Sweden opened the 3.8–4.2 GHz band for private 5G licences one day after the EU's 30 September deadline — a timing that sums up the bloc's uneven performance rather neatly. Of the 747 private 5G networks the European Commission's 5G Observatory counted across the EU in June 2026, 500 were in Germany. Ten member states had one or none.

The EU harmonised the band through an implementing decision adopted on 2 December 2025, requiring member states to make 3800–4200 MHz available on a non-exclusive basis by 30 September 2026. Progress reports are due at the end of December. Sweden's regulator PTS began accepting applications at the start of this month, offering local licences in two segments — 3800–3920 MHz and 3990–4130 MHz — for indoor and outdoor use at industrial sites, ports, mines, energy facilities, hospitals, research facilities and campuses.

Edvard Brinck, head of PTS's spectrum licensing unit, said a larger, harmonised band could improve equipment availability and lower the cost of entry for organisations building their own networks. Jonas Wessel of PTS went further, defending the wider machinery: "The current European spectrum governance model has proven successful and is a fundamental pillar for European spectrum harmonisation," he said. "All the studies, reports, meetings and negotiations demonstrate that the European model delivers."

Do the numbers support that claim?

Not obviously. Germany has held dedicated local spectrum in 3.7–3.8 GHz since 2019, and it accounts for two-thirds of EU deployments. After Germany, only France (65), the Netherlands (58), Poland (34) and Spain (32) reached double figures. Sweden had six. Outside Europe, the Observatory recorded 2,689 private networks in the US.

Implementation so far is patchy, despite the expired deadline. The decision defines "making available" loosely: member states must adapt national frameworks, begin coexistence measures and start the steps needed to allow use, supported by stakeholder consultation "where appropriate". A regulator that has only launched a consultation can therefore claim compliance. France, Ireland, Lithuania and Slovakia were still consulting; Slovenia has plans but no framework.

The technical conditions are strict. Base stations are limited to 24 dBm EIRP per channel at low power and 44 dBm at medium power, at bandwidths up to 20 MHz, and coverage must remain local — no nationwide networks. Member states must protect satellite earth stations, fixed links, 3.4–3.8 GHz mobile networks, radio altimeters above 4.2 GHz and the VLBI geodesy stations supporting Galileo.

What took five years?

The process began with a June 2021 Radio Spectrum Policy Group opinion recommending the band for local, low- and medium-power use. CEPT delivered harmonised technical conditions in November 2024. It has since been filling in the rulebook: a recommendation on protecting fixed links and satellite earth stations in October 2025, one on radio altimeter coexistence in June 2026, and a third — on coordination between local networks and mobile networks below 3.8 GHz — still being finalised in CEPT's FM60 working group.

That draft concedes "it is not possible to define generic technical conditions" guaranteeing incumbent protection. It offers regulators two options: assess each deployment before licensing, or grant licensees an exclusive local area with a field strength limit at its edge. Synchronised local networks could use the whole band without coordination, at the cost of uplink-to-downlink flexibility; unsynchronised ones would be pushed back from the band edge and face tighter emission limits plus receiver blocking requirements beyond 3GPP specs.

Cross-border coordination is contested too. Germany, which borders nine countries, proposed in March that administrations share information on local networks in border areas. The current draft leaves this to bilateral or multilateral agreements — in other words, to hope.

Licensing frameworks vary just as widely. Belgium is authorising 40 MHz and 80 MHz assignments on 10-year terms. Poland uses first-come, first-served applications with five-year terms, after a March consultation proposing 3.8–3.9 GHz be reserved for local government and applicants capped at 100 MHz. Norway licenses up to the full 400 MHz. Ofcom had issued 789 shared access licences in the band by April 2026, and South Africa's ICASA has opened it to database-driven dynamic spectrum access.

What happens to Germany's 3.7–3.8 GHz?

BNetzA set aside 3.7–3.8 GHz for campus networks in November 2019, in 10 MHz blocks up to 100 MHz with 10-year terms. Mobile operators objected at the time, arguing the spectrum belonged in nationwide networks. In May 2026 the regulator consulted on amending its frequency plan for the harmonised band above. The earliest assignments expire around 2030, and renewal versus migration to 3.8–4.2 GHz remains an open question.

Analyst Dean Bubley, commenting on deadline day, said the band should provide up to 400 MHz of harmonised spectrum but "it already looks like a messy patchwork, with many important elements out of phase, delayed or even ignored". Consultant Tommy Ljunggren put the commercial point more bluntly: "Successfully harmonising a frequency band does not necessarily mean that we have created the conditions for industrial investment." The December progress reports should reveal how many of the 27 member states actually have usable regimes — and how many will settle for a consultation.