Europe is often treated as a single market for IoT connectivity but, in practice, national rules on SIM registration, numbering and authorisation still differ between countries.

Cullen International's updated analysis of 31 European markets examines these rules across three reports. The research shows that the regulatory treatment of IoT connectivity is not determined primarily by its technical configuration. More important is how the service is designed and offered, which undertaking provides and takes responsibility for the connectivity, and the customers for whom the service is provided.

Different service models can also lead to different regulatory treatment, for example between traditional M2M connectivity and scenarios in which connectivity supports end-user-facing services or public internet access, such as infotainment services in connected vehicles.

Key takeaways

There is no common European approach to IoT SIM registration. Some countries apply general registration requirements that extend to IoT and M2M connectivity, while others permit anonymous prepaid use. The outcome can depend on specific exemptions, whether or not the service is prepaid or on the functions supported by the SIM.  A SIM registration requirement does not always prescribe a specific identity verification method or a minimum period for retaining subscriber registration data.

Permanent IoT roaming is generally permitted across Europe, but this does not determine the broader regulatory position. Several markets restrict the use of foreign numbering resources or require notification or authorisation, and public internet access provided through a roaming SIM can trigger national regulatory requirements.

Market-entry requirements depend mainly on the provider's role and whether the service is publicly available. Depending on the service model, regulatory obligations may apply to the IoT connectivity provider, the mobile network operator or another undertaking supplying connectivity. Requirements for local establishment or representation also vary between countries.

Regulatory developments in 2026

Several countries introduced or proposed changes in 2026, including new prepaid registration measures in Latvia, Lithuania and Portugal, and draft numbering rules in Austria and the Netherlands. At EU level, the Single Passport proposed under the Digital Networks Act could change how providers complete notifications across member states, although BEREC has raised concerns about the proposed model.

Why it matters

Even where permanent IoT roaming is permitted, registration, numbering and notification requirements may still apply depending on the service model. For example, for connected vehicles, the same connectivity may support closed vehicle communications and public internet access for passengers but with different regulatory consequences.

Cullen International’s latest three reports provide country-by-country comparisons and a practical decision framework for assessing market entry.

Scope

Region: Europe
Countries covered: 31
Policy area: Internet of Things
Last updated: October 2026

For more information and to access the research, please click “Access full content” or “Request access” if you are not a subscriber to our IoT service.