T – There are no (few) phones
C – Costly, adding new hardware (SE), distribution & and new players (TSM + MNO)
O – Only works at Point of Sale (POS) and for smaller amounts
Also the total cost of ownership (TCO) needs to be taken into account, when considering/deciding what mobile payment technology route to choose. As in all technology choices, it is important to choose the most flexible, user-friendly and cost-effective alternative.
There are many alternatives available that have successfully been launched, and that works for any phone, with any network, and in any payment situation. You should take a look into these, before committing to a solution that will become expensive in the long run, with for example recurring Secure Element provisioning of the subscribers! This and other look-ins can be avoided with a more flexible software based solution.
Maybe this is why we see so many pilots (TCO is not an issue in pilots!) and relatively few successful commercial launches..