Malaysian Communications and Multimedia Commission

Suruhanjaya Komunikasi dan Multimedia Malaysia

Public Inquiry Report

Review of the Mandatory Standards for Quality of

Service (Wireless Broadband Access Service) –
Determination No.2 of 2021

20 December 2023

This Public Inquiry Report was prepared in fulfilment of Sections 61 and 65 of the
Communications and Multimedia Act 1998
Public Inquiry Report on MSQoS (Wireless Broadband Access Service)

Content

Section
1 Summary of the Public Inquiry…………………….……………………………………………… 3
1.1 Introduction……………………………………………….…………………………………………………. 3
1.2 Public Inquiry Exercise……………………………….………………………………………………… 4
1.3 Structure of the Public Inquiry Report…………….………………………………………….. 5
2 Public Inquiry Input & Commission’s View…………………………………………………… 6
2.1 Revision on the Interpretation Part..……………………………………………………………. 6
2.2 Revision on the QoS Standards…….…………………………………………………………….. 7
2.3 Revision of the Applicable Guidelines……….…………………………………………………. 34
3 The Way Forward…………………………………………………………………………………………. 43

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1. Summary of the Public Inquiry

1.1. Introduction

1.1.1. The Mandatory Standards for Quality of Service (“MSQoS”) for Wireless
Broadband Access Service encompass two main aspects; the performance of
data delivery over internet protocol and the perceived quality of experience
(QoE) for consumers. This review specifically delves into the performance
evaluation of mobile broadband systems for 4G and 5G networks within
Malaysia.

1.1.2. The Public Inquiry (“PI”) concerning the revised MSQoS prioritizes network
performance parameters identified by the Malaysian Communications and
Multimedia Commission (“MCMC”) as pivotal for enhancing end-user
experience and enabling more effective monitoring of network capacity,
ultimately aiming for improved service delivery.

1.1.3. Notably, the revised MSQoS establishes two sets of Key Quality Indicators
(“KQI”) which are the “Mandatory KQI” and the “Monitoring KQI”. The
Mandatory KQI monitors and enforces the parameters in the standards, while
the Monitoring KQI monitors the parameters for improvement purpose.
Generally, the Monitoring KQIs apply specifically to 5G network operating in
the IMT frequency band 703 MHz to 743 MHz, 3.4 GHz to 3.6 GHz and 26.6
GHz to 28.1 GHz, which are currently undergoing migration from Single
Wholesale Network (“SWN”) to Dual Network model.

1.1.4. The proposed revisions in the MSQoS seek to guide the industry towards
delivering enhanced QoS and QoE to the consumers. These revisions draw
inspiration from benchmarks set by national regulatory authorities ("NRA")
in various countries, aiming to fortify and streamline the QoS framework to
accommodate present and future technologies. The revised MSQoS will take
effect upon the revocation of the existing MSQoS.

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1.2. Public Inquiry Exercise

1.2.1. In the PI issued on 3rd October 2023, the MCMC outlined the proposed QoS,
QoE and network performance parameters pertaining to:

i. Revision on the interpretation part of the standards;

ii. Introduction a n d revision of the QoS, QoE and network performance
parameters, measurement, standards, and notification; and
iii. Revision of the applicable guidelines.

1.2.2. The PI invited feedback from the public and relevant stakeholders on MCMC’s
proposed standards. The PI specifically sought comments for all proposed
revisions and the general views of the standards.

1.2.3. At the conclusion of the PI period, which ended at 12 noon on 21st November
2023, MCMC received eight (8) submissions from the following parties:

No. Submitting Parties

1 CelcomDigi Berhad (“CelcomDigi”)
2 Maxis Broadband Sdn Bhd (“Maxis”)
3 U Mobile Sdn Bhd (“U Mobile”)
4 Redtone Engineering & Network Services Sdn Bhd (“Redtone”)
5 Digital Nasional Berhad (“DNB”)
6 Rohde & Schwarz Malaysia Sdn Bhd (“RSMY”)
7 TM Technology Services Sdn Bhd (“TM Tech”)
8 YTL Communications Sdn Bhd (“YTLC”)
Table 1: List of respondents to the PI

1.2.4. MCMC considered these eight submissions where summary of comments and
suggestions are outlined in this report. The PI Report is presented within the
30-day requirement from the closing date of submissions, as stipulated under
section 65 of the Communications and Multimedia Act 1998 (“CMA98”).

1.2.5. MCMC proposes to issue a Commission Determination that will reflect the
Commission’s final views expressed in this PI Report in respect to the MSQoS
for Wireless Broadband Access Service.

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1.3. Structure of the PI Report

1.3.1. The remainder of this PI Report is structured to provide context for MCMC’s
questions for comments, as follows:

i. Section 2 provides the summary of input received on the proposed

changes and the Commission’s final views; and
ii. Section 3 highlights the way forward.

1.3.2. In the context of this PI, the terms “download throughput” or “upload
throughput” may be used interchangeably with “download speed” or “upload
speed”.

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2. Public Inquiry Input & Commission’s View

2.1. Revision on the Interpretation Part of the Standards

QUESTION 1: THE COMMISSION SEEK VIEWS ON THE INTERPRETATION
PART OF THE MANDATORY STANDARD FOR QUALITY OF
SERVICE (WIRELESS BROADBAND ACCESS SERVICE).

Submitting
Comments
Party
CelcomDigi Agrees with the proposal, with comment for the definition to
align with ITU standards.
Maxis Proposes for the following definition to be interpreted clearly:
• “ASP” means Applications Service Provider.
• “FWA” means Fixed Wireless Access.
• “HTTP” means Hypertext Transfer Protocol.
• “IMT” means International Mobile Telecommunications.
• “NSP” means Network Service Provider.
• “POI” means Point of Interconnection.
• “PRB” means Physical Resource Block.
U Mobile Agrees with the terms used which are consistent with ITU
standards of interpretation.
Redtone No comment provided.
TM Tech Proposes to include the following definition:
• National POI to include any location within the Klang
Valley and not limited to MYIX.
• Description of test location.
• Term “force majeure” to be properly defined and
clarified whether referring to an “event beyond control”
or “act of god”.
DNB Propose to remove “Klang Valley” from the test server
interpretation.
YTLC Propose to revise “end user” interpretation to “a person who
subscribes to or uses a wireless broadband access service and
includes customer”.
RSMY No comment provided.
Table 2: Response on interpretation part

Commission’s View

• The definition used in the revised MSQoS is based on International

Telecommunications Union (ITU) standards and the CMA98.

Conclusion:

• The Commission is of the view that the definition used which are based on ITU
and the CMA98 will be maintained.
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2.2. Revision on the QoS Standards

2.2.1. Download Throughput

QUESTION 2: THE COMMISSION SEEK VIEWS ON THE PROPOSED

STANDARD ON DOWNLOAD THROUGHPUT FOR THE
MANDATORY STANDARD FOR QUALITY OF SERVICE
(WIRELESS BROADBAND ACCESS SERVICE).

Technology Proposed KQI Mandatory /

Monitoring
• 4G or 5G (all allocated Download throughput for each Mandatory
IMT frequency band location measured shall be at or
other than 703 – 743 not less than:
MHz, 758 – 798 MHz, i) 7.7 Mbps until 31 December
3.4 – 3.6 GHz and 26.5 2024; and
– 28.1 GHz) ii) 10.0 Mbps from 1 January
2025 onwards,
averaged based on all test
sample.
• 5G (allocated IMT Download throughput for each Monitoring
frequency band in 703 – location measured shall be at or
743 MHz, 758 – 798 not less than 100 Mbps,
MHz, 3.4 – 3.6 GHz and averaged based on all test
26.5 – 28.1 GHz) sample.
• 4G and 5G (all allocated Download throughput for each Mandatory
IMT frequency bands, state and federal territories for
for a specific area) all technology (4G and 5G)
shall be at or not less than 50
Mbps, averaged based on all
test sample measured for each
quarter.
Table 3: Proposal for download throughput KQI

Submitting
Comments
Party
CelcomDigi • Disagrees with the proposal and proposed that the average
download throughput for each location shall be at or no less
than 5 Mbps applied within coverage area from 2024
onwards, and to remove the average 10 Mbps download
throughput from 1 January 2025 onwards.
• Propose to defer the download throughput per state and
federal territories, and 5G download speed monitoring until
5G dual network has matured.
• The reference to the Germany consultation report is
applicable within mixed technology of 4G and 5G. Thailand
regulated download speed of 2.5 Mbps for 4G and 5 Mbps
for 5G network while no QoS requirement for Singapore.
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• The proposed download speed of 5 Mbps is sufficient for

1080p videos on mobile device screen as there is no
perceptible difference between 1080p and 4K resolution.
• In addition, 5 Mbps download speed is also sufficient for
good mobile gaming experience, emails, music streaming,
web browsing and video streaming.
• A minimum of 100 MHz bandwidth is recommended for
robust 5G performance. The 700 MHz band with 40 MHz
bandwidth may not meet the requirement. At present, 700
MHz serves as an anchor band for the 5G non-standalone
(NSA).

