telecoms' regulatory accounting separation and oman case study
DESCRIPTION
Presentation at Conference on Telecoms Cost Accounting in Dubai - October 2009TRANSCRIPT
Telecom Cost Accounting Conference
Dubai 26 Oct. 2009
Accounting Separation Global Best Practices and Oman ModelGlobal Best Practices and Oman Model
Safdar ImamSafda aSenior Costing Specialist
Omantel SAOG
Talking Points !Talking Points !
h i i S i ?What is Accounting Separation?
Why to have it as a Regulatory Mechanism in y g yTelecoms?
What do IFRS say about AS and Why do we needWhat do IFRS say about AS and Why do we need other Standards?
Wh AS P i i l d B P i ?What are AS Principles, and Best Practices?
What are International Experiences?p
How is Oman AS Framework emerging?
What is Accounting Separation?What is Accounting Separation?
Depends on whom you ask!!!
“De‐consolidation of a holding company's accounts so g p ythat the costs and revenues associated with each subsidiary or unit can be individually identified and y yallocated.” (www.businessdictionary.com)
“Accounting Separation is a system of preparation ofAccounting Separation is a system of preparation of separate accounts of economic results, on some pre‐defined basis for some specific functions or services ”defined basis, for some specific functions or services. (OECD)
What is Accounting Separation?l ’ iRegulator’s Perspective
“The preparation of separate accounts for different p p pbusinesses and parts of the businesses run by the same company or group of companies, so that the costs and p y g p p ,revenues associated with each (and the transfers between them) can be separately identified and ) p yproperly allocated.” (OFCOM UK)
“Accounting Separation is a system of comprehensiveAccounting Separation is a system of comprehensive set of accounting policies, procedures and techniques for preparation of financial information to demonstratefor preparation of financial information to demonstrate compliance with ‘non‐discrimination’ obligations and absence of anti competitive cross subsidies” (ITU/EU NATPabsence of anti‐competitive cross‐subsidies (ITU/EU‐NATP Project Team)
What is Accounting Separation?Operator’s Perspective
AS refers to the preparation of separate “sets ofAS refers to the preparation of separate “sets of financial statements” for identified business lines of a notified dominant operator under ex ante regulatorynotified dominant operator under ex‐ante regulatory framework with the object to provide transparent disclosures about internal transactions (Transferdisclosures about internal transactions (Transfer Pricing) between various business lines.
Real Life Perspective !!Real Life Perspective !!
It is “Unscrambling of the Omelet”?It is Unscrambling of the Omelet ?
(www findlaw com au )(www.findlaw.com.au )
Scramble Challenge
Why is AS used as Regulatory Tool in Telecoms?Why is AS used as Regulatory Tool in Telecoms?
T id hi h l l f ti l dTo provide higher level of operational and financial details than what is derived from statutory financial statementsstatutory financial statementsTo reflect performance of the part of the business as if they had operated as separate businessesas if they had operated as separate businessesIn case of vertically integrated undertakings providing ICT Networks and Servicesproviding ICT Networks and Services– To prevent discrimination in favor of their own activitiesactivities
– To prevent unfair cross‐subsidy
Why Separation?Why Separation?Competition Problem – Vertically Connected Industry
Vertically integrated Anti‐
New Entrants /integrated
operatorStrategic WMD
AntiCompetitive Behavior
Possible Effects
Entrants / Competitors
Core Network Supply of Wholesale Products
Price Discrimination
Margin Squeeze
Fore‐closures
Access Network
Cross‐subsidization
Raising Rivals’ Costs
M & A
Retail Services
Supply of Retail Products
Predatory Pricing
Restriction of Competitors’
l
Bankruptcies
Pricing Sales
Solution to Competition Problem?Solution to Competition Problem?
