How we got here?
Albania is operating a “duopoly” mobile market structure, formally reflected in the national regulator’s reporting since 1 January 2023: the two mobile network operators are Vodafone Albania sh.a. and One Albania sh.a. This is not merely a market descriptor; it is a regulatory fact pattern that tightens the policy focus on spectrum, wholesale access, tariff transparency, and consumer outcomes, because in a two-player market, each operator’s commercial decisions tend to transmit quickly to the entire ecosystem.
On the most recently published quarterly dataset ahead of 23 March 2026 (Q3 2025), Albania recorded 3,391,748 mobile SIM subscriptions and 2,748,448 active mobile-service users. SIM-based market share at Q3 2025 is near-symmetric (Vodafone ~50.2%, ONE ~49.8%), but value capture is not: for year 2024 the regulator attributes ~58% of total/retail mobile revenues to Vodafone, alongside leadership in data volume, SMS, and outbound calls. An important “investor reality” when underwriting EBITDA durability.
The historical arc matters because consolidation outcomes explain today’s entry barriers. Modern mobile in Albania began with Albanian Mobile Communications (AMC), founded on 27 November 1995 and operational from 1996 as a state-owned enterprise. In 2000, the state privatized AMC, selling 85% to Cosmoholding Albania S.A., with the state retaining 12.6% and staff holding 2.38% at privatization.
The competitive landscape changed structurally in 2001 when Vodafone Albania entered the market, later described by the regulator as the most successful undertaking in the electronic communications market for more than two decades.
Eagle Mobile commenced operations in 2003, initially with Albtelecom as its sole shareholder, creating an early converged fixed–mobile group.
Plus Communication became the fourth entrant in 2010, but exited the mobile market in late 2017.
By 2009–2011, regulator statistics show AMC losing share across key indicators, while Vodafone and Eagle expanded their positions and Plus gained an initial foothold. In 2011, AMC still led SIM-user share at 37%, but Vodafone already led revenue share at 52% and SMS share at 64%, an early indicator that Vodafone’s commercial model translated into disproportionate monetization power.
In February 2013, AKEP approved the legal and operational transfer of Eagle Mobile’s rights and obligations, including frequency usage rights (GSM bands), numbering resources, and SMP-related obligations, to Albtelecom following a merger by absorption. This 2013 transfer effectively migrated Eagle’s mobile spectrum and regulatory rights into the Albtelecom corporate perimeter, setting the stage for later fixed–mobile integration within the eventual ONE group.
AMC’s corporate identity then evolved: the operator was acquired by Deutsche Telekom AG and renamed Telekom Albania on 22 July 2015. In 2019, OTE announced an agreement to sell its Telekom Albania stake to Telecom Invest AD, and the regulator later notes that the operator was renamed ONE Telecommunications following that ownership change. Parallel to this, 4iG signed in 2021 to acquire an 80.27% stake in Albtelecom, framing the transaction as a strategic telecom expansion. In December 2021, 4iG also announced that it had signed an agreement to acquire Albania Telecom Invest AD, the holding company controlling ONE Telecommunications, with completion subject to regulatory approvals.
The Albanian Competition Authority, in its decision authorizing 4iG’s acquisition of Albania Telecom Invest AD, expressly recognized that the transaction would combine ONE Telecommunications and Albtelecom and reduce the number of mobile operators to two. That same decision records that completion was conditioned, among other things, on a sector-regulatory consent proces. AKEP’s 2023 annual reporting confirms that, in late 2022, the company absorbed Albtelecom and adopted the name ONE Albania, consolidating the Eagle/Albtelecom mobile legacy and the earlier AMC lineage into a single counterweight to Vodafone.
From 1 January 2023 onward, AKEP’s statistical publications treat the mobile market as a two-operator structure, Vodafone and ONE, an inflection point that has materially raised the importance of wholesale access, pricing discipline, and spectrum policy. Market-share data for 2023 shows Vodafone leading on several core indicators, including approximately 56% of total/retail mobile revenues and around 55% of outbound calls, while ONE held a majority of SIM-card counts. For 2024, AKEP reports Vodafone still leading on value capture (about 58% of mobile revenues) and usage metrics, despite a 50/50 split of active SIM-card users, reinforcing a long-run pattern of Vodafone outperformance on monetization even where volume shares converge.
From an entry standpoint, Albanian law now offers a modernized electronic communications framework (Law No. 54/2024) with a general authorization regime (Article 26–28) and detailed spectrum governance (including Art. 71–76) that expressly empowers AKEP to use spectrum tools to promote competition—including spectrum caps, reserved spectrum for new entrants, and wholesale/national roaming-type conditions. The competition law merger-control clock is legally determinate: 2 months for preliminary review (Art. 56) and 3 months for in-depth review (Art. 57), with extensions in specified circumstances, which becomes transaction-critical in any change-of-control scenario.
Our bottom-line recommendation, on a risk-adjusted legal and execution basis, is that M&A is the generally superior entry pathway in a two-operator, spectrum-constrained market, provided the buyer can structure around
- Albanian merger control,
- AKEP consent and spectrum continuity risk, and
- (iii) emerging foreign investment / critical infrastructure screening dynamics.
Mobile networks have become baseline national infrastructure: they sustain day-to-day commerce, emergency communications, and digital public services, and global digital development frameworks consistently treat connectivity as a prerequisite for inclusive economic participation.
Because radio spectrum is a finite public resource, every country necessarily “institutionalizes” the MNO market through licensing and spectrum governance, meaning regulation is not peripheral; it is the operating system that sets investment incentives and competitive guardrails.