Maxis • Disagrees with the proposal and proposed the download

throughput for 4G service to be set at least 5 Mbps by static
test at a location declared in the coverage map.
• Proposes to defer the download throughput per state and
federal territories for all technology until the 5G penetration
reaches the target set by the dual networks, e.g., 80%
population coverage.
• Download speed of 5 Mbps is sufficient to support full HD
video streaming and other common OTT applications.
Furthermore, video codec will continue to improve, resulting
in lower throughput requirements for the same video quality.
• In Germany, more spectrum was allocated to the service
providers and without technology restriction. Therefore,
higher standards are set.
• Malaysian leading MNOs have significantly less spectrum
compared with those in other countries, thus poses a
challenge to cater for future data growth.
• Malaysia just started the 5G service in 2022-2023.
Therefore, it is still premature to start measuring and
enforcing for 5G service. The countries benchmark by MCMC
started 5G service earlier, for example Germany and
Thailand started 5G rollout since 2019.

U Mobile • Disagrees with the proposal and proposed to maintain

existing 2.5 Mbps download throughput standard for 4G.
• Propose to defer download throughput for all technologies
per state and federal territories and the 5G monitoring until
the 5G dual network reaches full maturity of deployment.
• Mobile operator in Germany has reached 75% to 80%
coverage population and utilized 700 MHz, 2100 MHz and
3600 MHz spectrum for 5G.
• The requirement for 5G monitoring applies only to 5G SWN
as the spectrum owner is the only one that has visibility on
their radio network and backhaul planning.
• It is unreasonable to include 5G measurement as mandatory
for download throughput for each state and federal
territories since 5G is set as monitoring indicator.
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Redtone • Disagrees with the proposal and recommends maintaining

the baseline of 2.5 Mbps.
• Proposed to defer 5G download throughput per location
requirement until finalization on 5G dual network.

TM Tech • Disagrees with the proposal and proposed to retain existing

2.5 Mbps download throughput standard.
• Propose to defer download throughput for each state and
federal territories for combined technology until 5G
penetration more than 50%.
• Substantial investment over the next 3 years will be required
to achieve the proposed download throughput of 7.7 Mbps
in 2024 and 10 Mbps by 2025.
• The industry’s current priority is to strengthen 5G coverage
and availability and to increase 5G subscription.
• Currently there are constraints in carrier aggregation for LTE
FDD band 5, TDD band 38 and 40. Due to significant
difference in the frequency ranges and not harmonized,
effective aggregation is technically challenging.
• LTE enabled device, including smartphone and network
equipment might not support carrier aggregation between
divergent LTE bands.

DNB • Agrees with the download throughput of 50 Mbps for each

state and federal territories proposal.
• In the event service providers unable to achieve 50 Mbps
download throughput and claim that it is due to 5G access
provider, service providers should provide relevant
information.
• Suggests increasing the minimum sample size to ensure the
target can be achieved with sufficient samples.

YTLC • Disagrees with the proposal and proposed to retain existing

download throughput of 2.5 Mbps.
• The review shall be made once the 5G network has matured.
Emphasis should be on encouraging users to use 5G service.
• Latest 5G coverage has exceeded 70%, however the uptake
is only 5.7% from the total mobile broadband subscribers.
• Current MSQoS was implemented only 2 years ago and
shown positive impact with the reduction of complaints by
65% in 2022 from 2021.
• Spectrum imbalances should be addressed before revision of
new MSQoS since it is the key factor for broadband
throughput.
RSMY • Proposes to replace average throughput with 10th and 90th
percentile throughput, or percentile value between 50th to
90th or median value.
• To apply weightage for test locations according to population
density.
• Download throughput of 100 Mbps for 5G monitoring is only
applicable for 26.5 GHz to 28.1 GHz due to bandwidth
limitation.
Table 4: Response to download throughput KQI
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Commission’s View

4G Download Throughput (per location):

• Germany standards are based on the study conducted to find the minimum internet
speed threshold, required for common user applications regardless of the type of
access network. The requirements set in the study include services such as emails,
search engines, education online tools, online newspaper, online shopping, job
searching tools, professional networking, internet banking, eGovernment services,
social media and video calls. The study concludes that download speed of 7.7 Mbps
is the minimum service criterion. However, Bundesnetzagentur (Germany NRA) has
opted to adopt 10 Mbps as the minimum requirement for download speed.

• This coincides with the Commission’s objective to improve the consumers’ minimum
internet access quality and close the gaps in "Consumer Satisfaction Index” which
was found based on the “Broadband QoE Survey” conducted by the Commission.

• The proposed standard was also based on benchmarking other national NRA. The
Federal Communication Commission (FCC) of the United States for example, has
published the “Broadband Speed Guide” which states that minimum download speed
for streaming HD video is between 5 – 8 Mbps and HD video teleconferencing
requires 6 Mbps.

• In addition, based on the on-field measurements conducted by MCMC, in order to

ensure good QoS and QoE to the end user, the download speed between 6-8 Mbps
is required. This supports the study mentioned above and explains why other
regulators are adopting higher download speeds for instance Germany and South
Africa.

• The 4G networks are highly relied upon for voice services. As Malaysia completed
the 3G shutdown, consumers are now relying on Voice over LTE (VoLTE) for voice
services which are delivered via 4G network.

• The Commission is anticipating that 4G traffic will still be dominant over the next 3
to 5 years until a higher 5G adoption rate is achieved. As of Oct 2023, 5G adoption
rate in Malaysia is at 10.8%. Based on the GSMA Mobile Economy 2023 Report, the
5G subscriber penetration rate in Asia Pacific will reach 71% by 2030. As such,
investment in improving 4G network quality is still relevant and necessary for the
next several years.

5G Download Throughput (per location):

• The 5G standards are considered under the Monitoring KQI considering the transition
from SWN to dual network.

• The proposed 5G download speed is aligned with the ITU-R M.2083 recommendation
and the license conditions.

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Download Throughput for 4G and 5G (per area)

• The combined 4G and 5G is to ensure that consumers are able to enjoy better mobile
broadband experience in a defined area.

• In addition, the combination of 4G and 5G download throughput measurement would

spur the 5G deployment and ensure a smooth transition from SWN to dual network.

Others:

• The proposed measurement methodology and calculation in the PI are aligned with
MCMC’s objective to meet user expectation.

Conclusion:

• The Commission is of the view that the proposed download throughput KQI to be
included in the MSQoS without any changes to the standards and methodology.

2.2.2. Upload Throughput

QUESTION 3: THE COMMISSION SEEK VIEWS ON THE PROPOSED STANDARD

ON UPLOAD THROUGHPUT FOR THE MANDATORY STANDARD
FOR QUALITY OF SERVICE (WIRELESS BROADBAND ACCESS
SERVICE).

Technology Proposed KQI Mandatory /

Monitoring
• 4G or 5G (all allocated Upload throughput for each Mandatory
IMT frequency band location measured shall be at or
other than 703 – 743 not less than:
MHz, 758 – 798 MHz, (i) 1.0 Mbps until 31 December
3.4 – 3.6 GHz and 26.5 2024; and
– 28.1 GHz) (ii) 1.3 Mbps from 1 January
2025 onwards,
averaged based on all test
sample.
• 5G (allocated IMT Upload throughput for each Monitoring
frequency band in 703 – location measured shall be at or
743 MHz, 758 – 798 not less than 5 Mbps averaged
MHz, 3.4 – 3.6 GHz and based on all test sample.
26.5 – 28.1 GHz)
Table 5: Proposal for upload throughput KQI

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Submitting
Comments
Party
CelcomDigi • Disagrees with the proposal and proposed to change the
upload throughput standard from mandatory to monitoring.
• Proposes to defer 5G upload throughput monitoring until 5G
dual network matured.
• Upload throughput requirement is a new initiative that
requires real-time data and network assessment, therefore
needs to establish a defined time frame during the
monitoring phase.
• 5G upload throughput performance is unclear due to the
sole operation by DNB.
Maxis • Disagrees with the proposal and proposed the 4G service
upload throughput to be set as monitoring.
• Proposes to defer related 5G upload throughput
measurement until 5G dual networks achieve 80%
population coverage.
• There is no historical data on upload throughput
measurement based on FTP testing. Hence, unable to
commit to the proposed upload throughput by MCMC.
U Mobile • Disagrees with the proposal and proposed to exclude upload
throughput from the mandatory requirement.
• Majority of the traffic is from the download direction, and
upload issues are often related to third party server.
Redtone • Disagrees with the proposal and proposed to defer the
implementation of 4G upload as mandatory requirement.
• Proposes to defer 5G upload throughput requirement.
TM Tech • Disagrees with the proposal and proposed to place the 4G
upload throughput to monitoring.
• Historical data during obtained during monitoring offers
valuable insights on the network performance concerning
upload throughput and potential areas for improvement.
DNB • Disagrees with the proposal and proposed MCMC to adopt
RAO target of 3 Mbps for NSA and 5 Mbps for SA for 5G
upload throughput.
• Traffic in 5G NSA for the initial implementation is carried in
the dual connectivity operation using 4G (700 MHz) and 5G
(3.5 GHz) radio access. If the upload traffic is using 700
MHz, it should not be subject to the same 5 Mbps upload
target for SA.
YTLC • Disagrees with the proposal and proposes that MSQoS
should not be amended yet until 5G has been fully rolled
out.
RSMY • Proposes to replace average upload throughput with 10th
and 90th percentile upload throughput, or percentile value
between 50th to 90th or median.
• To apply weightage for test locations according to
population density.
Table 6: Response to upload throughput KQI

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Commission’s View

4G Upload Throughput (per location)

• The Commission has allocated all mobile network operators with

spectrum in the coverage band and capacity band for nationwide
deployment. The operators need to increase the number of sites and
utilise all the spectrum that has been allocated to ensure good upload
speed for the consumers.

