Broadband ISP Aquiss calls on Ofcom and TOTSCo to fix One Touch Switching
Shropshire-based independent UK ISP Aquiss has today called on Ofcom and the The One Touch Switching Company (TOTSCo) to fix the One Touch Switch (OTS) process, which was designed to make it easier and quicker to change internet provider, but sadly still suffers from a problem with “unsolicited transfers” due to some ISPs trying to game the system.
The OTS system, which went live on 12th September 2024 via a central messaging platform (Hub) that is run by the industry-funded TOTSCo, is a Gaining Provider Led (GPL) process where the customer contacts their new (“gaining“) ISP to start and manage the process on their behalf. In its first two years of operation some 3.5 million consumers have switched their service using the system.
However, the messaging Hub is still not perfect and matching requested switches between providers can sometimes run into various difficulties, which among other things can occasionally result in unsolicited service transfers occurring.
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At present the gaining ISP sends a match request via the TOTSCo Hub; a successful match returns a Switch Order Reference — the Switch ID — which is then used to place the switch order with the losing retail provider. But that identity currently stops at the retail layer.
The order that actually moves or ceases the physical broadband service is raised separately with the underlying network. “There is no mandatory requirement for that network order to carry, or for the network to validate, the OTS Switch ID. The two processes are related in intent, but they are not formally tied together,” explained Aquiss.
The ISP describes this as being a “hole in the framework“, which means a gaining provider can raise a working-line takeover, transfer or provide against a live service “without ever completing an OTS match“. The losing provider then receives an “unsolicited cease or migration from the network, with no corresponding OTS journey to explain it“.
In practice, Aquiss says they end up seeing a “persistent minority of outbound migrations and transfers” where OTS has not been used by the gaining provider, and where no attempt was even made to perform a match. The gaining ISP then later seeks to pass the blame back to the losing provider — even though it is the gaining provider that failed to follow the mandated steps. “Matching is not optional. Where that step is skipped, the customer protections OTS was designed to deliver never take place,” explained Aquiss.
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Martin Pitt, Managing Director at Aquiss, said:
“One Touch Switching was meant to take friction out of changing provider, not to open a back door onto a working line. We still see between two and four per cent of outbound migrations arriving with no OTS journey behind them and no match attempted.
The Switch ID already exists. It is issued when a proper switch is performed. What it does not do today is travel with the order onto the underlying network, and the network cannot check that it is valid. Until those two layers are tied together, gaining providers who skip the match can still move a live service and then suggest the problem sits with the losing provider. That is the wrong way round.
We are not asking for OTS to be unwound. We are asking for it to be finished. Put the Switch ID on the network order, let the network validate it, and the industry will finally be able to say that a switch is a switch — not an unsolicited transfer wearing the same clothes.”
The solution that Aquiss proposes is to require the OTS Switch ID to be present on any network order that would migrate, transfer or cease a working residential service as part of a retail switch. The network should then be able to validate that the Switch ID is current and valid before accepting an order that would cease, transfer or take over a working service.
Aquiss’ Proposed Solution
➤ Require the OTS Switch ID on any network order that would migrate, transfer or cease a working residential service as part of a retail switch.
➤ Give access networks the ability — and the obligation — to validate that Switch ID against TOTSCo before the order is accepted.
➤ Reject or hold network orders that claim to be a customer-led switch but carry no valid Switch ID.
➤ Create an audit trail that identifies the gaining provider at both the retail layer and the network layer, so accountability cannot be shifted onto the losing provider after the event.
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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I’m not entirely sure what problem this is trying to solve.
If a customer chooses not to use OTS and instead explicitly arranges a new service themselves, that’s surely their choice? OTS is there to make switching easier – it shouldn’t necessarily become the only permitted route for every change of service.
There are definitely issues worth addressing around genuinely unsolicited transfers, but tying every underlying network order to an OTS Switch ID feels like it could create a whole new set of headaches for legitimate orders that simply aren’t using OTS.
The focus should surely be on stopping unsolicited transfers, rather than making a particular switching mechanism mandatory in practice.
