implications for how telecoms architecture to support the UK’s critical energy infrastructure must be designed.

In 2023, Ofcom published a call for input on potential spectrum bands to support utilities sector transformation.^{[footnote 17]} Ofcom’s consultation acknowledged that there are various options for meeting the utility sector communications needs. However, if a private wide-area network was to be chosen as the preferred option, this might require access to additional spectrum.

Ofcom’s proposals in 2023 were to study the following bands for Great Britain as options for providing telecoms solutions to support smart grids (additional options were identified that might be suitable in Northern Ireland, which are not shown here):

• Parts of 450MHz to 470MHz: while this band is well supported by 4G/LTE equipment, it is not immediately available in the UK. This is due to extensive use by business radio, PMSE and also by the DNOs for existing SCADA systems. SCADA specifically uses 457MHz to 458.5MHz and 463MHz to 464MHz.

• 733MHz to 736MHz/788MHz to 791MHz: Ofcom indicated this 2x3MHz of spectrum might be more immediately useable than the 450MHz to 470MHz band. It is adjacent to 700MHz assignments used by UK MNOs.

• Parts of 1900MHz to 1920MHz: Ofcom indicated this band was previously assigned for 3G use but was unused due to lack of 3G unpaired technology equipment development. Therefore, Ofcom proposed this spectrum could be available for other uses. However, Ofcom subsequently confirmed that 10MHz in this band will be assigned to the rail sector for the Future Rail Mobile Communications System (FRMCS). FRMCS is being rolled out as replacement for the older GSM railways (GSM-R) system. A further 5MHz has been authorised for ESN gateways. Hence this only leaves a 5MHz portion potentially available.

The energy sector, via JRC, has indicated a preference for using sub-1GHz spectrum, although without detailed cost/benefit analysis of alternative options being available. The JRC’s view is that a private LTE solution using sub-1GHz spectrum could best support a private wide-area network that needs to span a wide geography to connect many more assets as the energy grid becomes more distributed. This preference for sub-1GHz suggests the only one of Ofcom’s options above that will both be immediately available and below 1GHz is the 2x3MHz of 700MHz spectrum. However, the limited bandwidth of this assignment may constrain the future use cases that can be supported. This is particularly true if there is growing use of higher-speed data, or real-time video. Hence, with an initial deployment in the 700MHz band, there may be a further need for additional spectrum beyond the 2030s, to meet evolving needs. This suggests it is relevant to include potential utility sector requirements in our consideration of future uses of the 500MHz and 600MHz bands. It is noted that the government is expected to publish an assessment of the telecoms needs of the utility sector by end of 2026, as per the government’s latest ten-year Infrastructure Strategy, published in 2025.

4 Impacts on PMSE from changes in UHF spectrum use

4.1 Overview of PMSE use cases in UHF spectrum

Spectrum currently used for DTT (470MHz to 606MHz, and 614MHz to 694MHz) is also used by audio PMSE equipment in the UK. The UHF spectrum is the main frequency band used in the UK by this type of PMSE equipment.

Examples of audio PMSE equipment include wireless microphones, in-ear monitors and audio links. These different forms of audio equipment are used in a wide range of settings from radio and television studios for content production and live broadcast through to educational settings, theatres, art and culture venues, and large-scale sports and music events. PMSE equipment is used by a range of providers including large broadcasters, large event suppliers and performers, and a wide range of smaller organisations, including theatres, community centres and churches.

UHF is one of a small number of frequency bands used by audio PMSE, and is by far the most popular solution. The other bands available for these applications in the UK other than UHF are VHF (175–210MHz), 700MHz (694-703MHz), 800MHz (823–832MHz), 900MHz (960–1164MHz) and 1.8GHz (1785–1805MHz, and 1880–1900MHz). Of these alternatives, the 900MHz band is the most recent addition in the UK market. This band was also used for aviation equipment (distance measuring equipment, or DME) and was made available for audio PMSE use on a shared basis with DME around 5 years ago. This was after DTT was cleared from the 700MHz band meaning that PMSE’s use of the 700MHz portion of the UHF band was discontinued.

4.2 Spectrum bands available for PMSE use

The 470MHz to 694MHz band is widely available for audio PMSE use globally, and is regarded as the core spectrum resource for audio PMSE use in Europe in accordance with European Radiocommunications Committee (ERC) Recommendation 25–10. In the UK, audio PMSE uses UHF spectrum in two blocks on a geographically interleaved basis with DTT: 470MHz to 606MHz. and 614MHz to 694MHz. In addition, channel 38 (606MHz to 614MHz) provides exclusive, UK-wide, access to spectrum for audio PMSE. While channel 38 is a popular band for some uses in the UK (for example, outside broadcasting), it is limited in bandwidth and is more at risk from interference. Therefore, the geographically interleaved channels between 470 to 606MHz and 614 to 694MHz are often preferred by the audio PMSE industry for professional audio PMSE use. This is due to the co-ordinated nature of the frequency assignments, which allows for higher quality of audio transmission, less prone to interference.

There are several other frequency bands available for audio PMSE in the UK but there is a preference within the PMSE industry to use UHF spectrum, due to wide availability of equipment, large amount of bandwidth and the characteristics of UHF spectrum being well suited for body-worn audio equipment. Alternative bands include 960MHz to 1164MHz, 1880MHz to 1900MHz (which is audio PMSE via ‘DECT’ technology^{[footnote 18]}) and 1785MHz to 1800MHz. However, the UHF spectrum is generally considered to be the core spectrum band by the audio PMSE industry. The preference to use UHF frequencies is not only due to propagation characteristics and bandwidth, but also because many markets worldwide use the UHF spectrum for audio PMSE. This wide availability has supported economies of scale for UHF wireless microphone and in-ear monitor equipment. The use of UHF spectrum for audio PMSE in many markets worldwide up to this point also enables event suppliers to use the same equipment in the UK to that used in other markets.

4.3 Future evolution of the PMSE sector

As the production of large sports and music events become more complex, the PMSE industry’s view is that demand for audio PMSE applications will continue to rise. However, PMSE use tends to be on a temporary and localised basis. There are a relatively small number of locations in which demand for audio PMSE equipment is so high as to require the full amount of bandwidth available in the UHF band. For example, high demand tends to be concentrated around a few larger events taking place annually, in addition to a small number of large studio settings. Taking for example the BBC’s largest studio facilities, production might use 150 to 200 channels of audio PMSE in the UK (channel width for wireless microphone or in-ear monitor equipment is 200kHz). Such large concentrations of channel use can take up to the full amount of UHF spectrum available in a location, depending on the bandwidth of spectrum available for PMSE at that location, which is determined by how the channels are interleaved with those used by DTT.

There is also continued growth in the number of locations where audio PMSE equipment is used across the UK.^{[footnote 19]} To meet demand for media and film content production, several new large-scale multi-studio venues are currently being built, such as Shinfield (Reading), Stirling Studios (central Scotland), Universal Studios theme park (Bedford) and Studio Ulster (Belfast). This demonstrates the breadth of locations across the UK in which there is demand for use of audio PMSE equipment.

These new multi-studio venues are expected to attract production companies into the UK market that will require extensive audio PMSE capabilities. We note for the new studios under construction (Stirling and Bedford), developers could be informed to ensure audio PMSE requirements are met using spectrum other than UHF through the design of the facility. For example, such studios could be encouraged to use the 960MHz to 1164MHz band. Studios might also be suitable venues to use technologies that allow for transmission of multiple audio channels over a single radio channel, such as wireless multichannel audio systems (WMAS), to offset spectrum demand.

Stakeholder interviews indicate that using WMAS in locations with multiple productions and few suppliers has helped partially offset spectrum demand. This is feasible where broadband solutions can replace multiple narrowband channels. However, stakeholders also expressed to us that significant improvements in spectral efficiency from WMAS developments are yet to be proven. This is particularly true when equivalent latencies and audio quality are considered. In other words, combining several audio channels into a broader radio channel comes at the expense of reduced audio quality, latency and/or range. As such, WMAS is a solution that can cater to some site types only. WMAS may not be suitable for productions such as live broadcast media where audio must be of the highest quality. Stakeholders have also investigated the capability of 3GPP’s 5G new-radio (NR) technology to support audio PMSE. However, they have found that it cannot deliver the required latency demanded of high-quality audio PMSE. It is noted that video PMSE has been more successfully delivered using 5G technology. Examples of where 5G technology has been used for PMSE video applications include the Summer Olympics in Paris (2024) and the King’s Coronation in London (2023).

PMSE stakeholders have stated that identification of new pan-European options for audio PMSE use is required to meet growing demands in the creative sector and to ensure that new audio PMSE products can be developed.

4.4 Impact on PMSE of reduced UHF spectrum availability for DTT

There have been two previous releases of spectrum from DTT for mobile use. The first instance was in the late 2000s, when spectrum in the 800MHz band was reallocated from broadcasting to mobile use. This was followed by the release of 700MHz band in 2013/2014.

In both instances, DTT was re-planned to use fewer radio channels, to make way for mobile use. As a result, interleaved PMSE use was also moved into the remaining DTT spectrum below 694MHz. The replacement had to take place before the end of the standard equipment lifetime. As audio PMSE equipment operates over specific tuning ranges, Ofcom conducted audits to identify the volumes of equipment using frequencies affected by earlier UHF releases. A government grant scheme was set up whereby compensation was offered to affected users.^{[footnote 20]}

When the 700MHz band was re-assigned for mobile use, Ofcom noted the significant impact of this on large events using audio PMSE. To mitigate the loss of 700MHz, Ofcom decided to make additional spectrum in the 960MHz to 1164MHz band available for audio PMSE use. While this band is viewed as a good potential solution in the UK market, it has so far had very limited take-up in Europe. This is due to incumbent use of this spectrum by aeronautical wireless services. In turn, this has impacted investment in, and availability of, equipment that could operate at this frequency.

A further reduction in the remaining spectrum used by DTT will therefore impact audio PMSE users in the UK. The impact is potentially significant for peak demand events but would be tolerable in many other locations where audio PMSE demand is lower.

The precise impact on PMSE of further loss of UHF spectrum will depend on what the government decides in terms of whether the DTT network will continue to operate in parts of the UHF band. It also depends on how the re-assigned parts of the spectrum will be used and whether shared use of spectrum with PMSE is possible.

Shared use of spectrum between PMSE and mobile use in certain locations may be one way to allow PMSE to continue to use the full 470–694MHz band if needed in those locations. The feasibility of sharing has not yet been established and hence would need to be investigated.

Co-channel sharing between mobile and PMSE has not been used to date, and hence would require further study to investigate feasibility. We note PMSE has had the option to use the gaps between mobile uplinks and downlinks, often called ‘FDD duplex gaps’.^{[footnote 21]} However, these solutions have generally not been preferred by PMSE vendors and users. We understand this is due primarily to limited spectrum available for PMSE as well as concerns over adjacent channel interference from IMT into PMSE.

We note that some UHF spectrum may still be available for PMSE use if a 600MHz band is cleared for mobile use. For example, the 500MHz band could still be available for PMSE use. However, there will be some studio locations where the bandwidth available in the 500MHz band alone will be less than the bandwidth currently used to meet audio PMSE demand in those specific locations.

Stakeholders also commented that it takes up to 10 years for new PMSE products to be developed. Shorter timeframes are possible if existing technology can be adapted, whereas longer timeframes are needed if a new technology approach is required. If a decision is made to allow shared use between public mobile and PMSE, then details would need to be defined well ahead of implementing the solution. This would allow PMSE companies time to respond and raise issues of the view of some mobile operators we interviewed for this study was that specific, time-limited sharing could be possible. For example, mobile operators could cease 600MHz operations for 2 weeks around the dates of the Glastonbury festival, to allow 600MHz channels to be used for PMSE at Glastonbury.

More extensive geographical sharing was considered unlikely to be feasible. This was the opinion of both mobile and PMSE industry representatives who we consulted as part of this project. This was due to the impact on mobile roll-out. For example, some MNOs may wish to deploy 600MHz spectrum in city locations as well as in suburban and rural areas. There is also impact on PMSE. Representatives mentioned that large exclusion zones would be needed to protect PMSE outdoor use from mobile network interference. There was also a concern that indoor/outdoor sharing may risk interference into PMSE from either mobile devices operating indoors or base stations outdoors.

It should be noted that there are cultural, social and economic benefits of the creative industries to the UK economy and some of these benefits are enabled through events that use audio PMSE equipment. These are further discussed in Section 8.2.