• The upload speed measurement would encourage operators to deploy

more low-band spectrum (i.e. sub-1GHz) to cater for user device
limitations (transmit power, antenna gain) for indoors and remote
areas.

• It is noted that deployment of low band in densely populated area may

increase the possibility of inter-cell interference, which may affect
service quality. However, the operators should be able to reduce the
effects with proper planning, optimisation and control, and make good
use of the allocated spectrum.

5G Upload Throughput (per location)

• 5G upload speed is to be in line with the 5G license condition and

separated into 5G Non-standalone (SA) for not less than 3 Mbps and
5G Standalone (SA), for not less than 5 Mbps.

Others

• The proposed measurement methodology and calculation in the PI is

aligned with MCMC’s objective to meet user expectation.

Conclusion

• We are of the view that 4G Upload Throughput KQI to be included in

the MSQoS under Monitoring KQI with the same threshold.

• We are of the view that 5G Upload Throughput KQI is separated into

5G NSA for not less than 3 Mbps and 5G SA, for not less than 5 Mbps.

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2.2.3. Latency

QUESTION 4: THE COMMISSION SEEK VIEWS ON THE PROPOSED

STANDARD ON LATENCY FOR THE MANDATORY STANDARD
FOR QUALITY OF SERVICE (WIRELESS BROADBAND ACCESS
SERVICE).

Technology Proposed KQI Mandatory /

Monitoring
• 4G or 5G (all allocated Latency should be at or not Mandatory
IMT frequency band more than 100 ms measured
other than 703 – 743 between end user to the test
MHz, 758 – 798 MHz, server in Klang Valley averaged
3.4 – 3.6 GHz and 26.5 based on all test sample.
– 28.1 GHz)
• 5G (allocated IMT Latency should be at or not Monitoring
frequency band in 703 – more than 40 ms measured
743 MHz, 758 – 798 between end user to the test
MHz, 3.4 – 3.6 GHz and server in Klang Valley averaged
26.5 – 28.1 GHz) based on all test sample.
Table 7: Proposal for Latency KQI

Submitting
Comments
Party
CelcomDigi • Agrees with the proposal for latency shall be at or no more
than 100 ms to test server in Klang Valley for test samples
in West Malaysia for mandatory requirement.
• Proposes latency shall be at or nor more than 150 ms to test
server in Klang Valley for test samples in East Malaysia for
mandatory parameter.
• Proposes to defer latency for 5G monitoring requirement
until 5G dual network matured.
• Beside radio access, backhaul also contribute to latency
performance, where many of them are managed by third
party or NFP. The cross-ocean connectivity increases the
latency especially packet data from Sabah and Sarawak.
• The architecture of 5G NSA spans from 5G radio access
network to the existing or upgraded core network, facilitated
by the same transport network for 4G.
Maxis • Agrees with the proposal for 4G latency of not more than
100ms based on static test conducted outdoor within the
declared coverage and indoor within areas served by in-
building coverage.
• Proposes to defer latency for 5G monitoring requirement
until the second 5G network roll-out achieves 80%
population coverage.

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U Mobile • Disagrees with the proposal and proposed to maintain

existing latency of not more than 150 ms for mandatory
requirement.
• Proposes to defer latency for 5G monitoring requirement
until 5G dual network matured.
• The reference made for Germany and Thailand also imposes
latency of not more than 150 ms for their standard.
Redtone • Disagrees with the proposal and proposed to maintain 4G
latency of not more than 150 ms for 90% of the time.
TM Tech • Agrees with the proposal on latency with condition to
maintain the minimum download throughput of 2.5 Mbps.
• Proposes to use test server in East Malaysia for testing in
Sabah and Sarawak.
DNB • Disagrees with the proposal and proposed MCMC to assess
whether 40 ms latency requirement for 5G monitoring is
feasible especially for locations in Sabah, Sarawak,
Southern, Eastern and Northern regions.
• Proposes to include provision for removal of areas or
districts with long distance from the POI and require MNO’s
investment for regional POI.
• Proposes latency measurement to be conducted from a test
server located in the region or state, and to remove Klang
Valley as the location of the server in the MSQoS.
YTLC • Disagrees with the proposal and proposes that MSQoS
should not be amended yet until 5G has been fully rolled
out.
RSMY • Proposes to use interactivity testing model listed in ITU-T
G.1051 and install a TWAMP service inside the test server.
• Proposes to consider additional jitter or deviation parameter
for latency measurement.
• ICMP testing does not reflect real customer experience
based on UDP traffic.
• Measurement value to be based on median or 90th percentile
instead of average.
• To apply weightage for test locations according to
population density.
Table 8: Response to Latency KQI

Commission’s View

4G Latency (per location)

• The latency test methodology is designed to emulate real user traffic. The tests are
directed towards Klang Valley because that is where most Content Delivery Networks
(CDN) are located. Not all operators have regional core and CDNs in East Malaysia.

• The proposed standards take into consideration the Broadband QoE Survey and the
gap analysis which include dissatisfaction with online gaming. Hence, there is a need
to reduce network latency to close the gap.

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5G Latency (per location)

• 5G network must be designed as flat network architecture to meet 5G standards.

• The latency KQI proposed has already taken into consideration the calculated fibre
delay, submarine delay, network equipment, other transport, and air interface.

• The Reference Access Offer (RAO) of 5G SWN states the network latency from user
device to the Point of Interconnection (POI) must be within 15 ms. With the additional
fibre or subsea cable delay, from any regional POIs to the operators’ core network in
Klang Valley, the proposed standards should be able to be met.

Others

• The proposed measurement methodology and calculation in the PI is aligned with

MCMC’s objective to meet user expectation.

Conclusion

• The Commission is of the view that the Latency KQI to be included in the MSQoS
without any changes to the standards and methodology.

2.2.4. Packet loss

QUESTION 5: THE COMMISSION SEEK VIEWS ON THE PROPOSED

STANDARD ON PACKET LOSS FOR THE MANDATORY
STANDARD FOR QUALITY OF SERVICE (WIRELESS
BROADBAND ACCESS SERVICE).

Technology Proposed KQI Mandatory /

Monitoring
• 4G or 5G (all allocated Packet loss shall be at or not Mandatory
IMT frequency band more than 0.5%, measured
other than 703 – 743 between end user to the test
MHz, 758 – 798 MHz, server in Klang Valley.
3.4 – 3.6 GHz and 26.5
– 28.1 GHz)
• 5G (allocated IMT Packet loss shall be at or not Monitoring
frequency band in 703 – more than 0.25%, measured
743 MHz, 758 – 798 between end user to the test
MHz, 3.4 – 3.6 GHz and server in Klang Valley.
26.5 – 28.1 GHz)
Table 9: Proposal for Packet Loss KQI

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Submitting
Comments
Party
CelcomDigi • Agrees with the proposal as the requirement remain
unchanged from current standard.
• Proposes to defer packet loss for 5G monitoring until dual
network matured.
Maxis • Agrees with the proposal to maintain current standard for 4G
service.
• Proposes to defer 5G measurement until the second 5G
network roll out achieve 80% population coverage.
U Mobile • Agrees with the proposal to maintain current standard for 4G
service.
• Proposes to defer 5G packet loss requirement until dual
network matured.
Redtone • Proposes to maintain current standard for 4G service of 0.5%
based on test samples.
• Proposes to defer 5G packet loss requirement to allows for a
thorough evaluation of the measurement criteria.
TM Tech • Proposes to maintain current standards on packet loss.
DNB • No comment.
YTLC • Disagrees with the proposal and proposes that MSQoS
should not be amended yet until 5G has been fully rolled out.
RSMY • Proposes to use interactivity test as in the proposal for
latency test.
• Proposes to include packet arriving later than the delay
budget in the packet loss calculation.
• Proposes to use median or 90th percentile value instead of
average.
• To apply weightage for test locations according to population
density.
Table 10: Response to Packet Loss KQI

Commission’s View

4G Packet Loss (per location)

• The packet loss standard for 4G is retained from existing standards.

5G Packet Loss (per location)

• The packet loss for 5G is aligned with the 5G license condition.

• All 5G KQI is already proposed to be under Monitoring KQI.

Conclusion

• We are of the view that packet loss KQI to be included in the MSQoS without any
changes to the standards and methodology.

