FCS Response to BIST’s Proposed Statement of Strategic Priorities for telecommunications, the management of radio spectrum, and postal services

Please find below the Federation of Communication Services (FCS) response to the Department of Science, Innovation and Technology’s (BIST) Proposed Statement of Strategic Priorities for telecommunications, the management of radio spectrum, and postal services.  This document is not confidential, and we are happy for our response to be published on the BIST website.

The FCS represents companies which provide professional communications solutions to business users. Our members deliver telecommunications services via mobile and fixed line telephony networks, broadband, satellite, wi-fi and business radio. Our members’ customers range from SMEs, home-workers and micro-businesses up to the very largest private enterprises and public sector users. The FCS is the largest trade organisation in the professional communications arena, representing the interests of circa 350 businesses which supply B2B services nationwide.

Overall comments

The FCS welcomes both the publication of the draft Statement of Strategic Priorities (SSP) and the opportunity to comment upon it.   

There is plenty in the SSP which the FCS supports. The SSP requires a pro-growth policy and a regulatory environment that supports innovation and investment in infrastructure. The FCS believes that growth depends on a vibrant and efficient communications sector and that, alongside infrastructure investment, the regulatory regime must encourage and actively support smaller CP/MSPs and resellers, who play such a vital part in providing solutions to tens of thousands of SMEs.  The UK will only grow if SMEs are successful, and they are reliant on the expert solutions provided by smaller CP/MSPs and resellers, many of whom are FCS members.

The FCS was pleased to see a greater focus on growth and the business market in the SSP, although we think there is still some way to go. Specifically, we believe that the SSP should encourage Ofcom to have a more business-focused approach and suggest that it requires Ofcom to appoint a Business Champion/Division to ensure that this focus is given.  

Please find answers to the consultation questions below:

Do you agree with the Government’s strategic priorities and desired policy outcomes for fixed digital infrastructure? Are there alternative or additional strategic priorities and desired outcomes you believe are required?

The FCS was pleased to see a specific requirement for Ofcom to ensure that Openreach prices support innovation and roll-out. Crucially for FCS members, the SSP specifically mentions business broadband, and we believe that there needs to be increased focus in this area to ensure that businesses, as well as consumers, benefit from infrastructure deployment.

The FCS is, however, concerned about whether the SSP will be enough to make a tangible difference to the Ofcom work plan without changes to legislation and it may be that firmer language is required to ensure that the regulator takes due regard of the business market. The appointment of a Business Champion/Division in Ofcom would be a very good first step towards achieving this end.  We also believe that Ofcom should be required to collect business statistics to aid and support policy development as there is a general lack of understanding about the business market.  

In relation to PSTN switch-off, we support BIST’s position to ensure that vulnerable customers are supported. We also support the call that the regulator should ensure that transitions do not have an adverse impact on wholesale competition. The FCS believes this is an important area and that Ofcom should actively consider how battery back-up and other required products will be made available to the complex supply chain.   

The FCS also welcomes the focus on power resilience and supports the work proposed in this area. It will be important that due regard is given to smaller CPs and resellers and that, in relation to resilience, regulation applies at the appropriate point in the supply chain. As with battery back-up solutions, there is no point in having regulation on retail CPs/resellers if they are unable to easily source appropriate economically viable wholesale input products.

In relation to switching, the FCS supports the requirements for the regulator to “take all efforts to support effective and straightforward switching between providers to enable competition and enable more people to benefit from gigabit broadband”. The FCS believes that Ofcom should have more focus on business switching and associated processes to ensure that on implementation, smaller CPs are not disadvantaged when compared to larger CPs. There should also be focus on switching across multiple products/services, including mobile, as customers often buy a bundle of services. New product sets, such as satellite should also be included. Indeed, as a general point the FCS is concerned that Ofcom does not take sufficient regard of new technologies.  It is important that regulation is not based on legacy technologies and that it recognises how new products, services and markets are developing.

Overall, the FCS is encouraged by the SSP in this area and believes it focuses on the right issues. We hope that the SSP will have the desired effect, leading to tangible changes to the Ofcom work plan.   

Do you agree with the Government’s strategic priorities and desired policy outcomes for wireless (mobile) digital infrastructure? Are there alternative or additional strategic priorities and desired outcomes you believe are required?

The FCS supports the SSP’s aim to support growth and productivity through investment in high quality 5G networks.  

We were very pleased to see that the SSP asks Ofcom to “ensure that competition in the mobile market is working effectively and […] proactively identify where it may not be.”  This is an extremely important area to the complex supply chain, and we would hope that this will spur Ofcom into reviewing the need for the Mobile Network Operators to be required to provide wholesale products to smaller CPs/resellers on an equivalent basis. Without fundamental change in this market area, competition could be significantly constrained.  

Do you agree with the Government’s strategic priorities and desired policy outcomes for the management of radio spectrum? Are there alternative or additional strategic priorities and desired outcomes you believe are required?

The FCS welcomes the opening of spectrum and increased sharing, believing that it provides new opportunities to add value and to contribute to growth. There does, though, need to be awareness of potential harmful interference and safeguards must be put in place to prevent interference to other spectrum users.

Do you agree with the Government’s strategic priorities and desired policy outcomes for consumers? Are there alternative or additional strategic priorities and desired outcomes you believe are required?

The SSP requires that Ofcom should continue to work with telecoms operators to identify and address the vulnerabilities in telecoms networks that are exploited by criminals. The FCS supports this but believes there should be greater focus in the SSP on fraud. Greater coordination across Government and regulators would also be most welcome and would help to build customer confidence.  

The FCS notes that the SSP asks Ofcom to help in assessing the potential merits of establishing a Smart Data scheme in telecoms, including determining the costs and benefits of such a scheme for industry. The FCS would urge Ofcom and Government to explicitly review the impact of such a scheme on smaller CPs/resellers.

The SSP highlights the importance of the consumer voice, and the FCS applauds the fact that this voice includes both residential and business customers. It is important that business customers are not forgotten and their needs and perspective, which are sometimes different from residential consumers, are not overlooked by the regulatory regime. The impact of regulation in the business market cannot be underestimated, and it is imperative that unintended consequences of regulation, or indeed its absence, does not hinder smaller providers/resellers from offering the innovative solutions that will power growth in the UK economy. We would be very happy to work with Ofcom/Government in this area if this would help to ensure that engagement with business customers is effective.

Conclusion

In conclusion, the FCS welcomes the SSP and is pleased to see that there is a greater focus given to the business market. We are however concerned as to whether the SSP on its own will make a tangible difference to the regulatory regime and urge Ofcom to appoint a Business Champion/Division to ensure that this focus is given and gather appropriate data on the business market to aid policy development.  

The FCS believes that small CPs and resellers are drivers for growth. Our members educate business customers and help them to be more efficient and productive. It is vital that the Government’s priorities and subsequent regulatory focus support small providers to be successful, as this will undoubtedly help the Government to deliver its overarching aim of increased economic growth.

Federation of Communication Services

September 2025