Loss of UHF spectrum is therefore likely to lead to risks of insufficient spectrum being available to accommodate audio PMSE demand at larger events, under current PMSE frequency planning assumptions, unless other bands are used.

Ofcom’s estimate when studying the 700MHz band was that large events need 115MHz to 174MHz of spectrum per event.^{[footnote 22]} There is currently over 200MHz of spectrum available for audio PMSE use in the UHF band and hence we understand that demand for spectrum can be accommodated even for the largest events. Changing the use of the 600MHz band would reduce the availability by 80MHz, meaning that there may not be sufficient spectrum in the UHF band to accommodate demand. Further loss of the 500MHz band would necessitate more significant changes in the way audio PMSE spectrum demand is accommodated. Options would be for Ofcom to direct audio PMSE users towards alternative spectrum bands (primarily the 960-1164MHz band, which is currently less extensively used). Alternatively, changing the frequency coordination criteria applying for audio PMSE frequency assignments (i.e. more intensive frequency re-use) may help to accommodate demand in any UHF channels remaining for PMSE use (such as part of the 500MHz band, if this continues to be used for DTT and available on a shared basis for PMSE).

5 Future demand for mobile spectrum

5.1 Overview of the 4G/5G market in the UK

5G was introduced into the mobile market around 5 years ago, initially using non-standalone infrastructure. This means that 5G radio equipment was installed within existing 4G networks, with network operations managed via 4G core networks. There is a transition underway in the UK market to move to 5G standalone networks. This means that 5G networks will use new 5G core networks.

While initial 5G take-up was slow, there has been a more significant shift recently from pre-5G subscriptions to 5G-based subscriptions. This shift is in line with handset replacement cycles, as most new smartphones on the UK market support 5G.

Evolution of the UK mobile market in the past few years is summarised in Figure 5.1, Figure 5.2 and Figure 5.3.

Figure 5.1: Total mobile subscribers in the UK (Source: Analysys Mason, 2026)

Figure 5.2: Market share of UK MNOs by subscribers (Source: Analysys Mason, 2026)

Figure 5.3: Total data traffic in the UK by operator (Source: Analysys Mason, 2026)

5.2 Spectrum bands available for 4G/5G use

UK MNOs have access to mobile spectrum across nine different frequency bands, on a nationwide basis. In addition, the 26GHz and 40GHz bands were recently added to MNO spectrum portfolios across 68 high-density areas (mostly medium to large cities). The nationally available bands are as follows:

• sub-1GHz: 700MHz (4G/5G), 800MHz (4G/5G), 900MHz (2G/4G/5G)
• 1–3GHz: 1400MHz (4G/5G – downlink only), 1800MHz (4G/5G), 2100MHz (4G/5G), 2300MHz (4G/5G), 2600MHz (4G/5G)
• above 3GHz: 3.4–3.8GHz (5G).

The split of spectrum between UK MNOs varies between bands as shown in Figure 5.4. There is disparity both in terms of share of sub-1GHz spectrum (of particular relevance to this project), and overall spectrum amounts.

Figure 5.4: Spectrum holdings of UK operators (Source: Analysys Mason, 2026)

5.3 Future demand for spectrum

Our discussions with MNOs as part of this project identified that they see two types of future spectrum demand. The first is to increase capacity in locations with very high traffic density, for which bands above 3GHz (as per 5G equipment specifications) are identified as most suitable. The second is to serve traffic and improve network performance in hard-to-reach locations that sub-1GHz spectrum is uniquely suited to covering. This includes coverage in rural areas, and 4G/5G coverage indoors.

Improving the reliability of mobile coverage – especially in rural areas – is one of the key aspects of network performance that might be linked to further UHF spectrum availability. Further, having more sub-1GHz spectrum per operator may allow for a greater number of mobile networks to provide capacity in areas of marginal coverage. Another option would be to mandate network sharing to cover otherwise uneconomic areas. However, there is also some reliability benefit through network duplication.

Mobile coverage improvement using UHF spectrum might also improve in-home connectivity, since mobile networks provide an alternative means of communication if fixed connectivity into the home is lost. Finally, improving mobile network coverage using UHF spectrum might make public mobile networks more suited to cater for providing passenger connectivity along roads and railways. It may also enable public mobile networks to be used to provide specific use cases in the UK market, such as connectivity for energy grids.

Sub-1GHz spectrum may also lead to increased commercial value for operators, since delivering improved user experience could result in greater customer satisfaction. This could mean that users are less likely to be dissatisfied with their chosen MNO and/or switch to another. This commercial value consideration is important when assessing the value of spectrum to individual MNOs. However, in the context of a cost–benefit analysis on benefits of UHF spectrum in alternative use, our main focus is on the technical value of the spectrum. That is, we focus on costs avoided, and what those cost savings might deliver by way of benefits to consumers.

5.4 Technological developments

One factor providing an important input to mobile spectrum demand is technology change. In 5G technology, wider channels (for example, 100MHz) are used in bands such as 3.5GHz. Spectrum efficiency in these lower-frequency bands has shown modest improvements with successive generations of mobile technology and with development of MIMO antenna technology for these bands. However, spectrum efficiency has not increased at the same rate in lower-frequency bands as in higher-frequency mobile bands where massive MIMO antennas are feasible. The reason higher bands such as 3.5GHz have seen increased spectrum efficiency with massive MIMO antenna deployments is due to the wider bandwidth available, and the use of Time Division Duplex (TDD) technologies in these bands. By contrast, in the sub-1GHz bands, Frequency Division Duplex (FDD) configuration is used and MNOs have upgraded antennas but not to the same massive MIMO format.

We note that technological developments are taking place to enable mobile devices to be connected to satellites, via direct-to-device (D2D) technology. D2D services have the potential to make mobile connectivity ubiquitous in the UK. Skylo already supports D2D services in the UK but to selected devices only. Wider availability of D2D services through partnerships with UK MNOs is anticipated. These D2D services might use a combination of MNO licensed spectrum, together with spectrum allocated for Mobile Satellite Services (MSS) use in the 1.5GHz and 2GHz bands. The MNO spectrum used in future might include UHF bands such as 600MHz (and 500MHz) once these bands are supported in mobile devices, and also in satellites. A benefit of D2D in the UK market is that it might increase the resilience of mobile networks, by offering a fallback solution for devices in the event of network failure in a terrestrial network.

In the sub-1GHz bands, MNOs have favoured 2x2 or 4x4 MIMO antennas with spectrum channels in multiples of 2x10MHz. This preference for 2x10MHz as the minimum bandwidth in sub-1GHz bands is relevant to demand in the 470MHz to 694MHz band. MNOs also mentioned that higher bandwidths such as 2x20MHz are useful for rural capacity and in-building penetration. They noted that some portions of total data traffic can only be served by the sub-1GHz bands. We discuss this further in Section 7.

The emergence of 6G technology is relevant to the 2030s timeframes that are under consideration in this project. It seems likely that, once 6G is standardised and when commercially available to deploy, that it will be deployed using a combination of spectrum bands in the same way as 5G.

The future use of upper 6GHz spectrum has been widely debated in the UK and in the EU. Ofcom recently decided that the upper 6GHz band might be used for licensed mobile use in future, in city locations. Ofcom’s statement and further consultation on expanding access to the 6GHz band for commercial mobile and Wi-Fi services, published in January 2026, makes various references to use of this band for future 6G mobile. Using UHF spectrum alongside upper 6GHz would potentially enable wider 6G coverage. Based on previous mobile generation rollouts, we understand MNOs may prefer a new UHF spectrum assignment for 6G (e.g. 600MHz) rather than re-farming existing 700MHz, 800MHz and 900MHz bands. This is because, in their view, the existing bands are already heavily used for 4G/5G, making 6G use in these bands infeasible whilst existing uses continue well into the 2030s. Public mobile technologies are now in a well-established pattern of new technology generations building on top of previous ones. Hence, being able to deploy new bands into existing networks remains an important cost-efficiency consideration for mobile operators.

6 Future demand of other possible new uses of UHF spectrum

6.1 Future demand for emergency services spectrum

As discussed in Section 3.4.3, the UK’s current dedicated critical communications network for police, fire and ambulance use (Airwave) is being replaced by a new emergency service network (ESN). The new network provides voice and data capability via 3GPP 4G mobile technology using BTEE’s existing licensed 800MHz and 1800MHz spectrum. The ESN requires spectrum to support voice and data services across Great Britain. As such, there is demand for spectrum that enables increased coverage, particularly in rural areas. There may also be a future requirement for increased spectrum capacity to support more data-intensive use cases.

Satellite could offer a solution for extending ESN coverage, however the capacity available from D2D solutions may be limited. Such solutions are likely to use the same terrestrial core network as the ESN, so would offer no additional redundancy or resiliency.

Alternatively, the ESN could benefit from additional dedicated UHF spectrum to provide specific use cases. One example is resilient device-to-device connection outside commercial mobile networks. This would also ensure operational continuity from the current DMO that enables TETRA-based devices to communicate with each other. This service would require nationwide access to uplink-capable spectrum, for which sub-1GHz would be suitable if supported by the 3GPP ecosystem. As discussed in Section 3.4.3, a 3GPP technology known as Sidelink is being standardised.

6.2 Future demand for spectrum to support energy networks

As set out in Section 3.4.4, there is demand for additional spectrum to improve operational communications within energy networks. This is particularly important for the real-time load management and zero-carbon system co-ordination required to achieve 2030 clean energy targets, and to ensure energy network security and resilience. The energy system is forecast to experience substantial growth in connected assets, from renewable generation and storage to increasingly distributed resources. These assets require more frequent and more granular monitoring. We understand that it is becoming increasingly challenging for JRC to accommodate DNO SCADA demands in the existing 450MHz spectrum, for example. SCADA is one of several connectivity solutions used by DNOs. Public mobile networks (for example 2G) are also used for some use cases and the UK’s fixed network, the public switched telecommunications network (PSTN). – has also been used for legacy telemetry purposes as well as for voice communications.

The critical nature of these communications suggests a potential need for dedicated spectrum, which the government is expected to consider, alongside alternative solutions, in an assessment of the telecom needs of the utility sector to be published by end of 2026. We understand energy sector stakeholders have expressed a preference for use of sub-1GHz spectrum if dedicated spectrum is to be used. There is 2x3MHz of 700MHz spectrum that could support a private wide-area network to meet expanding operational communication needs, assuming a relevant device ecosystem develops. A private network could provide the required availability, resilience, security and coverage that cannot be guaranteed by public mobile networks. However, the limited bandwidth of the 700MHz assignment may limit the future use cases that can be supported. This is particularly true if high-throughput use cases (for instance real-time video drone inspection of overhead lines) continues to grow. As such, there may be a further need for additional spectrum beyond the 2030s to meet evolving needs.

Whilst any additional spectrum would be required nationally (so that energy companies across the UK might implement compatible solutions), it is also possible that solutions might be implemented regionally. However, nationally co-ordinated deployments could enable DNO field staff to work across regions, particularly when responding to major incidents. JRC noted that energy companies prefer to use lower frequencies for their current wireless connectivity solutions to maximise remote-area coverage and minimise the number of additional sites needed. Current 450MHz SCADA networks operate on narrow channels (~12.5kHz), but a future network may need wider channels. Both 500MHz and 600MHz bands are attractive in principle due to excellent propagation, reach and penetration, and wider channel bandwidth. 600MHz is a shorter-term option because it already has established 3GPP band plans and an equipment ecosystem. 500MHz is potentially feasible due to its lower frequency, but only viable once technology ecosystems mature

6.3 Future demand for spectrum in the transport sector

The different transport modes in the UK (road, rail, maritime, aviation) all make use of different communications solutions. The transport sector does not typically use dedicated UHF spectrum. Instead, it relies heavily on mobile operator networks whenever those networks can provide the required services and coverage. The largest unmet need is to have reliable mobile broadband-based solutions for rail and road passengers. While MNO networks do cover both rail and road networks, the capacity available is unreliable, particularly in rural or sparsely populated areas. As UHF spectrum provides the best wide-area coverage, it is in DfT’s interest that MNOs have sufficient sub-1GHz spectrum.

Railways do currently have some dedicated UHF spectrum; GSM-R uses 900MHz. However, the sector is moving to FRMCS (1900MHz) for mission-critical voice and data for track-to-train communications. Stakeholders interviewed do not see any additional or unmet demand that would require additional sub-1GHz spectrum. The 900MHz band could be repurposed once the move to FRMCS is complete.