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2.2.5. HTTP Session Time (Web browsing)

QUESTION 6: THE COMMISSION SEEK VIEWS ON THE PROPOSED

STANDARD ON HTTP SESSION TIME (WEB BROWSING) FOR
THE MANDATORY STANDARD FOR QUALITY OF SERVICE
(WIRELESS BROADBAND ACCESS SERVICE).

Technology Proposed KQI Mandatory /

Monitoring
• 4G or 5G (all allocated HTTP session time for each Mandatory
IMT frequency band location measured shall be at or
other than 703 – 743 not more than 5 seconds
MHz, 758 – 798 MHz, averaged based on all test
3.4 – 3.6 GHz and 26.5 sample.
– 28.1 GHz)
• 5G (allocated IMT HTTP session time for each Monitoring
frequency band in 703 location measured shall be at or
– 743 MHz, 758 – 798 not more than 5 seconds,
MHz, 3.4 – 3.6 GHz averaged based on all test
and 26.5 – 28.1 GHz) sample.
Table 11: Proposal for HTTP session time (web browsing) KQI

Submitting
Comments
Party
CelcomDigi • Disagrees with the proposal and proposed to remove HTTP
session time for web browsing measurement from the
mandatory and monitoring requirement.
• The assessment of download and upload throughput,
latency and packet loss serve as a comprehensive evaluation
for QoS and QoE.
• Web browsing access time is influenced by factors beyond
network providers control such as content server
performance, website design and user device.
• Monitoring specific aspects like web browsing access time
sessions might provide a limited presentation of the overall
user experience.
Maxis • Supports the proposed standard for 4G networks but
proposes for the standard to be set as monitoring for 4G
service and to defer the measurement for 5G service until
the second 5G network roll out achieves 80% population
coverage.
• Maxis is not in control of the design and production of the
content consumed by the end user, and these contents are
not hosted on the Maxis network for efficient delivery.
• Some factors impacting the measurements are end user’s
device, available hardware resources, network
infrastructure, offered service or applications, etc.
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U Mobile • Disagrees with the proposal and proposed to exclude HTTP

session time web browsing measurement from the
mandatory and monitoring requirement.
• Current MSQoS parameters are sufficient for checking
network performance.
Redtone • Highlighted that the actual content is beyond the operator’s
control, whereby the network can be optimized for a better
web browsing experience, but operator have no influence
over the diverse content available on the internet.
• Content of the websites or applications is managed by the
respective content providers, not the network operators.
TM Tech • Supports the proposal for HTTP session time for web
browsing KQI but proposes that it be placed under
monitoring until the next review by MCMC.
• This will allow sufficient time for MNOs to enhance their
transport layers and routing to international gateways and
CDN services.
• Proposes for MCMC to develop its own test webpage to
ensure a controlled environment for measurement.
DNB • No comment.
YTLC • Disagrees with the proposal and proposes that MSQoS
should not be amended yet until 5G has been fully rolled
out.
RSMY • Recommended to select two global websites with size less
than 500KB, two local websites with size between 1000KB
to 2000KB and have more than 40 resources, and one local
website with size more than 2500KB and have more than 60
resources.
• Proposes to use 1M fixed size downloaded within 5 seconds
to simplify the test setting.
• Proposes to apply weightage for test locations according to
population density.
Table 12: Response to HTTP session time (web browsing) KQI

Commission’s View

4G and 5G Web-browsing (per location)

• QoE test such as web browsing is slowly being implemented by several regulators.
Aside from QoS KQIs, the QoE KQIs are an important indicator to gauge common
user applications and improve user experience.

• The proposed web browsing KQI is aimed at closing the consumer satisfaction gaps,
identified from the Commission’s Broadband QoE Survey findings.

• The web browsing test will select 5 top consumer webpages to simulate real user
experience. The measurement of QoE KQI will help to identify any improvement
needed at the network back-end which is not directly measured using QoS.

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Conclusion

• The Commission is of the view that web browsing KQI for 4G is proposed to be
included in the MSQoS under Monitoring KQI for the 1st year to further study and
collect more information. This KQI will be included as Mandatory KQI starting 2025
onwards with no change to the parameters.

• We are also of the view that 5G web browsing KQI will be included in the MSQoS
without any changes.

2.2.6. Video Streaming Access Time

QUESTION 7: THE COMMISSION SEEK VIEWS ON THE PROPOSED

STANDARD ON VIDEO STREAMING ACCESS TIME FOR THE
MANDATORY STANDARD FOR QUALITY OF SERVICE
(WIRELESS BROADBAND ACCESS SERVICE).

Technology Proposed KQI Mandatory /

Monitoring
• 4G or 5G (all allocated Video streaming access time for Mandatory
IMT frequency band each location measured shall
other than 703 – 743 be at or not more than 6
MHz, 758 – 798 MHz, seconds averaged based on all
3.4 – 3.6 GHz and 26.5 test sample.
– 28.1 GHz)
• 5G (allocated IMT Video streaming access time for Monitoring
frequency band in 703 each location measured shall
– 743 MHz, 758 – 798 be at or not more than 6
MHz, 3.4 – 3.6 GHz seconds averaged based on all
and 26.5 – 28.1 GHz) test sample.
Table 13: Proposal for Video Streaming Access Time KQI

Submitting
Comments
Party
CelcomDigi • Proposes to remove the video streaming access time KQI
from the mandatory and monitoring requirement.
• Video streaming access time is influenced by various factors,
including content delivery mechanisms, buffering strategies,
and the efficiency of the video platform.
• Monitoring download throughput provides a holistic view of
the network’s efficiency in handling data transfer, including
video streaming.
Maxis • Maxis supports the proposal for video streaming access time
KQI for 4G service but proposes for the standard to be set
as monitoring for 4G service and to defer the measurement
for 5G service until the second 5G network roll out achieves
80% population coverage.
• The location of the content server and popularity of the
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video streamed may impact the access time along with the
end user’s device memory and processing capability.
U Mobile • Disagrees with the proposal and proposed to exclude video
streaming access time measurement from the mandatory
and monitoring requirement.
• Current MSQoS parameters are sufficient for checking
network performance.
Redtone • Highlighted that network operators are already measuring
and addressing QoS parameters.
• Content availability during video streaming is not within
network operator’s direct control and is managed by
individual content providers.
TM Tech • Disagrees with the proposal to make this KQI mandatory
and proposes to place this KQI under monitoring with an
agnostic video source approach.
• The test shall take into account the diverse range of
consumer devices with various 4K streaming capabilities.
DNB • No comment.
YTLC • Disagrees with the proposal and proposes that MSQoS
should not be amended yet until 5G has been fully rolled
out.
RSMY • Proposes to include video MOS KQI to address the poor
playback quality, which includes resolution, freezing and
jerkiness. Video MOS less than 3 is considered bad and the
typical value observed is above 3.6.
• Video streaming, including video on demand requires
periodic buffering, while live streaming requires a constant
throughput to support smooth playing.
• Proposes to use at least one live streaming clip to evaluate
the network performance.
• Proposes to use median instead of average value and to
apply weightage for test locations according to population
density.
Table 14: Response to proposal for Video Streaming Access Time KQI

Commission’s View

4G and 5G Video Streaming (per location)

• Video streaming is one of the KQI that needs to be measured to improve user
experience. This QoE KQI will help to identify any improvement needed at the
network back-end which is not directly measured using QoS.

• The QoE measurement will enable the Commission to gauge user experience. The
end goal is to increase consumers’ satisfaction and closing the gaps that have been
identified from the Commission’s Broadband QoE Survey.

• The targeted video streaming resolution is full HD at 1080p, which is common video
resolution on mobile devices and video streaming platforms.

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• On-field measurements conducted by the Commission indicated around 7Mbps is

enough to start streaming 1080p video in less than 6s. However, there are locations
tested with good download speed, but poor video access time. Therefore, more time
is needed to collect data and study the requirements.

Conclusion

• The Commission is of the view that video streaming KQI for 4G is proposed to be
included in the MSQoS under Monitoring KQI for the 1st year for further study and
collect more data. This KQI will be included as Mandatory KQI starting 2025 onwards
with no change to the parameters.

• The Commission is also of the view that 5G video streaming KQI will be included in
the MSQoS without any changes.

2.2.7. Service Accessibility

QUESTION 8: THE COMMISSION SEEK VIEWS ON THE PROPOSED

STANDARD ON SERVICE ACCESSIBILITY FOR THE
MANDATORY STANDARD FOR QUALITY OF SERVICE
(WIRELESS BROADBAND ACCESS SERVICE).

