Ofcom Consumer Switching final statement

1. Ofcom Consumer Switching final statement Next steps for BT Bev Bytheway-Jackson WBC Product Manager 10th February2014

2. Final statement (first phase) – key points • Scope remains: • Voice and broadband switching within Openreach network • Residential and small business customers (NB all customers affected) • Other networks (cable and FTTP) and services (Pay TV?) in next phase • Conclusions from consultation: • Implementation of the move from MAC to Notice of Transfer (NoT) for all voice and broadband switches to be complete by 20th June 2015 • All proposed “front end” enhancements to NoT to be adopted and implemented by 20th September 2014 • First industry working group meeting 22nd January 2014, chaired by Ofcom and supported by OTA • Second phase: • Further examination to consider - the extent and cause of erroneous transfers (largely as result of Working Line Take Overs)- feasibility of extending to include other technologies, networks and services- further development of NoT, or hub/database solution • Details and timeline to be published in Spring 2014

3. Openreach proposed milestones for move to NoT • January 2014 Industry working group to agree governance arrangements and underlying principles of harmonised process • March 2014 Stakeholder agreement on implementation strategy • April 2014 Stakeholders to submit Implementation Commitment Plans & agree e2e process • May 2014 Openreach to issue straw man interface spec, CPs to begin detailed design • June 2014 Wholesale CPs to submit straw man of their interface spec • October 2014 Openreach and wholesale CPs to confirm detailed design • November 2014 Openreach and wholesale CPs to publish final technical spec and CPs to begin interlock testing • January 2015 Final release of Openreach systems updates for CP testing • January-June 2015 Business readiness and testing • June 2015 Launch of harmonised switching process

4. Points to note about NoT implementation • Ofcom have opted for a “big bang” approach • Ofcom recognise that this requires more co-ordination and collaboration across industry than “normal” changes • A number of issues for further debate within the working group, such as:- mandatory use of RIDs on SMPF and FTTx- application of emergency restoration process- KPIs required to support enforcement- strategic KCIs needed from wholesale CPs on losses/ceases • Acknowledged that switches of larger businesses might be impacted, but regulation will not apply, so down to commercial negotiation with Openreach

5. Enhancements to NoT • Record of consent • Call recordings of telesales, “I agree” button for online orders • To include direct record of consent, explanation from CP that it is required to create this record, customer name & address, time, date & means by which consent given, place (where appropriate), address and CLI of target line • Retrievable on an individual basis and retained for 12 months • Provision of better info on implications of switching • NoT letters to contain precise info on ETCs, including means by which they must be paid, calculated according to planed switching date • impact on ancillary/retained services, including price, specific to consumer • clear statement that customer does not have to contact LP • Mandatory use of functionality to ensure seamless transfer of bundled services with no loss of service (e.g. Sim provide, Linked Orders, SIM2) where customer makes a single request to one GP • Mandating some best-practice elements of Working Line Takeover (WLT) process • No WLT order placed without exact match; GPs to take all reasonable steps to identify • Notification letter to “incumbent” customer, via post or another durable format if agreed

6. To be considered in future phase: • Options to address “poor quality Openreach address data – a major cause of Erroneous Transfers” • Whether recent industry developments, such as the MPF helpline, are sufficient to address lack of visibility of key data in identifying correct line • Whether a harmonised process giving consumers a similar end-to-end process regardless of underlying technology is possible (e.g. for moves to/from cable) • Whether further enhancements to the AoT process are needed (e.g. mandating use of Cancel Other • Whether a new GPL solution, based on Transfer Code and an industry database, may be necessary and proportionate