Ofcom UK Probe Primo Dialler Over Possible Misuse of Phone Numbers

The UK telecommunications regulator, Ofcom, has today opened a new investigation into call centre solutions’ provider Primo Dialler, which will examine “concerns that numbers sub-allocated to [the company] are/were being misused, including to facilitate scams.”

The regulator is concerned that Primo Dialler may have failed to comply with its obligations under their rules, specifically the General Conditions of Entitlement GC B1.8 and GC B1.9(b) and (c). The rules reference a requirement for such businesses to ensure that they’ve taken reasonably practicable steps to ensure that their customers are using telephone numbers correctly and that they don’t transfer use of such numbers from the National Telephone Numbering Plan (NTNP) unless that is the case. The numbers, once transferred, must also be used effectively and efficiently.

Ofcom added that they “also have concerns as to whether Primo Dialler is persistently misusing, or has persistently misused, an electronic communications network or services“, which is all explained in more detail below.

Ofcom’s Statement

We have concerns as to whether Primo Dialler has failed to comply with its obligations under the GCs, specifically:

GC B1.8 which states that “the Communications Provider shall take all reasonably practicable steps to secure that its Customers, in using Telephone Numbers, comply (where applicable) with the provisions of [GC B1], the provisions of the National Telephone Numbering Plan and the Non-provider Numbering Condition”; and;

GC B1.9(b) and (c) which state that “the Communications Provider shall not transfer use of Telephone Numbers from the National Telephone Numbering Plan unless… the Telephone Numbers are used in accordance with the National Telephone Numbering Plan; and the Telephone Numbers are Adopted or otherwise used effectively and efficiently”.

We also have concerns as to whether Primo Dialler is persistently misusing, or has persistently misused, an electronic communications network or services. Under section 128(5) – (7) of the Act, a person misuses an electronic communications network or service if:

1. the effect or likely effect of his use of the network or service is to cause another person unnecessarily to suffer annoyance, inconvenience or anxiety; or

2. he uses the network or service to engage in conduct the effect or likely effect of which is to cause another person unnecessarily to suffer annoyance, inconvenience or anxiety.

Misuse can be considered “persistent” where it is repeated enough for it to be clear that it represents a pattern of behaviour or practice, or recklessness about whether others suffer annoyance, inconvenience or anxiety.

The investigation will now seek to establish the facts surrounding this matter and examine whether there are reasonable grounds to believe that Primo Dialler has failed to comply with the rules. Such investigations can often be a slow and complex process, which means we may have to wait until much later this year or sometime in 2026 to learn the final outcome.