Technology Proposed KQI Mandatory /

Monitoring
• 4G or 5G (all allocated The service accessibility ratio Mandatory
IMT frequency band for all download, upload, web
other than 703 – 743 browsing and video streaming
MHz, 758 – 798 MHz, measurement shall be at or not
3.4 – 3.6 GHz and 26.5 less than 90% for each
– 28.1 GHz) location.
• 5G (allocated IMT The service accessibility ratio Monitoring
frequency band in 703 for all download, upload, web
– 743 MHz, 758 – 798 browsing and video streaming
MHz, 3.4 – 3.6 GHz measurement shall be at or not
and 26.5 – 28.1 GHz) less than 90% for each
location.
Table 15: Proposal for Service Accessibility KQI

Submitting
Comments
Party
CelcomDigi • Proposes to remove service accessibility KQI from the
mandatory and monitoring requirement.
• The assessment for download and upload, latency and packet
serve as a comprehensive evaluation of both QoS and QoE.
• Access time measurements for video streaming and web
browsing involve more subjective elements and
dependencies on external factors.
• Throughput measurements offers more comprehensive
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assessment and more applicable to assessing network

performance.
Maxis • Proposes to remove the service accessibility KQI for
mandatory and monitoring requirement as other
performance measurements of QoS and QoE are the direct
contributing factors for service accessibility.
U Mobile • Proposes to exclude service accessibility KQI from the
proposed MSQoS for both mandatory and monitoring
requirement.
Redtone • Proposes to defer service accessibility testing as it duplicates
existing testing process, such as download.
TM Tech • Proposes to place service accessibility KQI under monitoring
as this approach will facilitate accurate benchmarking and
providing valuable insights until the next review by MCMC.
• The combination of four different types of KQI into a single
ratio obscures performance issues specific to individual
services.
DNB • No comment.
YTLC • Disagrees with the proposal and proposes that MSQoS should
not be amended yet until 5G has been fully rolled out.
RSMY • Proposes session successful ratio for service accessibility,
which means the success ratio of complete testing sessions
from start to finish.
• Proposes to apply weightage for test locations according to
population density.
Table 16: Response to proposal for Service Accessibility KQI

Commission’s View

4G and 5G Service Accessibility (per location)

• Service accessibility measures the successful attempts of all the measurements

conducted. The purpose of having this standard is to ensure that any location tested
that is unable to establish connection and initiate measurement data (due to poor
coverage, quality or capacity), improvement and actions for these locations will be
able to be executed.

• This will differentiate between operators who have good, poor or no access to the
service at any particular location.

Conclusion

• The Commission is of the view that service accessibility KQI for 4G is proposed to
be included in the MSQoS under Monitoring KQI for the 1st year to further study and
collect more data. This KQI will be included as Mandatory KQI starting 2025 onwards
with no change to the parameters.

• The Commission is also of the view that 5G service accessibility KQI will be included
in MSQoS without any changes.

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2.2.8. Network Utilisation

QUESTION 9: THE COMMISSION SEEK VIEWS ON THE PROPOSED

STANDARD ON NETWORK UTILISATION FOR THE
MANDATORY STANDARD FOR QUALITY OF SERVICE
(WIRELESS BROADBAND ACCESS SERVICE).

Technology Proposed KQI Mandatory /

Monitoring
• 4G or 5G (all Percentage of PRB utilisation per Mandatory
allocated IMT serving sector for each eNodeB and
frequency band gNodeB shall be at or not more than
other than 703 – 80.0% of every month and shall be
743 MHz, 758 – rectified within 14 days.
798 MHz, 3.4 – Percentage of each transport node
3.6 GHz and 26.5 utilisation shall be at or not more
– 28.1 GHz) than 80.0% for every month and
shall be rectified within 14 days.
Percentage of each core network
utilisation shall be at or not more
than 80.0% for every month and
shall be rectified within 14 days.
• 5G (allocated IMT Percentage of PRB utilisation per Monitoring
frequency band in serving sector for each gNodeB shall
703 – 743 MHz, be at or not more than 80.0% of
758 – 798 MHz, every month and shall be rectified
3.4 – 3.6 GHz and within 14 days.
26.5 – 28.1 GHz) Percentage of each transport node
utilisation shall be at or not more
than 80.0% for every month and
shall be rectified within 14 days.
Percentage of each POI utilisation
shall be at or not more than 80.0%
for every month for each state and
national and shall be rectified within
14 days.
Percentage of each core network
utilisation shall be at or not more
than 80.0% for every month and
shall be rectified within 14 days.
Table 17: Proposal for Network Utilisation KQI

Submitting
Comments
Party
CelcomDigi • Proposed to remove PRB utilisation, transport node
utilisation and core network utilisation from Mandatory KQI
and remove PRB utilisation, transport node utilisation, POI
uitilisation and core network utilisation from monitoring KQI.
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• High PRB utilisation does not necessarily equate to low

throughput for users, while certain spikes in PRB utilisation
may not accurately represent the actual user experience.
PRB utilisation needs to be considered within the broader
context of network conditions, user demands, the
effectiveness of Radio Resource Management (RRM)
strategies. eNBs are presently equipped with Automatic
Congestion Handling to alleviate congestion, therefore
enhancing network performance and user experience.
• Transport network employ mix of technologies, including
fiber optics, microwave links and satellite communication.
Establishing a fixed standards for transport utilisation may
not consider the dynamic nature of network loads and
variations in protocols, potentially leading to requirements
that do not align with the operational realities of transport
networks.
• Core network was designed to meet highest utilisation or
availability including geo-redundancy. Core network
conditions can vary dynamically, and monitoring may not
provide any real time insights into the actual user
experience. Simplifying monitoring by focusing on user-
facing metrics reduces the complexity of the monitoring
process and straightforward evaluation of network
performance.

Maxis • Proposed to remove PRB utilisation, transport (backhaul)

utilisation and core network utilisation.
• Maxis also proposed that 5G POI utilisation/availability
standard to be set as monitoring and 5G related service
standards to be reviewed only when both 5G networks have
reached 80% populations coverage and the establishment
of 5G Dual Network is clearer.
• Transport aggregation and core networks are designed with
reserve capacity and alternate routes to balance traffic and
re-route in the event of failure.
• Networks carry aggregated fixed and mobile traffic with
shaping and scheduling mechanisms to manage bursty
traffic.
• High PRB utilisation may not necessarily represent low user
throughput. The high utilisation could be due to temporary
traffic spikes or temporary concurrent access at special
events, hence, does not necessarily mean congestion, and
such conditions may not require an upgrade which leads to
unnecessary expenditure.

U Mobile • Disagreed KQI for 4G and 5G (all allocated IMT frequency

band other than 703 – 743 MHz, 758 – 798 MHz, 3.4 – 3.6
GHz and 26.5 – 28.1 GHz) with the use of Busy Hour for PRB
Utilisation and transport node utilisation calculation and
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benchmarking.
• Proposed to keep current MSQoS 2021 standard for PRB
Utilisation and transport node utilisation.
• U Mobile also proposed to exclude core network utilisation
since the network element seldom faces congestion issue.
MNOs will report directly to MCMC if there is any issue in line
with the Customer Service process.
• To defer KQI for 5G (allocated IMT frequency band in 703 –
743 MHz, 758 – 798 MHz, 3.4 – 3.6 GHz and 26.5 – 28.1
GHz) for PRB utilisation, transport node utilisation, POI
utilisation and core network utilisation.

Redtone • Proposed to retain current MSQoS 2021 standard for PRB

Utilisation and transport node utilisation while core network
utilisation to be removed.
• Redtone disagreed with duration of rectification for PRB
utilisation, transport node utilisation and POI utilisation.
Redtone propose average time is 8 weeks or more for
duration of rectification.

TM Tech • Proposed to maintain the current network utilisation

standard of monthly average percentage of PRB utilisation
per base station and backhaul utilisation for a duration of 3
months, which shall not be more than 80% and shall be
rectified within reasonable timeline.
• TM Tech also proposed to remove core network utilisation.

Physical Resource Block (“PRB”) Utilisation

a. Operational Efficiency - PRB utilisation per sector will
require additional resources to manage and analyse
data. This may not be operationally efficient, especially
when other network optimisation and maintenance tasks
need to be prioritised.
b. Challenging Timelines - To fulfil the per sector utilisation
KQI, the rectification timeline will exceed the proposed
duration. This extension is necessary as it includes
studying and benchmarking the network, evaluating the
cost of network improvement, exploring alternative
solutions, and obtaining approvals through the
governance process for the improvement plan.
c. Data Management Challenges - Handling data from every
sector across more than 5000 sites generates a massive
volume of information. Storing, processing, and
analysing this data requires sophisticated data
management systems and tools. Managing such large
datasets can be resource-intensive and may strain TM’s
existing data management infrastructure.

