"Quick, easy and reliable switching": changes coming to Ofcom's General Conditions on 3 April 2023

If you run a telco or ISP - fixed or mobile - make sure you're aware of the imminent changes to Ofcom's General Conditions, around switching (customers moving from one provider to another).

Ofcom has made changes to the General Conditions - GC C7, in particular - and these take effect on 3rd April 2023.

You can find the modified GC C7 here, and unofficial consolidated GCs here.

Fixed location services:

The amended conditions C7.18 to C7.27 apply to residential customers who are switching fixed communications services at the same location (i.e. not moving house).

Note that "fixed" doesn't mean "fixed line". Ofcom says (at para 3.15 of its switching statement) that:

"Fixed Communications Service" is any Internet access service or number-based interpersonal communications service which is provided at a fixed location. As noted in Ofcom's September 2021 Statement and Consultation, this includes some services delivered via mobile broadband where they are used at a fixed location.

The revised GCs require providers to implement and operate the fixed switching process known as ‘One Touch Switch’. Not just within the scope of the same underlying network provider, but across network providers (e.g. a move from a service underpinned by BTOR, to one provided by an altnet).

Operators must maintain implement this One Touch Switch "in accordance with ... any applicable industry processes as agreed by the relevant industry forum."

That "relevant industry forum" is The One Touch Switching Company Ltd, or TOTSC, which is - it says - developing an API to make this all happen.

But it's not ready yet.

TOTSC says:

The design and specification of this interface is underway and will be published in due course along with test protocols and other information.

It also says that providers which sign up for its mailing list:

will receive the most up-to-date information concerning the progress of the TOTSCo Hub, the development steps that they need to undertake, and pricing and other commercial details, as soon as they are available

None of which is particularly promising (especially as this appears to be something ISPs will have to pay for), given that the change to the GCs, and the requirement to have one-touch switching in place, starts on 3rd April 2023.

Even more bluntly, TOTSC says:

TOTSCo considers it unlikely that OTS will be fully ready on this date, as not only does the Hub development need to be completed, but providers will have to modify their own processes and extensive end-to-end testing will be required.

So I'm really not sure what is going to happen here. Ofcom seems to be pressing ahead with the changes to the GCs, but it seems unlikely that the underlying systems which will be needed to give effect to those changes will be ready in time.

And that's leaving aside the needs for ISPs to implement the API into their own systems, adjust their processes, test it etc.

So much for "quick and easy"! This looks like a right pain, especially for smaller providers, and compliance by 3rd April 2023 doesn't seem feasible.

(There are also new rules about "home moves" within the BTOR / KCOM networks.)

Mobile services

For mobile services, Ofcom is promoting a new system which it terms "Auto-switch", for switching fewer than 25 mobile numbers.

It doesn't appear to be massively different to what we have in place today, aside from more specific information provision requirements. Ofcom envisages this appearing along the lines of:

“Your PAC for XXXXXXXXXXX is XXXXXXXXX and is valid for 30 days. If you switch today we will charge you £XX.XX for your airtime contract and you will continue to pay £x.x for your handset until [date]. You also have broadband with us, which will not be affected by your switch. More information about your current mobile service and how to switch is available here, visit www.[Y].co.uk/[landing_page]. If you can’t access this link, please reply ‘EMAIL’ to receive the additional information by email and ‘POST’ to receive it by post.”

So work to do, but perhaps not quite the same scale of work (or mess) as fixed location one touch switching.