At ecosystem scale, mobile contributes meaningfully to GDP, employment, and productivity in most jurisdictions, and, with only a small number of national networks, capital expenditure cycles by one or two operators can measurably shape a country’s digital resilience.
Legal pathways to market entry
Albania’s entry framework must be assessed through one pragmatic lens: mobile entry is not “incorporate and launch,” it is “secure spectrum + secure interconnection + secure rollout rights + clear competition.” The keystone is Law No. 54/2024 (Electronic Communications), which adopts a general authorization logic—operators are, in principle, free to provide networks/services (Art. 26) but must notify AKEP before commencing/altering/ceasing service (Art. 27), and any use of scarce resources (spectrum and numbering) is subject to rights-of-use conditions (Art. 28). Importantly, Law No. 54/2024 also hard-wires competition coordination: in market definition/analysis work, AKEP must consult and cooperate with the Competition Authority (and may formalize cooperation arrangements).
Foreign investment screening is an emerging variable: Albania amended the foreign investments framework to introduce a critical infrastructure-oriented provision (Law No. 56/2025, via an addition to Law No. 7764), and the official consultation materials show the new concept is targeted at FDI that “relates to or affects critical public infrastructure.” For a MNO acquisition, the investor should plan a governance-ready narrative early, because telecom is plainly within the realm of critical infrastructure and 5G supply-chain security is expressly regulated within the electronic communications framework itself.
For investor underwriting, it is also relevant that AKEP explicitly views the post-consolidation environment as one where wholesale policy tools (including potential MVNO access) become key to preserving competitive discipline, and AKEP recognizes that a third operator (MNO or MVNO) could seek interconnection under the current framework though none had done so “to date” as of the activity report. This matters because remedies may increasingly take the form of wholesale access obligations, which Law 54/2024 already anticipates as a spectrum-competition measure (Art. 72).
Legally, greenfield entry begins under the general authorization regime: the undertaking is free to offer networks/services (Art. 26) but must notify AKEP ahead of commencement (Art. 27), and must separately secure rights of use for scarce resources—most critically, radio spectrum (Art. 28). [43] In commercial reality, the decisive gate is spectrum: where rights are limited, Albanian law sets a structured process—public consultation with at least a 30-day response window, an AKEP proposal to the responsible minister, ministerial approval within 30 days, and then a public competitive procedure run by AKEP no later than 15 days after ministerial approval (Art. 75–76).
The investor must therefore accept that a new MNO is, by definition, a multi-year program: spectrum award timing depends on band availability (which is not fully determinable from public sources in this report beyond the 3.5 GHz authorizations already granted to the incumbents), followed by network rollout requiring right-of-way and passive infrastructure access. Albania does have an enabling framework to lower civil-works friction: Law No. 120/2016 is expressly designed to facilitate high-speed network deployment and secure right of way, including shared use of physical infrastructure, which can be strategically leveraged by a new entrant.
Recommendation on buy versus build
The core investor question is not “can we enter,” but “can we enter with acceptable certainty of spectrum, scale, and economics.” Under Albanian law, an undertaking is in principle free to provide networks and services under general authorization, but MNO economics turn on scarce resources and regulatory rights (spectrum + numbering), and that is where greenfield entry becomes both capital-intensive and timing-sensitive.
Accordingly, our lawyerly recommendation is to prioritize an M&A pathway—either of Vodafone or ONE, unless the investor has a uniquely patient capital stack and is strategically pursuing a “long-duration infrastructure play” where multi-year spectrum and rollout uncertainty is acceptable. In a two-operator market, M&A is the only route that immediately delivers
- an operational network footprint,
- embedded spectrum rights,
- established interconnection, and
- (iv) customer scale, each of which otherwise must be rebuilt from first principles.
Greenfield can be strategically rational only if the investor can
(a) secure a credible spectrum path under the Art. 75–76 award framework, and
(b) secure wholesale access/roaming economics that make early-stage market entry viable—both of which are legally possible but commercially non-trivial, as reflected by the regulator’s observation that no third MNO/MVNO entry request had materialized as of its 2024 activity reporting.
Is it doable?
A disciplined entry program benefits from phased execution, with each phase producing “board-usable” outputs and tightening the critical path.
Phase one: Regulatory perimeter and entry thesis (2–3 weeks)
Deliverables: (i) regulatory roadmap under Law 54/2024 (authorization + spectrum + wholesale), (ii) merger control likelihood matrix using the statutory clocks (Art. 56–57), (iii) initial FDI/critical infrastructure screening memo, and (iv) a stakeholder map (AKEP / Competition Authority / relevant ministries) anchored to decision-making points.
Phase two: Targeting and term-sheet architecture (3–7 weeks)
Deliverables: (i) acquisition structure options (share deal vs staged control), (ii) conditions-precedent schedule indexed to statutory timelines, (iii) remedy strategy playbook (competition and spectrum), and (iv) a draft regulatory engagement script to reduce procedural friction and preserve goodwill.
Phase three: Full diligence and filings (7–12 weeks, transaction-dependent)
Deliverables: (i) red-flag diligence report (licenses, spectrum, sites, data, security, consumer), (ii) merger notification package, (iii) AKEP consent/notifications package aligned with spectrum continuity, and (iv) GDPR-aligned / Law 124-aligned data protection integration plan.
Phase four: Closing and Day‑1 regulatory continuity (5–8 weeks)
Deliverables: (i) closing mechanics and registries, (ii) Day‑1 compliance register, (iii) incident-response and notification readiness (including security incident governance), and (iv) a 100‑day integration plan with regulator-facing reporting lines.
