2023 consultation responses

In response to the 2016 consultation, we recognised the effort and investment that had been put into improving broadband coverage and speeds by providers, Government and Ofcom to date. While we applauded that effort, we also highlighted that there were still large gaps in availability of a usable broadband service. Unfortunately, gaps remain in 2023, which continue to cause detriment to large numbers of citizens, consumers and micro-businesses, often disproportionately so for those living and working in remote and rural locations across the UK. We therefore agree that a broadband USO is still and will still be, required to ensure a legal right to request a decent broadband service.

We strongly agree that interventions are required for very hard to reach premises and that alternative approaches are required. The consumer, citizen, micro-business (broadband consumer) journey towards reliable, fast broadband is currently inconsistent and for some, frustrating, disappointing and costly (both in terms of time and money). Broadband consumers who wish to receive an improved service, or get connected for the first time, have a lot of work to do in finding out how to make this happen.

We support Ofcom’s consideration of the impact of roaming on all the UK’s consumers, those travelling outside the UK and particularly those who inadvertently roam while in the UK.

The impact of an unexpected bill increase during a cost-of-living crisis can lead consumers to making even tougher decisions than would normally be the case and it is our belief that all consumers should have the right to affordable, fair and reliable communications services.

The Panel supports Ofcom’s continued focus on the monitoring the quantity and quality of access services on broadcast and on-demand programmes services. Accessible and inclusive TV can be a lifeline to consumers of TV and on demand content (‘audiences’) who have less accessibility to other aspects of society.

The Panel is a strong advocate for universal access to affordable, reliable communications services – including postal services – and we passionately believe in retaining the safeguard cap to protect postal services users for at least a further five years.

Our engagement with other consumer advocates across the UK, as well as charities and not-for-profit organisations, strengthens our view that this level of regulatory protection is still needed in the digital age. Consumers use second class post as a gateway to services across sectors, particularly when they are not able to use email on online forms.

The Panel advocates for strong action against scams and number spoofing and our response is in support of Ofcom’s proposals. We pushed the communications industry firmly towards providing caller line identification (CLI) facilities at no additional cost to consumers, as a trusted, reliable service for all.

CLI is a tool that can empower consumers to identify a caller and based on that information, decide whether to take a call - that thought process is highlighted in Ofcom’s consultation document. It is vitally important that the information upon which consumers are making the decision to answer and trust a caller is authentic and accurately presented.

We welcome the opportunity to respond to the questions asked in the consultation that fall within the Panel’s remit. We consider that digital communications are an essential, gateway service in UK society today. Consumers and citizens who are not able to pay to stay connected to these services, or who cannot afford to use them are in a form of financial and social poverty that should be tackled by those with the power to assist them. 

We support Ofcom’s review of its approach to impact assessment, which we believe is a cornerstone to a fair communications market for consumers, citizens and micro businesses.

We support Ofcom’s proposal to introduce guidance for broadband providers on clearer information for broadband customers, informed by timely research.

Access to digital communications is now seen widely as a vital part of UK consumers’ everyday lives, as we hear regularly from those who take part in our independent research.

We welcome the Phone-paid Services’ (PSA) proposed amendments to Code 15, regarding Information, Connection and Signposting Services (ICSS). It is – in our opinion – vital that strong and clear action is taken to protect consumers who use these services from confusion and cost.

We have worked closely with the PSA, its Consumer Panel, Ofcom and members of our Industry Forum who represent the mobile sector, to understand the scope and impact of unfair and uncompliant practices by ICSS providers, which cause harm and inconvenience to consumers. We are keen to see action taken against those that do not comply with current regulation and cause harm and detriment to consumers.

We welcome the Consumer Council for Northern Ireland’s (CCNI) attention to the needs of consumers in Northern Ireland (NI) and value our collaboration with them on matters of mutual interest and concern. We work regularly with the CCNI under its postal services advocacy remit and its cross-sector workstreams.

The CCNI’s insights to our Northern Ireland Consumer Stakeholder Hub and our UK-wide Consumer Advocacy Hub can always be trusted to deliver the NI consumer perspective reliably and have helped us to shape previous research in a way that is useful to both organisations.

We welcome Consumer Scotland’s attention to the needs of Scottish consumers and support their focus on the key themes of tackling the cost of living; climate change, mitigation and adaptation; and a focus on consumers in vulnerable circumstances.

Consumer Scotland’s remit is wide-reaching and we hope that our sector-specific expertise will enable both organisations to share insights that benefit as wide a range of consumers as possible, in Scotland and across the UK communications sector.

We welcome the opportunity to comment on Citizens Advice’s draft workplan. We value regular collaboration with Citizens Advice as an active participant in our Consumer Advocacy Hub for the communications sector (including postal services) and look forward to working closely with them in the year ahead. We share many of Citizens Advice’s main aims and objectives, with our different remits enabling our complementary consumer advocacy functions to work harmoniously to provide a voice for consumers and users of this sector.

We welcome the opportunity to comment on Ofcom’s latest Plan of Work. With its current and expanding remit, we agree that Ofcom’s role is an ever-important one and more challenging than ever. Communications services – post, landline, mobile, broadband (and alternative forms of connectivity) and broadcast and on demand content are services that are relied upon by consumers and citizens and these services must now be as reliable and affordable as the water that comes of a tap, particularly during a cost-of-living crisis.

We welcome Ofcom’s review of Net Neutrality and its latest proposals to safeguard citizens’ and consumers’ access to the open internet, the open internet as an engine of innovation and well-run, robust and efficient networks.

Our interest in safeguarding citizens and consumers is clear from our remit; we also believe that innovation is key to meeting the changing demands of consumers and citizens and well-run, robust, efficient networks are a current – and will be an ongoing – need of consumers and citizens.