While low-bandwidth IoT requirements are mostly addressable with existing public mobile networks, high-bandwidth and reliability-critical applications remain unsupported. Several important future transport applications may require high-bandwidth uplink. These include real-time video monitoring of assets and drone inspection of assets (for example, bridges). These use cases may result in increased demand for spectrum by the transport sector. One solution could be a form of critical national infrastructure/private governmental wide-area network. Furthermore, the rise of self-driving public vehicles such as buses will create a need for remote supervision and potentially remote assistance, which may require use of a highly available and resilient communications solution. This again requires reliable video feeds and low-latency connectivity, which could be provided over a national critical infrastructure private network. UHF’s propagation characteristics make it attractive for wide-area, reliable coverage, and could address transport connectivity challenges around mission-critical use cases. Non-mission-critical applications will continue to use UK MNO networks if possible. For example, there are still some major dependencies on 2G, such as eCall in vehicles, some traffic signals and older generations of speed cameras. Following 2G switch-off by 2033, these will continue to be served by MNOs, potentially using MNO’s sub-1GHz spectrum. New use cases including vehicle-to-network (V2N) communication are also envisaged to depend on MNO networks.

7 Value of spectrum for mobile use

7.1 Modelling approach

In order to assess the benefits of additional UHF spectrum for mobile use, this study models the mobile network cost savings that could be realised by MNOs. This is done by comparing forward-looking projections of mobile network costs that would be incurred with and without additional UHF spectrum. The network cost savings model builds a bottom-up estimate of total mobile network (downlink) traffic and distributes that traffic across the sites in the mobile network. It then provisions sufficient capacity to serve this traffic at the lowest possible cost. The cost will, in general, be lower where MNOs have access to additional UHF spectrum. This is because additional spectrum allows for greater capacity per existing site and fewer (expensive) new site build requirements.

There are disparities in current spectrum holdings, market shares and number of sites between existing MNOs in the UK market. The model therefore calculates the value of additional spectrum separately for each MNO taking account of these disparities. The model assesses the incremental value of different spectrum bandwidths (2x5MHz, 2x10MHz, 2x15MHz, 2x20MHz) in different bands (600MHz and 500MHz) over different time periods. The choice of scenarios to model, which is described further in Section 7.3, is guided by the six overriding spectrum-release scenarios on UHF spectrum release provided to us by DCMS and DSIT. These scenarios are summarised in Figure 3.2.

Additional UHF spectrum is modelled as comprising 600MHz band and 500MHz FDD bands. There is an existing level of harmonisation for the 600MHz band (band n71), whilst an ecosystem is assumed to gradually develop in the 500MHz band between 2035 and 2045.^{[footnote 23]}

The overall flow of the model is illustrated in Figure 7.1 overleaf.

Figure 7.1: Flow chart of the network cost savings calculation (Source: Analysys Mason, 2026)

The model is scenario based and calculates the net present value (NPV) of future network costs for each scenario, for one operator at a time. A total of 576 scenarios per operator are identified, for which the model is run. These scenarios are a combination of spectrum, traffic and additional benefits scenarios.

• For the spectrum scenarios, there are a total of 96 options based on the potential amounts of spectrum available in the UHF bands in question (500MHz, 600MHz), bandwidth (0MHz, 2x5MHz, 2x10MHz, 2x15MHz, 2x20MHz) and the timing of release (2035, 2045).

• There are three traffic scenarios (low, base and high).

• There are two additional benefits scenarios, which relate to improvements in mobile network performance that result from additional UHF spectrum and are discussed in detail in Section 7.2.2. Note that these quantified additional benefits are distinct from the wider economic benefits discussed in Section 8.

The model considers each scenario individually and is run separately for each of the three MNOs (BTEE, VMO2, VF3), totalling 1728 model runs. The output generated from the model is the NPV of network costs in the 2035–2054 period, expressed in 2026 real terms. In order to find the cost savings in any scenario for an operator, we compare the NPV of that scenario with the NPV of the corresponding ‘no-spectrum release’ scenario.

We then combine the outputs of individual operator cost-savings to find the highest value combination for the three operators for each of the overriding spectrum-release scenarios (1a, 1b, 2a, 2b, 3a and 3b, as set out in Figure 3.2). This maximised sum of the cost savings for BTEE, VMO2 and VF3 therefore provides an estimate for the total benefits that can be achieved in each spectrum-release scenario. This process is illustrated in Figure 7.2 below.

Figure 7.2: Illustration of the process by which the benefits are estimated for each spectrum-release scenario (Source: Analysys Mason, 2026)

7.2 Assumptions

As explained in the previous section, the model uses a network cost savings approach to quantify the benefits of different scenarios of spectrum release. However, there are likely to be additional benefits of new UHF spectrum for mobile allocation, beyond the network cost savings, and these may be significant. Therefore, we consider the following types of benefits in the model:

• Network cost savings: as the traffic demand grows, MNOs would need to add capacity to their networks to meet this demand. This could be done by building more sites. The release of UHF spectrum would allow MNOs to deploy additional capacity on existing sites to (partly) mitigate this new site build requirement. The cost savings achieved are calculated by comparing the future network costs incurred by MNOs with and without the additional spectrum.

• Additional benefits: additional benefits arise from improvements in network performance (over and above additional capacity, which the network cost model assesses the costs of replicating) resulting from the new UHF spectrum. To assess these additional benefits, an ‘adjusted technical value’ approach is used, which we previously used in work for Ofcom on the cost–benefit analysis of 700MHz clearance.^{[footnote 24]} This approach calculates the additional network costs that operators would incur if they sought to provide the same quality of service that a new UHF spectrum assignment would enable, but without access to the new spectrum (i.e. using increased network density instead). These additional benefits may or may not be fully monetizable by MNOs. If they are not, then the MNOs may not choose to incur (all) of the additional costs of improving network performance without the additional UHF spectrum, but this would still lead to a foregone benefit for consumers.

7.2.1 Network cost savings

There are a number of key inputs to the model, which include:

• traffic forecasts and busy-hour assumptions
• capacity assumptions (including spectral efficiency, site volumes, spectrum holdings and device availability)
• unit costs (capex and opex) of equipment and civil works
• discounting assumptions for the NPV calculation.

These key inputs to the model are discussed in turn below.

Traffic forecasts and busy-hour assumptions

Traffic in the model is built up as the product of forecasts of subscriber volumes and forecasts of data traffic generated per subscriber over the modelled period.

Mobile penetration in the UK is expected to remain roughly flat in the coming years as it is a mature and saturated market. The mobile penetration in the UK in 2024 was 127%, which is forecast to remain constant for the modelled period. The number of subscribers is expected to increase in line with the population, representing a compound annual growth rate (CAGR) of 0.3% from 2025 to 2054.

In 2025, the subscriber market shares of each MNO were 25% (BTEE), 37% (VMO2) and 38% (VF3). For the purpose of this model, these market shares are assumed to remain constant throughout the modelling period. This, in effect, assumes a stable market structure with competition dynamics that do not change over time. We note that actual market outcomes may well deviate from this assumption, especially over such a long modelling horizon. For example, due to the recent merger and resulting behavioural remedies having a net positive or net negative effect on the intensity of competition. However, we consider that no change in competition dynamics is the most reasonable modelling assumption to make in relation to modelling expected network cost savings. This is because the nature of any change in competition dynamics is not known (intensity could increase or decrease, and any change could manifest itself in different ways) and we would expect any such deviations to have only a second-order effect on the network cost-savings calculation that we have modelled.^{[footnote 25]}

The projected subscriber volumes by operator are shown in Figure 7.3.

Figure 7.3: Total mobile subscribers in the UK, by operator (Source: Analysys Mason, 2026)

Forecasts of data traffic per subscriber are a key driver of the model. However, growth in data traffic per subscriber is a challenging metric to predict for a period of 30 years as it is dependent on a number of supply- and demand-side changes that will happen in the future.

Three scenarios have therefore been developed, taking historical traffic growth into consideration and applying three different growth rate trajectories. The traffic per subscriber for each of the UK MNOs is assumed to be at UK market-average levels (since data on a per-operator level is not publicly available). Data traffic per subscriber grew at an average rate of 20% per annum from 2021 to 2025. However, 2024 had a significantly lower growth rate of 9% as compared to earlier years and growth in 2025 has been similar. Therefore, data traffic per subscriber is expected to continue to grow in our base case, albeit at a lower rate than in the years prior to 2024.

Growth in data traffic volumes is challenging to predict for a period of 30 years. Data traffic growth is dependent on user behaviour as well as on future technological updates. Data traffic growth has slowed in the UK and in European markets in recent years.

To reflect uncertainty over future data traffic growth, the model considers three traffic scenarios for the period 2025–2054. These are defined in the list below, and shown in Figure 7.4:

• base-case traffic scenario: representing a CAGR of +8% in 2025–2054
• low-case traffic scenario: representing a CAGR of +4% in 2025–2054
• high-case traffic scenario: representing a CAGR of +12% in 2025–2054.

Figure 7.4: Monthly data traffic per subscriber forecast in the UK^{[footnote 26]} (Source: Analysys Mason, 2026)

Our assumption of constant market share from 2024, combined with our assumption of equal traffic per subscriber for each MNO, means that the traffic share of each MNO will remain constant at 2024 market share levels. New data usage applications such as smart homes, generative AI (GenAI) and other AI use cases, or the launch of 6G could increase data traffic in the coming years.

Total data traffic (reflecting both growth in traffic per subscriber and changes in the size of the subscriber base) is expected to grow at a CAGR of 9% in 2025–2054 in the base case, 4% in the low case and 13% in the high case (see Figure 7.5). This is mostly driven by growth in traffic per subscriber, with a relatively small change arising from the modest projected increase in subscriber volumes. The high case estimates the data traffic assuming that the new applications will drive data usage.

Figure 7.5: Total data traffic forecast in the UK^{[footnote 27]} (Source: Analysys Mason, 2026)

We assume that 90% of traffic is downlink and 8% of traffic will occur in the busy hour of each day, which is relevant for dimensioning the modelled networks. We consider it unlikely that there will be a significant rise from this 8% busy-hour traffic level, while in the extreme it is possible that this busy-hour traffic proportion may fall slightly.

Based on our experience of modelling mobile access networks, we assume that 20% of the total traffic is expected to arise in hard-to-reach (HTR) locations, including cell edge and deep indoor locations. Our model assumes this HTR traffic can only be served by low-frequency spectrum, which for the purposes of this modelling, consists of UHF and 1400MHz spectrum.^{[footnote 28]}

Capacity assumptions

Capacity per site is driven by spectral efficiency assumptions, the number of sites and sectors per site and the quantity of spectrum available. We consider each of these in turn below.

Spectral efficiency: a 4G base spectral efficiency of 1.5bit/s/Hz is assumed. This is an average across a typical cell area for a representative distribution of users across that cell area. Relevant multipliers are applied to estimate the spectral efficiencies for other technologies and upgrades. A 5G uplift of 10% applies. For MIMO 4x4 upgrades, a multiplier of 35% is used for low bands and 55% is assumed for high bands in 2024 (this varies between 40% and 60% in the 2022–2027 period). These multipliers are applied to the base spectral efficiency of the respective technology (4G or 5G). 5G massive MIMO 32x32 upgrades assume a multiplier of 350% and 5G massive MIMO 64x64 upgrades assume a multiplier of 400%, which are applied to the 5G base spectral efficiency. A maximum carrier utilisation threshold of 70% is applied. Figure 7.6 below shows the resultant spectral efficiencies assumed in the model.

Figure 7.6: Spectral efficiency assumptions (Source: Analysys Mason, 2026)

Band	Spectral efficiency (bits per second per Hz per sector) in 2024
4G base spectral efficiency	1.50
5G base spectral efficiency	1.65
4G MIMO (4x4) upgrade (low bands)	2.03
4G MIMO (4x4) upgrade (high bands)	2.10
5G MIMO (4x4) upgrade (low bands)	2.23
5G MIMO (4x4) upgrade (high bands)	2.31
5G mMIMO (32x32) upgrade	5.78
5G mMIMO (64x64) upgrade	6.60

Number of sectors per site: all sites are assumed to be tri-sectored. A sector non-homogeneity factor of 50% is assumed.

Quantity of spectrum available: the quantity of spectrum currently assigned to each MNO is discussed in Section 5.2 and summarised in Figure 7.7 below. We do not include mmWave spectrum (the 26 GHz and 40 GHz bands) in the model since we perceive the use case to be different to that for other licensed mobile spectrum bands.

