Fact-Check: GSMA Intelligence´s report “The cost of removing designated third-country vendors from EU telecoms networks”

This research note fact checks the report: “The cost of removing designated third-country vendors from EU telecoms networks” published by GSMA / GSMA Intelligence, called High-Risk Vendors (HRV) in report but also know as High-Risk Suppliers (HRS).

The report advances many claims that are inconsistent with the GSMA’s longstanding positions on competition and the European telecommunications market. It is also a relatively brief, 23-page document that, by the second page, includes several important caveats about the robustness of its own findings.

Rather than presenting new evidence, the report recycles many of the same arguments that Strand Consult has systematically challenged for almost nine years. During that time, Strand Consult has published an extensive body of research documenting the risks and market realities associated with High-Risk Suppliers (HRS). Despite our work being publicly available for years, neither the GSMA nor its members that have invested in HRS have been able to identify any factual inaccuracies in our analysis. See Strand Consult’s most recent note: New Figures from Strand Consult: Fact-Checking Operators’ Claims About the Impact of the European Commission’s Cybersecurity Act 2

GSMA Intelligence’s report is a document that investors in operators which have chosen to keep High-Risk Suppliers (HRS) in their networks after 2019 should read. The fact is that, in 2019, all 27 EU Member States agreed to phase out High-Risk Suppliers from Europe’s 5G networks. With the launch of the EU’s 5G Toolbox, the EU and its 27 Member States sent a clear signal to Europe’s telecommunications companies that they should phase out the use of HRS in their networks as they upgraded from 4G to 5G. Most Europe’s operators understood this and chose to phase out HRS. The financial consequences have been marginal, as evidenced by these companies’ financial statements and earnings calls, where they have discussed the associated costs.

Exposure to HRS in the EU is now concentrated in a small number of Member States. There are approximately 100 5G networks in the EU, of which, at the beginning of 2026, 60 were supplied by trusted vendors (Samsung, Nokia, and Ericsson). Approximately 10 additional networks will be supplied exclusively by trusted suppliers by the time the Cyber Security Act (CSA 2) comes into effect, following the national implementation of the 5G Toolbox.

Approximately 30 networks still have between 35 and 100 percent of their radio access network (RAN) supplied by High-Risk Suppliers. This does not apply to the core network, which has already been upgraded for 5G using trusted suppliers. These networks are owned and operated by a limited number of operators across Europe that made a commercial decision to retain High-Risk Suppliers when upgrading their 4G equipment to 5G, and they continue to do so as of early 2026. These operators should have understood, based on the action taken by the European Commission and at least half of the EU Member States under the 5G Toolbox, that this was not a prudent decision.

A substantial share of the equipment scheduled for replacement over the next five years is concentrated in Germany (Vodafone, O2, and Deutsche Telekom), Italy (Vodafone and Wind Tre), and Spain (MasOrange and Vodafone). Based on Strand Consult’s analysis, combined with figures from the EU’s Regulatory Impact Assessment as well as the underlying figures, these three countries make up over 55% of equipment that must be replaced over the next five years, which presents the opportunity to replace the supplier.

Vodafone and Deutsche Telekom (DT) are particularly significant in this context. DT operates across multiple countries with varying levels of exposure to high-risk suppliers, including Germany (58%), Greece (100%), Austria (100%), the Czech Republic (100%), Croatia (50%), and Poland (70%). In addition, its subsidiary T-Systems resells cloud solutions built and operated on Huawei infrastructure. Vodafone is also heavily exposed in several European markets, including 100% reliance on Huawei in the Czech Republic, Greece, Hungary, and Romania, as well as 67% in Spain and 53% in Germany.

To put it bluntly, the GSMA Intelligence report is an attempt to justify a strategic and willful mistake. It attempts to defend of the operators that knowingly upgraded their 4G networks to 5G with High-Risk Suppliers despite the clear direction set by all 27 EU Member States. These companies claim to be guardians of critical national infrastructure while choosing not to implement the security measures that Europe agreed were necessary to protect its citizens, businesses, and public authorities. The report ultimately illustrates the cost of those decisions—and why investors should pay close attention.

Strand Consult believes the report should be part of the debate on CSA2. However, based on nearly a decade of research in this field, the report’s claims and calculations should be subject to rigorous fact-checking rather than accepted at face value. Instead of relying on GSMA’s theoretical estimates, policymakers should examine the actual experience of operators across Europe that have successfully replaced High-Risk Suppliers with Trusted Suppliers as part of their 4G-to-5G upgrades.