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• Transport Utilisation
a. Operational Efficiency - The revision of this Transport
utilisation KQI standard from per base station to each
transport node utilisation will require more resources to
manage and analyse data. This may not be efficient
operationally, especially when other network
optimisation and maintenance tasks need to be
prioritised.
b. Challenging Timelines - To fulfil each transport node
utilisation KQI, the rectification timeline will exceed the
proposed duration between 3 to 6 months for the
microwave links. This extension is necessary as it
includes studying and benchmarking the network,
evaluating the cost of network improvement, exploring
alternative solutions, and obtaining approval through the
governance process for the improvement plan.
c. Data Management Challenges - Handling data from every
transport node across more than 5000 sites generates a
massive volume of information. Storing, processing, and
analysing this data require sophisticated data
management systems and tools. Managing such large
datasets can be resource-intensive and may strain TM’s
existing data management infrastructure.
• Core Network Utilisation
a. Focus on PRB & Transport Utilisation KQI - The KQI for
PRB and backhaul utilisation are sufficient to address the
network utilisation requirement. Core utilisation
improvement will be implemented when necessary,
ensuring minimum download throughput, latency and
packet loss KQI are consistently met.
Operational Efficiency - More resources are required to
manage and analyse data for each core network
elements in EPC. This may not be operationally efficient,
especially when other network optimisation and
maintenance tasks need to be prioritised.
DNB • Disagreed with the proposal and proposed to grant
extension of time for 5G technology for case-to-case basis.
• PRB utilisation may require deploying new site to resolve
congestion issue therefore require more time.
• For transport utilisation, DNB leverage on other Access
Provider for the fibre network therefore any rectification
subject to SLA between DNB and access provider
• POI utilisation DNB also leveraging POI from other Access
Provider and the Access Seekers are responsible for their
own POI.
YTLC • Proposed to retain existing standard. MSQoS should be
amended once 5G has been fully rolled out.
RSMY • No comment
Table 18: Response to the proposal for Network Utilisation KQI

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Commission’s View

4G and 5G Network Utilisation

• Network utilisation is important to gauge the network performance and identify

congestion in any part of the network including the Radio Access Network (RAN),
transport network, POI and core network.

• In the case of high utilisation, operators would find the best solution for network
improvement. Different solutions would be applied to different parts of the network
or issues. Some solutions may take longer than others. Therefore, 14 days may not
be sufficient to rectify all congestion issues.

Conclusion

• The Commission is of the view that the network utilisation shall take the average
network utilisation of 1 busy hour of each day, over 1 month period, for all network
elements (PRB, transport, POI and core). The busy hour will be based on the highest
network resource utilised and the highest number of connected users. The network
utilisation threshold of 80% will remain unchanged.

• The Commission is also of the view that operators shall submit a concrete plan with
a reasonable timeline to the Commission within 14 days, for the improvement of
any network element that did not comply with the standards.

2.2.9. Network Availability

QUESTION 10: THE COMMISSION SEEK VIEWS ON THE PROPOSED

STANDARD ON NETWORK AVAILABILITY FOR THE
MANDATORY STANDARD FOR QUALITY OF SERVICE
(WIRELESS BROADBAND ACCESS SERVICE).

Technology Proposed KQI Mandatory /

Monitoring
• 4G or 5G (all Percentage of network availability Mandatory
allocated IMT (access and aggregation) shall be
frequency band at or not less than 99.50% for each
other than 703 – quarter.
743 MHz, 758 – 798 Percentage of core network
MHz, 3.4 – 3.6 GHz availability shall be at or not less
and 26.5 – 28.1 than 99.97% for each quarter.
GHz)
• 5G (allocated IMT Percentage of network availability Monitoring
frequency band in (access and aggregation) shall be
703 – 743 MHz, 758 at or not less than 99.70% for each
– 798 MHz, 3.4 – quarter.
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3.6 GHz and 26.5 – Percentage of POI availability shall

28.1 GHz) be at or not less than 99.97% for
each quarter.
Percentage of core network
availability shall be at or not less
than 99.97% for each quarter.

Table 19: Proposal for Network Availability

Submitting
Comments
Party
CelcomDigi • Agreed with network availability for 4G/5G Mandatory KQI
with proposal to incorporate a provision allowing for the
exclusion of failures attributed to third parties.
• CelcomDigi proposed to remove core network availability
parameter for 4G/5G Mandatory KQI.
• CelcomDigi also proposed to defer network availability for
5G monitoring KQI until 5G dual network matured in 2026,
to remove POI and Core network availability for 5G
monitoring KQI.
• Element beyond control which impact network availability
should be considered for exclusion, including:
a. force majeure or actions by third parties
b. faults attributable to third parties, such as power
outages, natural disasters, or site access.
c. ad-hoc or planned maintenance and network upgrading
works.
• Core networks are designed with redundancy and over-
provisioning to ensure high availability. Core network
availability is often a subset of overall network availability.
User experiences are influenced by factors beyond core
network, including last-mile connections, transport
networks and external interference. Isolating core network
availability may not provide an accurate representation of
the entire service ecosystem.
• Ongoing discussion between industry and DNB regarding
POI availability, where the proposal is for West Malaysia
POI architecture is 1+0 with geo redundancy, and 1+1
high-availability architecture in East Malaysia.

Maxis • Maxis agreed to provide the access/aggregation network

availability and proposed network availability to be
monitored and to be set at not less than 99% on a
quarterly basis.
• Maxis acknowledged POI availability applies to the 5G
Wholesale Network Provider and proposed 5G POI
availability standard to be set as monitoring.
• Maxis also proposed for 5G related service standards to be
reviewed only when both 5G networks have reached 80%
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pop coverage and the establishment of 5G DN is clearer

and standard for core network availability to be removed.
• The measurement of the standard should have the
following exclusions:
a. Scheduled downtime or planned maintenance
downtime
b. Network outage at the sites which are not within Maxis’
control such as MOCN by other MNOs, 5G by DNB.
c. Health, safety and environment-related, e.g., weather
condition that compromises safety of workers.
d. Unavailability of power supply (i.e., power outage)
provided by national supplier.
e. Theft / vandalism of network components rendering a
site inoperative.
f. Site access-related issues caused by 3rd party including
but not limited to authorities, landlords, site owners,
public.
g. Travel-time of sites located on islands or remote areas.
h. Fiber cuts due to authority’s work permit and other
matters beyond Maxis’ control
i. Force majeure events

U Mobile • Proposed to exclude network availability and core cetwork

availability. MNOs will report directly to MCMC if there is
any issue in line with the Customer Service process.
• U Mobile also proposed to defer network availability, core
network availability and POI availability from the proposed
MSQoS.

Redtone • Proposed to remove because the standard is duplicate with

report under service downtime/unplanned service
disruption & planned maintenance.

TM Tech • Proposed to remove network availability (access and

aggregation) and core network availability.
• In Part C of MSQoS for Customer Service (Determination 4
of 2021), the MNOs are required to notify both MCMC and
customers of the scheduled downtime (Clause 14) and
unplanned service disruption (Clause 15). The notifications
served as our commitment to quickly address the
downtime, minimizing inconvenience for our valued
customers and maintaining high standards.
• Reporting disruptions and scheduled downtime to MCMC
already gives a detailed view of the network’s status.
Service availability is closely connected to these events,
making a separate KQI redundant.
• Consolidating the overlapping KQI avoids unnecessary
duplication of efforts and resources, allowing MNOs to
focus on addressing actual service issues.
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• The availability of the Evolved Packet Core (“EPC”) is

paramount, serving as the foundation of mobile network
infrastructure to maintain uninterrupted connectivity,
dependable services, and a positive user experience.
Recognizing the significant implications of EPC disruptions,
TM has strategically implemented EPC redundancies as a
pre-emptive measure, effectively mitigating the impact on
service availability.
• In the event of disruption, both MCMC and customers will
be promptly notified in accordance with obligations
outlined in Clause 14 and 15 of MSQoS Customer Service.
Given the comprehensive nature of disruption reporting,
introducing a separate KQI specifically for core network
availability is deemed unnecessary. The existing reporting
framework already encapsulates the essential information,
ensuring an efficient, streamlined, and focused approach
to maintaining network reliability and customer
satisfaction.
• Consolidating the overlapping KQI avoids unnecessary
duplication of efforts and resources, allowing MNOs to
focus on addressing actual service issues.
DNB • Proposed the network availability for 5G to follow the 4G
target which is 99.50% due to DNB leveraging existing
tower infrastructure and backhaul that is being used for
4G. Therefore, if there is any incident at the sites the
impact will be the same regardless of technology.
YTLC • Proposed to retain existing standard. MSQoS should be
amended once 5G has been fully rolled out.
RSMY • No comment.
Table 20: Response to the proposal for Network Utilisation KQI

Commission’s View

4G Network Availability

• The proposed service available for KQI covers the access and aggregation (RAN and
transport), POI and core network.

• The network availability KQI is not the same as the notification to MCMC on network
downtime as stated in MSQoS Customer Service. While the requirement to notify
MCMC is important to alert the public and stakeholders, the network availability KQI
is aimed at ensuring operators minimise their network downtime.

• Importantly, the internet has been gazetted as the third utility. Internet is not only
used for social purposes, but it has become a source of income and an important
medium for digital services, e-commerce, online business, conferences, and
education.

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• The exclusion of network downtime due to force majeure, 3rd party, vandalism, etc.
will be included in the guideline of the standards.

5G Network Availability

• The 5G network is more critical than 4G because it is a single network with multiple
operators. Hence, the network availability for access and aggregation should not be
the same as 4G. The network availability set in the standard is not separated into
targeted areas, but it considers the entire network.

Conclusion

• The Commission is of the view that network availability KQI to be included in the
MSQoS without any changes.

