Ofcom Partially Delays New UK Broadband Switching Process by 6 Weeks
The UK telecoms regulator, Ofcom, has today acknowledge that their already much delayed new One Touch Switch (OTS) system for faster consumer broadband ISP migrations won’t be 100% ready for launch on 12th September 2024. But rather than delay it, again, they’ve instead ordered providers to retain the old system for a further 6 weeks.
Just to recap. The new approach expands the existing Gaining Provider Led (GPL) migration system to work across alternative networks (the old system was mostly only focused on Openreach based providers) and to action switches within just 1 day instead of 10 days “where technically possible“. But that has required masses of internet providers to work together, and the development process has been a bit.. bumpy (here, here, here, here and here).
The industry-led One Touch Switching Company (TOTSCo), which is responsible for implementing the regulator’s OTS migration system, had most recently been expected to fully introduce the new system from 12th September 2024 (here), which is over a year past its original launch date of April 2023. But Ofcom has today recognised that the testing process for this still needs a bit more time.
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However, rather than suffer the embarrassment of having to delay the launch again, the regulator has instead ordered ISPs to retain the old migration process for an additional six weeks. “This would enable customers to be switched using the existing NoT+ process as a back-up option, and only in those circumstances where communications providers, having started the switching process via OTS, find that it is not possible to technically proceed,” said Ofcom. Put another way, OTS isn’t yet fully ready for prime time, but ISPs don’t have long to ensure it gets there.
Ofcom’s Letter to Communication Providers
One Touch Switch implementation – Extension of NoT+ consumer protections
I am writing to update you on Ofcom’s position regarding the enhanced Notification of Transfer (NoT+) functionality in light of the progress of the continuing One Touch Switch (OTS) industry trials.
The OTS Hub was made available by The One Touch Switching Company (TOTSCo) for live customer switches in July 2024. This has enabled a programme of live customer trials of OTS to be undertaken by communications providers with the goal of steadily increasing volumes of OTS customer switches towards full launch, with 20 brands already participating. This ramp up plan is essential to ensure that the OTS process is working effectively and reliably for customers before NoT+ is turned off.
The most recent information we have received from communications providers and TOTSCo indicates that although there are large and increasing volumes of customers being switched successfully using OTS, these volumes have not yet reached a level to provide sufficient confidence that all customer switches will be able to follow the OTS process by the planned industry launch date of 12 September 2024. I understand emerging evidence from the trials has indicated a need for providers to carry out further analysis and improvements to ensure the matching process achieves a sufficiently high success rate to effectively support all customer switching journeys, but these improvements may not be fully implemented by the planned launch date.
We expect all communications providers in scope of OTS to do everything possible to accelerate the full adoption of OTS for all customer switches, and for OTS to be the main switching mechanism from 12 September 2024.
However, in light of the progress to date, we consider that it would be appropriate to retain the existing NoT+ functionality, for a limited period beyond 12 September 2024. This would enable customers to be switched using the existing NoT+ process as a back-up option, and only in those circumstances where communications providers, having started the switching process via OTS, find that it is not possible to technically proceed. To this end, I am today writing to Openreach, KCOM and wholesalers who operate NoT+ to ask that they delay its removal for a six-week period. We will review progress during this time including requesting information from communications providers on the number of switches concluded via OTS, and those which may have had to be put through the NOT+ process and the reasons for this.
To be clear, we expect providers to use OTS in the first instance for all switches and only to consider the back-up NoT+ process when it is not technically possible to proceed with the switch through OTS, for example, if it is not possible to resolve a matching failure. This is to help protect consumers and ensure they receive the necessary information about their decision to switch. It is imperative that providers continue to make urgent progress with implementing improvements to the OTS process and we therefore expect any need for use of the NoT+ process as a back-up option to rapidly reduce over this period. Notwithstanding the extension of NoT+, providers must not use Cancel Other functionality for any OTS switch.