Strand Consult hopes that policymakers, regulators, and other stakeholders will be given access to the report’s underlying assumptions and calculations. These should be evaluated against the real-world experience of the many EU operators that have already completed, or are in the process of completing, the phase-out of High-Risk Suppliers.

The discussion should also address accountability for the commercial decisions made by those operators that chose not to implement the EU’s 5G Toolbox despite the clear political direction established in 2019. For these operators, CSA2 should not come as a surprise. They made a deliberate decision to retain High-Risk Suppliers in their networks while simultaneously investing significant resources in lobbying efforts to preserve the continued use of those suppliers.

GSMA Intelligence’s Cost Estimates

Strand Consult has reviewed the cost estimates presented by GSMA Intelligence. The following summarizes its findings.

1. GSMA presents this as a disruptive “rip-and-replace” scenario. In reality, the actual process is a phased replacement and network upgrade over a period of months or years. The issue is not the immediate removal of existing equipment but the gradual phase-out of High-Risk Suppliers (HRS) as networks are upgraded.

2. GSMA’s estimated costs are several times higher than those calculated by the EU, Strand Consult, and others. Strand Consult does not agree with the methodology or the conclusions underlying the GSMA’s estimates.

3. The cost estimates fail to reflect the actual distribution of HRS exposure. GSMA presents the costs as if they affect all European operators equally. In reality, these costs primarily affect the approximately 30 out of 100 operators that have chosen to retain HRS in their networks.

4. These costs are the result of commercial decisions. They affect operators that consciously chose to continue using HRS despite the EU’s 5G Toolbox and upgraded their 4G networks to 5G while retaining HRS in all or part of their radio access networks.

5. GSMA claims that the trusted equipment replacing HRS will consume more energy than the equipment currently in use. Strand Consult finds this claim difficult to reconcile with technological developments but assumes GSMA can provide supporting documentation. The technical specifications for equipment from all major vendors are publicly available on the manufacturers’ websites.

6. GSMA Intelligence’s central claims about deployment are contradicted by established facts, publicly available data, and the real-world experience of European operators. GSMA states, “Operators have highlighted that, notwithstanding the costs involved, the extremely tight timelines proposed to remove HRS from the RAN are also likely to create significant disruption to services for users and risks to network resilience.” Denmark provides a useful case study. Two of the country’s three mobile networks previously relied on HRS, yet Denmark now has Europe’s highest-performing 5G infrastructures according to multiple independent studies.

7. The report relies on highly questionable, conflicted sources. On page 7, GSMA cites a report by CCCEU-KPMG, which estimates the cost of CSA2 at €57 billion. What is rarely acknowledged is that CCCEU is the China Chamber of Commerce to the EU. In other words, the report cited by GSMA is a submission from an organization representing Chinese commercial interests. It should also be noted that the report was prepared by KPMG China, not by a European KPMG firm.

8. The credibility of the CCCEU-KPMG report demands scrutiny. Strand Consult participated virtually in the launch event hosted by the China Chamber of Commerce to the EU and submitted 13 questions to CCCEU and KPMG regarding the report’s methodology and conclusions. To date, none of those questions has been answered. That lack of transparency should be taken into account when assessing the report’s findings.

It is reasonable to debate whether the Chinese companies affected by CSA2 are correct in claiming that the regulation will cost the EU €57 billion. It is equally reasonable to examine the GSMA’s estimate that CSA2 will cost between €30 and €40 billion, as well as the European Union’s own risk assessment underpinning the proposal. Strand Consult has followed this issue for many years with the objective of increasing transparency in a debate where key assumptions and calculations have often received limited scrutiny.

Germany provides a useful case study. Approximately 58 percent of the country’s mobile sites—equivalent to around 46,000 sites—still use Huawei 5G RAN equipment. Based on Strand Consult’s research, replacing this equipment with 5G RAN equipment from trusted suppliers would cost approximately €50,000 per site. This results in an estimated total replacement cost of €2.5 billion, distributed approximately as follows: Deutsche Telekom: €1.1 billion; Vodafone Germany: €0.7 billion; and Telefónica Germany: €0.7 billion.

