When ISED’s Telecom Competition Roadmap was first released, I quickly provided a link to it, promising to say more in the coming weeks. And so, here we are. It is especially timely, given the release of the Federal Budget [pdf, 10.3 MB] last week that included references to the Roadmap.

My initial reaction was that the document is somewhat naive. I wouldn’t call it wrong, but I found it comes across as naive in a number of important ways.

For example, the Roadmap says,

Building on regulatory changes to facilitate switching, the Government will promote high value plans in the market. These efforts will focus on highlighting the lowest cost and best value plans available, in order to help consumers take advantage of the latest offers and reduce the cost of living.

The government already has a website to steer people to neutral third party price comparison tools. AI agents are widely available to consumers. Does the government plan to decide which plans are best for Canadians and become a marketing agency for those plans? How will “best value” be determined? Lowest price? Most data? Number of countries in roaming plans? Bundled devices? National coverage? Quality experienced in each neighbourhood? Will the government have customer service staff to answer consumers questions about the options getting promoted or field complaints about those plans the government promotes?

It is as though the authors were thinking that purchasing mobile services is like finding the lowest price per gallon for gasoline before topping up your car’s gas tank.

The Roadmap seems to be framed around a very simple theory: More competition → lower prices → better outcomes for consumers.

That’s politically attractive, but telecom has always been a sector where the hard question isn’t whether competition is good. It’s what kind of competition is sustainable. The Roadmap tends to assume that if government removes barriers and improves wholesale access, durable national competition will naturally – perhaps magically – emerge.

Here are a few observations I have made from reviewing the Telecom Competition Roadmap:

1. It treats competition as the objective instead of a means

The document repeatedly describes “cross-Canada competition” as the central policy goal. Competition in and of itself shouldn’t be what policy is striving for. Historically, Canadian telecom policy has tried to balance a number of objectives: affordability; investment for coverage, quality, resilience, advanced technology and services, etc.

While the Roadmap acknowledges investment, competition seems to dominate the framework.

That matters because there are real tradeoffs. A policy that maximizes short-term retail competition can reduce returns on network investment. A policy that maximizes investment can increase concentration. The Roadmap often reads as though those tensions can largely be engineered away.

They can’t.

2. It assumes wholesale competition naturally evolves into facilities-based competition

This is probably the biggest conceptual weakness. The Roadmap strongly emphasizes FTTH wholesale access and MVNO access as mechanisms to create national competitors. The implicit theory is:

1. competitor gets access;
2. competitor gains customers;
3. competitor expands;
4. competitor eventually builds more infrastructure.

But Canadian history provides mixed evidence for that progression.

Many wholesale-based providers became very effective retailers. What is much more rare is the transition from reseller to nationwide infrastructure owner. Building fibre and wireless networks requires extraordinary capital and scale.

The Roadmap talks about supporting “cross-Canada competition” as though a national competitor is mainly being held back by regulatory barriers. In reality, economics may be a much bigger constraint than regulation.

3. Its treatment of market power is somewhat one-dimensional

The Roadmap emphasizes incumbent advantages, natural monopoly characteristics, poles, towers, spectrum, and first-mover benefits. Those observations may be true. But telecom economics are not merely a story of incumbent power. They are also a story of scale efficiencies.

A network serving ten million subscribers can often operate more efficiently per customer than one serving one million subscribers.

The Roadmap discusses the first phenomenon extensively and the second only lightly. As a result, the reader can come away thinking concentration primarily reflects policy failure rather than technological and economic realities.

Those realities don’t excuse concentration, but they do constrain what policy can realistically achieve.

4. It understates the success of the market over the last few years

This is where I think the Roadmap is disconnected from recent evidence.

The document notes that wireless prices have fallen substantially since 2019 and cites a 49% decline in Statistics Canada’s Cellular Services Index. The Federal Budget acknowledges “the price of a 60 GB mobile plan falling from an average of $105 in 2022 to being widely available in the $40 to $50 range.

That’s no small achievement.

Yet the Roadmap and the Budget are written as though the fundamental policy model still requires major correction.

A tougher question would have been: “If prices have already fallen dramatically, which policy interventions were actually responsible?”

The document mostly sidesteps that question. It assumes more government intervention is the answer, rather than carefully isolating which regulations produced measurable results and which did not.

5. “Dig once” and faster approvals are probably the strongest parts

Ironically, I found that the least ideological sections are the most persuasive.

