A major change to the broadband industry affecting all network operators is coming and coming fast. Based on the new EU Electronic Communications Code – EECC – Ofcom is mandating a new method for consumers to be able to switch their broadband connection. This needs to be in place in just a few months, by 21st December 2020.
The new method will be a new Gaining Provider-led switching process where the Customer is moving between retailers whether they use the same or different access infrastructures (e.g. Openreach to another wholesale platform & vice versa). It even applies to non-fibre or copper infrastructure such as FWA.
It will need to be adopted by every INCA Member who runs a network and/or retails internet access services to consumers and SMEs. If you are not already involved in the process and planning the changes needed, you should start now. 14 months is not a long time to design, test and implement new business processes. There are active consultations going on right now to design the new process – Gaining Provider-led and Cross-platform - and there is still time for you to have input if you take action now.
A “Gaining Provider-led” process is driven by the desire of the customer to place their switch request directly with the gaining Retailer who will thereafter manage the switch on behalf of the customer. The customer will not be required to notify (or contact) their pre‑existing Retailer.
This type of process is already in place for customers switching between retailers who use the Openreach access infrastructure. As of December 2020, the new process will also cover switches between retailers using different access infrastructures.
You will need to:
- As a retailer, know what to do when a consumer wants to switch to you, how to validate their request and details
- As a retailer, carry out the process with the losing retailer
- As a retailer, respond to notifications from the gaining provider
- As a retailer, deal with number porting (if you have a relevant voice service chosen by the customer)
- As a retailer, deal with unbundling of voice if you are only providing the internet service
- As a wholesaler, support the process of switching between retailers who are both on your platform
- As a wholesaler, support your retailers who are accepting customers from or losing them to another wholesale platform
- As a wholesaler, carry out gaining / losing switches with the other wholesale platforms
Because the process is driven by the Gaining Retailer once they have accepted the order from the customer, it is likely that the first you will know about a switch is when:
- as the losing retailer, you get a notification from another retailer that you are potentially losing a customer
- as the losing retailer, you will be required to send notification of any Early Termination Charges and Switching implications to your Customer (a mandatory requirement of the new process), so your customer can make an informed choice.
- as the gaining wholesaler, you will get an order from your retailer who will expect you to know how to switch their service.
You may not know these new retailers or wholesalers or have had business dealings with them before.
DCMS has announced that the provisions of the EECC will be transposed into UK law by 21 December 2020 and a consultation on this closed in September. That has led Ofcom to ask the Office of the Telecommunications Adjudicator – OTA2 – to consult with industry and submit recommendations on the new processes by 30 November 2019.
The base capabilities of the new switching process are:
- Consumer Authentication – identify the customer and their authority to switch
- Consumer Intent – confirm the customer consent
- Customer awareness of implications – ensure they understand the implications
- Service / Asset Validation – identify the correct service and assets to be switched
- Reliable process – smooth, minimal loss of service, restoration
The OTA2 working group – ECWG – is sitting every few weeks and has come up with 4 basic models for initial consideration:
- Managed “Provide then Cease” (PtC) with central Hub for allocation of Switch Release Key (SRK)
- Managed PtC with central Hub Database of service ID and providers for Authenticaton
- Managed PtC with 3rd Party verification
- GP-Led Notification of Transfer+ (NoT+) as per current Openreach process
There will need to be a communications mechanism to facilitate message handling between the Losing / Gaining Access Providers and their respective Retailers.
This is not just about number porting. It is about fixed line Phone & Broadband services, and any associated Number Porting. The EECC makes this very clear in Articles 106 and 107. It will affect every INCA Member operating a network, even if only wholesale, and every Member that has retail customers. Article 106 starts:
- “In the case of switching between providers of Internet access services”
It covers every fixed line technology: fibre, copper, wireless, anything.
Number porting will be involved in cases where the customer currently has a voice service as well as internet access and you are the gaining or losing provider of that service at retail or wholesale.
This is separate to, but obviously has implications for, the migration to All-IP services which is being covered by Ofcom’s All-IP Steering and Technical Working Groups and BSG’s IP Consumer Messaging Group. INCA sits on all of these on behalf of its independent network members.
If INCA members would like to give us feedback for any of the Working Groups: Ofcom, BSG or OTA2, raise any issues with them at the next meetings, or be kept up-to-date with our work in this area, please register for the INCA Switching & Wholesale SIG here. We have the papers to date from these working groups and attend them on your behalf.