SEPARATION
Structural S
• Achieve ownership unbundling or Divestiture• Separate network infrastructure from units offering
i i hi i f
SEPARATION
Separation
F ti l
Separate Ownership
services using this infrastructure
•Separate part of the operation with a bottleneck resourceP id i l i h I b ilFunctional
SeparationIndependent Governance & Operations
•Provide access to competitors along with Incumbent retail divisions on non‐discriminatory basis
•Separate “set of accounts” for part of the operation with
Accounting SeparationAccounting Rules for Regulatory
Controls
p p pbottleneck resource and business units of retail services •Provide transparency of transactions between internal units to ensure equal treatment for external operators
But how much Separation?pAccounting Separation is a less intrusive and much less costly REMEDY to implement
Accounting Separationl bRegulatory Objectives
International Experiences highlight following safeguards against VIDOs*
• Monitoring cross subsidisation
International Experiences highlight following safeguards against VIDOs
• Comparison between internal transfer prices and externalwholesale service charges for vertically integrated operators
• Analysing potential anti‐competitive pricing behaviour, suchas margin squeeze or predatory pricing
• Determination and monitoring of interconnect charges
• Monitoring industry and service trends• Monitoring industry and service trends
• Tariff regulation
*Vertically Integrated Dominant Operator
Isn't IFRS sufficient for AS?Isn t IFRS sufficient for AS?
• On 30 Nov 2006, IASB issued IFRS 8 – Operating Segments to replaceIAS 14 Segment Reporting
International Financial Reporting Standard # 8 – Operating Segments
IAS 14‐ Segment Reporting.
• IFRS 8 is mandatory for annual financial statements of Listed Companiesfor the period beginning on or after 01 Jan 2009p g g
• Segmented financial information is required to be disclosed about an“Operating Segment” defined as follows;
Engaged in business activities earning revenues and incurring expenses(including transactions with other ROS’* of the same entity)
Whose operating results are reviewed regularly by the entity’s chiefWhose operating results are reviewed regularly by the entity s chiefoperating decision makers to make decisions about resource allocation andperformance assessment.
For which discrete financial information is available
* Reportable Operating Segments
What do IFRS say?What do IFRS say?
Exceptions/ Thresholds;
International Financial Reporting Standard # 8 – Operating Segments
p
Corporate HQ or Functional Units with no revenuestream from operational activities of the entityp y
Post retirement benefit plans
S t ith R i < 10% f bi dSegment with Revenue size < 10% of combined revenueof all ROS’*
S t ith P fit L f 10% f ll bi dSegment with Profit or Loss of < 10% of all combinedProfit or Loss of all ROS’
i h l % f ll bi dSegment with Assets value < 10% of all combined assets.* Reportable Operating Segments
Why do we need AS Framework on top of IFRS?Why do we need AS Framework on top of IFRS?
IFRS d d fi ROS dIFRS does not define ROS revenue, expense, assets and liabilities nor any allocation rules/ methodology
Only requires an explanation as to how these are measured for each ROS
Limited only by their internal reporting practices, entities have discretion in determining the number of ROS d h t i i l d d i th ROS P&L A tROS and what is included in the ROS P&L Account.
Scope is limited to Public Listed companies whose debt i i d d i bli kor equity instruments are traded in a public market.
Postulates of AS Regulatory Framework
D fi i th k t d iDefining the markets and services
Analyzing the market structure– Synthesizing the Market Study Results and available Remedies– Synthesizing the Market Study Results and available Remedies
– Determining the Dominant Position (SMP)
Defining objectives of Regulatory AccountingDefining objectives of Regulatory Accounting
Specifying key parameters of Cost Accounting Model
Using Regulatory Cost Accounting resultsg g y g– Margin Squeeze/ Imputation Tests
– Predatory Pricing Tests
– Anti‐competitive Bundling Tests
– Cross‐subsidization Tests
Postulate 4: Specifying Key Parameters of i d lCosting Model
– Accounting principlesAccounting principles
– Disaggregation level – Products and Services
– Accounting period & production timeline
– Criteria of Assets Valuation– Criteria of Assets Valuation
– Cost Standards & Categorization (SAC, FDC, LRAIC, )MC)
– Types of Models (Top Down vs. Bottom Up, HCA, yp ( p p, ,CCA, BCA)
Postulate 4: Specifying Key Parameters of i d lCosting Model
– Internal Transfer PricingInternal Transfer Pricing
– Life Span of Assets
– Weighted Average Cost of Capital
– Activity costs attributable to network directly to– Activity costs attributable to network, directly to services, indirectly to services
– Unattributable costs’ allocation principles
– Recommended CCA concepts (Excess Capacity, p ( p y,FCM, OCM)
Accounting Separation
OMAN MODEL
Sultanate of OmanMarket Overview
• Located south‐east of Arabian Peninsula next to Saudi Arabia and the UAEand the UAE.
