UK ISPs Set to Miss Ofcom’s Broadband Switching Deadline

A growing number of UK broadband providers, particularly those that are building alternative Fibre-to-the-Premises (FTTP) networks, are growing concerned that they won’t be able to meet Ofcom’s April 2023 deadline for the introduction of the new One Touch Switch (OTS) ISP migration system. Delays look inevitable.

Just to recap. At present switching between Internet Service Providers (ISP) on Openreach’s national network infrastructure is an easy and largely automated Gaining Provider Led (GPL) process (i.e. just contact your new ISP, and they’ll get the ball rolling), but this doesn’t work for operators on physically separate networks (Cityfibre, Hyperoptic, Virgin Media etc.).

At the end of last year the UK telecoms regulator, Ofcom, moved to resolve this by finalising the process for their new One Touch Switch (OTS) system, which in simple terms will extend the GPL migration to include AltNets. The goal is to make it easier for everybody to switch around in the market, while also reducing consumer costs and downtime. The rules require that ISPs have all of this implemented by 3rd April 2023.

The reason for the long lead-time to deployment is because creating a system like this, which must be able to work smoothly across multiple different physical networks in real-time, is a very slow, complex and costly process. In theory, work on the integration of all this should now be reaching maturity and moving into the final pre-launch phase of testing (OTS has been in the pipeline for years), but all is not well.

The Issues

As part of the preparation for this article, we engaged a large cross-section of over 20 different providers, both big and small alike. Some spoke to us on-the-record and others preferred to keep their feedback anonymous, but the majority echoed a mix of concerns about implementation of OTS – e.g. issues of awareness (some AltNets / ISPs don’t realise it applies to them too), poor communication from Ofcom and technical challenges.

The biggest ISPs, particularly those that have already adopted Ofcom’s original GPL migration system for Openreach, arguably have life a bit easier because they’ve already done a lot of related work. But even they have to adapt this to work across multiple networks, and that’s where a lot of the problems arise.

Naturally it’s difficult to work across so many networks, thus in June 2022 the industry established The One Touch Switching Company (TOTSCo) as a not-for-profit vehicle – owned by the membership – to take responsibility for the development and operation of the related messaging platform.

However, at present TOTSCo only has a few ISPs as members (Air Broadband, BT, CityFibre, Gamma, Sky Broadband, TalkTalk, Virgin Media and Vodafone), which means that the vast majority of AltNets have yet to join. Furthermore, the technical / API system being developed under TOTSCo is still in its infancy, with many question marks over how it will prevent slamming (moving a customer’s line without their consent), protect personal data and arrange its contract terms.

In terms of the risk from slamming, Ofcom’s old GPL system included a 10-day notification period, which gave ISPs time to process the switch and stop abuse if it occurred. The new system does away with that 10-day wait because Ofcom considers that the industry-proposed design of OTS contains “sufficient safeguards” to protect against the risk of slamming (e.g. a switch order cannot be placed without a successful match, which requires multiple pieces of information about the customer and their services). But getting all of this to work is another matter.

Finally, a number of ISPs, particularly smaller players, seem to be adopting the “wait and see” approach, which is a risky path to take with a regulator like Ofcom that will no doubt launch an enforcement programme to tackle any failures of implementation (big fines are possible). Unless, that is, Ofcom recognises the system may not be ready in time.

Some ISPs have even pondered whether it might be better to stop taking on new customers from outside Openreach’s systems (i.e. from AltNets) for a while to avoid running afoul of the rules, only adding other networks, one by one, as they feel the process works with them. But it’s unclear how Ofcom would view that.

Expect Delays

One of the best hints that something might be wrong came during the recent Connected Britain event, which included a presentation on TOSCo’s progress. The slides noted that the group is still only getting itself established (on 1st August 2022 it had just one dedicated employee – the CEO) and then there’s this quote: “Work is progressing at pace BUT it will not be possible to meet Ofcom’s April 2023 deadline.”