For comparison, Deutsche Telekom is estimated to invest approximately €300 million annually in RAN infrastructure in Germany. Viewed in this context, replacing all Huawei 5G RAN equipment represents a one-time capital investment rather than a recurring operating cost.

Expressed differently, the total replacement cost is equivalent to approximately €29 per German citizen. This provides a useful benchmark for assessing the economic impact of replacing High-Risk Suppliers.

Strand Consult welcomes the fact that GSMA Intelligence has attempted to quantify the cost of securing Europe’s digital infrastructure. Whether the one-time cost is €10, €20, €30, or €40 per European citizen is an important policy question. That figure should also be considered alongside the potential economic and security consequences of allowing vulnerabilities to persist in Europe’s telecommunications infrastructure, including the risk of disruption to critical communications services.

Put differently, if the one-time investment required to secure Europe’s telecommunications infrastructure amounts to the price of 10 to 40 cups of coffee, the relevant policy question is whether that is a reasonable premium for reducing reliance on High-Risk Suppliers operating under the jurisdiction of the People’s Republic of China.

Unfortunately, GSMA has chosen not to engage with this issue, despite repeatedly emphasizing the important role that telecommunications operators play in providing secure digital infrastructure for modern society. Strand Consult has examined these risks in detail in the research note Eight Risks for the 5G Supply Chain from Suppliers Under the Influence of Adversarial Countries Like China. The credibility of the GSMA’s position is weakened by its failure to address the security risks arising from the continued use of High-Risk Suppliers by a limited number of European operators. A balanced assessment of CSA2 should consider not only the costs of replacing High-Risk Suppliers, but also the costs and risks of maintaining them.

Europe has already experienced the strategic and economic costs of dependence on an authoritarian adversary. The continent’s reliance on Russian gas provides a clear example. Former German Chancellor Gerhard Schröder was one of the strongest advocates of that policy, arguing that his friend Vladimir Putin would never use energy as a geopolitical weapon. History proved otherwise. See coverage of Schröder’s relationship with Putin: Germany’s SPD calls on Gerhard Schröder to quit party over Russia links.

The question for Europe’s telecommunications sector is whether it is repeating a similar mistake by underestimating the strategic risks associated with dependence on High-Risk Suppliers. Strand Consult believes that policymakers, investors, and industry leaders should draw the appropriate lessons from Europe’s experience with Russian energy. Security dependencies are often defended on commercial grounds—until geopolitical events demonstrate that the underlying assumptions were flawed.

Europe’s Investment Challenge Is Not Caused by Trusted Suppliers

The GSMA Intelligence report devotes considerable attention to Europe’s investment gap. Strand Consult agrees that Europe faces a significant investment challenge, driven by a combination of excessive regulation and, in some cases, poor management decisions by operators. This has been a recurring theme in Strand Consult’s research for more than 25 years. The fact remains that countries such as the United States, South Korea, Japan, and India have developed stronger 5G infrastructure than Europe, despite all having chosen to exclude High-Risk Suppliers (HRS) from their networks.

From a consumer perspective, it is difficult to identify any tangible benefits delivered by the approximately 30 European operators that chose to retain HRS in their networks. These operators do not offer lower prices or higher-quality networks than operators that decided to deploy trusted suppliers.

Strand Consult’s research also shows no correlation between the continued use of HRS and stronger financial or operational performance. This is not surprising. Mobile operators typically invest around 12 percent of their revenue in capital expenditures (CapEx), of which approximately 25 percent is allocated to the radio access network (RAN). By comparison, the same operators typically spend between 20 and 25 percent of their operating costs on sales and marketing—an expenditure that has remained largely unchanged over the past five to eight years. This suggests that the financial impact of replacing HRS should be assessed within the broader context of operators’ overall cost structures rather than in isolation.

Inconsistent Arguments on Competition and Investment

GSMA Intelligence writes: “Wider economic consequences could be material. High-quality connectivity underpins productivity, innovation and competitiveness across manufacturing, logistics, healthcare and public services. Slower deployment of advanced networks would therefore dampen broader economic performance.”

Strand Consult agrees that investment in advanced telecommunications infrastructure is essential for economic growth. However, this argument appears difficult to reconcile with the GSMA’s longstanding position that declining ARPU in Europe is one of the sector’s fundamental challenges. On the one hand, the GSMA argues that operators need higher returns to support investment. On the other hand, it argues that measures intended to strengthen network security should be avoided because they may increase operators’ costs. These positions are not easily reconciled.