• Divided into three main Governorates and five RegionsGovernorates and five Regions
• 309,500 square kilometers
• GDP US $ 60 bGDP US $ 60 b
• Population 2.743 million *
• Teledensity• Teledensity
– Mobile: 130 %
Fixed: 10%– Fixed: 10%
*Excluding Expats ; 0.6 M ( Oman TRA Market Statistics – June 2009)
Oman Telecom LiberalizationOman Telecom Liberalization
O j i d th WTO i N 2000Oman joined the WTO in Nov 2000Committed to liberalize the market by Jan ‘05TRA was established in Mar 2002Second Mobile License issued in Mar 2005Second Mobile License issued in Mar 2005– Nawras; Jointly owned by Q Tel with localO M bil S b idi f G t d O t l– Oman Mobile; Subsidiary of Govt. owned Omantel
Second Fixed License issued in Nov 2008– Nawras Plans to install IGE / MAN (www.nawras.om )
– Omantel 270 K Subs (10%) / NG Upgrade( ) / pg
Regulatory Framework *Regulatory Framework Licensing RegimeLicensing Regime– Class I License – Public Fixed and Public Mobile Networks
– Class II License – Public Value‐Added ServiceClass II License Public Value Added Service
– Class III License – Private Telecommunications Service
I t tiInterconnection
– LRIC based charges
• Omantel & Oman Mobile FDC / LRIC model
• Fixed and Mobile Termination determined annuallyFixed and Mobile Termination determined annually
– RIO and RAO
* www.tra.gov.om
Regulatory FrameworkRegulatory FrameworkUniversal Service ObligationUniversal Service Obligation
– USF established to subsidize service for un‐served areas
f l d b b d d d f– Part of royalties paid by operators to be dedicated for USF
– Underserved Areas selected by TRA; to be offered for bidding
SMP Remedies
– Accounting Separationg p
– Transparency
– Access to NetworkAccess to Network
Current Oman Telecom Market TRA Report 30 JUN 2009
Market Share Market Share
Total Fixed Market: 0.265 M Total Mobile Market: 3.562 M
Oman Mobile 50%Nawras 47%Resellers 3%
Omantel 100%Nawras Preparing to Launch
Source: www.tra.gov.om
AS Framework Roll out in Oman UpdateAS Framework Roll‐out in Oman ‐ Update
Consultation Paper on Accounting Separation AUG 2008
Responses on AS Consultation Paper OCT 2008
Stakeholders’ Meeting FEB 2009Stakeholders Meeting FEB 2009
Consultation Paper on Market Dominance Criteria MAR 2009
TRA Position Statement JUL 2009
TRA Guideline / Determination NOV 2009TRA Guideline / Determination NOV 2009
Oman TRA Consultation PaperSMP Remedies
All current Class I license holders are classified as Notified OperatorsAll current Class I license holders are classified as Notified Operators– Omantel;
– Oman Mobile
– Nawras
Remedies– Accounting Separation,
– Cost Accounting /Price Control– Cost Accounting /Price Control
– Transparency
– Non‐discrimination
– Access to Network
– Unbundling of Products
Oman TRA Consultation PaperObjectives
/• Remedies/ obligations of the Notified and other Licensees
• Market‐based level of Accounting Separation
• Overall reporting requirements, format of the SRAs* and related issues
A i di d d di i i• Appropriate audit procedures and audit opinion
• Cost allocation process of costing models for SRAs
d d / h d l d• Mandated Accounting/ Costing Methodologies and principles for SRAs
S t d T f Ch i d CCA th d l i• Suggested Transfer Charging and CCA methodologies
• Long‐Run Incremental Costing (LRIC) modeling approach
M k t D t R ti R i t d d• Market Data Reporting Requirements and procedures
Market based Accounting Separation
Retail Fixed Market definition Level of development•Access
Voice •Local and/or national voice telephone services
•International voice telephone services