Figure 7.7: Spectrum holdings of UK operators in 2024 (Source: Analysys Mason, 2026)

Spectrum band	BTEE	VMO2	VF3
500MHz FDD	–	–	–
600MHz FDD	–	–	–
700MHz FDD	2x10MHz	2x10MHz	2x10MHz
700MHz SDL	20MHz	–	–
800MHz FDD	2x5MHz	2x10MHz	2x15MHz
900MHz FDD[footnote 29]	–	2x15MHz	2x15MHz
1400MHz SDL	–	20MHz	20MHz
1800MHz FDD	2x45MHz	2x5MHz	2x20MHz
2100MHz FDD	2x20MHz	2x20MHz	2x20MHz
2300MHz TDD	–	40MHz	–
2600MHz FDD	2x50MHz	–	2x20MHz
2600MHz TDD	–	45MHz	–
3500MHz TDD	80MHz	100MHz	210MHz

We assume 100% device penetration by 2035 for 700MHz, 800MHz, 900MHz, 1400MHz, 1800MHz, 2100MHz, 2300MHz, 2600MHz and 3500MHz. The 700MHz SDL spectrum does not currently have any compatible devices. However, assuming that an ecosystem does develop in the coming years, we model an expected penetration of 10% in 2030, increasing to 100% in 2039. For 600MHz, the device penetration is expected to start in 2025 and reach 100% in 2035, rising in a linear manner. Similarly, we model the device penetration of 500MHz to start in 2036 and increase linearly to 100% in 2045.

Whilst an ecosystem in 600MHz is highly likely to develop in a manner similar to our forecasts, the outlook for 500MHz is far less certain. The prerequisites for the development of a 500MHz ecosystem include a WRC decision on primary or co-primary allocation, 3GPP standardisation, and devices to be developed by major manufacturers, which in turn relies on overcoming physical constraints like the required antenna size. For an ecosystem to have started to develop by 2035 a WRC-31 primary or co-primary allocation decision (ideally within Region 1, but similar decisions in Regions 2 or 3 are also relevant) may be required. We consider our assumption on the timeline for development of a 500MHz ecosystem to be reasonable. However, we acknowledge that there is more downside risk than upside risk associated with this assumption. In particular, a delay in the development of a 500MHz ecosystem could reduce the benefits associated with a 2035 release (relative to a 2045 release), although this is mitigated by a low proportion of the value arising in the first few years. If, however, a 500MHz ecosystem failed to develop at all, then there would be no value for mobile spectrum in this band. This appears an unlikely but possible scenario.

Unit costs of equipment

We assume unit costs for the sites and for all the equipment required for deployment of a particular band. These costs are assumed to be the same for all three operators.

Figure 7.8: Unit costs of equipment, 2025 real terms (Source: Analysys Mason, 2026)

Asset	Unit cost: capex (GBP/site)	Unit cost: annual opex (GBP/site)
Site	120 000	18 000
500MHz FDD	20 000	1000
600MHz FDD	20 000	1000
700MHz FDD	20 000	1000
700MHz SDL	20 000	1000
800MHz FDD	20 000	1000
900MHz FDD	20 000	1000
1400MHz SDL	20 000	1000
1800MHz FDD	15 000	750
2100MHz FDD	15 000	750
2300MHz TDD	15 000	750
2600MHz FDD	15 000	750
2600MHz TDD	15 000	750
3400MHz TDD	50 000	2500

We assume the unit costs for capex remain flat in nominal terms. The unit costs for opex are expected to remain flat in real terms, with annual inflation of 2% assumed until 2054.

Discounting for the NPV calculation

The model calculates NPV of network costs for 2035–2054, expressed in 2026 real terms, using a discounting multiplier. We calculate this discounting multiplier using a weighted average cost of capital (WACC) of 7.2%. This is taken from the mid-point of the range of 6.6% to 7.8% for pre-tax nominal WACC applied by Ofcom in its Annual Licence Fee (ALF) decision for mobile spectrum of July 2025.^{[footnote 30]} The model calculates valuation for a 20-year period, starting from 2035.

7.2.2 Additional benefits

In this sub-section, we consider additional benefits of improved performance in mobile networks, beyond network cost savings. These quantified benefits remain distinct from the wider economic benefits discussed in Section 8. Some of these benefits may be commercially attractive for MNOs. When MNOs value spectrum (for example to prepare for an auction), they would generally consider a commercial value of the spectrum in addition to the technical value (network cost savings). This commercial value reflects the increased attractiveness of the MNO’s service to consumers, resulting from the improved network performance. It could manifest as reduction in churn rates, increase in share of gross adds or increase in average revenue per user (ARPU).

Commercial value is difficult to calculate accurately as it requires assumptions about relative future network performance and consumer behaviour. Assumptions about relative future network performance also depends on the network performance of competitors. Approaches from different MNOs to calculating commercial value vary widely. Moreover, from an outside-in perspective, with no access to MNOs’ customer-related data, the task of calculating commercial value is even more challenging.

As a result, when previously undertaking analysis of the benefits of the 700MHz clearance for Ofcom (as described in Section 7.1), Analysys Mason relied upon a different approach. Although we undertook a high-level commercial value estimate, our analysis focused on an ‘adjusted technical value’ approach. We replicate this adjusted technical value approach here to estimate the additional benefits of UHF spectrum in the current context.

Adjusted technical value approach

Our approach is to run the network cost model with changed inputs. We estimate the incremental network costs that operators would incur in order to deliver an equivalent quality of service to that enabled by additional UHF spectrum, but without access to this spectrum. To simulate this effect, our modelling approach is to reduce the maximum loading of a site to 88% of the maximum capacity that it could otherwise provide. This results in the model calculating an increased network densification as an alternative route to improving the network performance in a similar way. We can assume that the cost of this additional densification is equal to the incremental network costs that operators would incur to achieve the same network performance without access to UHF spectrum.

The 88% value was derived in our work for Ofcom in the context of changing use of the 700MHz band from DTT to mobile. At that time, we undertook simulations using Ofcom’s mobile coverage checker data, to estimate the signal-to-interference-plus-noise ratio (SINR) as a function of distance from a site and site loading. We then determined the change in network loading required to achieve the same performance (measured in terms of user throughput) as a network with 700MHz spectrum available. We found that a network loading reduction of ~12% was required in a denser network without the additional spectrum. This replicates the distribution of user throughputs that would have been possible in a correspondingly less-dense network with additional spectrum.^{[footnote 31]}

Within the model, this reduction in effective carrier capacity is reflected by applying a reduction in spectral efficiency, which serves as a proxy for carrier capacity. The difference in network costs between scenarios with access to additional UHF spectrum and the scenario without UHF spectrum, where effective cell capacity is reduced, constitutes the adjusted technical value. This value represents the cost savings achieved by an operator through the use of additional UHF spectrum to serve a given population at a specified throughput level, rather than expanding the network to deliver equivalent performance.

The 88% loading assumption was derived in the context of Ofcom’s 700MHz clearance studies. Replicating the calculation for additional UHF spectrum may be something that Ofcom chooses to do at a later date, when auction preparations are underway. However, we would expect the value for the 600MHz (and 500MHz) band to be somewhat similar to the value previously calculated for 700MHz. We report results with and without this loading reduction assumption in Section 7.4, and note that it only accounts for a small proportion of the overall benefits that we calculate.

Replicating the quality of service enabled by the 500MHz and 600MHz bands is expected to represent a plausible upper bound on the incremental benefits to operators arising from improvements in performance. In the absence of the spectrum, it is unlikely that operators would commercially choose to replicate this level of quality of service, as doing so would not be expected to be profitable. However, this estimate may not represent an upper bound on consumer benefits. Consumers may be willing to pay more for these improvements than operators are able to monetise.^{[footnote 32]}

7.3 Summary of modelling scenarios

As explained in earlier sections, the model tests different scenarios for each mobile operator. These scenarios are a combination of spectrum scenarios, traffic scenarios and additional benefit scenarios per modelled operator. Each of these are explained below:

• Spectrum scenarios: these specify the band, bandwidth and timing of spectrum acquisition by the MNO.

• Traffic scenarios: we model three cases (base, low and high).

• Additional benefits scenarios: we model two alternatives, one with additional benefits (12% loading reduction assumption) and one without additional benefits.

7.3.1 Spectrum scenarios

The spectrum scenarios are identified based on the six overriding release scenarios (1a, 1b, 2a, 2b, 3a, 3b), as set out in Figure 3.2.

• Band: 500MHz and 600MHz. Individual spectrum scenarios can include spectrum in either or both of these spectrum bands.
• Bandwidth: for the bandwidth per operator, we consider the following options within each band:
• 0MHz
• 2x5MHz
• 2x10MHz
• 2x15MHz

• 2x20MHz (note that 2x20MHz is the largest bandwidth we assume although the 500MHz band potentially offers sufficient bandwidth that one operator could obtain more than 2x20MHz).

• Timing: the overriding spectrum-release scenarios (1a–3b) specify two options, which are 2035 and 2045. Part of the bandwidth of either band can be released at either release date within any individual scenario.

The overall bandwidth considered for release, combined for the three operators, is 2x60MHz for 500MHz and 2x35MHz for 600MHz. In case of a partial spectrum band release in 2035 and 2045, the maximum spectrum assignment to an individual MNO (in combination across the two release dates) for each band does not exceed 2x20MHz. Using these bounds, a total of 96 spectrum scenarios are possible as shown in Figure 7.9.^{[footnote 33]}

Figure 7.9: Spectrum scenarios used in the model (Source: Analysys Mason, 2026)

	First release: 2035		Second release: 2045
Scenario no.	600MHz	500MHz	600MHz	500MHz
1	–	–	–	–
2	–	–	–	–
3	2x5MHz	–	–	–
4	2x10MHz	–	–	–
5	2x15MHz	–	–	–
6	2x20MHz	–	–	–
7	–	–	–	2x5MHz
8	2x5MHz	–	–	2x5MHz
9	2x10MHz	–	–	2x5MHz
10	2x15MHz	–	–	2x5MHz
11	2x20MHz	–	–	2x5MHz
12	–	–	–	2x10MHz
13	2x5MHz	–	–	2x10MHz
14	2x10MHz	–	–	2x10MHz
15	2x15MHz	–	–	2x10MHz
16	2x20MHz	–	–	2x10MHz
17	–	–	–	2x15MHz
18	2x5MHz	–	–	2x15MHz
19	2x10MHz	–	–	2x15MHz
20	2x15MHz	–	–	2x15MHz
21	2x20MHz	–	–	2x15MHz
22	–	–	–	2x20MHz
23	2x5MHz	–	–	2x20MHz
24	2x10MHz	–	–	2x20MHz
25	2x15MHz	–	–	2x20MHz
26	2x20MHz	–	–	2x20MHz
27	–	2x5MHz	–	–
28	2x5MHz	2x5MHz	–	–
29	2x10MHz	2x5MHz	–	–
30	2x15MHz	2x5MHz	–	–
31	2x20MHz	2x5MHz	–	–
32	–	2x5MHz	–	2x5MHz
33	2x5MHz	2x5MHz	–	2x5MHz
34	2x10MHz	2x5MHz	–	2x5MHz
35	2x15MHz	2x5MHz	–	2x5MHz
36	2x20MHz	2x5MHz	–	2x5MHz
37	–	2x5MHz	–	2x10MHz
38	2x5MHz	2x5MHz	–	2x10MHz
39	2x10MHz	2x5MHz	–	2x10MHz
40	2x15MHz	2x5MHz	–	2x10MHz
41	2x20MHz	2x5MHz	–	2x10MHz
42	–	2x5MHz	–	2x15MHz
43	2x5MHz	2x5MHz	–	2x15MHz
44	2x10MHz	2x5MHz	–	2x15MHz
45	2x15MHz	2x5MHz	–	2x15MHz
46	2x20MHz	2x5MHz	–	2x15MHz
47	–	2x10MHz	–	–
48	2x5MHz	2x10MHz	–	–
49	2x10MHz	2x10MHz	–	–
50	2x15MHz	2x10MHz	–	–
51	2x20MHz	2x10MHz	–	–
52	–	2x10MHz	–	2x5MHz
53	2x5MHz	2x10MHz	–	2x5MHz
54	2x10MHz	2x10MHz	–	2x5MHz
55	2x15MHz	2x10MHz	–	2x5MHz
56	2x20MHz	2x10MHz	–	2x5MHz
57	–	2x10MHz	–	2x10MHz
58	2x5MHz	2x10MHz	–	2x10MHz
59	2x10MHz	2x10MHz	–	2x10MHz
60	2x15MHz	2x10MHz	–	2x10MHz
61	2x20MHz	2x10MHz	–	2x10MHz
62	–	2x15MHz	–	–
63	2x5MHz	2x15MHz	–	–
64	2x10MHz	2x15MHz	–	–
65	2x15MHz	2x15MHz	–	–
66	2x20MHz	2x15MHz	–	–
67	–	2x15MHz	–	2x5MHz
68	2x5MHz	2x15MHz	–	2x5MHz
69	2x10MHz	2x15MHz	–	2x5MHz
70	2x15MHz	2x15MHz	–	2x5MHz
71	2x20MHz	2x15MHz	–	2x5MHz
72	–	2x20MHz	–	–
73	2x5MHz	2x20MHz	–	–
74	2x10MHz	2x20MHz	–	–
75	2x15MHz	2x20MHz	–	–
76	2x20MHz	2x20MHz	–	–
77	–	–	2x5MHz	–
78	–	–	2x10MHz	–
79	–	–	2x15MHz	–
80	–	–	2x20MHz	–
81	–	–	2x5MHz	2x5MHz
82	–	–	2x10MHz	2x5MHz
83	–	–	2x15MHz	2x5MHz
84	–	–	2x20MHz	2x5MHz
85	–	–	2x5MHz	2x10MHz
86	–	–	2x10MHz	2x10MHz
87	–	–	2x15MHz	2x10MHz
88	–	–	2x20MHz	2x10MHz
89	–	–	2x5MHz	2x15MHz
90	–	–	2x10MHz	2x15MHz
91	–	–	2x15MHz	2x15MHz
92	–	–	2x20MHz	2x15MHz
93	–	–	2x5MHz	2x20MHz
94	–	–	2x10MHz	2x20MHz
95	–	–	2x15MHz	2x20MHz
96	–	–	2x20MHz	2x20MHz

