OTA Identify Areas Needing Improvement in UK Broadband Switching Process UPDATE

The UK telecoms regulator, Ofcom, has revealed the outcome of the Telecoms Adjudicator‘s (OTA) recent review into the remaining problems (i.e. the matching process) with the new One Touch Switching (OTS) system, which was intended to make it easier for consumers to change broadband ISPs but is still somewhat of a work-in-progress.

At present, the OTS process is being implemented by both communications providers directly and a centralised messaging platform via the industry-led One Touch Switching Company (TOTSCo), which all providers need to use. But as previously reported (here), the success rate of the “matching process” (i.e. ensuring that customer switches are correctly verified and migrated between providers) is not as high as the regulator would like.

According to the latest switching data, the daily switch match success rate has risen from c.60% to around 63-64% over the past month (note: some failed switches will still get approved later, after corrections are made). In addition, daily switch orders recently reached peaks of c. 8,000 to 9,000 around the Black Friday weekend.

However, in case anybody has forgotten, Ofcom drafted in the OTA during late September 2024 to work with ISPs, TOTSCo and other relevant stakeholders to “coordinate and facilitate industry effort on matching improvement.”

The OTA has now reported its “initial findings” back to Ofcom, which has resulted in the regulator’s Director of Consumer Policy, Cristina Luna-Esteban, issuing a new open letter to say she remains “concerned that the OTS process needs improvement end to end“, while highlighting which areas need special attention.

Extract from Ofcom’s Letter to Industry

As a reminder, there are a number of regulatory requirements which are relevant to communications providers’ efficient and effective implementation of One Touch Switch. General Condition (GCs) C7.18 requires regulated providers to maintain a single process, One Touch Switch, for relevant switching customers in accordance with the GCs and “any applicable industry processes as agreed by the relevant industry forum”.

Further, the high-level switching requirement, GC C7.4, also requires that providers “maintain simple and efficient process” for switches, “cooperate in good faith and take all necessary steps within their control” to complete the switching process “in accordance with this Condition C7 and Condition B3 and any applicable industry agreed processes”; and “do not delay or abuse” the switching process.

GC C1.8 also requires regulated providers to “ensure that conditions or procedures for contract termination do not act as disincentives for relevant customers against changing their communications provider”.

The OTA2 has identified in their report a number of areas where improvements can and should be made by communications providers to secure improved rates of matching success for customers.
These recommendations include that CPs should:

1. Review their solutions to ensure they are fully compliant with the OTS process, and appropriate Best Practice;

2. Analyse their live matching performance, in both gaining and losing journeys, and collaborate with as many other communications providers as possible to identify root causes and resolve them; and

3. Consider improving their monitoring, reporting and diagnostic capability to improve their ability to identify root causes of failure and fix them.

I have asked the OTA2 to continue their work in coordinating and facilitating cross-industry improvements to matching success. I therefore expect communications providers to urgently prioritise further work to secure improvements to their use of OTS both as losing and gaining providers and to cooperate positively with the OTA2 and other communications providers (in relation to matching improvements) to enable all customers to realise the full benefits of quicker, easier and more reliable switching.

Communication providers can and must do more to ensure that they are compliant with the GCs set out above, so that OTS can be used by all customers in a simple and easy way. Ofcom will therefore continue to monitor the implementation of OTS by individual providers closely, including through our enforcement programme, and will take further enforcement action if required.

We think it’s fair to say that the level of OTS implementation between different communication providers is still quite varied, which continues to cause some problems, particularly with smaller providers. For example, we’ve seen consumers being unable to switch their broadband and phone services because some ISPs still aren’t fully live on TOTSCo’s platform.

In other cases, we’ve had reports about certain providers refusing to match any switching requests (even when the info. is correct) and then failing to engage in a resolution. Most recently, some losing providers have also complained that certain gaining providers are failing to inform them when a switch has completed, which stops them from being able to verify that the customer has fully cancelled / left.

Everybody is aware that implementing something as complex as OTS was always going to be a bit of a bumpy ride, yet it’s important to keep sight of the fact that positive progress is being made. Even if some of those bumps might yet take a bit more effort to iron out.

UPDATE 3:35pm

Ofcom has also just published the OTA’s related Matching Review Summary (PDF).