Market not OpenedIndividual SMPCompetitive market
Retail Data •Retail leased lines•Dial Up Internet•Broadband Internet
Wholesale Fixed Voice
•Call origination
Wholesale •Wholesale unbundled access
•Call termination
Wholesale “infrastructure”
Wholesale unbundled access •Wholesale Line Rental (WLR)
•Wholesale broadband access (Bit stream Market)
•Wholesale terminating segments of leased lines
Mobile Market •Access and voice call origination
•Wholesale terminating segments of leased lines
•Wholesale trunk segments of leased lines
•Voice call termination on individual mobile networks•Wholesale international roaming
OMAN TRA PRICE CONTROL REGIMEOMAN TRA PRICE CONTROL REGIME
SEPARATED REGULATORYSEPARATED REGULATORY ACCOUNTS
INVESTIGATIVE COSTING
Annual
INVESTIGATIVE COSTING STUDIES
FDC / LRIC MODELING
Rare Case
/INTERCONNECT TARIFF
APPROVALAnnual
TARIFF REBALANCING/ ADC APPROVALSAnnual
PRODUCTS PRICING APPROVALSEach Product
DIRECTIVE Occasional
AS Obligation for SMPTRA Position Statement Jul 2009
What to Submit? When to Submit?
Methodology document 3 months after TRA Decision Issuance
TD FDC/HCA FY 2009 One Year after the Decision
TD FDC/CCA FY 2010 6 th ft Y dTD FDC/CCA FY 2010TD LRIC Results FY 2010
6 month after Year-end
TD FDC/CCA FY 2011 6 month after Year-endTD FDC/CCA FY 2011TD LRIC Results FY 2011
6 month after Year-end
Timeline TRA Position Statement Jul 2009Timeline – TRA Position Statement Jul 2009
TRA DECISION
FY 2009 FDC/HCA
FY 2011 FDC/CCA,
LRICDECISION FDC/HCA LRIC
FEB NOV NOV JUL JUL 2012
METHODOLOGY DOCUMENT
FY 2010 FDC/CCA
20102009 2010 2011 2012
DOCUMENT FDC/CCA, LRIC
Omantel Response to AS ChallengeOmantel Response to AS Challenge
Omantel is one of the first Telcos of the Region to have implemented ABC in the Region
Omantel Group is already providing fully segmented costing analysis for Fixed Line (Omantel) and Cellular (Oman Mobile) businesses to the TRA annually based on;businesses to the TRA, annually, based on;
– Top‐down FDC
– LRIC Model
The Group is gearing up to meet AS obligations p g g p g
Arguing with TRA to reduce arduousness of the obligations
OMANTEL – The Challenge is to Turn Challenge into Opportunity
Cost Management/ Efficiency
Improvement
“Effective” fulfillment of
Leveraging Business
Accounting Separation
fulfillment of Regulatory
Requirements
Business Information for Value Creation
Separation Model
Budgeting and Strategic Fi i l
Performance Management
d D i i Financial Model
and Decision Making
Important References*Important References
Identification of Competition Problems and Remedies by Mark Scanlan & Ulrich Stumpf
ITU Regulatory Accounting Guide – March 2009
ITU Costing Experts’ Training Documents – Nov 2008
Oman TRA Accounting Separation Consultation PaperPaper
Oman TRA Market Statistics – June 2009
You can download, these documents from IIR Telecom Costing website
Q & A
For any further query please contactFor any further query, please contact
Safdar Imam
Sr. Costing Specialist, Omantelg p ,
ALQURAN ALHAKIMVerse 284 Chapter 2Verse 284, Chapter 2,
وإن تبدوا ما في أنفسكم أو تخفوه يحاسبكم لله ما في السماوات وما في الأرض والله على آل شيء قدير فيغفر لمن يشاء ويعذب من يشاءبه الله يب ن ب وي ي ن ر يري ي ى و
To Allah belongs all that is in the heavens andTo Allah belongs all that is in the heavens and all that is on the earth, and whether you
disclose what is inside you or conceal it Allahdisclose what is inside you or conceal it, Allah will call you to ACCOUNT for it. Then He
forgives whom He wills and punishes whomforgives whom He wills and punishes whom He wills. And Allah commands everything.
