It was the best of times, it was the worst of times, Victorian novelist Charles Dickens once wrote about late-18th-century turmoil in England and France. More than 200 years later, upheaval in those countries' telecom sectors could provoke similar feelings of jaundice and joy among the players affected.

In the UK, Hong Kong's Hutchison Whampoa Ltd. (Hong Kong: 0013; Pink Sheets: HUWHY) is still trying to execute a £10.25 billion ($14.6 billion) takeover of Telefónica UK Ltd. , the country's number-two mobile operator. By merging that business with its Three UK subsidiary, the smallest of the four mobile network operators, Hutchison hopes to create a new mobile market leader. But the deal would leave the UK with just three mobile networks. Unsurprisingly, it has prompted the usual head-scratching among watchdogs worried about the impact on competition.

Across the Channel (La Manche, as the French call it), incumbent Orange (NYSE: FTE) is at work on its own planned €10 billion ($11.2 billion) takeover of Bouygues Telecom , which operates France's third-biggest mobile network and the smallest of the country's four nationwide broadband businesses. As in the UK, the move, should it go ahead, will reduce the number of mobile networks from four to three, undoing the regulator's licensing of a fourth operator -- Iliad (Euronext: ILD) -- more than four years ago.

Yet while confidence is rising within Orange about the likelihood of a Bouygues takeover, Hutchison appears to be losing hope. The Hong Kong player has already offered to make some big concessions to get its plans blessed by regulators. Those include promises on pricing, investments and wholesale arrangements. Last week, in its annual results statement, it went even further, saying it would keep O2 (the brand used by Telefónica UK) and 3 as separate operations provided it could sell a stake in the company to a new investor. It all smacks of desperation. (See Eurobites: O2 & 3 May Not Become One.)

While Hutchison faces apparent opposition from both UK and European authorities, its deal has been referred to the European Commission (EC). That is not cause for optimism. Since becoming the European Commissioner for Competition in late 2014, Danish politician Margrethe Vestager has taken a hard line against merger activity in the mobile sector, blocking a tie-up between Telia Company and Telenor Group (Nasdaq: TELN) in her native country. Bengt Nordström, the CEO of consulting and analyst firm Northstream , does not expect Hutchison to get the green light but hopes he will be wrong. "It will send a negative signal to the investment community," he told Light Reading during a conversation at last month's Mobile World Congress in Barcelona. (See Eurobites: 3 & O2 Deal to Fail – Analyst.)

By contrast, Orange might escape EC scrutiny entirely. Following the sale of its 50% stake in UK mobile operator EE to UK fixed-line incumbent BT Group plc (NYSE: BT; London: BTA), Orange now generates a sufficiently high proportion of its sales in France to qualify for a vetting by French regulators rather than European ones, according to a Reuters report from January, which cites sources close to the matter. This could partly explain why Stéphane Richard, Orange's CEO, has recently sounded upbeat when discussing the probability of a deal. Market watchers reckon French authorities would demand fewer and milder concessions than the EC, and are less likely to block the takeover outright. (See Orange CEO Sees 50:50 Chance of Bouygues Deal.)

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That does not mean French authorities are caught up in Robespierre-like revolutionary fervor, though. In a recent interview with French newspaper Les Echos, Sebastien Soriano, the head of French regulatory authority Arcep , emphasized the need to ensure an overhaul of the current four-player set-up does not unduly strengthen Orange. Bruno Lassere, the president of the French competition authority, has also recently been quoted saying that France would be as rigorous as the EC in assessing the planned merger.

But if Orange is eventually allowed to acquire Bouygues, while 3 is stopped from merging with O2, it would create a "strange convention," according to Nordström, given the similar outcomes the moves would have. Indeed, from a neutral perspective, France arguably has less need for consolidation than the UK, which might benefit from having a counterweight to the recent tie-up between BT and EE. (See UK Needs O2/3 to Challenge BT/EE – Analyst.)

Structurally, such divergent approaches could store up problems for the future, as senior industry executives clamor for more joined-up regulatory thinking across the region. Mergers obviously have a bearing on investment activity, services evolution and spectrum needs in specific markets. If countries that are comparable in terms of population and income levels develop in entirely different ways, it will become much harder to co-ordinate policy and regulatory measures -- let alone create a single European market in the years ahead. (See Vodafone CEO: Europe Needs Uniform 5G Rules.)

— Iain Morris, , News Editor, Light Reading