The report also argues that the implementation of CSA2 will reduce competition among infrastructure suppliers and lead to higher equipment prices. Strand Consult finds little empirical evidence to support this conclusion. Operators in countries that have already phased out High-Risk Suppliers have not experienced cost increases of the magnitude suggested by the GSMA. Moreover, infrastructure equipment is priced in a global market in which Europe represents only about 12 percent of global RAN demand. It is therefore difficult to argue that European security policy alone will determine global equipment prices.

The GSMA has, for many years, argued that consolidation among mobile operators is necessary because many European markets have too many operators to generate sustainable returns. It is therefore noteworthy that the report presents consolidation among infrastructure suppliers as inherently problematic. The underlying logic appears inconsistent: consolidation is portrayed as beneficial when it involves the GSMA’s members but harmful when it affects infrastructure vendors.

It is also worth noting that the consolidation of the RAN equipment market has not been driven primarily by government regulation. Rather, it has been shaped by the purchasing decisions of mobile operators themselves. Over the past two decades, the number of major RAN suppliers has fallen from more than twenty to only a handful. During the same period, equipment prices have generally declined rather than increased. Strand Consult has documented these developments in its research note, What Creates Competition in the Telecommunications Industry? Can the Number of Mobile Operators Be Compared with the Number of Infrastructure Equipment Providers Like Huawei, Ericsson, Nokia, Samsung and Others?

If Vodafone genuinely believes that competition in the infrastructure market is critical, it is difficult to reconcile that position with its own procurement decisions. During its £2 billion-plus national network modernization following the merger of Vodafone and Three in the UK, the company chose to discontinue its relationship with Samsung for its radio access network (RAN) deployment, instead selecting Nokia and Ericsson as its suppliers. This decision suggests that, in practice, operators prioritize factors such as technology, performance, commercial terms, and long-term strategy over simply maximizing the number of equipment vendors.

The report also raises broader questions about the consistency of the GSMA’s position on infrastructure competition. In China, the market is overwhelmingly served by two suppliers, Huawei and ZTE. Strand Consult is not aware of the GSMA expressing concern that this level of supplier concentration undermines infrastructure competition or harms Chinese mobile operators. If supplier concentration is considered problematic in Europe, it would be reasonable to ask whether the GSMA applies the same standard to the Chinese market. Clarification of the GSMA’s position on this point would contribute to a more consistent discussion of competition policy.

Does the GSMA Take National Security Seriously?

Reading the report, together with the GSMA’s broader public statements, suggests that the organization wishes to present its members as responsible providers of secure digital infrastructure. The difficulty is that the report concerns a relatively small group of operators that chose to continue deploying High-Risk Suppliers (HRS) when upgrading their 4G networks to 5G, despite the policy direction established by the EU’s 5G Toolbox in 2019.

The report does not question the concept of High-Risk Suppliers. On the contrary, the GSMA’s public communications implicitly acknowledge that HRS represents a legitimate policy concern. At the same time, several operators continue to argue privately and publicly that there is little or no security risk associated with equipment supplied by Chinese vendors. Strand Consult believes the GSMA should clearly explain its position. If the organization believes that the European Union, NATO members, and national security authorities have overstated the risks associated with High-Risk Suppliers, it should say so openly and present the evidence supporting that view.

The operators that continued to deploy High-Risk Suppliers after the introduction of the EU’s 5G Toolbox made a deliberate commercial decision that was inconsistent with the direction established by the European Union and subsequently implemented by many Member States. Those operators accepted regulatory, financial, and geopolitical risks that were both foreseeable and avoidable. The principal High-Risk Suppliers are headquartered in China, a country that has declared a “no limits” strategic partnership with Russia and maintains close strategic relationships with Iran and North Korea. These geopolitical realities form part of the rationale behind the EU’s security framework.

Today, Europe’s operators broadly fall into two categories. The first consists of operators that recognized the implications of the EU’s 5G Toolbox and adapted their procurement strategies accordingly by transitioning to trusted suppliers. The second consists of operators that chose to retain High-Risk Suppliers as part of their 5G deployment strategy despite the changing regulatory environment. As the implementation of CSA2 progresses, the first group enters the new regulatory framework with significantly lower transition costs and greater regulatory certainty. They are also better positioned to offer networks built on suppliers that the EU and many NATO members regard as trusted.