ABC Design at OmanTelActivity Based Costing
ActivitiesActivities Cost ObjectsCost Objects1st Level11stst LevelLevel
ResourcesResources
EquipmentEquipmentEquipment
ABC Design at OmanTel1st Level
Network Blocks by Region
11 LevelLevel
Network Blocks by Region
EquipmentGroupsSwitchingBTS’s
Fiber Optic CableCross‐connects
Etc.
EquipmentEquipmentGroupsGroupsSwitching
Transmission EqmtFiber Optic CableCross‐connects
Etc.
Client FacingActivities byBusiness Unit /Global
Client FacingClient FacingActivitiesActivities bybyBusiness Unit /Business Unit /GlobalGlobal
GeneralCarrier’sProducts & Services
GeneralCarrier’sProducts & Services
2nd Level
International Routes by Carrier
22ndnd LevelLevel
International Routes by CarrierDepartmentsDirectorate HEMDirectorate HEPCorp. PlanningFinancial Serv
DepartmentsDepartmentsOmanTel
OrganizationalCost Centers
Resource Pools‐ Personnel‐ Fleet‐ Buildings‐ Communications‐Hardware/ Software
Resource PoolsResource Pools‐ Personnel‐ Fleet‐ Buildings‐ Communications‐Hardware/ Software
Network Activitiesby Business Unit /Network Block
Support Activitiesb B i U it /
Network ActivitiesNetwork Activitiesby Business Unit /by Business Unit /Network BlockNetwork Block
Support ActivitiesSupport Activitiesby Business Units/by Business Units/
Customer GroupsRegionsOther Cost Objects
Network Blocks
Hardware & Software
Regions
Other Cost Objects
Network Blocks
Hardware & Software
3rd Level
Basic Services b y Region
Customer Groups
33rdrd LevelLevel
Basic Services b y Region
Regions
Financial Serv.Customer Serv.Support Serv.Mobile C.U.Fixed C.U.
InternationalAdministration
Etc
/
Other Costs‐ Depreciation‐ Cost of Capital
Other Costs‐ Depreciation‐ Cost of Capital by Business Units/
Globalby Business Units/by Business Units/GlobalGlobal
Hardware GroupsHardware GroupsHardware Groups4th Level44thth LevelLevel
Regions
Etc.
Hardware &SoftwareGroupsTIMS
Hardware &Hardware &SoftwareSoftwareGroupsGroups
Billing SystemsPayroll System
Etc.
‐ Cost of Capital‐Maintenance‐ External Supplies‐ Etc.
Cost of Capital‐Maintenance‐ External Supplies‐ Etc.
Software GroupsSoftware GroupsSoftware GroupsProducts / Services by Region
and Customer Group
Other Cost Objects
Products / Services by Region
Other Cost Objects
C C t d RCommon Costs and Revenues
TABSPayrollEtc.
RevenuesRevenuesRevenues
Common Costs and RevenuesCommon Costs and Revenues
Segment Definitions for DominantFBO Domestic/InternationalFBO - Domestic/International
NetworkLocal
h
Tandemexchange/
interconnect gateway
Tandemexchange/
interconnect gateway
Internationalgateway
h exchangegateway switch
gateway switch
exchange
Linecards/ports
Local-tandemtransmission
Tandem-tandem
transmission
Internationaltransmission
Customer AccessDomestic networkInternational servicesnetwork