Last year we revealed (here) that Ofcom’s April 2023 deadline for the launch of One Touch Switch (OTS), which will make it easier for consumers to migrate between broadband ISPs on different networks, was at high risk of delay. The latest information suggests that some key aspects won’t even be ready to test until late 2023.
First, the obligatory recap. At present switching between ISPs, at least on Openreach’s national network, 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, such as Cityfibre, Hyperoptic, Virgin Media and many more (Summary of UK Full Fibre Builds).
Ofcom’s solution to this was the OTS process, which in simple terms aims to extend the GPL migration to include alternative networks, while also reducing customer downtime and costs. But getting this right across multiple network platforms is a hugely complex and technical challenge. Nevertheless, in 2021 ISPs were given until 3rd April 2023 to implement everything (back in 2020 the original deadline was proposed to be Dec 2022).
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The biggest ISPs, particularly those that have already adopted Ofcom’s original migration system, arguably have life a bit easier because they’re already familiar with some aspects of this kind of system. But for many others, especially smaller networks that often complain about poor communication from Ofcom, it would be more a baptism of fire. Nevertheless, in order for this to function properly, all ISPs would need to work together.
In response, ISPs across 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. But this was only setup in June 2022 and that left very little time for development and testing of an extremely complex system, which for many providers meant effectively starting from scratch (see last year’s article for more detail).
Suffice to say that it didn’t take long for TOTSCo to start warning that it would “not be possible to meet Ofcom’s April 2023 deadline“, although when we queried this with Ofcom last year they were still maintaining the April 2023 deadline and “[expected] all providers to work with them and make sure they are fully ready at launch.”
In fairness, some ISPs, such as CommunityFibre, Vodafone, Zen Internet, have indicated that they’ll be ready in time (questionable since they’ll all need to engage via TOTSCo for that to be fully viable). But most of the other providers that we spoke with were extremely pessimistic on the timeline, as well as being highly critical of Ofcom’s “poor communication” (some AltNets didn’t even realise OTS applied to them).
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Just to recap. The OTS Industry Process, and the initial specification of the API (Application Programming Interface) needed to interface with the messaging functions of TOTSCo’s Hub, were published on the TOTSCo website in October 2022 (this allows users to start the very early development of their own systems and processes). But actually building all this and then testing it was never going to be quick or easy.
The good news is that TOTSco has been making strong progress since then. Strong in that the organisation is so new, but not in respect of actually meeting Ofcom’s deadline. The group held a Stakeholder Forum in mid-December 2022, which was attended by around 150 figures from across the UK Telecoms industry. As a result of that, and the responses from ISPs, we now have a better idea of where the market currently stands.
Now the bad news. TOTSCo informed ISPreview.co.uk that it’s still too early to give a clear go-live date for OTS, which will depend on how the development and testing goes once the Hub itself is actually available (it isn’t live yet). The current “best estimate” for when the Hub itself will be available for users in a “test environment” is currently at some point between August and November 2023 (subject to revision as discussions continue). This suggests to us that full deployment may not happen until 2024, since testing across such a complex market will probably take months.
As one major broadband ISP told us late last year – “It’s not that we won’t be ready in April – it’s that the whole industry won’t be ready.” The big question now, given this somewhat unavoidable reality, is what will Ofcom do – use the carrot (i.e. patiently delay the implementation, potentially by another year) or the stick (i.e. fines / punishment of some sort until it’s ready).
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We have asked the regulator and await their response. In any case, no amount of wishful thinking or punishment is going to avoid the fact that OTS will need a lot more time before it can be fully implemented. Such a delay will also be damaging to providers too, since building take-up of new full fibre networks is something that would be hugely improved by a faster, simpler (for consumers at least) and more streamlined migration process.
UPDATE 1:35pm
We’ve had a response from Ofcom.
An Ofcom spokesperson told ISPreview.co.uk:
“We are very concerned at the rate of industry’s progress in implementing the new switching process in advance of the April deadline. These changes are vital for making broadband switching quicker, easier and more reliable, and it’s been well over a year since we announced our decision.
We are closely monitoring this situation as it develops and putting pressure on industry to meet the requirements. If the deadline is not met and companies are not complying with our rules when they come into effect, we will decide what action is appropriate to take.”
In addition, the regulator said this about their communication with other providers on the topic: “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.”
Whilst it sounds like a good idea in principle, I think the reality is that it is just too complicated. If I have openreach and CityFibre, with Talk talk on one and Zen on the other, what happens when I want to switch TalkTalk to a different provider? Then what if the gaining provider had agreements with both Openreach and CityFibre?
The example is not particularly complex from the switching side of things. I’d say it’s more complex for the consumer to think about, though. But you, as the consumer, don’t usually get to choose the underlying networks of an ISP, so they’ll just switch your service to whatever network they sell in that specific area.
A more realistic annoyance might be the sheer number of wall mounted ONTs people could end up with in some areas if they switch between multiple different FTTP networks.
My concern is, if I don’t get a choice, what happens if I want to swap TalkTalk in my example, but the new provider devices to swap Zen instead?
You may not have the option to do as you wish anyway Chris.
For example Zen have already stated (and signed an agreement with CityFibre) that in areas with both Cityfibre and Openreach then they will choose Cityfibre by default.
So it may not be possible to have 2 concurrent networks live at the same time over 2 access networks if they involve providers who work over both networks.
The OTS (One Touch Switch) system being discussed here will definitely not be designed with multiple connections in mind.
It is being designed for the average user who has 1 single connection at a time, switching from provider A to provider B.
Your requirements of having 2 live connections over separate networks will have to be manually ordered and likely won’t support migrations.
Theat isn’t a big deal.
You just pay for an additional line to be installed to have two connections. The same as now, you can have 2 or 3 open reach connections
Hate to say it but not surprised at all – the meetings held by OTS have been nothing short of a shambles, with the main person practically admitting that they were relying on outsourcing devs to tender to actually deliver the solution.
Interesting that Ofcom hasn’t picked it up and realised that if OTS continue nothing’ll change and they probably need to do it themselves to guarantee something actually workable for both providers and subscribers
“Interesting that Ofcom hasn’t picked it up and realised that if OTS continue nothing’ll change and they probably need to do it themselves to guarantee something actually workable for both providers and subscribers”
I really can’t see how Ofcom doing it themselves would guarantee anything – well, not anything workable in my lifetime anyhow! 🙂
What a shock
NOT
if I was moving from one network to another, I would make sure the new one is working first before I cancel the old one, even if it cost me extra for another month or so.
I want this yo happen and on time. I know of a lot of providers working on this. There will be teething problems, but with the investment and time many altnets have had there is no excuse for using the committee that was set up for them to harness this. I have read many of the files and I can’t believe some providers are using the excuse of bot being spoken to by ofcom. This will be better for consumers, just like the cs&Ci has been
I cannot understand why this is an issue now when the CWP (Common Wholesale Platform), which runs on a not for profit basis, has a few altnets signed up already and has a platform that works …. is not an option.
TOTSCO arguably has larger stakeholders but they are late to the party whilst others had already done the work to solve this problem …