Antitrust regulators who approved last year’s T-Mobile–Sprint merger are counting on Dish Network, long known for its satellite TV service, to maintain competition in the wireless market as the new fourth player.

But the clock is ticking. Dish faces huge financial penalties—agreed to as a condition for buying some of Sprint’s wireless business—if it doesn’t build its own 5G network over the next few years.

The bet by Dish and its founder and chairman, Charlie Ergen, is risky. Dish’s main business has been crushed by cord-cutting; efforts to build an Internet TV service have stagnated; and its stock is down by half from five years ago. Wireless could open huge new markets, but it’s still early, and Dish will need to spend billions of dollars to build its network.

“Dish’s satellite business has been shrinking for nearly 12 years now,” longtime industry analyst Craig Moffett noted last week. “What really matters is the 5G business. And what really matters for the 5G business is, for now at least, how are they going to fund it?”

So far, Ergen asserts that Dish can finance the first new U.S. wireless network in decades, costing some $10 billion, without additional partners.

In another sign of its seriousness, Dish on Thursday introduced a number of new privacy features to its mobile service. They’re intended to convince more security-minded wireless consumers that it’s worth going with the smaller carrier.

But would-be rivals aren’t standing still. Verizon, AT&T, and T-Mobile added 1.8 million new phone subscribers combined in the fourth quarter. They’re also spending tens of billions of dollars each to add more 5G to their networks, in addition to bidding on new 5G airwave licenses (Verizon and AT&T spent a combined $68 billion at the latest government auction).

In the meantime, with no significant fourth player in the wireless market yet, consumers are paying with their pocketbooks. Prices for wireless plans ticked 2% higher last year, the first time they’ve risen since 2009.

Dish’s clean slate

Thanks to regulators, Dish is starting off with nearly 9 million customers that it inherited from Sprint’s old Boost Mobile prepaid service. But until it builds its own network, Dish depends on leasing airwaves from T-Mobile. And while getting organized, Dish lost 363,000 wireless customers in the fourth quarter.

For now, Boost is mostly competing on price. Its cheapest unlimited plan starts at $50, 20% less than T-Mobile’s cheapest unlimited plan. The ultimate goal with Dish’s new 5G network is to also provide better service and more features than the bigger carriers.

Stephen Stokols, who became CEO of Dish’s Boost unit in September, tells Fortune that the current service isn’t up to the level of rivals, but he plans to lap the field with Dish’s new network. During 2021, Dish plans to “go from worst in class to best in class, and leapfrog what’s going on in the wireless space today,” he says.

To do that, Dish is building its 5G from scratch, skipping older technologies and following the same strategy that Indian telecom Reliance Jio used to build a low-cost 4G network in India and that Rakuten is using in Japan for 5G. It hopes to spend less on equipment but end up with a faster and more efficient network than that of larger rivals.

“As we enter 2021, we have everything that we need to build this one of a kind 5G network,” Dish chairman Ergen crowed on a call with analysts last month. “Wireless networks really haven’t been upgraded from an architecture point of view in the last 30 years.”

For years, Dish had been rumored to be seeking a better-known partner like Amazon or Google to join its wireless quest. But nothing has materialized. In the recent conference call with analysts, Ergen again downplayed the idea, saying Dish now has enough resources to forge ahead without an ally.

Analysts say going it alone could work for Dish because it already has licensed significant amounts of airwaves that are suitable for 5G and won’t have to install costly transmitters for 3G and 4G service. As a result, Dish’s costs to serve customers should be 20% lower than those of rivals, New Street Research analyst Jonathan Chaplin estimated in a recent report. Once it builds the new network, “Dish is poised to disrupt the U.S. wireless market,” Chaplin concluded.

Money on the line

But the new network can’t be late. Ergen’s company has held some airwave licenses for years without building a network. So to ensure Dish would provide true competition, regulators demanded guarantees as part of the Sprint asset sale last year. Dish’s new 5G network must reach 20% of the U.S. population by June of next year and 70% by the end of 2023 or the company will have to pay billions of dollars in penalties.

“These are really the true hard deadlines,” Morgan Stanley analyst Benjamin Swinburne noted in a cautious assessment of Dish’s progress. While calling the recent deals “real activity,” he said that Wall Street’s view of the company is a debate that “remains unresolved.”

While some of Dish’s network will be built without the usual telecom gear, its new 5G-focused radio transmitters must be installed on towers, rooftops, and other key spots. There’s nothing low cost or sexy about the nuts and bolts of putting transmitters on towers, but it’s a sign of progress and commitment to the plan that Ergen has signed a number of deals recently with key industry players.

A February deal with SBA Communications and another with Vertical Bridge gives Dish space at those key locations. Another new deal, with Aviat Networks, will provide connections between towers and ground networks via microwave technology. Those follow earlier agreements, including with Crown Castle for cell tower leases, fiber-optic network Zayo for connections, and Qualcomm for 5G radio transmitters.

The new features for Dish’s Boost service announced on Thursday include call screening to block spam calls, data encryption when a phone connects to public Wi-Fi to keep out would-be eavesdroppers, and automatic transcription of voicemail messages. The “privacy premium” package costs $6 monthly. “Phones are being hacked, malware’s on fire,” Stokols says. “There’s a huge concern around privacy and protecting your data.”

Dish’s strategy will be to add other digital services for consumers in areas like finance, gambling, and health care. Including privacy, “[these are] the four big macro areas that impact customers, and Boost can differentiate across all four of those,” Stokols says.

Other carriers have had mixed success in offering financial services and other digital extensions. T-Mobile’s Money service offers checking accounts with above-average interest rates, but it hasn’t made much of a dent in the banking industry. An earlier T-Mobile program introduced in 2014 relying on prepaid debit cards flopped.

“Cutting through all the noise and focusing on value,” Stokols says, summing up the plan. “That’s really what we’re trying to do.”