After over 17 months of delays, Ofcom’s new One Touch Switching (OTS) process for fixed line phone and broadband ISPs, which makes it quicker and easier for consumers to switch between providers on physically separate networks (e.g. Openreach to CityFibre or Virgin Media etc.), is today finally going LIVE. But don’t be surprised if your switch doesn’t use it, yet.
Migrating between UK ISPs on Openreach’s (BT) network is currently a fairly easy and largely automated Gaining Provider Led (GPL) process (i.e. just contact your new ISP, and they’ll do the rest). But it’s a different story if you need to change between internet service providers on physically separate networks, which have become increasingly common (Summary of UK Full Fibre Builds).
Customers who want to switch between such separate networks often have to take the manual cancellation route (i.e. order the new service and then contact your old ISP to cancel), which can result in longer periods of downtime (perfect coordination is difficult) and greater uncertainty for consumers. Some people may also end up paying for two services at once for a brief period, even if only one is usable.
In response Ofcom ended up developing the new One Touch Switch (OTS) process, which was originally due to be introduced from 3rd April 2023 before it was hit by a long string of delays (here, here, here, here and here). But we’re pleased to say that our focus today isn’t on the regulatory and industry failings, which were the cause of all those woes. Instead, we can finally focus on OTS itself and what it means for consumers.
How Does One Touch Switch (OTS) Work?
The new process works in a roughly similar way to the previous GPL process, but it now includes other networks, is being centrally managed by the industry-led One Touch Switching Company (TOTSCo) and should be faster. For example, Ofcom states that any “loss of service” that might occur during a switch must NOT be allowed to exceed 1 working day (“if technically possible“) and providers will be expected to compensate customers if things go wrong.
The OTS process starts when a customer contacts their chosen (new / gaining) ISP to begin a switch, such as by requesting one of their broadband services (i.e. there is no need to contact your existing ISP). After that both providers will automatically send you important information about the process (e.g. cancellation charges, new package details etc.) and inform you of the final switching date.
The losing provider will be required to continue to supply the end-user on the same terms, until the new service is activated by the gaining provider, and to automatically terminate the end-user’s contract(s) upon conclusion of the switching process. The losing ISP will also be required to reactivate the phone number and all related services where a switching process fails, and until the port is successful.
In terms of phone number porting, Ofcom previously said they will be making some “limited” changes, which includes giving customers the “right to port their number for one month after they have terminated their contract and a prohibition on charging customers to port their number.” At present, it can still be quite difficult to get your number back if it’s lost during a switch, so this will help to tackle that.
However, the OTS process does not currently specify porting arrangements, although the regulator has previously said they do expect “further development in relation to number porting” and that “there may be a need for the Hub to include a communications channel” to help facilitate all of this. In any case, providers will need to comply with all of these new rules.
Finally, Ofcom has also banned notice period charges beyond the switch date for residential customers, which should hopefully prevent situations where a customer ends up having to pay for two services at the same time. A detailed summary of how all of this will work can be found below.
Detailed Summary – One Touch Switching
Step 1: Customer Contacts the gaining provider and provides details
➤ The customer contacts their chosen gaining provider (in store, online or by phone) and requests to switch their services.
➤ The customer shares their:
– name;
– address and postcode;
– contact details;
– losing provider’s name; and
– the services they want to switch.
➤ The customer chooses the new services, confirms if they want to keep their phone number and agrees a switch date (this can be as soon as the next day, but can take longer). The gaining provider confirms whether any engineer visits are necessary.
➤ The gaining provider identifies the correct customer and services to switch.36 If this is unsuccessful (i.e. there is no match against the losing provider’s records), the gaining provider asks the customer for more details (e.g. account number, phone number or serial number on their equipment).
Step 2: Losing provider automatically gives customer switching information and customer gives the gaining provider their consent to the switch
➤ The losing provider automatically gives the customer switching information (e.g. early termination charges, impact on other services) without the need for the customer to request it. The
information is provided by the method and to the contact details the customer chooses e.g. as part of the gaining provider’s online order process (downloadable afterwards), email, text or letter.
➤ The gaining provider gives the customer information about their new contract.
➤ After having the opportunity to consider the information, if the customer is happy to proceed, they give the gaining provider their consent to switch (who retains a record of consent). This can happen in real time during their phone or online conversation.
