Are UK CSPs ready for changes in billing and notification requirements?

In one of its very last actions pre-Brexit, the UK ratified the European Electronic Communications Code (EECC) in December 2020 – transposing it into law by updating the Communications Act 2003 and the Wireless Telegraphy Act 2006. As a result, there will be a number of changes to the UK telecoms market that affect all players, with the first tranche of change coming in December 2021. In general, the EECC has five main objectives:

  • to promote investment in high capacity networks (such as fibre and 5G)
  • to promote competition
  • to develop the internal market across the EEA
  • to level the playing field between traditional telecoms players and OTT players
  • to protect customers.

In this article we’re going to focus on the last point – how changes will affect the service that customers can expect. Although we’re focusing on the UK, similar changes apply to other European markets, as the EECC is one of the essential building blocks of the EU’s Digital Single Market.

19 December 2021 changes

There will be a number of changes to general terms and conditions of operation in the UK that apply from 19th December 2021, including:

  • adding the definition of “number-based interpersonal communications service” to bring the general conditions into alignment with the Communications Act 2003
  • updates to conditions & procedures for contract termination (C1.8), the prohibition of handset locking (C1.9), contract duration (C1.11, C1.12), information on bundles in end of contract notifications and annual ‘best tariff’ notifications (C1.23-C1.36), sharing of information with third parties (C2.19-C2.21), publication of information (C2.3, C2.4, C2.16), billing notifications (C3.7, C3.13, C3.14) and providing communication materials in accessible formats (C5.15).

June 2022

From June 2022, CSPs must provide better contract information, customers will gain stronger termination rights and CSPs will need to support an emergency video-relay service.

December 2022

By the end of 2022, customers will benefit from improved switching processes for broadband. This provision is currently undergoing consultation and may change during the course of 2022.

What these changes mean for customers and CSPs


Current requirements are aimed at ensuring that switching terms, conditions and procedures do not act as a disincentive to customers to change service provider. These requirements are now being extended to bundles that contain a range of services and hardware (such as CPE or mobile phones). The guidance provided includes explicitly extending provisions for contract termination, auto-renewal, and contract notifications to micro, small enterprises, and not-for-profit customers as well as consumers. End-of-contract notifications, annual best tariff notifications and publication of information is also being extended to bundles – including internet access services, number-based interpersonal communication services, content services and terminal equipment (such as handsets).


Selling locked devices will be banned. Providers will be required to ensure that no handset locking restrictions are applied to a user’s mobile device when sold or provided as part of a bundle that prevents it being used on another service provider’s network. In June 2022, customers will be able to have these handset locking restrictions lifted free of charge, on or before the day in which the contract is terminated.

Balance data

Service providers will be required to give their subscribers access to adequate and up-to-date billing information at no extra charge to allow them to verify and control their charges and monitor their usage. The aim is to give subscribers “reasonable degree of control over their bills”.


The new GCs will also contain further rules on accessibility for users with disabilities – extending the definition of disabilities as well as the scope of provision.


The conditions have been rescoped to apply to “microenterprises and small enterprise customers” in addition to consumers. For the first time, OTT providers such as Skype and WhatsApp will now have to comply with certain Ofcom provisions, bringing them in line with traditional telecoms operators. 

You can read the detail of the changes on the UK regulator Ofcom’s website: here.

Omnisperience view

While the changes may seem minor, they do have significant consequences and it’s important to understand the trajectory of these rules. Three key objectives emerge: (1) to level the playing field between regulated telecoms providers and OTT providers (2) to give customers more rights, transparency and control, and to end telecoms industry practices that are deemed detrimental to customers (3) to extend provision from the consumer market to cover all small businesses.

The choice UK CSPs are faced with it doing the minimum to comply with the new rules or to take this as an opportunity to fundamentally change the way they engage with their customers.

Future success requires them to become more communicative with their customers about changes and charges – which means having the ability to notify mid-cycle customers about issues that affect them and providing realtime balances, as well as ensuring customers are on the best deal for them. In the past many CSPs have used bait-and-switch tactics where the best offers are reserved for new customers and there was a reliance on obscure and onerous terms & conditions, overage charges, and contract lock-ins to raise additional revenue and constrain customer usage. In future they need to reward loyalty, become easier to do business with, and improve the way they communicate with customers.

This poses a question to the industry: will it do the bare minimum and constantly have to be dragged into customer experience improvements by the regulator? Or will it seize the opportunity to do what is spends a lot of time talking about, but far less time doing, and become truly customer centric?