By bypassing the Hub, the losing provider never generates the implications of leaving communications that are sent via email. So the customer may lose dependent services (such as TV or phone) or find out (after they’ve left) that there is a bill from the losing provider.
These are rare, but the GPL conditions are clear that the customer should be making an informed choice in the situation
Yeah, I completely agree that customers should be properly informed about the consequences of leaving, especially around dependent services and outstanding balances.
My only issue is that OTS was ultimately created as a mechanism to make switching easier for the customer. If a customer understands the implications and deliberately chooses not to use OTS, I’m not sure we should be trying to make the underlying network process dependent on it.
There’s a difference between protecting customers from an unsolicited transfer and preventing a customer from choosing a different route to move their service.
The former absolutely needs addressing. The latter should still be the customer’s choice, IMO.
I don’t think that’s what is being said here, this seems to be referring to a situation where gaining and losing CPs both take part in OTS but the gaining CP then places the order out to CityFibre, Openreach etc. against the wrong premise.
OTS is not perfect we have seen issues with a few ISP’s not responding correctly to requests which means its not possible for us to use OTS as the gaining provider despite our best efforts including trying to reach out to the loosing ISP to work though the OTS issues this is frustrating but at least it does not hold up the actual order we are placing with the network provider.
There are also times as Ayden says where the customer does not want to use OTS that could be for example they are taking us as a secondary connection and want to keep their existing service running alongside.
Perhaps becoming a member of TOTSCo would be a good way to have a say on the way it operates.
Working line take overs will always be required. Think one person has left a property. New occupier moves in. How can the new occupiers ISP take over the service if they haven’t ceased the line.
I do however know from dealing with angry customers there are a number of providers performing working line take overs and not making any effort to use OTS which is frustrating. The loosing provider is unaware the service has moved. Battle then commences with customer on whose fault it is. We see this pain daily.
Are Squirrel a TOTSCo member?
OTS is for switching provider, not switching customer. I was told previously that for new occupiers, providers are expected to order a new line install, not switch an existing still-live service from a previous occupier. More money for Openreach, who’d have thought it? And we’re back round to penalizing smaller operators, rather than the bad operators who created the ‘need’ for OTS, or otherwise trying to create a level playing field and more competition better for the consumer, right? No chance. Don’t be surprised if retail ends up back with just 6 or so big providers all competing for the worst customer service experience.
Yes Squirrel are a TOTSCO member plus we sit on the operational forum. Not one of our Altnet providers will support a second fibre and ONT at the same address. Working line take overs will always needs to be an available option. You will be amazed how many people move out and do not inform their provider
My Aquiss OTS has failed as Martin blame my new provider Olilo but Olilo saying it was Aquiss has failed the OTS earl;ier this year in April. Caused me distressed and anxious. I don’t like OTS!
I believe it down to Aquiss problem with the OTS.
I had Aquiss – I let it cut off -then went with Olio who are just as crap, so I let that cut off too.
Next.
Not sure what happened with your particular services, Simon, but if you had an issue with Olilo, you were always welcome to contact us and give us the opportunity to put it right.
“Just as crap” doesn’t really give us much to work with
If a customer doesn’t want to use the OTS process, they don’t have to. The mandate is that the ISP must offer the service. It could just be they don’t agree to OTS at the point of sale.
How would a customer order a second line, or dual run for a period until they are happy? OTS is optional by design and 4% of switches with no switch order reference seems pretty low to me…
The biggest issue I’ve seen is where a data integrity issue with the network occurs. We successfully match someone’s service, take another property’s line over (as it’s registered against the wrong property) and then when the OTS sends the switch trigger the customers actual service working at the correct address (but registered against another) ceases. So you end up with two problems
Using OTS is risky when there are multiple layer 1 services installed (e.g. when there is more than one ONT installed). I think the only way this could work with OTS is if there is an equivalent of MPRN/MPAN for the communications industry so that the switcher can specify exactly which service they want to switch. Of course this could even be more complicated by CPE having multiple UNI (e.g. multi-port ONT, and L2 services delivered on different VLAN’s – not that I know of any UK providers doing this right now, but the possibility is there).