• dig-once policies
• tower siting reform
• faster dispute resolution
• faster regulatory decisions
• spectrum planning

These measures improve supply-side efficiency rather than trying to micromanage market outcomes. They’re the kinds of reforms economists across different schools generally support because they reduce costs without predetermining winners and losers.

Those sections feel grounded in operational reality.

6. The Roadmap largely avoids the fundamental question: How many networks are enough?

This is the question sitting underneath everything.

The Roadmap speaks about promoting competition while simultaneously acknowledging that telecom has characteristics such that infrastructure can’t be duplicated indefinitely. The Budget says “Canadians continue to face limited choice, confusing offers, and barriers to switching providers.”

But neither the Roadmap nor the Budget never really answer the question “how many networks are enough?” How will we know when we achieved the objective?

Is the policy objective 4 national networks? 5? 6? Facilities-based competition everywhere? Wholesale competition plus a smaller number of facilities owners?

That’s probably because there isn’t a politically comfortable answer.

Yet without that answer, it’s difficult to determine whether the Roadmap’s interventions are actually aimed at a coherent end state.

My bottom line

I’d describe the Roadmap as competent but built on an overly simplified theory of telecom competition. It is strongest when talking about reducing deployment costs, accelerating approvals, improving wholesale implementation, increasing spectrum availability.

It is weakest when it implicitly assumes that affordability, competition, and investment largely move in the same direction and can all be maximized simultaneously.

While the Roadmap acknowledges these tradeoffs, it doesn’t really grapple with them. I think that’s why it feels a bit naive.

As someone who tries to follow telecom policy closely, the Roadmap reads less like an economic strategy and more like a political statement of intent, with a collection of politically attractive regulatory actions attached to it.

I don’t think the hardest problem in telecom policy has ever been figuring out how to get more competition. The hard part is determining how much legislative and regulatory intervention is compatible with the level of investment, coverage, resilience, and sovereignty that Canada wants to maintain.

That is a question the Roadmap encircles, without reaching its ultimate destination.

With my background in mathematical statistics, I like to look at data to try to see what might be hidden in the numbers.

The latest round of quarterly earnings reports are being released this week. Beyond those financial metrics, I get to look at mountains of CRTC data aggregated from Canada’s telecommunications sector. Most headlines in the general business press and industry newsletters focus on prices, market share, and subscriber growth.

That’s understandable. Consumers care about what they pay; investors look at comparative data points. But those figures tend to represent yesterday’s news.

Buried in the tables is another metric that tells us more about tomorrow: capital investment. In Rogers’ latest quarterly results, capital spending in the 3rd quarter was down 46% compared to the same period last year. In the first 9 months of 2026, capital spending is down 27% versus 2025. Rogers reported “its lowest capital intensity in over two decades”.

While policymakers and consumer advocates should celebrate lower prices, investment has also been dropping across the industry. That should be cause for concern. The most recent CRTC figures continue to reflect a measurable decline in telecommunications capital expenditures, even as we face growing demands for investment for resilience, security and sovereignty.

This creates a profound accountability vacuum.

For years, the dominant focus of telecom policy has been somewhat myopic: price reduction. Policy makers pushed for lower rates and increased competition, treating quarterly affordability metrics as the ultimate measure of success. Let’s face it, lower prices make for good politics with favourable headlines on the consumer blogs – especially when the prices for just about everything else are going up. But, it sidesteps a tougher, less glamorous question: If policy makers are hyper-focused on today’s prices, who is looking out for tomorrow’s network?

Telecommunications infrastructure requires long-term planning and investment. Fibre deployment, wireless upgrades, rural expansion, and future-ready resiliency require billions in continuous cycles of capital spending. When investment capital dries up, the consequences do not appear overnight. Networks can coast on past momentum — until they don’t.

By treating affordability and investment as separate issues, policymakers are engaged in a dangerous sleight of hand. We see short-term savings by quietly passing the bill for network investment stagnation onto the next generation of users, businesses, and innovators.

Lower consumer prices are measured each month with the release of Statistics Canada’s Consumer Price Index. The price of starving Canada’s telecom networks — with stalled innovation, constrained capacity, and vulnerable infrastructure — will be paid years down the road.

By then it is far too late to reverse course quickly.

As quarterly results get released this week, keep in mind that the most important number isn’t what Canadians are paying today. It’s what network operators are no longer spending on tomorrow.