➤ The gaining provider confirms the start date and the services being provided.
Step 3: Customer’s new services begin on agreed date
➤ On the agreed date the new services will start and the old services will end. If requested, the customer’s phone number is transferred.
➤ The customer does not have to pay any notice period charges beyond the switch date.
The new system marks a significant change, particularly for the new generation of alternative network providers. Many of them won’t have had to deal with too many complicated consumer regulatory measures before, and it will probably take even more time before every ISP is fully up to speed on its implementation.
In terms of cost, Ofcom originally said the impact of this new system across the retail telephone and broadband market, in aggregate, would be equivalent to £0.03 per month per customer or less, which they said is “very small when compared to the typical bill for landline and broadband services of a UK household (c.£41 per month).” But that was back in 2021 and the figure today may well be higher.
Potential Caveats
Sadly, the new process is only a requirement for residential customers, which Ofcom states is because “business and residential customers can sometimes have different needs when switching and that there is diversity among business which means it may not be appropriate to specify certain rules that would apply to all business customers in the same way as to residential customers.” But businesses are still required to follow most of the same rules (i.e. Ofcom simply have not specified what the process should be for business ISPs) and so, in practice, many of those services will end up using OTS too.
On top of that, there are concerns (example) that the new process may not provide enough protection against SLAMMING (i.e. when your broadband and phone service is switched without your consent), which was a minor issue with the old GPL system too. Despite this, Ofcom has previously claimed that the “customer should … have enough time to take action and stop [a wrongful] switch” via OTS.
However, under the old system, it tended to take around a week or more to migrate between providers on the same Openreach based network, which allowed time for both providers to issue notices to customers and also afforded customers the ability to request that the switch be stopped. But that’s much harder to achieve via a rapid one-day switching process and, under OTS, a customer can no longer request that the switch be stopped.
Ofcom claims that the new OTS approach is designed to “safeguard against slamming“. Such safeguards include the requirement for the gaining ISP to take all reasonable steps to ensure that it does not switch customers without their consent, and in particular, that it does not engage in slamming, and that any customer who is requesting a switch is authorised to do so.
In addition, in OTS, the losing provider will be required to inform the customer of the identity of the gaining provider, which the regulator claims “should act as an additional safeguard against slamming.” But plenty of ISPs we’ve spoken to remain concerned that OTS could still make SLAMMING harder, not easier, to tackle and prevent. Time will tell.
Separately, Ofcom will also improve the information that providers must give to customers who are considering switching their mobile service. Your existing operator will now need to tell you about the impact of the switch on other services you have with the operator (e.g. any bundled services or specific services for disabled customers), which should help consumers to better understand the implications of switching.
A Bumpy Launch
However, the feedback from ISPs suggests that TOTSCo’s messaging platform for OTS is still a bit on the buggy side and needs more testing, which means that teething issues are expected during the early launch phase. Quite how much of an impact this will have remains unclear and experiences may vary between ISPs, but if you were planning to switch this month then Ofcom’s previous announcement may give some pause (here).
According to the aforementioned announcement, the testing of TOTSCo’s messaging platform still needs a bit more time to “ensure the matching process achieves a sufficiently high success rate to effectively support all customer switching journeys“.
In response, Ofcom has ordered ISPs to retain the old migration process for an additional six weeks: “This would enable customers to be switched using the [existing process] as a back-up option, and only in those circumstances where communications providers, having started the switching process via OTS, find that it is not possible to technically proceed.”
Suffice to say, consumers (i.e. those trying to switch) and ISPs may find the next few weeks to be a bit of a mess tedious. Prior to publishing this article ISPreview also asked a cross-section of ISPs about their thoughts on OTS / TOTSCo and their own readiness to support it, here’s what they said:
Ryan Battle, Managing Director of YouFibre, said:
“YouFibre has been at the forefront of testing the TOTSCo system, collaborating with various ISPs for weeks. We’re fully prepared for the launch and anticipate that the broader industry will meet the deadline.
The One Touch Switch system represents a significant leap forward for our sector, promising to streamline the customer switching process unprecedentedly. This aligns perfectly with our commitment to customer-centric innovation and service excellence. Our readiness for this transition is underpinned by our commitment to customer satisfaction, reflected in our excellent Trustpilot score. With a strong base of 122,000 satisfied customers, we’re excited to leverage this new system to further expand our reach and deliver our superior service to more UK households.