7.3.2 Traffic scenarios

We model three traffic scenarios:

• base-case traffic scenario: representing a CAGR of +8% in 2025–2054
• low-case traffic scenario: representing a CAGR of +4% in 2025–2054
• high-case traffic scenario: representing a CAGR of +12% in 2025–2054.

7.3.3 Additional benefits scenarios

We model two additional benefits scenarios:

• with additional benefits
• without additional benefits.

Overall, using 96 spectrum scenarios, 3 traffic scenarios and 2 additional benefits scenarios, there are 576 scenarios per operator. Running the model under the assumed spectrum, site and market share assumptions for each of the three operators, we end up with a total of 1728 model iterations.

We focus our reporting of results (in Section 7.4) on the four combinations of traffic and benefits scenarios, listed in Figure 7.10, that consider most relevant. This results in 1152 model iterations.

Figure 7.10: Traffic and benefits scenarios combinations used for sensitivity analysis (Source: Analysys Mason, 2026)

	Traffic scenario	Additional benefits scenario
Main case	Base	With
Sensitivity case 1	Base	Without
Sensitivity case 2	Low	With
Sensitivity case 3	High	With

7.4 Analysis and results

The analysis of the model outputs is a two-step process:

• network cost savings of individual operators, and the respective sensitivity analysis
• highest network cost-saving combinations of spectrum acquisition by the three operators, for each of the six overriding spectrum release scenarios, and the respective sensitivity analysis.

Within each scenario, the model calculates the costs of new sites, upgrades and carriers in each of the 20 modelled years from 2035 to 2054 and uses this information to calculate the NPV of network costs. The NPV of costs in each scenario is subtracted from the NPV in the scenario in which there is no allocation of these spectrum bands to mobile broadband. The difference in the NPV between these two cases provides an estimate of the network cost savings of the assignment of additional UHF spectrum to the operator.

The second part of the analysis is to find the highest network cost-saving combinations of spectrum acquisition by the three operators. As the model is run for one operator at a time, it provides the network cost savings for different scenarios for each operator. These individual scenarios are then combined to form the overriding spectrum-release scenarios (1a–3b), resulting in multiple potential combinations of the operator scenarios with different network cost savings. The highest network cost-saving combination is selected for each spectrum-release scenario. This exercise is undertaken for each of the different traffic and additional benefits scenarios.

Each of these steps is discussed in more detail in the sub-sections below.

7.4.1 Highest network cost-saving combinations of spectrum acquisition

We combine the network cost savings of individual operators for different scenarios to estimate total cost savings in the overriding spectrum-release scenarios (1a–3b). The combinations are governed by a number of factors:

• spectrum band, bandwidth and timings of release based on the spectrum-release scenarios 1a–3b
• assumptions on spectrum availability: overall 500MHz spectrum availability is assumed to be 2x60MHz and overall 600MHz spectrum availability is assumed to be 2x35MHz
• different traffic scenarios
• inclusion or exclusion of additional benefits.

Given these considerations, we analyse the values of all possible combinations of spectrum packages across the three MNOs. The combination with the greatest aggregate value is selected and defines the total benefits of that spectrum-release scenario (for a given traffic and additional benefits scenario combination).

Figure 7.11 provides the highest network cost-saving combination for each of the six overriding spectrum-release scenarios in our main case.

Figure 7.11: Highest network cost-saving combinations of spectrum acquisition by the three MNOs: main case (Source: Analysys Mason, 2026)

The total benefits from additional UHF spectrum for mobile use ranges between GBP2.1 billion (Scenario 1b and 3b) and GBP3.6 billion (Scenario 3a). Comparison of the spectrum-release scenarios can also be informative. For example, comparison of the network cost savings between Scenario 1a and 1b shows that the incremental benefit of releasing 500MHz in 2045 (over and above releasing 600MHz in 2035) is ~GBP1.1 billion (relative to GBP2.1 billion for release of the 600MHz in 2035). Scenario 3a, which involves releasing the entirety of both the 600MHz and 500MHz bands in 2035 has (unsurprisingly) the greatest overall benefit. The lowest benefit arises in Scenario 3b, which is the only scenario in which no additional UHF spectrum is released before 2045.

7.4.2 Sensitivity analysis of highest network cost-saving combinations of spectrum acquisition by the three operators

Base-case traffic without additional benefits

Removing the additional performance benefits reduces the total benefits estimate by ~14% on average relative to the main case.

Figure 7.12: Highest network cost-saving combinations of spectrum acquisition by the three MNOs: base-case traffic without additional benefits (Source: Analysys Mason, 2026)

Low-case traffic with additional benefits

The overall benefits are significantly reduced under a low-traffic scenario. The highest network saving combinations under this scenario are shown in Figure 7.13 overleaf.

Figure 7.13: Highest network cost-saving combinations of spectrum acquisition by the three MNOs: low-case traffic with additional benefits (Source: Analysys Mason, 2026)

High-case traffic with additional benefits

Conversely, the total benefits are significantly higher if traffic growth accelerates. Some of the spectrum-release scenario relativities in the high case (with additional benefits) differ compared to those in the main case. For example, total benefits in Scenario 3b are now materially lower than in Scenario 1b, since high traffic growth heightens the importance of earlier access to additional UHF spectrum. Scenario 3a, on the other hand, now offers relatively higher benefits as the value of bringing forward all spectrum release to 2035 increases.

Figure 7.14: Highest network cost-saving combinations of spectrum acquisition by the three MNOs: high-case traffic with additional benefits (Source: Analysys Mason, 2026)

8 Considerations relating to the value of spectrum to the economy

The focus of this section is an estimation of the potential benefits to the economy from deploying released spectrum in the 600MHz and 500MHz bands for the various use cases identified. The counterfactual is that no additional UHF spectrum would be forthcoming for these uses.

As we discuss below, many studies published by interested stakeholders seek to identify the overall benefits from spectrum use in a particular application. However, this is often expressed as a total economic value from the entire activity. The implicit counterfactual is, therefore, that no spectrum would be available and the application cannot continue. Whilst this may result in dramatically large benefits, it is not the relevant question here. Rather, the relevant considerations are:

• for mobile use, the incremental benefit that might result from making additional UHF spectrum available to be used alongside existing 700MHz, 800MHz and 900MHz bands
• for PMSE, the loss that might occur if access to UHF were curtailed and alternatives solutions needed to be found
• for smart grid, the costs of achieving similar functionality without access to the released UHF spectrum (and so which costs could be avoided if spectrum were made available).

Benefits from additional spectrum will typically increase as more spectrum is made available to applications. This relationship may be complex. Enough spectrum may be needed to make it worthwhile deploying services within a new band. Certain functionality may also require some minimum amount of spectrum (e.g. higher-bandwidth smart grid). However, whilst benefits may increase as available spectrum increases, there will typically be diminishing returns beyond some point.

There is a high degree of uncertainty about estimates of the economic value of spectrum, especially when considering external social benefits. This is not always explicitly recognised by published studies, and results need to be interpreted with caution. We take the approach of breaking benefits into categories according to how speculative they are. We can then establish a reasonable lower bound on benefits without the inclusion of highly speculative benefits.

8.1 Mobile services

8.1.1 Relevant published studies

Research into the current and future use cases of the UHF spectrum often notes two trends:

• demand for low-band spectrum is growing rapidly in the mobile industry, as data requirements from customers accelerate; and
• TV audience viewing behaviour is shifting away from linear services to streaming services.

In the UK, the DTT network is well established and has facilitated the introduction of a large number of free-to-air public and commercial TV services over the last two to three decades, and in some cases pay-DTT. Ofcom states that as of 2023, 11.7% of UK households are DTT-only viewers.^{[footnote 34]} Similarly, the University of Exeter estimate that there are 3.9 million homes (13.2% of TV homes) which solely rely on broadcast TV and predict that this number will fall to 1.5 million (5.2%) by 2040.^{[footnote 35]} Both studies note that these households tend to be older, from a lower socio-economic group or have a disability.

Universal access to public service broadcasting is a socially beneficial policy, and one that DTT transmission has long served. This distribution method has historically been low cost at point of use and available across the UK population. However, viewership of VOD services such as Netflix, Disney+ and Amazon Prime, and video-sharing platforms (VSPs) such as YouTube, has grown rapidly over the last decade.^{[footnote 36]} It is predicted that by 2040 linear viewing will have declined to just over a quarter of TV viewing time and VOD will represent a clear majority. These services are not direct substitutes for linear broadcast TV as viewers still find value in news and live cultural events (such as sports). Nevertheless, linear services have seen a deep decline in viewership, particularly among younger audiences.^{[footnote 37]}

These changes in viewer behaviour away from linear broadcast content entail less viewing of DTT-delivered content. There is both switching of viewing time to commercial VOD and VSP services away from linear broadcast and consumption of PSB content through IP delivery. A study predicts that by 2040, a “significant majority of homes will solely use IP-delivered services to watch TV” and “hybrid homes (mainly a combination of DTT and IP delivery) will represent just over a quarter of TV homes”.^{[footnote 38]} In Belgium (Flanders)^{[footnote 39]} and Switzerland,^{[footnote 40]} where the main PSB distribution technology has historically been cable, public broadcasters have halted DTT services due to low use and switching to IPTV.

Germany and Italy are switching or have switched over their whole terrestrial TV network to DVB-T2. This is a more spectrally efficient technology and delivers an almost 50% increase in capacity per MHz compared to DVB-T, which is currently used for most DTT multiplexes in the UK.^{[footnote 41]} The transition from DVB-T to DVB-T2 requires significant network upgrades, substantial costs for broadcasters and potential costs for viewers who need compatible receivers. The EC has previously predicted that the cost of replacing receivers in the UK would be GBP50 million.^{[footnote 42]}

It is possible that some form of converged mobile and TV broadcasting service, often called 5G Broadcast, might replace DTT in the long term. The technology is in the early stages of development and the commercial case for such a deployment in the UK is not clear. A significant number of trials and testbeds have taken place in Europe.^{[footnote 43]}

There are many potential social and economic benefits derived from assigning UHF spectrum to mobile.

First, the rural–urban digital divide has long been an issue in the UK. The cost of providing rural customers with high-quality connections often exceeds the benefit that operators receive due to low population density. The external benefits to customers and society from providing these connections can be significant, therefore it is generally accepted that work should be done to reduce the divide.

Sub-1GHz spectrum is much more effective in serving less densely populated rural areas than other bands. The potential of sub-1GHz to bridge the gap in the quality of mobile services between rural and urban locations is therefore a key argument made by those seeking a mobile allocation in the UHF

Building Digital UK (BDUK) undertook a survey and interviews to understand rural residents’ experiences with mobile coverage and views on how things could be improved.^{[footnote 44]} They found the following major themes:

• There is scope for growth in productivity, reducing time lost for commuters and delivery drivers, improved technology and increased competitiveness if rural areas see an improvement in mobile coverage.