When that bill finally comes due, it won’t be the policy makers who have to pay it. What is hidden in the numbers should not be ignored.

When does consumer protection become regulatory theatre?

I think that’s a question worth asking as the CRTC continues to introduce increasingly prescriptive requirements governing how telecommunications providers communicate with, sell to, and serve their customers.

Each new measure sounds reasonable enough. More disclosures. More notifications. More detailed rules governing customer interactions. More opportunities to complain.

But are consumers actually better off?

Consider the CRTC’s recent decision on broadband speed disclosures. The Commission has effectively defined “typical” Internet speeds as speeds customers should receive “at all times,” while simultaneously recognizing that compensation for slower speeds should depend on the materiality and frequency of the problem.

The result? A regulatory framework that risks encouraging technical disputes over speed-test results, even where customers experience no meaningful degradation in service.

Then there’s the ongoing proceeding examining consumer awareness of the Commission for Complaints for Telecom-television Services (CCTS). The CRTC is considering requirements that would notify customers of their right to complain earlier in the customer-service process.

But where is the evidence that earlier notifications will produce better outcomes?

More referrals to the CCTS won’t necessarily mean more complaints will be resolved, or that consumers are receiving better service. They could simply mean more complaints are being diverted from providers’ own resolution processes.

Meanwhile, the Commission’s proposal to harmonize its four consumer protection codes risks becoming an exercise in regulatory expansion disguised as simplification. Combining existing codes into one document isn’t simplification if the result is more obligations applying to more services. That’s regulatory theatre.

Each of these initiatives carries implementation costs. IT systems to be modified. Employees to be trained. Billing and customer-service processes to be redesigned. Compliance to be monitored and documented.

And for what measurable incremental benefit?

Legal scholars Omri Ben-Shahar and Carl Schneider have examined this phenomenon in their research on the failure of mandated disclosure. Their work explains why such requirements are politically attractive: they create the appearance of consumer protection, while their actual effectiveness often goes unexamined.

It’s easy to mandate another disclosure or notification. It’s much harder to demonstrate that it changes consumer outcomes. That’s regulatory theatre.

The problem is compounded when regulations are considered individually.

The CRTC examines each proposal on its own merits, but who is assessing the cumulative burden of successive consumer protection requirements? Who is measuring whether the combined costs are justified by improvements in consumer welfare?

These aren’t just academic questions.

Telecommunications is a capital-intensive industry. Resources devoted to implementing increasingly elaborate regulatory processes are resources unavailable for other priorities, including improving networks, developing services and enhancing the customer experience.

The timing is striking.

On October 21, the federal government announced a new Cabinet Directive on Regulatory Competitiveness and Red Tape Reduction. Taking effect December 31, it calls for evidence-informed, proportionate and outcome-focused regulation, with greater attention to compliance costs, competitiveness and unnecessary regulatory burden.

The government went so far as to establish a requirement to offset two dollars in regulatory burden costs for every dollar added.

The directive doesn’t automatically apply to CRTC regulatory decisions. But shouldn’t the principles behind it be reflected in the Commission’s approach?

Canada’s 2023 Telecommunications Policy Direction already calls for efficient and proportionate regulation that considers its effects on investment, innovation and competition.

Yet recent proceedings suggest an increasingly prescriptive approach to consumer protection, one in which the existence of a perceived problem too readily becomes justification for another regulatory obligation.

No one is arguing against protecting consumers. Accurate information, fair treatment and effective complaint resolution are legitimate regulatory objectives.

But good intentions don’t establish that a particular intervention is necessary, effective or proportionate.

Consumer protection should be measured by the problems solved, not the obligations imposed.

Otherwise, we risk confusing regulatory activity with regulatory achievement.

And Canadians may end up paying for increasingly elaborate consumer protection rules without receiving much additional protection.

That’s regulatory theatre.

There were two big releases today that impact the telecom sector.

The Competition Tribunal released its decision in a deceptive marketing practices case against Rogers, granting the application brought by the Commissioner of Competition.

By promoting and advertising across an array of marketing channels in Canada as “unlimited” or “infinite” mobile data plans that had a pre-determined and finite amount of high-speed data, after which the speed would be significantly reduced for the remainder of the billing cycle, Rogers’ “unlimited” or “infinite” representations contravened paragraph 74.01(1)(a) of the Act.

The Tribunal has assessed a $15 million penalty. In a statement, Rogers notes that the Commissioner of Competition had sought a penalty of $135M.

