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According to European Union Open Internet Regulation, commercial practices of internet access service providers (IASP) should not restrict end-users’ choice regarding services, applications or contents. This paper aims to analyze the effects of Zero Rating (ZR) on freedom of choice translating this regulatory criterion into a formal expression: providing a ZR offer on a content or application provider (CAP) restricts end-users’ choice if it reduces the volume or provision of others usages.

The analysis is made in two steps. First, the authors assess the direct effect of introducing zero rating on non-ZR usages, all other things equal. Second, the paper studies the knock-on effect of ZR on IASP offers and the supply of CAP.

In the short term, zero rating does not restrict end-users’ choice increasing both ZR and non-ZR usages. In the long term, in the case of pure ZR, IASPs may adapt their offer to support ZR costs impacting negatively other usages. However, in practice, these effects are compensated or diluted by competitive forces or if the ZR traffic is small relatively to the data allowance. In the case of SD, the CAP covers the cost which prevents cross-subsidies and protects freedom of choice if SD is open to all CAPs.

The economic literature on zero rating is scarce and assesses this practice from the general economic criterion of social or consumer welfare. This paper is the first one to use economic analysis to analyze whether Zero Rating is compatible with the EU regulatory criterion of freedom of choice.