By 2026, the continued deployment of High-Risk Suppliers is difficult to defend from a national security perspective. The policy direction has been clear for more than 14 years. Since Australia first acted in 2012, governments and security authorities across democratic countries have consistently concluded that telecommunications infrastructure should not rely on suppliers that pose unacceptable security risks.

GSMA Intelligence: Repeating Familiar Arguments

In its report, GSMA Intelligence largely recycles arguments GSMA has presented for nearly a decade. The report introduces few new facts or analytical perspectives. Many of its central claims have already been examined and challenged by Strand Consult and other researchers. Most recently, Strand Consult addressed these issues in the research note, Eight Risks for the 5G Supply Chain from Suppliers Under the Influence of Adversarial Countries Like China,

The GSMA Intelligence report states: “CSA2 also introduces, for the first time, an EU-level timeline: a mandatory phase-out of high-risk vendors from 5G core and RAN networks within three years of the CSA passing into law.”

What the report does not explain is the broader policy timeline. The process began in 2018, when concerns about High-Risk Suppliers first emerged as a major policy issue in Europe. CSA2 is expected to take effect in 2028, after which the remaining operators will have three years—until approximately 2031—to complete the phase-out. In practice, the transition period extends over roughly 13 years, not three.

Today, approximately 70 of Europe’s 100 mobile networks have already adapted to this policy direction. Many Member States have implemented the EU’s 5G Toolbox, and most operators have stopped purchasing equipment from High-Risk Suppliers and have upgraded their networks using trusted suppliers. For these operators, the transition has been gradual rather than abrupt. The three-year period under CSA2 primarily affects the limited number of operators that chose to continue deploying High-Risk Suppliers after the policy direction became clear.

It is also noteworthy that the report states: “This relies on GSMA Intelligence Network Tracker data to assess whether an operator has HRV equipment active in their mobile network that would require replacing.”

This suggests that GSMA Intelligence maintains operator-level information on the continued deployment of High-Risk Suppliers. If so, publication of this information would contribute to greater transparency for policymakers, regulators, investors, and other stakeholders by identifying which operators have continued to rely on High-Risk Suppliers since 2019.

The methodology section also indicates that GSMA Intelligence models the issue as a “rip-and-replace” exercise. That assumption does not reflect the approach adopted by European governments. In practice, countries have generally followed a “stop buying and upgrade with trusted suppliers” strategy, replacing High-Risk Suppliers as part of the normal network modernization cycle rather than through immediate replacement. Consequently, the analytical model underlying the report differs from the implementation model adopted in practice.

The report also assumes that the replacement cost per subscriber is broadly similar regardless of an operator’s level of exposure to High-Risk Suppliers. Under this methodology, an operator with 100 percent High-Risk Supplier deployment is treated similarly to one with only 30 percent exposure. Likewise, the model does not appear to distinguish between operators using a High-Risk Supplier in the radio access network only and those also relying on a High-Risk Supplier for the mobile core. These assumptions are difficult to reconcile with the actual diversity of network configurations across Europe. By the beginning of 2026, approximately 95 percent of mobile core networks in the European Union were already supplied by trusted vendors.

The report’s methodology is supported by the practical experience of European operators. The report largely repeats arguments that have been made for years, yet the experience of operators that have already completed—or are well advanced in—the transition away from High-Risk Suppliers has not produced evidence consistent with the report’s principal conclusions.

The United Kingdom provides a useful example. When the UK decided in 2020 to phase out High-Risk Suppliers, operators advanced many of the same arguments presented in the GSMA Intelligence report regarding costs, disruption, and implementation challenges. Once the transition was implemented, the actual costs proved to be substantially lower than initially claimed. Strand Consult has documented this experience in the following research note: New Figures from Strand Consult: Fact-Checking Operators’ Claims About the Impact of the European Commission’s Cybersecurity Act 2

Conclusion

GSMA Intelligence has produced a report that raises important policy questions. However, Strand Consult does not believe that its methodology or conclusions are supported by the available evidence.

The report presents the implementation of CSA2 as a challenge affecting Europe’s telecommunications sector as a whole. In reality, the issue is concentrated among a relatively small number of operators and Member States that chose to continue deploying High-Risk Suppliers after the EU established its 5G Toolbox in 2019. Approximately 70 of Europe’s 100 mobile networks have already adapted to this policy direction. The remaining transition costs are therefore concentrated among the operators that made a different commercial decision.