TOTSCo is said to have written to Ofcom to “explain delivery by the deadline is not possible“. Instead, they are trying to develop a more “achievable timetable“, although when we put these concerns to Ofcom they responded by reiterating their expectations for OTS to be implemented on time.

An Ofcom Spokesperson told ISPreview.co.uk:

“It’s been over a year since we finalised our plans to make it easier than ever for people to switch broadband provider. We gave companies until April 2023 so they could make the necessary changes to their systems in order for it to work well for customers.

It’s the responsibility of all providers to make sure they comply with our rules, including any changes we make to them. The new switching requirements have been well publicised and we’ve been talking to industry throughout the process.

An independent company has been established with responsibility for setting up and operating the new system. We expect all providers to work with them and make sure they are fully ready at launch.”

Except, they’re clearly a very long way away from being “fully ready at launch“.

What Do ISPs Say?

In terms of the many providers that supplied anonymous feedback, here are a few choice quotes from different industry sources.

Summary of Anonymous ISP Comments

➤ “We’ve had limited communication from ofcom. We are yet to sort anything and accessing information has been sketchy [unless you have expensive INCA membership].”

➤ “We signed-up with Ofcom to receive updates but have not had anything from them as yet. It rather feels like they are running behind schedule, particularly if they want to hit their deadline of April.”

➤ “First I’ve heard of [OTS].”

➤ “Not really given it much thought to be honest.”

➤ “I can see massive abuse [from slamming].”

➤ “The real problem is actually accurately identifying customers and communicating consequences and hoping the gaining provider actually does what the customer asks if they want to undo the transfer.”

➤ “The documentation they’ve produced is very comprehensive about the process, but has no details about the API yet” (a lot of ISPs raised this point).

➤ “This is, of course, a massive **** of ***** which will be abused and cause no end of angst and woe. It is a sledgehammer solution rattling around the empty heads of OFCOM searching for a nut of a problem.”

In terms of official on-the-record comments, the feedback is much more measured (these came via a largely different set of providers). Sadly neither BT, Sky Broadband, Virgin Media (VMO2) or TalkTalk were able to furnish us with a public comment, which may again suggest a lack of confidence in the deadline being met.

A Spokesperson for B4RN said:

“B4RN are in contact with TOTSCo (The One Touch Switching Company) and we intend to use the TOTSCo Hub as our OTS Solution. Our pace of implementation is therefore dependent on the development of the TOTSCo hub. We’re very pleased that TOTSCo has been established by the industry, as a not-for-profit company, to design a solution that will allow all providers to comply with the new regulations.”

Peter Rampling, CCO of CommunityFibre, said:

“Yes, Community Fibre will be ready for Ofcom’s One Touch Switching in April 2023. We are very supportive of Ofcom’s initiative as it will make switching providers seamless and easier for the consumer.”

David Barber, Strategy Director at Zen Internet, said:

“We are working to scope and plan requirements for Ofcom’s new one touch switching regulations for residential and single line small business customers due to come into effect in April next year. We have an internal project team and accompanying project plan in place and have every intention of being ready to go live in line with the industry.”

A Spokesperson for Vodafone said:

“We are working with the rest of industry on the implementation of the new switching regulation.”

As we understand it, TOTSCo will shortly go out to and procure a ‘hub’ solution on behalf of all providers. But that solution will then have to be built and, only after that, will ISPs be able to conduct an extensive period of testing and implementation. Not forgetting that a lot of wholesale suppliers (e.g. BT Wholesale, Cityfibre Wholesale) will also need to be ready, but they’re facing some of the same challenges as retail ISPs.

As one of the major providers told us off-the-record: “All of that will take a long time. As that’s how the solution is being delivered, it’s not that we won’t be ready in April – it’s that the whole industry won’t be ready.” In short, Ofcom may have to face the reality that OTS is not going to be fully ready by April 2023.