Posted on 24/02/2021
FCS has provided a summary to members on the Ofcom Customer Switching Consultation and request feedback. A call will take place 3rd March.
FCS Members please log in below for further details.
Ofcom has published a consultation setting out its long awaited proposals for the future of landline and broadband switching. At the same time, it is also consulting on some relatively minor changes to the current mobile switching process
Ofcom has essentially mandated the implementation of a new process, which it is calling “One Touch Switch”. This equates to “Option Y”, one of two competitive processes developed and proposed by industry to support cross network switching and to meet the requirements of the EECC. Option Y was supported by FCS as it is in our view the only true gaining provider led process, with no losing provider contact required.
While FCS broadly supports the proposals set out in the consultation for adoption of the new switching process, there are a number of fundamental aspects about which FCS has concerns.
- The proposals, as set out in the consultation document, only apply to switching by residential customers. FCS believes that the system should also be able to accommodate the needs of business customers and that this must be recognised from the inception of the development process – to ensure that the requirements of businesses are not excluded or only included as an afterthought.
- The new process will require the establishment of a messaging hub which Ofcom expects to be owned, developed, funded and run by industry. FCS is concerned that the project management for development of the necessary functionality specifications and appointment of suppliers must be inclusive and represent all sections of the industry – not just the major payers. We believe this will require an appropriate level of oversight by Ofcom.
- FCS is also concerned to ensure that the governance arrangements for acquiring and ongoing management of the hub, access and the associated switching processes must be fair and sustainable, allowing no undue influence by any part of the industry. This will also require active supervision and oversight by Ofcom.
- FCS is aware of current discussions in the industry number porting fora on the development of new platforms and processes to support number porting, number management, number validation and call routing. it would make sense to consider how any developments in this area should align with the switching hub and how the governance of these areas could be brought together.
- Ofcom proposes to remove the current regulation in General Condition C7 which supports the “Notification of Transfer” process (i.e. as per the current WLR process) – but has not yet provided any detail of the replacement wording for the new regulation – or any clear indication of its scope. Specifically, it is unclear whether the new regulation will include business customers with up to 10 employees as per the existing Notification of Transfer process – or all business customers, as appears to be required by the EECC.
- Ofcom proposes that the new system should be available for use by December 2022 – FCS questions whether this is a realistic timetable
With regard to the proposals for changes to the mobile switching process, our initial view is that this is fairly uncontroversial.
The FCS response will, therefore, focus on the above areas on switching.
However, we are keen to get member feedback and, accordingly, we will host a Teams meeting for FCS members at 10.00 on Wednesday 3rd March to present the Ofcom proposals in more detail and to enable discussion and member queries. If you wish to attend the call please email [email protected]
FCS then has a call with Ofcom on 11th March which will enable us to discuss our concerns in more detail and, where necessary, to get clarification of Ofcom’s intentions.
The consultation closes on 31st March and FCS will share the final draft of its response for feedback.
In the meantime, you can find a copy of the Ofcom consultation document on the Ofcom website at https://www.ofcom.org.uk/consultations-and-statements/category-2/simpler-broadband-switching.