• The agricultural and forestry sectors would benefit from improved work safety and satisfaction if there was better coverage. Other professions may see benefits in the form of an improved experience when working from home and improved messaging capabilities.

• Respondents were keen to note that the digital divide leaves them feeling left behind and improved mobile coverage would greatly impact their quality of life. Consumers believe they would make savings by, for example, not needing to pay for a landline at home and reducing their travel times by completing tasks online instead of in person.

Another important factor in rural coverage is consumer choice. Good coverage is a key driver of consumer choice. Deloitte’s Digital Consumer Trends 2025^{[footnote 45]} report finds that coverage is the lead motivation for consumers who change their mobile network.

Second, relating to quality of life in later years, the social care industry is facing the pressure of an ageing population. It is hopeful that improved mobile connectivity could help deliver more efficient outcomes. Mobile UK promotes digitising the industry through using digital devices to help people with care needs to live independently for longer, reduce hospital admissions and facilitate better targeting of care.^{[footnote 46]} The Liverpool 5G Testbed Trial in 2019 found that remote monitoring to ensure medication is taken means a 60% reduction in hospital admissions.^{[footnote 47]}

Third, increased connectivity can aid productivity, especially in the agricultural sector. Growing demand for food, supply-side constraints and increasing pressure to reduce environmental impact mean that productivity gains must be made in the agriculture industry. Use cases such as crop monitoring, livestock monitoring, building and equipment management, drone farming and autonomous farming machinery have the potential to unlock significant benefits. Successful implementation of connectivity could add more than USD500 billion to the global gross domestic product by 2030, according to McKinsey.^{[footnote 48]}

Finally, the estimated value of assigning additional UHF spectrum to mobile is argued to be greatly positive. A cost–benefit analysis of the UHF spectrum finds that the private cost of assigning 80MHz of additional UHF spectrum to mobile would be 6 to 24 times greater than the costs incurred by the broadcasting sector to maintain existing DTT programmes. This indicates the potential benefits that could be realised if allocated to mobile.^{[footnote 49]}

The GSMA studied the benefits of allocating 2x35MHz or 2x40MHz in the 600MHz band to mobile use. They found that this would deliver a 30–50% improvement in mobile speeds where service is only available from low band spectrum. It would also reduce the costs of covering rural roads for 5G connected vehicles, improve digital equality and enable smart agriculture.^{[footnote 50]}

BT released a statement requesting the government double the amount of spectrum available for mobile services from 1.1GHz to 2.2GHz, comprising the 3.8 to 4.2GHz, upper 6GHz and 600MHz bands. It stated that by 2035, up to GBP230 billion in economic benefits could be unlocked if the UK can “improve its capacity to handle more mobile traffic in the busiest parts of the country (GBP124 billion); fix gaps in road and rail connectivity (GBP57 billion) and make its networks more resilient and reliable (GBP45 billion)”.^{[footnote 51]} The study does not describe its detailed methodology and we consider that it is unlikely that it has correctly identified the benefit specifically associated with using the released UHF spectrum, as distinct from more general economic contributions of the mobile sector. By way of comparison, the claimed total benefit of GBP230 billion is almost 8% of current annual UK GDP (about GBP3 trillion).^{[footnote 52]}

On transport networks, Vodafone^{[footnote 53]} states that standalone 5G could support technologies to reduce road traffic by 25%, which would save drivers in the UK 216 million hours per annum and GBP3 billion annually in fuel costs. If the technology can reduce train delay times by 10%, then it would add GBP1 billion per annum to the UK economy through commuters being able to work on the train, save 26 million hours per annum and save over GBP10 million across the rail industry in reduced compensation claims. We note that the scale of these benefits is roughly two order of magnitudes smaller than those claimed in the BT study above.

Network Rail announced ‘Project Reach’ in June 2025^{[footnote 54]} which will aim to end signal blackspots across rail lines and is expected to save taxpayers GBP300 million while boosting productivity for commuters. Neos Networks will install fibre cable along key rail lines and Freshwave will work with MNOs to eliminate blackspots in rail tunnels and upgrade wireless infrastructure at key railway stations.

In Australia, the 600MHz band is currently allocated to DTT. Free TV engaged with Competition Economists Group in 2021 to value the band as the government consulted on re-assigning the spectrum for alternative uses.^{[footnote 55]} They estimate the value of 84MHz of spectrum in the 600MHz band to be AUD1.15/MHz/pop in 2021 terms. This implies a total value of AUD2.42 billion that could potentially be realised from an auction. These estimates depend on the timing of the auction, as allocating the 600MHz band soon after the planned reallocation of the 850/900MHz band was estimated to result in a discount of 52% in the price paid in both auctions due to higher supply.

8.1.2 Sources of benefits, and who they accrue to

The benefit of additional spectrum for mobile services is primarily achieved through avoiding costs of network densification to provide additional capacity in rural areas, and for better indoor coverage. It may also trigger service quality improvements that would have otherwise required cell densification. These costs are avoided by access to additional spectrum.

These benefits relate primarily to ‘hard-to-serve’ traffic. Therefore, benefits may accrue disproportionately to rural users and to use cases that require largely ubiquitous connectivity (for example, transport and logistics applications).

The model presented in Section 7 provides estimates of these costs savings in the order of GBP2.1 billion to GBP3.6 billion within the main case, depending on the spectrum-release scenario. These cost savings would be split amongst:

• receipts for the state from spectrum auction revenue
• benefits to customers through lower prices and better service quality than would have been the case without the additional spectrum
• returns to shareholders.

Provided competition in downstream mobile markets is effective, returns to shareholders should be limited to the cost of capital and any excess profits would give way to normal profits due to high competition in the UK mobile market. On this assumption of effective competition in mobile service markets, the value that each operator faces on winning spectrum will be equal to its network cost saving.

8.1.3 Coverage obligations

Regulators can impose obligations, such as ones for coverage, as part of spectrum awards. This would be an option that Ofcom could pursue in any spectrum award. The auction price would be reduced by the expected cost of meeting the obligation. Therefore, in the absence of state subsidy there is a limit in the scale of obligations that can be imposed. Above this limit, operators would not be willing to purchase a spectrum licence.

Ofcom already has an agreement with the mobile operators to extend coverage to 89.2% of the UK’s landmass by 31 January 2027.^{[footnote 56]} As part of the Three-Vodafone merger conditions, the company is committed to investing GBP11 billion in 5G standalone rollout to 95% of the population by 2030 and 99% by 2034.^{[footnote 57]} It is unclear what the balance of costs and benefits might be for further intervention potentially a decade into the future. Any case for imposing further obligations would need to be considered closer to the award of any spectrum in the light of prevailing competitive conditions. There might be a case for further intervention if there were concerns about market failure, such as competition failing to deliver an optimal level of coverage, or if significant positive external benefits for coverage were not reflected in consumers’ willingness to pay for services.

We spoke to Ofcom about this possibility. It does not have any current plans for such measures to augment mobile coverage and said the question would need to be considered in the light of prevailing market conditions. Nevertheless, we note that if Ofcom subsequently assessed the situation and found reason to impose coverage obligations, this would increase economic welfare relative to the simple assessment above. Such an obligation would divert auction receipts to pay for the costs of delivering additional coverage. If intervention were warranted, then the benefits from additional coverage should exceed the costs of delivering it.

For this reason, we have not added any uplift to our estimates of the benefits of spectrum release to reflect the possibility of coverage interventions implemented through obligations in spectrum licences. However, the possibility exists if market outcomes justified such intervention, which would increase benefits.

8.1.4 Competition benefits

It is possible that award of further sub-1GHz spectrum could be used as a market-shaping tool by Ofcom to bring about a more symmetrical distribution of spectrum (and especially sub-1GHz spectrum) amongst the three UK mobile operators. This would be with the intention of sharpening competition in mobile services.

This is a complex issue and would be a contentious matter for design of any auction. It would likely involve some capping of spectrum portfolios held, and so by implication the amount of spectrum that different operators might acquire.

Whether such an intervention might be justified would need to be considered by Ofcom in light of competitive conditions in mobile service markets at the time of designing a spectrum award. Therefore, we cannot reach any firm views at present.

Spectrum portfolios affect competitive positions as they affect the marginal cost to operators of additional network capacity. If there is less spectrum, more sites are needed to achieve similar capacity. Therefore, there may be variation in the effective marginal costs facing operators if they win customers or grow traffic through offering new or improved services. Those with more spectrum can handle the additional traffic more cheaply at the margin. This does not mean that all operators need identical spectrum portfolios for competition to be effective, but it does mean that they should not be too asymmetric.

Clearly customer numbers also matter for capacity needs and associated costs of serving those customers. At present, market shares are roughly 25:37:38 to BTEE, VMO2 and VF3. Interestingly, these market shares are roughly in proportion to current sub-1GHz holdings (subject to the caveats about the definition of sub-1GHz for this purpose).

It is not the case that a precisely symmetric spectrum allocation is needed to allow effective competition in mobile services. However, a more symmetric distribution might lead to somewhat greater competitive intensity by giving operators more similar costs of adding traffic (and customers) at the margin. However, this is only likely to be a modest effect.

As a highly speculative example, suppose that market shares equalised. A common measure of concentration is the Herfindahl–Hirshman index or HHI (the sum of squares of market shares). Moving from current market shares to equal market shares would reduce the HHI from around 3420 to 3333, a reduction of 88 (allowing for rounding).

The HHI is commonly considered as a screening device in the control of mergers, though approaches differ across jurisdictions:

• US Department of Justice guidelines identify a market with an HHI in excess of 1800 to be highly concentrated, with a presumption that mergers increasing the HHI by more than 100 enhance market power.^{[footnote 58]}

• Under EU merger guidelines,^{[footnote 59]} a post-merger HHI above 2000 that increased the HHI by less than 150 is unlikely to raise concerns unless special circumstances apply (such as cross-shareholdings).

• Historically, the UK has taken a similar approach to the EU, though more recent guidance from the CMA has de-emphasised specific thresholds for HHI changes in favour of metrics considered on a case-by-case basis.

Therefore, an increase of 88 in HHI within a highly concentrated market would not trigger a presumption of enhancing market power under merger control. Equally, it is not immaterial relative to the typical screen thresholds used. Mobile markets would be considered highly concentrated by general antitrust standards.

As a regulator setting spectrum policy, Ofcom would not be enforcing competition law when making decisions about spectrum assignment, but rather working to its remit for efficient assignment and use of that spectrum to the benefit of end users. Therefore, changes in competition conditions that are material, but below the level of changes that would typically trigger presumptions of concerns in merger control, would still be a relevant consideration for design of an award process.

The scale of the mobile market and the importance of mobile services as inputs into nearly every other sector of the economy also mean that even small changes in prices or service quality have significant economic welfare effects. The current mobile services market is about GBP15 billion per annum. Therefore, a 1% impact on prices, even though small in relative terms, translates to a GBP150 million annual benefit to customers.

This scale of benefit is material, but equally an order of magnitude smaller than the direct benefits of spectrum to the mobile sector of GBP2.1 to 3.6 billion estimated above. Therefore, we do not apply any upgrade to estimated benefits given the uncertainties involved. Rather, we note that additional benefits from enhancement of competition in mobile services are possible.

8.1.5 External benefits

Because UHF spectrum release helps mobile networks deal with hard-to-serve traffic, there would likely be some external benefits to consumers. By definition, these are benefits that cannot be monetised by network operators.

Improvements in rural coverage, and the reliability of existing rural services, potentially bring benefits through improved public safety. These benefits are difficult to quantify and are unlikely to add significantly to our overall estimates of benefit given the uncertainties involved. Nevertheless, improved rural services may assist in meeting various societal goals, as discussed in the literature review below.

Rolling out services in additional bands may create some small improvement in the reliability of radio access networks. However, this is unlikely to be a significant benefit as much of the equipment at mobile sites would still be common to radio access networks in different bands. Therefore, failure risks would not be significantly reduced and additional benefits small. We do not agree with the BT study (discussed above) that finds large resilience benefits associated with additional UHF spectrum for mobile.

