The Regulatory Landscape for Private Wireless Spectrum Allocation across Different Regions

Abstract

The global telecommunications landscape is experiencing a fundamental change, driven by the democratization of wireless spectrum access. As Industry 4.0, the Internet of Things (IoT), and mission-critical industrial applications grow, the traditional model of exclusive, nationwide spectrum licensing held by Mobile Network Operators (MNOs) is becoming inadequate to meet the complex needs of "vertical" industries—manufacturing, logistics, healthcare, energy, and utilities. In response, regulators across North America, Europe, and the Asia-Pacific have developed diverse regulatory frameworks to enable Private 5G (P5G) and Private LTE (PLTE) networks. This paper offers a comprehensive comparative analysis of these regulatory systems. It examines the three-tiered dynamic sharing model of the United States’ Citizens Broadband Radio Service (CBRS), Germany’s BNetzA’s administrative "campus network' licensing, the hybrid Shared Access License (SAL) system of the United Kingdom’s Ofcom, and the dedicated "Local 5G" and "e-Um 5G" programs in Japan and South Korea, respectively. By analyzing spectrum bands (especially the differences among bands n78, n77, n79, and n48), licensing economics, device ecosystem maturity, and deployment data, this paper highlights the tension between policy goals and market realities. It concludes that although regulatory approaches vary—from market-driven auctions to nominal administrative fees—the overall trend worldwide is clearly toward localized, enterprise-controlled spectrum