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One Touch Switch. Ofcom's new name for GPL Switching

On 3rd Feb 21, Ofcom published their statement on GPL Switching. It is here. They are now consulting on it until 31 Mar 21 and the consultation response form is on that page. INCA encourages all members to make their individual views known. INCA is also preparing a response and encourages members to get involved with SWSIG to provide their input. INCA issued a statement on 3 Feb broadly welcoming the proposals.

The schedule for SWSIG meetings is here.

The key take is Ofcom's "preferred approach": They say (s1.15)

"We believe One Touch Switch would be easier to use than Code to Switch, because it would:
• be simpler to understand and follow than Code to Switch. It would be a ‘one touch’ process for landline and broadband switching where customers only have to contact the new provider and follow the instructions given by them. Code to Switch, on the other hand, requires two steps."

This is also the approach favoured by the Option Y Group which included a majority of independent network operators.

The Option X (Code to Switch) group of 2 submitted an updated proposal on Fri 26 Mar and this was released on the Ofcom site on Mon 29 Mar. In brief, it now includes an IVR (Interactive Voice Response) system as an extra channel for the customer to request a Code from the Losing Provider before contacting the Gaining Provider. It is unclear if this is material enough to make Code to Switch a GPL / EECC-compliant system. INCA is adapting its consultation response accordingly. Please give us your thoughts so they can be included as well as make your own response directly to Ofcom on their form which is here.

The Next Steps set out by Ofcom are (s7):

  1. Consultation on the statement (originally to close 31 Mar 21, now extended to 14 Apr 21)
  2. Policy decision published Q2 21

And they give guidance on "Preparatory implementation work by industry" (s7.6, 7.7, 7.8)

"We think it would be helpful for industry to begin preparatory work for implementation prior to the publication of our policy statement."

"Given the cross-industry nature of the Hub, providers may need to establish a means of jointly procuring the necessary systems and of managing its ongoing operation." And "Providers cannot implement a cross-industry switching process independently ... some form of industry forum may be required."

"Establishing the governance arrangements through which providers will work together is one area where industry could usefully start developing plans." They will have initial discussions with industry in Feb and Mar 21.

INCA's SWSIG and PRSIG will be considering both the policy and the practicalities of what Ofcom's requirements mean and assisting members to respond and implement. We encourage you all to get involved with those SIGs.

We are also drafting a response from INCA and, following discussions at SWSIG and the first OTA2 roundtable, it has been suggested that our starting point could be:

  1. broadly supportive of OTS
  2. agree with Ofcom as to their thoughts on Code-to-Switch
  3. OTS may be a potential enabler for wholesale for interested parties
  4. governance needs to cater for all
  5. issues on the timescale to Dec 22 as they haven't confirmed the final decision and the gates to that are in Ofcom's hands, not the industry's

Please give us your thoughts over the coming days through PRSIG, SWSIG, to Board or to Malcolm or myself. 

We had a follow-up meeting with Ofcom on this subject on Monday 15th Feb 21. There was interest in INCA's broad support and willingness to engage with the governance issues. OTA2 have been asked to follow this up with industry and INCA will be involved on behalf of Members.Howver, we detected no engagement with the issue of the Dec 22 deadline so we do not expect Ofcom to change their opinion.