8.2 PMSE

8.2.1 Relevant published studies

There is a widespread expectation that PMSE use will grow over time due to an increasing number of large events. However, this is not necessarily to say that associated demand for spectrum will grow, as technology improvements are improving the efficiency of spectrum use. Some commentators predict that additional spectrum will be required for major future events, though this is dependent on sufficient growth of the industry.^{[footnote 60]}

PMSE industry groups such as the British Entertainment Industry Radio Group (BEIRG)^{[footnote 61]} and the Wireless Microphone Spectrum Alliance (WMSA)^{[footnote 62]} have expressed concerns for the industry if the UHF spectrum is assigned to mobile. Although PMSE has lost spectrum in the 700MHz and 800MHz bands over the last 12 years, there have been technological advances that have mitigated the impacts. The industry is nevertheless concerned that further losses would have a significant impact on large-scale events.

Coleago indicated that there is scope to share UHF spectrum between PSME and IMT. This was on the basis that the former is rarely used in rural areas, with the occasional predictable exception for festivals. Overlap in urban areas could be delimited temporally as it would not be the primary use case for mobile operators in the band.^{[footnote 63]}

PMSE industry groups strongly oppose the 600MHz band being assigned for mobile use. They argue the industry is growing and they expect spectrum demand to increase due to technology advances. As with mobile, there are economic benefits derived from PMSE use of UHF spectrum. For example, DSIT’s 2022 report on value of spectrum to the economy discusses the value created by the PMSE sector to the UK economy. In this report, the approach adopted is to assess the direct private economic contribution of sectors that use spectrum, as measured by their contribution to economic output (measured by their gross value add, or GVA). The report does not estimate the PMSE’s sector in terms of GVA but references an external study that estimates value of the UK events industries (e.g. in terms of direct spend for business-related events and attendance at large music events). The report points out that not all of these benefits are attributable to spectrum. However, loss of spectrum risks impacting the level of these benefits in future.^{[footnote 64]} The reason that loss of UHF spectrum might impact benefits is, for example, if changes to spectrum availability were to result in a lowering of audio production quality. However, assuming other bands are available, this seems unlikely. At the extreme, perceptions of lower audio quality linked to less UHF spectrum being available could risk damaging the UK’s reputation as a place to host major events, possibly reducing the number of events being hosted here. Impacts on future benefits may also risk harming the further scaling of largest UK events, although it is noted that changes in planning methods and use of other bands to allow PMSE demand at peak times/locations to be accommodated will mitigate this risk.

PMSE stakeholders have also pointed to several published reports describing how the UK’s creative economy contributes to growth.^{[footnote 65]} Stakeholders stressed that a cost–benefit analysis on future DTT options should consider the significant risk of disruption and financial impact on the UK’s creative industries if PMSE spectrum access is impacted. The potential impacts cited by the PMSE community includes impacts on jobs, creative supply chains, exports and loss of events, in addition to losses in non-tangible societal impacts like risks to the UK’s cultural prestige.

8.2.2 Sources of benefits

The primary benefit of maintaining access to the 500MHz and 600MHz bands for PMSE use is avoiding costs of making changes, whether due to:

• moving out of the UHF spectrum into other bands currently available to PMSE
• maintaining access to a reduced amount of UHF spectrum and using more efficient technologies and/or operating with more intensive spectrum re-use.

Such changes would involve retuning and/or replacement of equipment. In addition, there may also be costs arising from the need to adjust equipment use and working practices, for example through changes to re-use of spectrum and/or use of newer PMSE technologies such as WMAS. This could require investment in additional resources/training.

We have already seen a comparable situation of clearance of PMSE licences in the 694 to 790MHz frequency range (the 700MHz band) in the UK to make way for mobile services in 2020. As part of the process, Ofcom estimated the cost to PMSE users of moving out of the band to be in the region of GBP23 million to GBP34 million (in 2014 terms).^{[footnote 66]} In current terms, that translates to approximately GBP32 million to GBP47 million. However, as discussed below, it may well be that significantly greater notice of any changes could be given for changes to the 600MHz and especially the 500MHz bands, reducing adjustment costs. A similar study on the 700MHz band in Ireland concluded costs to PMSE users (over an assessment period up to 2035) of up to EUR436 000, assuming a repurposing of the 700MHz band in 2018. The Irish study was one commissioned by ComReg and conducted by Frontier Economics, as part of a cost-benefit analysis on changing the use of the 700MHz.^{[footnote 67]} This study is outdated and PMSE use is likely to have grown significantly since then. Nevertheless, it noted that costs could be strongly controlled by giving sufficient notice of clearance so that equipment could be replaced at end of life.

To support PMSE users with moving out of the 700MHz band earlier than expected, Ofcom initiated a grant scheme designed to cover a proportion of eligible equipment replacement costs and the administrative/management costs of participating in the scheme. The actual costs incurred by Ofcom in relation to this grant scheme could be used to help verify or refine the earlier estimates. To our knowledge, this information is not publicly available, although Ofcom may be able to provide it.

We might expect the costs of moving PMSE out of the 500MHz and 600MHz bands to be of a similar order of magnitude to the costs of the 700MHz band clearance. However, there are some differences between the scenarios, including the following:

• Demand for PMSE licences has increased since 2014, meaning that more equipment would likely be affected by a change in UHF availability.

• If the amount of UHF spectrum available to PMSE were reduced, users would be squeezed into a smaller total amount of spectrum than before (particularly in the sub-1GHz bands) at a time when demand for spectrum is growing. According to some stakeholders, scarcity of spectrum is already arising at some of the largest events – this may put more pressure than before on the need to improve spectral efficiency through accommodating a greater number of assignments simultaneously at the same site, for example by re-using frequencies over shorter distances. There will be a point at which quality of service degrades with increasing frequency re-use, meaning use of alternative bands and/or investing (where feasible) in new technologies is needed, which has the effect of increasing the potential costs of moving from using the UHF band.

• Previously, PMSE users were required to move out of the 700MHz band within the lifecycle of their existing equipment. The greater the notice given of the need to migrate, the greater the possibility of swapping out equipment at the natural end of life. Therefore, there is considerable scope for mitigating costs by providing early indication of any changes to the availability of the 500MHz and 600MHz bands for PMSE. In scenarios where the 500MHz is not cleared until 2045, it is plausible that sufficient notice could be given for migration costs to be minimal, as any existing equipment would reach end of life.

• There needs to be an alternative band for impacted PMSE users to move to. With 700MHz clearance, other parts of the UHF (that is, the 500MHz and 600MHz bands) could be largely relied upon. The same would not be true for potential clearance of the 500MHz and 600MHz bands. The availability of suitable alternative bands would depend on the development of equipment ecosystems, which in turn may depend on the requirement for other bands for PMSE in other European markets. If 500MHz and 600MHz were also repurposed in the rest of Europe, this would create a need for an alternative PMSE band at greater scale; if only the UK were to repurpose this band, an alternative for PMSE may be more problematic.

Another key question is whether all the UHF spectrum currently in use is essential to PMSE. There could be options to consolidate usage within a smaller amount of spectrum through more spectrally efficient technologies and/or further increases in re-use of spectrum in time and location. Over the timeframes we are considering, it is plausible that new technologies such as WMAS used in other bands could be brought to UHF, substantially reducing the overall bandwidth requirements. However, equipment manufacturers need clarity regarding the spectrum available and a sufficiently large market to make such developments viable. Again, early notice of changes would help greatly in providing incentives for equipment manufacturers.

There are several frequency bands available to PMSE. However, as set out above, several stakeholders have reported that the UHF bands are essential. This is particularly in relation to wireless microphones and in-ear monitors used for large indoor and outdoor events, as well as in theatre productions and broadcasting live events. Those who advocate to retain UHF spectrum for PMSE argue that these technologies require the high reliability of the UHF bands, which are not sufficiently provided by the other PMSE bands and that other PMSE bands are not as reliable (for various reasons, such as increased interference, reduced bandwidth or less choice of equipment). In this case, keeping at least some of the UHF spectrum available to PMSE could lead to benefits over and above avoiding migration costs:

• direct benefits to PMSE operators from being able to utilise the spectrum
• benefits to consumers from being able to enjoy the resulting content and higher quality productions.

These benefits are difficult to quantify. Some commentators point to the overall economic value of the creative industries (or sub-sectors of these industries), leading to high numbers (in the order of billions of pounds per annum). However, this is not the relevant question. The importance of the sector is not in dispute, nor that creative industries may be particularly important to the UK economy. We are interested in the much more limited question of the relative benefits of continued access to UHF spectrum for PMSE, relative to moving use to other bands. Modified usage may possibly occur alongside continued access to a reduced amount of UHF spectrum to support audio applications (if there is a sufficient case that there is functionality that cannot be replicated with alternative spectrum). This is a matter primarily of costs of moving or modifying usage, not the overall economic output of the sector. The larger the economic value created by users, the greater the ability of those users to absorb costs of moving or modifying current usage. What matters most is that effective alternative solutions become available and that migration can be achieved without risk of losing functionality.

It is also difficult to establish what the value of maintaining UHF spectrum for PMSE might be in the future, at the point where the spectrum might be repurposed (i.e. 2035 or 2045). This will depend on technology developments and the future ability of users to move away from the band. We note, for example, that audio PMSE can also operate in the 960 to 1164MHz band (shared with critical aeronautical systems). However, equipment availability is currently more limited than in UHF (and we understand limited to one type of use too – wireless microphones. In-ear monitors are not yet available for this band). Equipment is also more expensive than the standard UHF equivalent. There is also scope for PMSE to make use of developments in WMAS technology and/or potentially to use private 5G network solutions. Presently stakeholders appear unconvinced that these are adequate alternatives, but this may not be the case in the 9- to 19-year period envisaged for potentially repurposing the spectrum.

Stakeholders have expressed concerns about the UK adopting UK-specific frequency allocations that would lose scale economies in manufacturing PMSE equipment. Again, it is challenging to judge the relevance of this concern over the longer timeframes being considered here. Plans do not necessarily need to be country specific and there are mechanisms for pan-European or international co-ordination (such as via CEPT ECC or via a World Radiocommunications Conference) that would be relevant over these time scales. ^{[footnote 68]} Alternative bands (such as 2.4GHz) are already widely available internationally. Furthermore, the current use of Channel 38 for PMSE is already UK-specific.

8.2.3 Costs of clearing PMSE

The costs of clearing PMSE from UHF are strongly driven by the notice period given and the ability of users to mitigate costs by replacing equipment as part of natural renewal cycles. If moves to clear the 500MHz band only started in the 2040s, all existing equipment would have been through at least one replacement cycle by then. On these timeframes, more spectral efficient technologies could be adopted.

The 700MHz clearance scenario provides some indication of clearance costs, which to an order of magnitude is multiple tens of millions of pounds. Clearly even in the worst-case scenario, where a UK-specific alternative spectrum solution needed to be found, leading to loss of scale economies in equipment manufacturer, these costs are one or more orders of magnitude smaller than estimated benefits from mobile use.

8.3 Energy smart grid

8.3.1 Relevant published studies

In its 2021 study, Gemserv^{[footnote 69]} finds that the benefits derived from implementing smart grid technology in the UK could amount to GBP12.7 billion.

In Ireland, the Sustainable Energy Authority of Ireland estimates that by 2050, smart grids will see an accumulated reduction in energy-related CO2 emissions of 250 million tonnes.^{[footnote 70]}

In the Gemserv report mentioned above, public and private fibre, private radio frequency and commercial mobile networks were considered as potential communications methods for smart grids in the UK. Comparing the costs of each method, the study finds using a private radio frequency is the most efficient, at a cost of GBP10.7 billion compared to GBP61.3 billion for a smart grid managed via fibre, and GBP12.2 billion via a commercial mobile network.

It is implausible to assume that, in the absence of access to appropriate spectrum, all of the use cases needed to manage a smart grid would be achieved by fixed fibre connections. Therefore, the approximately GBP50 billion cost saving relative to this counterfactual that Gemserv identifies is of limited relevance. The relevant counterfactual would rather be a mix of fibre connections to larger assets, point-to-point microwave links and wireless and/or commercial mobile connections as most cost effective. However, the coverage of mobile networks in the UK today is designed to meet the needs of the operators’ customers, subject to coverage obligations set by Ofcom. The resulting coverage pattern is not optimised to the needs of a smart grid and there would likely be some electrical network assets at remote locations without mobile coverage. This may raise costs, as fixed connectivity or point-to-point microwave may be needed at such locations.

Detailed modelling of likely deployment costs with and without access to UHF spectrum would require consideration of the connectivity options currently available for electrical network assets. However, it is not implausible that costs could be reduced by around GBP1 billion through access to UHF spectrum. Gemserv identifies this as a cost saving relative to using commercial mobile networks.