2.2.10. 5G Single Wholesale Network QoS Requirements

QUESTION 11: THE COMMISSION SEEK VIEWS ON THE PROPOSED

STANDARD ON 5G SWN KEY QUALITY INDICATORS FOR THE
MANDATORY STANDARD FOR QUALITY OF SERVICE
(WIRELESS BROADBAND ACCESS SERVICE).

Technology Proposed KQI Mandatory /

Monitoring
• 5G (all allocated Mean latency for each service Monitoring
IMT frequency provider calculated via network
band other than statistic shall be not more than:
703 – 743 MHz, i. 35 ms, between end user to the
758 – 798 MHz, national POI; OR
3.4 – 3.6 GHz ii. 15 ms, between end user to the
and 26.5 – 28.1 regional POI.
GHz) Packet loss for each service provider
shall be at or not more than 0.25%
calculated via network statistic
between the end user to regional or
national POI.
Mean download throughput for each
service provider shall be at or not less
than 100 Mbps calculated via
network statistic from the regional or
national POI to the end user
Mean upload throughput for each
service provider shall be at or not less
than 5 Mbps calculated via network
statistic from the end user to the
regional or national POI.
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Service accessibility for each service

provider shall be not less than 99.0%
calculated via network statistics.
Network statistics calculated the ratio
of successful end user registration, to
the number of attempts.
Table 21: Proposal for 5G SWN network performance KQI

Submitting
Comments
Party
CelcomDigi • Proposed to defer 5G SWN network statistic reporting for
5G monitoring KQI until 5G dual network matured in 2026.
Maxis • Proposed the 5G related measurement to be deferred until
the 5G second network rolls out and both 5G networks
achieve 80% population coverage.
U Mobile • Proposed this standard should be exclusively reported by
the 5G wholesale network providers.
Redtone • Proposed to defer the 5G QoS standards until both of 5G
networks in 5G Dual Network model concluded. Further
review when both 5G networks arrive at 80% population
coverage.
TM Tech • No view on this standard.
DNB • Proposed to adopt the RAO upload throughput target of
3Mbps for NSA and 5 Mbps for SA.
• Latency to be measured from the server located in the
region or state instead of only Klang Valley.
YTLC • Proposed to retain existing standard. MSQoS should be
amended once 5G has been fully rolled out.
RSMY • No comment.
Table 22: Response to the proposal for 5G SWN network performance KQI

Commission’s View

5G SWN QoS Requirements

• The SWN Reference Access Offer (RAO) stated the upload speed to be not less than
3 Mbps for 5G NSA and not less than 5 Mbps for 5G SA. It is noted that there are
no specific 5G apps that use high uplink bandwidth, and it would be a big challenge
to achieve the intended target because it is dependent on consumer usage.

• The SWN operator will be responsible for providing all network data to the
Commission.

• The Commission has taken into consideration the shift to 5G dual network model.
Hence, the 5G network is proposed to be under Monitoring KQI. This will enable the
Commission to gauge the performance of 1st 5G network and ensure that
deployment of the 2nd 5G network is on par or better.
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Conclusion

• The Commission is of the view that the 5G SWN QoS requirements based on network
statistic reporting, to be implemented in the MSQoS with the change to separate
upload speed of 5G NSA for not less than 3 Mbps and 5G NSA for not less 5 Mbps.

• This network statistic reporting will apply to 5G SWN operator during the transition
period to dual network, and to any of the entities providing 5G dual network during
and after the transition.

2.3 Revision of the Applicable Guidelines

QUESTION 12: THE COMMISSION SEEK VIEWS ON THE PROPOSED

GUIDELINES FOR THE COMMISSION DETERMINATION ON
MANDATORY STANDARD FOR QUALITY OF SERVICE
(WIRELESS BROADBAND ACCESS SERVICE).

2.3.1 Interpretation

Submitting
Comments
Party
CelcomDigi No comment.
Maxis No comment.
U Mobile No comment.
Redtone No comment.
TM Tech TM Tech proposed for the definition of test server to be refined
by specifying its location. There should be uniform
specifications for both test terminal and test server that
addressed aspects of client and hardware for the measurement
server.
DNB No comment.
YTLC No comment.
RSMY No comment.
Table 23: Responses to the Interpretation of the guidelines

2.3.2 Part A: Objective and scope

Submitting
Comments
Party
CelcomDigi No comment.
Maxis Maxis is of the view that it is premature to set the standard for
5G services and should only be set once the 5G rollout is
complete and 5G service adoption is matured.
U Mobile U Mobile proposed to defer the guideline until 5G Dual
Network achieves full maturity and deployment.
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Redtone No comment.
TM Tech No comment.
DNB No comment.
YTLC No comment.
RSMY No Comment.
Table 24: Responses to the objective and scope of the guidelines

2.3.3 Part B: Key Quality Indicators (KQI) Assessment

Submitting
Comments
Party
CelcomDigi No comment.
Maxis Maxis took note of the requirement.
U Mobile The 5G network statistic data reporting should exclusively
reported by 5G SWN since they are the entities with all the
necessary information.
Redtone No comment.
TM Tech No comment.
DNB No comment.
YTLC No comment.
RSMY No comment.
Table 25: Responses to the KQI assessment of the guidelines

2.3.4 Part C: Measurement Methodology for Quality of Service and Quality of Experience

Submitting
Comments
Party
Maxis • Indoor location should only be measured when it has
dedicated IBC solution, building that are accessible to the
public, signal strength of more than -90dBm and within Maxis
control to design, operate and maintain. Indoor
measurement should only use static test methodology.
• Outdoor locations measurement shall exclude all USP/MC
RAN sharing sites and third party operated sites. The signal
strength should be more than -90dBm and within Maxis
control to design, operate and maintain.
• Outdoor testing should only be conducted within the service
provider’s declared coverage areas and using static test
methodology. Drive test should be excluded from the
outdoor measurement since site serving highways or trunk
road are only meant for connectivity not for capacity.
• Maxis proposed the test tool and testing methodology should
support latest capabilities including multi-thread and higher
order MIMO.
• 4G measurement equipment should be logged to 4G
technology during the measurement.
• Maxis proposed the usage of standard script for the testing
that has been agreed upon by MCMC and the drive tools
vendor. MCMC also should notify the service provider 1 year
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ahead if there are any changes in the drive test tool vendor.
• The number of locations should be maintained at 120 as per
current MSQoS. MCMC should consider adopting
crowdsource methodology for better sampling and wider
analysis.
• Network unavailability should only be considered during total
site outage since during partial network failure, the end user
is still able to access the network service.
• Maxis proposed for para 36 to be reconsider as “The
Commission may at its discretion, on reasonable grounds
including consideration of technical capability and cost,
acquire a more granular set of data or data within specific
period, on network utilisation and availability.”
• Maxis is of the view that for 5G access network statistic data
reporting should be deferred until the dual 5G network
reaches 80%.
• Maxis proposed for para 41 to be reconsider as “The
Commission may at its discretion, on reasonable grounds
including consideration of technical capability and cost,
acquire a more granular set of data or raw data.”
• Maxis is of the view that service provider should not be held
responsible for network elements to which the service
provider do not have control over.
• MCMC should exempt any non-compliance for areas that
service provider has not declared in the coverage area map
since it would need 100% coverage even at non-populated
areas.

CelcomDigi • Disagreed with the sample size and proposed to increase the
sample size to 10 and to use multiple thread as it provides
more accurate simulation and reduce overall testing time.
• CelcomDigi is of the view that the test logfiles to only be
stored for 3 months instead of 24 months due to concern on
storage management and further upgrade /optimization may
already take place within 24 months.
• Proposed to do static tests as it provides more accurate
measurement and allows for detailed analysis and for
improvement.
• To gauge the indoor coverage performance, measurements
are conducted at public common access area with IBC
coverage.
• Indoor measurement at residential area should be exempted
due to internal design layout, material and obstruction that
affects signal penetration.
• There should also be exclusion for building of residential
apartment/condominium above 3rd floor as antenna at the
tower is tilted towards the ground.
• The test area should only be conducted within the declared
coverage map.

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• The test should be performed on weekdays during working

hours as it provides a realistic assessment of network
performance because it aligns with the times when the
network is likely to experience the highest usage.
• The number of test locations should be maintained at 120
locations as increasing the test location will impact the cost,
resource, and delivery time.
• The measurement for utilisation parameters should be
removed. Monitoring one busy hour of each day averaging
over one month does not represent actual high utilisation.

U Mobile • U Mobile proposed that the background data should not be

present during the QoE measurement.
• The test should be conducted in stationary conditions since
mobility test involves unavoidable mobility signaling
between service cells that can affect the KQI results.
• MCMC should maintain the current measurement location
methodology, since a certain signal level is necessary to
provide service.
• The enforcement for each specific location should be
removed.
• There should be an exclusion of location such as locations
that fall outside mobile operator’s published coverage map,
cell edge, overspill areas, in-building and MOCN locations.
• U Mobile also proposed for multi-thread measurement and
and observe the actual performance results of the mobile
network.
• U Mobile disagreed with para 33 that stated any non-
compliance in the network utilisation should be rectified
within 14 days since an event that causes temporary spike
in traffic which will normalize in the following months.
• U Mobile disagreed with para 36 that stated the Commission
may acquire more granular set of data due to the data
extraction process that requires extended timeframe and
coordination across multiple network elements.

