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UK ISPs Set to Miss Ofcom’s Broadband Switching Deadline

Saturday, Nov 5th, 2022 (12:01 am) - Score 8,488

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.).

NOTE: See our up-to-date ‘Summary of UK Full Fibre Build Progress‘ for a list of alternative UK networks (AltNets).

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.

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By Mark Jackson
Mark is a professional technology writer, IT consultant and computer engineer from Dorset (England), he also founded ISPreview in 1999 and enjoys analysing the latest telecoms and broadband developments. Find me on X (Twitter), Mastodon, Facebook and .
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19 Responses
  1. Avatar photo Kris says:

    Where switches should be easy, Ofcom should be enforcing sensible rules.

    Where switching isn’t easy eg openreach to Virgin etc then trying to mask the complexity of such a move is a waste of time and effort.

    Most people switching would have both services live with an overlap surely? There’s no guarantee on the new service install date.

    1. Avatar photo Ad47uk says:

      If I moved from FTTC to an Alt network, I would certainly want an overlap just in case, so I would not use the One touch switch thing.

    2. Avatar photo Jonny says:

      That’s fine, it’s your decision. The intent behind the one-touch switch is that the gaining provider can tell the losing provider that you are leaving, and to stand by for confirmation that the new service has gone live so that the old service can be ceased. It’s designed to avoid the current situation where e.g. people serve their 30-day notice on an Openreach service and then Virgin Media don’t install when they say they well, and the customer loses their connection completely. Or where you end up paying for a month of overlap because you can only comfortably serve notice on your old connection once you are sure the new one has been installed and works.

      Personally I’m with you – paying for a month of two connections being active is far preferable to even a day without connectivity (a train ticket to the office costs nearly as much as a month of broadband), but for low income households looking to move from something like a £22 TalkTalk FTTC to a £12.50 Community Fibre service, the possibility of a month where your internet bill comes to £34.50 is enough to put you off switching.

      I’ve not looked into the rules around the one touch switch process, but one of the most important parts has to be an element of punitive compensation (three figures) paid to the customer if a gaining provider gives notification to the losing provider to cease before they’ve actually got their connection installed.

    3. Avatar photo Ad47uk says:

      @Jonny. I know what the intent behind this one touch thing is, the problem is a lot can go wrong, changing from one supplier to another on the same network can sometimes go wrong, I just think there is more to muck up when changing from one network to another, which is why I would not cancel the one before i have made sure the other one is working, I know it will cost more money.

      we will see how it goes.

  2. Avatar photo Rob smith says:

    So basically if I’m gave them notice yet most of them are done little to nothing I hope ofcom punish their lack of action

  3. Avatar photo Reality says:

    It will take 9 months to build and test the hub solution then 9 months for ISPs to integrate and test. So that’s 18 months. And this is after a software development company is picked to implement the solution and according to TOTSCo this hasn’t happened yet.

    Even April 2024 is looking hard to achieve.

    If the hub isn’t ready, OFCOM would have to fine every provider for not being ready? As they can’t fine TOTSCo…

    1. Avatar photo Walter says:

      Yes they’ll fine every provider and where do you think that money will come? Where will the money come from for providers to join TOTSCLUB to pay for the software developers.
      Yep will end up with a have ar5ed broadband provider migration system that won’t work properly and higher broadband costs.
      Reminds me of number portability, exactly the same thing. “Hey Ofcom we are going to lose money everytime someone ports a number away” Ofcom response, “yes we know, we expect you to build that into your margins” just put your prices up everyone, the british are used to it

  4. Avatar photo Justin says:

    Ofcom: “You have until April 2023 to comply”

    ISP: “Ok our software development team have been ready since January 2022 to develop our API to the industry switching platform. Can we have the detailed in terface specification please?”

    Ofcom: “Ah, well we don’t actually have the interface specification yet. Or a platform or a supplier. But a company has been set up to find a supplier and procure a system”

    ISP: “So when will you have a spec we can develop against and a system we can test against?”

    Ofcom/OTA2: “Well the procurement has only just started so we’ll get back to you on that”

    ISP: “You do realise it’s not just the network providers that will need to use this, there are literally hundreds of service providers and re-sellers for broadband and VoIP that will need to queue up to test against the platform? If the platform isn’t even selected yet never mind in place yet how is that going to happen in the next 5 months?”

    Ofcom: “You have to comply by April 2023”

    ISP: “WTF!”

    1. Avatar photo Eccles says:

      Yup! It’s crazy. And the some of the documents released last week from TOTSCo are still drafts or ridiculously long (84 pages!). The API docs are sort of useable to get started but just present more questions.

  5. Avatar photo occasionally factual says:

    Any idea of which company is actually providing all of the software, hardware etc for TOTSCo? And how much that organisation is charging as the retail customers (us) will be picking up the bill via increased subscription charges?
    I bet that organisation is a very much for profit company so the so called not for profit TOTSCo is going to make some people much richer.

    1. Avatar photo ES says:

      At the moment even TOTSCo don’t even know the charges, or who is building the software or hardware!

  6. Avatar photo Brian says:

    Expect a legal challenge in 3…2…1…

  7. Avatar photo Jamie Felstone says:

    I recently wanted to switch from Talk Talk to Vodafone on Cityfibre and Vodafone wouldnt allow me to order, without calling talk talk.

    No I’m without Internet as somehow, talk talk cut the line and Vodafone still can’t place the new order. It’s been like this for 12 days.

  8. Avatar photo Ivor says:

    this “totsco” thing gives the same vibes as the smart meter fiasco. Too many middlemen and moving parts – but then that’s the hallmark of the alt net movement.

    The mobile sector seems to be able to manage this among themselves quite well.

    1. Avatar photo Iain says:

      Eh, it takes 2 working days to port a mobile number. That’s appalling compared to Ireland, where it’s something like 2 hours IIRC. I’ve also had issues when porting a number back to the original provider.

  9. Avatar photo Tim S says:

    Hi Mark – to make the article more balanced it might be better to seek comment from TOTSCo. Draft API and a very detailed process specification has now been published; these have to remain draft whilst system development continues. This has had significant input from experts across industry and includes measures to prevent slamming. The membership list was limited because membership application forms had not been sent out by TOTSCo, this has now happened. TOTSCo should be able to say how many operators have signed up for free updates from them. Ofcom have placed the obligation on industry to get this sorted so those expecting updates from Ofcom should probably instead sign up for TOTSCo updates https://totsco.org.uk/ . The annual membership fee for INCA is probably less than the fine operators might receive from Ofcom and so I argue probably represents good value for money.

    1. Mark-Jackson Mark Jackson says:

      At the time I started doing the research for this in the summer, TOTSCo didn’t seem to have any staff or media contacts who could comment. Instead, I felt it was more than balanced enough to seek comment and feedback from 30 odd ISPs, including the bulk of those on the group’s member’s list – some of which have been directly involved in its design.

  10. Avatar photo HullLad says:

    It’s quite amazing that some (e.g. B4RN) are confident of being ready by April when the platform that will enable it literally doesn’t exist yet…

  11. Avatar photo Lee says:

    If the entire industry turns around to Ofcom and says “No” to April 2023 what can they realistically do? Fine everyone?

    Even the clued-up providers and resellers who are aware of the changes and willing to work to the deadline still have to wait for TOTSCO to release a secure hub that won’t leak customer data all over the web.

    Added to this, most resellers sit within a giant ecosystem of dependency on third party billing providers, ecommerce developers and wholesalers who will all need to build this into their roadmaps and allocate resources to it. It ain’t going to be done by April, no matter what Ofcom “expects”.

Comments are closed

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