Strand Consult also disagrees with the report’s estimates of the costs and consequences of implementing CSA2. The analysis relies primarily on theoretical modelling rather than the practical experience of operators that have already completed, or are well advanced in, the transition to trusted suppliers. Many of the report’s principal claims have been tested in practice and have not been supported by the experience of European operators.

The United Kingdom provides an instructive example. During BT’s investor call on 30 January 2020, the company estimated that complying with the UK’s Huawei restrictions would cost approximately £100 million per year over five years. BT also explained that much of this represented the acceleration of planned investment rather than entirely new expenditure. The estimated annual impact corresponded to approximately 2.4 percent of BT’s annual network capital expenditure. Importantly, the UK’s restrictions covered both mobile and fixed broadband infrastructure.

Rather than relying primarily on evidence from such real-world implementations, GSMA Intelligence places considerable weight on external studies, including a report prepared by the China Chamber of Commerce to the EU and KPMG China. Readers should consider the origin, methodology, and assumptions of those reports when evaluating their conclusions.

The report also argues that reducing the number of infrastructure suppliers will weaken competition. Yet the consolidation of the global RAN equipment market has largely been driven by the purchasing decisions of mobile operators themselves. Recent procurement decisions, including VodafoneThree UK’s decision to deploy Nokia and Ericsson rather than Samsung, demonstrate that operators continue to shape the structure of the supplier market through their commercial choices.

Finally, if supplier concentration is considered a concern in Europe, the same analytical standard should also be applied to other markets. China’s mobile infrastructure market is overwhelmingly supplied by Huawei and ZTE, yet GSMA has not publicly argued that this level of supplier concentration represents a competition concern. Applying consistent principles across markets would strengthen the credibility of the debate.

CSA2 should ultimately be assessed on the basis of evidence rather than assumptions. More than a decade of policy development and several years of practical implementation across Europe provide a substantial body of experience from which to draw conclusions. Strand Consult believes that future discussions should rely on those empirical outcomes rather than theoretical models that are not reflected in the experience of operators that have already completed the transition to trusted suppliers.

This inconsistency extends beyond the GSMA Intelligence report. It is reflected more broadly in the GSMA’s public communications, including the news and analysis published under the Mobile World Live brand. The GSMA has consistently emphasized the need for a stronger and more competitive European telecommunications sector while giving comparatively little attention to the implications of continued reliance on High-Risk Suppliers.

Europe needs a regulatory framework that encourages investment, innovation, and consolidation. For many years, Strand Consult has published research documenting why excessive regulation has weakened the competitiveness of the European telecommunications industry relative to markets such as the United States, South Korea, and India.

However, advocating regulatory reform should not come at the expense of national security. The credibility of the industry’s policy agenda is weakened when the same organizations argue that telecommunications operators provide critical national infrastructure while simultaneously defending, or seeking to delay the phase-out of, High-Risk Suppliers that European governments have concluded should no longer form part of that infrastructure.

Rather than focusing on practical solutions for the relatively small number of operators that continued to deploy High-Risk Suppliers after 2019, the report attempts to portray their commercial decisions as a challenge for the entire European telecommunications sector. The evidence suggests otherwise. The transition to trusted suppliers has already been completed, or is well underway, across most European mobile networks. The remaining costs are the consequence of commercial decisions made by a limited number of operators despite more than a decade of evolving security policy and clear regulatory signals from the European Union.

Over the past eight years, Strand Consult has published extensive research on the security, economic, and competitive implications of relying on High-Risk Suppliers. That research has consistently challenged many claims made by both certain operators and High-Risk Suppliers regarding the costs and consequences of supplier replacement.

The evidence from Europe is clear. Countries and operators that implemented the EU’s 5G Toolbox have successfully transitioned to trusted suppliers while maintaining competitive 5G deployment and network performance. At the same time, some operators continue to argue that they play a critical role in national security while choosing to retain High-Risk Suppliers in their networks. As national security becomes an increasingly important consideration for governments, regulators, investors, and enterprise customers, that position is becoming progressively more difficult to justify.

Feedback and questions about this note can be directed to Strand Consult CEO John Strand.