We understand that all communications providers who are to date participating in the OTS ramp up are fully committed to supporting 100 percent of customer switching journeys as a losing provider. Therefore, this should enable other providers to continue with existing plans to sign up with TOTSCo to use the OTS Hub and start gaining customers using the OTS process from 12 September 2024. Any provider which currently uses NoT+ should be aware that, for this 6-week transition period, they may need to support a proportion of losing customer journeys within the existing NoT+ process as well as via OTS.
Ofcom will continue to monitor the implementation of OTS closely. I expect communications providers to cooperate positively including with TOTSCo, network operators and wholesalers to ensure that customers continue to be able to switch services smoothly during this transition and that OTS can be fully adopted with the greatest urgency. In particular, it is important to share any insights from analysis of the matching process. I have asked the Office of the Telecommunications Adjudicator to continue to work closely with industry to ensure a smooth and speedy transition. As previously announced, our ongoing enforcement programme will review the conduct of all industry participants since our statement in 2021 in order to determine whether it is appropriate to open investigations into individual providers after launch.
Yours sincerely,
Cristina Luna-Esteban
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, BlueSky, Threads.net and Linkedin.
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This is scary:
“…indicated a need for providers to carry out further analysis and improvements to ensure the matching process achieves a sufficiently high success rate to effectively support all customer switching journeys”
Surely if ALL customer switching journeys are to be effectively supported, the matching process needs to be 100% successful? Taking the phrase “matching process” to include both fully automated and manual-assisted matching.
The TOTSCo ‘spec’ (and I use that word rather lightly) has an SLA of 60 seconds response time 24/7 for matching. Manual intervention isn’t really an option.
This will come as a surprise to absolutely no one who is aware of Adrian Kennards open letter to Ofcom. ISP Review covered it at the time here:-
https://www.ispreview.co.uk/index.php/2024/07/andrews-arnold-clash-with-ofcom-over-broadband-isp-switching-woes.html
So what is the process if say you’re a tenant, your tenancy just expired and you moved out without cancelling, and a new tenant has moved in and wants to switch to a different provider?
Are they treating that as a cancellation and new sign-up, or is it one that they’ll screw up using OTS (your details won’t match the existing customer details)?
Home moves were out of scope for OTS, so would assume it would be as you say.
Does anyone at OFCOM have any experience in managing IT projects?
That’s the problem – they don’t run the projects at all, and would not listen to the industry when they told them how problematic it would be to try and match customer data and services with another provider’s customer data and services. They just insisted that it must be implemented.
They’ve now forced a situation where it will likely become much more frustrating for customers trying to leave via the OTS process. This is not the utilities or mobile industry, much as they’d like it to be.
Disaster waiting to happen really, only AAISP customers have a anti slam mechanism on this system.
Surely a basic system would have been simpler?
Person orders with “gaining provider” and picks/is given an installation/service start date with punitive penalties (which go to the end user!) if gaining provider doesn’t meet deliver.
Then a simple “Text to cancel” service to cancel service with losing provider.
I’ve been saying this for the best part of 5 years. A return to where a customer obtained a MAC (Migration Authorisation Code) from the old provider to give to new new provider, was how this should have gone back to and not the crazy situation we now as an industry find ourselves in.
The whole process could have easily been extended to include all networks. Old provider generates a MAC from a central database and unlocks the circuit ready for a move, this is valid for 7 days. This is given to new provider, who then validates the MAC from the central database along with a customer postcode to make sure they match. This then provides a link between 2 providers/networks to move customer over, agree dates and handover. The flow back and forth would keep everyone in the loop. Honestly very simple to work with. Those who have domain names will find a very similar method for moving them with EPP codes.
What we have now is too many people without industry knowledge trying to feel important who have created a overly complex approach, for all parties (SPs and customers).
Martin Pitt
Managing Director
Aquiss Limited
http://www.aquiss.net