Dear Ofcom team,

Please find below the FCS’s response to your consultation: Combatting mobile messaging scams. Our response is not confidential and it would be helpful if you could acknowledge receipt of the response. 

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. FCS is the largest trade organisation in the professional communications arena, representing the interests of circa 350 businesses which supply B2B services nationwide. 

As our members are in the main, small CPs and resellers and the major regulatory changes proposed are aimed at Mobile Network Operators (MNOs) and Tier 1 Aggregators, we haven’t answered individual questions, but we do have a couple of overall points to make.

On a general level we support the Ofcom focus on mobile scamming.  We agree that consumer and business customers alike can face significant harm from mobile scammers.  It is important that there is trust and confidence in numbers throughout the industry.  It is also important that Ofcom reviews emerging threats. The FCS believes that scammers may move to unregulated platforms such as What’s App and this needs to be addressed across the industry if the safeguards are to make a real difference.

Whilst much of the consultation focused on MNOs, there will be a requirement for resellers and smaller CPs to change processes, particularly in relation to Know Your Customer checks and other customer facing requirements.  It would be very helpful for the consultation to make clear which obligations apply to which part of the supply chain in a way that is simple and clear to a small provider.  The FCS suggests that it would be useful to have a matrix clearly showing the responsibilities at each stage of the supply chain and would be very happy to discuss this in more detail if it would help.

It is important that any changes made by the vertically integrated MNOs are made available throughout the supply chain so that smaller CPs and resellers and their customers are not disadvantaged.  There is no “right” to mobile access in a similar way that there is to fixed access and this can cause competition concerns.  Whilst this point is wider than the scope of this consultation, the FCS urges Ofcom to ensure that any fraud prevention capability is made available across the complex supply chain on the same terms and conditions available to large vertically integrated providers.  The FCS is also concerned about how the cost of implementing these requirements will be “shared” across the supply chain.  Given the structure of the mobile market is it very difficult for smaller CPs and resellers to compete with the large vertically integrated providers and it will be important that the impact of any additional costs passed through the chain are understood and do not distort competition further.

Stefanie Norman

Head of Regulation and Public Affairs

For the Federation of Communication Services

28 January 2026