We introduced unlimited data plans in 2019 to deliver great value to our customers. These plans eliminated overage fees and gave our customers bill certainty at a time when data use started growing exponentially. These plans are commonplace in the industry and reflected a significant and positive development for consumers and small businesses. We stand behind our advertising and are considering next steps.

The Order is currently very brief since the Tribunal is working with the parties (the Commissioner of Competition and Rogers) to identify confidential or competitively sensitive information that will be redacted from the public version, expected to be released within the next 2 weeks.

The other one of the big releases earlier today was a Telecom Competition Roadmap released by ISED.

As part of a multi-pronged approach to augment competition, affordability, and transparency for consumers, Innovation, Science and Economic Development Canada is publishing this Telecom Competition Roadmap that outlines a broad range of actions that are being taken over 2026–2027 that each target specific areas for improvement. This is the first time a comprehensive approach is being taken to this issue.

I’ll have more to say about both these releases in the coming weeks.

At what point does a policy framework designed to lower prices undermine the telecom investment upon which it ultimately depends? Has Canada crossed that line?

I continue to ask such questions in light of data that continues to show a sharp decline in capital investment by Canadian telecommunications providers, as well as the recent GSMA report (which was the subject of a Telecom Trends post last week).

For years, Canadian telecom policy has been guided by an objective to make communications services more affordable. By many measures, regulators and policymakers have succeeded. Wireless prices are down, competition has intensified, consumers enjoy more choice.

Affordability is only one measure of success. Nearly a decade ago, I wrote about the need to balance “quality, coverage, and price.”

Telecommunications is a capital-intensive industry. Networks don’t improve on their own. Networks don’t expand on their own. Networks are built with telecom investment.

Expanding fibre coverage, deploying 5G, increasing capacity, strengthening resilience, and building next-generation networks all require billions of dollars of ongoing investment. Capital spending is how we pay for “quality”, and “coverage” in the telecom policy balancing act.

That is why the pattern of declining telecom investment should be raising alarm bells.

The CRTC’s own data shows that capital investment has been falling. The question is “why”.

To be sure, regulation is not the only factor. Interest rates, economic uncertainty, market maturity, the completion of major fibre and 5G buildouts, and broader business conditions all impact investment decisions. But, it would be surprising if regulatory policy played no role.

Over the past several years, governments and regulators have consistently prioritized lower prices and expanded wholesale access to existing networks. Those objectives are understandable and politically popular. Yet policies that make it easier for competitors to use infrastructure built by others can also reduce the incentives for facilities-based investment.

Investors pay close attention to those signals from government policy makers and regulators. If expected returns decline, investment tends to decline as well.

This creates an uncomfortable paradox. Those policies intended to help consumers today may inadvertently weaken those incentives needed to build the networks upon which consumers will depend tomorrow.

The consequences may not be immediately felt. Canada continues to benefit from extensive fibre deployment, widespread 5G coverage, and generally high-performing networks. But, the impact will become more apparent over time.

The consequences will be seen in slower upgrades, delayed rural expansion, lower network resilience, and diminished competitiveness in the years ahead. When demand for connectivity continues to grow, driven by cloud computing, streaming, artificial intelligence, and connected devices, sustained declines in investment should not be dismissed as a footnote to the Communications Monitoring Reports.

Too often, investment incentives and disincentives disappear from the policy conversation, or are paid lip service.

At last week’s Canadian Chapter of the International Institute of Communication’s annual conference, the CRTC Chair said:

The infrastructure matters. The rules governing access and competition matter. But ultimately, what matters is whether the system works — whether it connects Canadians, supports businesses and communities, and delivers reliable, affordable services that people can depend on.

The CRTC will continue to do its part: listening to Canadians and industry, making evidence-based decisions, and assessing whether those decisions are achieving their intended results.

The challenge is not to choose between strong networks and strong consumer outcomes. It is to create the conditions for both.

Unfortunately, the CRTC has not responded to a number of years of evidence demonstrating sharp declines in telecom investment.

Price reductions generate headlines; reductions in telecom investment rarely does, despite its role as the foundation upon which future affordability, innovation, and network performance ultimately depend.

Canadians deserve affordable telecommunications services. That should never be in dispute. But, if capital spending continues to fall, policymakers may need to ask whether their dogged pursuit of lower prices has weakened the incentives for telecom investment that made Canada’s world-class networks possible in the first place.

Competition can be mandated. Investment cannot.