Germany’s mobile value-added services (VAS) market is once again becoming a lucrative opportunity. Direct Carrier Billing (DCB) offers a seamless payment channel with strong consumer appeal, and the early signs point towards solid growth potential. But history shows that whenever a market starts to expand, it also becomes more attractive to those who seek to exploit weaknesses in oversight.
At present, complaint levels in Germany remain relatively low. That can make it tempting to believe that existing approaches are sufficient. However, experience in other markets suggests otherwise. Without early intervention, it is only a matter of time before misleading advertising, non-compliant payment flows, and fraudulent activities begin to erode customer trust. From our monitoring with MCP SCANNER, we are already seeing increasing non-compliant practices in the German market, including misleading advertising, as well as promotional branding and pricing.
The Risk Curve: What Other Markets Teach Us
In several mature DCB markets, a familiar pattern has played out:
- At first, growth is strong, and oversight is limited.
- Bad actors move in, taking advantage of weak controls.
- Customer complaints rise sharply, drawing attention from the regulator as well as the media.
- MNOs respond with heavy restrictions – banning affiliate traffic, introducing stricter flows, and imposing fines or suspensions.
These reactive measures may stop the immediate issues, but they also reduce conversion rates and make the market less attractive to reputable content providers. In some cases, revenues declined so significantly that the long-term future of DCB was put at risk.
Why German MNOs Have an Advantage
Germany is at an earlier stage. That creates a unique opportunity for MNOs to take control before the market reaches a tipping point. By setting standards now – and by requiring compliance and anti-fraud measures across the value chain – MNOs can create an environment that is both secure and commercially attractive, regardless of whether customers are subscribing through 1-click, 2-click, MSISDN-based, or PIN-confirmation flows.
This is not about introducing unnecessary barriers. It is about shaping a market that encourages quality services, builds consumer trust, and creates stable, long-term revenues for operators and their partners.
The Business Case for Leadership
Taking proactive steps today delivers clear advantages:
- Protecting revenue streams: By reducing fraudulent traffic and customer complaints, MNOs prevent future revenue disruption caused by punitive measures.
- Building stronger partnerships: A cleaner, well-regulated environment attracts premium brands and content providers who want to invest for the long term.
- Owning the narrative: By leading the charge, German MNOs can define how DCB evolves in the country – rather than waiting for the regulator, Bundesnetzagentur, or external pressures to dictate terms.
Taking Practical Action
The practical steps are clear:
- Mandate the use of compliance monitoring platforms at aggregator and CSP level, working collaboratively with active players in the market such as MBE or Internet Q to ensure services are tested and verified before launch, and monitored thereafter.
- Require anti-fraud solutions that detect and block suspicious behaviours or malicious traffic.
- Implement robust due diligence when onboarding new partners, using structured checks and verification to reduce exposure to reputational or financial risk.
- Mandate clear customer care workflows at CSP level and test them regularly, ensuring that if a customer experiences an issue, there is a straightforward way to resolve it without escalating into a formal complaint.
- Leverage risk management tools internally to monitor and enforce standards consistently across all traffic and campaigns.
These measures are not theoretical. They are already being used successfully in other markets to stabilise revenues, reduce complaints, and strengthen customer trust.
Building a Sustainable DCB Market in Germany
Germany has the chance to write a different story. By acting now, MNOs can protect their own revenues, safeguard their brands, and build a thriving mobile VAS ecosystem that delivers value for the entire chain – from games and video to music, lifestyle, and eLearning services that are popular with German consumers. The opportunity is significant – but so is the responsibility to ensure that it grows on solid foundations.
Download the white paper: Unlock Sustainable Carrier Billing Growth Through DDRC for a deeper look at how proactive compliance and risk management create long-term value.