It is also important to note that current regulations do not require commercial mobile networks to provide any guarantee of continued operation during power outages, or quality of service or availability. These are key requirements of a smart grid solution and were not costed for in the above figures. In particular, to restart a network from a deep and prolonged outage (a ‘black start’, or energy system restoration) requires connectivity already in place prior to the restart. Commercial mobile networks would not have sufficient power in place for cell sites to achieve this.

In addition, the Gemserv report finds that relatively little spectrum is needed for smart grids, potentially 2x3MHz or 2x5MHz. Ericsson identifies a similar requirement.^{[footnote 71]}

In 2023, Ofcom consulted on assigning spectrum bands to support transformation of the utilities sector.^{[footnote 72]} The 400MHz, 450MHz, 700MHz, 800/900MHz and 1900MHz bands formed part of this consultation. Stakeholders widely supported a focus on sub-1GHz bands for the purpose, which facilitated cost-effective network deployment over wide geographic areas.

In March 2025, an Ofcom update stated that it continues to work with the government on potential solutions, but had not yet allocated spectrum to the utilities sector. ^{[footnote 73]} An initial assessment has been completed on the usability of the 400MHz band in Northern Ireland. This would harmonise use with the Republic of Ireland, which has assigned the 400MHz band specifically for utilities use.^{[footnote 74]}

We are not currently aware of other studies that can corroborate the Gemserv study. Nevertheless, it is plausible that a modest allocation of UHF spectrum to smart grid use could provide a significant reduction in the costs of deploying a smart grid communications network to reach electrical network assets, some of which may be remote from current telecoms connectivity. Given the large number of sites needing connectivity, this cost saving could be considerable (potentially in the order of around GBP1 billion, according to Gemserv).

A dedicated smart grid radio network may provide reliability benefits not readily achievable through commercial mobile networks, due to the impact of power outages on those commercial networks.

1. DCMS and DSIT may also be interested in an intermediate date of release, in 2040.

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2. Digital European Cordless Telephony (DECT) technology is also used for digital cordless phones and smart home audio applications. It can be used for audio PMSE providing low-latency audio connection. More information can be found here www.etsi.org

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3. It is noted this band is shared with aeronautical systems and has restricted use for PMSE around airports where these aeronautical systems are deployed.

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4. Note that these quantified additional benefits are distinct from the wider economic benefits discussed in Section 1.5.

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5. Ofcom (2025), Shared Rural Network (SRN) coverage obligations, www.ofcom.org.uk

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6. ITU Region 1 covers countries in Europe, Africa and parts of the Middle East. ITU Region 2 covers North America and South America, and ITU Region 3 covers Asia and Australasia, not including the Middle East.

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7. The 3GPP band plans for LTE or 5G broadcast networks are collectively called 3GPP operating band 108.

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8. DCMS and DSIT may also be interested in an intermediate date of release, in 2040.

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9. BBC (2023), Using A Private 5G Network To Support Coverage of the King’s Coronation, www.bbc.co.uk

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10. Ofcom (2025), Connected Nations 2025, www.ofcom.org.uk

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11. Shared Rural Network (2025), 99 New Government Funded Mobile Phone Mast Upgrades Live, www.srn.org.uk

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12. CEPT is an organisation in which representatives of European postal and telecommunications administrations meet to discuss harmonised conditions for use of wireless communications and telecommunications.

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13. Ofcom (2025), Statement and Further Consultation: Future authorisation of the 1900MHz to 1920MHz band, www.ofcom.org.uk

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14. National Highways (2025), Digital Roads, www.nationalhighways.co.uk

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15. Department for Transport (2025), Driving Innovation, www.gov.uk

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16. BT (2024), BT Group Signs Major New Contract To Deliver Mobile Services For Government’s Emergency Services Network, www.newsroom.bt.com

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17. Ofcom (2023), Call for Input: Potential Spectrum Bands to Support Utilities Sector Transformation, www.ofcom.org.uk

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18. Digital European Cordless Telephony (DECT) technology is also used for digital cordless phones and smart home audio applications. It can be used for audio PMSE providing low-latency audio connection. More information can be found here www.etsi.org

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19. Ofcom’s PMSE licensing record has confirmed continued growth in PMSE events. See also BEIRG’s 2025 Spectrum Report: www.beirg.org

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20. Ofcom (2018), PMSE clearing the 700MHz band, www.ofcom.org.uk

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21. In frequency bands below 1GHz, mobile networks typically operate using paired spectrum based on Frequency Division Duplex (FDD) technology. This means that separate blocks of frequencies are assigned for mobile uplink and downlink operations. There is a frequency gap between the uplink and the downlink blocks to allow for receiver filtering operation. This sub-1GHz use of spectrum contrasts with the 3.5GHz band, used for 5G technology, where Time Division Duplex (TDD) equipment is used. In the context of TDD operation, mobile uplinks and downlinks operate in the same frequency block, and separation occurs in the time domain.

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22. Ofcom (2014), Consultation on Future Use of the 700MHz Band: Cost-Benefit Analysis of Changing its Use to Mobile Services, www.ofcom.org.uk

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23. According to the stakeholder interview with Nokia, 3GPP has also defined a band category “standalone DL only (SDO)” for 5G broadcast, including band 108, covering 470–698MHz. Channel bandwidths of 8, 7 and 6MHz are defined to fit different DTV channel raster globally, intended for 5G-Broadcast. SDO bands can also be used for mobile supplemental downlink (SDL) services.

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24. Ofcom (2014), Assessment of the benefits of a change of use of the 700MHz band to mobile, www.ofcom.org.uk

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25. For example, BTEE’s network cost savings may increase if it gained market share, though there would then likely be a corresponding decrease in the cost savings for an operator losing market share.

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26. Data traffic includes FWA traffic that is carried over a mobile network but excludes FWA traffic carried over other networks.

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27. Data traffic includes FWA traffic that is carried over a mobile network but excludes FWA traffic carried over other networks.

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28. In practice the ability of the 1400MHz to serve this traffic is likely to be lower than for UHF spectrum. However, 1400MHz could be strategically used to serve the easier to reach of the HTR traffic, meaning that it can effectively contribute to meeting the HTR capacity requirement.

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29. The actual holdings of VMO2 and VF3 in this band are ~2x17.4MHz each. The amount above the modelled 2x15MHz will initially be used for 2G, although by 2035, 2G may no longer be required. At this point, the additional ~2x5MHz could be used for 4G/5G, but not easily in its current assignment since 4G and 5G rely mostly on carrier sizes that are multiples of 2x5MHz. A future trade between VMO2 and VF3 could facilitate the use of this additional 2x5MHz of spectrum, but our modelling has not assumed that this occurs.

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30. Ofcom (2025), Review of Annual Licence Fees, www.ofcom.org.uk

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31. Ofcom (2014), Assessment of the benefits of a change of use of the 700MHz band to mobile, www.ofcom.org.uk

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32. We note that in practice it might also be the case that this approach calculates a value greater than the total benefit to operators and consumers.

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33. In practice there are 95 distinct spectrum scenarios, since at an individual MNO level scenarios 1 and 2 are identical. Scenario 1 represents no spectrum release, whilst Scenario 2 refers to an individual MNO winning no spectrum within the wider context of spectrum being released and acquired by other MNOs.

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34. Ofcom (2024) Future of TV Distribution, www.ofcom.org.uk

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35. DCMS (Prepared by University of Exeter, University of Leeds, MTM, 3 Reasons and Real Wireless) (2024), Future of TV Distribution, assets.publishing.service.gov.uk

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36. Ofcom (2024), Media Nations, www.ofcom.org.uk

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37. Ofcom (2024), Media Nations, www.ofcom.org.uk

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38. DCMS (Prepared by University of Exeter, University of Leeds, MTM, 3 Reasons and Real Wireless) (2024), Future of TV Distribution, assets.publishing.service.gov.uk

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39. VRT News (2018), VRT will stop broadcasting via DVB-T at the end of this year, www.vrt.be

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40. Broadband TV News (2019), Switzerland to switch off DTT on June 3, 2019, www.broadbandtvnews.com

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41. EBU UER (2011), Frequency and Network Planning Aspects of DVB-T2, tech.ebu.ch

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42. EC (Prepared by VVA and LS telecom) (2022), Study on the use of the sub-700MHz band (470-694MHz), www.apwpt.org

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43. EBU (2022), Trials tests and projects relating to 4G/5G Broadcast supported by European PSB, www.tech.ebu.ch

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44. Building Digital UK (2022), Benefits of Rural Mobile Coverage, www.gov.uk

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45. Deloitte (2025), Digital Consumer Trends 2025, UK Edition, www.deloitte.com

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46. Mobile UK (2022), Connected Care: How mobile connectivity can help councils overcome the challenges of delivery adult social care, www.mobileuk.org

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47. Liverpool 5G (2019), Health and Social Care Testbed: Benefits Outcomes and Impact, www.liverpool5g.org.uk

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48. McKinsey (2020), Agriculture’s connected future: How technology can yield new growth, www.mckinsey.com

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49. Bahia et al. (2023), Cost-benefit analysis of options for the 470-694 MHz spectrum band, www.econstor.eu

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50. GSMA (2022), Vision 2030: Low-Band Spectrum for 5G, www.gsma.com

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51. BT Group (Prepared by Assembly Research) (2025), Driving Growth: The GBP230bn Opportunity of Improved Mobile Networks, www.bt.com

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52. ONS (2025), Gross Domestic Product at market prices, www.ons.gov.uk

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53. Vodafone UK (Prepared by WPI Strategy) (2024), Standalone 5G and the UK’s Road and Rail Network, www.vodafone.co.uk

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54. Network Rail (2025) Major boost for rail passengers: Say “goodbye” to mobile signal blackspots!, www.networkrailmediacentre.co.uk

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55. Free TV (Prepared by Competition Economists Group) (2021), Value of the 600 MHz spectrum band, www.infrastructure.gov.au

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56. Ofcom (2025), Shared Rural Network (SRN) coverage obligations, www.ofcom.org.uk

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57. CMA (2024), Anticipated Joint Venture between Vodafone Group PLS and CK Hutchison Holdings Limited concerning Vodafone Limited and Hutchison 3G UK Limited, assets.publishing.service.gov.uk

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58. US Department of Justice (2024), Herfindahl-Hirschman Index, www.justice.gov

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59. Official Journal of the European Union (2004), Guidelines on the assessment of horizontal mergers under the Council Regulation on the control of concentrations between undertakings, eur-lex.europa.eu

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60. EC (Prepared by VVA and LS telecom) (2022), Study on the use of the sub-700MHz band (470-694MHz), www.apwpt.org

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61. BEIRG (2025), BEIRG Spectrum Report, www.beirg.org

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62. WSMA (2025), Spectrum for Programme Making and Special Events (PMSE), www.wirelessinnovation.org

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63. UK Spectrum Policy Forum (Prepared by Coleago Consulting) (2022), Future Utilisation of the 470-694 MHz Band in the UK, www.coleago.com

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64. Frontier Economics (2022), Ensuring Optimal Value from Spectrum, A Report for DSIT, www.assets.publishing.service.gov.uk

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65. McKinsey (2023), The Arts in the UK: Seeing the Bigger Picture, www.mckinsey.com, EY (2021), Rebuilding Europe – The Cultural and Creative Economy Before and After the COVID-19 Crisis, www.rebuilding-europe.eu and Deloitte (2021), Future of the Creative Economy, www.deloitte.com

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66. GBP13 to 21 million from equipment replacements costs and GBP10 to 13 million for staff training and recruitment to support improved working practices.

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67. ComReg (Prepared by Frontier Economics) (2015), A cost benefit analysis of the change in use of the 700MHz radio frequency band in Ireland, www.comreg.ie

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68. Noting that WRC-31 will consider future allocations in the UHF band, it will be essential in preparations for WRC-31 to consider impact of changes to allocations on existing secondary uses, such as PMSE.

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69. Economic rationale for enabling Smart Grid functionality of the UK energy system via a Private Radio Frequency based enhanced Operational Communications Solution, November 2021, for Joint Radio Company by Gemserv.

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70. SEAI (2019), Smart Grid Roadmap, www.seai.ie

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71. Ericsson (2023), Spectrum Simplified, www.ericsson.com

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72. Ofcom (2023), Call for input: Potential spectrum bands to support utilities sector transformation, www.ofcom.org.uk

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73. Ofcom (2025), Call for Input: Potential spectrum bands to support utilities sector transformation – Update – March 2025, www.ofcom.org.uk

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74. ComReg (2019), ComReg completes the 400 MHz Spectrum Award, www.comreg.ie

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