While we recognize the challenges that led to previous delays, we believe the TOTSCo system is now poised for a successful launch. We’re prepared to embrace this change, seeing it as a catalyst for enhanced consumer choice and market dynamism in the UK broadband landscape.”
Adrian Kennard, MD of A&A (AAISP), said:
“Andrews & Arnold Ltd have been ready for months, and we are extremely confident that we are fully ready. We have been using One Touch Switching live with over a dozen other large CPs for over a week now and *our* systems are working correctly.
I am not allowed to comment on individual CPs on the ramp up, but I am seeing lots of errors of various levels of severity. Even so, I am reasonably confident that at least the major issues will be fixed by these CPs by the launch date. All the CPs involved are working hard on this, but some have very complex and time consuming processes for even small changes, which is understandable.
We then expect lots of CPs to join on the 12th Sep. We don’t even really know how many, it could be hundreds! I have voiced my concerns with the totally inadequate testing systems in place. I even created a free test platform, and over 50 CPs are signed up on it, because TOTSCO have nothing like it. www.notsco.co.uk
How bad it will be on the 12th is something none of use can really know, but I am not hopeful that more than the few large CPs will actually be working correctly. That said, I do know of a lot of small CPs that are doing things right, as I can see from the test platform, so it may be that many work as well, if not better than, the major CPs.
I am also very concerned over slamming, and the removal of the 14 day cooling off period. Really, only time will tell.”
Ben McKee, Systems Programmer for Freeola, said:
“We’re using a MAP provider who have been involved with the development of the hub from an early stage so we’re confident things should work properly … we will be ready for launch day.”
A Vodafone spokesperson said:
“Vodafone is ready for One Touch Switching (OTS) launch day and intends to send all its switching traffic through TOTSCo’s OTS Hub from 12 September 2024. Evidence from our own testing and within the industry suggests that the OTS Hub is functioning as required, delivering the capability to exchange messages between gaining and losing Communication Providers.”
A Spokesperson for Hyperoptic said:
“As a consumer champion, Hyperoptic has been fully supportive of One Touch Switch (OTS) because we believe it offers a significantly improved switching experience. The success of OTS, in ensuring a seamless experience for consumers, requires all ISPs to be diligent in running as many switching scenarios as possible – however, this sentiment isn’t necessarily shared across the board.
The success of any systems-led project is determined by the level of testing across the industry, and the management of issues reported. Robust testing is crucial, and it is clearly apparent from the low number of switches carried out to date (and the number of issues being reported) that there is a varying level of commitment to testing. It is no surprise that larger providers are keen to hold on to their customers, so may be more reluctant to test with other providers.
We know the importance of hyper simple switching, so we have been working hard to ensure that we are ready to launch; we recently completed a switch in less than 30 minutes, so are confident in the success that OTS will achieve. Hyperoptic is fully prepared and ready to support and work with TOTSCo’s new switching system on launch day. We have taken the necessary steps to be prepared and look forward to delivering a seamless experience for our customers.”
Sarah Howells, Managing Director at Cuckoo, said:
“We really hope Ofcom’s backstop measure to One Touch Switching isn’t used by some in the industry to delay full implementation. At Cuckoo, we are ready to go. There were always going to be potential issues – for the customer’s sake, let’s get on with it.
Broadband should be fast, fair, and feel-good, and changing providers should be as simple as flipping a switch. From customer service to contracts to confusing delay clauses on One Touch Switching, customers continue to be kept in the dark while the industry fumbles around.
Delays shatter trust, and with the latest setbacks, we risk annoying already disillusioned customers further. Customers deserve a hassle-free way to switch broadband providers.
We’re ready for One Touch Switch – it’s time for the industry to start putting the customer first.”
Sadly, neither TalkTalk, Sky Broadband nor EE (inc. BT, Plusnet) were able to provide a public comment. But Sky did express broad optimism and expected to be ready, while EE echoed an almost identical sentiment.
By comparison, TalkTalk spoke of the unprecedented technical complexity of the new system and confirmed they’re fully participating in the trials, but they otherwise appear to be working toward delivering OTS as quick as possible for consumers (i.e. we’re unsure whether they’re fully ready and live today).