Redtone No comment.
TM Tech • TM Tech propose that the test measurement should be done
outdoor and only by static test and walk test only. The
measurement should exclude indoor measurement.
• If indoor measurement to be carried out it should be limited
to where IBC infrastructure is already available.
• TM Tech is of the view that there should be a different KQI
for the drive test since it has a different environment and
involves handing over of connections between eNodeB.
• The site location selection must be carried out at the location
that is ascertained to have wireless broadband service
coverage.
• The service coverage should be identified based on service
coverage information as advertised in the service provider’s
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website or from consumer or individual service’s complaint

that has been lodged to MCMC.
• TM Tech propose that the test location site remain at 480
sites per year as the increase of site locations to 1000 per
year will result in unnecessary regulatory overhead.
• TM Tech deem that network statistic KQI should be removed
as MNOs implement robust support system to ensure
minimal network interruption. The network elements are
monitored daily and will be rectified proactively and
reactively.
• TM Tech suggested that non-compliance actions should not
be taken for audit locations that are undergoing scheduled
downtime or experiencing unplanned service disruption.
• TM Tech propose for para 46 “..on condition that the event
is reported in time.” to “..on condition that an event beyond
control is reported to MCMC within reasonable time.”
• TM Tech finds that there is not any proposal specifications
for the measurement devices in the PI. This is an important
aspect in measuring the KQI as uniform measurement device
allow comparison of results to be made.

DNB • DNB proposed for the sample size to be increased based on

calculation of Mandatory KQI of 200 locations with the
minimum speed of 7.7 Mbps for 4G and 50 locations of
monitoring KQI with the minimum speed of 100 Mbps, the
average download throughput will be 26.16 Mbps as follows:

(6𝑥200𝑥7.7𝑀𝑏𝑝𝑠) + (6𝑥50𝑥100𝑀𝑏𝑝𝑠)
= 26.16𝑀𝑏𝑝𝑠
250𝑥6𝑠𝑎𝑚𝑝𝑙𝑒𝑠
• The appropriate number of samples will ensure the end-to-
end measurement to be on acceptable confidence level.
• DNB also proposed for the rectification process for POI
Network Utilisation in para 34 to be further extended on
case-to-case basis.
• DNB also proposed for para 46 to include following exclusion
events aligned with the RAO and Access Agreement that
includes vandalism, theft, sabotage, planned and emergency
maintenance, delay to obtained access from other third
party, prolonged fibre rectification or power blackout,
damage to the facilities or any other similar events or cause
beyond DNB’s reasonable control.

YTLC No comment.
RSMY • RSMY recommends for the download throughput test to use
HTTPS multi-thread with the file size of 1 GB and the test
time should be 10 seconds.
• RSMY proposed for the upload throughput test to use HTTPS
multi-thread with the file size of 200 MB or 500 MB and the
test time should be 10 seconds.
• As for round-trip latency measurement, RSMY recommends
for the test to use TWAMP. The test should apply defined
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applications profile and 6 cycles for each location.

• The service accessibility test should be measured based on
the successful session ratio instead of the successful attempt
ratio.
• RSMY proposed for the video streaming access test, the
video source should include one 4K video resolution, one live
streaming channel and one HD video with a duration of more
than 1 minute each. The streaming duration should be set at
45 seconds for each video source to get sufficient Video MOS
sample.
• The download throughput per area test should be weighted
according to population density for each state and federal
territories within a quarter.
• RSMY also recommends including social media and
messaging test.
• RSMY proposed the wait time to be shortened to 3s and
allowing for shortened whole testing time collecting more
data samples.
• For monitoring KQI, the test should be done at the same
time for all entities and service providers to test the resource
allocation fairness.

Table 26: Responses to the measurement methodology of the guidelines

2.3.5 Part D: Requirement for Report Submission

Submitting
Comments
Party
CelcomDigi • Proposed to allow C-levels management to endorse and
signoff the MSQoS quarterly report submission.
• All of the submission on the reporting should be streamlined
on a quarterly basis for better internal resource
management.

Maxis • Proposed allowing other Maxis Management Team members

or Chief Officer that has been delegated by the Board of
Directors to endorse the signoff the quarterly report.
• This is to ensure the respective Chief Officer to take
accountability on the network performances to comply with
the MSQoS.
• Maxis proposed that Network Utilisation Report to be
removed from the MSQoS and Access Network Statistic
Report submission to be on quarterly basis.

U Mobile • U Mobile proposed that Report submission for Access

Network Statistic Report should be aligned with the others
which is quarterly.

Redtone • Redtone proposed that all the reports should be submitted

quarterly.

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TM Tech No comment.
DNB • DNB recommends the Access Network Statistic Report to be
a quarterly submission aligned with the licence conditions
and MNO’s obligations for QoS reports.
• Reference to para 73 of the PI, 5G KQIs will be monitored
for each gNodeB and Access Seekers and DNB will need to
prepare the report for each of Access Seekers.
• The raw data for the network statistics will be generated
manually and DNB will need to prepare, extract, compile and
analyze from each network element and this is time
consuming monthly.
• DNB suggested for the endorsement and the signoff of the
report, it is sufficient to be on the relevant executive level
which is C-level that includes Chief Operating Officer or Chief
Technology Officer.

YTLC No comment.
RSMY No comment.
Table 27: Responses to the requirement for report submission of the guidelines

2.3.6 Part E: Effective Date and Commission Contact

Submitting
Comments
Party
CelcomDigi No comment.
Maxis MNOs should be given a grace period for the readiness of any
new measurement and reports.
U Mobile No comment.
Redtone No comment.
TM Tech No comment.
DNB No comment.
YTLC YTLC is of the view that the MSQOS and Guidelines should not
be amended until 5G rollout is complete.
RSMY No comment.
Table 28: Responses to the effective date of the guidelines

2.3.7 Other comments

Submitting
Comments
Party
U Mobile • To enforce the MSQoS yearly basis to reflect the overall
performance of service provider.
• To abolish the enforcement of for each specific location.

DNB • DNB suggested to include new provision that the Guideline

can be updated by MCMC with consultation by the industry
in updating the testing methodology in line with the latest
international standard (i.e ITU, ETSI) and regulatory best
practices.
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• The MSQoS also should have a reference to the definitions

and measurement methodologies in accordance with the
relevant international standards such as ITU and ETSI
pertaining to each KQI.
• This is to ensure that the best industry and international
practices are followed and the results from the
measurements would be comparable to other countries.

RSMY • RSMY recommends MCMC to adopt ETSI 103 559 scoring

method that will give common and standardized criteria for
vendors and service providers.
• RSMY also recommends MCMC to deploy remote probe at
key locations to monitor the network KQI’s performance
from end-to-end perspective.

Table 29: Responses for other comments of the guidelines

Commission’s View

MSQoS Guidelines

• The number of test locations is increased to provide better representation of 4G, and
5G network performance and to ensure more locations can be improved in the case
of non-compliance to the standards.

• Tests will be conducted in populated areas to push for infra-sharing among operators
and ensure all consumers are connected.

• The measurement may also be performed indoors to encourage operators to deploy

IBC or small cells, since most people are using internet indoors. In addition, this is to
encourage operators to make use of the sub-1GHz band which has better indoor
penetration.

• Network improvement plan must be submitted with reasonable timeline for locations
with no IBC or out of declared coverage. The Commission will explore the plan on a
case-by-case basis.

• USP sites with MOCN or MORAN active sharing have higher QoS target. In time, more
USP sites have become commercial sites. A total of 806 sites from T3 and T3E projects
have been established as commercial sites.

• The report submission will be required on a quarterly basis and must be endorsed by
the CEO or any designated C-level.

• The test tool used by the Commission is of the latest model and uniform for any
particular location.

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• Use of multi-thread can be done with the support from the operators to provide the
test server in Klang Valley. The operators shall be responsible to ensure the multi-
thread server capacity is always sufficient to be tested by the Commission.

Conclusion

• The Commission is of the view that the proposed Guidelines to MSQOS will be
implemented with the change for the declaration of report submission endorsed by
C-level of respective operators.

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3. The Way Forward

• MCMC is of the view that the proposed revision of the MSQoS for Wireless
Broadband Access Service will ensure enhancements to existing levels of
quality of service by the service providers and further improve consumers’
experience.

• In selecting a particular benchmark for the quality of service, MCMC endeavours

to make certain that the benchmark is meaningful to the customer and will
enable them to assess and make informed decisions on the levels of quality
they are experiencing. The benchmark will be equally useful for MCMC to gauge
the performance of the service providers in fulfilling its role to monitor the
industry.

• MCMC has considered all the general views and proposed approaches, from
respondents to improve the state of the wireless broadband services in
Malaysia.

• The Commission Determination on revised MSQoS for Wireless Broadband

Access Service will be published within 45 days from the conclusion of the PI
and come into effect starting 1 April 2024.

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