VodafoneThree’s merger scorecard is redacted: buy coverage by contract

On 29 September the Competition and Markets Authority (CMA) published VodafoneThree’s first annual progress report on its Network Commitment, the legally binding network build on which the CMA cleared the merger of Vodafone and Three. The document, a nine-page slide deck dated 26 June 2026, is the first report on progress against that promise that the CMA has published. Most of its numbers have been removed.

What survives is VodafoneThree’s verdict on itself. “VodafoneThree is on course to meet the Year 3 Network Commitment target, having exceeded its informal Year 1 target by the end of the first Reporting Year,” the report says. The only figure offered in support is a percentage: 103.26% of that informal target. The target, the number of sites upgraded and every breakdown beneath them are withheld.

That matters to businesses that buy mobile connectivity from Vodafone and Three, whether for fleets, field teams or connected devices. They are being asked to take “on course” on trust. Businesses should write the coverage and performance they need into their own contracts, because the national commitment is owed to regulators, not to any one customer.

What the report withholds

The final undertakings the CMA accepted on 28 March 2025 require VodafoneThree to report each year on its total upgraded sites, their split between urban and rural areas and between high-, mid- and low-configuration sites, and 4G and 5G coverage for the UK and each of its four nations. The same undertakings let the company remove competitively or commercially sensitive information from the published version, subject to CMA approval.

It has used that room. The site table withholds every count and shows only the 103.26% total against a 100% target. The coverage table gives UK figures but blanks the columns for all four nations, along with four entire rows whose labels are also removed. The 5G C-band coverage achieved by early network sharing is redacted for both brands. The undertakings themselves blank the Year 3 and Year 5 site targets; only the Year 8 total appears, and then only as a range of 25,000 to 30,000 sites.

What the published figures measure

The figures that remain are narrow. They show coverage at the end of the first reporting year, which the undertakings define as the 12 months from completion; the companies said the merger completed on 31 May 2025. Each figure appears twice, for “Combined Vodafone” and “Combined Three”, meaning each legacy network plus the upgraded network.

UK 5G population coverage, across all 5G bands, rose from 63.43% to 67.38% for Vodafone and from 71.56% to 75.75% for Three, gains of 3.95 and 4.19 percentage points. Geographic 5G coverage moved from 15.87% to 16.62% for Vodafone and from 23.09% to 26.40% for Three. On 4G, population coverage is above 99% on both, at 99.32% and 99.73%.

None of these is a 5G standalone (SA) figure, the measure VodafoneThree’s own network page uses for its pledge of 99% population coverage by 2030. The speed figures need care too: 226Mbps for Three and 173Mbps for Vodafone, described as national average maximum available download speeds from NetCheck, a third-party benchmarking service. The report gives no test period and no Year 0 comparison. It says 2x20MHz of 1800MHz spectrum has been activated at almost 15,000 sites on Three’s grid, and early multi-operator core network (MOCN) sharing, which runs on existing radio sites without the need for an upgrade, at more than 10,000. It puts the change in 4G low-band geographic not-spots resulting from that sharing at 26.31% for Three and 14.45% for Vodafone.

Who checks the numbers

The detail exists; it goes elsewhere. The confidential report goes to Ofcom, the CMA and a monitoring trustee, Monitoring Trustee Partners, whose appointment the CMA approved on 25 April 2025. Within a month of each report the trustee must give Ofcom and the CMA its assessment of the integrity of the systems and models behind the data and of VodafoneThree’s progress toward compliance. That assessment is not on the CMA’s case page. Under a joint statement from June 2025, Ofcom has primary responsibility for monitoring and is the starting point for any enforcement; the commitment is also a condition of the operator’s spectrum license.

Vodafone became sole owner of VodafoneThree on 30 July 2026 after buying out CK Hutchison, and the CMA said the undertakings “remain unchanged and in full effect”.

The redactions are within the rules: the undertakings allow them, subject to CMA approval. The problem for customers is that the regime is built for regulators. Its binding targets count sites, not pounds and not the service at any one depot or on any one route. The £11bn headline comes from the companies, which said on completion that VodafoneThree “will invest £11 billion over the next 10 years”.

Put the pledge in the contract

Businesses should treat the national commitment as background, not as a term of supply. The retail tariff protections in the undertakings apply to consumer retail customers. A business customer gets none of them, and cannot see from the published report how coverage is changing in any of the four nations.

The fix sits in procurement. Buyers should name the sites, postcodes and routes that matter and ask for indoor and outdoor coverage commitments at each, with 4G, 5G and 5G SA stated separately where the use case depends on them. They should set measured performance floors rather than “maximum available” speeds, agree who tests and how often, and attach service credits or exit rights to missed levels. Any price rise justified by network investment should be tied to coverage delivered at their own locations.

VodafoneThree’s postcode checker shows customers what has changed in their area, but a marketing tool is not a contractual commitment. Until the public scorecard shows more than a percentage of a hidden target, the only network pledge a business can enforce is the one in its own contract.